NC0072575_Permit Issuance_19960517

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
May 17, 1996
Mr. Steven Woodruff
Golden Poultry Company, Inc.
P.O. Box 2210
Atlanta, Georgia 30301
ern
[DEHN
Subject:
r u_ .._..
Permit Issuance
Golden Poultry Company, Inc.
Lee County WW
MSC ►-f kwl-
ia> f fuwPp Pt 9Paf
Iti accordance with your application for discharge permit received on October 30, 1995, we are
forwarding herewith the subject State - NPDES permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the US Environmental Protection Agency dated December 6, 1983.
The following comments are offered in response to the April 15, 1996letter from Mr. Warren
Howe:
• Supplement to cover sheet -The reference to a 96 acre overland flow system has been changed
to 130 acre overland flow system.
• Wastewater treatment facility capacity - Since the permitted flow limit is 1.0 MGD, the treatment
plant capacity is specified in that manner in the NPDES permit. The Authorization to Construct
(ATC) letter, when issued, will document that the new treatment plant is capable of treating 1.5
MGD assuming design calculations justify that capability. The ATC letter is sufficient
documentation for plant treatability should flows up to 1.5 MGD be permitted in the future.
• Outfall location - A revised map has been added to the permit designating the existing and future
discharge locations.
• Monitoring frequencies - These are based on the 15A NCAC 2B .0508 regulations for Class III
wastewater treatment facilities. Facilities, such as this one, that must remove a high percentage of
pollutants from their wastestream prior to discharge typically have more extensive treatment, more
treatment units, and are required to monitor more frequently to ensure that the high levels of
treatment are achieved The requirement to conduct instream monitoring 3/week versus weekly
only occurs from June through September. Given the low dissolved oxygen levels typically
occurring in the Deep River during this period, this monitoring frequency is justified.
• Existing land application system - Use of this land for disposal of wastewater must first be
permitted (non -discharge permit) by the Division. This operation is not covered by NPDES
permits. An application form for a slow rate system is provided. Questions regarding the non-
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

discharge application should be addressed to Mr. Michael Allen (ext. 547) or Mr. Ray Cox (ext.
549).
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicative hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless
such demand is made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part II, EA. addresses the requirements to be
followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be required by
the Division of Environmental Management or permits required by the Division of Land Resources,
Coastal Area Management Act or any other Federal or Local governmental permit that may be
required.
If you have any questions concerning this permit, please contact Mr. Greg Nizich at telephone
number 919/733-5083, ext. 541.
Sincerely,
Original Signed By
David A Goodrich
A. Preston Howard, Jr., P.E.
cc: Central Files
Raleigh Regional Office, Water Quality Section
Mr. Roosevelt Childress, EPA
Facility Assessment Unit
Aquatic Survey and Toxicology Unit
Technical Assistance & Certification Group
Permits and Engineering Unit

Permit No. NCO072575
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standardsand regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
Golden Poultry Company, Inc. �L 60 '—�S J
is hereby authorized to discharge w ocated at —t
Golden Poultry Processi ant
NCSRL400
vnmuck—
Lee County
to receiving waters designated as the Deep River in the Cape Fear River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III and IV hereof. nn�
This permit shall become effective Jarnrl; T996-' `S� �a Iv�
This permit and authorization to discharge shall expire at midnight on April 001.
Signed this day MiF4,6t996.--
original Signed By
David A Goodrich
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

Permit No. NCO072575
SUPPLEMENT T PERMIT COVER SHEET
GoldeennPPouul�try, Inc. ``�
is hereby authorized to: _ (j 1 l�C
1. Continue to operate an existing wastewater trea ent facility consisting of screens, dissolved air
flotation, chemical feed, aerated lagoon, storage a oon 130 acr rl d flow system, chlorine
disinfection and flow measurement located at o en Poultry Processin PI NCSR 1400,
Cumnock, Lee County (See Part III of this Pe ' ,
After receiving an Authorization to Construct from the Divi n of Environmental Management,
Construct and operate a new 1.0 MGD wastewater treatiq6t facility, and
i
P
6�1�
3. Discharge from said treatment works at the location specified on the attached map into Deep River
which is classified Class C waters in the Cape Fear River Basin.

