PERDUE AGRIBUSINESS INC, ZION CHURCH ROAD COMPLEX

Perdue AgriBusiness LLC's Zion Church Road Complex in Salisbury, Maryland (EPA FRS registry ID 110009684010, NAICS 311224 — soybean and other oilseed processing) carries eight quarters of noncompliance over the trailing 24 months and approximately $6.41 million in derived penalty exposure according to EPA ECHO exporter data as of 4 May 2026 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip] [source: https://frs-public.epa.gov/ords/frs_public2/fii_query_dtl.disp_program_facility?p_registry_id=110009684010]. The facility reported approximately 2.1 million pounds of Toxic Release Inventory emissions across seven chemicals in the most recent reporting year, with 100% of mass moving via air release pathways [source: https://plainenviro.com/facilities/maryland/perdue-agribusiness-llc-salisbury-md-czionc]. Both figures place the Salisbury complex at the center of a compliance record that has grown materially more complex since late 2024.

The site is the subject of active federal PFAS litigation filed in Wicomico County, Maryland, covering per- and polyfluoroalkyl substance contamination at and adjacent to the Zion Church Road parcel [source: https://www.wboc.com/news/perdue-agribusiness-faces-new-federal-lawsuit-over-pfas-contamination/article_dfed5943-be6e-4fda-94c5-b2a675cad75d.html]. In November 2025 the company publicly attributed elevated groundwater PFAS readings in the surrounding residential area to a legacy fire-suppression system at the complex — a disclosure that arrived a full year after residents received October 2024 notification letters [source: https://www.wmdt.com/2025/11/perdue-links-elevated-pfas-levels-on-zion-church-road-to-former-fire-suppression-system/]. Perdue Farms Inc., the privately held parent, continues to present the operation within its FY2024 Company Stewardship Report framework [source: https://corporate.perduefarms.com/pdfs/perdue-farms-responsibility-report.pdf]. That report, however, contains no site-specific PFAS discussion for Salisbury and no quantitative reconciliation against the Zion Church Road groundwater findings. Because Perdue Farms is private, no 10-K or 10-Q disclosures exist to reconcile against ECHO data — a structural transparency gap that is directly relevant to analysts tracking PFAS tail risk across the oilseed-processing peer set.

EPA ECHO exporter data (as-of 4 May 2026) records eight quarters with noncompliance status for facility 110009684010 over the past 24 months. Total five-year federal penalty assessments, pro-rated at 24/60 per the ECHO derivation methodology, yield a $6,414,600 figure for the trailing two-year window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. ECHO lists zero currently active permits at the Zion Church Road Complex, with a latest permit date of 15 April 2026, indicating a pending authorization cycle at the time of extract [source: https://frs-public.epa.gov/ords/frs_public2/fii_query_dtl.disp_program_facility?p_registry_id=110009684010]. The EJ index average field is reported as 0.0. That figure reflects absent rather than zero exposure and should be read as a data-completeness gap in the ECHO extract, not a substantive finding.

A chronological reconstruction of the past 24 months begins in October 2024, when Perdue AgriBusiness sent notification letters to homeowners surrounding the Zion Church Road facility disclosing elevated PFAS detections in area groundwater [source: https://www.wmdt.com/2025/11/perdue-links-elevated-pfas-levels-on-zion-church-road-to-former-fire-suppression-system/]. A federal civil action was filed in the District of Maryland in the summer of 2025 alleging PFAS contamination attributable to facility operations, reported on 1 August 2025 [source: https://www.wboc.com/news/perdue-agribusiness-faces-new-federal-lawsuit-over-pfas-contamination/article_dfed5943-be6e-4fda-94c5-b2a675cad75d.html]. Running concurrently with that litigation, the Maryland Department of the Environment Air and Radiation Administration opened Docket #04-25 on 31 March 2025, covering a permit-to-construct application for installation of a soybean oil extractor and associated equipment at 6906 Zion Church Road. That docket includes a Lowest Achievable Emission Rate (LAER) analysis and a formal Environmental Justice screening [source: https://mde.maryland.gov/programs/permits/AirManagementPermits/Documents/Public-Review/new%20public%20review%20documents/Perdue%20InitialDocket04-25.pdf]. Then, in November 2025, the company publicly linked the PFAS detections to a former on-site fire-suppression system [source: https://www.wmdt.com/2025/11/perdue-links-elevated-pfas-levels-on-zion-church-road-to-former-fire-suppression-system/].

