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Home My WebLink AboutNCG060188_Assessment of BMP Report_20131201W-SR6 November 26, 2013 NCDENR Stormwater Permitting Unit 1612 Mail Service Center Raleigh, NC 27699-1612 ��0�2013 WULANDS AND S IOR A E S �Li�ti Re: Assessment of Best Management Practices (BMPs) Report Pilgrim's Pride Corporation Staley, North Carolina Feed Mill 2607 Old 421 Road in Staley, North Carolina A 1 C &,o 6 0 8S To Whom It May Concern: Pilgrim's Pride Corporation (Pilgrim's) operates a poultry Feed Mill located at 2607 Old 421 Road in Staley, North Carolina Please find attached the Assessment of Best Management Practices (BMPs) report as required under Section E of General Permit Number NCG060000. An assessment was performed at the Facility on November 19, 2013 for best management practices associated with the off-loading, handling and spill prevention of rendered fats and oils, as well as other materials that are stored and used at the Facility. The Feed Mill is not in operation at this time, but feed milling operations could potentially resume during the coverage period of NCG060000. Pilgrim's also owns a Hatchery onsite, which is in operation, and the Feed Mill office is currently used by various Pilgrim's Pride personnel (Live Operations personnel, etc.) As required, a copy of this report has also been submitted to the NCDENR Stormwater Permitting Unit. Should you have any questions, please feel free to contact me at (540) 901-6063 or (540) 239-2983. M 7- Sharon Wetzel Director of Environmental Affairs, Eastern Region Pilgrim's Pride Corporation Cc: Mr. Bruce Morgan (Pilgrim's Pride, via email) I F'J.1 jj Lic r., j,q /i, Ij 0 fo c (.j: b1f t,� tjific�j tjjr-. f 00 1 ay v'2 1!q) Nury f bO., 11jwLA41 CURIUit MG 11GLIO(I Of, (• MU; "(f- ffJ jljor Ili obGvmJ1fojj ul jj1' .-Jill G #(JUG' I W1 0112' V1 1; 11 'J -jr V-;Ji mu2. fit r! bu c ;jj, fj f ffj.(' 01. t3t;�"J' "i L'orlm), --qjjj i i uu f r,,q Ufal (j 7t" t U C-1 v v IMAL T, j 711 50., W h I 1r: I;: WOODRUFF&HOWE ENVIRONMENTAL ENGINEERING, INC. Assessment of Best Management Practices (BMPs) As Required by Section E of Permit No. NCG060000 Pilgrim's Pride Corporation Staley, North Carolina Feed Mill mq� DEL0�2013 pELDNNR-WSAYRRUTR SDTY BRAta�H This Assessment of Best Management Practices (BMPs) at the Pilgrim's Pride Staley, North Carolina Feed Mill was performed by Mr. Stefan Gosey with Woodruff and Howe Environmental Engineering, Inc. (WHEE, Inc.) on November 19, 2013. Facility Overview Pilgrim's Pride Corporation (Pilgrim's Pride) owns a poultry Feed Mill located at 2607 Old 421 Road in Staley, North Carolina. The Feed Mill is not currently operational, but Pilgrim's understands that operations could potentially resume during the coverage period of Permit No. NCG060000. As such, this Assessment of Best Management Practices is an evaluation of the Feed Mill as it has operated in the past and would be expected to operate in the future. This Facility receives, stores and handles animal fats and animal byproducts (meat and bone meal, etc.) for use as ingredients in the production of poultry feed, which is then shipped offsite to contract poultry growers. Narrative When operational, various liquid and solid materials are stored and handled in outdoor areas at the Pilgrim's Pride Staley Feed Mill Site. Best management practices (BMPs) have been developed and are utilized for the handling and storage of these materials in an effort to reduce their potential for exposure and/or discharge to stormwater drainage features. Liquid feed ingredients (Fat, Rhodimet, Santoquin, Betaine, etc.) are stored in above -ground storage tanks (ASTs) located in three (3) concrete containment structures that are interconnected via piping through the containment structure walls. No. 2 fuel oil is stored in an AST provided with an integral secondary containment structure and rain shield to prevent the entry of rainfall. Diesel fuel is stored in a double -wall AST. Accumulated stormwater, if any, in secondary containment structures exposed to rainfall is pumped out and treated in the onsite wastewater November 26, 2013 Pagel of 3 0 C()1Jf'U1l-JJJJ4;1J! 2t4.41CLr1UW GAYWq f0 L0!tjjpjj ja ofif `Juq ifi.r;'�wxq pj (.1,jG2Gj 210LGO !1J V,:--.r111j(pjG(j 1101ju"Y"1f6L. !i. m)"'. p) kfLUCCOM :marl Ljyj �jj!qq fo bo-,/niij i1jr. cop.