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A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1- Oc. tober 31) Permit No. N00072575
During the period beginning on the effective date of the permit and lasting until COMPLETION OFCONSTRUCTION CONSTRUCTION OF A NEW WWTP but
no later than Nov ber 30, 1997, the Permittee is authorized to discharge from outfall(s) serial me nber 001. Such discharges shall be limited
and monitored by the rmittee as specified below:
Effluent Characteristic.
Flow
BOD, 5 Day, 20 °C
NH3 asN
Dissolved Oxygen**
Total Suspended Solids
Oil and Grease
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Total Nitrogen (NO2+NO3+TKN)
Total Phosphorus
Discharge Limitations
Monitoring
ReRequirementa
bs da Units (specify
Measurement
Sample
*Sample
Ava, Daily Max Mon. Ava. Daily Max.
.--reguency
Type
Location
;:ontinuous
Recorder
E
80. 160.0
:?/Week
Composite
E,U,D
12.0 24.0
=/Week
Composite
E
/Week
Grab
E,U,D
496.0 2.0
=; Week
Composite
E
160.0 320.
: /Week
Grab
E
200.0 /100 ml 400.0 /100 ml
_ /Week
Grab
E,U,D
/Week
Grab
E
/Week
Grab
E,U,D
Honthly
Composite
E
Monthly
Composite
E
*Sample locations: E - Effluent,�I - Influent, U - Upstream at NCSR 14ft D - Downstream, 50' above City of Sanford outfall. All stream
samples shall be grab samples. Instream sampling shall be conducted 3/w%tffih
June, July, ,august and September and weekly during the
remaining months of the year.
** The daily average dissolved oxygen effluent concentration shall not be .6 mg/l.
*** Chronic Toxicity (Ceriodaphnia) P/F at 9.0%; January, April, July and October;
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Part III, Condition E.
monitored 3/week at the effluent by grab
�Kp

A. ().EFFLUENT LIMITATION MONITORING REQUIREMENTS SUMMER (April 1- Oti tober 31) Permit No. NCO072575
During the period beginning on th effective date of the permit and lasting until COMPLETION OF CONSTRUCTION OF A NEW WWTP but
no later than November 30, 1997, th Permittee is authorized to discharge fm outfall(s) serial niicnber 001. (Continued)
Effluent Characteristic. Discharge Limitations Monitoring Requirements
a Other Units (specify} iMeasurement Sample *Sample
Mon. Avg. aMaxMon, Avg. Daily Max. ;Frequency Txpj.ocatlon
Conductivity _ /Week Grab U,D
Chronic Toxicity** :tuarterly Composite E
Rainfall inches inches

