NCS000525_COMPLIANCE_20120702

STORMWATER DIVISION CODING SHEET
PERMIT NO.
DOC TYPE
❑FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
COMPLIANCE
OTHER
DOC DATE
Z o-7 OZ
YYYYMMDD

W�s000 52-15
wal lacefarm prod ucts.com
A FAMILY TRADITION SINCE 1863
Committed to Growing a
Greener Environment
RCFO2tV:-:D
DIVISION OF vvA-ER QUALITY
Y
JUL 4 3 2012
SUMP SECT;0N
MOON-ESVILLE REGIONAL OFFICE
July 2, 2012
Robert B. Krebs
Regional Supervisor
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Dear Mr. Krebs:
In response to your letter dated June 21, 2012, please see the enclosed
documents. The following documents have been included:
• Analytical Analysis for storm water samples taken on 6/6/12
• Completed Comprehensive Semi -Annual Site Inspection Report Forms
• SWPPP Amendment Log Documenting Changes Made to SWPPP on
7/2/12
The information found here should bring our facility back into compliance.
Please let me know if you have any questions or need additional
information.
Sincerely yours,
Eric T. Wallace
Vice President
Enclosures

e �
aceAnalXical
wxw.pecelabscom
Project: WFSW
Pace Project No.: 92120314
Pace Analytical Services, Inc.
205 East Meadow Road - Suite A
Eden, NC 27288
[phone]
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
SAMPLE ANALYTE COUNT
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Hunteraville, NC 28078
[phone]
Lab ID Sample 1D Method
Analysts
Analytes
Reported
laboratory
92120314001 WFSW SM 9222D
KDF
1
PASI-C
SM 2540D
LMD
1
PASI-A
SM 5210B
LIVID
1
PASI-A
EPA 9040
AES
1
PASI-A
EPA 351.2
JDA
1
PAS1-A
EPA 353.2
DMN
3
PASI-A
EPA 365.1
JDA
1
PASI-A
SM 5220D
SMW
1
PASI-A
REPORT OF LABORATORY ANALYSIS Page 3 of 15
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..

aceAnalytical
wwwpacelabscom
Project: WFSW
Pace Project No.: 92120314
Pace Analytical Services, Inc.
205 East Meadow Road - Suite A
Eden, NC 27288
[phone]
Pace Analytical Services, inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave, Suite 100
Huntersville, NC 28078
[phone]
Sample: WFSW
Lab ID: 92120314001 Collected: 06106112 10:00
Received: 06/06/12 13:30 Matrix: Water
Parameters
Results Units
Report Limit
DF
Prepared Analyzed CAS No. Qual
MBIO 9222D Fecal Coliform CHT
Analytical Method: SM 92220
Fecal Coliforms
2400 CFU/100 mL
1.0
1
06/06/12 14:01 N2
2640D Total Suspended Solids
Analytical Method: SM 25400
i
Total Suspended Solids
141 mg/L
163
1
- 06/08/12 20:32
6210E BOD, 5 day
Analytical Method:.SM 5210B
BOD, 5 day
11.7 mg1L
2.0
1
06/07/12 20:57 06/12/12 16:45
9040 pH
Analytical Method: EPA9040
pH
7.4 Std. Units
0.10
1
06/09/12 17:39 H6
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
4.3 mg/L
0.50
1
06/19/12 15:44 7727-37-9
353.2 Nitrogen, N021NO3 unpres
Analytical Method: EPA353.2
Nitrogen, Nitrate
0.31 mg/L
0.020
1
06/07/12 00:53
Nitrogen, Nitrite
0.12 mg/L
0.020
1
06/07/12 00:53
Nitrogen, NO2-plus NO3
0.43 mg/L
0,020
1
06107/12 00:53
366.1 Phosphorus, Total
Analytical Method: EPA 365.1
Phosphorus
0.88 mglL
0.050
1
06/15/12 09:20 7723-14-0
5220D COD
Analytical Method: SM 5220D
Chemical Oxygen Demand
114 mg1L
25.0
1
06/15/12 10:30
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 4 of 15
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc-

aceAnalytical
wwwpecelabs,com
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
205 East Meadow Road - Suite A 2225 Riverside Dr.
Eden, NC 27288 Asheville, NC 28804
[phone] [phone]
QUALITY CONTROL DATA
Project: WFSW
Pace Project No.: 92120314
OC Batch: MBCH/4182 Analysis Method: SM 9222D
QC Batch Method: SM 9222D Analysis Description: 9222D MBIO Fecal Coliform - CHT
Associated Lab Samples: 92120314001
METHOD BLANK: 775067
Associated Lab Samples: 92120314001
Parameter Units
Fecal Coliforms CFU/100 mL
SAMPLE DUPLICATE: 775068
Parameter Units
Fecal Coliforms CFU1100 mL
Matrix; Water
Blank Reporting
Result Limit Analyzed `tQualifiers
ND 1.0 06/06/1214:01 N2
92120314001 Dup
Result Result
2400 600
RPD Qualifiers
120 N2,u2
Pace Analytical Services, Inc.
9600 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
4
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 5 of 15
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without the written consent of Pace Analytical Services, Inc..

aceAnalyiical
www.oacabbs.com
Project: WFSW
Pace Project No.: 92120314
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
205 East Meadow Road - Suite A 2225 Riverside Dr.
Eden, NC 27288 Asheville, NC 28804
[phone] [phone]
QC Batch: WET121155
QC Batch Method: SM 2540D
Associated Lab Samples: 92120314001
METHOD BLANK: 776303
Associated Lab Samples: 92120314001
Parameter
Units
Total Suspended Solids
mglL
LABORATORY CONTROL SAMPLE:
776304
Parameter
Units
Total Suspended Solids
mglL
SAMPLE DUPLICATE: 776305
Parameter
Units
Total Suspended Solids
mg1L
QUALITY CONTROL DATA
Analysis Method: SM 2540D
Analysis Description: 2540D Total Suspended Solids
Matrix: Water
Blank Reporting
Result Limit Analyzed Qualifiers
NO 2.5 06/08/12 20:27
Pace Analytical Services, Inc.
9B00 Kincey Ave, 'Suite 100
Huntersville, NC 28078
[phone]
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualifiers
250 246 98 80-120
92120632001 Dup
Result Result RPD Qualifiers
10 9.8 2
SAMPLE DUPLICATE: 776306
92120299001 Dup
Parameter Units Result Result RPD Qualifiers
Total Suspended Solids mg1L NO NO
9
Dale: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 6 of 15
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without the written consent of Pace Analytical Services, Inc..

aceAnaIXical
w M..pacelabs.com
Project: WFSW
Pace Project No,: 92120314
Pace Analytical Services, Inc.
205 East Meadow Road - Suite A
Eden, NC 27288
[phone]
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
QC Batch: WET121133 Analysis Method: SM 521 OB
QC Batch Method: SM 5210B Analysis Description: 5210B BOD, 5 day
Associated Lab Samples: 92120314001
METHOD BLANK: 775200 Matrix: Water
Associated Lab Samples: 92120314001
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
BOD, 5 day mgJL ND 2.0 06/12/12 16:46
LABORATORY CONTROL SAMPLE: 775201
Parameter Units
BOD, 5 day mg1L
SAMPLE DUPLICATE: 775202
Parameter Units
BOD, 5 day mg/L
Pace Analytical Services, Inc.
9800 Kincey Ave. Suits 100
Huntersville, NC 28076
[phone]
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualifiers
198 172 87 84-115
92120548001 Dup
Result Result RPD Qualifiers
40.4 40.4 0
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 7 of 15
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without the written consent of Pace Analytical Services, Inc..

Pace
lc Pace Analytical
Pace
Analytical Services, Inc.
✓eAalytcal 205East Meadow RodSute A 225 Riverside Dr9800 KneyAve, Suite 1o0a
wwwpacar'ab1com Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA
Project: WFSW
Pace Project No,: 92120314
QC Batch: WET121163 Analysis Method: EPA 9040
OC Batch Method: EPA 9040 Analysis Description: 9040 pH
Associated Lab Samples: 92120314001
SAMPLE DUPLICATE: 776431
92120611011 Dup
Parameter Units Result Result RPD Qualifiers
pH Sid. Units 7.3 7.5 2 H6
SAMPLE DUPLICATE: 776432
92120540001 Dup
Parameter Units Result Result RPD Qualifiers
pH Sid. Units 6.8 7.0 4 H6
t
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 8 of 15
This report shall not be reproduced, except In full,
without the written consent of Pace Analytical Services, Inc..

aceAnalytical'
www.pacejabs.com
Project: WFSW
Pace Project No.: 92120314
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
205 East Meadow Road - Suite A 2225 Riverside Dr.
Eden, NC 27288 Asheville, NC 28804
[phone] [phone]
QUALITY CONTROL DATA
QC Batch: WETA112356 Analysis Method: EPA 351.2
QC Batch Method: EPA 351.2 Analysis Description: 351.2 TKN
Associated Lab Samples: 92120314001
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
METHOD BLANK: 779659
Matrix: Water
Associated Lab Samples: 92120314001
Blank
Reporting
Parameter
Units
Result
Limit
Analyzed
Qualifiers
Nitrogen, Kjeldahl, Total
mglL
ND
0.50
06/1911215:48
LABORATORY CONTROL SAMPLE:
779660
Spike LCS
LCS %
Rec
Parameter
Units
Conc. Result
% Rec Limits
Qualifiers
Nitrogen, Kjeldahl, Total
mglL
10
9.6
96
90-110
MATRIX SPIKE SAMPLE:
779661
92121025002
Spike
MS
MS
% Rec
Parameter
Units
Result
Conc.
Result
% Rec
Limits Qualifiers
Nitrogen, Kjeldahl, Total
mg1L
1580
10
3010
14283
90-110 M6
(MATRIX SPIKE SAMPLE:
779663
92120445002
Spike
MS
MS
% Rec
Parameter
Units
Result
Cane.
Result
% Rec
Limits Qualifiers
Nitrogen, Kjeldahl, Total
mg1L
1.1
10
12.5
114
90-110 M1
SAMPLE DUPLICATE: 779662
92121025003
Dup
Parameter
Units
Result
Result
RPD
Qualifiers
Nitrogen, Kjeldahl, Total
mg1L
1290
1300
0
SAMPLE DUPLICATE: 779664
92120873001
Dup
Parameter
Units
Result
Result
RPD
Qualifiers
Nitrogen, Kjeldahl, Total
mg1L
1,1
1.1
4
.
r
.
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 9 of 15
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..

aceAnalytical
wawpaceiahs.com
Project: WFSW
Pace Project No.: 92120314
Pace Analytical Services, Inc.
205 East Meadow Road - Suite A
Eden. NC 27288
[phone]
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
(82B)254-7176
QUALITY CONTROL DATA
QC Balch: WETA/12271 Analysis Method: EPA 353.2
QC Batch Method: EPA 353.2 Analysis Description: 353.2 Nitrate + Nitrite, Unpres.
Associated Lab Samples: • 92120314001
METHOD BLANK: 774461 Matrix: Water
Associated Lab Samples: 92120314001
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Nitrogen, Nitrate mg1L ND 0.020 06/07/12 00:19
Nitrogen, Nitrite mglL ND 0,020 06/07/12 00:19
Nitrogen, NO2 plus NO3 mg/L ND 0.020 06107112 00:19
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
LABORATORY CONTROL SAMPLE:
774462
Spike
LCS LCS % Rec
Parameter
Units
Conc.
Result % Rec Limits Qualifiers
Nitrogen, Nitrate
mglL
2.5
2.5 101 90-110
Nitrogen, Nitrite
mglL
1
1.0 100 90-110
Nitrogen, NO2 plus NO3
mglL
2.5
2.5 101 90-110
MATRIX SPIKE.SAMPLE:
774463
i
92120312002
Spike
MS
MS
% Rec
Parameter
Units
Result
Conc.
Result
% Rec
Limits Qualifiers
Nitrogen, Nitrate
mg1L
ND
2.5
2.3
93
90-110
Nitrogen, Nitrite
mg1L
ND
1
1.0
100
90-110
Nitrogen, NO2 plus NO3.
mg1L
ND
2.5
2.3
93
90-110
MATRIX SPIKE SAMPLE:
774465
92120312003
Spike
MS
MS
% Rec
Parameter •
Units
Result
Cone,
Resutt-'
% Rec
Limits Qualifiers
Nitrogen, Nitrate
mg1L
0,15
2.5
2.5
95
90-110
Nitrogen, Nitrite
mg1L
ND
1
1.0
103
90-110
Nitrogen, NO2 plus NO3
mg1L
0.15
2.5
2.5
95
90-110
SAMPLE DUPLICATE: 774464
92120312002
Dup
Parameter
Units
Result
Result
RPD
Qualifiers
Nitrogen, Nitrate
mg1L
ND
ND
i
Nitrogen, Nitrite
mglL
ND
ND
Nitrogen, NO2 plus NO3
mg/L
ND
ND
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 10 of 15
This report shall not be reproduced, except in full,
without the written consent of pace Analytical Services, Inc..

aceAnalytical
"-Pacelebs —
Project: WFSW
Pace Project No.: 92120314
Pace Analytical Services, Inc.
205 East Meadow Road - Suite A
Eden, NC 27288
[phone]
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
SAMPLE DUPLICATE: 774466
92120312003 Dup
Parameter Units Result Result RPD Qualifiers
Nitrogen, Nilrale mg1L 0.15 0.15 0
Nitrogen, Nitrite mg/L ND ND
Nitrogen, NO2 plus NO3 mg1L 0.15 0.15 0
Pace Analytical Services, Inc.
9809 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 11 of 15
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without the written consent of Pace Analytical Services, Inc..

aceAnaljftal
www.Paeeletxeom
Project: WFSW
Pace Project No.: 92120314
Pace Analytical Services, Inc.
205 East Meadow Road - Suite A
Eden, NC 27288
(336)623-B921
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
(704)875-9o92
QC Batch: WETA112322
Analysis Method:
EPA 365.1
QC Batch Method: EPA 365.1
Analysis Description:
365.1 Phosphorus, Total
Associated Lab Samples: 92120314001
METHOD BLANK: 777479
Matrix: Water
Associated Lab Samples: 92120314001
Blank Reporting
Parameter
Units
Result Limit
Analyzed
Qualifiers
Phosphorus
mg/L
ND 0,050 06/15/12 09:12
LABORATORY CONTROL SAMPLE:
777480
Spike LCS
LCS
% Rec
Parameter
Units
Cone, Result
% Rec
Limits Qualifiers
Phosphorus
mg/L
2.5 2.6
104
90-110
MATRIX SPIKE SAMPLE:
777481
92120463005 Spike
MS
MS
% Rec
Parameter
Units
Result Cone.
Result
% Rec
Limits Qualifiers
Phosphorus
mg/L
3.0 2.5
5.9
114
90-110 M1
MATRIX SPIKE SAMPLE:
777483
92120207001 Spike
MS
MS
% Rec
Parameter
Units
Result Cone.
Result
% Rec
Limits Qualifiers
Phosphorus
mg1L
1.1 2.5
3.6
101
90-110
SAMPLE DUPLICATE: 777484
92120209001 Dup
Parameter Units Result Result RPD Qualifiers
Phosphorus mg/L 0.70 0.69 1
SAMPLE DUPLICATE: 777582
92120127002 Dup
Parameter Units Result Result RPD
Phosphorus mg/L 1.4 1.4 1
r
Qualifiers
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 12 of 15
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
1

aceAnalytical.
wNw,paceleDs.com
Project: WFSW
Pace Project No.: 92120314
Pace Analytical Servfcea, Inc.
205 East Meadow Road - Suite A
Eden, NC 27288
[phone]
Pace AnalyticaI Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
QC Batch: WETAM2350 Analysis Method: SM 5220D
QC Batch Method: SM 5220D Analysis Description: 5220D COD
Associated Lab Samples: 92120314001
METHOD BLANK: 779546 Matrix: Water
Associated Lab Samples: 92120314001
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Chemical Oxygen Demand mg1L ND 25.0 06/15/12 10:30
LABORATORY CONTROL SAMPLE: 779547
Parameter Units
Chemical Oxygen Demand mglt_
Pace Analytical Services, Inc.
9800 Kincey Ave, Suite 100
Huntersville, NC 28078
[phone]
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualifiers
750 756 101 90-110
MATRIX SPIKE SAMPLE:
779553
92121025003
Spike
MS
MS
% Rec
Parameter
Units
Result
Conc.
Result
% Rec
Limits Qualifiers
Chemical Oxygen Demand
mg1L
49.0
750
880
111
75-125
MATRIX SPIKE SAMPLE:
779555
92120287001
Spike
MS
MS
% Rec
Parameter
Units
Result
Conc.
Result
% Rec
Limits Qualifiers
Chemical Oxygen Demand
mg/L
908
750
1490
77
75-125
SAMPLE DUPLICATE: 779552
92121025002 pup
Parameter Units Result Result RPD Qualifiers
Chemical Oxygen Demand mg1L 41400 31000 29 06
SAMPLE DUPLICATE: 779554
92120263001 Dup
Parameter Units Result Result RPD Qualifiers
Chemical Oxygen Demand mg1L 449 438 2
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 13 of 15
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without the written consent of Pace Analytical Services, Inc..

aceAnalytical.
WWW-pacelebs cam
Project: WFSW
Pace Project No.: 92120314
DEFINITIONS
Paco Analytical Services, Inc.
205 East Meadow Road - Suite A
Eden, NC 27288
[phone]
QUALIFIERS
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Pace Analytical Services, Inc.
9800 KincayAve. Suite 100
Huntersville, NC 28078
(704)8759092
OF - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of
the sample aliquot, or moisture content
NO - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit,
MDL-Adjusted Method Detection Limit.
PRL - Pace Reporting Limit. `
RL - Reporting Limit.
S - Surrogate
1,2-Diphenylhydrazine (8270 listed analyte) decomposes to Azabenzene.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Acid preservation may not be appropriate for 2-Chioroethylvinyl ether, Styrene, and Vinyl chloride.
r
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI - The NELAC Institute.
LABORATORIES
PAST -A Pace Analytical Services - Asheville
PASI-C Pace Analytical Services - Charlotte
ANALYTE QUALIFIERS
D6 The relative percent difference (RPD) between the sample and sample duplicate exceeded laboratory control limits.
H6 Analysis initiated outside of the 15 minute EPA recommended holding time.
M1 Matrix spike recovery exceeded QC limits. Batch accepted based on laboratory control sample (LCS) recovery.
MG Matrix spike and Matrix spike duplicate recovery not evaluated against control limits due to sample dilution.
N2 The lab does not hold TNI accreditation for this parameter.
u2 Colonies are too numerous to count. Actual result may be greater than reported.
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 14 of 15
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without the written consent of Pace Analytical Services, Inc..

