WQ0005681_Staff Report_20200506

DocuSign Envelope ID: 713013E50-1 D91-491 F-A31 C-511 BED5513544
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May 6, 2020
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00005861
Attn: Poonam Giri Facility name: Pilgrim's Pride — Staley Wastewater Irri.ag tion
From: Patrick Mitchell
Winston-Salem Regional Office
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: May 5, 2020
b. Site visit conducted by: P. Mitchell & C. Caudle
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Melissa Achterman and their contact information: (919) 599 - 1295
e. Driving directions: See file.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
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.): The second tablet chlorinator is located on the outlet pipe to the effluent storage lagoon, on the inside edge
of the treatment lagoon. The tablet chlorinator needs to be replaced. The Permittee is planningto o replace this with
a like Norweco-3000 tablet chlorinator on the same outlet pipe which flows into the effluent storage_lagoon.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
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
5. Is the residuals management plan adequate? ® Yes or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
Note: Reported irrigation rates and effluent PAN concentration indicates agronomic loading of —67 lbs. of
PAN/acre/year. This is below the agronomic limit of the crops present in the spray field.
7. Is the existing groundwater monitoring program adequate? ® Yes ❑ No ❑ N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ® No
Explain: There is an effluent flow meter present on the system just prior to the WWTF, there is an irrigation
pumphouse that includes a 15 HP Baldor Irrigation Pump, a''/z HP Myers Priming Pump, and an effluent flow
meter. None of these items are listed in the permit description in the current permit.
10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
FORM: WQROSSR 04-14 Page 1 of 3

DocuSign Envelope ID: 713013E50-1D91-491F-A31C-511BED55B544
11. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ❑ Yes or ❑ No
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
14. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑Yes®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: )
,--Docuftned by:
Signature of report preparer:
Signature of regional supervisor:
Date: May 6, 2020
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
145B49E225C94EA...
On May 5, 2020, WSRO staff conducted a site visit for review associated with the application for permit renewal.
Melissa Achterman and Tina Pedley accompanied staff on the site visit. The system appears to be well maintained and
in good working order. Below is a summary of notes from observations made during the site visit. WSRO will follow-
up on these items during compliance inspections.
1. The vegetation in the spray field was too high to review the field in detail. Reportedly the hay crop is to be
mowed as soon as conditions allow. WSRO staff to do a follow-up review when crops are mowed, and a more
detailed review is possible.
2. The SAR values reported in NDMR reports are slightly elevated (i.e. elevated values as high as 6.5). The most
recent three years soils reports indicate slightly elevated ESP (i.e. elevated values reported range from 4 — 6).
No visual evidence of impacts to the spray field (healthy vegetative cover present and no obvious signs of runoff
or ponding). WSRO staff to do a follow-up review when crops are mowed, and a more detailed review is
possible. Recommend that an auger or soil probe be used to review the topsoil for any potential impacts.
3. Effluent sampling is reportedly conducted by R&A Labs, and samples are collected via a dipper from the
effluent storage lagoon. Recommended Permittee ensure that lagoon samples are composite and not grab
samples to ensure representative sampling occurs. Recommend that a split sample or compliance sample event
be considered at some point.
FORM: WQROSSR 04-14 Page 2 of 3

DocuSign Envelope ID: 713013E50-1D91-491F-A31C-511BED55B544
4. Groundwater sampling is reportedly conducted by R&A Labs. Recommend that a split sample event be
scheduled at some point to review well prep and sampling procedures.
5. Sludge was building up in the sludge storage basin of the WWTP and starting to spill over into the clarifier. A
minor amount of sludge was present in the weirs and in the treated effluent trough. Reportedly sludge is schedule
to be pumped out and waiting on sludge hauler. WSRO staff to do a follow-up inspection to ensure appropriate
sludge removal is occurring. Agronomic loading is —67 lbs PAN/acre/year and SAR values have been slightly
elevated; if sludge is not removed, additional nutrients and other solids may be loaded to the field resulting in
increased PAN and sodium application rates near or in excess of limits.
6. Irrigation operations are run on an automatic solenoid switch that rotates irrigation such that all five of the
irrigation lanes are dosed one following the other with every irrigation event (i.e. 100% of the field is dosed
with each irrigation event). Reportedly this is the primary use and only during rare occasions (e.g. a popup
rainstorm or during repairs to one lane) is the system shut down during an event or the entire field is not irrigated.
7. The system currently is manually operated. The Permittee is considering some upgrades to electrical controls
to allow automated operations at some point in the future. Reminded Permittee that permit modification would
be necessary prior to changes to the system, and that installation of a rain sensor would be required if irrigation
is not manually conducted. Reportedly Permittee does not have plans at this point, it is just a consideration.
FORM: WQROSSR 04-14 Page 3 of 3

