NCG060209_MONITORING INFO_20090729

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO. 0.)o a"
DOC TYPE 1 ❑ HISTORICAL FILE
MONITORING REPORTS
DOC DATE ❑ a� cn
YYYYMMDD

STORMWATER DISCHARGE OUThALL (SDO)
MONITORING REPORT
GENERAL, PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE NO. NCG06_
FACILITY NAME
PERSON COLLECTING PLES � r,e_
CERTIFIED LABORATORY Lab #
Lab #
Part A: Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR: OO
(This monitoring report is due at the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
COUNTY
PHONsiv0. °k( l 0) -1ai3 -sari --
PLEASE 466N ON`TI'IE'REVERSE 4
Ouffall
No.
Date '
---Sample
Collected, ;:.
--`, maida/r
. 00530,E
00400
00340
00556
31616
Tdtal'Sitspen6d
=�z• "; _;
-Solids,'
.m
pFI,
Standard units
Chern'ical-Oxygen _
Demand,
ru
Oil. and Grease;.
mglL
: .
Fecal Coliform,
Colonies per 100 ml
Bench.marii•-
-
140, : -:
:' Wstiein6.0 — r}.0
120
30
1000
Note: If you report a sampled value in excess of the benchmark value, or outside the benchmark range for pH, you must implement Tier l or Tier 2 responses
See General Permit text.
Did this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? _ yes �Ino
(if yes, complete Part B)
Part 13: Vehicle Maintenance Activity Monitoring Requirements
Outfall
No.
Date'
Sample Collected,
mo/dd/ r
00556
00530
00400 .
Oil and Grease,
m
Total Suspended Solids,
m /L
pH,
Standard units
N6v Motor Oil Usage,
Annual aversegal,/ma
Benchmark
-
30
100
6.0 — 9.0
-
Note: If you report a sampled value in excess of the benchmark value, or outside the benchmark range for pH, you must implement Tier I or Tier 2 responses.
See General Permit text. / �1
n (�ecor er ��4s �,e" �ar. .y-,ror�i, �Ts5) ('o:D L 04 G)
STORM EVENT CHARACTERISTICS:
Date(first event sampled)
Total Event Precipitation (inches): �•
Date - (list each additional event sampled this reporting; period, and rainfall amount)
Total Event Precipitation (inches):
Mail Original and one copy to:
Division of Water Quality
Attn. DWQ Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
S WU-249-102107
Pacer t nr7

"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information subntted. 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. Lam aware that there are significant penalties for submitting false information, including
the possibility of fines and im risonmeut r knowing violations."
(Signature of Pe nuttee) (Date)
r
a
f
S WU-249-102107

Permit: NCG060209
SOC:
County: Duplin
Region: Wilmington
Compliance Inspection Report
Effective: 12/01/12 Expiration: 10/31/17
Effective: Expiration:
Owner: Murphy -Brown LLC
Facility: Warsaw Feed Mill
2822 NC Highway 24 West
Warsaw NC 28398
Contact Person: Katie//��A Elmer Title: PE Phone: [phone]
Directions to Facility: �V+,ARRL-� 1�E�v+,.t �n�•,�Pr,.�r IE��na,c.a�SERv+cLS
1`I e-0q pa K+iaCC+ WA"s A" AKCA AAAjALa
System Classifications:
Primary ORC: Certification:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 06/17/2014
Primary Inspector: Brian P Lambe
Secondary Inspector(s):
Entry Time: 11:00 AM Exit Time: 01:00 PM
Phone:
Phone:
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

Permit: NGG060209 Owner - Facility: Murphy -Brown LLC
Inspection Date: 0611712014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Received a Tier III notification for this site regarding TSS for outfalls 1 and 3.
Monitoring data suggests that there are consistant problems with COD and TSS. An analysis of the data should be
performed to evaluate the causation of the elevated levels. However, values of the COD and TSS appear to be improving
when referenced to 2009-2010 data.
Murphy Brown reps proposed to install rock check dams in the ditchlines for 1 and 3 outlets. This may prove to lower the
numbers. Filtration can provide some relief in regards to TSS and COD, but the filtration provided by #57 stone may not
be enough to impact the analytical results. However, this inspector feels it may be prudent to consider enlarging the
stormwater pond and routing the 1 and 3 outlets to the pond. There are some downfalls to this idea as you may be
concentrating the problem, but in concentrating it, you may be able to treat it better. The problem root is in the quantity of
organic debris in the facility. Diligent housekeeping may also help in reducing numbers. Maintenance on the pond by
cleaning out the bottom will aid in this as well. Install permanent baffles, not silt fence, to increase flow path.
In any case, the problem needs to be evaluated. If the sampling continues to prove problematic, you will need to submit
alternative solutions to this offce.
Inclusion of the vehicle maintainace areas will activate section C of the general permit if there is more than 55 gallons of
motor oil and or hydraulic oil per month. You will need to revise the SPPP to include these areas, minus the truck wash
areas covered by the recycle system. Evaluate additional for outfalls. I discussed this with the previous inspector. She
said that these areas need to be included.
Page: 2

