NCG060184_Assessment of BMP Report_20131201

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November 27, 2013
NCDENR Stormwater Permitting Unit
1612 Mail Service Center
Raleigh, NC 27699-1612
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Re: Assessment of Best Management Practices (BMPs) Report
Pilgrim's Pride Corporation Wingate, North Carolina Feed Mal
205 Edgewood Drive in Wingate, North Carolina
To whom it may concern:
Pilgrim's Pride Corporation (Pilgrim's) operates a poultry Feed Mill located at 205 Edgewood
Drive in Wingate, North Carolina. Please find attached the Assessment of Best Management
Practices (BMPs) report as required under Section E of General Permit Number NCG060000. An
assessment was performed at the Facility on November 19, 2013 for best management practices
associated with the off-loading, handling and spill prevention of rendered fats and oils, as well as
other materials that are stored and used at the Facility.
As required, a copy of this report has also been submitted to the NCDENR Stormwater
Permitting Unit. Should you have any questions, please feel free to contact me at [phone]
or [phone].
Since
WHIA
he
Director of Environmental Affairs, Eastern Region
Pilgrim's Pride Corporation
Cc: Mr. Hayne Haigler (Pilgrim's Pride, via email)

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WOODRUFF&HOWE
ENVIRONMENTAL ENGINEERING, INC.
DEL 0 1 2013
DENR-WA7c0. DUAIJ;'...,
Assessment of Best Management Practices (BMP"DSAND STDRMWATER
As Required by Section E of Permit No. NCGO60000
Pilgrim's Pride Corporation
Wingate, North Carolina Feed Mill
This Assessment of Best Management Practices (BMPs) at the Pilgrim's Pride Wingate, North Carolina
Feed Mill was performed by Mr. Stefan Gosey with Woodruff and Howe Environmental Engineering,
hic. (WHEE, Inc.) on November 19, 2013.
Facility Overview
Pilgrim's Pride Corporation (Pilgrim's Pride) owns a poultry Feed Mill located at 205 Edgewood Dive in
Wingate, North Carolina. This Facility receives, stores and handles animal fats and animal byproducts
(meat and bone meal, etc.) for use as ingredients in the production of poultry feed, which is then shipped
offshe to contract poultry growers. Pilgrim's Pride also owns and operates a Truck Maintenance Shop
onsite.
Narrative
When operational, various liquid and solid materials are stored and handled in outdoor areas at the
Pilgrim's Pride Wingate Feed Mill Site. Best management practices (BMPs) have been developed and
are utilized for the handling and storage of these materials in an effort to reduce their potential for
exposure and/or discharge to stormwater drainage features.
Liquid feed ingredients (Fat, Rhodimet, Choline, LSS, mold inhibitors, etc.) and No. 6 fuel oil, used as
boiler backup fuel, are stored in above -ground storage tanks (ASTs) in a poured concrete containment
structure that also contains 55-gallon oil drums and various storage containers for recovered fat.
Gasoline and diesel fuel are stored in two (2) ASTs in a concrete masonry unit (CMU) secondary
containment structure located between the Truck Maintenance Shop and Feed Mill. A covered fueling
area, which consists of two (2) fuel pumps and dispensers associated with these fuel tanks, is located
immediately south of these ASTs. Various oils used in truck maintenance activities (engine oil, motor oil,
hydraulic oil, etc.) are located inside the Truck Maintenance Shop in double -wall tanks and/or 55-gallon
drums. Used oil is stored in two (2) double -wall tanks on the south side of the Truck Maintenance Shop,
and this used oil is burned as heating oil at the Truck Maintenance Shop.

