NC0026441_Pretreatment_Annual_Report_20240229

Tobin of *ffer ettp
Public Works and Utilities
February 29,2024
NC DEQ
Pretreatment
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Pretreatment,
Enclosed is the Town of Siler City's 2023 Pretreatment Annual Report. Please review and should you have any
questions or need additional information, please let me know.
Sincerely,
Chris McCo q dale
Director of Priblie Utilities
Town of Siler City
Chris McCorquodale
Director Public Utilities
PO Box 769 • 311 N. Second Avenue
Siler City, NC 27344-0769
[e-mail]
Phone: [phone] • Fax: [phone]
www.silercity.org
To advance a framework for oarsuccess thror{gh balaned governance, dVnrarnic partnerships, and an engaged community.

DocuSign Envelope ID: E2FDF938-CB5C-4903-99BQ-47A5016OBBE9
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR
Director
NORTH CAROLINA
Environmental Quality
Subject: 2024 Pretreatment Mailing — End of the 2023 Calendar Year
Greetings Pretreatment Professionals:
The beginning of a pretreatment year is a very busy time, and this letter is an update for important
issues along with the attached Pretreatment Program Info Database page(s) for the 2023
Pretreatment Annual Report due March 1, 2024.
New Items for 2024:
Certified Permit Writer (CPW) Streamlining
o By attending the NC -PC Training and submitting 3 lUP packages successfully a
pretreatment professional can be deemed to be a CPW.
o Streamlined submissions will in the fiiture require transmission of the 1UP
application and IUP inspection for the Division's file.
o The Division needs completed applications on file for both new and renewals of
RJPs. Pretreatment and NPDES staff will need to refer to these for industrial contact
information and to respond to management inquiries about industrial process
effluent characteristics and assessments of permit requirements. Without this
information, the Division is unable to provide accurate information regarding the
decision of the Control Authorities.
• PFAS
o Renewed NPDES permits may include PFAS monitoring or other pretreatment
requirements.
0 1633 Method
If you plan to Monitor for PFAS before EPA approval of 1633, we are
recommending using either draft method 3 or 4 in the absence of a final 40
CFR Part 136 method. Laboratories approved for aqueous matrix may be
utilized. Please note that the lab used does not have to be physically located
in North Carolina.
Note. PFAS data would not typically be reported in DMRs until the method
is approved by North Carolina.
In various conversations and discussions with EPA representatives, the
Division has been informed that draft 4 of method 1633 will eventually be
the final aqueous method. The Division has been informed that the aqueous
method information will remain as presented in the 4" draft of the method.
D E Q � North Carolina Dcpamricni or Cnviranusntal Qnality I Division of Water Resources
5 t2 North Salisbury Strcct 11611 Lail Service Cenccr [ Rakich. North Carolina 27699-161 l
919.707.9000
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• 1,4-Dioxane
o Renewed NPDES permits may include 1,4-dioxane as a pollutant of concern. The
Division encourages all POTW to screen industries for their potential to discharge
1,4-dioxane.
• Updated Permit Model
o A new Industrial User Permit (IUP) model has been released for use. Changes
include the addition of SIC/NAICS code requirements and a description of SIU's
operations which discharge process wastewater, Although POTWs are not required
to use the IUP model, the Division requests that all POTWs conform to include
elements represented in the changes made to the model.
• IWS
o In 2024, Industrial Waste Surveys (IWS) will no longer have a date requirement to
be submitted to the Division every S years. POTWs should maintain an IWS that
may be requested by the Division for review.
o An appropriately maintained IWS is a valuable overview of the POTW's service
area and industrial profile. This information can be used for current assessments of
potential industrial additions. The Division has received an increased volume of
third -party requests for POTW information and the IWS is an integral part of
supplying representative up-to-date data. A well -maintained IWS is a good measure
of the POTW's ability to fulfill the foundational requirements of the Pretreatment
program.
o DWR staff will review the IWS for completeness during program inspections.
Renewal of NPDES permits will indicate the need to revise and/or update the IWS
within ISO days following the effective date of the new NPDES permit. We request
that the most recent IWS spreadsheet on the Division's website be used.
+ HWA
o POTW with a Headworks Analysis (HWA) due within a 6-month period prior to
the issuance of a new NPDES permit can request an extension to submit their HWA
after the NPDES permit is issued.
• Backlog Concerns
o Prioritization of IUP reviews has been successfiil in reducing the backlog,
o Selected backlogged HWAs are being reviewed in conjunction with IUP reviews
and program assessments.
• SNC Data Sheet
o The 2023 PAR cycle will not provide the SNC data sheet. This is due to the
decommissioning of FileMaker Pro, the database program for maintaining SNC
infonmation.
• Pretreatment Information Database Sheet
o Most information from the 2022 PAR Program database has been updated, but
some may have been overlooked in the process. Please make any changes necessary
to bring your Program's information up to date in 2024.
• EPA Update
o The EPA has proposed updating 40 CFR 432 Meat and Poultry Products effluent
guidelines.
DE�'7A North Carolina Dcparnnent Of EnviroomentaI Quality I Division of Water Resources
�/ 512 North Salisbury Street 1 1611 Mail Service C'cnter [ Raleigh, North Carolina 27699-1611
n�mi, cana,w �
arm 1of[IIM1lfmm N A919.707.9000

