NCG500021_Inspection_20100806

ATA
NCDEN
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue - Coleen H. Sullins Dee Freeman
Governor - Director Secretary
August 6, 2010
Edward Greene
Manager, Candor Feedmill
Perdue Farms, Inc.
P.O. Box 550
Candor, NC 27229
SUBJECT: Compliance Evaluation Inspection
Perdue Farms, Inc., Eagle Springs facility
NPDES Permit NCG500021
Moore County
Dear Mr. Greene,
Enclosed you will find a copy of the report for the July 20, 2010 Compliance Evaluation
Inspection that was conducted with your assistance, as well as that of Allen Johnson (Complex
Environmental Manager) and Frederick Thomen (Complex Environmental Manager). Your
cooperation was greatly appreciated. As according to your explanation during this CEI, it
appeared that there were two types of wastewaters (Air Compressor Condensate and Boiler
Blowdown) that were covered by permit # NCG500021 at the Perdue Farms Eagle Springs
facility. It was understood by this inspector that there was not Cooling Tower Blowdown
wastewater, nor Non -Contact Cooling water. The Air Compressor Condensate wastewater and
automatic Boiler Blowdown commingled in a catch basin, then flowed (via an underground
culvert) to a "V" notch weir. Immediately downstream from the weir, it commingled with
stormwater in a drainage ditch that may be present after a rain event. The 001 Plant Outfall was
sampled at a location that was 100 to 300 meters downstream, at a point that was a few meters
before it flowed into a holding pond. After a retention time in the holding pond, it flowed to a
drainage ditch that later commingled with Drowning Creek. In an effort to control the
automatic Boiler Blowdown pH (which is normally in the pH range of 10 to 11), Perdue Farms
was considering the addition of a slow drip of citric acid to bring the pH to approximately pH 7
in the catch basin area, and periodically check the pH at the discharge over the "V" notch weir.
In the past, the pH measurements were performed by a color comparator method (which is not
an acceptable pH method for this NCG permit). Please refer to NCG500021, Part II, Section
D, 3, which states, in part, that "Test procedures...shall conform to...40 CFR 136". The pH test
procedures listed in 40 CFR 136 are the Electrometric measurement and the Automated electrode
methods. Please immediately adopt an Electrometric measurement method that will be capable
of a two -point slope calibration, or a three-point slope calibration. Enclosed with this CEI
report are two information sheets that may be useful for establishing good laboratory pH
measurement protocol at your facility.
225 Greer St., Suite 714, Fayetteville, NC 28301-5043
Phone: [phone] FAX: 9 i 0-486-0707 \ Customer Service: 1-877-623-6748
Internet: www,ncwaterquality.org
An Equal OpportunityAffirmative Action; Employer
_One.
Naturally

Mr. Greene
August 6, 2010
Page 2
The following self -monitoring reports were reviewed:
Date
Location
pH
Temperature
(Celsius)
Flow (gal/min)
when Boiler BD
05/06/2010
001
7.6
19
12
11/17/2009
001
7.4
14
14
06/30/2009
001
7.5
26
16
09/25/2008
001
7.8
17
16
Concerning your question about whether or not the Air Compressor Condensate may be diverted
to a conventional septic tank system at your facility, please consult with the Moore County
Environment Health Section for permission (phone number 910-947-6283), please also mention
that the Air Compressor Condensate wastewater flows through an Oil/Water Separator before it
would flow to the septic tank and that the historical data indicated very low Oil and Grease
values. Since chlorine was not used at this facility, the chorine testing was not required.
Biocides were also not used, and there was no need for the Biocide 101 Worksheet. Since the
commingled flow from the Air Compressor Condensate and the Boiler Blowdown flowed into
the stormwater drainage ditch (which would only have stormwater after a rain event), and since it
then flowed 100 to 300 meters to the Plant Outfall 001 location before it flowed into a holding
pond, it would not be required of this facility to sample for Upstream and Downstream
temperature. As according to NCG500021, Part I, A (1), 1: "Upstream and downstream
monitoring is not necessary if the discharge is to a receiving stream that does not contain any
flowing water at the time of discharge".
This was the first NCG500000 inspection at the facility, and the permit requirements
were not fully understood. For that reason, they were not implemented as intended by the
permit. It was this inspector's impression that with the guidance offered during the inspection
and with this report, clarification of the permit requirements was achieved. Please be aware
that it is the intention of this Office to perform a Compliance Evaluation Inspection at your
facility within our next fiscal year of inspections. At that time, the permit requirements will be
reviewed. If you have any questions or comments concerning this report or require clarification
on part(s) of this report or of the permit, please contact me at [phone].
Sincerely,
Dale Lopez
Environmental Special's
Enclosures: EPA Water Compliance Inspection Report
Example Field Parameter Worksheet (pH Analysis)
Technical Assistance for Field Analysis of pH
cc: +` FRO Files

