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HomeMy WebLinkAboutNCG060216_CEI_20220525ROY COOPER Governor ELIZABETH S. BISER Secretary BRIAN WRENN Director Murphy -Brown, LLC Attn: John Sargent, Executive Vice President PO Box 856 Warsaw, NC 28398-0856 NORTH CAROLINA Environmental Quatity May 25, 2022 Subject: COMPLIANCE EVALUATION INSPECTION NPDES Stormwater General Permit NCG060000 Murphy -Brown, LLC Laurinburg Feed Mill, Certificate of Coverage NCG060216 Scotland County Dear Mr. Sargent: On May 23, 2022, a site inspection was conducted for the Laurinburg Feed Mill facility located at 19600 Andrew Jackson Highway in Laurinburg, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Evan Hicks, Feed Mill Manager, Mr. Greg Ewing, Regional Operations Manager, and Mr. Robert Richardson, Environmental Resource Specialist, were also present during the inspection and their 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 NCG060216. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Leith Creek (Johns Pond), class C;Sw waters in the Lumber River Basin. As a result of the inspection, the facility was found to be compliant with the conditions of the NCG060000 permit. Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil penalty assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with understanding any aspect of your permit, please contact me at (910) 433-3394 or via e-mail at mike.lawyer@ncdenr.gov. Sincerely, Michael Lawyer, CPSWQ Environmental Program Consultant Division of Energy, Mineral and Land Resources Enclosures: Compliance Inspection Report, Representative Outfall Status Request Form ec: Evan Hicks, Feed Mill Manager — Smithfield Hog Production Division Greg Ewing, Regional Operations Manager — Smithfield Hog Production Division Robert Richardson, Environmental Resource Specialist — Smithfield Hog Production Division DEMLR NPDES Stormwater Permit Laserfiche File cc: FRO — DEMLR, Stormwater Files D....w-- + North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources & rayetteville Regional Office 1225 Green Street, Suite 714 I Fayetteville, North Carolina 28301 DeWrtmeritotEmhunmenfnl4ua@y 910.433.3300 Compliance Inspection Report Permit: NCG060216 Effective: 07/01/21 Expiration: 06/30/26 Owner: Murphy -Brown LLC SOC: Effective: Expiration: Facility: Laurinburg Feed Mill (Murphy -Brown LLC) County: Scotland 19600 Andrew Jackson Hwy Region: Fayetteville Laurinburg NC 28353 Contact Person: Katie A Elmer Title: Phone: 910-293-5245 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): On -site representative Evan Hicks 910-277-8999 ext 6E On -site representative Robert Richardson 910-217-1471 On -site representative Greg Ewing 910-277-8999 Related Permits: Inspection Date: 05/23/2022 Entry Time 09:55AM Exit Time: 11:45AM Primary Inspector: Mike Lawyer %`` Phone: 910-433-3394 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Food/Tobacco/Soaps/Cosmetics/Public Warehousing Stormwater Discharge COC Facility Status: 0 Compliant ❑ Not Compliant Question Areas: N Storm Water (See attachment summary) Page 1 of 3 Permit: NCG060216 Owner - Facility: Murphy -Brown LLC Inspection Date: 05/23/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: Met with Evan Hicks, Feed Mill Manager, Greg Ewing, Regional Operations Manager, and Robert Richardson, Environmental Resource Specialist, to conduct a compliance inspection regarding the facility's coverage under NPDES Stormwater General Permit NCG060000. Facility's Stormwater Pollution Prevention Plan (SPPP) and stormwater discharge monitoring records were provided for review. The SPPP appeared to contain all required components along with documentation pertaining to the annual review and update requirements. Monitoring records for the current permit period indicate that outfall 001 is in the Tier Two monthly monitoring frequency due to consecutive exceedances of the benchmark value for COD. Facility personnel have taken action to try to address these exceedances by installing silt fence around their main grain storage areas, placing filters in catch basins, and increasing housekeeping practices. An additional stormwater discharge outfall was constructed around 2016/17, which is currently in the baseline quarterly monitoring frequency. This additional outfall needs to be added to the permit database by emailing the outfall information (identifier and coordinates) to Bethany Georgoulias at bethany.georgoulias@ncdenr.gov. Once the additional outfall has been added to the database, a Representative Outfall Status Request Form (included with this report) could be submitted to the Fayetteville Regional Office for review. After the records review, observations were made of the facility's secondary containment around ASTs, stormwater discharge outfalls, and grain storage areas. Page 2 of 3 Permit: NCG060216 Owner - Facility: Murphy -Brown LLC Inspection Date: 05/23/2022 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? 0 ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? 0 ❑ ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 0 ❑ ❑ ❑ # Does the facility provide and document Employee Training? 0 ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? N ❑ ❑ ❑ # Is the Plan reviewed and updated annually? N ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plari been implemented? 0 ❑ ❑ ❑ Comment: Qualitative Monitorinq Yes No NA NE Has the facility conducted its Qualitative Monitoring? 