DocuSign Envelope ID: E2FDF938-CB5C-49D3-99BO-47A5016OBBE9
Pretreatment Staff Training Updates
o This past year, the Pretreatment staff attended training sessions organized by
Federal, State, and Professional Organizations.
■ EPA Pretreatment IQ 1 in Albuquerque, New Mexico, and Columbia, South
Carolina.
■ Association of Clean Water Administration (ACWA) Workshop plus
Training in Boise, Idaho.
■ The Great Lakes PI~AS Summit, a virtual event.
■ NC -PC Annual Conference and Industry Day
■ NC One Water Conference in Raleigh, North Carolina
■ Various EPA's Office of Compliance Technical Assistance Webinars
Additional Information and Reference Links
Industrial Wastewater Survey Summary Table
EPA 4th Draft Method 1633
l 4-Dioxane Document
Addressing PFAS Discharges in NPDES Permits and Through the Pretreatment Program and
Monitoring Programs
Meat and PoultEy Effluent Guidelines
Pen -nit Writing Guidance page
NPDES Wastewater PermittingBranch anch Update: Michael Montebello, NPDES Wastewater
Permitting Branch Chief is managing 3 units. The NPDES Municipal Permitting Unit
supervisor position is vacant - pretreatment staff are reporting directly to Michael Montebello.
The NPDES Compliance & Expedited Permitting Unit supervisor position is vacant because
John Hennessy has been promoted and is now DWR's Regional Offices Section Chief, The
NPDES Industrial Permitting Unit is supervised by Doug Dowden.
NPDES Wastewater
Permitting Branch
Branch Chief: Michael
Montebello
NPDES Compliance & I NPDES Industrial Permitting
Expedited Permitting Unit Unit I NPDES Municipal Permitting Unit
Supervisor: Pending + Supervisor: Doug Dowden I Supervisor: Vacant
NPDES Municipal Pretreatment Collection
Permitting Systerns
D—E0 North Carolina Department of Environmental Quality I Division of Water Rcourccs
112 North Salisbury Street 11611 ivlail service Center I Raleigh, North Carolina 27699-1611
m
+aan+cnpo! a+n 919.707.9000
u�o.roirm

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Staff Assignments: Pretreatment Unit goals for project reviews are 30 days for R- Ps and SIU
drops and 90 days for ERP, HWA, IWS, LTMP, and SUO. This year, we have filled a previously
vacant pretreatment coordinator position.
Octavio Henriquez: Octavio. Henriquez cr deq.nc.gov, Office Phone: [phone]
Keyes McGee. Keyes. Mcee deg. nc. gov, Office Phone. [phone]
Al Woodall: ALWoodall a,deq.nc.gov, Office Phone: [phone]
Natalie Gorensek: Natalie.Gorensek de .ne. ov, Office Phone: [phone]
New Staff Introduction
Natalie Gorensek started at the Central Office in October of 2023. She has a degree in chemical
engineering from NC State (Go Pack?) and previously worked as an Environmental, Health,
and Safety professional for several industries in Moore, Robeson, and Richmond counties.
Workshops: The following workshops are projected for 2024. The invitations and directions
for these workshops will be emailed to POTWs and NC -PC.
We will send links to register for the virtual events once scheduled.
a. Pretreatment Annual Report (PAR) Workshop—1February 8, 2024
b. NC Manufacturers Association (NCMA) Water Quality Compliance Workshop — February
2024
c. Headworks Analysis (HWA) — Staff assistance available upon request
d. Industrial User Permit Writing (IUP) NC -PC Pretreatment Professional Training
Program
Pretreatment 101 (PT 101) — With NC -PC Conference - September 2024.
As always, please contact pretreatment staff members (as listed above) with any questions or
comments.
tkm/EOY_2023_Letter
Attachments: Program Info Sheet(s)
EC: Municipal Permitting Unit Staff
Regional Office Pretreatment Staff
Pretreatment Consultants
Sincerely,
Cy
nocuSigned b: l 1, l tuh
C464537439644FE...
Michael Montebello, Branch Chief
NPDES Wastewater Permitting Branch
North Carolina Dcparhncn[ ofEnv iratmen[al Quality I Division oflVatcrRcsoutres
i 12 North Salisbury Street l 1611 Mail Scrvice Center I Raleigh, north Carolina 27699-1611
NOKfH Gy,9uN.t +
D.P,i,„y� 919.707.9040