Permit: NCG060209 Owner - Facility: Murphy -Brown LLC
Inspection Date: 06/17/2014 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"?
■
Q
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
Cl
0
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑
0
0
# Has the facility evaluated feasible alternatives to current practices?
■
❑
Cl
Q
# Does the facility provide all necessary secondary containment?
■
0
n
n
# Does the Plan include a BMP summary?
■
❑
Q
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
Q
❑
❑
# Does the facility provide and document Employee Training?
■
Q
❑
Cl
# Does the Plan include a list of Responsible Party(s)?
■
0
Q
n
# Is the Plan reviewed and updated annually?
■
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
■
0
n
Q
Comment:
Qualitative Monitoring
Yes No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■ ❑
0
Q
Comment:
Analytical Monitoring
Yes No
NA
NE
Has the facility conducted its Analytical monitoring?
■ 0
0
0
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑ ■
Comment: The Trailer wash area has a wastewater permit W00023310. All other
drainage from the the sites involving truck maintainance and storage should be included
within this permit.
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■
Q
0
# Were all outfalls observed during the inspection?
■
❑
Q
❑
# If the facility has representative outfall status, is it properly documented by the Division?
0
n
■
❑
# Has the facility evaluated all illicit (non stormwater) discharges?
■
❑
0
Page: 3

Permit: NCG060209 Owner - Facility: Murphy -Brown LLC
Inspection Date: 0611712014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment:
Page: 4

Permit: NCG060209
SOC:
County: Duplin
Region, Wilmington
Compliance Inspection Report
Effective: 11/01/07 Expiration: 10/31/12
Effective: Expiration:,
Contact Person: Katie A Elmer
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/11/2010
Primary Inspector: Linda Willis
Secondary Inspector(s):
Title:
Entry Time: 03:00 PM
Certification:
Owner: Murphy -Brown, LLC
Facility: Warsaw Feed Mill
2822 NC Hwy 24 W
Warsaw NC 28398
Phone: [phone]
Exit Time: 05:20 PM
Phone:
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Food/Tobacco/SoapslCosmetics/Public Warehousing
Stormwater Discharge COC
Facility Status: Q Compliant ® Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Page: 1
0

Permit: NCG060209 Owner -Facility: Murphy -Brown, LLC
Inspection Date: 0811112010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
There were several areas in which oil spills to the facility grounds were observed. Two areas under the fat transmission
line and one in the area of the railcar offloading area for fat. Oily contaminated condensate from the railcar offloading
area is discharged to an inground basin that has an overflow to a lined ditch, both exposed to stormwater. The lined ditch
has a release valve that allows discharges to a grease pit that has not been adequately maintained and was full at the
time of the inspection_ Facility personnel indicated it has not been maintained for roughly over 18 months. This facility
had a major fat spill in 2009 (see incident # 200901733). Personnel at the site indicated they lost their outlet for disposal
when the vendor realized Fecal Coliform bacteria was present due to the source of the fats (meat processing facilities).
Two secondary containment structures had significant oil spill/leaks that contaminates stormwater in those basins. The
secondary containment structures for the fat silos discharges to a pit that has an oil water separator (that has not been
adequately maintained) prior to discharge to a ditch on the south side of the facility Secondary containment contents for
the diesel tank was contaminated with oil as well. It is released via pump and hose to the ground upstream of the grease
trap. The oil water separator on the northeast side of the property has not been adequately maintained, it too discharges
to surface waters. The use of the grease pit must be eliminated. It is a direct conduit to surface waters and is exposed to
stormwater that is contaminated with the contents of the grease pit. The outfall to the stormwater pond from the grease
trap was discharging at the time of the inspection. The contents of this basin is not stormwater, it is a wastewater and
requires treatment and a permit prior to discharge, Grain is exposed to stormwater in various areas of the plant. One
puddle of water had fermenting grain that was covered with insects that looked like filter flies posing a vector problem. It
appears staff are hosing down grain spills rather than sweeping up and removing the source.
Both oil water separators must be monitored at their discharge point. All stormwater outfalls from the facility should be
monitored for all parameters of concern. Both the oil water separator discharges and the stormwater discharges need to
be monitored for Fecal Coliform bacteria in addition to the other parameters outlined in the permit.
Page: 2