A. ().EFFLUENT LIMIT ONS AND MONITORING REQUIREMENTS WINTER (November 1 • March 31) Permit No. NCO072575
During the period be ' g on the effective date of the permit and lasting until COMPLETION Ol ; CONSTRUCTION OF A NEW W WTP but
no later than November 30, 997, the Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited
and monitored by the permit as specified below:
Effluent Characteristic. Discharge Limitation: Monitoring Requirements
Lbs/day Units (specify bleasurement Sample 'Sample
. Daily Max Mon. Ava. Daily Max. I:reauencv Type Location
Flow Continuous Recorder E
BOD, 5 Day, 20 °C 80.0 160.0 3/Week Composite E,U,D
NH3 asN 12.0 24.0 3/Week Composite E
Dissolved Oxygen" 3/Week Grab E,U,D
Total Suspended Solids 496.0 992. 31Week Composite E
Oil and Grease 160.0 320.0 3/Week Grab E
Fecal Coliform (geometric mean) 20 /100 ml 400.0 /100 ml 3iWeek Grab E,U,D
Total Residual Chlorine 3/Week Grab E
Temperature 3/Week Grab E,U,D
Total Nitrogen (NO2+NO3+TKN) monthly Composite E
Total Phosphorus Illonthly Composite E
*Sample locations: E - Effluent, I - Influent, U - Upstream at NCSR 1400, D - wnstream, 50' above City of Sanford outfall. All stream
samples shall be grab samples. Instream sampling shall be conducted 3/week d June, July, August and September and weekly during the
remaining months of the year.
** The daily average dissolved oxygen effluent concentration shall not be less than 6.6 m
*** Chronic Toxicity (Ceriodaphnia) P/F at 9.0%; January, April, July and October; See Part Condition E.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be mu 'tored 3/week at the effluent by grab
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts. �f
b

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November I. - March 31) Permit No. NCO072575
During the period beginning on the effective date of the permit and lasting until COMPLETION O CONSTRUCTION OF A NEW WWTP but
no later than November 30, 1997, the Permittee is authorized to discharge from outfall(s) serial number 001. (Continued)
Effluent Characteristic.
Discharge Limitation: Monitoring
Requirements
Lbs/da . Other Units (specify) Measurement
Samale
*Samale
Mon. Avg,. Daily Max Mon. Avg,. Daily Max. requencv
Type
Location
Conductivity
; /Week
Grab
U,D
Chronic Toxicity'*'
(quarterly
Composite
E
Rainfall
inches inches

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A. p. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1- Oc ober 31) Permit No. NCO072575
During the period beginning upon COMPLETION OF CONSTRUCTION OF A NEW WWTP, but no later than December 1,
1997, and
lasting until expiration., the Permittee is authorized to discharge from outfall(s) serial number 001 Such discharges shall be limited
and
monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring Requirements
LbsLbs/dav
Units(Specify)
K:xsurement
Sample
*Sample
Mon. Ava. Daily Max.
Mon. Avg, Daily Max.
Ermuencv
Type
Location
Flow
1.0 MGD
C mtinuous
Recording
I or E
BOD, 5-Day, 20°C
5.0 mg/i 10.0 mg/I
3/Week
Composite
NH3 asN
1.0 mg/1 2.0 mg/I
3,Week
Composite
E
Dissolved Oxygen"
3,Week
Grab
E,U,D
Total Suspended Solids 496.0 992.0
VNeek
Composite
E
Oil and Grease 160.0 320.0
3, Week
Grab
E
(�
Fecal coliform (geometric mean)
200 /100 ml 400 /100 ml
&Week
Grab
E,U,D
t
Total Residual Chlorine
28.0 µg/I
3,Week
Grab
E
Temperature
3 Week
Grab
E,U,D
S
Conductivity
3,Week
Grab
U,D
Total Nitrogen (NO2+ NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Chronic Toxicity*** /
Quarterly
Composite
E
* Sample locations: E - Effluent, I - Influent, U - Upstream at NCSR 1400, D - Downstream 50 fo-. t above City of Sanford outfall.
Upstream and downstream samples shall be grab samples. Stream samples shall be taken three tirr es per week during the months of June, July,
August and September, and once per week during the remaining months of the year.
** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/1.
*** Chronic Toxicity (Ceriodaphnia) P/F @ 9.0%;'January, April, July and October, see Part III, Condition E.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 3/week at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER ve 9 b � � Q (November 1 •March 31)
Permit No. NCO072575 = 1
During the period beginning upon COMPLETION OF CONSTRUCTION OF A NEW WWTP, but no later than December 1, 1997, and
lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001 Such discharges shall be limited and
monitored by the permittee as specified below:
Effluent Characteristics
Lbs/day
Mon. Avg, Daily Max.
Flow
BOD, 5-Day, 200C
NH3 as N
Dissolved Oxygen"
Total Suspended Solids 496.0
Oil and Grease 160.0
Fecal coliform (geometric mean)
Total Residual Chlorine
Temperature
Conductivity
Total Nitrogen (NO2+ NO3+TKN)
Total Phosphorus
Chronic Toxicity"'
992.0
320.0
it
Units (Specify)
Mon. Avg. Daily Max.
1.0 MGD
10.0 mg/I 20.0 mg/I
2.0 mg/I 4.0 mg/I
200 /100 ml 400 /100 ml
28.0 µg/I
Monitoring
Requirements
hl-gasurement
Sample
'Sample
Erequency
Tvoe
Location
C:•>ntinuous
Recording
I or E
3/Week
Composite
E,U,D
3jWeek
Composite
E
3jWeek
Grab
E,U,D
3jWeek
Composite
E
IWeek
Grab
E
ZlMeek
Grab
E,U,D
.jWeek
Grab
E
3,Week
Grab
E,U,D
3,Week
Grab
U,D
Monthly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
* Sample locations: E - Effluent, I - Influent, U - Upstream at NCSR 1400, D - Downstream 50 feet above City of Sanford outfall.
Upstream and downstream samples shall be grab samples. Stream samples shall be taken three tir es per week during the months of June, July,
August and September, and once per week during the remaining months of the year.
** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
*** Chronic Toxicity (Ceriodaphnia) P/F @ 9.0%; January, April, July and October, see Part III, Condition E.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 3/week at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Part III
Permit No. NC0072575
E. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 9.0% (defined as treatment two in the North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. The first test will be performed after thirty days from the effective date
of this permit during the months of January, April, July and October. Effluent sampling for this
testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGP3B . Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.

