NC0072575_2024 Compliance Evaluation Inspection_20240223

February 23rd, 2024

Daniel Shaw
Pilgrim’s Pride Corporation
484 Zimmerman Road
Sanford, NC 27330

Subject: Compliance Evaluation Inspection
Sanford Processing Plant
NPDES Permit NC0072575
Lee County

Dear Mr. Shaw:

On Wednesday, February 21st, 2024, Kevin Fowler conducted a compliance evaluation
inspection of the treatment systems located at Sanford Processing Plant. The purpose of this visit
was to conduct an inspection of the subject NPDES facility. During the inspection, the presence
and cooperation of Tina Pedley, Operator in Responsible Charge (ORC), and Dennis Lopez
Sumpter were greatly appreciated.

The Sanford Processing Plant is located at 484 Zimmerman Road, Sanford, North Carolina
27330 in Lee County. The plant has an Industrial Process & Commercial Wastewater Discharge
permit.

This NPDES compliance evaluation inspection consisted of the following:
 Review of the NPDES permit;
 Review of the owner/facility information;
 Review of February 2023 – February 2024 monitoring data.
 Review of February 2022 – February 2024 compliance history.
 On-site inspection of the treatment systems; and
 On-site inspection of the discharge outfall and receiving waters.

DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
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Sanford Processing Plant
Compliance Inspection 2024
2
Findings during the pre-inspection file review were:

1. Through NPDES permit NC0072575, Sanford Processing Plant is authorized to discharge
treated wastewater from the plant to the Deep River, which is classified as Class-C waters in
the Cape Fear River Basin. The current NPDES permit was issued effective May 1, 2021,
and will expire April 30, 2026. An application for renewal of this permit should be submitted
no less than six months before the expiration of the current permit.
2. The plant provides treatment and discharge of wastewater through outfall pipe 001 to the
Deep River. The plant is permitted to discharge at a monthly average rate of 1.0 MGD. The
system consists of: a solids screening area, one equalization tank, one anaerobic treatment
lagoon, a methane incinerator, aeration basin, tertiary filter, backwash pump station,
emergency storage pond, chlorine contact basin, dichlorination contact chamber, Parshall
flume effluent flow meter, composite sampler, cascade post aeration at the out fall, and one
belt filter press with waste tank.
3. For the review period February 2022 – December 2024, 1 limit violation for BOD, and 1
monitoring violation for Total Hardness were found. No Civil Penalty Assessments were
issued for these violations.

Findings during the inspection were:

4. The operator’s log and supporting analytical documentation were consistent and up to date.
5. DMR reports from November 2023, and July 2023 were brought to be compared to
laboratory analytical results. No discrepancies were found.
6. The facility has an onsite laboratory to analyze pH, DO, and Chlorine. Equipment is
calibrated regularly with an outside contractor. Other parameters are analyzed by a
contracted lab (Cameron Testing Services.)
7. The facility has added a backup generator located near the treatment units. This addition is
not currently in the permit. ORC indicated that this powers everything except the belt press.
8. Anerobic treatment lagoon is covered so visual inspection inside lagoon was not possible.
Methane gas from this lagoon is sent to the methane incinerator.
9. Aeration basin has rotating arm/bridge with diffused air blowers attached to it. Average DO
at time of inspection was 2.5mg/l.
10. Mixed liquor from the aeration basin is pumped to the secondary clarifier. At the time of
inspection, sludge blanket was normal (3 ½ feet blanket in the 13 feet deep clarifier). RAS
pumps are available to return to the aeration basin. Wasted sludge can be sent to the waste
tank.
11. Tertiary filters are “Fuzzy Filters.” These are medium size sponge like objects that float in
tank to filter effluent.
12. Plant has switched to using liquid disinfection; however, gas disinfection is kept as a backup.
Storage of all materials for both systems was adequate.
13. The right of way to Outfall 001 was well maintained. No evidence of solids or visible
environmental impacts were noted at Outfall 001. Last inspection noted brown tinted
effluent; however, the effluent during time of this inspection was clear. ORC indicated last
inspection effluent color was later found to be caused by malfunctioning tertiary filters.
14. The belt press appeared to be very clean and well maintained. McGill compost is contracted
to remove wasted sludge from the plant. ORC indicated that they are typically very timely in
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
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Sanford Processing Plant
Compliance Inspection 2024
3
removing the sludge. The ORC did indicate that they have a second trailer on hand if they
ever had to store sludge for a period of time.

