NCS000244_COMPLIANCE_20151009

STORMWATER DIVISION CODING -SHEET
PERMIT NO,
AJ LS () 0 D
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
COMPLIANCE
❑ OTHER
DOC DATE
❑ D I s 10 o9
YYYYM M D D

r
VVJL.Trr
roof i�! ,�. EERI Al' c�
October 9. 2015
ATTN: Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
To Whom It May Concern,
Enclosed is the quarterly discharge report for American Distillation Inc. for the 3`d quarter of
2015.
If ,you have any questions, please call me at 910-259-4800.
Sincerely,
4&,3wA---
Ilen Thornton
].otter DWI 080515 Te1. 910-259-4800 Po Boa 995, Burgaw, North Caroling 28425 Fnx: 910-259-1 T19

STORM WATER DISCHARGE OUT>i~ALL (SDO)
MONITORING REPORT
Permit Number NCS _ 00i2l 9
FACILITY NAME ('Igf1 (0 D_ls-� 0
PERSON COLLECTING SAMPLE(S) Ai (" S, �, {
CER-rIF1ED LABORATORY(S)E,,,L,,,,N,.61 Chen,'d Lob#1._�Wa # 01
Lab #
Part A. Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR: a I S
('Phis monitoring report shall be received by the Division no.later than 30 days from
the date the facility receives the sampling resutts from the laboratory.)
COUNTY %[VAJ.w irk
PHONE NO. ( Alta} -4 1 -
SIGNATURE OF PERMl7TEE OR DESIGNEE
R& UQ IRED ON PAGE 2.
Rims
Does this facility pertbrm Vehicle Maintenance Activities using more than 55 gallons ofnew motor oil per month'? _yes _no
(if yes, complete Part B)
Part B: Vehicle Maintenance Ac ivity Monitorin Requirements N N
Outfall
No.
Date
Sample
Collected
50050
00556
00530
00400
Total Flow
(if applicable)
Totat
Rainfall
Oil & Grease
(ifappl.)
Non -polar
O&GITPH
(Method 1664
SGT-HEMh if
appl.
Total
Suspended
Solids
pH
New Motor
Oil Usage
rnekid} r—
eheg
m
unit
al}mo
Norm S W IJ-247, last revised 2/2/2012
Page I of 2

,.
C[-O'j '1' o ¢a / WAY Z
STORMWATER DISCHARGE OU'17FALL ($DO)
MONITORING REPORT
Permit Number NCS 0 0 0 2.. 4 SAMPLES COLLECTED DURING CALENDAR YEAR: ON
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
FACILITY NAME A me f i GQn D'S 4' [ � s5 �b,-i COUNTY . '9("
PERSON COLLECTING SAM PLE(S) 1k.t r v k,4W'te, PHONE NO. [-q 1 O) a 3 1 - ftct q 3
CERTIFIED LABORATORY(S)
S1GNA'1'URE OF PERMITTEE OR DESIGNEE
RF,OUIItED ON PACE Z.
Part A: Specific Monitoring Requirements
NMI
, ,
Does this facility pc&wni Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? — yes no
(if yes, complete Pan B)
Part B: Vehicle Maintenance Activity Monitoring Requirements N1 �
Outfall
No.
Date
Sample
Collected
50050
00556
00530
00400
Total Flow
(if applicable)
'Total
Rainfall
Oil & Grease
(if appl.)
Non -polar
O&G/TPH
(Method 1664
SGT-HEM), If
a I.
Total
Suspended
Solids
pH
New Motor
Oil Usage
rnoldd --
-MG---------
-inches------
i'onn SWU-247, krst revised 21212012
Page I of 2

S'IOWNf EVENT CFiARACTE'Rfs-rics:
Date
Total Event Precipitation (inches): Q! r_
Event Duration (hours): Q. S (only if applicable —see permit_)
(if' mura thwl one swrm event was sampled) .
Dale
"Total Event Precipitation (inches):
Event Duration (hours): __ (only if applicable— sec; perinit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"I certify, under penalty of law, that thin document and all attachments were prepared under my direction or supervision in accordance with it
system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or persons who manage the system, or those persons directly reapousible for gathering the information, the information submitted is, to the
best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting foNe information,
including the possibility of finest and Imprisonment for knowing violations."
(SiKn:irure of Permittee) T (Dale)
Form SWU-247, lust revised MI-2012
Page 2 of 2

