NCG060009_NOD_20191025

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
CERTIFIED MAIL: 7012 3050 0001 9398 7416
RETURN RECEIPT REQUESTED
Prestage Farms, Inc.
Attn: William Prestage
735 Moltonville Road
Clinton, NC 28328
NORTH CAROLINA
Environmental Quality
October 25, 2019
Subject: NOTICE OF DEFICIENCY (NOD-2019-PC-0230)
NPDES Stormwater General Permit NCG060000
Prestage Farms, Inc.
Prestage Foods, Inc. -St. Pauls NC, Certificate of Coverage NCG060009
Robeson County
Dear Mr. Prestage:
On October 22, 2019, Mike Lawyer, Environmental Program Consultant, and Penny Markle, Environmental Specialist
from the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site
inspection for the Prestage Foods, Inc. -St. Pauls NC facility located at 4470 Highway 20 East, Saint Pauls, Robeson
County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Eric Hup,
Maintenance Supervisor, was also present during the inspection and his time and assistance is greatly appreciated. The
site visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit NCG060000
under Certificate of Coverage NCG060009. Permit coverage authorizes the discharge of stormwater from the facility to
receiving waters designated as Gallberry Swamp, class C;Sw waters in the Lumber River Basin.
As a result of the site inspection, the following deficiencies are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
Facility's Stormwater Pollution Prevention Plan (SPPP) does not contain appropriate documentation of an annual
review/update per Part II, Section A, item 8 of the NCG060000 permit.
2) Secondary Containment Requirements
Adequate secondary containment is not provided around the sodium chlorite and acid tank located at the back of the
plant.
Other Observations '
Please refer to the enclosed Compliance Inspection Report for additional details, comments and observations made
during the inspection.
Requested Response
A written response is not requested at this time.
o •fil'H � oi��� � � Y
Dryernmntot EmtronmenWpu®ly /—'
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
910.433.3300

Thank you for your attention to this matter. This office requires that the deficiencies, as noted above and detailed in
the enclosed inspection report, be properly resolved. Failure to address the deficiencies could result in the
issuance of a Notice of Violation, which is subject to a civil penalty assessment of up to $25,000 per day for each
violation. Should you have any questions or concerns, please contact Mike Lawyer at [phone] or via e-mail at
[e-mail].
Sincerely,`
Timothy L. LaePE
Regional Engineer
DEMLR
TL/ml
Enclosure (Compliance Inspection Report)
ec: Eric Hup, Maintenance Supervisor — Prestage Foods, Inc. -St. Pauls NC
Barry Tyner, Maintenance Manager— Prestage Foods, Inc. -St. Pauls NC
Darron Ezzell, General Manager - Prestage Foods, Inc. -St. Pauls NC
Toby Vinson, PE, CPESC, CPM, Program Operations Chief — DEMLR
Annette Lucas, PE, Program Supervisor — DEMLR, Stormwater Program
Alaina Morman, Environmental Specialist — DEMLR, Stormwater Program
cc: FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit: NCG060009 Effective: 11/01/18 Expiration: 05/31/21 Owner: Prestage Farms Inc
SOC: Effective: Expiration: Facility: Prestage Foods, Inc.- St. Pauls NC
County: Robeson 4470 Hwy 20 E
Region: Fayetteville
Saint Pauls NC 28384
Contact Person: Eric Charles Hup Title: Maintenance Supervisor Phone: [phone] Ext.7708
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Certification:
On -site representative Eric Charles Hup
Related Permits:
Inspection Date: 10/22/2019 y�Entry
�Time: 0
Primary Inspector: Mike Lawye./%I(,,<c� (�
Secondary Inspector(s):
Phone:
910-865-6611 ext 770l
Exit Time: 04:25PM
Phone: [phone] ExtV29
339Y
i
Penny Markle' —pt'm
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Food/Tobacco/Soaps/Cosmetics/Public Warehousing Stormwater Discharge COC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG060009 Owner - Facility: Prestage Farms Inc
Inspection Date: 10/22/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to determine compliance with the conditions of NPDES Stormwater General Permit NCG060000. Met
with Eric Hup, Maintenance Supervisor, who provided the facility's Stormwater Pollution Prevention Plan (SPPP) and
stormwater monitoring records for review. Facility's SPPP appeared to contain all permit -required components, however it
was last updated in 2015 and does not contain appropriate documentation of an annual review/update as required by Part ll,
Section A, item 8 of the NCG060000 permit. Analytical monitoring records from 2015 to the first half of 2019 for the facility's
single stormwater dicharge outfall were reviewed, which revealed that there had been a couple of exceedances of the
benchmark value for fecal coliform in the previous permit cycle. Mr. Hup relayed that a procedure for collecting accumulated
stormwater in the live bird area and placing it in the facility's onsite wastewater system was initiated and subsequent
stormwater discharge monitoring events in December 2018 and the first half of 2019, under the current permit cycle, have
resulted in meeting the benchmark value for fecal coliform. There have been no exceedances of the benchmark values for
other parameters in the permit. Qualitative monitoring records indicated that the facility has been conducting visual
monitoring at six locations throughout the site where ditches or drain pipes enter the primary perimeter ditch along the side
and back of the plant, which is the only true discharge outfall where stormwater leaves the property. After the records review,
observations were made of the facility's ASTs with secondary containment. While the secondary containment structures for
the facility's diesel tanks were equipped with a closed and locked drain pipe, the containment structure around the sodium
chlorite and acid tank had a hole thru the bottom of the front side wall where an apparent drain pipe used to be. Mr. Hup was
advised to install a drain pipe with a valve that can be closed and locked. Alternatively, the hole could be filled with an
appropriate grout or concrete. Observations were also made of storm drains, ditches and the stormwater discharge outfall. It
was relayed to Mr. Hup at the time of inspection that the lack of documentation of an annual review/update of the SPPP as
required by the NCG060000 permit as well as the secondary containment issue detailed above could result in the issuance
of a Notice of Deficiency.
Page 2 of 3

Permit: NCG060009
Inspection Date: 10/22/2019
Owner - Facility: Prestage Farms Inc
Inspection Type : Compliance Evaluation
Stormwater Pollution Prevention Plan
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 altematives 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?
Reason for Visit: Routine
Yes No NA NE
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❑ E ❑ ❑
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Comment: Facilitv's SPPP does not contain documentation of an annual review/update per Part II, Section
A item 8 of the NCG060000 permit. See Inspection Summary regarding secondary containment
issue.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? N ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ E ❑ ❑
Comment: No documentation of an annual evaluation of the stormwater outfall for any non-stormwater
discharges as required by Part II, Section A, item 1(e) and item 8 of the NCG060000 permit.
Page 3 of 3