Permit: NCG060209 Owner - Facility: Murphy -Brown, LLC
Inspection Date: 08111/2010 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
n
# Does the Plan include a "Narrative Description of Practices"?
■
n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
n
n
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
n
n
n
# Has the facility evaluated feasible alternatives to current practices?
■
n
n
n
# Does the facility provide all necessary secondary containment?
■
n
n
n
# Does the Plan include a BMP summary?
■
n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
n
n
# Does the facility provide and document Employee Training?
■
n
n
n
# Does the Plan include a list of Responsible Party(s)?
■
n
n
n
# Is the Ptan reviewed and updated annually?
■
n
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
■
n
n
n
Comment: Stormwater Pollution Prevention Plan requires significant improvements.
The plan is not being implemented in the facility. There was no documentation for the
annual certification for non stormwater discharges from the site, feasibility study, or plan
amendments. Spills at the site had not been documented in the plan. Large spill
occurred in 2009. SWP3 indicated no spills since 2003. Significant sources of oil
pollution were identified at the site. Fat spills are directed to open ditches and grease
pits that are open to rainfall. The grease trap and oil water separators had not been
maintained, were full and able to discharge to surface waters of the State.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ 0 0
Comment: Qualitative monitoring has been conducted, however, the reports do not
reflect the conditions found in the facility.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ■ Q 0 0
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 n ■ 0
Page: 3

Permit: NCGO60209 Owner - Facility: Murphy -Brown, LLC
Inspection Date: 0811112010 Inspection Type: Compliance Evaluaticn
Reason for Visit: Routine
Comment: COD is excessive in stormwater samples collected from this facility.
Benchmarks were exceeded two sampling events in a row triggering monthly monitoring
requirements. The oil water separators need to be monitored at their outfall prior to
discharging to the stormwater pond or ditch. No stormwater analytical data exists for
January 2010 to June 2010.
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 outfali status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: See comments on summary page.
Yes
No
NA
NE
■nnn
■nnn
nnn■
n■nn
Page:

ANYIF
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 7, 2010
CERTIFIED MAIL #7008 1140 0002 3401 3659
RETURN RECEIPT REQUESTED
Kraig Westerbeek, Vice President
Murphy -Brown, LLC
P.O. Box 856
Warsaw, NC 28398-0856
Subject: NOTICE OF VIOLATION and RECOMMENDATION FOR ENFORCEMENT
NOV-2010-PC-0995
Warsaw Feed Mill
Certificate of Coverages NCGD60209 and NCG500619
Permit Condition Violations and Discharge Without a Permit
Duplin County
Dear Mr. Westerbeek:
A compliance evaluation inspection.was conducted on August 11, 2010 at the Warsaw Feed Mill Facility
in Duplin County by Division Representatives, Linda Willis and Dean Hunkele. The inspection was
conducted to determine whether the facility is compliant with the requirements of the NPDES General
Permits NCG060000 and NCG500000.
This site drains to an unnamed tributary of Turkey Creek, classified as a C-Swamp Water of the State in
the Cape Fear River Basin. A review of the Stormwater Pollution Prevention Plan (SWP3),
documentation required by the SWP3, and all analytical and qualitative monitoring data was conducted.
Division Representatives were accompanied by Mr. Wayne High.
Analytical monitoring data for NCGO60209 for the time period January 1, 2010 through June 30, 2010
was not available for review. Analytical data for the boiler blowdown discharge (NCG500619) could not
be located. A review of monitoring data for NCG060209 from 2008 to 2009 indicated monthly monitoring
was triggered (Tier 2) due to benchmark exceedances from two consecutive stormwater monitoring
results. Qualitative monitoring appeared to be conducted, but all data suggested stormwater was
consistently the same with every rain event. No problems concerning qualitative observations were
noted.
N. C. Division of Water Quality
Wilmington Regional Office
127 Cardinal Drive Extension, NC 28405
Phone: [phone] FAX: [phone]
Customer Service: 1-877-623-6748
lAtemet: www.rtcwaterquality.org
NorthCarolina
Natmall#
An Equal Opportunity V Affirmative Action Employer

