HomeMy WebLinkAboutNCG060216_CEI_20220525ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
Murphy -Brown, LLC
Attn: John Sargent, Executive Vice President
PO Box 856
Warsaw, NC 28398-0856
NORTH CAROLINA
Environmental Quatity
May 25, 2022
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG060000
Murphy -Brown, LLC
Laurinburg Feed Mill, Certificate of Coverage NCG060216
Scotland County
Dear Mr. Sargent:
On May 23, 2022, a site inspection was conducted for the Laurinburg Feed Mill facility located at 19600 Andrew Jackson
Highway in Laurinburg, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Evan
Hicks, Feed Mill Manager, Mr. Greg Ewing, Regional Operations Manager, and Mr. Robert Richardson, Environmental
Resource Specialist, were also present during the inspection and their 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 NCG060216. Permit coverage authorizes the discharge of stormwater from the facility to receiving
waters designated as Leith Creek (Johns Pond), class C;Sw waters in the Lumber River Basin.
As a result of the inspection, the facility was found to be compliant 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 (910) 433-3394 or via e-mail at
mike.lawyer@ncdenr.gov.
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
Enclosures: Compliance Inspection Report, Representative Outfall Status Request Form
ec: Evan Hicks, Feed Mill Manager — Smithfield Hog Production Division
Greg Ewing, Regional Operations Manager — Smithfield Hog Production Division
Robert Richardson, Environmental Resource Specialist — Smithfield Hog Production Division
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO — DEMLR, Stormwater Files
D....w-- + North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
& rayetteville Regional Office 1225 Green Street, Suite 714 I Fayetteville, North Carolina 28301
DeWrtmeritotEmhunmenfnl4ua@y 910.433.3300
Compliance Inspection Report
Permit: NCG060216 Effective: 07/01/21 Expiration: 06/30/26 Owner: Murphy -Brown LLC
SOC: Effective: Expiration: Facility: Laurinburg Feed Mill (Murphy -Brown LLC)
County: Scotland 19600 Andrew Jackson Hwy
Region: Fayetteville
Laurinburg NC 28353
Contact Person: Katie A Elmer Title: Phone: 910-293-5245
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Evan Hicks 910-277-8999 ext 6E
On -site representative Robert Richardson 910-217-1471
On -site representative Greg Ewing 910-277-8999
Related Permits:
Inspection Date: 05/23/2022 Entry Time 09:55AM Exit Time: 11:45AM
Primary Inspector: Mike Lawyer %`` Phone: 910-433-3394
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Food/Tobacco/Soaps/Cosmetics/Public Warehousing Stormwater Discharge COC
Facility Status: 0 Compliant ❑ Not Compliant
Question Areas:
N Storm Water
(See attachment summary)
Page 1 of 3
Permit: NCG060216 Owner - Facility: Murphy -Brown LLC
Inspection Date: 05/23/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Evan Hicks, Feed Mill Manager, Greg Ewing, Regional Operations Manager, and Robert Richardson, Environmental
Resource Specialist, to conduct a compliance inspection regarding the facility's coverage under NPDES Stormwater General
Permit NCG060000. Facility's Stormwater Pollution Prevention Plan (SPPP) and stormwater discharge monitoring records
were provided for review. The SPPP appeared to contain all required components along with documentation pertaining to the
annual review and update requirements. Monitoring records for the current permit period indicate that outfall 001 is in the Tier
Two monthly monitoring frequency due to consecutive exceedances of the benchmark value for COD. Facility personnel have
taken action to try to address these exceedances by installing silt fence around their main grain storage areas, placing
filters in catch basins, and increasing housekeeping practices. An additional stormwater discharge outfall was constructed
around 2016/17, which is currently in the baseline quarterly monitoring frequency. This additional outfall needs to be added
to the permit database by emailing the outfall information (identifier and coordinates) to Bethany Georgoulias at
bethany.georgoulias@ncdenr.gov. Once the additional outfall has been added to the database, a Representative Outfall
Status Request Form (included with this report) could be submitted to the Fayetteville Regional Office for review. After the
records review, observations were made of the facility's secondary containment around ASTs, stormwater discharge outfalls,
and grain storage areas.
Page 2 of 3
Permit: NCG060216 Owner - Facility: Murphy -Brown LLC
Inspection Date: 05/23/2022 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?