'Totull of *ffer City
Public Works and Utilities
February 23, 2024
ANNUAL PRETREATMENT REPORT NARRATIVE
The Town updated Brookwood and Mountaire's permits and added Siler City Water Plant onto the
pretreatment program this year to comply with the Special Order of Consent (SOC).
All three IUP's were placed on a compliance schedule. Compliance schedules are attached.
Wolfspeed has requested a pretreatment permit. It is in review.
NOTICE OF NONCOMPLIANCE
Brookwood Farms, Inc. — I.U. 003
Brookwood Farms had eight (8) violations through their self -monitoring program for the year 2022. This
was issued as one NOV in March of 2023. There were no violations through their self -monitoring
program for the year 2023.
• During the 2022 PAR review, it was discovered that Brookwood had seven self -violations for 2022
issued in March 2023 after completing the 2022 PAR report.
Exceeding Flow for the months of May, June, and August. **
• Exceeding Total Nitrogen for January, June, July, September, and October.
Brookwood Farms, Inc. had one (1) notice of violation through the Town's monitoring program for the
year 2023.
• Exceeding daily max flow in the month of March.**
• They requested a flow increase before the moratorium as they were expanding. A flow increase
of an additional 25,000 gpd was granted in June of 2023 with the release of flow from phase 1 of
the SOC.
**The person who submitted Brookwood's report every month has been replaced. There was some
confusion with the new person about how to report their flow. When Brittany reached out to help it was
discovered they had been reporting flow wrong. They were reporting the flow of what the Town billed

for water instead of what their pretreatment meter read, giving them a higher reading than what should
have been. With Brittany's help, they started reporting their flow the right way.
Mountaire Farms, Inc. —I.U.004
Mountaire Farms, Inc. had ten (10) notice of violations through the Town's monitoring program for the
year 2023.
• Exceeding daily max of NH3 in January, February, March, April, May, June, July, August,
September, October.
• Exceeded monthly max of NH3 in January, February, March, May, July, September.
• Exceeding daily max of BOD in January, February, March, April, May, June, September.
• Exceeded monthly max of BOD in January, February, March, April, May, September.
• Exceeded daily max of TN in January, March, April, June, September, and December.
• Exceeded monthly max of TN in January, February, April, May, September.
• Exceeded daily max of TP in January.
Mountaire Farms, Inc. had one (1) reported notice of violation through their self -monitoring program for
the year 2023.
• Exceeding daily max of BOD in the month of September.
Mountaire was not placed under SNC as the Town is working with Mountaire to possibly remove or
reduce some NOV based on additional research the Town is conducting.
Mountaire has contested their permit. We have had a meeting with Mountaire and NCDEQat
Mountaire's request. We have also had a hearing in front of a hearing officer as required in sewer use
ordinance. The hearing officer ruled in favor of the town. The hearing Officer report is attached.
Mountaire contested the hearing officers report. The next step is to have a hearing in front of the Town
Board. This hearing has been delayed multiple times for various reasons. The last hearing was postponed
by the Siler City Utilities Director as we are working with Mountaire to see if these issues can be resolved
without having a hearing.
We have addressed and resolved some issues already, which include sampling location. We are currently
reviewing data from the wastewater plant lab and Mountaire's outside lab to see if any NOV's and civil
penalties can be resolved. There are currently $495,850 unpaid civil penalties that are being contested
as well.
We are also looking to have Mountaire start sampling daily to address the additional sampling
requirement placed on the Town by NCDEQ.
Chris McCorquodale
Director of Public Utilities [e-mail]
PO Box 769.311 N. Second Ave. Phone: [phone] • Fax: [phone]
Slier City, NC 27344.0769 www.silercity.org
To advance a fruinework for our success through balanced governance, dynamic partnerships, and an engaged co nmunity.

Town Of Siler City — I.U. 005
• Town of Slier City Water Plant was added to the pretreatment program in 2023.
Siler City Water Plant had two (2) notice of violations through the Town's monitoring program for the
year 2023.
• Exceeding Monthly Average of Iron for June and August.
Siler City Water Plant had one (1) reported notice of violation through their self -monitoring program for
the year 2023.
• Exceeding Daily max of Iron for August.
Chris McCorquodale
Director of Public Utilities
Town of Siler City
Chris McCorquodale
Director of Public Utilities [e-mail]
PO Box 769 e 311 N. Second Ave. Phone: [phone] • Fax: [phone]
Siler City, NC 27344-0769 www.silei,city.org
To advance a%rarnework for our success through halancedgovernonce, dynamic partnerships, and an engaged community.

