NCG060102_CEI_20191210

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Perdue Foods, LLC
Attn: Edward Greene, Feedmill Manager
PO Box 550
Candor, NC 27229
NORTH CAROLINA
Environmental Quality
December 10, 2019
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG060000
Perdue Foods, LLC
Candor Feedmill / Eagle Springs Facility, Certificate of Coverage NCG060102
Moore County
Dear Mr. Greene:
On December 5, 2019, a site inspection was conducted for the Candor Feedmill / Eagle Springs Facility located off NC
Highway 211 East in Moore County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your
review. Along with yourself, Mr. Gordon Sessoms was also present during the inspection and both your and his 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 NCG060102. Permit coverage authorizes the
discharge of stormwater from the facility to receiving waters designated as Drowning Creek, a class WS-II;Sw,HQW
waterbody in the Lumber River Basin.
As a result of the inspection, the facility was found to be in compliance 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 [phone] or via e-mail at
[e-mail].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure: Compliance Inspection Report
cc: FRO — DEMLR, Stormwater Files
North Carolina Department of Environmental Quality I Division of Energy. Mineral and Land Resources
A .� ,�/jj Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
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Compliance Inspection Report
Permit: NCG060102 Effective: 11/01/18 Expiration: 05/31/21 Owner: Perdue Agribusiness LLC
SOC: Effective: Expiration: Facility: Candor Feed Mill / Eagle Springs Facility
NC Hwy 211 E
County: Moore
Region: Fayetteville
Eagle Springs NC 27242
Contact Person: Paul Bruce Roberts Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Certification:
On -site representative Edward Greene
Related Permits:
Inspection Date: 12/05/2019 EntryTime: 10:OOAM
Primary Inspector: Mike Lawyer
Secondary Inspector(s):
Phone:
910-673-4148 ext 18
Exit Time: 12:45PM
Phone: [phone]
Penny Markle `PAA
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 of 3

Permit: NCG060102 Owner - Facility: Perdue Agribusiness LLC
Inspection Date: 12/05/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Edward Greene, Feedmill Manager, and Gordon Sessoms, Clerk. Reviewed facility's Stormwater Pollution
Prevention Plan (SPPP) and monitoring records from 2016 to 2019. The SPPP contained all permit -required components as
well as supporting documentation related to spill prevention and response, housekeeping practices, employee training, etc.
It was recommended at the time of inspection that the facility's detailed site map be revised/updated to more clearly depict
the required information listed in Part II, Section A, item 1(c) of the NCG060000 permit. Although the facility's monthly
self -inspection records indicate various observations of outfalls, it was recommended that facility personnel complete
specific documentation/forms related to the annual non-stormwater certification. Upon reviewing analytical monitoring
records for outfall #1, there were consecutive exceedances of the benchmark value for TSS in 2017, however Tier Two
monthly monitoring was not initiated. Semi-annual monitoring conducted in 2018 and 2019 also showed occasional
exceedances of the benchmark value for TSS and COD, but not consecutively. Monitoring records for outfall #2 indicated no
discharges. During. site observations of facility grounds, it was determined that outfall #1 primarily receives boiler blowdown
discharges, which are covered and monitored under a General Wastewater Permit (Certificate of Coverage NCG500021).
This means that all previous stormwater monitoring results at this outfall, including the consecutive exceedances of the
benchmark value for TSS in 2017, were not representative of stormwater only discharges as any stormwater flow would be
commingled with boiler blowdown wastewater flow. This also likely accounts for the elevated levels of COD in the 2018 and
2019 stormwater monitoring. Based on these observations, Mr. Greene was advised to re -designate stormwater outfall #1 as
wastewater outfall #1 to be monitored in accordance with the facility's General Wastewater Permit coverage for boiler
blowdown discharges. Likewise, stormwater outfall #2 would be re -designated as stormwater outfall #1 and monitored in
accordance with the facility's General Stormwater Permit coverage.
Page 2 of 3

Permit: NCG060102 Owner - Facility: Perdue Agribusiness LLC
Inspection Date: 12/05/2019 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?
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ❑ ❑
# 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)?
E
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
N
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0
❑ ❑ ❑
Comment: Recommend that the detailed site map be revised/updated to more clearly
depict all information
as required by Part II, Section A, item 1(c) of the NCG060000 permit.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
E
❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? E ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 ❑ ❑ ❑
Comment: See the Inspection Summary for more detailed information regarding monitoring.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? N ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3