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07 01/95 16:34
001
O�r
TELEFAX COVER SHEET
DATE: 31/ A'5
TOTAL NUMBER OF PAGES (Including Cover Sheet) \O
Telefax Telephone Number: (gS2L -133 _ qq,q
TO: iJAn..ks Rarv,afy 6N 4 M .
SEC[ r;
FROM: -s , ul) .FF
. GOLD KIST INC.
CORPORATE ENGINEERING DEPARTMENT
244 Perimeter Center Parkway, N.E./P.O. Box 2210, Atlanta, GA 30301
FAX: [phone]
NOTES:
If you experience any difficulty receiving this transmittal, please call us at
[phone].

03/01/95 16:37 002
GOLD KIST INC. P.O.3ox?2,10 . Atlanta, GA 3U301 • Z44 Perimeter Center Pkwy., N.E Atlanta, GA 30346. (404) 393-X00
February 23, 1995
Mr. Dennis R. Ramsey
North Carolina Department of Environment,
Health and Natural Resources
]division of Environmental Management
Water Quality Section .
F.O. Box 29535
Raleigh, North Carolina 27626-0535
Re: response to February 14, 1995 Letter
Golden Poultry Company Inc.
Sanford, North CaroUna
Dear Mr. Ramsey:
This letter responds to your second round of inquiries on the Diagnostic Evaluation submitted
by Golden Poultry Company on December 1, 1994. Our responses are arranged to correspond
to your numbered questions.
1) Question
When the wastewater treatment system was originally designed, what was the number of
days per week that the overland flow system was intended to be in service? If more than
five days per week, what was the effect of reducing the number of days per week in
service on the quality of the effluent'!
MuRnse
The overland flow (OF) treatment system was designed to be operated with direct
application of wastewater from the dissolved air flotation (DAF) unit. Processing
operations are primarily conducted five days a week (Monday - Friday), and wastewater
generated in processing operations is typically directly applied to the fields. If processing
is conducted on Saturdays, the OF system is typically operated (i.e. wastewater from the
DAP unit is sprayed directly and not stored). The OF system was designed under the
scenario the plant would typically process chickens five to six (5-6) days per week.
On a weekend during which there has been no processing, typically about 400,000 to
600,000 gallons of wastewater are generated as a result of maintenance activities, clean-
up, melting ice, etc. This wastewater is typically held in the. surge and storage ponds
and irrigated over the processing week (i.e. Monday - Friday). The volume of
wastewater generated over weekends typically accounts for 5 % to 10 % of the total
volume of wastewater generated over a seven day week. Applying "weekend
wastewater" during the processing week results in slightly higher hydraulic loadings on
the OF fields. However, as indicated in my letter of January 17, 1995 (response to

