NC0077615_Response to Notice_20220815

From: Brian Foor
To: Bell. Wes
Subject: RE: [External] RE: Stormwater Permit application and permit info
Date: Monday, August 15, 2022 3:53:38 PM
Attachments: Drum Tracking.xlsx
Employee Training.pdf
NCR violation response.docx
Signed NCR - Response and Corrective Action.pdf
Stormwater application SCAN.odf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Wes, I have attached 5 files:
• NCR Violation response —This is the description of the event with a root cause analysis,
corrective actions performed, and preventative measures to prevent reoccurrence.
• Signed NCR —The above form signed and dated
• Employee Training —This scan includes our modified program to address the drums. It also
includes the employee training for the modification along with employee signatures
• Drum Tracking —This form will be used to track all drums exiting the plant beginning this
week.
• Stormwater application —This is a scan of all of the physical forms submitted last week via
certified mail
Let me know if you have any questions.
Thanks.
Brian Foor
From: Bell, Wes <[e-mail]>
Sent: Monday, August 15, 2022 3:11 PM
To: Brian Foor <[e-mail]>
Subject: RE: [External] RE: Stormwater Permit application and permit info
Thanks.
Wes
Wes Bell
Env. Specialist II
Mooresville Regional Office
Water Quality Regional Operations Section
NCDEQ-Division of Water Resources
[phone] Office
[phone] Office Direct Line
Email: [e-mail]

610 East Center Avenue
Suite 301
Mooresville, NC 28115
From: Brian Foor <[e-mail]>
Sent: Monday, August 15, 2022 2:37 PM
To: Bell, Wes <wes.bellPncdenr.gov>
Subject: RE: [External] RE: Stormwater Permit application and permit info
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
We submitted the Stormwater Application last week and I will have the response with electronic
documents to you this afternoon.
From: Bell, Wes <[e-mail]>
Sent: Monday, August 15, 2022 2:24 PM
To: Brian Foor <[e-mail]>
Subject: RE: [External] RE: Stormwater Permit application and permit info
Good afternoon,
This is my first day back from an extended vacation. Please provide a response to the NOV letter (to
address all noted issues) as a result of the July 25 site inspection that is due by tomorrow.
Thank you for all your cooperation in this matter.
Wes
Wes Bell
Env. Specialist II
Mooresville Regional Office
Water Quality Regional Operations Section
NCDEQ-Division of Water Resources
[phone] Office
[phone] Office Direct Line
Email: wes.bellPncdenr.gov
610 East Center Avenue
Suite 301
Mooresville, NC 28115

From: Brian Foor <[e-mail]>
Sent: Thursday, July 28, 2022 9:54 PM
To: Bell, Wes <wes.bellPncdenr.gov>
Subject: [External] RE: Stormwater Permit application and permit info
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Wes,
Good evening. We are starting this process and have a meeting tomorrow morning to discuss the
permit and our plan moving forward. Just wanted to communicate with you our intentions. We plan
on building a solid plan quickly.
Thanks.
From: Bell, Wes <wes.bellPncdenr.gov>
Sent: Thursday, July 21, 2022 4:12 PM
To: Brian Foor <bfoorPoriginfoodgroup.com>
Subject: Stormwater Permit application and permit info
Good afternoon,
As we discussed earlier, I am providing the link for the application for an industrial stormwater
permit that will need to be completed and submitted according to the application. Please verify
your SIC Code but it probably falls under the list of SIC Codes for the Food & Kindred stormwater
permit (NCG060000s).
https://deq.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-
program/npdes-industrial-program/general-industrial-permits#ncg060000-food-and-kindred-
effective-7-1-2021-expires-6-30-2026
You can click on the https://deq.nc.gov/energy-mineral-and-land-resources/stormwater/npdes-
general-permits/ncg06-noi-20210629-demlr-sw/download link (listed as NCG06 Notice of Intent) to
get the application. The actual permit is at this link https://deq.nc.gov/energy-mineral-and-land-
resources/stormwater/npdes-general-permits/ncg060000-general-permit-20210630-demlr-
sw/downloadthe (listed as NCG06 General Permit).
You can contact Lily Kay at 704-235-2137 or Kenny Llywelyn at 704-235-2146 with the Division of
Energy, Minerals & Land Resources, who permits and regulates the stormwater permits, if you have
any additional questions.
My Section will be sending you a report on the site visit today within the near future.
Thanks.
Wes
Wes Bell

