NCG060379_Waiver Request_20230908

September 8, 2023
Winston-Salem Regional Office—DEQ
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Re: Request for Variance from the 72-hour Storm Interval
Pilgrim's Pride Corporation—Staley Feed Mill
General Permit No. NCG060000
Certificate of Coverage No. NCG060379
To Whom It May Concern,
The Pilgrim's Pride Corporation (Pilgrim's) poultry feed mill located in Staley (Coverage No.
NCG060379) conducts routine stormwater monitoring in general accordance with the Permit.
There are times, however, this Facility may fall subject to the Tier Two (or Tier Three) Response
as a result of a benchmark exceedance and monthly stormwater monitoring is required. The
frequent monitoring of multiple outfalls, along with the storm event constraints of the Permit
(i.e., timing of the Storm, operating status of the feed mill, duration since last rainfall event, etc.)
places a hardship on the Facility to properly gather stormwater samples. Therefore, Pilgrim's is
requesting to reduce the time after the pervious measurable storm event from 72 hours to
36 hours in accordance with Permit Part E-3(b).
Pilgrim's believes that 36 hours is sufficient time to provide a representative sample for the
following reasons:
• Industrial operations at the mill are very continuous/homogenous. The mill typically
operates 24 hours/day for 5-6 days week (as the mill provides feed for local poultry farms
in the area and chickens require feeding year-round). Any industrial activity that may
influence the stormwater runoff quality (i.e., dusts, truck traffic, etc.) are almost always in
operation. Therefore, any potential "washing" from a previous rain event to the next rain
event is short lived and not likely to be a factor within 36 hours.
• Runoff from the feed mill to the outfalls has a short time of travel, as the distance runoff
travels is minimal (less than 750 feet). There are no onsite retention/detention ponds or
holding sumps, etc. that would influence the attenuation of the runoff (i.e., storm runoff
from an event several days prior would have left the property and not remain onsite to
influence the stormwater monitoring). Stormwater that falls on the Site typically dries
quickly(time is dependent upon atmospheric conditions).
Please contact me at (919) 895-3457 ([e-mail]) if you should have any
questions. Pilgrim's cordially requests your response, which may be directed to my attention.

September 8, 2023
Page 2
Sincerely,
Pilgrim's Pride— Sanford, NC Complex
� �Cc
Tina Pedley V '
Complex Environmental Manager
Attachments
Cc: Mr. David Hayes (Pilgrim's)
Ms. Kimberly Turney (NCDEQ Winston Salem Regional Office) — via email
[e-mail]
Ms. Tamera Eplin (NCDEQ Winston Salem Regional Office) - via email
tamera.epl in @ deq.nc.gov