Pretreatment Program Info -Database,
for Program Name Sller City
WWTP Name Town of Siler City
Program Approval Date 06/15/1984
Pretreatment Status Full
Region RRO
County Chatham
NPDES Number NCO026441
printed on: 1 2/22/2023
Stream Information . IWC pro at 7Q10 95.38
7010 Flow cfs / mgd D.3 / 0.19
1 Q 10 Flow cfs / mgd 0.26 / 0.16
Stream Classification C
Basin Number CPF12
Receiving Stream Name LOVES CREEK
NPDES Effective Date 06/01/2014
Last PAR Rec 03/03/2023
PAR Due Date03/01/2024
mercury
NPDES Expire Date 05/31/2019
Current Fiscal
08/24/2020
1631
required
Year PCI Done
POTW is Primary WWTP TRUE
Last Audit on 09/29/2021
Audit Year Nex125/26
es
Design Flow mgd 4.0000 % Design
mgd is SIU permitted
40.88
Permitted SIU flow (mgd) [Pt-,SIU) 1.635
WWTP SIU's Program SIUs
WWTP CIU's Program CIUs
HWA LTMP
1WS Sl#O
ERP
date Inactive Date Next Due
Date Received by DWR
04/16/2021 10/11/2021 02/28/2023 12/18/2012
06/02/2-020
Date Approved
01/02/2013
09/02/2020
Adopt Date Required
Date Adopted
01/22/2013
Info in this Box from Pt Contacts
PT —Pro
Formal Name g.Prime Phonel
Mr. Chris McCorquodale jPrirr
[e-mail]
Ms. Bobbie Hill
[e-mail]
JQ�+Prim
"')b 2- )4
1o'4 D a-}-4� 5 Lza.: k- , as
19-742-4732
19-742-4581
ent Related NOVs from DWQ
NOV-2005-PC-0235-submit IUP mods
Date Date
Attended Attended
ext Fax HWA Wksp UP Wksp
19-663-3874 01/31/2018
Director of Public Works & Utilities 1POBox769
01131 /2018
Lab Supervisor IPO Box 769
I Pu a er t- IPO Box 769
Date
Attended
PAR Wksp
-1�a I AA146.zdAq
344
DWR Central Office Contact JPretreatment Staff
DWR Regional Contact Cheng Zhang

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1. Pretreatment Town Name: Town of Siler City
2. "Primary" NPDES Number NC00 26441
or Non Discharge Permit # if applicable =>
3. PAR Begin Date, please enter 01/01/yyyy
4. PAR End Date, please enter 12/31/yyyy
5. Total number of SIUs, includes CIUs
6. Number of CIUs
7. Number of SIUs with no IUP, or with an expired IUP
8. Number of SIUs not inspected by POTW
9. Number of SIUs not sampled by POTW
10. Number of SIUs in SNC due to IUP Limit violations
it. Number of SIUs in SNC due to Reporting violations
12. Number of SIUs in SNC due to violation of a Compliance Schedule, CO, AO or similar
13. Number of CIUs in SNC
14. Number of SIUs included in Public Notice
15 Total number of SIUs on a compliance schedule, CO, AO or similar
16. Number of NOVs, NNCs or similar assesed to SIUs
17. Number of Civil Penalties assessed to SIUs
18. Number of Criminal Penalties assessed to SIUs
19. Total Amount of Civil Penalties Collected 19. =>
20. Number of IUs from which penalties collected
AO
Administrative Order
CIU
Categorical industrial User
CO
Consent Order
IU
Industrial User
IUP Industrial User Pretreatment Permit
NNC Notice of Non -Compliance
NOV Notice of Violation
PAR Pretreatment Annual Report
3. => 01/012023
4.=> 12/31/2023
5. _>
3
6. =>
0
7. =>
0
8. _>
0
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$
401,900
20. _>
1
POTW Publicly Owned Treatment Wort
SIU Significant Industrial User
SNC Significant Non -Compliance
revised 1/2018: PAR PPS 2018