Env. Specialist II
Mooresville Regional Office
Water Quality Regional Operations Section
NCDEQ-Division of Water Resources
[phone] Office
[phone] Office Direct Line
Email: [e-mail]
610 East Center Avenue
Suite 301
Mooresville, NC 28115

ORIGIN
FOOD GROUP
Non -Conformance Report Date: 08/09/2022
Non -Conformance Details:
What went wrong? Residual coconut oil from drums reached the ground.
Root Cause: Increased consumption of coconut oil due to business increase coupled with loss of
contracted pickup due to illness. The investigation revealed a lack of diligence on securing the bunghole
covers to the drums when empty. 100% adherence to this step would prevent rainwater from entering
the drums that are awaiting pickup allowing some to overflow.
Corrective Actions:
• All drums in the area were removed.
• Solidified materials were scraped and shoveled up and placed in appropriate containers for
disposal.
• All other effected items were removed.
• Further evaluation will be completed with a contractor by 8/19 to determine if any additional
physical measures need to be taken to return to as close as previous conditions
Preventative Actions:
• Secured new contractor and backup contractor for drum pickup
• Drum disposal added to Waste Management Procedure
• Drum tracking form created. The form is designed to require inspection of all outgoing drums,
their content, cleanliness, and presence of caps/covers
• Completed and documented employee training
Drafted:
Date: ei
Verified:
4-)
Date:

ORIGIN
F000 GROUP
One Point Training: Waste Management
Purpose: To explain the new changes to Prerequisite 17 — Waste Management.
Scope: This applies to all production employees who handle waste.
See Attached SOP.
What is new?
• Procedures have been added for how to properly handle drums and totes for disposal
What do I need to know?
• Cardboard totes should be removed from the production floor and staged for disposal in
front of the overhead door.
o All Tote liners should be removed from the inside of the tote to assist with
disposal.
■ If any liquid remains, inspect the bag. If the bag is damaged, additional
cleaning may be required before disposal.
o Sanitation will be cutting up the totes in order to allow for disposal in the onsite
dumpsters.
• Drums must be cleaned for proper disposal.
o When a drum is emptied, remove the liner if it has one and rinse out the inside
of the drum if it is dirty.
■ Dump this water down the inside drains. Do not dump the water outside.
o Once the drum is clean, cover it back up using the lid or cap.
o Sanitation will now move the drum outside and place it in a designated storage
area.
o Sanitation will notify the plant manager once 20 or 40 drums have accumulated.
The Plant Manager will contact the removal service.
See attached signature pages for all trained employees.
Training Verified:
Date: 0 ' 15 ` a ?-