Outside the Salisbury complex, the broader Perdue enterprise carries prior regulatory history that provides useful pattern context. Delaware DNREC reached a settlement with Perdue AgriRecycle, LLC on solid-waste permit violations in June 2019 [source: https://news.delaware.gov/2019/06/07/dnrec-and-perdue-agrirecycle-llc-reach-settlement-agreement-on-solid-waste-permit-violations/], and Perdue Foods was fined for wastewater violations in Delaware in 2018 [source: https://www.wboc.com/archive/perdue-foods-fined-for-wastewater-violations-in-delaware/article_7ce022cc-5dce-5810-b3df-8519b53e583b.html]. A separate Perdue feed mill site in Cofield, NC is entering demolition, with company officials indicating no rebuild [source: https://www.gatescountyindex.com/news/demolition-to-begin-at-perdue-feed-mill-fc739913]. These data points bracket the Zion Church Road record: the Salisbury facility's 24-month noncompliance count and PFAS litigation sit atop a multi-state enterprise record of intermittent wastewater and solid-waste settlements spanning roughly seven years.

The ECHO exporter extract for registry 110009684010 records eight quarters with noncompliance flags during Q2 2024 through Q1 2026, capped by the ECHO derivation method at a maximum of 8. The assessed-penalty figure is derived by pro-rating the five-year total at a 24/60 factor, producing $6,414,600 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The extract does not disaggregate that penalty by statute — CWA, CAA, or RCRA — at the summary level. ECHO's facility-detail and FRS cross-walk identify program linkages to be confirmed in the FRS report for this registry [source: https://frs-public.epa.gov/ords/frs_public2/fii_query_dtl.disp_program_facility?p_registry_id=110009684010]. Independent TRI aggregation shows 2.1 million pounds of toxic releases across seven chemicals, with 100% via air pathway, 282 lbs to water, and 30 lbs to land. That profile indicates CAA Title V program exposure is the material emissions channel [source: https://plainenviro.com/facilities/maryland/perdue-agribusiness-llc-salisbury-md-czionc].

On the state regulatory side, MDE Docket #04-25, opened 31 March 2025, is a permit-to-construct proceeding rather than an enforcement action. It covers installation of a soybean oil extractor with LAER analysis and an EJ Fact Sheet [source: https://mde.maryland.gov/programs/permits/AirManagementPermits/Documents/Public-Review/new%20public%20review%20documents/Perdue%20InitialDocket04-25.pdf]. The PFAS federal lawsuit reported 1 August 2025 is a private civil action, not a federal enforcement matter. Penalty exposure from that docket is not reflected in the ECHO $6.41M figure [source: https://www.wboc.com/news/perdue-agribusiness-faces-new-federal-lawsuit-over-pfas-contamination/article_dfed5943-be6e-4fda-94c5-b2a675cad75d.html]. Historical enterprise-level actions at affiliates include the June 2019 DNREC solid-waste settlement with Perdue AgriRecycle LLC [source: https://news.delaware.gov/2019/06/07/dnrec-and-perdue-agrirecycle-llc-reach-settlement-agreement-on-solid-waste-permit-violations/] and a 2018 Delaware wastewater fine against Perdue Foods [source: https://www.wboc.com/archive/perdue-foods-fined-for-wastewater-violations-in-delaware/article_7ce022cc-5dce-5810-b3df-8519b53e583b.html]. Dollar values for the 2018 and 2019 matters are not itemized in the retrieved sources.

Zion Church Road Complex, Salisbury, MD (FRS 110009684010) — the single facility in this ECHO extract and the focal site. EPA records show 8 quarters with noncompliance in the 24-month window and derived penalty exposure of $6.41M [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The site is the subject of a federal PFAS lawsuit filed in 2025 [source: https://www.wboc.com/news/perdue-agribusiness-faces-new-federal-lawsuit-over-pfas-contamination/article_dfed5943-be6e-4fda-94c5-b2a675cad75d.html] and a pending MDE air construction permit, Docket #04-25, for a new soybean oil extractor at 6906 Zion Church Road [source: https://mde.maryland.gov/programs/permits/AirManagementPermits/Documents/Public-Review/new%20public%20review%20documents/Perdue%20InitialDocket04-25.pdf].

Perdue AgriRecycle LLC, Seaford, DE — enterprise affiliate with a June 2019 DNREC solid-waste permit settlement; included here for pattern context, not within the 24-month ECHO window [source: https://news.delaware.gov/2019/06/07/dnrec-and-perdue-agrirecycle-llc-reach-settlement-agreement-on-solid-waste-permit-violations/].

Perdue Foods — Delaware wastewater operations — 2018 state wastewater violation fines reported by WBOC; again, outside the 24-month window but relevant to enterprise compliance history [source: https://www.wboc.com/archive/perdue-foods-fined-for-wastewater-violations-in-delaware/article_7ce022cc-5dce-5810-b3df-8519b53e583b.html].

Perdue Feed Mill, Cofield, NC — site entering demolition in 2026 with no rebuild planned, reported by the Gates County Index; relevant to asset-footprint changes but not tied to the Salisbury violation file [source: https://www.gatescountyindex.com/news/demolition-to-begin-at-perdue-feed-mill-fc739913].