Blowdown water from the Feed Mill boiler and accumulated stormwater in the secondary containment
structure containing the fat and other liquid feed ingredient ASTs is pumped out and transported to the
Pilgrim's Pride Marshville Processing Plant wastewater pretreatment system for pretreatment and
discharge to the local publicly owned treatment works (PDTW). The boiler blowdown collection/loadout
system consists of an underground storage tank (UST), an AST and overhead piping from the AST to the
loadout area located immediately south of the UST and AST. Accumulated stormwater in the CMU
secondary containment structure containing the gasoline and diesel fuel ASTs is inspected to ensure it is
free of signs of contaminants prior to being discharged to stormwater drainage features via a manually
operated drain valve. Contaminated stormwater in this gasoline/diesel AST CMU containment structure is
collected and hauled to the Marshville Processing Plant wastewater pretreatment system for treatment.
Liquid receiving operations (liquid feed ingredients, No. 6 fuel oil, hydraulic oil, etc.) generally occur in
the daytime or in well -lit areas, and receiving activities are actively monitored by delivery and/or Feed
Mill personnel. Delivery drivers are discouraged from "topping -off' ASTs.
Solid feed ingredients (corn, meat and bone meal, soybean meal, etc.) are received via hopper bottom
trucks / railcars in two (2) adjacent 2-sided, covered structures on the south side of the Feed Mill.
Finished feed is loaded out in a 2-sided, covered structure via load out spouts outfitted with "drop socks"
to help minimize fugitive emissions. Horizontal surfaces of feed loadout trailers are cleaned of finished
feed prior to leaving the Loadout Area, and the Loadout Area is routinely cleaned to help prevent "drag -
out" of finished feed by trailers. An equipment and materials storage area is located northwest of the Feed
Mill, in a gravel area adjacent to the Maintenance Shop, and materials stored in this area are cleaned of
signs of oil/grease and other pollutants prior to long-term storage outdoors. General housekeeping is
routinely performed at the Facility. General housekeeping and other BMPs include routine inspection of
areas with potential for spills, leaks, dust accumulation, etc. and the cleanup of these areas as required
(i.e., material handling areas are swept, materials are stored under cover or roof as allowed, etc.).
The Facility maintains a Spill Prevention Countermeasure and Control (SPCC) Plan, which includes
practices and procedures for oil, fuel, and fat storage and handling as well as spill prevention and
response procedures in the event of a fat, fuel or oil spill. Additionally, the Facility performs regular
testing of certain emission sources as required by NESHAP Subpart DDDDDDD and per the Facility's air
permit. Air pollution control system are provided for significant air emission sources, and these systems
are inspected, operated and maintained per the Facility's air permit and associated plans, etc.
Feasibility Evaluation
The Facility has developed and maintains best management practices that include reducing the exposure
of materials to rainfall and the routine cleanup of areas with the potential for exposure of liquid or solid
material, associated with incidental or accidental material spills or leaks, and/or associated with fugitive
emission sources. Liquid storage tanks are stored inside secondary containment structures or in double -
wall tanks, solid feed ingredients are generally received under cover of roof or via pneumatic systems and
stored in enclosed bins or inside the Feed Mill building, and areas with potential for dust accumulation
(cyclone exhaust, paved areas, receiving areas, etc.) are routinely inspected and cleaned as required to
prevent excessive dust accumulations. Pilgrim's Pride continuously monitors solid and liquid receiving,
storage and handling systems and modifies / incorporates additional BMPs as deemed necessary. Various
structural controls and BMPs are employed at the Facility to prevent and/or minimize the exposure and/or

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discharge of animal fat and byproduct materials as well as other materials to rainfall and storm water
runoff. The animal fat and byproduct materials handled at the Facility are obtained from regulated
rendering facilities, and these materials are processed in a manner that kills bacteria and other pathogens.
Wildlife Presence/Absence
A significant portion of the surrounding area is undeveloped and provides habitat for wildlife (wooded
areas, etc.). The BMPs employed by the Mill provide for prompt cleanup of feed materials, etc., thereby
minimizing attracting wildlife into the developed areas of the site. FDA / USDA regulations also require
feed mills to implement various measures (good housekeeping, good manufacturing processes, etc.) to
control/prevent contamination of feed ingredients and finished feeds by external vectors such as rodents,
birds and other wildlife. The Feed Mill also maintains an active pest control program, which primarily
consists of the use of bait boxes located at various key locations inside and outside the Facility.
It is important to note that the University of Alabama and the Center for Watershed Protection was issued
a grant by the USEPA to perform a study of national stormwater quality by sampling stormwater
discharged from areas associated with various land uses across the United States (i.e., residential,
industrial, open space, etc.) and complied their results in a paper published in February, 2004 titled "The
National Stormwater Quality Database (NSQD, version 1.1)". Based on the results of Phase 1 of this
study, stormwater discharged from areas designated "Mixed Open Space," which most accurately
describes the area surrounding the Feed Mill, had a fecal coliform median value of 2,600 mpn/100 mL.
This analytical data, along with the fact that the Feed Mill is located in a primarily wooded area reinforces
Pilgrim's Pride's belief that stormwater discharges from the Wingate Feed Mill Site could potentially
have naturally occurring levels of fecal coliform for reasons unrelated to operations at the Feed Mill Site.
Corrective Action Measures Plan
Stefan Gosey, with Woodruff and Howe Environmental Engineering, Inc. (WHEE, Inc.), performed the
Site Visit and BMP assessment on November 19, 2013, and during his Site Visit he observed various
systems / operations that required corrective action. Pilgrim's Pride will address these items and perform
corrective actions in a timely manner:
1. The area around the fat AST fill port should be cleaned of signs of spilled fat, and the stainless
steel container used to store fat recovered from the screener should be routinely cleaned.
Additionally, the recovered fat material should be beneficially used or the fat material should be
properly disposed offsite.

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