0 ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
0 ❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
# 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)?
N ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
N ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plari been implemented?
0 ❑ ❑ ❑
Comment:
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? N ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 ❑ ❑ ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all outfalls observed during the inspection? E ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? E ❑ ❑ ❑
Comment:
Page 3 of 3
Division of Energy, Mineral & Land Resources
;;r?+ Stormwater Program
National Pollutant Discharge Elimination System
FOR AGENCY USE ONLY
Date Received
Yeaz
Month
Day
If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the
permittee may petition the Director for Representative Outfall Status (ROS). DEQ may grant Representative
Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
If Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring
requirements of the facility's permit —unless otherwise allowed by the permit (such as NCG020000) and DEQ
approval. The approval letter from DEQ must be kept on site with the facility's Stormwater Pollution
Prevention Plan. The facility must notify DEQ in writing if any changes affect representative status.
For questions, please contact the DEQ Regional Office for your area (see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (or) Certificate of Coverage
I
2) Facility Information:
Owner/Facility Name
Facility Contact
Street Address
City State ZIP Code
County E-mail Address
Telephone No. Fax:
3) List the representative outfall(s) information (attach additional sheets if necessary):
Outfall(s)
is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s)
is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s)
is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No ❑ No data*
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No ❑ No data*
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No ❑ No data*
*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
circumstances will be considered by the Regional Office responsible for review.
Page 1 of 3
SWU-ROS-2009 Last revised 12/30/2009
Representative Outfall Status Request
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or, attach a letter or narrative to discuss this information.) For example, describe how activities and/or
materials are similar.
5) Certification:
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record,
report, plan, or other document filed or required to be maintained under this Article or a rule implementing this
Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case
under this Article; or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device
or method required to be operated or maintained under this Article or rules of the [Environmental Management]
Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed
ten thousand dollars ($10,000).
I hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit
and regional office approval. I must notify DEQ in writing if any changes to the facility or its operations
take place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must
resume monitoring of all outfalls as specified in my NPDES permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing:
Title:
(Signature of Applicant)
(Date Signed)
Please note: This application for Representative Outfall Status is subject to
approval by the NCDEQ Regional Office. The Regional Office may inspect your
facility for compliance with the conditions of the permit prior to that approval.
Final Checklist for ROS Reauest
This application should include the following items:
❑ This completed form.
❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status, unless all information can be included in Question 4.
❑ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas, industrial activities, and raw materials/finished products within each drainage area.
❑ Summary of results from monitoring conducted at the outfalls listed in Question 3.
❑ Any other supporting documentation.
Page 2 of 3
SWU-ROS-2009 Last revised 12/30/2009
Representative Outfall Status Request
Mail the entire package to:
NCDEQ DEMLR at the appropriate Regional Office (See map and
addresses below)
Notes
The submission of this document does not guarantee Representative Outfall Status (ROS) will be granted as
requested. Analytical monitoring as per your current permit must be continued, at all outfalls, until written
approval of this request is granted by DEQ. Non-compliance with analytical monitoring prior to this request
may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for
review.
For questions, please contact the DEQ Regional Office for your area.
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Washington Regional Office
943 Washington Square Mall
Phone (828) 296-4500
Washington, NC 27889
FAX (828) 299-7043
Phone (252) 946-6481
Fayetteville Regional Office
FAX (252) 975-3716
Systel Building,
225 Green St., Suite 714
Wilmington Regional Office
Fayetteville, NC 28301-5094
127 Cardinal Drive Extension
Wilmington, NC 28405
Phone (910) 433-3300
FAX 910/ 486-0707
Phone (910) 796-7215
FAX (910) 350-2004
Mooresville Regional Office
610 East Center Ave.
Winston-Salem Regional Office
Mooresville, NC 28115
585 Waughtown Street
Winston-Salem, NC 27107
Phone (704) 663-1699
Phone (336) 771-5000
FAX (704) 663-6040
Water Quality Main FAX (336) 771-4630
Raleigh Regional Office
Central Office
1628 Mail Service Center
1612 Mail Service Center
Raleigh, NC 27699-1628
Raleigh, NC 27699-1612
Phone (919) 791-4200
Phone (919) 807-6300
FAX (919) 571-4718
FAX (919) 807-6494
Page 3 of 3
SWU-ROS-2009 Last revised 12/30/2009