�,, 2rl.111'HIM 10411y' /V 5 111rl C'H !% PJ 'Jij JQGC (2) CUMCM !-,!)Jj!U1!J!jJ(;1J[ MFICUILG2 Q]!-j4, 'TV,' rfr) uu; p; jIJCQHX PGMIUze flLGCj'CKQ CL .!V,u,C rite: 1,q1QUQ: jQqr; 11julck !Aq VIHI MA Papt pt.ru 11JIr ?(-Jj!(l SILO RMLACI ,iij(,,. p) onjq0QL 101 'If c i-m(I pour, immuI4 !1,' "'liq t"'oriiq pG pj fpc ,pmLr,- "CO GA�Ijfl,' I! -.� 111) t. I ( i I'll 0 If rMICAMU(12 JPVI SUMQU2 0111VI RIG1111111? PAIUM; J.sW;;7 !IJ ?[DICY "Wp (IOUJIM' Q1 ON :11111 j? IJC" MUOU.,"J/ o'b4�ing!orJul. J."m lJLhUU;jj(JU (1,11ALY11,Y WN") 1 Q in I vqjjj lowly al 1.011LOUMQUIS1 J:UQUGQUH JUT QYjFjjjj;' pj,-.') 710!2, Ii, XCIPU (TWO it 1qj A ()C'-,' I.',! Lk ,Ijqn 'Jacomium ok [jr.al quiJuAnuirall j3L11QW? QuAltQ) Ell IPA jj!jQUJ.`, bl"rif; /.our i L I L I . i�- � ri - i Q C Cj L i L iJ treatment system, which consists of two (2) treatment lagoons and a land application system (LAS). The No. 2 fuel oil tank is filled via tanker truck, and the AST fill port is located directly above a concrete curbed area, which also contains the transfer pump associated with diesel fuel transfer activities. Liquid feed ingredients, No. 2 fuel oil and diesel fuel receiving activities are actively monitored by delivery and/or Feed Mill personnel, and ASTs are not "topped -off'. Solid feed ingredients (corn, meat and bone meal, soybean meal, limestone, etc.) received via hopper bottom trucks / railcars are received in a 2-sided, covered structure located on the west side of the Mill. Finished feed is loaded out in a 2-sided, covered structure via load out spouts outfitted with "drop socks" to help minimize fugitive emissions. Horizontal surfaces of feed loadout trailers are cleaned of finished feed prior to leaving the Loadout Area, and the Loadout Area is routinely cleaned to help prevent "drag -out" of finished feed by trailers. An equipment and materials storage area is located south of the Feed Mill around the Maintenance Shop, and materials stored in this area are cleaned of signs of oil/grease and other pollutants prior to long- term storage outdoors. Air compressor condensate is collected in a 300-gallon tote and hauled offsite. General housekeeping is routinely performed at the Facility. General housekeeping and other BMPs include routine inspection of areas with potential for spills, leaks, dust accumulation, etc. and the cleanup of these areas as required (i.e., material handling areas are swept, materials are stored under cover or roof as allowed, etc.). The Facility maintains a Spill Prevention Countermeasure and Control (SPCC) Plan, which includes practices and procedures for oil, fuel, and fat storage and handling as well as spill prevention and response procedures in the event of a fat, fuel or oil spill. Additionally, the Facility performs regular testing of certain emission sources as required by NESHAP Subpart DDDDDDD and per the Facility's air permit. Air pollution control systems are provided for significant air emission sources, and these systems are inspected, operated and maintained per the Facility's air permit and associated plans, etc. Feasibility Evaluation The Facility has developed and maintains best management practices that include reducing the exposure of materials to rainfall and the routine cleanup of areas with the potential for exposure of liquid or solid material, associated with incidental or accidental material spills or leaks, and/or associated with fugitive emission sources. Liquid storage tanks are stored inside secondary containment structures or in double -wall tanks, solid feed ingredients are generally received under cover of roof or via pneumatic systems and stored in enclosed bins or inside the Feed Mill building, and areas with potential for dust accumulation (cyclone exhaust, paved areas, receiving areas, etc.) are routinely inspected and cleaned as required to prevent excessive dust accumulations. Pilgrim's Pride continuously monitors solid and liquid receiving, storage and handling systems and modifies / incorporates additional BMPs as deemed necessary. Various structural controls and BMPs are employed at the Facility to prevent and/or minimize the exposure and/or discharge of animal fat and byproduct materials as well as other materials to November 26, 2013 Page 2 of 3 !1V f0 'OG I...' 1j)(Alli(Ii owl !!drim, rl(,-,,) 11,11A VAIIIJJCIIi. pj?I)-,cfncj -(,jq r.