Permit Number NCS000244
Program Category
NPDES SW
Permit Type
Stormwater Discharge, Individual
Primary Reviewer
iulie.ventaloro
Coastal SWRule
Permitted Flow
0
Facility
Central Files: APS _ SWP
12117/2014
Permit Tracking Slip
Status Project Type
Issued Renewal
Version Permit Classification
Individual
Permit Contact Affiliation
Andrew J. Simmons Jr.
PO Box 400
Leland
NC 28451040C
Facility Name
Major/Minor
Region
American Distillation - Navassa
Minor
Wilmington
Location Address
County
1690 Royster Rd NE
Brunswick
Facility Contact Affiliation.
Leland NC 28451
Hugh Croom
I '
Mgr Plant
Owner
Owner Name
Owner Type
American Distillation Inc
Non -Goverment
Owner Affiliation
Edward Eari Simmons
PO Box 400
Dates/Events
Leland
NC 28451040
.:C; ;l:.. . '
Scheduled
Orlg Issue App Received Draft initiated
Issuance Public Notice Issue
Effective Expiration
12/6/1994 3/6/2012 8/12/2014
10/24/2014 12/15/2014
.11112015 12/31/2018
_Regulated Activities
Requested /Received Events
Non -contact cooling water_ condensate
Region comments on draft requested
8113114
Organic chemical manufacturing
Region comments on draft received
1016/14
Organic chemical processing
Storrnwater (activities not covered)
Water conditioning
Ou"all 001
Waterbody Name
Streamindex Number Current Class
Subbasin
_ Cartwheel Branch
18-72 SC;Sw
03-06-17

RUM
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvada, III
Governor Secretary
December 15, 2014
Mr. Andrew J. Simmons, Jr.
American Distillation, Inc.
P.O. Box 400
Leland, NC 28451
Subject: Final NPDES Stormwater Permit
Permit No. NCS000244
American Distillation - Navassa
Brunswick County
Dear Mr. Simmons:
In response to your renewal application for continued coverage under. NPDES stormwater permit
NCS000244, the Division of Energy, Mineral and Land Resources is forwarding herewith the subject
state - NPDES permit. This permit is issued pursuant to the requirements of North Carolina General
Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
The final permit contains no significant changes from the draft permit that was noticed on
October 24, 2014.
The monitoring strategy remains the same (quarterly) as the previous term of the permit. Please note
that analytical and qualitative monitoring is required in this permit. Failure to complete the
monitoring as required is a violation of the permit and any permit noncompliance constitutes a
-violation of the Clean Water Act. Reference Part III, Section A, Item 2 "Duty to Comply", Item 9
"Penalties for Tampering" and item 10 "Penalties for Falsification of Reports" of your permit for
further information.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless
such demand is made, this decision shall be final and binding.
Division of Energy, Mineral, and Land Resources
Energy Section • Geological Survey Section • Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-92001 FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: httpaloortal.nodenr.ora/webAr/
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper

NCS000244
Page 2 of 2
Please take notice this permit is not transferable. Part III, B.2. addresses the requirements to be
followed in case of change in ownership or control of this discharge. This permit does not affect the
legal requirements to obtain other permits which may be required by the Division of Energy, Mineral
and Land Resources, or permits required by the Division of Water Resources, Coastal Area
Management Act or any other federal or local governmental permit that may be required.
If you have any questions or comments concerning this permit, contact Julie Ventaloro at (919) 807-
6370 or [e-mail].
Sincerely,
for Tracy E. Davis, P.E., CPM, Director
Division of Energy, Mineral and Land Resources
cc: Wilmington Regional Office, S. Pusey
Stormwater Permitting Program Files
Sam Sampath, Ph.D., EPA Region IV, 61 Forsyth Street, Atlanta, GA 30303
DWR Central Files
Attachment: Permif NCS000244