Perdue Farms enterprise reporting unit — captured in the FY2024 Company Stewardship Report as the corporate parent of the Zion Church Road operation [source: https://corporate.perduefarms.com/pdfs/perdue-farms-responsibility-report.pdf]. Because only one facility is in-scope for this ECHO extract, the remaining four entries are enterprise-adjacent context rather than discrete ECHO facility records.

PFAS (per- and polyfluoroalkyl substances) — the dominant community-exposure pollutant at Zion Church Road. The company attributed elevated groundwater PFAS in the surrounding residential zone to a legacy fire-suppression system on the property, with notification letters to residents sent in October 2024 [source: https://www.wmdt.com/2025/11/perdue-links-elevated-pfas-levels-on-zion-church-road-to-former-fire-suppression-system/]. PFAS are persistent and bioaccumulative. They are associated with drinking-water exposure via groundwater migration — precisely the pathway at issue in the federal civil complaint [source: https://www.wboc.com/news/perdue-agribusiness-faces-new-federal-lawsuit-over-pfas-contamination/article_dfed5943-be6e-4fda-94c5-b2a675cad75d.html].

Air-pathway TRI chemicals — the Salisbury facility reports 2.1 million pounds of TRI releases with 100% via air pathway across seven listed chemicals, a profile typical of hexane-based solvent extraction in soybean oil processing under NAICS 311224 [source: https://plainenviro.com/facilities/maryland/perdue-agribusiness-llc-salisbury-md-czionc]. The MDE permit-to-construct docket for the new soybean oil extractor explicitly required a LAER analysis, consistent with nonattainment-area treatment of volatile organic compound emissions [source: https://mde.maryland.gov/programs/permits/AirManagementPermits/Documents/Public-Review/new%20public%20review%20documents/Perdue%20InitialDocket04-25.pdf]. That LAER requirement signals that regulators view the facility's VOC load as material enough to demand best-available control technology before any capacity expansion proceeds.

Wastewater-associated pollutants — the 2018 Delaware wastewater fines against Perdue Foods document episodic CWA-relevant discharge exceedances at enterprise affiliates. Those violations do not appear in the current Zion Church Road ECHO window, but they inform the enterprise-wide pollutant profile [source: https://www.wboc.com/archive/perdue-foods-fined-for-wastewater-violations-in-delaware/article_7ce022cc-5dce-5810-b3df-8519b53e583b.html]. Environmental-justice implications at Zion Church Road are captured in MDE's formal EJ screening attached to Docket #04-25. The ECHO EJ index average of 0.0 reflects missing data in the federal extract rather than the state-level EJ score actually on file at MDE [source: https://mde.maryland.gov/programs/permits/AirManagementPermits/Documents/Public-Review/new%20public%20review%20documents/Perdue%20InitialDocket04-25.pdf].

No NAICS 311224 peer benchmark rows were returned in the research bundle, so quantitative peer ranking for violation count and penalty exposure within the oilseed-processing segment cannot be presented here. The TRI-reported 2.1 million pounds of air releases at the Salisbury site sits in the range typical of solvent-extraction soybean facilities, per the aggregated facility record [source: https://plainenviro.com/facilities/maryland/perdue-agribusiness-llc-salisbury-md-czionc], and the 24-month ECHO-derived penalty of $6.41M is the only peer-set data point available in-bundle [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Analysts requiring peer positioning should pull the ECHO NAICS 311224 cohort directly.

Perdue Farms Inc. is privately held and files no SEC 10-K or 10-Q; consequently no Item 1A forward-looking environmental risk disclosure is available to quote [source: https://corporate.perduefarms.com/pdfs/perdue-farms-responsibility-report.pdf]. That absence concentrates analytical weight on the public regulatory record. Forward-looking risk indicators from that record include: the pending federal PFAS civil action in Maryland [source: https://www.wboc.com/news/perdue-agribusiness-faces-new-federal-lawsuit-over-pfas-contamination/article_dfed5943-be6e-4fda-94c5-b2a675cad75d.html]; MDE Docket #04-25 permit-to-construct proceedings that carry LAER and EJ screening obligations for a new soybean oil extractor at 6906 Zion Church Road [source: https://mde.maryland.gov/programs/permits/AirManagementPermits/Documents/Public-Review/new%20public%20review%20documents/Perdue%20InitialDocket04-25.pdf]; and the November 2025 company statement assigning PFAS source attribution to a former fire-suppression system, which may affect remediation-scope negotiation in the civil proceeding [source: https://www.wmdt.com/2025/11/perdue-links-elevated-pfas-levels-on-zion-church-road-to-former-fire-suppression-system/].