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Town of Slier City
Long/Short Term Monitoring Plan
(Updated 04/26/2023)
A. Sampling Points
1. Influent
2. Effluent
3. Activated Sludge Basin (Oxidation Ditch)
4, Sludge to Disposal
5. SIU 0003 - Brookwood Farms
6, SIU 0004 - Mountaire Farms
7. SIU 0005 - Slier City WTP
8. SIU 0006 - Wolfspeed
13. Pollutants of Concern (POC)
1.
Ag
12.
Zn
2.
As
13.
Chloride
3.
Cd
14.
Total Phosphorus
4.
Cr
15.
NH3-N
5.
Cu
16.
BOD
6.
Fe
17.
TSS
7.
Pb
18.
% Solids
8.
Hg
19.
Flow
9.
Mo
20,
Oil & Grease (Industries Only)
10,
Ni
21.
Total Nitrogen
11.
Se
C. Flow
Flow Is Monitored at the Influent site during sampling events.
D. SIU Monitoring
Signficant Industrial User monitoring will be conducted per industrial
User permit. All POC's will be monitored once per year.

E.
Sampling
Point
1. Influent
2. Effluent
Town of Slier City
Long/Short Term Monitoring Plan
(Updated 04/26/2023)
Sampling Frequency
First Year Thereafter
Quarterly on a
workday per
NPDES
Quarterly on a
workday per
NPDES
3.Activated Twice per year
Sludge Basin
4. Sludge Per Sludge Permit
to Disposal & 503Regulations
S. SIU #0003
Per SIU Permit
Brookwood Farms
all POC's once
per year
6. SIU #0004
Per SIU Permit
Mountaire Farms
all POC's once
per year
7. SIU #0005
Per SIU Permit
Slier City WTP
all POC's once
per year
8. SIU #0006
No permit issued yet
Walfspeed
Quarterly on a
workday per
NPDES
Quarterly on a
workday per
NPDES
Twice per year
Per Sludge Permit
& 503Regulations
Per SIU Permit
all POC's once
per year
Per SIU Permit
all POC's once
per year
Per SIU Permit
all POC's once
per year
One Year
before HWA
Quarterly on a
workday per
NPDES
Quarterly on a
workday per
NPDES
Twice per year
Per Sludge Permit
& 503Regulations
Per SIU Permit
all POC's once
per year
Per SIU Permit
all POC's once
per year
Per SIU Permit
all POC's once
per year

Town of Slier City
Long/Short Term Monitoring Plan
Updated 04/26/2023)
F. Sampling Plan
POC
IRA
I Pt.2
I PT.3
I PTA
jPt.5
I PT.6
JPT.7
PT.B
AA.
X_
X
I
Ix
Ix
X
As
X
Ix
X
X
Ix
Ix
X
Cd
X
Ix
Ix
X
Ix
Ix
X
Cr
X
Ix
X
X
Ix
Ix
X
Fe
x
I
I
Ix
x
X
Cu
Ix
x
Ix
x
Ix
x
Ix
Pb
X
Ix
Ix
X
X
X
X
Hg*
X
X
X
X
X
X
X
Mb
X
X
X
X
X
X
X
Ni
X
X
X
X
X
X
X
Se
X
X
X
X
X
X
X
Zn
x
X
X
X
X
X
X
Total Nitrogen
Ix
Ix
I Ix
X
Chloride
Ix
Ix
I
X
X
Total Phosphorus
X
Ix
I
X
X
NH3-N
X
Ix
X
I
X
X
BOD
X
Ix
I
X
X
TSS
x
x
I
I
x
x
x
Oil & Grease
X
X
Solids
X
Flow
X
X
x
x
* EPA method 1631 for plant Effluent. All others use method 245.1
** PT.7 - WTP - Testing for annual metals, TSS, Flow, and Iron
** PT.S - Wolfspeed - No permit issued yet

Town of Slier City
Long/Short Term Monitoring Plan
(Updated 04/26/2023)
G. Detection Levels and Sampling Methods
POC
Detection Limits
Sampling Methods
mg/I
ug/l
ng/I
Ag
1
24 Hour Composite
As
2
24 Hour Composite
Cd
0.5
24 Flour Composite
Cr
0.005
24 Hour Composite
Cu
0.002
24 Hour Composite
Fe
250
24 Hour Composite
Pb
2
24 Hour Composite
Hg-Efluent
1
Grab
Hg-All other sites
0.0002
24 Hour Composite
Mb
0.005
24 Hour Composite
Mo
10
24 Hour Composite
Ni
0.01
24 Hour Composite
Se
5
24 Hour Composite
Zn
0.01
24 Hour Composite
Fluoride
0.01
24 Hour Composite
Total Phosphorus
0.05
24 Hour Composite
NH3-N
0.5
24 Hour Composite
BOD
1
24 Hour Composite
TSS
1
24 Hour Composite
Oil & Grease
5
Grab
Solids
IGrab
Flow
24 Hour Composite

