NC0077615_Inspection_20180913

NORTH CAROLINA
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MICHAEL S. REGAL
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LINDA CULPEPPER
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13 September 2018
CERTIFIED MAIL #: 70161370 0000 2596 1341
RETURN RECEIPT REQUESTED
Mr. David Tupman, General Manager
Origin Food Group, LLC
PO Box 7621
Statesville, North Carolina 28687-7621
Subject: Notice of Violation
Compliance Evaluation Inspection
Origin Food Group, LLC WWTP
NPDES Permit No. NCO077615
Iredell County
Tracking #: NOV-2018-PC-0369
Dear Mr. Tupman:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
August 31, 2018, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge (ORC) of our
findings by forwarding a copy of the enclosed report.
This report is being issued as a Notice of Violation (NOV) due to both the facility's introduction of an unpermitted waste
stream into the wastewater treatment plant and the failure to notify the Division within twenty-four (24) hours of first
knowledge of the occurrence or on the next working day following the occurrence, which are violations of the subject NPDES
Permit and North Carolina General Statute (G.S.) 143-215.1 as detailed in the Permit/Summary Section of the attached
report. Please be advised that G.S. 143-215.6A provides for a civil penalty assessment of not more than twenty-five thousand
dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature,
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued
pursuant to G.S. 143-215.1. Penalties may also be assessed for any damage to surface waters of the State that may result from
the violations.
It is requested that a written response be submitted to this Office by October 4, 2018, detailing the actions taken to
prevent the recurrence of any future violations. The response should include the facility's operation & maintenance program
that will be implemented on the process wastewater pump station/pumping system. In responding, please address your
comments to the attention of Mr. Wes Bell.
EQ.:>
`_=r
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 3011 Mooresville, North Carolina 28115
704.663.1699

Mr. David Tupman
Page Two
13 September 2018
Should you have any questions concerning this letter, please do not hesitate to contact Mr. Bell at [phone], or via
email at wes.bellkncdenr.gov.
Sincerely,
DocuSigned by:
F161 FB69A2D84A3... for
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure: Inspection Report

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 15 I 3 I NCO077615 111 12 I 18/08/31 I17 18 I S i 19 LG] i 201 I
211111 1 1 1 1 1 111 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 111 1 1 1 1 1 166
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
67 2.0 70 71 I.. I 72 I �, I 73 �74 751 I I I 1 1 1 I80
u
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES oermit Number)
09:06AM 18/08/31
14/04/01
Origin Food Group, LLC
306 Stamey Farm Rd
Exit Time/Date
Permit Expiration Date
Statesville NC 28677
10:47AM 18/08/31
19/03/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Dennis W Murdock/ORC/828-238-4659/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
David Tupman,PO Box 7621 Statesville NC 286877621/General
Manager/704-768-9000/7047689646 Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
EDocuSigned by: 9/12/2018
Wes Bell �� �� MRO WQ//704-663-1699 Ext.2192/
A61696D90=43T
Signature of Management Q A Reviewer Agency/Office/Phone and Fax NumbersDocuSigned by: Date
4-0 t'�H ;PZUft
for WCB EF1611`1369AMUAI..
W. Corey Basinger MRO WQ//704-235-2194/ 9/13/1
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO077615 111 121 18/08/31 1 17 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On-site Representatives:
The following personnel were in attendance during the inspection: Mr. David Tupman/Origin Food
Group; Mr. George Buff/Origin Food Group; Mr. Chris Bitterman/Envirolink; Mr. Chip White/Envirolink;
and Mr. Dennis Murdock/Envirolink.
PERMIT SECTION cont'd:
On August 24, 2018, approximately 3,000 to 3,500 gallons of industrial wastewater (wash down
wastewater from the yogurt production facility) was diverted into the wastewater treatment plant
(WWTP) due to inoperable pumps in the process wastewater's pump station. Note: The process
wastewater is permitted to be treated/disposed at an adjacent Animal Waste Operation under the
authority of Permit #: AW1490048. The facility's wastewater treatment facility was only permitted (via
NPDES Permit) for the treatment of domestic wastewater. In addition, the Division was not notified of
this incident until August 29, 2018. Please be advised that the facility violated the subject NPDES
Permit by both the introduction of an unpermitted waste stream into the WWTP and the failure to notify
the Division within 24-hrs. of first knowledge of the occurrence or on the next working day following the
occurrence.
RECORD KEEPING SECTION cont'd:
A review of the June 2018 edmr revealed the following monitoring discrepancies:
1) no effluent MBAS (1/month) was reported;
2) no effluent oil & grease (2/month) was reported;
3) only one effluent ammonia result (2/month) was reported;
4) "NO Discharge" was indicated on the edmr;
5) effluent TRC values were not reported down to the TRC meter's lowest detection level (<15 ug/L
should have been reported instead of 0 ug/L). Note: A "0" ug/L TRC effluent result was also
reported in May 2018.
The ORC and staff must also change the NO DISCHARGE status on the June 2018 edmr (change the
"yes" to a "No" to represent the facility discharged during June 2018).
Please be advised that the Permittee and ORC must ensure all edmrs are accurate and complete prior
to submittal. The Division will address any limit and/or monitoring violations following the submittal of
the revised June 2018 edmr.
Page#

