WQ0028653_WQ0028653_2021 Annual Report Review_02.09.2022_20220209

February 9, 2022
Daniel Shaw – Complex Manager
Pilgrim’s Pride Corporation
484 Zimmerman Road
Sanford, NC 27330
Subject: Permit No. WQ0028653
Pilgrim’s Pride – Sanford DCAR
Distribution of Class A Residuals
Lee County
Daniel Shaw,
On February 9, 2022 Chris Smith of the Raleigh Regional Office reviewed the 2021 Annual Land
Application Report for permit WQ0028653. The annual report was received on February 2, 2022. The
report was prepared by Branch Residuals & Soils LLC. The above permit covers distribution of residuals
generated at a water treatment facility located at the Pilgrim's Pride facility in Sanford, NC.
According to the 2021 Annual Report, a total of 995,300 gallons, or 53.3 dry tons of alum residuals were
land applied to sites located at the facility. This amount is below the permit limit of 300 dry tons per
year. Permit WQ0028653 is a residuals distribution permit, but the facility is handling the residuals as if
it were a dedicated land application permit.
Residual sampling is required annually and was conducted on August 19, 2021. Analyses for metals and
nutrients were conducted as required by Waypoint Analytical. Metals results are under Ceiling
Concentration Limits. TCLP analyses are required once per permit cycle. Previous annual report reviews
indicate TCLP analyses were conducted as required by Research and Analytical Laboratories, Inc. and are
compliant with federal limits where applicable.
Pathogen reduction requirements were met using a fecal coliform analysis quantified by Most Probable
Number (MPN/G). This analysis was conducted by Environmental Chemists, Inc. Vector Attraction
Reduction is not required for non-biological residuals of the sort generated by this facility.
A representative soil analysis was not included in the annual report. The report preparer indicated the
soils analysis lab results had not been received at the time of report submittal. While a soil analysis is
not required by the permit, lab results for aluminum in the residuals appear high (95700 mg/kg) and it
would be advisable to monitor soil aluminum levels. If the current application areas become unsuitable
for land application of residuals, the permittee has the option of finding new application areas due to
the distribution language in the permit.
The Residuals Annual Report was received on time and in the proper format. At the time of the report
review the facility appeared compliant with the annual report requirement.

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Sincerely,

Vanessa Manuel
Assistant Regional Supervisor
Water Quality Regional Operations Raleigh Regional Office

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