United States Environmental Protection Agency
E PA 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
1 I NI 2 151 31 NCG500021 111 121 '10/07/20 117
Type Inspector Fac Type
181 cl 191 SI 20
1 1
11111111111111166
Remarks
2111111111 11111111 1 I I I 1 I 1 I 11111111
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --Reserved
671 2.0 169 70121 711 I 721 N I 73I 1 174 75I I I I I I I 180
`
Section B: Facility Data
Name and Location of FacilityInspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Eagle. Springs facility
NC Hwy 211 E
Eagle Springs NC 27242
Entry Time/Date
11:00 AM 10/07/20
Permit Effective Date
07/08/01
Exit Time/Date
02:00 PM 10/07/20
Permit Expiration Date
12/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Jimmiy A Davis,PO Box 1357 Rockingham NC 28379//910-997-8601/910997860
0
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Other
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) an re(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
pate
t 0 yJ ,r, OM
Dale Lopez FRO WQ//910-433-3300 Ext.712/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Da
,ems qtv/l b
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

31
NPDES yr/mo/day Inspection Type
NCG500021 I11 12I 10/07/20 117 18I C
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Enclosed you will find a copy of the report for the July 20, 2010 Compliance Evaluation Inspection that was
conducted with your assistance, as well as that of Allen Johnson (Complex Environmental Manager) and
Frederick Thomen (Complex Environmental Manager). Your cooperation was greatly appreciated. As
according to your explanation during this CEI, it appeared that there were two types of wastewaters (Air
Compressor Condensate and Boiler Blowdown) that were covered by permit # NCG500021 at the Perdue
Farms Eagle Springs facility. It was understood by this inspector that there was not Cooling Tower
Blowdown wastewater, nor Non -Contact Cooling water. The Air Compressor Condensate wastewater and
automatic Boiler Blowdown commingled in a catch basin, then flowed (via an underground culvert) to a "V"
notch weir. Immediately downstream from the weir, it commingled with stormwater in a drainage ditch that
may be present after a rain event. The 001 Plant Outfall was sampled at a location that was 100 to 300
meters downstream, at a point that was a few meters before it flowed into a holding pond. After a retention
time in the holding pond, it flowed to a drainage ditch that later commingled with Drowning Creek. In an
effort to control the automatic Boiler Blowdown pH (which is normally in the pH range of 10 to 11), Perdue
Farms was considering the addition of a slow drip of citric acid to bring the pH to approximately pH 7 in the
catch basin area, and periodically check the pH at the discharge over the "V" notch weir. In the past, the
pH measurements were performed by a color comparator method (which is not an acceptable pH method
for this NCG permit). Please refer to NCG500021, Part II, Section D, 3, which states, in part, that "Test
procedures...shall conform to...40 CFR 136". The pH test procedures listed in 40 CFR 136 are the
Electrometric measurement and the Automated electrode methods. Please immediately adopt an
Electrometric measurement method that will be capable of a two -point slope calibration, or a three-point
slope calibration. Enclosed with this CEI report are two information sheets that may be useful for
establishing good laboratory pH measurement protocol at your facility. Concerning your question about
whether or not the Air Compressor Condensate may be diverted to a conventional septic tank system at
your facility, please consult with the Moore County Environment Health Section for permission (phone
number 910-947-6283), please also mention that the Air Compressor Condensate wastewater flows through
an Oil/Water Separator before it would flow to the septic tank and that the historical data indicated very low
Oil and Grease values. Since chlorine was not used at this facility, the chorine testing was not required.
Biocides were also not used, and there was no need for the Biocide 101 Worksheet. Since the
commingled flow from the Air Compressor Condensate and the Boiler Blowdown flowed into the stormwater
drainage ditch (which would only have stormwater after a rain event), and since it then flowed 100 to 300
meters to the Plant Ouffall 001 location before it flowed into a holding pond, it would not be required of this
facility to sample for Upstream and Downstream temperature. As according to NCG500021, Part I, A (1),
1: "Upstream and downstream monitoring is not necessary if the discharge is to a receiving stream that
does not contain any flowing water at the time of discharge". This was the first NCG500000 inspection at
the facility, and the permit requirements were not fully understood. For that reason, they were not
implemented as intended by the permit. It was this inspector's impression that with the guidance offered
during the inspection and with this report, clarification of the permit requirements was achieved. Please
be aware that it is the intention of this Office to perform a Compliance Evaluation. Inspection at your facility
within our next fiscal year of inspections. At that time, the permit requirements will be reviewed.
Page # 2