ORIGIN
FOOD GROUP
WASTE MANAGEMENT AND DISPOSAL PROTOCOL
PREREQUISITE-17
PLANT
PREVIOUS REVIVION: 11/10/2020
PREPARED BY: MW
APPROVED BY: BF
CURRENT REVISION: 08/05/2022
• Flooring is sloped to drains.
• All waste collection containers are maintained in a serviceable condition and are cleaned and
sanitized on a routine basis so as not to attract pests and other vermin.
• Any microbiological tests that are positive for coliform are destroyed in the autoclave prior to
disposal.
• Origin Food Group has contracted with an outside disposal company to remove waste that is
deposited into the dumpsters.
• Liquids from cleaning escape the facility via the floor drains.
• The facility does not hold liquid waste on -site awaiting disposal.
• The sanitary sewer system contains drainage and waste from restrooms that drain directly to
the off -site treatment facility.
• Reviews of the effectiveness of waste management are a part of daily hygiene inspections and
results of these inspections are distributed to all relevant personnel.
Cardboard Tote Disposal:
Totes are utilized to store large quantities of raw materials for use in the HTST Batching Process. Such
materials include but are not limited to corn syrup and tapioca syrup. The following procedure occurs
once the HTST operators have finished emptying the tote.
1. Stage the tote for disposal by moving it from the HTST room to the overhead door that leads
outside.
2. Open the top of the tote and pull out the tote liner.
3. Leave the tote by the door for the sanitation employees to take care of.
4. The tote liner may be disposed of directly into the dumpster.
a. If any liquid remains in the tote liner, inspect the integrity of the bag. If the bag is
leaking farther cleaning may be required for proper waste disposal.
5. The tote cardboard requires farther processing for adequate disposal.
a. Bring the tote outside to an area that doesn't put production at risk.
b. Obtain a reciprocating saw (AKA sawz-all) to break down the tote.
c. Cut the tote into smaller pieces so it can be efficiently stored in the onsite dumpster.
6. The tote is now properly disposed of.
Drums and Barrels Disposal:
Drums and Barrels perform the same function as cardboard totes. They are utilized by the HTST
Operators and Tank Room Operators for various recipes. Once a Drum or Barrel is emptied, the
following procedure occurs.
1. Remove the container from the production area.
2. Stage it in front of the overhead door.
3. If there is a liner inside of the drum, remove it and set it aside with the other production waste.
4. If any product remains inside of the drum, remove it by cleaning it out with water and sending it
down the drain inside the facility.

ORIGIN
FOOD GROUP
WASTE MANAGEMENT AND DISPOSAL PROTOCOL PREREQUISITE-17
PLANT
PREVIOUS REVIVION: 11/10/2020
PREPARED BY: MW
APPROVED BY: BF
CURRENT REVISION: 08/05/2022
• Flooring is sloped to drains.
• All waste collection containers are maintained in a serviceable condition and are cleaned and
sanitized on a routine basis so as not to attract pests and other vermin.
• Any microbiological tests that are positive for coliform are destroyed in the autoclave prior to
disposal.
• Origin Food Group has contracted with an outside disposal company to remove waste that is
deposited into the dumpsters.
• Liquids from cleaning escape the facility via the floor drains.
• The facility does not hold liquid waste on -site awaiting disposal.
• The sanitary sewer system contains drainage and waste from restrooms that drain directly to
the off -site treatment facility.
• Reviews of the effectiveness of waste management are a part of daily hygiene inspections and
results of these inspections are distributed to all relevant personnel.
Cardboard Tote Disposal:
Totes are utilized to store large quantities of raw materials for use in the HTST Batching Process. Such
materials include but are not limited to corn syrup and tapioca syrup. The following procedure occurs
once the HTST operators have finished emptying the tote.
1. Stage the tote for disposal by moving it from the HTST room to the overhead door that leads
outside.
2. Open the top of the tote and pull out the tote liner.
3. Leave the tote by the door for the sanitation employees to take care of.
4. The tote liner may be disposed of directly into the dumpster.
a. If any liquid remains in the tote liner, inspect the integrity of the bag. If the bag is
leaking farther cleaning may be required for proper waste disposal.
5. The tote cardboard requires farther processing for adequate disposal.
a. Bring the tote outside to an area that doesn't put production at risk.
b. Obtain a reciprocating saw (AKA sawz-all) to break down the tote.
c. Cut the tote into smaller pieces so it can be efficiently stored in the onsite dumpster.
6. The tote is now properly disposed of.
Drums and Barrels Disposal:
Drums and Barrels perform the same function as cardboard totes. They are utilized by the HTST
Operators and Tank Room Operators for various recipes. Once a Drum or Barrel is emptied, the
following procedure occurs.
1. Remove the container from the production area.
2. Stage it in front of the overhead door.
3. If there is a liner inside of the drum, remove it and set it aside with the other production waste.
4. If any product remains inside of the drum, remove it by cleaning it out with water and sending it
down the drain inside the facility.