-) bUIACAM qrjL>l tmqj bofrj,,fi,jl tpi. qfr?, !:canwilan-ju Ci.r too,,-, 5fj.r.-J,?- OU -,!A I U Ex 'Itiq of. 111 OL M IJIA Jul j!Q,-, i (I OL Iq 1.0- -'1 t,-. )I UlJq\(-)L qjr, f1j" borr'linfil JOL G .1)0?-fli.G n t.c, r; i j.; I ri be bLOI ;rir;q IoL u :mri f f- .fjrl. f.d. Vqrj!vfmcilj*�.4 ilx, 5J fj;�iliit //.pjq; qc c�rc %ijq jjjr, Cicmjob- wvj�! �n imort-'i.mi pl�w (JIFI'Ti. 11KAHM.'. U)W-rj." .7% 1 -/IAllp- 'it i Pj '.I m)(I ji-111irg. 11A(I W IPGL j i i %I1.11.10;. Ir. jou'Ai- UDC', U W q) UA1 Y- If !jijq 1,,jq l'ofpat OUILIWMI fjLj,* r IA 'I)"- fr,jii�,, 1� C P !'I "i rip.r1c,f(mr, ;.i�j i,)iq i of ?boip0mpIA PoI)bGL Dutf()!P 1.1,111CUL2 JLG Id j(jc9.F'j(j OIJ fpc DG"fli NGG.,., i h("q, /. vi wowfol.G(f, j(j; rjljf., '!f�!MQ trI�rl !1.3 i-� fj; ,Iljr., ir cil rainfall and storm water runoff. Also, the animal fat and byproduct materials handled at the Facility are obtained from regulated rendering facilities, and these materials are processed in a manner to kill bacteria and other pathogens. Wildlife Presence/Absence A significant portion of the surrounding area is undeveloped and provides habitat for wildlife. The BMPs employed by the Mill provide for prompt cleanup of feed materials, etc., thereby minimizing attracting wildlife into developed areas of the site. FDA/USDA regulations also require feed mills to implement various measures (good housekeeping, good manufacturing processes, etc.) to control/prevent contamination of feed ingredients and finished feeds by external vectors such as rodents, birds and other wildlife. The Feed Mill also maintains an active pest control program, which primarily consists of the use of bait boxes located at various key locations inside and outside the Facility. It is important to note that the University of Alabama and the Center for Watershed Protection was issued a grant by the USEPA to perform a study of national stormwater quality by sampling stormwater discharged from areas associated with various land uses across the United States (i.e., residential, industrial, open space, etc.) and compiled their results in a paper published in February, 2004 titled "The National Stormwater Quality Database (NSQD, version 1.1)." Based on the results of Phase 1 of this study, stormwater discharged from areas designated "Mixed Open Space," which most accurately describes the area surrounding the Feed Mill, had a fecal coliform median value of 2,600 mpn/100 mL. This analytical data, along with the fact that the Feed Mill is located in a primarily wooded area reinforces Pilgrim's Pride's belief that stormwater discharges from the Staley Feed Mill Site could potentially have naturally occurring levels of fecal coliform for reasons unrelated to operations at the Feed Mill Site. Corrective Action Measures Plan Stefan Gosey, with Woodruff and Howe Environmental Engineering, Inc. (WHEE, Inc.), performed the Site Visit and BMP assessment on November 19, 2013, and he observed no handling or storage systems / operations that required corrective action, and thus no corrective action measures plan is required for the Staley Feed Mill at this time. Pilgrim's Pride will ensure sufficient and proper BMPs are in place and operational prior to the Feed Mill resuming operations. November 26, 2013 Page 3 of 3 ( )ljr, uq It)) 3 ?. 0110015M 111ri bLubw ;?pp :aG m &P10% SM MALUMMI QW. 10 tIJ(-, L-f;Cq !fill' Ispi n Lujainq Y..,. (11P; 'J! P !Ildfl r11jeAf;1.(71 HCjh:W- 44t� j I ---jC q� L, G -AQ -�L baywinq 111C RG KAF Wil 1;vlb io* 50.1— miq fic, miq I 1MV 1CLI&Iwaulcu1ul j.--*u.R!u(;C1.p3t,- lur'. --jEP(M 4IG"ROMP JAM) Imp %paul co p 10 c.lE)!':!.CJ lif:;i' `' i Jt: .C,r:c i ,.pc- q!pr.p-,m4.-, it--w. f1jr, V.!.!i omq Pg-1..G wwr1u;J11'. occnapj� LcGq JQ,l jjqjjCj, jP0,' c(Illplij! mujp1!-. lijbu%l (y 1331 ** Q11 NjujQ:f;i f-luft;- mini rpc yr, 1pur 1pr (Ibcu 'bur',, mlyp umn cm qx W,. flilfe "?JOLUMML Tjj%QJWWq jyINJ OWN CICRIBUMCCI jtlj'XC(,f Ar.L?PJU 1-1f, JIMM piqw1pu(- mjc-7n 2bi;cx- cim) auq cvujbqr.(1,, tpr,i. pj u bubri. bop;i�,licq ill 8PM31.}m1QL Q01MAQ YOU! ULCM =0 UW;?? 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