Pace Analytical Services, Inc. Pace Analytical Services, Inc. Pace Analytical Services, Inc.
aceAnalytical 205 East Meadow Road - Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.pacofaba.cam Eden, NC 27280 Asheville, NC 28804 Huntersville, NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project: WFSW
Pace Project No.: 92120314
Analytical
Lab ID
Sample ID
QC Batch Method
QC Batch Analytical Method Batch
92120314001 -
WFSW
SM 9222D
MBCH14182
92120314001
WFSW
SM 2540D
WET/21155
92120314001
WFSW
SM 5210B
WET/21133 SM 5210B WET121134
92120314001
WFSW
EPA 9040
WET/21163
92120314001
WFSW
EPA 351.2
WETA112356
92120314001
WFSW
EPA 353.2
WETA112271
92120314001
WFSW
EPA 365.1
WETA112322
92120314001
WFSW
SM 5220D
WETA/12350
Date: 06/20/2012 06:28 PM REPORT OF LABORATORY ANALYSIS Page 15 of 15
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without the written consent of Pace Analytical Services, Inc..

Wallace Farm, Inc.
Stormwater Industrial Routine Facility Inspection Report
e oram n 1 ti f
Facility Naive
a
Permit Number
'
Date of Inspection
i0
,ZX
Start/End Time
Inspector's Name(s)
C a
.Inspector's Title(s)
Inspector's Contact Information
�
G u A L
aim
Inspector's Qualifications
Weather at tim of this ins ection?
❑ Clear I17CIoudy �ain ❑ Sleet ❑ Fog ❑ Snow ❑ High Winds
❑ Other: Temperature: g 2a
Have any previously unidentified discharges of pollutants occurred since the last inspection? ❑Yes eo
If yes, describe:
ArA there any discharges occurring at the time of inspection? es ❑No
If yes, describe: ��� WoLt e—C ►���1A f Q,
Control Measures
• • Number the structural stormwater control measures identified in your SWPPP on your site map and list them .
below (add as many control measures as are implemented on -site). Carry a copy of the numbered site map with
you during your inspections. This list will ensure that you are inspecting all required control measures at your
facility.
• Describe corrective actions inilpted, date completed, and note the person that completed the work in the
[7
Corrective .fiction Lo
?s
s.
1
Coverings for
❑Yes ❑No
❑ Maintenance
❑ Repair
V.. � C. m ' X . 4 N
Product Mix Area
N',N
❑ Replacement
2
St&rnwater
9yes ❑No
❑ Maintenance
Retention Pond and
❑ Repair
Basins
❑ Replacement
3
Berm around F= a
Yes ❑No
❑ Maintenance
Tank
❑ Repair
❑ Replacement
4
❑Yes ❑No
❑ Maintenance
❑ Repair -
❑ Replacement
5
❑Yes ❑No
❑ Maintenance
❑ Repair
❑ Replacement
6
❑Yes ❑No
❑ Maintenance
❑ Repair
❑ Replacement
7
❑Yes ❑No
❑ Maintenance
❑ Repair
❑ Replacement
Documentation for SWPPP ,�

•
•
Areas of Industrial Materials or Activities exposed to stormwater
Below are some general areas that should be assessed during routine inspections, as appropriate. Customize this
list as needed for the specific types of industrial materials or activities at your facility.
1
Material
JdYes ❑No ❑ NIA '
®Yes ❑No
loading/unloading and
I
storage areas
2
Equipment operations
EfYes ❑No © NIA
ZYes 1JNo
and maintenance areas
3
.Fueling areas
Wes ©No ❑ NIA
Wf es ❑No
4
Outdoor vehicle and.
❑Yes ONo IA
❑Yes ❑No
equipment washing areas
5
Waste handling and
vYes ❑No /A
❑Yes ❑No
disposal areas
oe
6
Erodible
❑Yes ❑No NIA
❑Yes ❑No
areas/construction
7
Non-stormwater/ illicit
❑Yes ❑No NIA
❑Yes ❑No
connections
8
NIA
❑Yes ONo ❑ N/A
❑Yes ❑No
9
Dust generation and
es ONo ❑ N/A
1res ©No
vehicle tracking
10
(Other)
©Yes QNo ❑ NIA
❑Yes ❑No.
11
(Other)
C]Yes ❑No 0 NIA
❑Yes ❑No
12'
(Other)
❑Yes ❑No ❑ N/A
❑Yes ONo
Documentation for 5WPPP
7

Ah
Wallace Farm, Inc.
Additional Control Measures
Describe any additional control measures needed to comply with the permit requirements:
. a
Use this space for any additional notes or observations from the inspection:
CERTIFICATION STATEMENT
"I certify under penalty of law that this document and all attachments (including forms in Section DI) were
prepared under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gathered and evaluated 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, I am aware that
. there are significant penalties for submitting false information, including the possibility of fine and imprisonment
for knowing violations." , i
Print name and title: �, G wa l ``Ct 1.c --_-- V ,-,:.t- 2r es e n:�
Signature. f3.� -�- Vt! _ Date:
Documentation for SWPPP g

•
•
WaIlaca Farm, Inc.
Stormwater Operation, Maintenance, and Management Inspection
Locationi ProductMix Area; and Stormwater. Swale and Retention Ponds
jA PfojuJs be;n m.Xl:l un�zc. Poo
j
Maintenance -Item
Product Mix Area
Cover All Exposed Compost and Products with Tarp Prior to Storms
and
Inspection of Area
Date
Rainfall, in
Inspector, initials
Comments
•
'a
Documentation for SWPPP p

Wallace Faun, Inc.
DStormwater Operation, Maintenance, and Management Inspection
Checklist
Location: Stormwater Swale and Retention Pond and Stormwater Ponds
r
Date: b b 12
Inspector: car'; JJa f-P.
•
Maintenance Item Satisfactory/ Comments
Unsatisfactory
A. Side Slopes
(Inspect after major storms"and annually)
1. • y¢�i rYa��'Y E^,h7..�n`�vS�tii-A per: ��" nit,vtjMitisi:..
a.
Adequate •
i
•. uniesirable•' •
3. Animal burrows
i
Unauthorized planting
5. Cracking, bulging, yEndE �,%*�i �„�`� �},'L� �"u'rA4�'��,2 �gc4�
• of sideslopes Wr ty�'3 i1 �1�`', �% ti4� Y a "�
�Sr u �i
p ikryij�Si.Z"��ja�� .�
' �
r downstream slopes
6. Slope protection or riprap failure
7. Other (specify)
z
Additional Comments:
Actions to be Taken: bac'. below
� 5�� c�C ;r, G►r2c�
more r,� sap ,'(� Lo PTC d►id)-OV (Arta
Documentation for SWPPP

� y
Wallace Farm, Inc.
•
•
•
Quarterly Visual Assessment Form (During Sampling)
Name of Facility: Wallace Farm Permit No. N G !; 000.52-S
Outfall Name: SW1. "Substantially Identical Outfair? ❑ No ❑ Yes (identify substantially identical outfalls):
r
Person(s)/Title(s) collecting sample: Person(s)/Title(s) examining sample: '
Date & Time Discharge Began: Date & Time Sample Collected: Date & Time Sample
G161I,2 -z- /-a ctrn 6/6//4-L !0 c,m Examined: 4/qI01
t 0 a -n
Substitute Sample? ❑ No ❑ Yes (identify quarter/year when sample was originally scheduled to be collected):.
Nature of Discharge: ainfall • ❑ Snowmelt
If rainfall: Rainfall Previous Storm Ended > 72 hours A -Yes❑ No* (explain):
Amount: I.5 inches Before Start of This Storm?
Parameter
Color j] None Q15her (describe): ✓erg
Odor one ❑ Musty ❑ .Sewage ❑ Sulfur ❑ Sour ❑ Petroleum/Gas
' ❑ Solvents ❑ Other (describe):
Clarity ❑ Clear ightly Cloudy ❑ Cloudy ❑ Opaque ❑ Other
Floating Solids 13N6 El Yes (describe):
Settled Solids** Q No Yes (describe):
Suspended Solids " la 0 Yes (describe):
Foam (gently shake sample) ,0No. ❑ Yes (describe):
Oil Sheen None ❑ Flecks . ❑ Globs ❑ Sheen ❑ Slick
❑ Other (describe):
Other Obvious, Indicators No ElYes (describe):
of Stormwater Pollution
'The 72-hour interval can be waived when the previous storm did not yield a measurable discharge or if you are able to document (attach
applicable documentation) that less than i 72-hour interval is.representailve of local storm events during the sarripling period.
" Observe for settled solids after allowing the sample to sit for approximately one-half hour.
Detail any concerns, additional comments, descriptions of pictures taken, and any corrective actions taken below
(attach additional sheets as necessary).
Certification by Facility Responsible Official (Refer to MSGP Subpart 11 Appendix B for Signatory Requirements)
1 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 property gathered and evaluated 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 hest of my knowledge 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,
A. Name: 15 r i C wu I iIr,�Le., B. Title: V.
C. Signature:
D. Date Signed: CA112.
Documentation for SWPPP
Vml3

,'Wallace Farm, Inc.
•
0
•
Wallace Farm, Inc.
Huntersville, NC. Semi -Annual Inspection Form
Wallace Farm, Inc.
Comprehensive Evaluation Form
A. GENERAL INFORMATION
1. Fadllty Name:
3• Facility Physical Address:
1'4 41 a
a. Street
b• City:.
un (ssv, l�
c. State:
C.
d. Zi Code: 7
o'
4. Lead Inspectors Name:
q I f G>< Le.
Title: ,
Tide:
Additional Inspectors Name(s): .
Title:
S. Contact Person: � . l -� � � �• J � 1 � Q `L
Ti
Phone:
EA
E-mall:
6. inspection Date: ^^��
B. GENERAL INSPECTION FINDINGS 'a
1. As part of Skcmvrphensive site inspection, did you inspect all potential pollutant sources, including areas where industrial activity may be exposed to
stormwaler?l YES AO
If NO, descriWw-hx not
N0TE., Complete Section C of this form for each industrial activity area inspected and Included in your SWPPP or as newly identified in 82 or B.3 below where
pollutants may be exposed to stormwater.
2. Did this Ins 'on idenll any stormwater or non-slotmvaler outfalls not previousIdentified in your SWPPP? YES N
If YES, for each location, describe the sources of those stormwater and non-stommater discharges and any associated control measures in lace:
0e+
15

Wallace`Farm, Inc,
0
•
3. Did this Inspection Identity any sources of stormwater or non-stormwater discharges not prevIoUSITIdenfified in your SWPPP? YES
If YES, describe these sources of stormwater or non-stormwater pollutants expected to be present in these discharges, and any control measures in place:
4. Did you review stormwater rrionitorl2a data as partof this Inspection to Identify potential pollutant hot s Is? E NO NA, no mnibring perfonned
If YES, summarize the findings of that review and describe any additional inspection activities resulting from this review:
W; 11 czkesk So; �e�.al and T ;n J..1.!G �a.
ask ; r1 �art+.'n3 w�.�<f" SFr"rn ctd, a cr4
5�.�, c�;�►"s�;,n r;�; CBc.a` CGl:
a+rc,.r►A- P-Lrk� Frain ,k r,"6 J -on .
5. Describe any evidence of pollutants entering the drainage system or discharging to surface waters, and the condition of and around outralls, Including flow
dissipation measures to prevent scouring:
Sys}e,7n oC oM;schur�;r� 4o Fetc wa�Ct'S
R
-t� WA ~add;�:,�,�� fi.� sip , 40
6. Have you taken or do you plan to take any corrective actions, as specified In Part 3 of the permit, since your last annual report submission (or since you
received authorization to discharge under this permit If this is your first annual report), including any corrective actions identified as a result of this annual
Srehensive'site Inspection?
NO
wu�ec Jta;na 0-Nfn �OP Sc; j df y,`nd. area
1k u f { cl
uS I of 40 dry IT Scs; l
1f YES, how many coridditions requiring review for correction action as specified in Parts 3.11 and 3.2 were addressed by these corrective
actions?
NOTE. Complete a atteched Corrective Action Form (Section D) for each condition identified, including any conditions identified as a result of this
comprehensive stormwater inspection.
16

Wallace Farm, Inc. `
•
•
0
C. INDUSTRIAL. ACTIVITY AREA SPECIFIC FINDINGS
'Complete one block for each Industrial activity area where pollutants maybe exposed to stormwater. Copy this page for additional industrial activity
areas.
In reviewing each area, you should consider.
Industrial materials, residue, or trash that may have or could come into contact with slomrxater,
Leaks or spills from industrial equipment, drums, tanks, and other containers;
Mite tracking of industrial or waste materials from areas of no exposure to exposed areas; and
Tracking or blowing of raw, final, or waste materials from areas of no exposure to exposed areas.
INDUSTRIAL ACTIVITY AREA
1, Brief Description:
ipoxk:n� aCttk
[�6AN
2. Ara any control measures in need of maintenance or repair.? YES
3. Have any control measures failed and require re lacement? YE
4. Are any addlGonaVrevised control measures necessary in this area? YE N
If YES to any of these three questions, provide a description of the problem: (Any necessary corrective actions should be described on the attached Corrective
Action Farm) .
INDUSTRIAL ACTIVITY AREA
1. Brief Description: e
�allck S�o.ct�tz a��a � o��;�e t✓c��a
2. Are any control measures in need of maintenance or reir? YES
3. Have an control measures failed and require re lacement? YE N
4. Are any additionallrevised c necessa In this area? YE O
If YES to any of these three questions, provide a description MR problem: (Any necessary corrective actions should be described on the attached Corrective
Action Form)
INDUSTRIAL ACTIVITY AREA
Brief Description:
2. Are any control measures in need of maintenance or repair? YES NO
17

_..._., Wallace Farm, Inc.
•
•
�J
3. Have any control measures failed and require replacement? YES NO
4. Areany additionallrevised 8MPs necessary in this area? YES NO
If YES to any of these three questions, provide a description of the problem: (Any necessary corrective actions should be described on the attached Corrective
Action Form)
NOTE: Copy this page and aftach additional pages as necessary
INDUSTRIAL ACTIVITY AREA '
1. Brief Description:
2. Are =y control measures In need of maintenance or re ir? YES NO
3. Have an control measures failed and require replacement? YES NO
4. Are any additionallrevised BMPs necessary in this area? YES NO
If YES to any of these three questions, provide a description of the problem: (Any necessary corrective actions should be described on the attached Corrective
Action Form).
m
INDUSTRIAL ACTIVITY AREA
1. Brief Description: .
2. Are any contiol measures In need of maintenance or repair? YES NO
3. Have any control measures failed and require re lacermt? YES NO
4. Are any addltional/revlsed 8MPs necessary in this area? YES NO
If YES to any of these three questions, provide a description of the problem: (Any necessary corrective actions should be described on the attached Corrective
Action Form)
INDUSTRIAL ACTIVITY AREA
18