03/01/95 16:38 003
Page TWO
question number 2), the actual hydraulic loading rates on the OF treatment system are
well within the design hydraulic loading rates (very low end of design range) for OF
treatment systems specified in USEPA's "Process Design Manual For Land Treatment
of Municipal Wastewater", dated October 1981.
2) Quation
What were the reasons for the reduced efficiency of the DAF unit during May, June and
July 1994? This is of special concern to us since there were also major permit violations
for this same period of time.
Reslionse
We cannot specifically pinpoint what conditions contributed to the decreased treatment
efficiency in the DAF unit during May, June and July, 1994. However, we speculate
that a combination of factors including possible polymer quality problems, lower pH in
the DAF system, and/or other unknown conditions may have influenced DAF treatment
effic' ticy during this time period. I wish to note that wastewater operators had lowered
the p in DAF system in attempts to improve DAF treatment performance.
3) QuestLU
There seems to be mussing data on effluent from the DAF unit for the month of July
1994. Samples are normally collected and analyzed weekly but during this month results
for only one sample were provided. What was the reason for the missing data?
Response
Sampling of DAF influent and effluent is performed as time and operator workload
allow. We try to collect the data regularly to have a record of the operational
performance of the DAF unit, but occasionally others factors prevent the collection of
these data. Only one DAF effluent sample was reported for the most of July 1994 for
the following specific reasons:
The effluent sample collected from the DAF during the week of July 111 1994
was broken in shipment to the laboratory.
• Sampling of influent and effluent to the DAF unit is typically performed at the
same time final effluent sampling is being conducted. Due to significant rain
events during the beginning of the weeks of July 18, 1994 and July 25, 1994,
final effluent sampling was moved to later in the week, Friday and Thursday,
respectively. Due to this shift, samples could not be delivered to our laboratory
(Gold Kist Research Laboratory, located in Lithonia Georgia) within holding time
(48 hour for BOD analysis), and DAF influent and effluent sampling was not
conducted. Analysis of final effluent samples is performed by a Iocal "third
party" laboratory. To minimize costs, all other analytical testing is typically
performed by Gold Kist's laboratory.

• 03/01/95 16:38
IIi
Page Three
4) Questi
On page 3 of your report, you stated that "there has been a trend of increasing
concentrations of BOD, TSS, and TKN in influent water to the DAF unit over the past
2-112 years". What is the reason for this increasing concentration?
Emome
As indicated in my letter dated January 17, 1995 (response to question No, 3), it is
difficult to collect representative influent samples to the DAF unit, and any conclusions
drawn about variations in influent levels may or may not be correct.
Fluctuations in DAF influent water quality is not unusual for poultry processing
operations. We can not definitively pinpoint any specific factor that may have
contributed to the perceived increase in influent levels of BOD, TSS, and TKN to the
DAIS system at the Sanford plant. However, following is a listing of conditions that can
account for variations in influent levels of BOD, TSS, and TKN:
0 Variations in product yields and condemnation rates in processing
operations;
• Variations in the fat content in the birds processed;
• Variations in the amount of product processed in "cut-up" operations;
• Variations in plant clean-up operations required by USDA inspectors; and
• Variations in bird size.
The factors listed above have been present since start-up of the facility. Over the most
recent months, influent levels of BOD, TSS, and TKN to the DAF have been trending
downward.
As Indicated In my January 17,1994 letter, the concentrations of BOD, TKN, TSS,
and NHs-N in DAF effluent have remained relatively consistent over the past several
years, making this concern a non -issue.
S) offlestion
On page 3 of your report you state "The NH3-N concentration in DAF effluent on July
14, 1993 was above the design level for NH3-N.". What was the reason for this
increased concentration?
ResRonse
A review of plant operating logs indicated no specific condition(s) that wouId have
explained the elevated NH3-N concentration detected on July 14, 1993.

