WQ0004075_Staff Report_20220601

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Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: W00004075
Attn: Cord Anthony Facility name: Pender Packing Company
From: Steve West
Wilmington Regional Office
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 5/20/22
b. Site visit conducted by: Steve West
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Marty Fritz (910) 319 - 0037
e. Driving directions: 4520 NC Hwy 133, Rocky Point
2. Discharge Point(s): N/A
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS -N/A
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Marty Fritz Certificate #: 995923 Backup ORC: Chad Watkins Certificate #:995927
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or n No
If no, please explain:
Description of existing facilities: Pender Packing Company packages fresh pork products for distribution to area
grocery stores and restaurants. Wastewater consists mainly of equipment wash water. The flow path differs
from the description in the current permit. The wastewater from the packaging building flows into an 800 gallon
grease trap, then to three septic tanks in series (800/1000/1000 gal), then to two holding tanks in series
(4320/1000 gal). Approximately 70% (or 5300 gpd) of the wastewater that reaches the holding tanks flows by
gravity to a CFPUA pump station located across NC Hwy 133. Pender packing uses its own 1600 gal pump truck
to pump the remaining wastewater from the two holding tanks and then transports to the off -site irrigation pond.
These two tanks are pumped 4-5 times per week at 1600 gallons per trip. The grease trap and solids from the
septic tanks are pumped by Lewis Farms every two weeks at 6000 gallons per trip. There is no active duplex
pump station on site as described in the permit. Wastewater flows by gravity from the site holding tanks to the
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DocuSign Envelope ID: 003DCF6A-103F-44C1-BC7B-8F04A68C63E4
CFPUA pump station across the road. The off -site pond, irrigation system and field are as described in the
current permit.
Proposed flow: N/A
Current permitted flow: 4000 gpd
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.) There is no permit specification or requirement for an irrigation crop to be used, and no corresponding
agronomic rate limits. The permit's required `Field Management Plan' mentions use of
fescue/Bermuda/bahia/winter rye, which from observation from the visit, appears pretty accurate. There are few
weeds and no dead areas or indications of ponding which indicate good field management. Annual field soil
samples are not being collected as required in the permit. It is recommended that the permit contain a requirement
to have an agronomist review the site conditions and soil sample results every 2-3 years and make
recommendations for improvements to the site as needed. The property is owned by the company owner and
public access is restricted.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
If no, please explain: From appearance, yes, but there were no soil sample results to review
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ® Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ® No
If no, please explain: See above
10. Were monitoring wells properly constructed and located? ® Yes ❑ No n N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or n No
Please summarize any findings resulting from this review: There are no water quality limits except for the
monitoring wells, which showed no violations over the last two years and no concerning trends. Although
effluent (irrigation) fecal coliform results are typically high, there is no current permit limit. It was noted during
the visit that the chlorination system was not functioning and will be addressed in the inspection report. Effluent
SAR results appear high, but without an agronomist's recommendations, it is difficult to determine the
ramifications of these results nor the sodium and chloride results.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. N/A
13. Are there any permit changes needed in order to address ongoing BIMS violations? n Yes or ® No
If yes, please explain:
14. Check all that apply:
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❑ No compliance issues
Z Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
n Currently under SOC n Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) NOV
for the inspection is pending due to the lack of soils testing, missing hauling records, irrigation calibration, and
chlorination system status
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? N/A
Have all compliance dates/conditions in the existing permit been satisfied? Yes ❑ No ❑ N/A
If no, please explain: Permit schedule item no. 1 has been met
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
16. Possible toxic impacts to surface waters: N/A
17. Pretreatment Program (POTWs only): N/A
REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request.
Item
Reason
New map
Current map is difficult to read and doesn't delineate the three irrigation areas.
Also can't find anything in the permit that shows or describes the locations of the
US/DS sample sites
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Soil samples and
agronomist report within 60
days. Requirement for an
agronomist to periodically
review site conditions and
make recommendations
High effluent salt content and lack of soil results/interpretation of soil results
5. Recommendation: n Hold, pending receipt and review of additional information by regional office
n Hold, pending review of draft permit by regional office
n Issue upon receipt of needed additional information
® Issue
Deny (Please state reasons: )
FORM: WQROSSR 04-14
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DocuSign Envelope ID: 003DCF6A-103F-44C1-BC7B-8F04A68C63E4
DocuSigned by:
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6. Signature of report preparer:
Signature of regional supervisor:
Date:
6/1/2022
—DocuSigned by:
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IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Envirochem lab collects the effluent, MW and US/DS samples. Waiting to hear from the ORC where the US/DS
samples have been collected. Then a determination can be made regarding the locations and if they need to be
changed
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