Wallace Farm, Inc.
I: Benchmark Exceedances
Instructions:
Include in the records documentation of any benchmark exceedances and how they were
responded to, including: inspections and corrective action taken:
I
Date:
Parameter Exceeded and Results:
Quarter 1 (Sample date:) Result:
Quarter 2 (Sample date: CIU12) Result: VeLA 2Lkoo e, qwc) M
Quarter 3 (Sample date: ) Result:
Quarter 4 (Sample date: ) Result:
Average Result:
Benchmark Value: t 000 CcLo ; it m t
Document how benchmark exceedance(s) responded to:
[corrective action taken
Parameter(s):
Complete Part D (corrective actions) of the Semi -Annual Report Form.
s
Date:
Parameter Exceeded and Results:
Quarter I (Sample date:) Result:
Quarter 2 (San! pie date: �/Wa) Result: r55 141 m j /L
Quarter 3 (Sample date: ) Result:
Quarter 4 (Sample date: ) Result:
Average Result:
Benchmark Value: I oo
Docu9Wt how benchmark exceedance(s) responded to:
Corrective action taken
Parameter(s):
Complete Part D (corrective actions) of the Semi-Ahn`ual Report Form,
•
23

Wallace Farm, Inc.
0
V
•
2. Are any control measures in need of maintenance ir? YES NO
3. Have"any control measures failed and require repiaceT�Q YES NO
4. Are any addilionaUrevised BMPs necessary in this area? NO
It YES to any of these three questions, provide a description of the (Any.necessary corrective actions should be described on the attached Corrective
Action Form)
D. CORRECTIVE ACTIONS
Complete this page for each specific condition requiring a corrective action or a review determining that no corrective action is needed Copy this
a a for additional comective actions or reviews.
Include both corrective actions that have been Initiated or completed since the last annual report, and future corrective actions needed to address problems
Identified in this comprehensive stomrwater inspectipn. Include an update on any outstanding corrective actions that had not been compteted at the time of your
previous annual report
1 • Corrective Action # of
for this reporting
clod.
2. Is this corrective action:
An update on a corrective action from a previous annual report; or
A new corrective action?
3. Identify the conditions) ngering the need for this review:
Unauthorized release or discha e
Numeric effluent limitation exoeedanee
Control measures inadequate to meet applicable water quality standards
Control measures inadequate to meet non -numeric effluent limitations
Control measures not property operated or.maintained
Change In facility operations necessitated change In control measures
verage benchmark value exceedanee
Other (describe):
4, Briefly describe the nature of the problem identified: yy
Ct;ti' 0o rn ekcee':j
5. Date problem Identified:
fi. How problem was identified:
At ,;L. ,
Corn rehensive site inspection
LJ Quarterly visual assessment
Routine facility inspection
19

-"'Wallace Farm, Inca - "
•
[atenchmark
monitoring
Notification by EPA or State or local authorities
El
Other (describe):
7. Description of corrective action(s) taken or to be taken to ofiminate or further investigate the problem (e.g„ describe modifications or repairs to control
measures, analyses to be conducted, etc.) or if no modifications are needed, basis for that determination:
1,�� l� Sa.cY,�1E, ; ncom;n Shot t,n wa�tC ('rom OLD .z0
Suh �Jc4; {l• �ecc+l c:al; YoFivl
c11� a'►rN ; f1 SiAll :Zorn, .
8. Di 1MIf this corrective action require modification of your SWPPP? YES
8. Date oorreelive action initiated:
ti
10. Date correction action. completed: I
or expected to be completed:
11. if corrective action not yet completed, provide the status of corrective action at the time of the comprehensive site inspection and describe any remaining
steps (including timeframes associated with each step) necessary to complete corrective action:
brx c1C
MMNNUAL REPORT CERTIFICATION
1. Com ce Certification
Do you oerfiftet your annual inspection has met the requirements of the permit, and that, based upon the results of this inspection, to the bast ur
knowledge, you a compliance with thepermit? YES NO,
If NO, summarize why are not in compliance with the permit:
2. Annual Report Certification
I certify under penalty of law that this document a attachments were prepared under my dire r supervision in accordance with a system designed to
assure that qualified personnel property ga and evaluated the information submitted. Based on m ' u€ry of the person or persons who manage the
system, or those persons directly res le for gathering the information, the information submitted is, to th esl of my knowledge and ballef, true, accurate,
and complete. I am aware that are significant penalties for submitting false Information, Including the poss of fine and imprisonment for knowing
violations.
Authorized Repres ve Printed Name:
Title:
S
Date Si" .,
20

Watlace Farm, Inc. ..... "
.7
Description:
2, Are any control measures in need of maintenance or iR YES NO
3. Have arty control measures tailed and requite replacemAk YES NO
4, Are any additionallrevised BMPs nemssary in this area? Y 0
If YES to any of We three questions, provide. a description of the p m: (Any,necessary corrective actions should be described on the attached Corrective
Action Form)
0. CORRECTIVE ACTIONS
Complete this page for each specif% condition requiring a cormctive action or a review defe►mining that no corrective action Is needed. Copy this
page for additional corrective actions or reviews.
Include bclh corrective actions that have been Initiated or completed since the last annual report, and future corrective actions needed to address problems
Identified in this comprehensive stormwater inspection. Include an update on any outstanding corrective actions that had not been completed al the time of your
previous annual report.
I. Corrective Action # of
for this reporting
edod.
1 Is this corrective action:
An update on a corrective action tram a previous annual report, or
Lj A new corrective action?
3. Identi the condition s triggering the need for this review:
Unauthorized release or discharge
Numeric effluent limitation exceedance
Control measures Inadequate to meet applicable water quality standards
Control measures inadequate to meet non -numeric effluent limitations
Control measures not property operated or maintained
Change in fac li operations necessitated change in control measures
Average benchmark value exoeedanoe
Other (describe):
4. Briefly describe the nature of the problem identified:
9-'A C. a tt IBC. -f a v l'4
S. Dale problem identified: a
6. How problem was identified: y
Comprehensive site inspection
LJ Quarterly visual assessment
Routine facility inspection
19

Farm, Inc.-...._ __.. _ -- ._...__..._..�_-._- — — ..._.... ..__.......... _��� ..
•
•
C
Benchmark monitoring
Notification by EPA or State or local authorities
Other (describe):
1. Description of corrective action(s) taken or to be taken to eliminate or further investigate the problem (e.g.. describe modifications or repairs to control
measures, analyses to be conducted, etc,) or if no modifications are needed, basis for that determination:
WaJer d{aloy ;fora
8. Didlwih this corrective action require modification of your SWPPP? YES 0
9. Dale corrective action initiated: �$ L
10. Date correction action.completed: -
orexpect§lo a com't� :
��ff 0
11. If corrective action not yet completed, provide the status of corrective action at the time of the comprehensive Me inspection and describe any remaining
steps (including timeframes associated with each step) necessary to complete corrective action:
E. SEM11-ANNUAL REPORT CERTIFICATION
1. Compliance Certification
Do you certify that your annual inspection has met threments of the permit, and that, based upon the results of this Inspection, to the best of your
knowledge, you are in compliance with the L3a meth E NO.
If NO. summarize why you are not in compliance with the permit:
2. Annual Report Certification
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 property gathered and evaluated 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 hest of my knowledge 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.
Authorized Representative Printed Name:
Title:
r -
Signature: >
Date Si mad:
__2 I —/!.
20

Wallace Farm, Inc.
•
n
LJ
0
J. SWPPP Amendment Log
Wa 11 n cQ. Fa f nr. C n c. N P D E S
nstlu�lions .
Include m your;records:'
A ril descriptiorf dlAny amen m'r~rfts tb yaur SWPPR
1
Added PA es 2A,,9YjdC +ro . sack ,. dacurnen♦
s: fjf+;F,can s��14s r non--Oorwa}ec d,Ona(ses
rf/jal►a
2
Amenr)t se':i -n Z•, b4 oc,..n OM;ni.
4v'4 Om prot;uc
3
Am¢cr�ss� Scck;on2srl-, Y."41rs;on dsa:ngje.
waS pctr} of aaoq
77211
4
Arn videJ So c.�,of% 3, yncluJe l;Si of
5
7 .a 12
6
Md 4 q. u A +0 doc.urncni employ re i4a:c%,K
*' mec4,rq . �;"'}e i q'Jal,� C4 tra;fleri
*71z%Iz
7
8
9
10
11
v, 1p
V !�
L. VP
8. v1 'VP
f.ut V.i>
24

I FILE
NCDER
'Norih-Carolina Department of Environment and*Natural'Fkesources - -
Division of Water Quality
Beverly Eaves Perdue
Governor
Mr. Eric Wallace
Wallace Farm Soil Products
14410 Eastfield Road
Huntersville, North Carolina 28078
Dear Mr. Wallace:
Charles Wakild, P.E.
Director
June 21, 2012
Subject: Notice of Deficiency
NOD-2012-PC-0018
Compliance Evaluation Inspection
Wallace Farm
NPDES Permit No. NCS000525
Mecklenburg County, NC
Dee Freeman
Secretary
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the joint inspection
conducted at your facility on May 22, 2012, by Mr. Michael L. Parker with this Office and Mr. Ron
Eubanks with Mecklenburg County Department of Water Quality. The inspection focused on a review of
the operation and maintenance of your stormwater treatment facilities, your Stormwater Pollution
Prevention Plan (SPPP), and analytical and qualitative monitoring data required by the subject permit.
The enclosed report should be self-explanatory. Please note the comments located in the summary
portion of the inspection report. As noted by Mr. Parker and Mr. Eubanks during their inspection,
analytical and qualitative monitoring has not been performed at this facility as required by Part II, Section
D of the subject permit. Such being the case, this inspection report is being issued as a Notice of
Deficiency for the failure to comply with the terms and conditions of your General Permit. Please note
that your facilities SPPP should be updated on an annual basis as required by Part II, Section A, No. 7 of
your permit.
Mooresville Regional office
Location: 610 East Center Avenue, Suite 301, Mooresville, NC 28115 One
Phone: [phone] Fax [phone] NUI'hCarUia_nd
Internet: httpa/partaLncdenr.orglweblwq �gtur�ll�
An Equal opportunity 1 Affirmative Action Employer — 50% Recycled/10% Post Consumer paper

Mr. Eric Wallace _..
June 21, 2012
Page Two
It is requested that this Office be provided a written response detailing the measures taken in order
to bring your facility into compliance. Your response should document the initiation of analytical and
qualitative monitoring at the subject facility in accordance with the terms and conditions of the subject
permit. This response should be received by no later than 30 days from the date of this letter.
Please note that unresolved deficiencies may lead to the issuance of a Notice of Violation and/or
assessments of civil penalties. If you have any questions, comments, or need assistance with
understanding any aspect of your permit, please do not hesitate to contact Mr. Parker at [phone] or
me.
Sincerely,
1 1"
Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
/mlp
Enclosure
cc: Shelton Sullivan — NPS/ACO Unit
Ron Eubanks, MCDWQ

Compliance Inspection Report
Permit: NCS000525 Effective: 10/01/08 Expiration: 09/30/13 Owner: Wallace Farm Inc
SOC: Effective: Expiration: Facility: Wallace Farm
County: Mecklenburg 14410 Eastfield Rd
Region: Mooresville
Huntersville NC 28078
Contact Person: Eric Wallace Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
Related Permits:
Eric T Wallace
Eric T Wallace
Certification:
Phone:
Phone: [phone]
Phone: [phone]
Inspection Date: 05/22/2012 EntryTime: 10:00 AM Exit Time: 12:45 PM
Primary Inspector: Michael L Parkervw Phone: [phone]
Ext.2194
Secondary Inspector(s):
Water Quality Program Mecklenburg County Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: '❑ Compliant ■ Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page: 1

Permit: NCS000525 owner - Facility: Wallace Farm Inc
Inspection Dale: 05/22/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Joint inspection wim mLuvvuV ana UVVU. Lastinspection was conducted Dy uvvu staff on August Z5, 2001J. I he
ectigaradfiwaaSssued on October 1, 2008, and will expire on September 30, 2013.
Facility Description: Wallace Farm is a family owned and operated business located at 14410 Eastfield Road in
Mecklenburg County near the Cabarrus County line. Beginning in the early 1940s, the Wallace Farm operated as one of
the largest dairy farms in the State until 1990, when it began converting to a soil and composting operation. Currently the
facility produces a line of soil and compost products using aerobic composting techniques.
Compliance History: Wallace Farm is regulated as a permitted solid waste compost facility by the N.C. Department of
Environment and Natural Resources (NCDENR), Waste Management Division under Permit Number SWC-60-22.
Mecklenburg County's Solid Waste Management Program works cooperatively with the State through a Memorandum of
Agreement to enforce the requirements of this permit; however, all regulatory authority for this facility lies with the State
and not the County. Wallace Farm is also regulated by the NCDENR, Division of Water Quality under NPDES
Stormwater Permit NCS000525. In addition, Wallace Farm has an industrial pretreatment permit from
Charlotte -Mecklenburg Utilities (CMU) to discharge into their sanitary sewer system (CMU Permit #6001).
The facilities Stormwater Pollution Prevention Plan (SPPP) had been implemented, however, there were a number of
deficiencies of the SPPP noted during the inspection. There also has been no analytical testing or qualitative monitoring
performed since December 2010. The deficiencies noted in the SPPP include:
1. The general location (USGS) map did not include whether or not the receiving waters were on the State's 303D list for
impaired waters. Clarke Creek is on the 303(d) List for poor bioclassification (Ecological/biological Integrity Fish). Clarke
Creek is a Class C stream in the Yadkin River Basin.
2. The site map needs to show drainage areas and detail activities occurring within the drainage area.
3. The SPPP should contain an annual certification as to whether any significant spills have occured and any corrective
actions that were taken. The permittee should be aware of the reportable quantities for wastewater and oil releases, and
SARA Title 111.
4. Any releases from secondary containment structures should be observed for color, foam, outfall staining, visible
sheens, and dry weather flow prior to release. The SPPP should also include documentation of the individual making the
observation, description of water, date, and time of release.
5. The SPPP included a BMP summary, but the summary had not been updated to include the SW diversion berm and
additional SW detention that had been added since the SPPP had been written.
6. The Spill Prevention and Response Plan (SPRP) should be updated to include the (team) responsible for
implementing the SPRP. It is recommended that the SPRP be posted in the Office for quick reference by other company
staff.
7. The SPPP included a Preventative Maintenance and Good Housekeeping Plan, however the Plan had not been
updated since 2010.
8. The person responsible for employee training should be identified in the SPPP. At a minimum, annual training for all
personnel should be provided. This training should include: proper spill response, cleanup procedures, preventative
maintenance activities for all personnel involved in any of the facility's operations that have the potential to contaminate
stormwater runoff.
Page: 2

Permit: NCS000525 Owner - Facility: Wallace Farm Inc
Inspection Date: 05/22/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
9. The SPPP has not been updated on an annual basis as required by the permit. Yearly updates should be noted in the
plan and then certified by an authorized signature.
10. Qualitative monitoring is not being performed at this facility as required by the permit. The last documented
qualitative monitoring was performed in December 2010.
11. Analytical testing is not being performed at this facility as required by the permit. The last documented analytical
testing was performed in December 2010. A review of this data reflected a number of benchmark exceedances which
should have required the permittee to increase monitoring, increase management actions, increase record keeping,
and/or install additional BMPs in a tiered program (see Section B of the permit). Such being the case, this inspection
report will be issued as a Notice of Deficiency for the failure to conduct the required analytical testing and qualitative
monitoring as set forth in the subject permit.
The SW outfall for this facility was observed during the inspection. There was no evidence that a release of product
(compost) had occurred nor was there evidence that the SW pond on the southern most part of the site had experienced
a release. The water level in the pond was over a foot below the emergency spillway and the area had recently
experienced a heavy rainfall event.
Page: 3

Permit: NCS000525 owner - Facility: Wallace Farm Inc
Inspection Date: 05/22/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices"?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment: Although many of these components were found in the SPPP, many were
incomplete or lacking in detail. There was no list of significant spills included in the
SPPP nor is the SPPP reviewed annually (see Inspection Summary).
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment: Qualitative monitoring has not been conducted as required by the permit.
The last qualitative monitoring performed at this facility was in December 2010 (see
Summary).
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: Analytical monitoring has not been conducted as required by the permit.
The last analytical monitoring performed at this facility was in December 2010. The
most recent analytical monitoring test results indicated several Benchmark exceedances
(see Summary).
Permit and Outfalls
Yes No NA NE
1101113
Yes No NA NE
❑ ■ ❑ ❑
❑ ❑ ■ ❑
Yes No NA NE
Page: 4

Permit: NC5000525 Owner - Facility: Wallace Farm Inc
Inspection Date: 05/M2012 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: Annual re-certifcation for illicit (non-stormwater) discharges has not been
performed (see Summary).
Page: 5