Permit: NCO077615 Owner - Facility: Origin Food Group, LLC
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
Inspection Date: 08/31/2018 Inspection Type: Compliance Evaluation
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
0
❑
❑
❑
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
0
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: The last compliance evaluation inspection was performed at the facility on 2/1/18 by DWR
staff.
Transported COCs
See "Summarv" Section for additional comments.
Are DMRs complete: do they include all permit parameters?
❑
0
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
❑
0
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
0
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
Page# 3

Permit: NCO077615
Inspection Date: 08/31/2018
Record Keeping
Owner - Facility: Origin Food Group, LLC
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The records reviewed durina the inspection were oraanized and well maintained. Discharae
Monitoring Reports (edmrs) were reviewed for the period November 2017 through June
2018. The facility only reported effluent discharges in April 2018, May 2018, and June 2018.
Monthly average BOD and TSS effluent limit violations were reported in May 2018. The
Division has separately addressed these limit violations through the issuance of a NOV.
See "Summary" Section for additional comments.
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑ ❑
Are all other parameters(excluding field parameters) performed by a certified lab?
M
❑
❑ ❑
# Is the facility using a contract lab?
0
❑
❑ ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0 ❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0 ❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0 ❑
Comment: On-site field analyses (PH, total residual chlorine, temperature) are being
performed under
Envirolink's field laboratory certification #5212. Statesville Analytical, Inc.
(all effluent
parameters except field) has also been contracted to provide analytical support.
The CIRC was not performing post -analysis calibration checks on the pH
and total residual
chlorine meters following field analyses at multiple sites. Post -analysis calibration checks
must be performed in accordance with the NC Wastewater/Groundwater laboratory
certification approved procedures for the analyses of dissolved oxygen, pH,
and total
residual chlorine. Note: The technical guidance documents developed by
the Division's
Laboratory Certification Unit detailing these approved laboratory procedures have been
emailed to Envirolink's Field Supervisor.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment: The subject permit requires effluent grab samples.
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
1[TN►rem ►/_M►1M
❑ ❑ ■ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
Yes No NA NE
■ ❑ ❑ ❑
Page# 4

