NCS000130_Compliance Evaluation Inspection_20240913

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Governor �, �' - COS
ELIZABETH S.BISER . �*_.0 .
Secretary � «. WO'
E.TOBY VINSON,JR NORTH CAROLINA
Interim Director Environmental Quality
9/13/2024
Perdue Foods, LLC
Attn: Drew Getty, Assistant General Counsel
6906 Zion Church Road
Salisbury, MD 21802
Subject: COMPLIANCE EVALUATION INSPECTION—Non-Compliance Status
NPDES Stormwater Permit NCS000130
Purdue Foods, LLC
Perdue
Richmond County
Dear Mr. Getty:
On July 23, 2024, a site inspection was conducted for the Purdue facility located at 416 South Long Drive,
Rockingham, Richmond County, North Carolina. A copy of the Compliance Inspection Report is enclosed
for your review. Neal Powell, Regional Environmental Manager, Tamra Lanford, Director of Operations and
Jerry Manis, Wastewater Manager were also present during the inspection and their time and assistance
is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES
Stormwater Permit NCS000130. Permit coverage authorizes the discharge of stormwater from the facility
to receiving waters designated as Falling Creek, a class WSIII;CA stream in the Yadkin/Pee Dee River
Basin.
As a result of the inspection, the facility was found to not be compliant with the conditions of the NPDES
Stormwater Permit NCS000130. Please refer to the enclosed Compliance Inspection Report for additional
comments and observations made during the inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil
penalty assessment of up to$25,000 per day for each violation. If you or your staff have any questions,
comments, or needs assistance with understanding any aspect of your permit, please contact me at(910
433-3384 or via e-mail at [e-mail]
Sincerely,
AuA/
Melissa Joyner
Environmental Senior Specialist
DEMLR
Enclosure: Compliance Inspection Report
ec: Jonathan Green, Owner—Perdue Foods, LLC
Neal Powell, Regional Environmental Manager—Perdue Foods, LLC
Pam Keeney, Environmental Manager—Perdue Foods, LLC
Tamra Langford, Director of Operations—Perdue Foods, LLC
Jerry Manis,Wastewater Manager—Perdue Foods, LLC
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO—DEMLR,Stormwater Files
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Regional DepartmentOffice o1f22S EnvironmeGreenntal StreetQSuituality71 4 DivisionIFayetteville of Energy,MineralCarolina and Land28301 Resources
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Compliance Inspection Report
Permit:NCS000130 Effective: 01/01/15 Expiration: 12/31/19 Owner: Perdue Foods LLC
SOC: Effective: Expiration: Facility: Rockingham
County: Richmond 416 S Long Dr
Region: Fayetteville
Rockingham NC 28379
Contact Person:Pamela Keeney Title: Environmental Manager Phone:[phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 07/23/2024 Entry T ime 10:10AM Exit Time: 01:13PM
Primary Inspector:Melissa A Joyner , y 4` a` Phone:
Secondary Inspector(s):
Tabytha Smith
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: 0 Compliant Not Compliant
Question Areas:
1.1 Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000130 Owner-Facility:Perdue Foods LLC
Inspection Date: 07/23/2024 inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner and Taby Smith met with Neal Powell, Regional Environmental Manager,Tamra Langford, Director of
Operations and Jerry Manis,Wastewater Manager to conduct an inspection of the Perdue facility. The Stormwater Pollution
Prevention Plan (SWPPP)was reviewed and the following items were noted.:
1. The site map should be updated showing the location of the drainage ditch which conveys water underneath the facility
grounds and discharges to stormwater Outfall 1.
2. Table 5-3—"Reportable Events and Contacts Required"—"Environment"—add NCDEQ.
3. Provide documentation of Annual Review of SWPPP per an individual's name, signature and date instead of usage of the
term "TEAM".
4.Provide list of individual names of people in charge of the permit instead of usage of the term "TEAM".
5. The Spill Prevention and Response Procedures (SPRP)should include a list of the individuals in charge of it with their
dated, printed names and signatures.
6.There were no Non-Stormwater Discharge evaluations documented from 2020-2022.
7. The facility is currently in Tier Three due to previous benchmark parameter exceedances of Fecal Coliform and is doing
monthly monitoring. Additional benchmark exceedances of benchmark parameters had been noted in the Analytical
Monitoring records in February 2024 for both: TSS—340 mg/L and COD—236 mg/L. There was no documentation of Tier
One responses in the SWPPP about this. Since this inspection a Discharge Monitoring Report (DMR)has been submitted
for July 2024 in which there was a benchmark exceedance for Total Nitrogen(58.8 mg/L).A notification of this Tier One
exceedance has not been received by this Office. Although this facility is in Tier Three for the benchmark exceedances of
Fecal Coliform, Tier One responses are still required if there is an exceedance of other benchmark parameters.
8. Analytical Monitoring Form—Missing Discharge Monitoring Form from June 2023.
The facility grounds were inspected with the following observations:
There were buckets with no lids and need of signage.One of the buckets was next to AST#2 and another was near a
wastewater drain. Totes were observed some partially filled with polymers such as Sodium Biophosphate, etc. and some
empty totes which were not in a secondary containment structure.A stormwater drain near Outfall 1 had some garbage in it
and a possible sheen on the water in the bottom of it. Outfall 1 was observed which was discharging and had a strong
Ammonia odor. On the northwest side of the facility grounds, adjacent to a building,there was some off-color liquid observed
on the pavement.
Since this inspection there has been correspondence received via email about corrective actions which have been taken
place in regards to the aforementioned noted items (1-5 and 8)and in response to the facility grounds observations.A
follow-up inspection will occur within 6 months of the issuance of this inspection report.
Page 2 of 3

Permit: NCS000130 Owner-Facility:Perdue Foods LLC
Inspection Date: 07/23/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? • ❑ 0 0
#Does the Plan include a General Location(USGS)map? • ❑ 0 0
#Does the Plan include a "Narrative Description of Practices"? 0 0 0
# Does the Plan include a detailed site map including outfall locations and drainage areas? • 0 0 0
#Does the Plan include a list of significant spills occurring during the past 3 years? I 0 ❑ 0
#Has the facility evaluated feasible alternatives to current practices? • 0 0 ❑
#Does the facility provide all necessary secondary containment? • 0 0 0
#Does the Plan include a BMP summary? • ❑ 0 ❑
#Does the Plan include a Spill Prevention and Response Plan(SPRP)? • El 0 Cl
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? • El 0 0
#Does the facility provide and document Employee Training? • ❑ ❑ 0
#Does the Plan include a list of Responsible Party(s)? • 0 ❑ ❑
#Is the Plan reviewed and updated annually? • ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? • ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? • ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? • 0 0 ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? • 0 ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ El
Comment:
Permit and Outfalls Yes No NA NE
#Is a copy of the Permit and the Certificate of Coverage available at the site? • ❑ 0 0
#Were all outfalls observed during the inspection? • ❑ ❑ ❑
#If the facility has representative outfall status, is it properly documented by the Division? 0 0 ❑
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ • 0 ❑
Comment:
Page 3 of 3