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. Eric Wallace, Vice President
Wallace Farms, Inc.
1.4410 Eastf eld Road
Huntersville, North Carolina 28078
Dear Mr. Wallace:
Division of Water Quality
Coleen H. Sullins
Director
September 1, 2009
Dee Freeman
Secretary
Subject: Compliance Evaluation Inspection
Wallace Farms, Inc
Permit No. NCS000525
Mecklenburg County, NC
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the inspection
conducted at the subject facility on August 26, 2009, by Mr. Michael L. Parker with this Office. Thank
you for your assistance and cooperation during the inspection.
The enclosed report should be self-explanatory. Overall, your facility's Stormwater Pollution
Prevention Plan (SPPP) was well developed and implemented. As'a reminder, please note that your SPPP
should be updated on an annual basis as required by Part II, Section B, No. 7 of your permit.
If you have any questions, comments, or need assistance with understanding any aspect of your
permit, please do not hesitate to contact Mr. Parker at [phone].
Sincerely,
-----/
Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Enclosure
Electronic copies: Ron Eubanks, Meek Co. WQ
Teresa Bradford
cc: Shelton Sullivan — NPS/ACO Unit
Mooresville Regional Office
Location: 610 East Center Ave„ Suite 301 Mooresville, NC 28115 One
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 NorthCaroli.na
Internet: vrww.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled110% Post Consumer paper �%tlma"1 J

Permit: NCS000525
SOC:
County: Mecklenburg
Region: Mooresville
Compliance Inspection Report
Effective: 10/01/08 Expiration
Effective: Expiration
Contact Person: Eric Wallace
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Eric T Wallace
On -site representative Eric T Wallace
Related Permits:
Title:
Inspection Date: 08/26/2009 Entry Time: 10:00 AM
Primary Inspector: Michael L ParkJmyl
Secondary Inspector(s): 11
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Owner: Wallace Farm Inc
Facility: Wallace Farm
14410 Eastfield Rd
Huntersville NC 28078
Phone: [phone]
Certification:
Exit Time: 12:15 PM
Phone:
Phone: [phone]
Phone: [phone]
Phone: [phone]
Ext2194
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000525 Owner - Facility: Wallace Farm Inc
Inspection Date: 08/26/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On September 30, 2008, Wallace Farms, Inc. (WFI) was issued NPDES Stormwater permit No. NCS000525 by the
Division of Water Quality. In addition to the requirements set for in the subject permit, there were additional provisions
added to the final permit that WFI was required to implement within six months of permit issuance. These include:
1. Develop and implement a SPPP.
WFI developed a SPPP, which was received by the Division of Water Quality (DWQ) for review on May 29, 2009. In a
letter dated July 15, 2009, the DWQ acknowledged receipt of the SPPP and noted that the Plan contains the basic
components required by the NPDES permit. Deficiencies in the SPPP were noted and WFI is in the process of addressing
these deficiencies. Implementation of the Plan was confirmed during the Compliance Evaluation Inspection (see attached
report).
2. WFI must provide and emply a flexible fabric cover to prevent incident rainfall on the working material in the Product
Mixing Area.
WFI chose to move the area where the product is mixed under roof so there would be no contact with SW.
3. WFI must install a BMP to reduce solids which may be in the runoff from the SW drainage area.
WFI has installed the requested BMP to reduce solids which may be found in the runoff from the SW drainage area. In
addition, WFI has constructed additional sediment basins that will aid in sediment removal from the site's SW.
4. WFI must augment the eastern boundary of the SW drainage area to insure effective run on minimization and
segregation.
WFI has made the necessary topographic changes to provide an effective drainage divide so that Product Mixing Area
SW and other SWs are segregated and do not comingle. This drainage augementation has been accomplished by
reshaping the topography so that the two areas are separated by an elevated ridge that prevents comingling of the SW
from the two areas.
Page: 2

Permit: NCS000525 owner - Facility: Wallace Farm Inc
Inspection Date: 0812612009 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■
n n n
# Does the Plan include a General Location (USGS) map?
■
n ❑ n
# Does the Plan include a "Narrative Description of Practices"?
■
n n ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑ fl ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
n ❑ 0
# Has the facility evaluated feasible alternatives to current practices?
■
n n ❑
# Does the facility provide all necessary secondary containment?
M.
n fl ❑
# Does the Plan include a BMP summary?
■
n n Cl
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
❑
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
❑
0
# Does the facility provide and document Employee Training?
■
n
❑
❑l
# Does the Plan include a list of Responsible Party(s)?
■
❑
❑
❑
# Is the Plan reviewed and updated annually?
■
0
0
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑
❑
Comment: SPPP should note that no product mixing is performed in stormwater (SW)
drainage area.
Site map should note the name of the nearby receiving waters and that the receiving
waters are also a 303(d) listed stream (see comments in Summary).
Although no significant spills have occurred since the permit was issued (September 30,
2008), the SPPP should be updated annually to include a statement attesting to such.
Any SW releases from secondary containment structures should be documented and
recorded in the SPPP as required by Part II, Section A, No. 2(b) of the SW permit.
The SPRP should identify a specific person (or team) who is responsible for the
implementing the SPRP as noted in Part II, Section A, No. 3
The SPPP should include a statement signifying that the Plan has been updated
annually.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑
Comment:
Page: 3

i
Permit: NCS000525 Owner - Facility: Wallace Farm Inc
Inspection Date: 08126I2CO9 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ■ n n n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: All vehicle maintenance is perforated under roof by an outside contractor.
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it pfoperiy documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: On an annual basis, the permittee should include a statement in the SPPP
that the presence of illict (non-stormwater) discharges has been evaluated.
nn■n
Page: 4

Allocco, Marcia
From: Massengale, Susan [[e-mail]]
Sent: Monday, August 24, 2009 3:43 PM
To: [e-mail]
Subject: Settlement Agreement Reached Between State and Composting Facility
Attachments: ATT00001.c
From DENR
Settlement A reement Reached Between State and Composting Facilit
RALEIGH — State environmental officials have reached an agreement that resolves a dispute with a composting facility in
Huntersville.
Last fall, the N.C. Division of Waste Management issued Wallace Farm Inc. a notice of violation and a compliance order
for alleged violations of the state's solid waste management rules and laws and the facility's operating permit. The
alleged violations came about in connection with complaints that strong odors were coming from the Wallace Farm site
at 14410 Eastfield Road, Huntersville.
The settlement agreement seeks to reduce or eliminate the strong odors by calling for an immediate change in
operational practices at Wallace Farm and the elimination of one waste stream and the possibility that other waste
streams will be removed if the odors recur or persist.
"Without enduring a lengthy court battle, we have reached an agreement that benefits the community, the facility and
the state because we are able to immediately start addressing the problems the state identified at the facility," said
Dexter Matthews, director of the N.C. Division of Waste Management.
Composting is a managed aerobic process that uses naturally occurring bacteria and fungi at temperatures above 110
degrees to break down raw, organic materials such as food, yard and agricultural wastes. Breaking down those wastes
produces a relatively stable, humus -like product that can be used to improve soils or as mulch for plants. State rules
require a permit to operate a facility such as Wallace Farm that composts solid wastes.
The state imposed a $10,500 administrative penalty as part of last fall's compliance order. Wallace Farm agreed to pay
the state -imposed penalty if it didn't fulfill the conditions of the agreement. Upon satisfaction of the conditions outlined
in the settlement agreement, the state agreed that no administrative penalty would be due. Wallace Farm has fulfilled
those conditions.
For a copy of the settlement agreement or more information, check out the Web link,
http://www.wastenotnc.org/swhome/`­Wallace Farm Settlement Aereement.pdf, or contact Jamie Kritzer at
Jamie.Kritzer ncdenr. ov or [phone].
###
Susan Massengale
Public Information Officer
DENR- Division of Water Quality
1617 MSC, Raleigh, NC 27699-16-17
(919) 8o7-6359> fax [phone]
Please note: my e-mail address has changed to susan.massengalenncdenr.gov

STATE OF NORTH CAROLINA ' IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
COUNTY OF MECKLENBURG 08 EHR 3040 and 08 EHR 3041
Wallace Farm Inc., )
Petitioner, )
v. )
SETTLEMENT AGREEMENT
N. C. Department of Environment and )
Natural Resources, Division of Waste )
Management, }
Respondent. )
Respondent, North Carolina Department of Environment and Natural Resources,
Division of Waste Management, Solid Waste Section (hereinafter "the Division"), and
Petitioner, Wallace Farm, Inc. (hereinafter "Wallace Farm") hereby enter into this
Settlement Agreement ("Agreement") pursuant to N.C. Gen. Stat. § 150B-31(b), in order
to resolve the following disputed matters as a result of mediation, without need of further
litigation, and without any admission of liability on the part of Wallace Farm;
1. 08-EHR-3040 arose out of the issuance by the Mecklenburg County Land Use
and Environmental Services Agency (LUESA), as delegate of the Division, of
a Notice of Violation of Solid Waste Permit (SWC-60-22) (the "Permit") on
November 7, 2008 for alleged violations of the North Carolina Solid Waste
Management Rules and conditions of the Permit pertaining to the design and
operation of the facility in a manner that allowed for the purported detection
of strong odors off the Wallace Farm site. Petitioners filed a Petition for
Contested Case hearing in the Office of Administrative Hearings ("OAH")
challenging the Notice of Violation;
2. 08-EHR-3041 arose out of the issuance by the North Carolina Department of
Environment and Natural Resources, Division of Waste Management, Solid
Waste Section of a Compliance Order with Administrative Penalty in the
amount of $10,500 and investigative costs of $1,003.53 on November 12,
2008 for alleged violations of the North Carolina Solid Waste Management
Act and of the North Carolina Solid Waste Management Rules for the
purported detection of objectionable odors off the Wallace Farm site,
Petitioner filed a Petition for Contested Case hearing in the Office of
Administrative Hearings challenging the Compliance Order and Penalty
Assessment, dated November 12, 2008; and
3. A Notice of Violation dated September 26, 2008 was issued by the North
Carolina Department of Environment and Natural Resources, Division of
Waste Management, Solid Waste Section for alleged violations of 15A NCAC
13B .1046(l)(A) and the Permit for odors emitting from a flooded pond.

Petitioner denied any violation had occurred and challenged this Notice of
Violation by letter dated October 10, 2008.
Without any trial of the facts or law in a contested case hearing and without any
admission of liability on the part of Wallace Farm, Wallace Farm represents that it
intends to do the following:
1. Relocate its Large, Type III compost facility currently located at 14410
Eastfield Road, Huntersville, North Carolina to another county within the
State of North Carolina.
2. If and when it receives a renewal of its current permit as a Large, Type III
compost facility at its present location, Wallace Farm represents that it does
not intend to seek a renewal of that Large, Type III compost facility permit at
its present location upon the permit's five (5) year expiration.
In addition, without any trial of the facts or law in a contested case hearing and
without any admission of liability on the part of Wallace Farm, the Division and Wallace
Farm have reached the following Settlement Agreement in these matters:
1) Wallace Farm denies the allegations made in these three (3) matters and makes no
admission as to the correctness or accuracy of the allegations and denies any violation
of its Permit,
2) Although the allegations made in these three (3) matters have not been proven in a
court of law, the Division reaffirms its position regarding the allegations in these
three (3) matters.
3) The Division of Waste Management agrees to hold the administrative penalty of
$10,500 in abeyance if the following conditions delineated below are met and said
conditions are integrated into Wallace Farm's Operation and Maintenance Manual as
an addendum within thirty (30) days of the execution of this Agreement. Upon
confirmation of the following conditions being met and integrated into Wallace
Farm's Operation and Maintenance Manual as an addendum upon the allotted times
identified, the Division shall reduce the $10,500 administrative penalty to $0. Upon
confirmation that the following conditions are not met upon the time schedule
identified and not integrated into Wallace Farm's Operation and Maintenance Manual
as an addendum within thirty (30) days, then and in that event, Wallace Farm, Inc.
shall pay the entire amount of the $10,500 administrative penalty within ten (10) days
of that confirmation.
a) Wallace Farm shall not turn any compost windrow that has been in existence less
than six (6) weeks unless it has two operators on site, one operating its compost
windrow turner and the second its custom spreader. Both operators shall work in
tandem so that the top surface and the upper half of each side surface of compost
2

windrows being turned are evenly covered with a 3"-6" layer of finished compost
of carbonaceous material within ninety (90) minutes of completion of the turning.
b) Each newly created compost windrow shall be evenly covered on the top surface
and the upper half of each side surface with a 3 "-6" layer of finished compost or
carbonaceous material within three (3) hours of its creation.
c) Wallace Farm eliminated a feedstock (a feedstock ranked as potentially a factor in
affecting odor at its property boundary) from its composting process in February,
2009 and shall permanently eliminate said feedstock from its composting
operation.
d) The obligations of Wallace Farm set forth in paragraph 3(a) and (b) hereof shall
be suspended during the occurrence of a "Force Majeure." For purposes hereof,
the term Force Majeure shall mean tornadoes, sudden lightening storm, other Acts
of God, and other events 'not reasonably within Wallace Farm's control or
anticipation. Wallace Farm shall promptly notify the Division upon the
occurrence of an event of Force,Majeure, shall use reasonable efforts to rectify the
event of Force Majeure, including termination of any turning of windrows and
shall promptly notify the Division upon the conclusion of such period of Force
Majeure.
e) In the event of a mechanical failure of the spreader during placement of cover as
set forth in paragraph 3(a) and (b) hereof, Wallace Farm shall immediately
terminate windrow turning and shall use its best effort to utilize substitute
equipment for cover placement.
Upon the request of DENR, based upon field observations, Wallace Farm shall
consult with DENR and shall eliminate another feedstock within sixty (60) days
from the date of the consultation. After a full cycle of composting has elapsed
(60-90 days) following the date of the elimination of the second feedstock, DENR
and Wallace Farm shall assess odors at the property boundary. If the elimination
of this feedstock results in an improvement of odor conditions at the property
boundary, then this feedstock shall be permanently eliminated from the Wallace
Farm composting process. If the elimination of this feedstock does not result in
an improvement of odor conditions at the property boundary, then this feedstock
may be reintroduced into the composting process. If and in the event that this
feedstock is reintroduced and field observations warrant, then Wallace Farm shall
eliminate another feedstock, following the same procedure' delineated herein until
a determination is made as to whether any particular feedstock should be
eliminated because of it being a factor in affecting odor at the property boundary.
If Wallace Farms shall have identified four feedstocks through this process, then
the parties shall enter into negotiations in good faith to determine whether -

IV
elimination of further feedstocks will affect odor at the property boundary,
provided however that DENR agrees that it shall not seek to require Wallace
Farms to eliminate any feedstock that could be accepted at a Type I facility.
g) Wallace Farm shall obtain an oxygen meter within thirty (30) days following the
execution of this Agreement and shall begin monitoring oxygen levels within the
compost windrows within sixty (60) days of the execution of this Agreement.
h) Wallace Farm shall advise Mecklenburg County and DENR authorities by email
at least one (1) hour prior to the turning of each of its compost windrows. Such
emaits shall be deemed delivered when sent by Wallace Farms to the following
addresses: Teresa Bradford at Teresa.bradford a ncdenr. ov and Joe Hack at
j oe.hack(a7mecklenburgcountync. g_ov.
i) Wallace Farm shall ensure that moisture levels in the compost windrows are
maintained in the 40-60% range for newly created compost windrows and
compost windrows within PFRP, Wallace Farm shall test for moisture with a
hand squeeze test when it records temperatures and shall record the results of the
moisture test at the time it records the temperatures.
j) Wallace Farm shall pay to the Division the investigative costs of 51,003.53 within
ten (10) days of the execution of this Agreement.
k) Wallace Farm retains all rights to apply for and operate a large Type I composting
facility at its current location beyond the expiration or termination of its current
Permit for operation of a Large Type III composting facility and the Renewal
Permit. In addition, Wallace Farm retains all rights to conduct any other
operations at its current facility for which no permit from the. Division is required.
1) While its application for a renewal of its current Permit is pending, and until a
Renewal Permit is issued, Wallace Farm agrees to accept no more than 100,000
tons of material for composting in any one year reporting period.
4) The Division agrees to consider the two Notices of Violation and the Compliance
Order with Administrative Penalty closed upon confirmation of the above conditions
of paragraph 3 being met and integrated into Wallace Farm's Operation and
Maintenance Manual within the allotted time frames.
S) The Division agrees that it will not delay its review of Wallace Farm's application for
renewal of its Permit, or any other permit, license or certification, on the basis of
these three (3) matters; and further, the Division's decision regarding Wallace Farm's
renewal permit, either its approval, denial, or modification, will be issued as
expeditiously as possible following any public hearing and comment period.
4

6) The Division reaffirms its position that a Notice of Violation is not a proper basis for
a contested case pursuant to N.C, Gen, Stat. § 150B-22 and makes no admission as to
the correctness and accuracy of the Court's Order dated March 3, 2009 denying the
Division's Motion.to Dismiss,
7) Nothing in this Agreement shall restrict the right of the Division to inspect or take
enforcement action against Wallace Farm for any new, subsequent, or repeated
violation of Article 9 of Chapter 130A of the North Carolina General Statutes, or the
State's Solid Waste Management Rules, codified at 15A N.C.A.C. Subchapter 13B,
or the right of Wallace Farm to contest any subsequent enforcement action based on
allegations of new, subsequent or repeated violations, to the extent such right is
provided by law.
8) For purposes of Article 3A of Chapter 105 of the North Carolina General Statutes,
the Division hereby notifies Wallace Farm, Inc., that it will find that the facts cited in
the Compliance Order with Administrative Penalty constitute a "violation" and will
report the violation to the North Carolina Department of �-'.evenue. Wallace Farm
denies there has been any violation and expressly incorporates l :!ragraph 1 of the
Settlement Agreement on page 2 hereinabove set forth.
9) The Parties agree that each shall bear its own costs related to any disputes covered
by this Agreement.
10) This Agreement shall be binding upon the parties and is entered into knowingly,
intelligently, and voluntarily. The consideration for the promises contained herein,
and this Agreement contains the whole agreement between the parties as to the
matters covered herein.
11) This Agreement is binding upon the parties and their successors and assigns.
Petitioner agrees to file Notices of Dismissal of Petitioner's Contested Cases in the
Office of Administrative Hearings within ten (10) days of being notified that the
Division has confirmed that the conditions have been met and that the penalty held in
abeyance has been reduced to $0.
12) The Parties agree to cooperate fully in executing any and all supplementary
documents and in taking all additional actions that may be necessary to give full force
and effect to the terms of this Agreement.
5
13) Each provision of this Agreement is intended to be severable, and if any provision
is held to be invalid, illegal, or unenforceable in any respect, such invalidity,
illegality, or unenforceability shall not affect or impair any other provision of this
Agreement, but this Agreement shall be construed as if such invalid, illegal, or
unenforceable provision had not been contained therein.