Permit: NCO077615 Owner - Facility: Origin Food Group, LLC
Inspection Date: 08/31/2018 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Excessive veaetation was observed inside the fenced Derimeter that includes the WWTP
Please be advised that the subject permit requires the Permittee to properly operate and
maintain the facility at all times.
The WWTP continues to receive minimal influent flow/loading. The ORC currently has to
treat the wastewater in batches when sufficient flow has accumulated in the equalization
basin.
Bar Screens
Yes No NA NE
Type of bar screen
0
❑
❑
❑
a.Manual
0
❑
❑
❑
b.Mechanical
❑
❑
❑
❑
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment:
Equalization Basins
Yes No NA NE
Is the basin aerated?
0
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
0
❑
❑
❑
Is the basin free of excessive grease?
0
❑
❑
❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
0
❑
❑
❑
Are float controls operable?
0
❑
❑
❑
Are audible and visual alarms operable?
0
❑
❑
❑
# Is basin size/volume adequate?
0
❑
❑
❑
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots? 0 ❑ ❑ ❑
Are surface aerators and mixers operational? ❑ ❑ 0 ❑
Page# 5

Permit: NCO077615
Owner - Facility: Origin Food Group, LLC
Is the clarifier free of black and odorous wastewater?
0
Inspection Date: 08/31/2018
Inspection Type: Compliance Evaluation
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
Aeration Basins
Yes No NA NE
Are the diffusers operational?
0 ❑
❑
❑
Is the foam the proper color for the treatment process?
❑ 0
❑
❑
Does the foam cover less than 25% of the basin's surface?
0 ❑
❑
❑
Is the DO level acceptable?
0 ❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑ ❑
0
❑
Comment: The aeration basin appeared white in appearance
due to the introduction of the unpermitted
Is the site free of excessive floating sludge?
0
waste stream/process wastewater. The aeration basin foam was also white due to a very
❑
❑
low mixed liquor (biomass) concentration.
The 30 -minute settleability test was <50 ml/L
❑
❑
with a turbid (white colored) supernate.
Is the return rate acceptable (low turbulence)?
0
❑
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
❑
❑
0
❑
Are weirs level?
❑
❑
❑
0
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
❑
❑
❑
0
Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
0
❑
❑
❑
Comment: The clarifier was not discharaina at the time of the inspection: however. the wastewater
inside the clarifier was turbid with a white appearance due to the introduction of the
unpermitted waste stream/process wastewater.
Disinfection -Tablet Yes No NA NE
Are tablet chlorinators operational? 0 ❑ ❑ ❑
Are the tablets the proper size and type? 0 ❑ ❑ ❑
Number of tubes in use?
3
Is the level of chlorine residual acceptable?
❑
❑
0
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
0
❑
Comment: No wastewater was observed flowing through the tablet chlorinator.
The chlorine contact
chamber had been recently pumped out by a contracted company.
Page# 6

Permit: NCO077615 Owner - Facility:
Inspection Date: 08/31/2018 Inspection Type:
Origin Food Group, LLC
Compliance Evaluation
# Is flow meter used for reporting?
❑
De -chlorination
Yes No NA NE
Type of system ?
Tablet
❑
❑
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑ ❑
0
❑
Is storage appropriate for cylinders?
❑ ❑
0
❑
# Is de -chlorination substance stored away from chlorine containers?
❑ ❑
0
❑
Comment:
Are the tablets the proper size and type? 0 ❑ ❑ ❑
Are tablet de -chlorinators operational? 0 ❑ ❑ ❑
Number of tubes in use? 2
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
❑
❑
0
❑
Is flow meter calibrated annually?
❑
❑
0
❑
Is the flow meter operational?
❑
❑
0
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment: Instantaneous effluent flows are measured by the bucket and stop watch method.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
❑
❑
❑
0
Are the receiving water free of foam other than trace amounts and other debris?
❑
❑
❑
0
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: The facility was not discharging at the time of the inspection.
Aerobic Digester
Yes No NA NE
Is the capacity adequate?
0
❑
❑
❑
Is the mixing adequate?
❑
❑
0
❑
Is the site free of excessive foaming in the tank?
❑
❑
0
❑
# Is the odor acceptable?
0
❑
❑
❑
# Is tankage available for properly waste sludge?
0
❑
❑
❑
Comment: The facility is equipped with an aerated sludge holding tank. The ORC has not wasted any
sludge due to the extremely low influent flows/loading. A contracted company (Lentz Septic
Tank Service) would be used to remove wastewater solids on an as -needed basis.
Page# 7