Page 2 of 4
Murphy -Brown; LLC
Duplin County
NOV-2010-PC-0995
There did not appear to be any documentation of the annual certifications for non stormwater discharges
from the site (Part 11, Section A, 1. (e)), nor a feasibility study (Part II, Section A, 2. (a)). The Stormwater
Pollution Prevention Plan indicates a revision on January 22, 2009, however supporting documentation of
the revisions were not found in the plan as required by the permit (Part Il, Section A, 7.). The spill
(incident # 200901733) that occurred on July 1, 2009, was not documented in the plan as required by the
permit (Part II, Section A, 1. (d)). The SWP3 indicates no spills since 2003.
There were several areas observed in which oil spills to the ground within the facility grounds, two areas
under the fat transmission line and one in the railcar offloading area. Two oil water separators were
inspected. There is an oil water separator located northeast of the jumbo tank and one next to the fat
silos. The oil water separators were full with oil sheens on the surface of the water. Both discharge to
surface waters, one to the stormwater pond the other to the ditch on the south side of the railroad
(according to the site map)
There is'a grease trap next to the railcar offloading area that collects spills from the railcar offloading
area It has been plumbed to a synthetically lined ditch adjacent to the offloading area. Both the grease
trap and the lined ditch are exposed to stormwater. The lined ditch has a valve that can be opened to
allow a discharge to the grease trap located at the northeast side of the boiler building. The grease trap
is plumbed to surface waters via a small stormwater pond. This grease trap is full of wastewater that is
comingled with stormwater. The entire contents in this trap are considered a wastewater rather than
stormwater. Any discharge from the grease trap requires treatment and a wastewater permit prior to any
discharge. The grease trap was full of putrefied grease and fat and was discharging a dark grey, odorous
wastewater to the stormwater pond at the time of the inspection. Currentiy, no disposal option exists for
fats, oils, or grease spills generated at the railcar offloading area due to the presence of Fecal Coliform
bacteria (the source of fats are from meat processing operations). Mr. High indicated the grease trap had
not been maintained for at least 18 months due to the lack of an outlet for disposal. Mr. High was asked
to pull samples from all of the oil water separators as well as the contents of the grease trap for analyses.
All parameters required by NCG060209 were requested.
The secondary containment structure around the fat tanks (#4, #5 and #6) had significant amounts of oil
from leaks. The secondary containment dike is plumbed to a subsurface catch basin with an oil water
separator that can discharge to the ditch along the south side of the rail spur. The secondary
containment basin surrounding the fuel oil tank had standing stormwater in it which was contaminated
with oil. The stormwater in this containment structure is of such poor quality, it should not be released as
clean stormwater. The facility map does not show that the secondary containment structure around the
fuel oil tank is plumbed to an oil/water separator. It appears it is pumped out and discharged to the
ground up gradient of the grease trap.
Grain is on the ground in various areas throughout the facility. Fermenting grain with flies covering the
waste was seen in the paved area on the south side of the warehouse. Since there had been no recent
rain, it is believed this was not stormwater but washdown water. The SWP3 Best Management Practices
(BMP) section pertaining to the Loading and Unloading of Materials specifies that spills are to be swept
up, not hosed down. This poses vector attraction issues.
In addition, the truck parking, fueling, maintenance and washing area adjacent to the feed mill requires a
stormwater permit as well. The appropriate general permit for this site is the General Stormwater Permit
NCG080000 for discharges associated with vehicle maintenance operations.
As a result of the site inspection and a file review, the following violations are noted:
Item I. Failure to Meet the Requirements of the Stormwater Pollution Prevention Plan (SWP3)
Part II, Section A of the permit requires documentation in the SWP3 of the list of significant spills,
certification that stormwater outfalls have been evaluated for the presence of non stormwater discharges,
feasibility study, plan amendments, facility inspections that reflect the actual condition of the facility, and
Tier One and Two requirements and actions.