.i
14) This Agreement shall be binding upon the Parties upon execution by the undersigned.
The Agreement becomes effective on the last date of the signatures of the
undersigned.
15) - The undersigned representative of Wallace Farm hereby acknowledges that he has
read this Agreement, conferred with his attorney, fully understands the contents of the
Agreement, consents to the settlement of claims on the terms set forth herein, and
does so in reliance upon his own judgment and advice of his attorney and not in
reliance on any other representations or promises of the Division, its representatives,
or its attorneys.
11(
Entered and effective this the ly day of June, 2009.
tv
FOR THE PETITIONER WALLACE FARM, FOR THE RESPONDENT NC, THE
INC. DIVISION OF WASTE MANAGEMENT
(:its. L 'Id lay
Eric Wallace, Vice -President
Wallace Farm, Inc.
aFonti do Or'
State Bar No 3266
THE ODOM FIRM, PLLC
1109 Greenwood Cliff
Charlotte, North Carolina 28204
Telephone: [phone]
Facsimile: [phone]
Paul Crissman, Section Chief
Solid Waste Section, Division of
Waste Management, DENR INC.
Roy Cooper
Attornev General
Teresa L. T send
Assistant Attorney General
N. C. Department of Justice
9001 Mail Service Center
Raleigh, North Carolina 27699-9001
Telephone: [phone]
Facsimile: [phone]

NIFMA
NCDENR
North Carolina Department of Environment nd atural.Resources
Division of Water Quality
DeF Beverly Eaves Perdue Coleen H, Sullins>• .J e man
V
Governor-. Director Secretary
july•15, 2009
Mr. Eric Wallace, VP
Wallace Farm, Inc.
J U L 17 2009
14410 Eastfleld Road'r^
Huntersville, NC 26078 DV
Subject: Stormwater Pollution Prevention Plan Review
Wallace Farm, Inc
Permit Number NCSb00525
individual Stormwater Permit
Mecklenburg County
Dear Mr. Wallace:
The Division of Water Quality's Stormwater Permitting Unit (SPU) acknowledges receipt of your .
Stormwater-Pollution Preveritlon Plan (SP3) developed in accordance with NPDES Permit Number NCS000525
on May 29, 2009. Our Unit has had -the' opportunity to read through and review your submission. Overall, the
Wallace Farm. SP3 contains most of the basic components required by your permit. However, SPU noted a
number of deficiencies and provides the following comments for your consideration:
1. The,gen.eral location rnap.does not clearly depict the receiving water, nor does it indicate that Clarke
Creek is listed on the 303(d) list as impaired for biological integrity. Please revise to include this
information (required in your permit in Part II Section A.1.a.);
2. The site plan should show surface waters and wetlands both onsite and adjacent to the property. If no
wetlands exist, please include a note on the drawing stating so. At a minimum, the general direction
of the UT to Clark Creek must be illustrated on the site plan (II.A.1.c.(8)).
3. -The certification in Sectlon 1.8 of the SP3 must be signed and dated. Addltionally, a summary of
stormwater outfall evaluations should be included in this section'to determine the presence or absence
of non-stormwater discharges
4. The discussion of -secondary containment in Section 2.2 lists three tanks requiring secondary
containment, however, the Routine Facility Inspection Report in Part II, D lists only one tank. Please
revise the Report template to include all three tanks (II.A.2.b.).
Currently, the BMP Summary in Section 2.3 of the Plan references the report by Integrated Water
Strategies that presents potential BMPs for Wallace Farm. Please include a summary of all structural
and non-structural BMPs currently in place at the site, in addition to potential BMPs to be considered,
as are discussed in the report (II.A.2.).
6. Section 4: Preventative Maintenance and Good Housekeeplrig Program should include a schedule table
documenting maintenance, inspections, cleanings, etc. to be performed at regular intervals. The
schedule for these activities should be more specific (I.e.,' how often, and what other circumstances
should prompt inspections such as changes or tank refilling?) (II.A.4.).
7.' Section 5: Employee Training should identify facility personnel responsible'for implementing employee
,. tr6ining.-L A training schedule must also be developed and included in this section (II.A.5.).
Additionally, please include a copy of the referenced Wallace Farm O&M Manual, which..presumably
contains emergency lnformation related to spill prevention -and response employee training, as part of
the SP3.
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location; 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet www.ncwaterquality.org .
An Equal Oppodunl:y 1 Affirmative Action Employer
No e hCarolina
)aturall

Mr. Eric Wallace
NCS000525
SP3 Review
8. Please consider if it would be helpful for the Plan Amendment Log. in Part II, } to•include space for the
preparer's name, title and signature. Note that plan amendment must be performed at a frequency of
at least annually (iI.A.7.).
9., Section 8: Inspections should include an inspection schedule at least semi-annually for the duration of
the permit (II.A.B.),
10: Per Part 11, Section A (d.) of the permit, the Wallace Farm Plan should include more specific information
on temporary cover requirementsin the product mixing area. Where exactly'are the covers and
anchors stored? What personnel are specifically trained to perform this activity? Please note that a
daily log is required to record instances when the covers are employed, and staff training on cover
employment must be recorded in the SP3 (II.A.2.d.).
If you have any questions or concerns regarding our review, feel free to contact myself at (919) 807-
6365 or cory.larsen(@ncdenr.aov or -Ken Pickle at [phone] or ken. gickle0pncdehr.gov.
Sincerely,
Co
Env mental Engineer
Stormwater Permitting Unit
cc: Ken Pickle, SPU
Barnes Blerk, PE, PhD
Mooresville Regional Office
Stormwater Permitting Unit Files.

SARNES MERCK, P.E., PH.D.
ENVIRONMENTAL ENGINEERING 01:INSULTANRECEIVFD
3 HAMPT❑N HILL PLACE
CHAPEL HILL, NO 2751 7 �A 2
TEL 9 1 9-4❑ 1-❑59 1
EF'Ax E31 5 550-2322
December 31, 2008
M-Surface Water Profec;tion
Mike Parker (Via facsimile to fax number 704-663-6040, and US Mail
NCDENR - DWQ
Mooresville Regional Office
610 East Center Ave., Ste 301
Mooresville, NC 2811 5
Re: Wallace Farm, Inc., Huntersville, NC: Requirements for Stormwater Permit No.
NCS000525
Dear Mr. Parker:
This letter is in follow-up to our recent conference call_ with Marcia Alloco regarding Wallace
Farm's stormwater permit requirements.,
As required in the permit, Wallace Farm:
1. Submits the attached drawing showing a BMP they have developed to address the
stormwater BMP required in Part II, Section A, Paragraph 2e, pursuant to the requirement
of Part III, Section A, 1. Compliance Schedule, which reads as follows:
"The stormwater BMP required in Part II, Section A, Paragraph 2e of this permit shall be
installed within six months of the effective date of the initial permit issuance. Within
three months of permit issuance the permittee shall submit to DWQ's Mooresville
Regional Office Supervisor, Surface Water Protection Section, a narrative description,
layout drawing, and dimensional information for the proposed stormwater BMP."
By way of narrative, this drawing shows a detention basin and swale improvements for
reducing solids in runoff from the product mixing area.
2. Requests your assistance with a field determination for drainage divide augmentation
required in Part II, Section A, Paragraph 2f, of the permit, pursuant to the requirement of
Part III, Section A, 1. Compliance Schedule, which reads as follows:
"The drainage divide augmentation required in Part 1T, Section A, Paragraph 2f of this
permit shall be accomplished within six months of the effective date of the initial permit
issuance. Within three months of permit issuance the permittee shall request a field

wl

Mr. Mike Parker
December 31, 2008, Page -2-
determination of the necessary extent of augmeritation measures by DWQ's Mooresville
Regional Office Supervisor, Surface Water Protection Section."
Thanks very much for your assistance.
Sincerely,
Barnes Bierck, P.E., Ph.D.
Attachment: BMP drawing
cc: Eric Wallace, Wallace Farm, Huntersville, NC
Marcia Alloco, Mooresville Regional Office (via facsimile)

12/29/2008 01:11 FAX [phone] Wallace FarmA.
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VWal4e;Farm - Stinky farm ordered to clean up
Subject: Wallace Farm - Stinky farm ordered to clean up
From: susan massengale <[e-mail]>
Date: Fri, 05 Dec 2008 17:05:51 -0500
To: DWQ Clips <[e-mail]>
*
Farm could be fined for stench after neighbors complain
**
08:07 AM EST on Friday, December 5, 2008
**By TONY BURBECK / NewsChannel 36
E-mail Tony: [e-mail] <mailto:tburbeck®wcnc.com>
Stinky farm ordered to clean up
HUNTERSVILLE, N.C. -- A local farm known for its rancid eye -watering smell has been
fined for noxious odors. Now in a NewsChannel 36 exclusive, the state is saying pay
up, not just clean up.
Wallace Farm in Huntersville makes compost. Chances are you buy it at your local home
improvement store or garden center. We could tell you the ingredients, but it might
make you sick.
"It's like rotten eggs, just rotten food, waste," said neighbor Darryl Lorenz. "You
can almost taste it when you are out here."
That's what it's like living near Wallace Farm.
"I was raised on a farm, I know what a farm smells like, this is much worse than
that," Lorenz said.
Now, the state agrees, to the tune of a $11,500 fine, something it hadn't issued
before.
A state investigator gave it the old smell test on six different days, including
Cambridge Bay Drive.
That's where Brian Dare lives.
"It's a sour smell. I think of something rotting. Dairy maybe, just a real sour
rancid smell," Dare said.
Until now, Wallace Farm had been cited. Basically, told to clean up.
"If there's not a consequence accompanying it, then it's like a slap on the wrist,"
Dare said.
The farm spent a half million dollars on improvements and says it wants to be good
neighbors.
We found court records showing the farm filed a complaint against the City of
Charlotte for a recent alleged "invalid inspection" and wants the city to hand over
all of its Wallace Farm records.
Neighbors just want that stench gone.
"Maybe this will help," Lorenz said.
A Wallace family member tells us the farm will appeal. If it doesn't correct the
1 of 2 12/8/2008 9:29 AM

Wai4alarm - Stinky farm ordered to clean up
problem, the state could fine the farm $15,000 a day.
One suggested remedy says to rank the ingredients brought in by smell and don't
include the worst in the compost.
The farm's permit is up for renewal. A hearing date has not been set.
DENR.DWQ.CLiPS mailing list
DENR.DWQ.CLZPSOlists.ncmail.net
2 of 2 12/812008 9:29 AM

AdIfW: Wallace Farm Pond Discharge]
Subject: Re: [Fwd: FW: Wallace Farm Pond Discharge]
From: Ken Pickle <[e-mail]>
Date: Thu, 02 Oct 2008 16:11:07 -0400
To: Marcia Allocco <[e-mail]>
Marcia,
Just spoke with Ron. I told him that the runoff from the windrows is considered a
wastewater. Clarified for him that there's no NC water rule or law that says, "Type
III compost facilities produce wastewater as a runoff." But that instead, we read
the 40CFR122.2 definition of "process wastewater" as a water which comes into direct
contact with, or results from the production or use of any raw material,
intermediate product, finished product, byproduct, or waste product. We apply that
definition to the circumstances at Wallace Farm by noting that anything that leaks
out the bottom of a windrow can be certainly assumed to be a liquid that has come
into direct contact with one or more of the categories named in the definition. And
is therefore a "process wastewater" according to the federal definition.
There is also a supporting definition of "industrial waste" in NC GS 143-213(18) - I
make the jump from "industrial waste" to wastewater intuitively, in this case - -
although I think a legal opinion may eventually be necessary on this point. I'm not
a lawyer.
Further, note that DWM rules at 15A NCAC 13B .0101(11) and 15A NCAC 13A .1405
(a)(7)(H) define leachate as a liquid that has come into contact with solid waste,
and require that it be controlled, collected, treated, and disposed of. While this
may not say definitively that leachate is a wastewater, or that leachate should be
permitted as a wastewater, it's hard to imagine a credible alternative suggestion as
to how to regulate the leachate with respect to protecting North Carolina receiving
waters. From this we take support for our posture that leachate is wastewater, and
should be permitted as wastewater, not stormwater.
Ken
Marcia Allocco wrote:
Ken,
Please see the attached e-mail from Ron Eubanks from MCWQP regarding the
definition of "wastewater" from composting sites. Could you provide answer to
Ron?
Thanks,
Marcia
Marcia Allocco - Marcia.Alloccooncmail.net
Environmental Chemist
North Carolina Department of Environment & Natural Resources
Division of Water Quality - Surface Water Protection Group
610 East Center Ave., Suite 301
Mooresville, NC 28115
Ph: [phone] Faxt [phone]
Subject:
FW: Wallace Farm Pond Discharge
From:
"Eubanks, Ron" <Perry.Eubanks®mecklenburgcountync.gov>
l of 3 10/6/2008 3:03 PM

ReVwd8W: Wallace Farm Pond Discharge]
Date:
Thu, 2 Oct 2008 14:35:07 -0400
To.
"Marcia Allocco" <[e-mail]>
To.
"Marcia Allocco" <[e-mail]>
CC:
"Eubanks, Ron" <[e-mail]>
Hey Marcia,
As you are aware, there are several local and State agencies working to address
citizen concerns regarding the Wallace Farm property. Per the attached e-mail,
the Mecklenburg County Water Quality Program (MCWQP) has requested Wallace Farm to
provide information concerning the recent discharge from their wastewater pond.
From recent site inspections and conversations with Mr. Eric Wallace (Wallace
Farm), there were some questions regarding the State's classification or
regulatory statutes concerning the definition of wastewater. In other words, has
storm water runoff from a Type III composting operation been designated by the
State as wastewater? If so, is it designated in the Solid Waste regulations or
Water Quality regulations? Please send me an e-mail or contact me at (704)
336-5446 to discuss this matter at your convenience.
Thank you,
Ron------------------------------------------------------------------------
*From:* Eubanks, Ron
*Sent:* Monday, September 29, 2008 2:17 PM
*To:* Hack, Joe
*Subject:* FW: Wallace Farm Pond Discharge
Joe,
From our conversation earlier today, please find attached the e-mail I sent to Mr.
Eric Wallace on Friday concerning the recent discharge from the pond at Wallace
Farm. As we discussed, I will follow-up with Charlotte -Mecklenburg Utilities
(CMU) to determine if they have authority in their wastewater permit to require
Wallace Farm to recirculate the water in the pond to avoid anaerobic conditions.
Their CMU wastewater permit may require a certain dissolved oxygen concentration
to be maintained in the pond prior to discharging into the CMU sanitary sewer. I
understand your concerns regarding an increase in the discharge capacity with
CMU. However, when Rusty and I spoke with Mr. Wallace last week, we all agreed
that Wallace Farm should request -for an increase in their discharge capacity,
since they are limited in their wastewater disposal options at the site. I will
send you a copy of the response letter when received from Wallace Farm for your
files. Please send me an e-mail or contact me at [phone], if you have any
questions or need additional information regarding this matter.
Thank you,
Ron
*From:* Eubanks, Ron
*Sent:* Friday, September 26, 2008 4:59 PM
*To:* 'Eric Wallace'
*Cc:* Eubanks, Ron; Rozzelle, Rusty
*Subject:* Wallace Farm Pond Discharge
Eric,
I'm sorry I missed your call earlier today. From your voice mail message and our
previous conversations, the Mecklenburg County Water Quality Program (MCWQP) is
requesting a letter from Wallace Farm containing the following information:
2 of 3 10/2/2008 4:21 PM