• 03/01/95 16:39 005
Page Four
6) Queue
On page 5 of the report you state "the DAF performance has not been a major factor
contributing to the noncompliance". We fail to see how such a matter of fact statement
can be made considering the correlation between poor performance of the DAF unit
during the summer of 1994 and the effluent violations during these same months. How
can taking a major part of your treatment system off line not have a significant effect on
the quality of the effluent? Please explain.
R. Monse
To clarify the issue, the DAF unit was not taken off-line during the summer of 1994.
The DAF unit was being operated throughout the summer of 1994, and this unit was
removing a significant portion of the materials contributing to BOD, TSS, and TKN
concentrations in plant wastewater. During the summer of 1994, the treatment efficiency
of the DAF unit was depressed for some unknown reason(s). However, experience has
shown that the OF treatment system can handle significant loading fluctuations without
significantly impacting final effluent quality, A review of operating data collected from
the OF treatment system clearly displays this benefit. Specifically, a review of operating
data indicates several other incidences (other than during the summer of 1994) when
elevated BOD, TSS, and TKN concentrations were present in the influent to the OF
system, and no degradation of effluent quality occurred (i.e. no violations occurred).
The summer of 1994 was one of the wettest summers since plant operations began. This
condition, coupled with the contribution of BOD, NH3-N, etc. from background sources,
had the strongest influences on OF treatment system performance during this time period.
Degraded treatment efficiency in DAF unit may have had some influence on conditions
during the summer of 1994, but, as indicated above, past operating history does not fully
support this conclusion. In depth discussions on rainfall amounts during the summer of
1994 and background contributions of BOD, NH3•N, etc. were included in my January
179 1995 letter.
7) Quesi on .
On page 7 nF the. rP.nnrt whilta rlicpimaina tho ^ffssnto ni MIA— rozl In ^..♦ .+R wwr.i.w ......
.. v a .— --- ��"'� ---- v• •ay.wdv WWI va qva rAL4 YWU
state "We do not attribute BOD noncompliances to this action". We do not understand
how this conclusion was reached. Please explain.
Review of operating data indicates no correlation between BOD noncompliances and
taking fields out of service for maintenance. As indicated in my January 17, 1995 letter
(response to question No. 4), the BOD noncompliances that have occurred over the past
several years are primarily related to high flows caused by rainfall conditions and
background contributions of BOD, NH3-N, etc.. Further, a review of operating data
indicates no significant variation in effluent BOD concentrations between winter (Nov. -
Mar.) and summer (Apr. - Oct.) months. Fields are typically not taken out of service
for maintenance during the winter months.