ORIGIN
FOOD GROUP
WASTE MANAGEMENT AND DISPOSAL PROTOCOL
PREREQUISITE-17
PLANT
PREVIOUS REVIVION: 11/10/2020
PREPARED BY: MW
APPROVED BY: BF
CURRENT REVISION: 08/05/2022
a. Drains inside the facility go to a treatment plant and it is acceptable for food waste to be
processed this way.
b. Drains outside the facility function as storm water drains which empty to local creeks.
It is unacceptable for food waste to be processed using those drains.
5. Once the drum is empty and clean, cover it by using either it's cap or lid to prevent rainwater
buildup.
6. The sanitation team will remove the now capped and clean drums and stage them by the
dumpster.
7. Once 20 barrels have been accumulated, notify the plant manager who will contact the removal
service to take the barrels off site.
ANNUAL REVIEW
8/12/2017
ANNUAL REVIEW
9/24/2019
ANNUAL REVIEW, ADDED HEADER (LB)
11/10/20
ANNUAL REVIEW, ADDED AUTOCLAVE
STATEMENT

Date
8/11/2022
ORIGIN
F�ooCRO
Topic:
Waste
Management
Training
Signature Roster
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FOR AGENCY USE ONLY
NCG06____
Assigned to:
ARO FRO MRO RRO WARO WIRO WSRO
Division of Energy, Mineral, and Land Resources Land Quality Section
National Pollutant Discharge Elimination System
NCG060000 Notice of Intent
This General Permit covers STORMWATER DISCHARGES associated with activities under the following Standard
Industrial Classifications: SIC 20 [Food and Kindred Products], SIC 21 [Tobacco Products], SIC 283 [Drugs], SIC 284
[Soaps, Detergents, & Cleaning Preparations; Perfumes, Cosmetics, & Other Toilet Preparations], SIC 422 [Public
Warehousing and Storage — except for 4226]. You can find information on the DEMLR Stormwater Program at
deq.nc.gov/SW.
Directions: Print or type all entries on this application. Send the original, signed application with all required
items listed in Item (6) below to: NCDEMLR Stormwater Program, 1612 MSC, Raleigh, NC 27699-1612. The
submission of this application does not guarantee coverage under the General Permit. Prior to coverage under
this General Permit a site inspection will be conducted.
1. Owner/Operator (to whom all permit correspondence will be mailed):
Name of legal organizational entity:
Origin Food Group, LLC
Legally responsible person as signed in Item (7) below:
Halil Ulukaya
Street address:
306 Stamey Farm Road
City:
Statesville
State:
NC
Zip Code:
28677
Telephone number:
704-768-9000
Email address:
[e-mail]
Type of Ownership:
Government
must be included with this application)
MI County MI Federal Dvlunicipal M State
Non -government
IMBusiness (If ownership is business, a copy of NCSOS report
MI Individual
2. Industrial Facility (facility being permitted):
Facility name:
Origin Food Group
Facility environmental contact:
Brian Foor
Street address:
306 Stamey Farm Road
City:
Statesville
State:
NC
Zip Code:
28677
Parcel Identification Number (PIN):
County:
Iredell
Telephone number:
704-768-9000
Email address:
[e-mail]
4-digit SIC code:
2023
Facility is:
Date operation is to begin or began:
2011?
V New • Proposed Di Existing
Latitude of entrance:
35.780507208
Longitude of entrance:
-80.9733833105
Brief description of the types of industrial activities and products manufactured at this facility:
Ice cream, frozen dessert, drinkable yogurt, cup yogurt
This facility processes meat: • Yes 12 No
If the stormwater discharges
to a municipal separate storm sewer system (MS4), name the operator of the MS4:
o N/A
Page 1 of 5