Refwd"*W: Wallace Farm Pond Discharge]
1. Circumstances surrounding the discharge of water from the wastewater pond at
Wallace Farm on September 17, 2008 and records of previous rainfall that
contributed to the discharge.
2. Response regarding MCWQP's concerns for potential negative water quality
impacts as a result of the discharge. Provide copies of the discharge monitoring
reports (DMRs) for the Charlotte -Mecklenburg Utilities (CMU) permit.
3. Actions that are being taken to control future discharges, including an
engineering analysis of the pond (i.e., pond capacity & water balance) and a
request to CMU to increase the discharge capacity in your wastewater permit.
Please send the response letter to Mr. Rusty Rozzelle (Mecklenburg County Water
Quality Program Manager) at 700 North Tryon Street, Charlotte, NC 28202. Please
copy Mr. Daryl Hammock (Charlotte Storm Water Services) at 600 East 4th Street,
Charlotte, NC 28202 and Mr. Mike Parker (NCDENR-DWQ) at 610 East Center Avenue,
Mooresville, NC 28115. Please send the response letter by October 8, 2008.
Please let me know if you need additional time to prepare the letter. Please send
me an e-mail or contact me at [phone], if you have any questions or need
additional information regarding this matter. Thank you for your cooperation.
Have a great weekend!
Ron Eubanks
Environmental Specialist
Mecklenburg County Water Quality Program
700 North Tryon Street
Charlotte, North Carolina 28202
Phone: [phone]
Fax: [phone]
E-mail: Perry.Eubanks®MecklenburgCountyNC.gov
cmailto:[e-mail]>
3 of 3 10/2/2008 4:21 PM

CITY OF CHARLOTTE
OFFICE OF THE CITY ATTORNEY
Memorandum
TO: Mayor and City Council
FROM: DeWitt F. McCarley, City Attorney
S. Mujeeb Shah -Khan, Senior Assistant City Attorney
DATE: September 30, 2008 (Sent Via E-Mail on 9130108 and Via Mayor and Council
Packet on 1011108)
RE: City Activity at Wallace Farm
Wallace Farm is a former dairy farm that is now a composting facility located in the
City's Extra Territorial Jurisdiction. As composting activity has increased at Wallace Farm, odor
complaints from residents of nearby neighborhoods such as Highland Creek and Skybrook also
increased. Many of the neighbors called the odors foul or disgusting, and complained about flies
drawn to the odors.
Wallace Farm is in the process of having its solid waste permit renewed by the State,
which would allow it to continue operating as a composting facility. During this process, the
neighbors have repeatedly mentioned the odor problem, and how it affects their quality of life.
The City, with the approval of the City Manager, entered into a contract with the
engineering firm of Brown and Caldwell to perform an odor study of Wallace Farms and its
impact on nearby neighborhoods. The results of this study will be used in two ways: 1) as City
input into the State's review of Wallace's application for renewal of the State solid waste permit;
and 2) possible documentation in support of any notices of violation under the Zoning Ordinance
related to odors which could be issued by City Code Enforcement staff in the future. Brown and
Caldwell began its work yesterday in the neighborhoods surrounding Wallace Farms.
This morning, with an administrative search warrant in hand (the Wallaces would not
consent to the City and Brown and Caldwell to be on their property), the City's Code
Enforcement Division and Brown and Caldwell began an inspection of Wallace Farm including
collection of air samples. The air samples will be used by Brown and Caldwell to scientifically
determine if the odors complained of in the neighborhoods come from Wallace Farm's
composting activities.
Code Enforcement and Brown and Caldwell met with some resistance from the Wallaces,
including threats against City personnel and suggestions that the Wallaces would interfere with
Code Enforcement's and Brown and Caldwell's work. However, Brown and Caldwell was able
to complete their work at Wallace Farm this afternoon. Under the contract the City has with
Brown and Caldwell, Brown and Caldwell will complete their study within the next 75 days.

Memorandum to Mayor and Council
September 30, 2008
Page 2
The study report will then be available as a public record document. The City Manager's Office
will send the report to the Solid Waste Division for their review as part of Wallace Farm's permit
application.
If you have any questions, please contact either of us. Mac can be reached by phone
(704/336-4112) or by e-mail(dmccarleycr,ci.charlotte. nc.us), and Mujeeb can also be reached by
phone [phone]) or by e-mail ([e-mail]. nc.us).
DFMIms
cc: Mr. W. Curtis Walton, Jr./City Manager
Ms. Julie Burch/Assistant City Manager
Mr. Stanley Watkins/KBE, Neighborhood Development
MI. Walter Abernethy/Division Manager- Neighborhood Development Code Enforcement Division

Michael F. Easley, Govemor ;
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
?"
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit Application 2�nU o
April 2, 2008 APR
:Facility Name:
Wallace Farm, Inc. NC DNR MR4
t-NPDES Permit Number:
�{
NCS000525
M-Sur#ace Wafer PryFacility
North
Location:Huntersville,
Carolina (Mecklenburg.ty)
t�Te ofActivity:
yp
Composting
�.
r:SIC Code
2875
,Receiving Streams:
See Figure 1, UT to Clarke Creek, index number.13-17-4, to Rocky River
River Basin:
Yadkin -Pee Dee River Basin, Sub -basin 03-07-11
,.Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit,
`.Monitoring Data:
None
Facility Location: See Figure 1, Mooresville Regional Office
;Response Requested by (Date): April 10, 2008
'Central Office Staff Contact: Ken Pickle, [phone] ext. 584
Anticipated and encountered special issues influencing processingtime:
Issue
Rating Scale: 1(less time) to'
:.
10 more time
Com liance history
4
Benchmark exceedence
I
Location (TMDL, T&E
2
-species, etc
Other time challenges:
• DWM renewal coord,
6
• Hearing likely
8
• Leachate not sw
10
Time Investment Rating:
31/40
Special Issues Explanation:
+ Compliance — Now suspect discharging sw and/or ww w/o a permit in the past, but no data to
substantiate.
• DWM — coordination w/ sister agency so as to reduce the delay in their permitting process.
• Hearing - applicant has requested hearing.
• Leachate not sw — applicant originally pursued sw permit for Leachate, which delayed final resolution
of permitting actions, permit eventually written for Leachate discharge to CMUD, instead.

lotions.: Ba!
is sufficient
by (Signature)
towater Fermitting Unit Supervisor Date oZL0
-ftw Bradley Bennett
Concurrence by Regional Office Date
Water
. . . . Quality Supervisor Date
gional Office Staff Comments
.71
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At
Page 5 of 5
e4
-0t4ta,

W A r�gQG Michael F. Easley, Governor
William G. Ross Jr„ Secretary
North Carolina Department of Environment and Natural Resources
0 Alan W. Klimek, P.E. Director
Division of Water Quality
October 5, 2006 - DRAFT
To: Stormwater Permitting Unit, Land Application Unit, and NPDES Wastewater
Units
Through: Paul Rawls, Water Quality Section Chief
From: Bradley Bennett, Stormwater Permitting Unit Supervisor
Subject: Permitting Policy for Composting and Mulch Operations
Over the past year, the Stormwater Permitting Unit (SPU) has faced an increasing
number of composting operations seeking NPDES stormwater discharge permits. At the
same time, analytical data from composting sites permitted under the program in the past
suggests pollutant levels in stormwater discharges are more characteristic of wastewater. It
is now clear that leachate from composting operations is a wastewater and poses water
quality concerns without adequate treatment. As a result, the SPU has worked to define
which discharges from compost facilities are wastewater and which may still be permitted as
stormwater. We have also considered whether yard waste composting and mulch production
should be treated differently. This memo clarifies DWQ's policy regarding stormwater and
wastewater permitting of both composting and mulch facilities, and outlines our rationale for
those decisions.
Applicability
Composting operations produce what is considered a soil conditioner. SIC category
2879 (Pesticides and Agricultural Chemicals, Not Elsewhere Classified) includes facilities
primarily engaged in manufacturing or formulating soil conditioners. Composters that mix
fertilizers into compost produce a fertilizer and are classified under SIC code 2875
(Fertilizers, Mixing Only). Mulch operations fall under SIC 2499 (Miscellaneous Wood
Products, Not Elsewhere Classified). Point source discharges of stormwater from all these
industrial categories are subject to the NPDES Stormwater Regulations in 40 CFR §122.
However, those regulations do not specifically address leachate discharge at these sites.
Rationale for Wastewater Determination
Leachate characteristics. Data from these operations suggest untreated leachate
pollutant levels pose a significant concern to surface waters. Samples of leachate from
compost and mulch facilities show BOD5 levels over 400 mg/l (over 1000 mg/l at one mulch
facility); COD levels over 800 mg/l; Total Phosphorus over 10 mg/l; Total Kjeldahl Nitrogen
(TKN) over 100 mg/l; ammonia levels above 100 mg/l, and fecal coliform counts in excess of
40,000 col./ 100 ml. The pH at a mulch facility was also recorded as low as 3.2 SU.
Nor hCaro ma
Naturallit
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.newaterqualitv.ore Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycledl10% Post Consumer Paper

DWQ Permitting Policy for Composting Operations
October 5, 2005 - DRAFT
Regulatory definitions of wastewater. The nature of the discharge aside, the SPU
has determined that leachate from these sites is wastewater, and not stormwater, based on
definitions of "industrial waste" and "process wastewater" in the North Carolina General
Statutes GS § 143-213 (18) and Federal Regulations 40 CFR § 122.2. Composting relies on
proper moisture content, often provided by rainfall (and supplemented with other water when
necessary). Stormwater in essence becomes a part of this industrial process when it contacts
composting materials. In addition, North Carolina Solid Waste Rules governing compost
facilities (15 NCAC 13A .1400) require "leachate"--defined as any liquid that has percolated
through solid waste —to be contained on site and treated, and runoff to be diverted away from
composting areas.
It seems intuitive that leachate from sites that compost Type 2 and higher -tiered
feedstocks (including pre -consumer food processing wastes, manure, post -consumer food
wastes, etc.) is a wastewater; however, even small yard and garden waste (Type 1 feedstocks)
facilities that are exempted from N.C. Solid Waste permitting requirements must meet
operational requirements to capture and treat leachate. To be consistent with the Solid
Waste rules, the SPU has concluded leachate from all these facilities is wastewater. This
philosophy mirrors regulatory practice in other states that have addressed the composting
issue (such as the State of Washington) and view leachate at all types of composting facilities
as a wastewater. Consequently, leachate discharges. are not permitted through the NPDES
stormwater program.
Special consideration of finished compost piles. Leachate and runoff from final
composted product, which is no longer classified a solid waste, can still introduce
concentrated amounts of oxygen demand, nutrients, solids, and -other pollutants into surface
waters. Also, DWQ expects that at most sites, the leachate from finished composted product
will commingle with runoff from other in -process solid waste materials. Furthermore, DWQ
sees a regulatory basis for identifying leachate from final compost as a wastewater. The
statutory definition of industrial waste is any liquid resulting from "any process of industry,
manufacture, trade or business." We interpret this description to encompass leachate from a
finished compost pile at these operations, even though the pile is no longer solid waste.
Why? Several activities may take place in final storage areas, including screening to remove
large materials and optimize consistency size; blending with materials like sand for certain
customer markets; bagging operations; etc. First of all, these types of activities extend the
period of "manufacture," and precipitation draining from them can be considered wastewater.
Secondly, if these activities ensue after compost piles have "fully composted," that compost is
not really finished product. For all of these reasons, DWQ does not consider leachate from
final compost piles to be stormwater. This approach is a departure from policies in states
like Washington, where runoff from final product storage areas is considered stormwater.
Mulch operations. DWQ believes wood mulch operations should be treated similarly
to composting operations. While mulch feedstocks initially contain less objectionable
materials, mulch product storage piles foster the initial active stages of decomposition. In
fact, partial composting is a recommended pre-treatment to mulch. Some mulch facilities
also supplement their product with fertilizer to off -set nitrogen loss from the soil when first
applied. Given that stormwater contacts concentrated areas of decomposing material, and
that DWQ has collected limited data from mulch leachate that demonstrate pollutant levels
can be just as high as in compost leachate, DWQ views discharges from mulch storage areas
as a wastewater. Rainfall or runoff that contacts mulch production activities (shredding, etc.)
is clearly a wastewater, based on definitions cited above.

DWQ Permitting Policy for Composting Operations
y, October 5, 2006 - DRAFT
Permitting Strategies
These decisions mean a shift of permitting burden to other parts of the Division. The
SPU has met with representatives from the Aquifer Protection Section and NPDES
Wastewater Units to discuss the issue, and the consensus is that leachate from these
operations should not be permitted under the NPDES stormwater program. The group
acknowledged that DWQ should estimate the number of compost and mulch facilities this
policy will affect, and whether wastewater permitting programs can streamline and/or
prioritize efforts either through general permits, permit -by -rule initiatives, minimum size
thresholds, or other approaches.
DWQ will not issue a Stormwater permit for any rainfall that contacts active
composting areas, including raw material storage and processing areas, or rainfall that
contacts final compost or mulch storage areas. Stormwater that contacts these materials
is considered a wastewater and should be permitted through an alternative program.
However, DWQ will issue a stormwater discharge permit for rainfall that does not contact
these areas or materials. This policy affects all composting operations, as well as some
facilities in the Timber Products industry.
The SPU has already begun transitioning compost facilities out of stormwater permit
coverage. We have also denied new applications and are advising applicants to seek permits
from other sections in the Division to discharge treated wastewater from their facilities.
These applicants will now be directed to the non -discharge, NPDES wastewater, and possibly
pretreatment programs. In some cases, it may be feasible to cover discharges through Solid
Waste permitting.
References: Compost Facility Resource Handbook: Guidance for Washington State, November
1998; Washington State Department of Ecology, Publication # 97-502.
North Carolina Rules Governing Solid Waste Compost Facilities: 15A NCAC 13A
Section .1400.
cc: Ted Bush, Aquifer Protection Section Chief
Kim Colson, Supervisor, Land Application Unit (Aquifer Protection Section)
Tom Reeder, Wetlands and Stormwater Branch Head
Supervisor, Composting and Land Application Branch, Division of Waste Management
Jeff Poupart, Supervisor, Pretreatment/Emergency Response/Collection Systems
Susan Wilson, Supervisor, NPDES West Unit
Gil Vinzani, Supervisor, NPDES East Unit
Matt Matthews, Point Source Branch Head
Stormwater Permitting Guidance Materials File
Rick Shriver, Assistance Director for Regional Operations
DWQ Supervisor, Raleigh Regional Office
DWQ Supervisor, Mooresville Regional Office
DWQ Supervisor, Asheville Regional Office
DWQ Supervisor, Winston-Salem Regional Office
DWQ Supervisor, Wilmington Regional Office
DWQ Supervisor, Washington Regional Office
DWQ Supervisor, Fayetteville Regional Office

BARNES BIERCK, P.E., PH.D.
ENVIRONMENTAL ENGINEERING CONSULTANT
3 HAMPTON HILL PLACE
CHAPEL HILL, NC 2751 7
TEL [phone]
EFAX B 1 5 550-2322
Bradley Bennett
Unit Supervisor
Stormwater Permitting Unit
Division of Water Quality
NC DENR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
FAX: [phone]
January 31, 2005
l (e
S)4•zMcv,j-)4e^
twCDEPT. Di" &lVlFZ09r.g641
AND RAT'""„ `'70URCE§
rt� •+C�1`�
1
Re: Wallace Farm, Huntersville: Stormwater Runoff Requirements
Dear Mr. Bennett:
FEB B 4 2005
Many thanks for speaking.with me last Monday concerning efforts to ascertain stormwater
requirements at Wallace Farm in Mecklenburg County. It is certain that all involved are keeping
paramount preserving the water quality. -Of our state, and I look forward to helping as these
matters proceed.
As we discussed, Wallace Farm'is currently renewing its Solid Waste Composting Permit. The
renewal process triggers the need for understanding and addressing any stormwater permitting
or other associated requirements.
Can we ask your Division to please inform us regarding any stormwater requirements, along
with approaches for meeting them as necessary?
At this stage, I've been able to gather preliminary information on requirements on the State
level. For example, it has been noted that composting facilities of this type do not currently fall
under SIC code designations or other listings requiring stormwater permits in North Carolina at
present. Combined with absence of surface water quality issues resulting from site activities,
this information suggests a permit would not be necessary at this time. If this is the case, then
it would of course be useful to receive confirmation.
During our discussion, we touched on earlier assessments concerning the potential for retaining
(and recycling in compost mixes) stormwater on -site, with the exception of outlier storm events.
This approach may be feasible, although implementing it could be costly in terms of stormwater
routing and potential need for expanding stormwater retention volume. Thus, it is important to
consider other approaches as well.
For example, please note that passive on -site treatment (overland flow and detention) occurs
on the site. Assessing the efficacy of this treatment should prove useful. A program of testing
would help learn treatment results, as well as potential for water quality impacts. Other
treatment schemes could be evaluated as necessary using this information.

rk;i.ro
Bradley Bennett
January 31, 2005, Page -2-
I would very much appreciate it if you could help inform us of any specific requirements that
exist at this time, and as appropriate, help with developing approaches for meeting them.
Should further examination, such as monitoring, be useful for helping pinpoint requirements,
Wallace Farm is I know eager to get to work on them.
(Please note also that I have been in touch with Mecklenburg County personnel, who indicate
that any stormwater requirements for this facility would be determined on the State level. In all
events, I look forward to receiving any further input that the County may provide.)
Please don't hesitate to get in touch at any time about any questions or concerns.
Thanks very much.
Sincerely,
sxl-� �r<�
Barnes Bierck, P.E., Ph.D.
cc ke Parker, Division of Water Quality, DENR, Mooresville, NC
usty Rozzelle, Water Quality Program Manager, Mecklenburg County
Ron Eubanks, Water Quality Environmental Engineer 11, Mecklenburg County
Ted Lyon, Division of Solid Waste, DENR, Raleigh
Eric Wallace, Wallace Farm, Huntersville, NC

IFAX Dale a�.e DSO
Number e a es lncludln cover sheer
FROM-
Wallace Farm, Inc.
[� 14410 Easo7eld Road
Himlersville, NC 28079
Phont D / ~ A~ 7041875-1975
Fax Phone '% D 91/ 6 613 — ( 6 YO Fax Phont 7041875-2394
{ cc,
.yfj•M.�.
.1�JA$�!