Page 3 of 4
Murphy -Brown, LLC
Duplin County
NOV-2010-PC-0995
Item II. Failure to Implement the Plan
Part II, Section A, 9. of the permit requires the plan be implemented. Best management practices and
good housekeeping practices are not being implemented in the plant as outlined in the SWP3.
Item III. Failure to Meet Analytical Monitoring Requirements
Part II, Section B of the permits (NCG060209 and NCG500619) requires semi annual monitoring of
stormwater and wastewater discharges from the site. There was no analytical data available for the
January 1, 2010 to June 30, 2010 sampling period for stormwater discharges from the site (NCG060209)
Tier Two actions should have been implemented and documented. There were no records indicating
monitoring has been conducted for the boiler blowdown discharge (NCG500619).
Item IV. Activities for Which Permits Required
General Statute 143-215.1(a): No person shall do any of the following things or carry out any of the
following activities unless that person has received a permit from the Commission and has complied with
all conditions set forth in the permit:
(1) Make any outlets into the waters of the State.
The discharge from the contents of the grease trap is making an outlet to waters of the State for an
untreated wastewater.
REQUESTED RESPONSE
Accordingly, you are directed to respond to this letter in writing within_30 calendar days of receipt of this
Notice. Your response should be sent to both this office at the letterhead address and to the Wetlands
and Stormwater Branch, NPS Assistance and Compliance Oversight Unit, Attention John Hennessy,
1617 Mail Service Center, Raleigh, NC 27699-1617. Your response should include the following:
1. Explain how and when you will amend your Stormwater Pollution Prevention Plan to improve best
management practices and good housekeeping to control the sources of pollutants at this site.
Please include the reasons for non compliance with the components of the plan that are identified
in Item I above.
You must eliminate the piping from the spill containment basin next to the railcar offloading area
to the lined ditch. You must provide this office documentation that the pipe has been
disconnected (including pictures). You must immediately block the outlets from the grease trap to
prevent any further discharges until the contents of that basin can be removed for proper storage
and disposal. You must clean out the oil water separator basins and the lined ditch and properly
store the contents until you secure a disposal outlet. You must locate an appropriate disposal
outlet and provide this office with documentation supporting proper disposal. The grease trap
should never have standing grease and oil in it unless a spill occurs and if a spill occurs you must
report the spill to this office immediately and document it in the SWP3. Please explain why fat
offloading at from the railcar are not being supervised and spills abated at that location.
Provide this office with documentation showing the secondary containment inspections prior to
any release of stormwater from the structures since January, 2008.
4. Provide this office with copies of all analytical monitoring for the time period January 1, 2008 to
present for both NCG060209. Also include documentation for all efforts to comply with the Tier
One and Two requirements. Provide analytical data for wastewater samples collected from
January, 2008 to present for the boiler blowdown discharge (NCG500619).

Page 4 of 4
Murphy -Brown, LLC
Duplin County
NOV-2010-PC-0995
5. Immediately institute monthly Fecal Coliform bacteria monitoring at all stormwater outfalls based
upon the fact that the fats, oil, and grease being brought in by railcar is contaminated with Fecal
Coliform bacteria.
6. Provide all hauling records for the disposal of oily wastewater from secondary containment and oil
water separators for the past two years. Also provide records showing proper disposal of spilled
fat, oil and grease removed from the ditch and the grease trap since January, 2008. Provide
records of all inspections conducted on the contents of the secondary containment for the fuel oil
tank prior to any release since January 2008.
7. In addition to the outfalls you currently monitor, you must include monitoring the oil water
separators at their point of discharge as well as the stormwater pond. Institute monthly
monitoring at each in accordance with permit NCG060209 and include the parameter for Fecal
Coliform bacteria.
8. Wayne High was instructed during the site inspection to collect samples from each oil water
separator basin as well as the grease trap contents for analyses for all the parameters specified
in the NPDES permit NCG060209. Please provide this office with the analytical data from the
laboratory.
9. You must update your SWP3 to reflect all of the activities that occur as a result of this inspection
and notice of violation.
10. Apply for the NCGO80000 permit for the site located to the south of the feed mill within 30 days of
receipt of this notice.
Given the condition of the Warsaw Feed Mill facility and the significant sources of stormwater pollution,
this Office is considering sending a recommendation to the NPDES Stormwater Permitting Unit
requesting the Division require this facility to apply for an individual stormwater permit rather than allowing
continued coverage under the NCG060000 General Stormwater Permit.
Currently, this office is considering sending a recommendation for civil penalties for the violations
identified in this notice. Your above -mentioned response to this correspondence will be considered in this
process. This office requires that the violations, as detailed above, be abated immediately. These
violations and any future violations are subject to a civil penalty assessment of up to $25,000.00
per day for each violation. Should you have any questions regarding these matters, please contact
Linda Willis at [phone] or myself at [phone].
Sincerely,
Rick Shiver
Wilmington Regional Supervisor
Division of Water Quality
Surface Water Protection Section
cc: ' WiRO File Copy (NCG060 Duplin: Willis)
John Hennessy— NPS-ACO Unit, Archdale Building
DWQ NPDES Stormwater Permitting Unit Attn: Bradley Bennett
DWQ SWP Central Files