Compliance Inspection Report
Permit: WQ0005681 Effective: 11/01/15 Expiration: 10/31/20 Owner: Pilgrim's Pride Corporation
SOC: Effective: Expiration: Facility: Staley Hatchery & Feed Mill
County: Randolph 2607 Old 421 Rd
Region: Winston-Salem
Staley NC 27355
Contact Person: Tina Pedley Title: Phone: [phone]
Directions to Facility:
from winston-salem take 1-40 to greensboro and take US 421 south. From US 421, take old US 421 to staley by taking a right off
the exit ramp. The second entrance on the right will take you to the gold kist office, hatchery, and feed mills.
System Classifications: SI, WW2,
Primary ORC: Melissa Corinne Harshman Certification: 1001745 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/05/2020 Entry Time 09:30AM
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Caitlin Caudle
Reason for Inspection: Other
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Exit Time: 11:OOAM
Phone: [phone]
Inspection Type: Reconnaissance
Z Neither
Page 1 of 3

Permit: WQ0005681 Owner - Facility: Pilgrim's Pride Corporation
Inspection Date: 05/05/2020 Inspection Type : Reconnaissance Reason for Visit: Other
Inspection Summary:
On May 5, 2020, WSRO staff conducted a site visit for review associated with the application for permit renewal. Melissa
Achterman and Tina Pedley accompanied staff on the site visit. The system appears to be well maintained and in good
working order. However, the items listed below require follow-up.
1. The vegetation in the spray field was too high to review the field in detail. Reportedly the hay crop is to be mowed as soon
as conditions allow. WSRO staff to do a follow-up review when crops are mowed, and a more detailed review is possible.
2. The SAR values reported in NDMR reports are slightly elevated (i.e. elevated values as high as 6.5). The most recent
three years soils reports indicate slightly elevated ESP (i.e. elevated values reported range from 4 — 6). No visual evidence of
impacts to the spray field (healthy vegetative cover present and no obvious signs of runoff or ponding). WSRO staff to do a
follow-up review when crops are mowed, and a more detailed review is possible. Recommend that an auger or soil probe be
used to review the topsoil for any potential impacts.
3. Effluent sampling is reportedly conducted by R&A Labs, and samples are collected via a dipper from the effluent storage
lagoon. Recommended Permittee ensure that lagoon samples are composite and not grab samples to ensure representative
sampling occurs. Recommend that a split sample or compliance sample event be considered at some point.
4. Groundwater sampling is reportedly conducted by R&A Labs. Recommend that a split sample event be scheduled at
some point to review well prep and sampling procedures.
5. Sludge was building up in the sludge storage basin of the WWTP and starting to spill over into the clarifier. A minor
amount of sludge was present in the weirs and in the treated effluent trough. Reportedly sludge is schedule to be pumped
out and waiting on sludge hauler. WSRO staff to do a follow-up inspection to ensure appropriate sludge removal is occurring.
Agronomic loading is —67 Ibs PAN/acre/year and SAR values have been slightly elevated; if sludge is not removed, additional
nutrients and other solids may be loaded to the field resulting in increased PAN and sodium application rates near or in
excess of limits.
6. Irrigation operations are run on an automatic solenoid switch that rotates irrigation such that all five of the irrigation lanes
are dosed one following the other with every irrigation event (i.e. 100% of the field is dosed with each irrigation event).
Reportedly this is the primary use and only during rare occasions (e.g. a popup rainstorm or during repairs to one lane) is
the system shut down during an event or the entire field is not irrigated.
7. The system currently is manually operated. The Permittee is considering some upgrades to electrical controls to allow
automated operations at some point in the future. Reminded Permittee that permit modification would be necessary prior to
changes to the system, and that installation of a rain sensor would be required if irrigation is not manually conducted.
Reportedly Permittee does not have plans at this point, it is just a consideration.
Page 2 of 3

Permit: WQ0005681 Owner - Facility: Pilgrim's Pride Corporation
Inspection Date: 05/05/2020 Inspection Type : Reconnaissance
Reason for Visit: Other
Type
Yes No NA NE
Reuse (Quality)
❑
Single Family Spray, LR
❑
Infiltration System
❑
Recycle/Reuse
❑
Lagoon Spray, LR
❑
Activated Sludge Drip, LR
❑
Activated Sludge Spray, HR
❑
Single Family Drip
❑
Activated Sludge Spray, LR
Page 3 of 3

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