Co.�
on ao4 �oA 4�D M; e, Packet'
C Dwa, R.CO Gnak) Of) I - a o - 05,
illeither hazardous waste nor asbestos cantaininb waste shall be accepted at a facility or processed into compost.
�) Household lazardous waste shall not be accepted by a facility, except in an area designated by facility site plans for
storage, and shall not be processed into compost.
(c) Any compost made from solid waste which cannot be used pursuant to the requirements of this Mule shall be reprocessed
or disposed of pursuant to the requirements of I SA NCAC 13B.
Hisi .y Note: Authority C.S. 130A-294; 130A-309.03; 130A-309.11; 130A-309,29:
Ffr Decei'piher 1. 1991;
Amended Ejf. A1ay 1, 1996.
15A NCAC 13I3.1404 SITJNG/DESIGN REQUIREMENT'S FOR SOLID WASTE COMPOST FACILITIES
(a) A site shall meet the following requirements at the time of initial permitting and shall continue to meet these tequirements
throubhnut the life of the permit only on the property owned or controlled by the applicant or by the landowner(s) at the time
of permitting;
(1) A site located in a floodplain shall not restrict the flow of the 100-year flood; reduce the temporary storage
capacityof the floudplain; or result in washout ofsolid waste so as to pose a hazard to human life, wildlife,
land or water resources;
(2)
A 100-foot minimum buffer is required between all property lines and compost areas for Type 3 and 4
facilities, 50-foot for Type I or 2 facilities;
(3)
A 500-foot minimumbuffer is required between compost areas and residences or dwellings not owned and
occupied by the permittee, except that Type l and Small Type 2 and 3 facilities shall have a 200-foot
minimum buffer;
(4)
A 100-foot minimum buffer is required between all wells and compost areas, except monitoring wells;
(5)
A 50-foot minimum buffer is required between perennial streams/rivers and compost areas;
(6)
A compost facility shall be located in accordance with 15A NCAC 23 .0200, Classification and Water
Quality Standards Applicable to Surface Waters in North Carolina;
(7)
All portions of any compost facility located over a closed -out disposal area shall be designed with a pad
adequate to protect the disposal area cap from being disturbed, as defined in Part (a)(10)(E) of this Rule,
and there shall be no runoff from the pad onto the cap or side slopes of the closed out area;
(8)
A 25-foot minimum distance is required between compost areas and sweles or berms to allow for adequate
access of fire fighting equipment;
(9)
A site shall meet the following surface water requirements;
(A) A site shall not cause a discharge of materials or fill materials into waters or wetlands of the state
that is in violations of Section 404 of the Clean Water Act;
4�Ga� pt
(13) A site shall not cause a discharge of pollutants into waters of the state that is in violation of the
requirements of the National Pollutant Discharge Elimination System (NPI)ES), under Section
402 of (lie Clean Water Act; and
11
(C) A site shall not cause non -point source pollution of waters of the state that violates assigned water
/
(104
quality standards;
A site shall meet the following requirements:
r.'ft!
groundwater
(A) A site shall not contravene groundwater standards as established under 15A NCAC 21,;
(13) Portions of a site used for waste receipt and storage, active composting, and caring shall have a
soil texture Liner than loamy sand and the depth to the seasonal high water table shall be
maintained at least 12 inches fora Type 1 or 2 facilityand 24 inches for a Type 3 facility, unlessa
pad is provided;
(C) A pad shall be provided for portions of a Type 4 facility used for waste receiving and storage,
active composting, and curing;
(D) A pad is not required for storage of finished product that is dried so as to pass the paint Filter
Liquids Test (EPA Method 9095), and for which the storage area is prepared in such a manner
that water does not collect around the base of the stored material, and where the depth to the
seasonal high watertable is maintained at least 12 inches; and

(D) Special precautions or procedures for operating during wind, heavy rain, snow, freezing or other
adverse conditions;
(E) A description of actions to be taken to minimize noise, vectors, air borne particulates, and odors;
and
(F) A description of the ultimate use for the finished compost, method for removal from the site, and a
contingency plan for disposal or alternative usage of residues or finished compost that cannot be
used in the expected manner due to poor quality or change in market conditions.
(7) A report on the design of the facility, including:
(A) Dcsign capacity of the facility;
(D) A process now diagram of (lie entire facility, including (lie type, size, and location of all major
equipment, and feedstock flow streams. The flow streams shall indicate the quantity of materials
on a wet weight and volumetric basis;
(C) The paeans for measuring, shredding, [Waxing, and proportioning input materials;
(D) Anticipated process duration, including receiving, preparation, composting, curing, and
distribution;
(E) A description of the location of all temperature, air and any other type of monitoring points, and
the frequency of monitoring;
(F) A description ofhow the temperature control and monitoring equipment will demonstrate that the
facility meets the requirements in Rule .1406 Iterns (10), (11), or (12) of this Section, as
appropriate for the feedstock;
(0) The method of aeration provided and the capacity of aeration equipment; and
*(H) A description of the method to control surface water run-on and run-off; and the method to
control, collect, treat, and dispose of leachate generated.
(8) A description of the label or other information source that meets the requirements ofRule. 1407(k) of this
Section.
(9) Plans and specifications for the facility, including manufacturer's performance data for all equipment
selected.
(10) A► detailed operation and maintenance manual outlining:
(A) A quality assurance plan for the process and final product which lists the procedures used in
inspecting incoming material; monitoring, sampling and analyzing the compost process and final
product, testing schedule, and recordkeeping requirements;
(B) Contingency plaits detailing corrective or remedial action to be tatter[ in the event of equipment
breakdown; non•confortning waste delivered to the facility; spills, and undesirable conditions such
as fires, vectors and odors; and
(C) An explanation of how the facility will comply with operational requirements as outlined in little
.1406 of this Section, detailed operational iriforrtaation and instruction, anoutline of reports to be
submitted in compliance with this Section, and safety instructions.
(11) As built drawings where applicable.
(b) The following information is required for an application for a permit to construct a proposed large 2 or 3 or a Type 4
solid waste compost facility:
(1) An aerial photograph or scaled drawing, where one Inch Is less than or equal to 400 feet, accurately
showing the area within one-fourth of the mile of the proposed site's boundaries with the following
specifically identified:
(A) Entire property owned or leased by the person proposing the site;
(B) Location of all homes, wells, industrial buildings, public or private utilities and roads,
watercourses, dry runs, and other applicable information regarding the general topography within
one-fourth mile; and
(C) Land use and zoning of the proposed site.
(2) A letter from the unit of government having zoning jurisdiction over the site which states that the proposed
use is allowed within the existing zoning, if any, and that any necessary zoning approval or permit has been
obtained.
(1) An explanation of how the site complies with siting and design standards in Rule .1404 of this Section.
(4) A detailed report indicating the following:

Waliace Farms in Meck: County
Subject: Wallace Farms in Mock. County
Date: Tue, 10 Apr 2001 18:16:58 -0400
From: Dennis Ramsey <[e-mail]>
To: Michael Parker <Michael. Parker@ ncma il. net>,
TED LYON <[e-mail]>
CC: Kim Colson <[e-mail]>
Ted and Mike
Kim Colson and I discussed this facility again today. If there is still
any uncertainty about what criteria should be used to review the pond
that will catch the runoff from this compost facility, hopefully the
following will help clarify the situation.
1. The pond must be designed as a nondischarge system.' Any discharge
from the pond would be a violation.
2. In determining the approprioate size of the pond, the engineer should
use his best engineering judgement to insure that there is not a
discharge.
3. At a minimum the following criteria should be used.
a) The treatment/storage volume should be calculated using a water
balance based on the 25 year history for the site.
b) In additon to the treatment/storage volume, the pond must be able
to retain the volume of water from the 25-year, 24-hour storm event that
falls both in the pond and on the area that drains into the pond.
c) In addition to the volumes needed to meet the treatment/storage
volume and the volume from the 25-year, 24-hour storm event, the pond
must also be designed to have either a properly designed spillway to
prevent structural failure due to a storm greater than the 25-year,
24-hour storm event or have an additional minimum of 12 inches of
structural freeboard.
As stated previously these are minimum criteria and it will be up to the
design engineer to determine if the pond should be made larger based on
specific site conditions.
If I have missed anything I am sure that Kim or Mike will provide the
needed modifications.
Thanks
Dennis
1 of 1 4/26101 11:13 AM

Wallace Farms...
Subject: Wallace Farms...
Date: Wed, 11 Apr 2001 15:36:01 -0400
From: Bradley Bennett <bradley. ben [e-mail]>
Organization: NC DWQ
To: TED LYON <TED.LYON [e-mail]>,
DEXTER MATTHEWS <DEXTER. MATTHEWS@ncmail. net>
CC: Michael Parker <Michael. Parker@ncmail. net>,
Dennis Ramsey <Dennis. Ramsey@ncmail. net>,
Kim Colson <[e-mail]>,
Coleen Sullins <[e-mail]>
Ted and Dexter,
In the stormwater review of this project we determined that the
leachate/stormwater that would be coming from their composting areas
would need to be treated as wastewater and would have to be handled
through a wastewater permit rather than stormwater. Since the stream
they would discharge to is zero flow their only permitting alternative
is recycle which they are currently working toward.
Let me know if you need any additional information.
BB
Bradley Bennett
NC Division of Water Quality
Stormwater and General Permits Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone] ext. 525
Fax: [phone]
------------------------------------------------------------------------------
Mailto:[e-mail]
Web Site httr)://h2o.enr.state.nc.us/su/stormwater.html
Post -it• Fax Note
i
Ephone # �� Z
Fax #
917 -2
7671 Date
r From
Co.
i phone
Fax #
®� pages
#
1 of 1 4/26/01 11:15 AM

E & A Environmental Consultants, Inc. NCGEPT.dFEI4V11 ONIVIE'NT�
1130 Kildaire Farm Road, Suite 200 AND NATURAL RESOURCES
Cary, North Carolina 27511 E�OE)RESViGt..F..'"..OFFICE
[phone] Fax [phone] E-mail eaenvcary@akcom pl
Ms. Sue Homewood
North Carolina Division of Water Quality
Non -Discharge Permitting Unit, NCDENR
1617 Mail Service Center
Raleigh, NC 27699-1617
February 21, 2001 [ FEB 2 6 2001
. R QUALITY SECTION
A 0
RE: Wallace Farm: 1. Summary of storm water and water balance calculations and approaches
2. Request for written approval from the Department of Water Quality
Dear Ms. Homewood:
This letter follows -up on previous communications regarding Wallace Farm. As
discussed, Wallace Farm intends to use collected storm water at the facility for preparing
compost mixes and for keeping down dust. As per Ted Lyon's letter of January 22, 2001, we
were asked to show that water storage and usage at the facility will prevent discharges, with any
circumstances under which pond discharges could occur being approved in writing by the
Division of Water Quality. Other requirements include alerting the Division of Water Quality in
the event of any fish kills.
Calculations and suggested approaches are presented below for your review. We
appreciate the time and effort taken by your Division in working with Wallace Farm to protect
the quality of state waters.
Existing Site Conditions
Three composting areas are in use. The eastern -most area is not of concern because it is
part of the region contributing runoff to the smaller pond previously approved for sheet flow by
the Division of Water Quality. The southern -most area occupies approximately 9.75 acres and
the third area occupies 4.5 acres. These two areas on the western side of the property are of
concern because runoff from them reaches the final down -gradient storm water pond.
This storm water pond receives runoff from a total area of 105.4 acres. Approximately
50.6 of this area is on the property to the west of Wallace Farm (at the corner of Street Acres
Road and Eastfield Road). The storm water pond was measured as approximately 246' by 261'
wide and estimated to be about 8' in average depth. Assuming an elliptical shape, the pond is
403, 400 cubic feet in volume.
Weather data were obtained from the current Charlotte Mecklenburg Storm Water Design
Manual (published July 8, 1993) and from the State Climate Office of North Carolina, at NC
State University. These data are described below in more detail. Rainfall in the Charlotte area is
America's Premier Compost and Odor Control Specialists
0

E & A Environmental Consultants, Inc.
Ms. Sue Homewood, February 21, 2001
Page -2-
described as follows: "Rainfall is generally rather evenly distributed throughout the year, the
driest weather usually coming in the fall. Summer rainfall comes principally from thunderstorms
with occasional dry spells of one to three weeks duration."
Soil classification information was obtained from the Soil Survey of Mecklenburg
County, North Carolina (USDA Soil Conservation Service, 1977). The site consists primarily of
Iredale fine sandy loam (Ir) and Mecklenburg fine sandy loam (Me). Ir soils are moderately well
drained, with low subsurface permeability due to presence of clay layers. Me soils are similar to
Ir soils.
A mass balance was performed on current average composting operations, which mix
wood waste, yard waste, cotton waste, food processing wastewater sludge, and manure. These
calculations show that, in preparing compost mixes Wallace Farm' uses on average
approximately 7,000 gallons of water per day, or about 210,000 gallons per month.
Regulatory, Requirements - Storm Water
The Division of Water Quality has noted that a pond designed for the 25-year storm of 24
hours duration, and having two feet of freeboard, should be sufficient in terms of handling peak
rain events. The Charlotte Mecklenburg Storm Water Design Manual lists this rain event as 5.76
in of precipitation. This value was used in calculations below for sizing the storm water pond.
Within this guideline, as noted above, water balance considerations should show that the pond
and water usage are sufficient to prevent pond discharges.
Calculations and Results
i. Design Storm Conditions
The SCS (Soil Conservation Service) curve number method was used to calculate runoff
quantities. This standard approach is described in the Charlotte Mecklenburg Storm Water
Design Manual and numerous other texts including Elements of Urban Stormwater Design, by
H. Rooney Malcolm, P.E., (NCSU, 1989), and Hydraulic Engineering, by John A. Roberson, et
al. (John Wiley and Sons, NY, 1995).
Following the approach in these texts, two average curve numbers (CN) result for the
105.4 acres of concern: 75 for normal antecedent rain conditions, and 60 for dry antecedent rain
conditions. With the 5.76 in of precipitation for the 25-year, 24-hour storm, these two CN values
result in runoff totals of 1,177,900 cubic feet and 675,800 cubic feet, respectively. Rainfall data
for Charlotte supplied by the State Climate Office of North Carolina show that the 25-year, 24-
hour storm was exceeded only one time since 1948. The next largest rainfall depth was 4.51 in
of precipitation. With 4.51 in of precipitation, the CN approach results in 787,500 cubic feet for
normal antecedent conditions and 392,200 cubic feet for dry antecedent conditions.
America's Premier Compost and Odor Control Specialists
n
0

