HomeMy WebLinkAboutWQ0014565_More Information Received_20240423Initial Review
Reviewer
nathaniel.thorn burg
Is this submittal an application? (Excluding additional information.) *
Yes No
If not an application what is the submittal type?* Annual Report
Residual Annual Report
Additional Information
Other
Permit Number (IR) * W00014565
Applicant/Permittee Pilgrim's Pride Corporation
Email Notifications
Does this need review by the hydrogeologist? * Yes No
Regional Office
CO Reviewer
Admin Reviewer
Submittal Form
Project Contact Information
Please provide information on the person to be contacted by NDB Staff regarding electronic submittal, confirmation of receipt, and other correspondence.
Name* Daniel Shaw
Email Address*
daniel.shaw@pilgrims.com
Project Information
Application/Document Type*
New (Fee Required)
Modification - Major (Fee Required)
Renewal with Major Modification (Fee
Required)
Annual Report
Additional Information
Other
Phone Number*
4029201166
Modification - Minor
Renewal
GW-59, NDMR, NDMLR, NDAR-1,
N DAR-2
Residual Annual Report
Change of Ownership
We no longer accept these monitoring reports through this portal. Please click on the link below and it will take you to the correct form.
https://edoes.deq.nc.gov/Forms/NonDischarge_Monitoring_Report
Permit Type:*
Wastewater Irrigation
High -Rate Infiltration
Other Wastewater
Reclaimed Water
Closed -Loop Recycle
Residuals
Single -Family Residence Wastewater
Other
Irrigation
Permit Number:*
WQ0014565
Has Current Existing permit number
Applicant/Permittee Address*
484 Zimmerman Rd., Sanford, NC
Facility Name*
Pilgrim's Pride - Sanford WWTF
Please provide comments/notes on your current submittal below.
At this time, paper copies are no longer required. If you have any questions about what is required, please contact Nathaniel Thornburg
at nathaniel.thornburg@ncdenr.gov.
Please attach all information required or requested for this submittal to be reviewed here.
(Application Form, Engineering Plans, Specifications, Calculations, Etc.)
Comments on Draft Permit.pdf 55.03KB
Upload only 1 PDF document (less than 250 MB). Multiple documents must be combined into one PDF file unless file is larger
than upload limit.
* By checking this box, I acknowledge that I understand the application will not be accepted for pre -review until the fee (if required) has
been received by the Non -Discharge Branch. Application fees must be submitted by check or money order and made payable to the
North Carolina Department of Environmental Quality (NCDEQ). I also confirm that the uploaded document is a single PDF with all parts
of the application in correct order (as specified by the application).
Mail payment to:
NCDEQ — Division of Water Resources
Attn: Non -Discharge Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Signature
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Submission Date 4/23/2024
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April 23, 2024
Uploaded via the online portal (Non Discharge Branch Submittal Form) and via email to
(elton.luong@deq.nc.gov)
Elton Luong
North Carolina Department of Environment Quality
Division of Water Resources
Non -Discharge Branch
512 N. Salisbury Street
Raleigh, North Carolina 27604
Re: Application/Permit No. WQ0014565
Additional Information Request #1— Comments on Draft Permit
Pilgrim's Pride Processing Plant
Sanford, Lee County, North Carolina
Dear Mr. Luong:
Pilgrim's has reviewed the Draft Permit for our Sanford Facility as it pertains to the Non -Discharge
Permit No. WQ0014565 and we have the following comments:
1) Condition III.7: Pilgrim's requests the language be changed similar to the 2019 Permit
language to "test and calibrate the irrigation equipment once per permit cycle". Pilgrim's
has 340 irrigation risers/sprayheads in our sprayfields and it is cost prohibitive and time
consuming to test/calibrate each one on an annual basis, as our current calibration
procedure consists of hiring a third party consultant to measure the discharge pressure at
each riser, use catch pans to measure volume applied for each riser and observe the spray
pattern. Pilgrim's visually inspects each riser weekly, at a minimum, in accordance with
our O&M Plan. Irrigation risers with obvious problems (i.e., spewing water onto ground,
irregular spray pattern, etc.) are promptly corrected. Therefore, we feel that annual
calibration is excessive.
2) Condition III.13: Pilgrim's requests the language be modified to read similar to the 2019
Permit "freeboard of not less than eighteen inches". No changes are proposed, or have
been made, to the 1.3 MG aeration treatment lagoon and the 3.9 MG holding pond and
subjecting these existing ponds to greater freeboard requirements is unnecessary. There
are times during wet weather periods that maintaining two feet of freeboard will be
difficult. The additional six inches represents a significant reduction in storage and
treatment volume. Also, we have an emergency overflow pipe from these ponds that
www.pligrims.com
Mr. Elton Luong
April 19, 2024
Page 2
ensures we maintain eighteen inches of freeboard. Increasing the freeboard would make
our existing overflow piping system obsolete. (The emergency overflow pipe discharges
to the wastewater treatment system where discharges are permitted under an NPDES
Permit). Further, the chlorine contact chamber is fed via gravity flow from the aeration
treatment lagoon and discharges chlorinated/sanitized effluent to the holding pond. Adding
additional freeboard (lowering the lagoon water level) will impact the chlorine contact
chamber hydraulics (i.e., flow rate and detention time) and will impact how this system has
been managed successfully for years.
3) Attachment A: Pilgrim's requests that the monitoring frequency for Total Residual
Chlorine and pH be reduced from weekly to monthly. This request is being made to ease
the financial and labor -related burdens this additional sampling places on the
Facility. Further, there are currently no limits for these parameters and monitoring is done
for informational purposes only. As designed, Pilgrim's doses sodium hypochlorite to get
a chlorine concentration of approximately 20-25 ppm in the contact chamber to disinfect
the effluent from the aerated lagoon. After the contact chamber, water flows to the holding
pond to await irrigation (average detention time is over a week).
4) Attachment C: Footnote #5 references Figure 1 which was not included with the Draft
Permit. Pilgrim's assumes the same Figure 1 as included in the 2019 Permit will be
included in the new Permit, and this is satisfactory.
If you have any questions, please contact Tina Pedley at (919) 895-3457
(tina.pedley @pilgrims.com).
Sincerely,
Daniel Shaw, Complex Manager
Pilgrim's Pride Corporation — Sanford, NC
Cc: Ms. Tina Pedley (Pilgrim's)
Mr. Steven Woodruff, P.E. (WHEE)