Compliance schedule for Brookwood Farms, Inc.
a) Pretreaonent facility improvements are required to achieve compliance with final effuem Iintits. The Penniuec shalt comply
with the following schedule to complete these inhprovmuerris to allow the facility to meat eRLietu limits specified in F. (2)
above.
L By July 3 k 2023, the grate that covers the sample location must be removed and a manhole lid pill in it place.
b) "I've Sit) ,hall submit to the Control Authority a letterstating these changes have been matte. Letter shall be submitted to:
Director of Public Utilities
Town of Siler City
Post Office Box 769
Siler City, North Carolina 27344
Compliance schedule for Mountaire Farms, Inc.
a) Pretrrnment facility iugtrocernents are required to achieve compliance wit, final effluent limits.'fhe Per nittee shall comply
Mill the following schedule to complete these inhprow"lents to allow the facility to meet final effluent limits specified in F. (2)
above.
I. By October, 2023 Complele Desigu and Submit to Twvn of Site, City for Authorization to Conshiict
2. By January 1, 2014 Begin Consonction
3. By November 30, 2024 Complete Constntelion of Improvotuents
4. By January 1, 2025 Comply with Final Effluent Limits.
b) file Stu shall submit to the Control authority quarterly reports as follows:
I. Quarterly Compliance progress repots shall delail the work and activities undertaken and cmnpleted oil all scheduled
activities listed in Part III Special Conditions 8 a). Quarterly reports shall he submited to:
Director Public Utilities
Town or Siler City
Post Office floe 769
Siler City. Not th Carolina 27344

Compliance schedule for Siter City Water Plant
a) WnterTreittwit Plant solids handling facility ingrrovelnenis are required to achieve compliance with final effluent limits. The SIU
shall comply with the following schedule to complete these improvements to allow the flei Iity to meel final cIII uent limits specified
in F.(2)above.
I. By Jidy 1, 2023. Complete Engineering Report and Submit to Division ork%later Infrastrucutre.
2. By October 1, 2023. Complete Oesigu and Submit for permitting.
3. By February I. 2024. Execute C'onslruction Contract
q. By February I, 2025. Complete Construction of Ingnvnvennnas
5. By March I, 2025. Comply with Final I-i luent Limits.
b) The SIU shall submit to the Control authority quarterly reports as follows:
1. Quartery Compliance progress reports shall detail the work and activities undertaken and completed oil all schedulcyl activities
listed in Part III Special Conditions S a). Quarterly reports slmll be submitted to:
Dircetor Public Utilitias
Town of Sfler City
Pwt Mike Box 709
Silcr City. Nordn Carolina 273•14

HEARING OFFICER'S REPORT AND FINAL DECISION
FOR THE TOWN OF SILER CITY, NORTH CAROLINA
In Re: Mountaire Farms of North Carolina Corporation Request for Adjudicatory Hearing in the
matters of a Modified Industrial User Permit (IUP #004) issued May 16, 2023
and
Notice of Violation and Assessment of Civil Penalties (NOV-2023-LV-0003) issued
May 10, 2023.
This matter came before the presiding Hearing Officer, Mr. Theodore J. Lynch, for an
adjudicatory hearing on Friday July 21, 2023, based on the appeal of the issued Industrial User
Permit (IUP) and the issuance of Notices of Violation (NOV) by the Town of Siler City to
Mountaire Farms of North Carolina, Corporation (Mountaire Farms). Mountaire Farms requested
an adjudicatory hearing via certified letter on June 9, 2023. The certified letter outlined
supporting claims for rescinding the issued Industrial Use Permit and return of the civil penalties
associated with NOW issued to Mountaire Farms. Based on the evidence submitted into the
record at the hearing, including receiving the testimony from Mr. Chris McCorquodale (Utilities
Director for the Town of Siler City), Ms. Tanya Rogers -Vickers (Director of Environmental
Compliance for Momitaire Farms), and the arguments of counsel for the parties, the Hearing
Officer makes the following:
FINDINGS OF FACT
Industrial User Permit Modification
1. Mountaire Farms, Corp, is a poultry processing facility located in Siler City, North Carolina.
2. The property at issue is the Mountaire Farms chicken processing facility located at
1100 E 3' St, Siler City, North Carolina 27344.
3. Mountaire Farms is a Significant Industrial User (SIU) discharging to the Town of Siler City
collection system. The Town of Siler City initially issued Mountaire Farms an Industrial User
Permit (IUP) effective January 1, 2018, A renewed IUP was effective January 1, 2020. A
draft of the current IUP was provided to Mountaire Farms for review in December of 2022,
effective on June 1, 2023,
4. The Town of Siler City received effluent violations from the North Carolina Department of
Environmental Quality (DEQ) for the exceedance of National Pollutant Discharge Permit