If you have questions or comments about the inspection, this report or the requirements to take
corrective action (if applicable), please contact Kevin Fowler at 919-437-0047 or via email at
[e-mail]

Sincerely,

Vanessa Manuel
Water Quality Regional Assistant Supervisor
Raleigh Regional Office

Attachments: EPA Water Compliance Inspection Report

Cc: Laserfische
Tina Pedley (ORC)
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 N 52 NC0072575 24/02/21 C S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Sanford Processing Plant
484 Zimmerman Rd
Sanford NC 27330
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
12:00PM 24/02/21 21/05/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Tina Marie Pedley/ORC/919-498-4471/
Other Facility Data
02:15PM 24/02/21 26/04/30
Name, Address of Responsible Official/Title/Phone and Fax Number
Tina Pedley,484 Zimmerman Rd Sanford NC 273304260//919-895-3457/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Kevin Fowler DWR/RRO WQ/919-791-4200/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
02/26/2024
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
2/27/2024
NPDES yr/mo/day
24/02/21
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
System appeared to be in good shape and compliant at time of inspection. New standby generator
had been installed which may need to be included in a future permit.
NC0072575 17
Page#2
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
Permit:NC0072575
Inspection Date:02/21/2024
Owner - Facility:
Inspection Type:
Sanford Processing Plant
Compliance Evaluation
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Cameron Testing Services Lab 654Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Facility test for pH, DO, Chrlorine onsite.Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
New standby power has been installed.Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain-of-custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Page#3
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
Permit:NC0072575
Inspection Date:02/21/2024
Owner - Facility:
Inspection Type:
Sanford Processing Plant
Compliance Evaluation
Record Keeping Yes No NA NE
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment:
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Last calibrated 2/5/2024. Calibrated every 6 months.Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Solids screening and seperation area for animal product.Comment:
Chemical Feed Yes No NA NE
Is containment adequate?
Page#4
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
Permit:NC0072575
Inspection Date:02/21/2024
Owner - Facility:
Inspection Type:
Sanford Processing Plant
Compliance Evaluation
Chemical Feed Yes No NA NE
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
DisinfectionComment:
Pump Station - Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Comment:
Equalization Basins Yes No NA NE
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Page#5
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
Permit:NC0072575
Inspection Date:02/21/2024
Owner - Facility:
Inspection Type:
Sanford Processing Plant
Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth)
Clarifier was 13 feet deep (had 3 and a half foot blanket.) Covers around weir had
been put in place to prevent algae growth.
Comment:
Aeration Basins Yes No NA NE
Mode of operation
Type of aeration system Diffused
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin’s surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/l)
DO average level was 2.5mg/lComment:
Filtration (High Rate Tertiary)Yes No NA NE
Type of operation:
Is the filter media present?
Is the filter surface free of clogging?
Is the filter free of growth?
Is the air scour operational?
Is the scouring acceptable?
Is the clear well free of excessive solids and filter media?
Fuzzy filterComment:
Disinfection-Gas Yes No NA NE
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Page#6
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
Permit:NC0072575
Inspection Date:02/21/2024
Owner - Facility:
Inspection Type:
Sanford Processing Plant
Compliance Evaluation
Disinfection-Gas Yes No NA NE
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de-chlorination?
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No.
7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000-____-____)
If yes, then when was the RMP last updated?
Used as backup to liquid chemical feedComment:
De-chlorination Yes No NA NE
Type of system ?Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de-chlorination substance stored away from chlorine containers?
Comment:
Are the tablets the proper size and type?
Are tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Standby Power Yes No NA NE
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up
power?
Is the generator fuel level monitored?
Newly installed generator. Tested weekly under loadComment:
Pumps-RAS-WAS Yes No NA NE
Page#7
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
Permit:NC0072575
Inspection Date:02/21/2024
Owner - Facility:
Inspection Type:
Sanford Processing Plant
Compliance Evaluation
Pumps-RAS-WAS Yes No NA NE
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
Lagoons Yes No NA NE
Type of lagoons?Anaerobic
# Number of lagoons in operation at time of visit?1
Are lagoons operated in?
# Is a re-circulation line present?
Is lagoon free of excessive floating materials?
# Are baffles between ponds or effluent baffles adjustable?
Are dike slopes clear of woody vegetation?
Are weeds controlled around the edge of the lagoon?
Are dikes free of seepage?
Are dikes free of erosion?
Are dikes free of burrowing animals?
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple
locations?
# If excessive algae is present, has barley straw been used to help control the growth?
Is the lagoon surface free of weeds?
Is the lagoon free of short circuiting?
Lagoon surface is covered. Methane gas is collected and sent to incinerator.Comment:
Disinfection-Liquid Yes No NA NE
Is there adequate reserve supply of disinfectant?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de-chlorination?
Comment:
Page#8
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B
Permit:NC0072575
Inspection Date:02/21/2024
Owner - Facility:
Inspection Type:
Sanford Processing Plant
Compliance Evaluation
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type,
and sampling location)?
Upstream/Downstream are provisionally waived based on the permittees membership
in the Upper Cape Fear River Basin Association.
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Calibrated every 6 months.Comment:
Solids Handling Equipment Yes No NA NE
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
One belt filter press with waste tank. Solids are removed by McGill compostComment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Step aeration to rip rap present.Comment:
Page#9
DocuSign Envelope ID: FA42FB94-1A67-4775-9498-D87D6A8CE55B