E & A Environmental Consultants, Inc.
Ms. Sue Homewood, February 21, 2001
Page -3-
Based on these considerations, it is suggested that Wallace Farm double the pond's
volume to approximately 800,000 cubic feet. This volume is within the design range for the two
calculated 25-year, 24-hour design storm conditions, sufficiently sized for all but one storm of
the past 50 years, and is economically feasible to accomplish. Note also that the CN method is in
fact "slightly conservative when used for predicting runoff from long -duration storms"
(Roberson, et al., 1995). Thus, this suggested design approach is considered to be a reasonable
one for preventing discharges from the pond.
ii. Water Balance
The water balance takes into consideration rainfall and resulting runoff, storage pond
volume, pond evaporation, and collected storm water used in the compost mix. Water used for
keeping down dust on the facility is not considered, making the approach conservative. (Note
that, following Ted Lyon's guidance, Wallace Farm will not apply pond water to piles following
the start of the required pathogen reduction period.) Infiltration is considered to be minimal due
to the presence of clay layers -in the local soil -types, and build-up of a low -permeability benthic
layer on the pond -bottom. (Ground water was addressed by the Division of Water Quality
during earlier stages of the Solid Waste permitting process.)
The CN method for predicting total runoff volumes is considered very realistic and to be
the best method available in the absence of site -specific runoff data recordings (Roberson, et al.,
1995). The method takes account of interception, depression storage, and infiltration, thus
predicting the minimum quantity of rainfall necessary to produce runoff. At Wallace Farm, this
quantity is 0.67 in of rainfall for normal conditions and 1.41 in for dry antecedent conditions.
Assuming, conservatively, normal antecedent conditions at -all times, rainfall above 0.67 in
produces runoff.
A water balance for the most recent year is shown on the attached table. Saving paper,
the rainfall data include only days during which rainfall occurred. Therefore, withdrawals for
intervening days were added cumulatively to those of each rain day shown. (For example, on
1/18 there was 0.15 in of rain: evaporation, direct rain to the pond, and withdrawal for making
compost mixes shown for that date are for days 1/11 through 1/18.) Average monthly pan
evaporation data for central North Carolina, provided by the State Climate Office of North
Carolina, were used to estimate daily evaporative losses from the pond. It was also assumed for
these calculations that the pond shall be expanded to have a surface area of 100,000 sf and 8 ft of
depth. For purposes of illustration, the pond was assumed to start out with 300,000 cubic feet of
water. As can be seen, the predictions illustrate that the expanded pond would not have
overflowed.
America's Premier Compost and Odor Control Specialists
0

E & A Environmental Consultants, Inc.
Ms. Sue Homewood, February 21, 2001
Page -4-
Conclusions and Next Steps
Based on considerations detailed above, we suggest that Wallace Farm increase the size
of their storm water pond to 800,000 cubic feet, with an additional 2 ft of freeboard. Following
this step, conditions can be monitored as needed. No known fish populations exist in the storm
water pond. Should a fish kill occur, Wallace Farm will immediately alert the Mooresville office
of the Division of Water Quality. Other steps required by the Division of Solid Waste will be
detailed in a separate communication to them, along with suggestions for appropriate
modifications to the Wallace Farm Composting Permit. Given that the current pond is sufficient
for handling all but the worst anticipated rain event over the last 50 years, we trust that, if
Wallace Farm completes the pond expansion project within the next several months, this will be
adequate in terms of timing.
We are very pleased that the suggestion for utilizing collected runoff on -site has been
shown to be feasible. Following -up on previous discussions, and considerations and calculations
detailed above, we would very much appreciate receiving as soon as possible from your offices a
letter indicating Division of Water Quality approval of these approvals.
Please don't hesitate to get in touch if there are any questions or concerns regarding these
matters. Thank you very much.
Very truly yours,
E&A Environmental Consultants, Inc.
Barnes-R. Bierck, Ph.D., P.E.
Branch Manager
Attachment: Water Balance (3 pages)
cc: Eric Wallace, Wallace Farm
Bradley Bennett, Storm Water & General Permits Unit
Mike Parker, Mooresville Regional Office ✓
Ted Lyon, Division of Waste Management
America's Premier Compost and Odor Control Specialists

Wallace Farm Water Balance
Pan
Net of
Withdrawal
Runoff
Evap
Direct Rain
Evap
(Daily)
Net
Cumulative
cf
cf
to Pond
and Rain
Month
Day
In Rain
(Normal)
of
cf
cf
cf
cf
Jan-00
4
0.39
1111
3250
2139
-3743
-1604
300000
1
8
0.03
1111
250
-861
-3743
-4604
295396
1
9
0.37
278
3083
2806
-936
1870
297265
1
10
0.7
126
278
5833
5556
-936
4746
302011
1
18
0.15
2222
1250
-972
-7487
-8459
293552
1
19
0.1
278
833
556
-936
-380
293172
1
20
0.09
278
750
472
-936
-464
292708
1
22
0.42
556
3500
2944
-1872
1073
293781
1
23
0.4
278
3333
3056
-936
2120
295901
1
24
0.47
278
3917
3639
-936
2703
298604
1
25
0.02
278
167
-111
-936
-1047
297557
1
29
0.32
1111
2667
1556
-3743
-2188
295369
1
30
0.61
278
5083
4806
-936
3870
299239
2
11
0.12
4556
1000
-3556
-11230
-14786
284453
2
12
0.94
7,925
389
7833
7444
-936
14434
298887
2
13
0.25
389
2083
1694
-936
759
299646
2
14
0.67
389
5583
5194
-936
4259
303904
2
17
0.16
1167
1333
167
-2807
-2641
301263
2
18
0.15
389
1250
861
-936
-75
301189
2
27
0.3
3500
2500
-1000
-8422
-9422
291766
3
4
0.17
3944
1417
-2528
-5615
-8143
283623
3
11
0.31
6222
2583
-3639
-6561
-10190
273434
3
16
1.26
34300
4444
10500
6056
-4679
35676
309110
3
20
1.54
69370
3556
12833
9278
-3743
74904
384015
3
27
0.26
6222
2167
-4056
-6551
-10606
373408
3
30
0.01
2667
83
-2583
-2807'
-5391
368017
3
31
0.04
889
333
-556
-936
-1491
366526
4
2
0.25
2833
2083
-750
-1872
-2622
363904
4
3
0.23
1417
1917
500
-936
-436
363469
4
4
0.03
1417
250
-1167
-936
-2102
361366
4
8
0.83
2919
5667
6917
1250
-3743
426
361792
4
13
1.01
12267
7083
8417
1333
-4679
8921
370713
4
14
0.82
2580
1417
6833
5417
-936
7061
377774
4
15
0.8
1,962
1417
6667
5250
-936
6276
384050
4
17
0.36
2833
3000
167
-1872
-1705
382345
4
24
0.45
9917
3750
-6167
-6551
-12717
369627
4
25
0.15
1417
1250
-167
-936
-1102
368525
4
26
0.15
1417
1250
-167
-936
-1102
367422
4
28
0.4
2833
3333
500
-1872
-1372
366051
5
3
0.02
7750
167
-7583
-4679
-12262
353788
5
10
0.49
11472
4083
-7389
-6551
-13940
339849
5
13
0.25
4917
2083
-2833
-2807
-5641
334208
5
21
0.01
13111
83
-13028
-7487
-20514
313693
5
23
0.09
3278
750
-2528
-1872
-4399
309294
5
24
0.12
1639
1000
-639
-936
-1575
307719
5
25
0.06
1639
500
-1139
-936
-2075
305644
Page 1 E&A Environmental Consultants, Inc.

Wallace Farm Water Balance
5
28
0.13
4917
1083
-3833
-2807
-6641
299004
6
3
0.06
10333
500
-9833
-5615
-15448
283555
6
4
0.08
1806
667
-1139
-936
-2075
281481
6
5
0.39
1806
3250
14"
-936
509
281989
6
15
0.61
18056
5083
-12972
-9358
-22331
259659
6
18
0.76
973
5417
6333
917
-2807
-918
258741
6
25
0.24
12639
2000
-10639
-6551
-17190
241551
6
26
0.17
1806
1417
-389
-936
-1325
240226
6
27
0.08
1806
667
-1139
-936
-2075
238152
6
28
0.77
1189
1806
6417
4611
-936
4864
243016
6
29
0.32
1806
2667
861
-936
-75
242941
7
6
0.11
13139
917
-122222
-6551
-18773
224168
7
7
0.02
1889
167
-1722
-936
-2658
221510
7
11
0.23
7556
1917
-5639
-3743
-9382
212128
7
12
0.58
1889
4833
29"
-936
2009
214137
7
13
0.01
1889
83
-1806
-936
-2741
211395
7
19
0.22
11333
1833
-9500
-5615
-15115
196280
7
23
0.15
7556
1250
-6306
-3743
-10049
186231
7
24
0.02
1889
167
-1722
-936
-2658
183573
7
25
0.1
1889
833
-1056
-936
-1991
181582
7
26
0.01
1889
83
-1806
-936
-2741
178841
7
27
0.01
1889
83
-1806
-936
-2741
176099
7
29
0.01
3778
83
-3694
-1872
-5566
170533
8
1
0.82
2580
5472
6833
1361
-2807
1134
171667
8
2
0.02
1694
167
-1528
-936
-2464
169203
8
3
0.32
1694
2667
972
-936
36
189239
8
4
0.12
1694
1000
-694
-936
-1630
167609
8
8
0.19
6778
1583
-5194
-3743
-8938
158671
8
10
0.58
3389
4833
1444
-1872
-427
158244
8
18
0.2
13556
1667
-11889
-7487
-19376
138869
8
24
0.42
10167
3500
-6667
-5615
-12282
126587
8
25
0.29
1694
2417
722
-936
-214
126373
8
30
0.13
8472
1083
-7389
-4679
-12068
114305
8
31
0.17
1694
1417
-278
-936
-1214
113092
9
1
0.56
1333
4687
3333
-936
2398
115489
9
2
0.56
1333
4667
3333
-936
2398
117887
9
3
0.69
162
1333
5750
4417
-936
3543
121430
9
4
0.06
1333
500
-833
-936
-1769
119660
9
5
0.01
1333
83
-1250
-936
-2186
117475
9
18
1.55
70799
17333
12917
-4417
-12166
54217
171691
9
19
0.06
1333
500
.833
-936
-1769
169922
9
21
0.07
2667
583
-2083
-1872
-3955
165967
9
22
1.41
51857
1333
11750
10417
-936
61338
227305
9
23
0.68
1333
5667
4333
-936
3398
230702
9
25
0.16
2667
1333
-1333
-1872
-3205
227497
11
4
0.11
31500
917
-30583
-36497
-67081
160417
11
5
0.02
556
167
-389
-936
-1325
159092
11
7
0.02
1111
167
-944
.1872
-2816
156276
11
9
0.68
1111
5667
4556
-1872
2684
158980
11
14
0.41
2778
3417
639
-4679
-4040
154919
11
16
0.09
1111
750
-361
-1872
-2233
152687
Page 2 E&A Environmental Consultants, Inc.

Wallace Farm Water Balance
11
17
0.2
556
1667
1111
-936
175
152862
11
19
0.57
1111
4750
3639
-1872
1767
154629
11
25
0.65
3333
5417
2083
-5615
-3532
151098
12
2
0.02
3444
167
-3278
-6551
-9829
141269
12
13
0.1
3667
833
-2833
-10294
-13127
128142
12
14
0.13
333
1083
750
-936
-186
127956
12
15
0.01
333
83
-250
-936
-1186
126770
12
16
0.61
333
5083
4750
-936
3814
130584
12
17
0.32
333
2667
2333
-936
1398
131982
12
19
0.13
667
1083
417
-1872
-1455
130527
12
21
0.04
667
333
-333
-1872
-2205
128322
12
27
0.03
2000
250
-1750
-5615
-7365
120957
Page 3 E&A Environmental Consultants, Inc.

North Carolina
Department of Environment and Natural Resources
Michael F. Easley, Governor
Sherri Evans -Stanton, Acting Secretary
V►
January 22, 2001
Barnes R. Bierck, Ph.D.
E & A Environmental Consultants, Inc.
1130 Kildaire Farm Road, Ste. 200
Cary, North Carolina 27511
ern
NCDENR
Re: Wallace Farm Composting Facility — SWC 60-22 — Storm Water
121(664 , �5 .
Dear Dr. Bierck:
The Division of Waste Management, Solid Waste Section, reviewed your letter
concerning the Wallace Farm Compost Facility. Your letter was received on January 3,
2001 and addresses storm water management at the compost facility.
The Division supports the concept of using waste water or storm water as a
source of moisture in the compost process. In order for us to approve the reuse of
storm water as a moisture source the operation and maintenance manual for the facility
must be modified to indicate how water will be transported from the pond(s) to the
windrows and how the water will be incorporated into the windrows. The manual
should also indicate that since the storm water runoff from the site would be considered
a source of pathogens that the pathogen reduction period must be started when the
water is added to the windrows.
If reuse of the storm water as a moisture source is intended as the only means
of storm water management it must be demonstrated that there is an adequate amount
of active compost and water storage at the site to contain the water. The size of the
pond(s) at the facility must be designed to contain all runoff unless the Division of
Water Quality approves, in writing, a discharge from the pond(s). If fish are living in
the pond(s) Division Water Quality will need to indicate the acceptable level of
pollutants in the ponds. The operation and maintenance manual will need to include
the steps to take, including who with Water Quality to contact, in the event of a fish kill.
It is unclear from the information you provided why an additional 5 to 6 months
will be needed to complete the requirements of condition number 3 of the solid waste
compost permit. Permit condition 3 provided 180 days to obtain a permit from the
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: 919 — 733-0692 1 FAX: 919 — 733-48101 Internet: www.enr.state.nc.us/ENR/
AN EQUAL OPPORTUNITY 1 AFFIRMATIVE ACTION EMPLOYER -- 50% RECYCLED / 10% POST CONSUMER PAPER

Division of Water Quality for managing any storm water or wastewater on the facility.
This period expires in early February. We will however agree to extend the period to
March 15, 2001. This will provide you with an extra 30 to 40 days to complete the
necessary plans.
Should you have questions, please feel free to contact me at 919-733-0692,
extension 253.
��_777, "-:N%
cc: Eric Wallace, Wallace Farm
Sincerely,
Ted Lyon, Sud4i�sor
Composting & Land Application Branch
Mike Parker, Mooresville Regional Office
Sue Homewood, Non -Discharge permitting Unit
Bradley Bennett, Storm Water & General Permits Unit
h: cla/compost/permits/60-meck/Wal IaceFa rm/strmwtr&extreply

E & A Environmental Consultants, Inc.
1130 Kildaire Farm Road, Suite 200
Cary, North Carolina 27511
/[phone] Fax [phone] E-mail [e-mail]
January 2, 2001
Mr. Ted Lyon h+ 4t
NC DENR
Division of Waste Management �F
P.O. Box 27687 tapagtyy ft
Raleigh, NC 27611-7687
Re: Wallace Farm Solid Waste Composting Facility Permit (#SWC-60-22) Storm Water -AXF?
Dear Mr. Lyon:
This letter is for following up and to summarize storm water runoff issues at the Wallace Farm
Composting Facility.
Since the permit was issued, DENR water quality staff have visited Wallace Farm to inspect
matters there with regard to storm water. These DENR staff members include Mike Parker of
the Mooresville Regional Office, Sue Homewood of the Non -Discharge Permitting Unit, and
Bradley Bennett of the Storm Water & General Permits Unit. These inspections pertain to the
condition in the facility's composting permit that "An Appropriate Division of Water Quality
permit; for ;mapaging any; storm water or wastewater on the facility shall be obtained within 180
is
days of receipt of.this permit." .
Two'storm` water matters were identified during these site visits. The first dealt with the smaller
pond to one side of the property. It was indicated by Division of Water Quality staff that, once
modified to promote sheet flow during rain overflow events, this pond would not be of concern.
R We have been informed by Wallace Farm that this matter has been properly addressed.
The other issue concerns storm water flows from composting areas to a large holding pond, and
thence off the property when it overflows. We understand that DENR staff noted during their
inspections that this pond is not a wastewater pond, and that it does not appear to pose a threat to
water quality, in part because live minnows were observed in this pond. Nevertheless, it is
understood by Wallace Farm that this storm water issue must be addressed.
We understand that one approach suggested by Division of Water Quality staff, and which they
have discussed with you, is for Wallace Farm to develop means for using the collected storm
water,.keeping it on -site. In that event, we have been informed that the Division of Water
Quality will not require a permit, and that the approach could become a part of the operation's
Solid.Waste Composting Facility Permit. To that end, as discussed with Sue Homewood, it will
be, necessary to provide;a water balance for the property, showing that this is a workable plan.
America's Premier Compost and Odor Control Specialists
10

Environmental Consultants, Inc.
Mr. Ted Lyon, January 2, 2001
Page -2-
Wallace farm is very willing to take steps toward implementing this suggested course of action,
expanding the pond as necessary and developing means for pumping pond water for use in the
compost operations. They have asked E&A Environmental Consultants, Inc. to confirm these
understandings and to begin preparing the water balance calculations.
Would you mind confirming that this summary of the present situation and courses of action is in
keeping with your understandings? Also, in conformance with the Division of Water Quality's
indication that a permit from their division will not be necessary if Wallace Farm takes the
appropriate steps, and given that no immediate threat to water quality has been noted, would it be
possible to amend condition Number 3 of the permit to allow time into 2001 (say, until July) to
take the approach. outlined abov e? ,Much has been accompl_isbed to date, and progress is on-
going in addressing these issues.
Thanks very much.
Sincerely,
E A Environmental Cons ltants, Inc.
Barnes R. Bierck, Ph.
Enclosures
cc: Eric Wallace, Wallace Farm
Mike Parker, Mooresville Regional Office
Sue Homewood, Non -Discharge Permitting Unit.
Bradley Bennett, Storm Water & General Permits Unit
America's Premier Compost and Odor Control Specialists
0