NCG060143_Email Response from WiRO to Tier 3 Action Plan_20220104

Georgoulias, Bethany
From: Lambe, Brian
Sent: Tuesday, January 4, 2022 2:17 PM
To: Haynes, Matthew
Cc: Lanier, Corey; White, Paul; Sams, Dan; Georgoulias, Bethany; Morman, Alaina; Carson,
Brittany
Subject: RE: [External] Fwd: Emailing: Storm Water compliance evaluation inspection
12-29-21.pdf
Attachments: sampling data.xlsx
Valley Proteins submitted an action plan to this office December 29, 2021 in a Tier III response for sampling results from
July 2021 to November 2021. The permit cycle began 7/1/2021.
The facility submitted a DMR for 7/2/2021 documenting that they are in Tier II response. However, tier responses do not
reset from previous permit terms. Preliminary data review reveals that Outfall 3 had 4 TSS exceedances from
12/13/2016 to 12/14/2020. Outfall 3 is consistently exceeding benchmarks for COD (lowest is 117 on 2/16/2019). Outfall
4 has exceeded the benchmark for TSS 4 times in the previous permit term, and is consistently exceeding the COD
benchmark. Outfall 3 and 4 must be in Tier III for COD and TSS dating back to the previous permit. Provide this office
with previous Tier III action plan if available. If not, submit Tier II responses to this office.
On a side note, in review of the data, often in 2018 and 2017, no flow was documented for Outfall 3 and 4, possibly from
sampling protocols. Outfall 4 is inundated by the adjacent swamp.
The proposed action plan outlines BMPs for outfall 3 including periodic pumping of the settling chambers, street
sweeping, pressure washing, and frequent inspection of raw material trailer staging area to identify leaking containers.
The action plan proposes to increase frequency of pumping chambers, street sweeping, inspections, and with an
renewed focus on employee training. Outfall 4 is similar in increased frequency at key locations including raw material
staging areas, raw material ramp, containment areas and roof drains.
The proposed increases in frequency must be measurable. Documentation of the proposed actions should be recorded
in the SPPP. Submit the blank inspection forms to this office. Submit a map of inspection areas.
There is a lack of mechanical barriers for reduction of pollutants in the submitted action plan. The concrete settling
chambers are a good pretreatment for Outfall 3, and increased maintenance may be the answer, but Outfall 4 does not
have the same benefit of the outfall 3 (Outfall 3 is a stormwater basin). Outfall 4 is a ditch with multiple inputs. Describe
pretreatment for the ditch in greater detail and possible improvements.
In response to the cover letter included with the action plan, disagreement in the analytical sampling requirements were
put forth. The reason the monitoring was out of compliance with the permit is the Tier classification and responses. You
say in the letter that the response form has been updated. Please submit tier response inspection form to this office for
review.
In the letter, you argue that the facility is not required to sample for fecal coliform, providing a memo that tries to clarify
the definition of facilities that process meats. This definition is a source of constant debate. However, I am not calling for
any changes in protocols or permits. During the inspection, I proposed the fecal sampling a way to identify differences
between the swamp and the facility discharge. Valley Proteins offered that the swamp may be contributing to the high
numbers in outfall 4. COD is a good indicator of pollution, but fecal coliform may help indicate if the cause is from the
plant. I also requested additional downstream sampling in the swamp, but you did not include that plan in the action
plan. If there are better ways to identify pollutants coming from the site, please propose in the action plan.

I am still requesting that you fill out the ROS form again, and you should include proposal to eliminate outfall 1.
At this time, the action plan is insufficient to adequately reduce pollution in the stormwater at the Valley Proteins Rose
Hill plant. Please revise and submit by January 31, 2022. Please include any actions already taken. If you have any
questions, please do not hesitate to call, email, or set up a meeting onsite.
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington, NC 28405
910 796 7215 T 1 910 350 2004 F I http://portal.ncdenr.org/web/Ir/
-----Original Message -----
From: Haynes, Matthew [mailto:[e-mail]]
Sent: Thursday, December 30, 2021 9:55 AM
To: Lambe, Brian <[e-mail]>
Cc: Lanier, Corey <[e-mail]>; White, Paul <[e-mail]>
Subject: [External] Fwd: Emailing: Storm Water compliance evaluation inspection 12-29-21.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spa m.<mailto:[e-mail]>
Mr. Lambe,
The attached document has been mailed to the Wilmington Regional Office in response to your recent inspection report.
Thanks.
Matt
Begin forwarded message:
From: "White, Paul" <[e-mail]>
Date: December 29, 2021 at 4:20:27 PM EST
To: "Haynes, Matthew" <[e-mail]>
Cc: "Lanier, Corey" <[e-mail]>, "Ortiz, Ashley" <[e-mail]>
Subject: Emailing: Storm Water compliance evaluation inspection 12-29-21.pdf
We will get it in the mail for overnight delivery tomorrow. thanks
The information transmitted herewith is confidential, proprietary information for use only by the addressee to whom it
was supplied. This information is not to be disclosed to any person or entity not employed by the addressee company,
and requiring the information to perform their job without the express written consent of Valley Proteins, Inc.

Outfall 3
10/28/2015
12/13/2016
3/28/2017
5/5/2017
6/8/2017
12/8/2017
5/30/2018
8/30/2018
9/11/2018
2/16/2019
3/26/2019
4/2/2019
5/1/2019
12/17/2019
1/5/2020
2/16/2019
3/25/2020
4/13/2020
5/19/2020
11/11/2020
12/14/2020
Oil and Grease-30
8.54
14.2
43
7.6
5
9
0
0
0
18
0
11
ND
8
0
0
12
11
0
0
8.7
TSS-100
31.3
596
63
26
80
115
73.8
71
23.7
57
32.5
38.7
ND
32.2
24.7
24
121
63
39
453
65.7
COD-120
234
148
300
359
219
258
372
350
218
326
231
138
ND
142
261
117
299
326
342
850
364
Outfall 4
Oil and Grease
TSS
COD
10/28/2015
5.53
11.7
92.7
12/13/2016
16
52
144
3/28/2017
13
12
105
5/5/2017
0
26
359
6/8/2017
nd
nd
nd
12/8/2017
nd
nd
nd
5/30/2018
nd
nd
nd
8/30/2018
ND
ND
ND
9/11/2018
No Discharge
ND
ND
2/16/2019
13
97.9
326
3/26/2019
21
53.3
366
4/2/2019
23
189
303
5/1/2019
ND
ND
ND

12/17/2019
0
20
292
1/13/2020
0
4.9
87
2/14/2020
0
11
113
3/25/2020
11
200
303
4/13/2020
19
249
412
5/19/2020
12.9
124
391
11/11/2020
0
41
188
12/14/2020
6.8
31.5
155