03/01/95 16:40
Page Five
8) Queen
Can page 8 of the report you cite an EPA report which states "Studies with screened raw
and primary effluent municipal wastewaters showed effluent BOD concentrations to be
only slightly elevated above normal operations values, but well below 30 mg/l secondary
treatment standard".
We agree that your effluent values are below 30 mg/1, but the data in table 10 does not
support the contention that the concentrations are only slightly elevated. Your data show
an average 130D of 4.1 mg/1 with no rain increasing to 12.71 mg/1 with over 1.0 inch
of rain. This would seem to indicate that either deposited materials are being washed off
the fields during rain events, or the wastewater is receiving lower levels of treatment
during rain events, or very possibly both. Please provide sufficient information to clarify
this issue.
On page 8 of the January 17, 1995 letter, I cited a USEPA study that states "Experience
has shown that rainfall of any intensity has little effect on effluent BOD concentrations.
Studies with screened raw and primary effluent municipal wastewaters showed effluent
BOD concentrations during rainfall events to be only slightly elevated above normal
operating values, but well below the 30 mg/L secondary treatment standard, Similar
results have been found at. several industrial overland flow systems treating food
processing, textile, and pulp and paper wastewaters. Most of the industrial experiences
showed that the effluent BOD concentrations increased slightly during moderate rainfall
intensities and/or short duration storms, but actually decreased below normal operating
values during high intensity and/or long duration rainfall events. This decrease can most
likely be attributed to dilution."
In the response to question number 9 in the January 17, 1995 letter, rainfall and effluent
data was analyzed in two parts, parts II and III, Part II began on page 9 and Part III
began on 11. Part II was a high-level analysis that used all available data to determine,
in general terms, the influence of rainfall on effluent discharge. We stated that the data
were non -normal and hence used medians as a measure of central tendency. We also
provided Table 11 which gave summary statistics for the rainfall intervals that were
chosen for the analysis. Part III was a more detailed analysis that included random
sampling (relative to rainfall) and assessed the role of antecedent watershed conditions
on discharge.
'fable 10 was prepared as a means of simply showing median values. However, as Table
I I clearly showed, the ranges of the BOD concentration data for each rain interval were
very similar, even though the median values increased. A statistical analysis comparing
these data was not conducted because, as we indicated (p. 11), these data were non-
random relative to rainfall events (that's why a different data base was used for the
analysis in part III). Sample sizes were also very different. The difference in sample
sizes between rainfall intervals is believed to have had the strongest influence over

03/01/95 16:40
i
.%
Page Six
the difference in median effluent BOD values between rainfall intervals (i.e.
difference is not be a real condition but rather a statistic$I anomaly). Attached Table
1 shows the range of BOD concentrations associated with the different rainfall intervals,
Response to question number 14 and Table 9 included in the January 17, 1995 letter
Presented a more representative comparison of BOD and NH3-N concentrations in final
effluent during wet and dry weather conditions. 'Table 9 clearly indicated very similar
concentrations of BOD and NH3-ICI in final effluent during wet and dry weather
conditions. Over a range of rainfall from 0,2 to 1.8 inches, the average 130D
concentration was 8.5 mg/l, and at times of no rainfall the average BOD concentration
was 7.3 mg/l. The average NH3-N concentration was 0.9. mg/1 during wet weather
(rainfall) and 1.8 mg/l during no rainfall. The comparison presented in Table 9 is more
applicable for assessing any variations in BOD and NH3-N concentrations during wet
weather and dry weather, since data pairs from the same time periods were used in the
analysis.
The OF treatment system at the facility produces a final effluent with substantially lower
BOD concentrations than 30 ing/l, The OF system typically produces a final effluent
with constituent concentrations comparable to other conventional tertiary (advanced)
treatment systems. The book "Wastewater Engineering, Treatment, Disposal and
Reuse", third edition by Metcalf and Eddy, Inc., page 670 indicates the following
treatment levels achievable with advanced conventional wastewater treatment systems
(i.e. activated sludge with nitrification - denitrification + granular -medium filtration):
Activated Sludge Actual Avg. Cones, off
OF F TrgMme�ntSrystem`
BODS (mg/1) < 5-10 6.6
NH3-N (mg/1) 1-5 1.2
SS (mg/1) < 3-6 6.3
Total N (mg/1) 5-10 903
* Actual average concentrations of constituents in final effluent from the OF system
during the time period of October 1992 - November 1994.
9) 011WHOn
On page 14 of the report you state, "The operating pressure issue with the DAP system
was not a significant problem". What led you to that conclusion? What data is available
to support that position?
Respgnse
As indicated in the January 17, 1995 letter (response to question number 11), the DAF
system had been operating at a lower pressure prior to the decline in treatment
performance experienced during the summer of 1994. This factor alone indicates this

