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Home My WebLink AboutNCG500229_Compliance Evaluation Inspection_20220128ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH NORTH CAROLINA Director Environmental Quality January 28, 2022 Perdue Foods, LLC Attn: Drew Getty, Assistant General Counsel P.O. Box 1537 Salisbury, MD 21802-1537 SUBJECT: Compliance Evaluation Inspection Elkin Feed Mill NPDES Permit Number NCG500229 Surry County Dear Mr. Getty: Mr. Ron Boone, of the NC Division of Water Resources (NCDWR), Winston-Salem Regional Office (WSRO), conducted a compliance evaluation inspection of Perdue Foods, LLC's, Elkin Feed Mill, on January 19, 2022. Mr. Boone met with Spergie Blue, Robert Morgan, and Peggy Mills. Their assistance and cooperation was greatly appreciated. Inspection findings are detailed in the attached Water Compliance Inspection Report and summarized below. It was discovered during the inspection that there is no discharge of wastewater, associated with this permit, from the site to surface waters of the state. According to Mr. Blue, the only waste stream at the facility that would be covered by this permit is boiler blowdown and all boiler blowdown wastewater is currently piped to the onsite wastewater treatment and disposal system, which is a conventional septic tank system with a sub -surface leeching system. Mr. Boone asked Mr. Blue why they have the permit. He informed Mr. Boone that others above him in the organization's chain of command believe the permit is required. Please be aware that as long as no waste streams, which would be covered by this general permit, are being discharged from the site to surface waters of the state, then the permit is not required. If all the above information is correct, then Perdue does not need the subject permit and can request rescission by submitting a letter requesting rescission to DWR's NPDES Unit in our Raleigh Central Office at the following address: Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Please be aware that the Division may take enforcement action against any permittee who fails to comply with any requirement of their permit. Pursuant to NC General Statute (NCGS) 143-215.6A, NORTH D E neo.rtm.m .f Envim.mo.t.i Ou.i` North Carolina Department of Environmental Quality Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. Please reply to this notice in writing within 15 business days of receiving it indicating your intent regarding keeping the permit or requesting rescission. If you decide to request rescission and require additional information to initiate the process, please feel free to contact us. If you have any questions or concerns, please do not hesitate to contact Mr. Boone by phone at 336-776-9690, or by email at ron.boone@ncdenr.gov. Thank you in advance for your time and attention to this matter. Attachments: 1 Water Compliance Inspection Report cc: 1. Laserfiche 2. Perdue Foods, LLC Elkin Feed Mill Attn: Spergie Blue 105 Greenwood Circle Elkin, NC 28621 LD_E NORTH CAROLINA Department of Environmental quaky Sincerely, (—DocuSigned by: LU. l . JMAU' —145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality j Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 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 1 IN Code I 2 IL NPDES yr/mo/day Inspection Type Inspector Fac I 3 I NCG500229 111 121 22/01/19 117 1810I 19I S I 2011 Type 21IIIIII IIIIIIIIIII IIIIIII I IIIIII IIIIIIIIIII P6 Inspection 671 Work Days Facility Self -Monitoring I 70I Evaluation Rating I 71 B1 I 1 72 QA I N I 73I 1 I I Reserved 74 71 I I I I I I 180 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES oermit Number) Elkin Feedmill 105 Greenwood Cir Elkin NC 28621 Entry Time/Date 11:OOAM 22/01/19 Permit Effective Date 20/12/15 Exit Time/Date 12:OOPM 22/01/19 Permit Expiration Date 25/11/30 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 Spergie Blue,105 Greenwood Cir Elkin NC 28621//336-366-2591/3363664375 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran Facility Site Review Effluent/Receiving Wate 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 CID9i1Ped by: DWR/WSRO WQ/336 776 9690/ o siaecl 13oosvri 1/25/2022 B20F8DD5F2A3460... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date FDocuSigned by: L-o, T. Stiacr 1/28/2022 �14EA. EPA Form5 55g9-2C (i4ev 9-94) Previous editions are obsolete. Page# 1 sI NPDES yr/mo/day NCG500229 111 121 22/01/19 117 Inspection Type 18 [j (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mr. Ron Boone, of the NC Division of Water Resources (NCDWR), Winston-Salem Regional Office (WSRO), conducted a compliance evaluation inspection of Perdue Foods, LLC's, Elkin Feed Mill, on January 19, 2022. Mr. Boone met with Spergie Blue, Robert Morgan, and Peggy Mills. Their assistance and cooperation was greatly appreciated. Inspection findings are detailed in the attached Water Compliance Inspection Report. It was discovered during the inspection that there is no discharge to a receiving stream. All wastewater is conveyed to the onsite wastewater treatment system which consists of septic tanks and a leeching system. The permit is therefore NOT required but according to Mr. Blue, the permittee, or someone in the organization over him, believes the permit is needed. It is recommended that, as long as nothing was missed during the inspection, and there is in fact, no discharges from the site to a receiving stream, that the permittee request recission of the permit via letter to the NC Division of Water Resources, NPDES Unit, in Raleigh, NC. Such letter can be submitted to the following address: Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 No other concerns, discrepancies, or violations were noted during the inspection. Page# 2 Permit: NCG500229 Inspection Date: 01/19/2022 Owner - Facility: Elkin Feedmill Inspection Type: Compliance Evaluation 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? • ❑ ❑ ❑ Comment: It was discovered during the inspection that there is no discharge to a receiving stream. Samples are taken and analyzed of the site's stormwater discharge, in accordance with the site's general stormwater permit. 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 ■ 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: None Page# 3 Permit: NCG500229 Inspection Date: 01/19/2022 Owner - Facility: Elkin Feedmill Inspection Type: Compliance Evaluation 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 El El M El Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: None Page# 4