(NPDES) limits in 2020, 2021 and 2022. On May 12, 2022, the Town of Siler City received a
letter from the DEQ that required increased monitoring (daily) for the Town's Wastewater
Treatment Plant and for the Town's SILT Mountaire Farms.
5. On September 8, 2022, the Town of Siler City applied to begin the process to establish a
Special Order by Consent (SOC) between the Town of Siler City and the DEQ and the state
of North Carolina.
6. The Town of Siler City Municipal Code Chapter 27 Utilities, Division 27-III-2-IV
(Wastewater Discharge Permit Application and Issuance) is the guiding ordinance for
pretreatment permit application, modification, and renewal. The Town's Municipal Code
also covers sampling and monitoring requirements. The Town has an approved Enforcement
Response Plan,
Since January of 2020 Mountaire Farms has violated the IUP approximately two -hundred
and four times (204).
8. Mountaire Farms requested an IUP modification in October 2022. In a letter dated
October 31, 2022, Mountaire Farms requested that the Town's compliance sampling point be
moved from Manhole #1 to the Parshall Flume located inside a building at the Mountaire
Farms facility. Laboratory analysis results were presented during the Hearing to show that
Manhole #1 is not representative of discharge when compared to the results from the Parshall
Flume. Both Manhole #1 and the Parshall Flume are owned by Mountaire Farms and as such
was Mountaire Farm's obligation to do the necessary maintenance required to ensure that the
reported data was representative of the actual discharge.
9. Due to IUP violations over the course of 2021 and 2022, Mountaire Farms planned treatment
process improvements to bring the facility into compliance. To communicate the timing of
the improvements, Mountaire Farms provided the Town of Siler City a Gant Chart dated
October 28, 2022, to show a projected construction schedule. The chart showed construction
completion and start-up of a Moving Bed Biofilm Reactor (MBBR) at the end of September
2024 with float into October 2024,
10. David Honeycutt, PE of McGill Engineering, Inc. provided engineering calculations for the
development of pretreatment limits for the industrial dischargers to the Town of Siler City
Collection System and ultimately the Siler City Wastewater Treatment Plant (W WTP). The
engineering calculations were in response to the Town's W WTP expansion and more
stringent NPDES nutrient limits for the Town of Siler City.
11.On December 1, 2022, the Town of Siler City provided a draft of the modified IUP to
Mountaire Farms, Corp, of NC. The modified IUP included new monitoring requirements
for perfluorinated compounds (PFAS) and 1,4-Dioxane beginning June 1, 2023, until
December 31, 2024. The draft IUP also included reduced permit limits for total nitrogen,

ammonia, biochemical oxygen demand (BOD), and total phosphorous effective January 1,
2025, The email correspondence that accompanied the modified IUP referenced that DEQ
was reviewing the draft IUP, and that Mountaire Farms would have an additional 30 days
after the State's approval before the IUP would become effective.
12. On December 2nd, 2022, Ms. Tanya Rogers-Vicker of Mountaire Farms sent an email to Mr.
Chris McCorquodale regarding her concern with the reduction of TN to 50 mg/L but stated
that she would reply to the Town of Siler City when the design numbers were received for
the proposed MBBR system. The email correspondence is the only Mountaire Farms
response to the draft modified IUP limits that were provided during testimony. Mountaire
Farms did not formally submit comments to the Town of Siler City during the draft IUP
comment period. The draft IUP was provided to Mountaire Farms on December 1, 2022, and
the final, State approved IUP was issued on May 19, 2023. This equates to roughly a 169-day
review period versus the required 60 days.
13.On February 10, 2023, the Town of Siler City entered a SOC with the State of North
Carolina. On page three of the SOC, the Town is required to issue updated IUPs and include
compliance schedules for pretreatment upgrades necessary to meet IUP effluent limits. Page
six of the SOC mandates that all pretreatment upgrades for compliance shall be completed by
June 30, 2024.
14. On May 16, 2023, the Town of Siler City issued the final renewed IUP to Mountaire Farms,
which included a compliance schedule for Mountaire Farms to complete construction of
pretreatment process upgrades by November 30, 2024,
15.On June 9, 2023, Mountaire Farms Attorney Peter J. McGrath submitted a request for Initial
Adjudicatory Hearing in the matters of Modified Industrial User Pretreatment Permit (IUP
#004) and for the Notice of Violations and Assessment of Civil Penalties issued on May 10,
2023.
16. On July 17, 2023, all parties were notified of a scheduled initial adjudicatory hearing for July
21, 2023, with T.J. Lynch of Hazen and Sawyer serving as the Hearing Officer.
17. The initial adjudicatory hearing took place as scheduled on July 21, 2023. The hearing took
place in the Town of Siler City's Municipal Building. The following participated in the
hearing process:
Town of Siler City Mountaire Farms
William Morgan Peter McGrath
Chris McCorquodale Tanya Rogers -Vickers
David Honeycutt