JUN 2 b 2014
Murphy -Brown LLC Warsaw Facilities -Parcel Identification

Murphy -Brown LLC
PO Box 856
Warsaw, NC 23398
11JN 7 5 z��y
June 25, 2014
Mr. Brian Lambe
NCDENR—Division of Energy, Mineral and Land Resources
127 Cardinal Drive Ext.
Wilmington, NC 28405
Re: Warsaw Feed Mill NPDES Compliance Report (Stormwater)
Dear Mr. Lambe:
We received your comments dated June 18. 2014 and have addressed them accordingly Our
responses to the comments are detailed below,
Monitoring data suggests that there are consistent problems with COD and TSS. An analysis
of the data should be performed to evaluate the causation of the elevated levels. However,
values of the COD and TSS appear to be improving when referenced to 2009-2010 data.
Response: The average analytical results for calendar year 2013 were below
benchmark values for all parameters at each outfall. In 2012, the average COD result at
outfall 2, and the average TSS result at outfall 3 were above benchmark values. In 2011,
the average COD result at outfalls 1 and 2 were above benchmark values. In 2010, the
average TSS and COD results at outfall 1, the average COD result at outfall 2, and the
average COD result at outfall 3 were above benchmark values. Analysis of the data
shows that values of COD and TSS were not only improving when referenced to 2009-
2010 data, but have improved when compared to each annual average calculated from
records kept according to the retention time as specified in part til section D of the
permit.
There were only two instances in 2013 where benchmark values were exceeded for TSS
at outfalls 1 and 3. The first two samples recorded in 2014 exceeded TSS benchmark
values at outfalls 1 and 3 (disregarding "No Flow" months). These were the four results
that triggered a Tier III notification. While there were two TSS samples above
benchmark values in 2013, the annual averages were below benchmark values,
uncharacteristic of historical results. Construction for the mill renovations began at the
beginning of 2014. Since the results from 2013 were on average below benchmark
values, Murphy -Brown representatives believe the high TSS levels in 2014 could have
been caused by ongoing construction and unrelated to results prior to 2013.
2. Murphy Brown reps proposed to install rock check dams in the ditchlines for 1 and 3 outlets.
This may prove to lower the numbers. Filtration can provide some relief in regards to TSS and
COD, but the filtration provided by #57 stone may not be enough to impact the analytical
results. However, this inspector feels it may be prudent to consider enlarging the stormwater
pond and rcuting the 1 and 3 outlets to the pond. There are some downfalls to this idea as you
may be concentrating the problem, but in concentrating it, you may be able to treat it better.
The problem root is in the quantity of organic debris in the facility. Diligent housekeeping may
also help in reducing numbers Maintenance on the pond by cleaning out the bottom will aid in
this as well. Install permanent baffles, not silt fence, to increase flow path.
Response: The pond in reference was not designed as a stormwater pond, but
designed as a boiler blow down pond. The purpose of the pond is to cool boiler water