3. Consultant (if applicable):
Name of consultant:
Consulting firm:
Street address:
City:
State:
Zip Code:
Telephone number:
Email address:
4. Outfall(s1 At least one outfall is required to be eligible for coverage.
3-4 digit identifier:
OFG1
Name of receiving water:
Third Creek
Classification:
Other
❑ This water is impaired.
❑ This watershed has a TMDL.
Latitude of outfall:
35.7798530
Longitude of outfall:
-80.9715547
Brief description of the industrial activities that drain to th's outfall:
Loading and unloading trucks. Disposal of trash and debris.
Do Vehicle Maintenance Activities occur in the drainage area of this outfall?
If yes, how many gallons of new motor oil are used each month when averaged over the
• Yes >d No
calendar year?
3-4 digit identifier:
Name of receiving water:
Classification:
❑ This water is impaired.
❑ This watershed has a TMDL.
Latitude of outfall:
Longitude of outfall:
Brief description of the industrial activities that drain to this outfall:
Do Vehicle Maintenance Activities occur in the drainage area of this outfall? II Yes ■ No
If yes, how many gallons of new motor oil are used each month when averaged over the calendar year?
3-4 digit identifier:
Name of receiving water:
Classification:
❑ This water is impaired.
❑ This watershed has a TMDL.
Latitude of outfall:
Longitude of outfall:
Brief description of the industrial activities that drain to this outfall:
Do Vehicle Maintenance Activities occur in the drainage area of this outfall?
If yes, how many gallons of new motor oil are used each month when averaged over the
■ Yes ■ No
calendar year?
3-4 digit identifier:
Name of receiving water:
Classification:
❑ This water is impaired.
❑ This watershed has a TMDL.
Latitude of outfall:
Longitude of outfall:
Brief description of the industrial activities that drain to this outfall:
Do Vehicle Maintenance Activities occur in the drainage area of this outfall?
If yes, how many gallons of new motor oil are used each month when averaged over the
■ Yes ■ No
calendar year?
All outfalls must be listed and at least one outfall is required. Additional outfalls may be added in the section
"Additional Outfalls" found on the last page of this NOI.
Page 2 of 5

5. Other Facility Conditions (check all that ay and explain accordingIv):
0 This facility has other NPDES permits.
If checked, list the permit numbers for all current NPDES permits:
NC077615
■ This facility has Non -Discharge permits (e.g. recycle permit).
permits:
If checked, list the permit numbers for all current Non -Discharge
0 This facility uses best management practices or structural stormwater control measures.
If checked, briefly describe the practices/measures and show on site diagram:
O This facility has a Stormwater Pollution Prevention Plan (SWPPP).
If checked, please list the date the SWPPP was implemented:
• This facility stores hazardous waste in the 100-year floodplain.
If checked, describe how the area is protected from flooding:
■ This facility is a (mark all that apply)
❑ Hazardous Waste Generation Facility
❑ Hazardous Waste Treatment Facility
❑ Hazardous Waste Storage Facility
❑ Hazardous Waste Disposal Facility
If checked, indicate:
Kilograms of waste generated each month:
Type(s) of waste:
How material is stored:
Where material is stored:
Number of waste shipments per year:
Name of transport/disposal vendor:
Transport/disposal vendor EPA ID:
Vendor address:
■ This facility is located on a Brownfield or Superfund site
If checked, briefly describe the site conditions
6. Required Items (Application will be returned unless all of the following items have been included):
o Check for $100 made payable to NCDEQ
o Copy of most recent Annual Report to the NC Secretary of State
o This completed application and any supporting documentation
0 A site diagram showing, at a minimum, existing and proposed:
a) outline of drainage areas
b) surface waters
c) stormwater management structures
d) location of stormwater outfalls corresponding to the drainage areas
e) runoff conveyance features
f) areas where industrial process materials are stored
g) impervious areas
h) site property lines
0 Copy of county map or USGS quad sheet with the location of the facility clearly marked
Page 3 of 5