03/01/95 16:41 008
Page Seven
condition was not a significant cause of the decline in DAF treatment performance during
this time period. In addition, Gold Kist has several other DAF systems operating at
similar pressures, and constituent levels are comparable to those typically provided by
the DAF system at the Sanford, North Carolina plant.
10) QMestion
On page 14 of the report you state "The ideal pH for the optimum treatment in DAF
systems will vary from plant to plant as well as day to day". What is the optimum pH
for the facility?
Rest
As indicated in the January 17, 1995 letter, the ideal pH for optimum treatment in DAF
systems will vary from plant to plant as well as day to day. The typical operating pH
in the DAF system at the Sanford plant is 5.2.5.5 units. However, operators typically
"fine tune" the pH (adjust set point on pH controller) in the DAF system based on the
clarity of the effluent from the DAF system (i.e. DAF system is operated at the pH that
provides the best water clarity). Operators will operate the DAF outside the above listed
pH range if enhanced water clarity is provided. Fluctuations in the optimum pH for the
DAF system can be caused by variations in polymer composition, ferric sulfate
composition, influent water duality, etc..
11) Question
The effluent sampling for the months of June and July, 1994, deviate from the normal
practice of Wednesday monitoring. Why was this done? This is of concern to us
considering the facility's noncompliance during these months.
Res o e
As indicated in the January 17, 1995 letter, a significant amount of rainfall was received
at the facility during the summer of 1994. In June 1994 the facility received 6.27 inches
of rainfall, and 5.54 inches of rainfall were received in July 1994. Sampling days were
shifted during these months in an attempt to avoid sampling under conditions
unreprescntative of the OF system's performance, since rainfall off the terraces and
surrounding areas would carry a certain background load of HOD, TSS, NH3-N, etc.
Golden Poultry was advised that sampling days could be shifted to avoid the influences
of rainfall events by Tim Donnelly of the Raleigh Regional Office of DlM, during a
meeting held at DEM offices on November 17, 1993.
12) Questio
How often in the past two years has production taken place on the weekends? When
were these periods?

i
03/01/95 16:41
f
Page Fight
Respo
Following is a summary of the days production that took place on the weekends;
16 January 9, 1993 - one processing shift (Plant down on 1/1/94)
• August 14, 1993 - one processing shift
July 2, 1994 ; one processing shift (Plant down on 7/4/94)
• August 27, 1994 - one processing shift
0 September 17, 1994 - one processing shift
• November 5, 1994 - one processing shift (Plant down 11111/94)
As indicated above, production was conducted on several of the Saturdays
to offset the plant being down on a weekday.
..-
please contact me at [phone] if you have any additional questions concerning the above
information,
Sincerely,
Steven R. Woodruff, P.E.
Director, Environmental Engineering
and Compliance
SRW.*jmc
Attachment
cct Mr. Sidney Prince/Mr. Bruce Morgan
Mr, Glenn Berry
Mr. Vernon Rowe, Rowe Environmental
Mr. Bud Smart, Smart & Associates
Mr. Craig Bromby, Hunton & Williams
File

16:42
Ip 03/01/95
NE
Fable 1. Rainfhll Intervals, Median Effluent (MOD) and DODs tmg/L and lb/day), and Range of
BODs.
Rain Interval .
Median Values (from Table 11)
Range of BUD
Effluent
BODS' .
Inches
MOD
mg/L
lblday
n
mg/L
0
0,38
4.1
13
205
1.1 to 17.3
0,01 - 0.50
0.52
5.69
25
31
1.2 to 13.8
0.51- 0,99
0.87
9.34
68
9
0.5 to 25.9
1.0+
1.43
12.71
151
4
2.4to 12.5