• Page 2
June 25, 2014
before it is released to waters of the state, in accordance with requirements found in
General Permit NCG500000 Part I, Section A(1). While the pond is sized to contain
stormwater from a portion of the site, along with the boiler blow down water, it is not
large enough to handle the capacity of stormwater for the entire site. Enlarging the
pond is not an economical or practical option, due to property line and elevation
constraints. Excavating the bottom portion of the pond, and installing permanent
baffles are options that are currently being discussed for implementation. Murphy -
Brown representatives believe that the rock check dams, which were installed on June
23, 2014, will be sufficient enough to address the issue of TSS until mill renovations are
complete. We will continue to monitor the outfalls monthly, and explore further options
if problems persist. Upon completion of the mill renovations, the root problem in the
quantity of organic debris at the facility should be improved.
3. Inclusion of the vehicle maintenance areas will activate section C of the general permit if there
is more than 55 gallons of motor oil and or hydraulic oil per month. You will need to revise the
SPPP to include these areas, minus the truck wash areas covered by the recycle system.
Evaluate additional for outFalls. I discussed this with the previous inspector. She said that
there areas need to be included.
Response: According to the "Technical Bulletin for N.C. General Stormwater Permit
NCG060000" located at the end of the permit, vehicle maintenance activities are not
required to be regulated under the General Permit. While Part II Section C of the permit
requires alternate and or additional "On -site Vehicle and Equipment Maintenance
Monitoring Requirements", Murphy -Brown representatives do not believe this applies
to the Warsaw Garage facility. We believe the mill facility qualifies under "SIC Code
2048 Prepared Feed and Feed Ingredients for Animals and Fowls, Except Dogs and
Cats", and the garage facility qualifies under "SIC Code 7699 Repair Shops and Related
Services, Not Elsewhere Classified".
The local Duplin County Government recognizes the parcels of land that the two
facilities are located on as separate entities, with the parcel containing the garage being
located in the Town of Warsaw, and the parcel containing the mill being located outside
of the town limits. This is further identified on the attached map. Murphy -Brown
representatives believe the stormwater that falls on the garage flows back to the
northeast corner of the property, and does not enter the stormwater systems
associated with the mill. Sampling of the stormwater from the garage would only be
representative of the garage, and not of the mill. Since the garage is a separate facility
from the mill, which does not qualify under the General Permit, we believe it should not
be included in the SPPP or analytical monitoring requirements.
This package is being resubmitted in response to the stormwater inspection conducted on June 17,
2014. The following items are included in this package:
• Summarized tables of analytical data recorded at the Warsaw Feed Mill dating back to the
required retention time stated in the permit.
• A map titled "Murphy -Brown LLC Warsaw Facilities -Parcel Identification".
Thank you for taking the time to review this response. Please contact me at [phone] or
[e-mail] if you have any questions or need additional information.
Sincerely,
Garrett Melvin
Engineering & Technical Services/Environmental Compliance

[I JUN 2 6 2014
Warsaw Feed Mill2014 Analytical Results Ry `
Sample Collection Datel AVERAGE 1 5/31/2014 4/30/2014 3/31/2014 2/28/2014 1/31/2014 --,
. Outfall #1
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #2
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #3
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
NO FLOW NO FLOW NO FLOW NO FLOW
rr
rr
• rr
•
NO FLOW NO FLOW NO FLOW NO FLOW
rr
. r
R r�
NO FLOW NO FLOW NO FLOW NO FLOW
rr
rr

c.
EC E R L'9r I
JUN 2 6 2014
Warsaw Feed Mill2013 Analytical Results I i k4
Sample Collection Datel AVERAGE 12/31/2013 11/26/2013 10/31/2013 9 / 3 0 / 2 0 1 3 8YS/-17/2013. I 7 31 2013
Outfall #1 NO FLOW NO FLOW NO FLOW NO FLOW
Oil & Grease (30 mg/L)
TSS (100 mg/L)
PH (6-9)
COD (120 mg/L)
�•
1
Outfall #2 NO FLOW
Oil & Grease (30 mg/L)
TSS (100 mg/L)
PH (6-9)
COD (120 mg/L)
NO FLOW NO FLOW
NO FLOW
I
Outfall #3 NO FLOW
Oil & Grease (30 mg/L)
TSS (100 mg/L)
PH (6-9)
COD (120 mg/L)
NO FLOW NO FLOW
NO FLOW
' .: 1
�1
•1

.w
Warsaw Feed Mill2013 Analytical Results
Sample Collection Date 6/24/2013 5/31/2013 4/29/2013 3/12/2013 2/11/2013 1/31/2013
Outfall #1
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #2
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #3
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
NO FLOW
NO FLOW
NO FLOW
NO FLOW
5
5
5
6
16.5
85.6
44.7
68.9
6.72
6.59
6.52
6.59
281
110
621
190
NO FLOW
NO FLOW

C E 0 V E
JUN 2 6 2014
Warsaw Feed Mill 2012 Analytical Results ;
Sample Collection Date I AVERAGE 1 12/26/2012 11/30/2012 10/31/2012 9/30/2012 I9/19 2012 7/11/2012
Outfall #1 NO FLOW NO FLOW
Oil & Grease (30 mg/L)
TSS 1100 mg/L)
PH (6-9)
COD (120 mg/L)
Outfall #2
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #3
Oil & Grease (30 mg/L)
TSS (100 mg/L)
PH (6-9)
COD (120 mg/L)
5.75
5
11
5
5
80.81
172
68.8
108
45.5
7.03
7.22
6.78
7.41
6.92
84.751
67
701
471
42
NO FLOW NO FLOW
5.88
5
10
5
5
70.38
68.3
89
54
102
7.09
7.28
6.5
6.81
6.34
124.501
82
1481
701
148
NO FLOW NO FLOW
5.00
5
5
5
5
107.16
143
193
55.5
129
6.91
7.3
7.06
7.65
6.72
92.631
891
1 651
371
70