7. Applicant Certification:
North Carolina General Statute 143-215.6E (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 . , . shall be guilty of a Class 2 misdemeanor which may include a fine not
to exceed ten thousand dollars ($10,000).
Under penalty of law, I certify that:
O I am the person responsible for the permitted industrial activity, for satisfying the requirements of this permit, and for any
civil or criminal penalties incurred due to violations of this permit.
0 The information submitted in this NOI is, to the best of my knowledge and belief, true, accurate, and complete based on
my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information.
O 1 will abide by all conditions of the NCG060000 permit. I understand that coverage under this permit will constitute the
permit requirements for the discharge(s) and is enforceable in the same manner as an individual permit.
O I hereby request coverage under the NCG060000 General Permit.
Printed Name of Applicant: Brian Foor
Title: Plant Manager
8/12/22
(Signature of Applicant) (Date Signed)
Mail the entire package to:
DEMLR — Stormwater Program
Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
Page 4 of 5

Additional Outfalls
3-4 digit identifier:
Name of receiving water:
Classification:
❑ This water is impaired.
❑ This watershed has a TMDL.
Latitude of outfall:
Longitude of outfall:
Brief description of the industrial activities that drain to this outfall:
Do Vehicle Maintenance Activities occur in the drainage area of this outfall?
If yes, how many gallons of new motor oil are used each month when averaged over the
r Yes ■ No
calendar year?
3-4 digit identifier:
Name of receiving water:
Classification:
❑ This water is impaired.
❑ This watershed has a TMDL.
Latitude of outfall:
Longitude of outfall:
Brief description of the industrial activities that drain to this outfall:
Do Vehicle Maintenance Activities occur in the drainage area of this outfall? ❑ Yes ❑ No
If yes, how many gallons of new motor oil are used each month when averaged over the calendar year?
3-4 digit identifier:
Name of receiving water:
Classification:
❑ This water is impaired.
❑ This watershed has a TMDL.
Latitude of outfall:
Longitude of outfall:
Brief description of the industrial activities that drain to this outfall:
Do Vehicle Maintenance Activities occur in the drainage area of this outfall?
If yes, how many gallons of new motor oil are used each month when averaged over the
■ Yes r
No
calendar year?
3-4 digit identifier:
Name of receiving water:
Classification:
❑ This water is impaired.
❑ This watershed has a TMDL.
Latitude of outfall:
Longitude of outfall:
Brief description of the industrial activities that drain to this outfall:
Do Vehicle Maintenance Activities occur in the drainage area of this outfall?
If yes, how many gallons of new motor oil are used each month when averaged over the
■ Yes MI
No
calendar year?
3-4 digit identifier:
Name of receiving water:
Classification:
❑ This water is impaired.
❑ This watershed has a TMDL.
Latitude of outfall:
Longitude of outfall:
Brief description of the industrial activities that drain to this outfall:
Do Vehicle Maintenance Activities occur in the drainage area of this outfall?
If yes, how many gallons of new motor oil are used each month when averaged over the
N Yes ■
No
calendar year?
Page 5of5

Origin -Food Group, LLC'
306'Stamey Farm; Road
Statesville, NC 28677-8326
PAY TO THE NCDEQ - Division of Water Resources
ORDER OF
One Hundred and 00/100****************************************************************************************************
DOLLARS
BRANCH BANKING AND TRUSTCOMPANY.,
STATESVILLE,NC 28677 , ,
66-112/531
17540
8/10/2022
I $ **100.00
r; MEMO
NCUEQ - Division of Water Resources H FoaoT D AGARMIr FRAUD
1617 Mail Service Centere k�oH;agb
Raleigh, NC 27699-1617
n'O L751,00 1:05`3 LO L L 2.LI:000'S'L0lit, 2254'Sum
Origin Food Group, LLC
NCDEQ - Division of Water Resources
Date Type Reference
8/9/2022 Bill Stormwater App
BB&T Checking Acco
Original Amt.
100.00
17540
8/10/2022
Balance Due Discount Payment
100.00 100.00
Check Amount 100.00
100.00
er
0