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? E ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑ # Has the facility evaluated all illicit (non stormwater) discharges? E ❑ ❑ ❑ Comment: Page 3 of 3 Division of Energy, Mineral & Land Resources ;;r?+ Stormwater Program National Pollutant Discharge Elimination System FOR AGENCY USE ONLY Date Received Yeaz Month Day If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the permittee may petition the Director for Representative Outfall Status (ROS). DEQ may grant Representative Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply. If Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring requirements of the facility's permit —unless otherwise allowed by the permit (such as NCG020000) and DEQ approval. The approval letter from DEQ must be kept on site with the facility's Stormwater Pollution Prevention Plan. The facility must notify DEQ in writing if any changes affect representative status. For questions, please contact the DEQ Regional Office for your area (see page 3). (Please print or type) 1) Enter the permit number to which this ROS request applies: Individual Permit (or) Certificate of Coverage I 2) Facility Information: Owner/Facility Name Facility Contact Street Address City State ZIP Code County E-mail Address Telephone No. Fax: 3) List the representative outfall(s) information (attach additional sheets if necessary): Outfall(s) is representative of Outfall(s) Outfalls' drainage areas have the same or similar activities? Outfalls' drainage areas contain the same or similar materials? Outfalls have similar monitoring results? Outfall(s) is representative of Outfall(s) Outfalls' drainage areas have the same or similar activities? Outfalls' drainage areas contain the same or similar materials? Outfalls have similar monitoring results? Outfall(s) is representative of Outfall(s) Outfalls' drainage areas have the same or similar activities? Outfalls' drainage areas contain the same or similar materials? Outfalls have similar monitoring results? ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No ❑ No data* ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No ❑ No data* ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No ❑ No data* *Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for review. Page 1 of 3 SWU-ROS-2009 Last revised 12/30/2009 Representative Outfall Status Request 4) Detailed explanation about why the outfalls above should be granted Representative Status: (Or, attach a letter or narrative to discuss this information.) For example, describe how activities and/or materials are similar. 5) Certification: North Carolina General Statute 143-215.6 B(i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the [Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed ten thousand dollars ($10,000). I hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit and regional office approval. I must notify DEQ in writing if any changes to the facility or its operations take place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must resume monitoring of all outfalls as specified in my NPDES permit. I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: Title: (Signature of Applicant) (Date Signed) Please note: This application for Representative Outfall Status is subject to approval by the NCDEQ Regional Office. The Regional Office may inspect your facility for compliance with the conditions of the permit prior to that approval. Final Checklist for ROS Reauest This application should include the following items: ❑ This completed form. ❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative status, unless all information can be included in Question 4. ❑ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the drainage areas, industrial activities, and raw materials/finished products within each drainage area. ❑ Summary of results from monitoring conducted at the outfalls listed in Question 3. ❑ Any other supporting documentation. Page 2 of 3 SWU-ROS-2009 Last revised 12/30/2009 Representative Outfall Status Request Mail the entire package to: NCDEQ DEMLR at the appropriate Regional Office (See map and addresses below) Notes The submission of this document does not guarantee Representative Outfall Status (ROS) will be granted as requested. Analytical monitoring as per your current permit must be continued, at all outfalls, until written approval of this request is granted by DEQ. Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for review. For questions, please contact the DEQ Regional Office for your area. Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Washington Regional Office 943 Washington Square Mall Phone (828) 296-4500 Washington, NC 27889 FAX (828) 299-7043 Phone (252) 946-6481 Fayetteville Regional Office FAX (252) 975-3716 Systel Building, 225 Green St., Suite 714 Wilmington Regional Office Fayetteville, NC 28301-5094 127 Cardinal Drive Extension Wilmington, NC 28405 Phone (910) 433-3300 FAX 910/ 486-0707 Phone (910) 796-7215 FAX (910) 350-2004 Mooresville Regional Office 610 East Center Ave. Winston-Salem Regional Office Mooresville, NC 28115 585 Waughtown Street Winston-Salem, NC 27107 Phone (704) 663-1699 Phone (336) 771-5000 FAX (704) 663-6040 Water Quality Main FAX (336) 771-4630 Raleigh Regional Office Central Office 1628 Mail Service Center 1612 Mail Service Center Raleigh, NC 27699-1628 Raleigh, NC 27699-1612 Phone (919) 791-4200 Phone (919) 807-6300 FAX (919) 571-4718 FAX (919) 807-6494 Page 3 of 3 SWU-ROS-2009 Last revised 12/30/2009