Warsaw Feed Mill 2012 Analytical Results
Sample Collection Date 6/30/2012 5/9/2012 4/30/2012 3/31/2012 2/24/2012 1/11/2012
Outfall #1 NO FLOW NO FLOW
Oil & Grease (30 mg/L)
T55 (100 mg/L)
pH (6-9)
COD (120 mg/L)
5
5
5
5
108
31.5
85.3
27.4
6.44
7.35
7.09
7.04
193
441
126
89
Outfall #2 NO FLOW NO FLOW
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
5
5
5
7
65.3
25
75.3
84.1
6.6
7.01
9.34
6.84
153
109
112
174
Outfall #3 NO FLOW NO FLOW
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
5
5
5
5
202
17.3
36
81.5
5.56
7.05
6.82
7.15
246
66
66
102

E 0 E 0
JUN 2 6 2014
Warsaw Feed Mill 2011 Analytical Results Pv,
Sample Collection Date AVERAGE 12/31/2011 11/29/2011 10/12/2011 9/30/2011 8/12/2011 7/31/2011
Outfall #1
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #2
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #3
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
NO FLOW
NO FLOW NO FLOW NO FLOW
NO FLOW
NO FLOW
NO FLOW
5.5
5
5
5
65.875
35.21
29
87
7,34875
6.74
S.74
6.29
157.875
44
441
1 192
NO FLOW
NO FLOW
NO FLOW
6.125
5
5
5
57.975
18.9
66
15
6,43125
6.75
3.56
6.23
95.751
60L
S91
1 43

Warsaw Feed Mill 2011 Analytical Results
Sample Collection Date
Outfall #1
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #2
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #3
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
6/27/20111 5/6/20111 3/30/2011
NO FLOW NO FLOW
2/28/2011
NO FLOW
1/26/2011
9
5
5
5
5
115
73
42.5
108
37.3
6.38
6.89
9.55
6.7
10.5
3481
1801
163
221
71
13
5
6
5
5
198
63
56.7
26
20.2
6.73
6.72
6.68
6.5
8.28
152
2321
1271
791
14

.SUN 2 6 2014
Warsaw Feed Mill 2O10 Analytical Results BY:
Sample Collection Date I AVERAGE 1 12/31/2010 11/3/2010 10/14/2010 7/29/2010 3/2/2010 2/9/2010
Outfall #1
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #2
Oil & Grease (30 mg/L)
T55 (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #3
Oil & Grease (30 mg/L)
T55 (100 mg/L)
pH (6-9)
COD (120 mg/L)
NO FLOW
NO FLOW
5.20
5
6
5
5
129.06
38.3
222
163
168
6.75
5.58
7.31
7.36
264.601
143
5781
141
139
INOXIXOMA
5.00
5
5
5
5
5
44.92
38.6
23.9
62
49
36
7.96
7.86
6.91
9.25
7.8
178.831
1051
2231
2131
132
1 175
NO FLOW
5.17
6
5
5
5
5
76.83
42.8
81
51.2
135
126
6.85
6.9
6.43
6.91
7.16
170.67
153
303
182
150
188

Ir
Warsaw Feed Mill 2010 Analytical Results
Sample Collection Datel 1/21/20101
Outfall #1
Oil & Grease (30 mg/L) 5
T55 (100 mg/L) 54
pH (6-9)
COD (120 mg/L) 322
Outfall #2
Oil & Grease (30 mg/L) 5
TSS (100 mg/L) 60
pH (6-9)
COD (120 mg/L) 225
Outfall #3
Oil & Grease (30 mg/L) 5
TSS (100 mg/L) 25
pH (6-9)
COD (120 mg/L) 48

�EOV r
.SUN 2 6 2014
Warsaw Feed Mill 1009 Analytical Results RY• _
Sample Collection Date AVERAGE 12/2/2009 10/26/2009 9/30/2009 8/31/2009 7/27/2009 — 6/15/20 079
Outfall #1
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #2
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
Outfall #3
Oil & Grease (30 mg/L)
TSS (100 mg/L)
pH (6-9)
COD (120 mg/L)
NO FLOW NO FLOW
NO FLOW NO FLOW
8.40
5
5
5
5
89.80
41
18
126
114
8.14
202.001
132
1001
1 2151
149
NO FLOW NO FLOW
5M
5
5
5
5
88.00
194
68
25
116
7.21
157.801
152
2021
541
169