Also in attendance were Hank Raper (Siler City Town Manager), Marcus Bell (Mountaire
Farms Plant Manager), and Kimberly Picard (Town Clerk).
March 2023 Notice of Violation Issued by Town of Siler City to Mountaire Farms
A letter dated May 12, 2022, from NC Department of Environmental Quality, Division of
Water Resources to the Town of Siler City required the Town to increase influent and
effluent monitoring frequency to "daily" for BOD, Total Suspended Solids (TSS), Ammonia
Nitrogen, Total Nitrogen, and Total Phosphorous.
2. The draft and final IUPs issued to Mountaire Farms by the Town of Siler City contained
"Daily Maximum" limits.
The Town of Siler City, in accordance with approved Town of Siler City Ordinance C27 A3 Sec.
27-183, issued a monthly Civil Penalty Assessment letter to Mountaire Farms on May 10, 2023,
for violations that occurred during the month of March 2023. Also supporting the Town's
authority to issue civil penalties for violations are NCGS 143-215.6A and Code of Federal
Regulations Title 40 Part 403 for Pretreatment Program Requirements.
4. The Notice of Violation with Civil Penalties issued to Mountaire Farms on May 10, 2023,
included:
• Sixteen violations for exceedances of ammonia
• Eleven violations for exceedances of DOD
• One violation of Total Nitrogen
• One violation of Part II, General Conditions for failure to mitigate conditions at Mountaire
Farms that allowed multiple exceedances of permit limits.
The Town had issued similar NOVs to Mountaire Farms prior to March 2023 extending back to
2020.
5. Included in the Mountaire Farms IUP Part lI are the following applicable General Conditions: 5.
Duty to Comply and 15. Civil and Criminal Liability. General Conditions: 5. Duty to Comply
states that the industry must comply, and that noncompliance is grounds for possible enforcement
action. General Conditions: 15. Civil and Criminal Liability states that nothing in the permit shall
be construed to relieve the permittee from civil or criminal penalties for noncompliance.
6. The City Code Chapter 27, Utilities Article 27-III-2 Disposal of Wastes, Subdivision 27411-
2-VII Penalties: Costs, Section 27-183 Civil Penalties states that "Any user who is found to
have failed to comply with any provisions of this chapter, or the orders, rules regulations and
permits issued hereunder, may be fined up to twenty-five thousand dollars per day of
violation." The Utilities Director has the discretion to determine the fine amount by
considering Eight Factors described in the Town's approved Enforcement Response Plan.

CONCLUSIONS OF LAW
1. The Town of Siler City, as a control authority, had legal authority to modify IUP #004 issued
to Mountaire Farms per 15A NCAC 02H .0916 (c)(6) and City Code, Chapter 27 Utilities,
Division 27-III-2-IV Wastewater Discharge Permit Application and Issuance.
2. Mountaire Farms was granted more than the specified 60 days (December 1, 2022, to May
16, 2023) to review and comment on the modified IUP #004 per City Code Section 27-134
(g)(2)(c)•
3. The Town of Siler City had legal authority and was required by the State of North Carolina
to monitor "daily" in a letter from DEQ dated May 5, 2022. The draft modified IUP
contained limits for Daily Maximum. Per Town Code Sec 27-169, the POTW Director may
issue a Notices of Violation (NOV) to Mountaire Farms for exceedances of the "Daily
Maximum" limits.
4. The Town has legal authority to issue fines (civil penalties) up to twenty-five thousand
dollars per day per violation per Town Code Section 27-183. City Code Section 27-183 also
requires that the eight Findings of Fact be considered in determining penalties. Factor Two of
Eight considers the duration and gravity of the violations and Factor Seven of Eight considers
the prior record of the violator in complying or failing to comply with the pretreatment
program. Fines have escalated over time as violations have increased in frequency and have
occurred between 2020 and have continued to occur in 2023.
Based upon all the foregoing Findings of Fact and Conclusions of Law, it is hereby
ORDERED, ADRJDGED, and DECREED that the process to issue a modified Industrial Use
Permit used by Town of Siler City's Director was proper and the issuance of Notices of Violation
with fines are AFFIRMED.
I
- _te,-21
Theodore J. Lynch, eari Officer
Associate Vice President, Hazen and Sawyer
_% 12Z ZoZ3
Date of signature