TECHNICAL ASSISTANCE FOR.FIELDANALYSIS
OF pH
This document is intended to provide technical assistance and guidance for the measurement of pH. This is
not meant to be a substitute for the method, but is offered as a guide to the method.
HOLDING TIME:
REQUIREMENT: Samples must be analyzed within 15 minutes of collection.
METER CALIBRATION:
REQUIREMENT: Meter must be calibrated prior to the analysis of samples. It is recommended that the
meter be calibrated prior to collection of samples due to short hold time.
For routine work, use a pH meter accurateand reproducible to 0.1 pH unit with a range of 0 to 14 and
equipped with a temperature compensation device. Follow all manufacturers recommendations for the
calibration of the meter each analysis day. In all cases the meter must be calibrated with at least two
buffers and the calibration verified with a third pH buffer.
In order to meet the above specified criteria, Standard Methods 18th Edition recommends that the meter be
calibrated .with the pH 4 and pH 10 buffers. In addition to the calibrationstandards, a pH 7 buffer calibration
check must be performed. The pH 7 buffer must read within a range of pH 6.9 to 7.1 to be acceptable.
General Information:
Samples shall be gently stirred during measurement.
The electrode must be rinsed between measurements.
REQUIREMENT: The temperature sensor in the meter must be checked annually against a NIST certified
thermometer and the process documented if the instrument is used for reporting temperature results.
RECOMMENDATION: It is recommended that the temperature sensor be calibrated annually even. if not
being used to report temperature. (Other certified laboratories may provide assistance in meeting this
requirement.)
RECOMMENDATION: The thermometer should be less than 3°C from the certified reading to be acceptable.
REQUIREMENT: Report all data values to the nearest 0.1 pH unit.
Equipment types may vary. If this presents problems, please contact this office for technical assistance.
DOCUMENTATION:
The following criteria must be documented whenever sample analysis is performed.
1. REQUIREMENT: Time and date of sample collection
2. REQUIREMENT: Time and date of analysis (to verify 15 minute holding time is met)
3. REQUIREMENT: Collector's/analyst's name
4. REQUIREMENT: Value of buffers used for calibration
5. REQUIREMENT: Value obtained for check buffer (pH 7 buffer)
6. REQUIREMENT: Sample location/site
Ref: Standard Methods, 18th Edition - Method 4500-H* B.
Ref: Standard Methods, 1.8th Edition - Method 2550 B.

Date:
Example Field Parameter Worksheet
Analyst:
pH Analysis
Cal. Time
Calibration
Calibration
Buffer 10.0
Check °
Buffer7.0
Comments
°The off check buffer mud he• within + n 1 ..Lr ,...:,.. ,, r.t... L..ca.�..._._ .._t.._
Facility
Time Sampledo .
•• Time Analyzed
Result •
• 4Buffer Ch•eck
Comment
•pH
If I
.
o samp a ,s measured directly at the source only tune analyzed would be recorded.
4 Indicates a recommended drift check- (use Buffer 7.0, should be within ± 0.1 pH units of the buffer's true value)
Calibration drift check is recommended three times daily (for a full workday) moming, mid -day, end of the day.
Example Field Parameter Worksheet
Date: Analyst:
pH Analysis
Cal. Time
Calibration.
Buffet4.0
Calibration
Buffer 10.0
Check ° •
Buffer 7.0
Comments .
°The pH check buffer must be within ± 0.i pH units of the buffer's true value.
Facility
Time Sam led+
Time Analyzed*
pH Result
Buffer Check
Comment
o If sample is measured directly at the source only time analyzed would be recorded.
4 Indicates a recommended drift check- (use Buffer 7.0, should be within ± 0.1 pH units of the buffer's true value)
Calibration drift check is recommended three times daily (for a full workday) morning, mid -day, end of the day.