Ventaloro, Julie
From: Pusey, Steven
Sent: Monday, November 17, 2014 2:03 PM
To: Mark Walton; Ventaloro, Julie; [e-mail]
Cc: allen@waltonengineering. net
Subject: RE: NPDES Stormwater Draft Permit - NCS000244
Follow Up Flag: Follow up
Flag Status: Flagged
Mark,
Are you going to issue a certification for the new State stormwater pond at American Distillation this week? If so, do
you want me to meet you at the site?
Thanks,
Steve Pusey
From: Mark Walton [mailto:[e-mail]]
Sent: Wednesday, October 15, 2014 2.06 PM
To: Ventaloro, Julie; nancy(aamericandistillation.net
Cc: allen@waltonengineering,net; Pusey, Steven
Subject: Re: NPDES Stormwater Draft Permit - NCS000244
Julie,
We don't need a paper copy.
Thanks,
Mark Walton
On 10/15/2014 1:36 PM, Ventaloro, Julie wrote:
Mr. Simmons,
We are seeking your comments on the attached draft permit for the American Distillation, Inc facility in
Brunswick County. The cover letter outlines significant changes that were made to the permit since it
was last issued as well as some outstanding issues that need your attention. Please review the draft
permit and send your comments and required documents (site map, data) to me either by email or
regular mail. I've dropped a hard copy in the mail to you as well.
The draft has not gone out for public notice yet, but I anticipate that happening by the end of October.
I'll let you know when that happens.
Please give me a call if you have any questions.
Mark and Allen — Let me know if you would also like to receive a hard copy of the draft permit in
addition to the attached electronic copy.
Julie Ventaloro
Stormwater Permitting Program
NC Division of'Gncrggr, Mineral, and Land Resources
1612 Mail Service Cunter, Raleigh, NC 27699-ifm2
Phone: (919) $07-6370 l:aa: [phone]
1

Ventaloro, Julie
From: Mark Walton [[e-mail]]
Sent: Friday, November 14, 2014 11:30 AM
To: Ventaloro, Julie
Subject: Re: NPDES Stormwater Draft Permit - NCS000244
Attachments: Stormwater Plan As-Built.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
Julie,
This is in response to Item 6 of your letter.
A revised plan is attached showing the new outfall location. The stormwater pond has been constructed and all
drainage from impervious surfaces and containment areas will be routed to the pond. No other outfalls will exist. Nor
have there been any discharges from any outfalls other than previously permitted outfall 001.
There were a couple of areas identified during the last NPDES site inspection where the berm along the western side of
the property was eroded. Those areas have been repaired.
Thank You,
Mark Walton
Walton Engineering
PO Box 895
Burgaw, NC 28425
Tel: [phone]
On 10/15/2014 1:36 PM, Ventaloro, Julie wrote:
Mr. Simmons,
We are seeking your comments on the attached draft permit for the American Distillation, Inc facility in
Brunswick County. The cover letter outlines significant changes that were made to the permit since it
was last issued as well as some outstanding issues that need your attention. Please review the draft
permit and send your comments and required documents (site map, data) to me either by email or
regular mail. I've dropped a hard copy in the mail to you as well.
The draft has not gone out for public notice yet, but I anticipate that happening by the end of October.
I'll let you know when that happens.
Please give me a call if you have any questions.
Mork and Allen — Let me know if you would also like to receive a hard copy of the draft permit in
addition to the attached electronic copy.
Julie Ventaloro
Stormwater Permitting Program
NC Division of Energy, Mineral, and land Resen11-ces
1612. Mail Service Center, Raleigh, NC 27699-1612
Phone: (gig) 807-6370 1`ax: [phone]

_ e
Website: htfn:l/watersupplvwatershgd.nc.gov
!•:-mail correspondence to and Ji-am this address may he sulhject to the North Carolina Public Rcc•ords Lain and inay be
disclosed to third parties.
R. Mark Walton
Licensed Professionsal Engineer
Walton Engineering
PO Box 895
Burgaw, NC 28425
Tel: [phone]
Fax: [phone]
e-mail: [e-mail]
101_
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DIMEWO'l
NOTES
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Dh
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Diameter of ePch aewafenng HWe (Temoorwy POW)
N
1
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C
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Ele
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RISER AND BARRELL DETAIL

Ventaloro, Julie
From: Darlene Wells ][e-mail]]
Sent: Wednesday, November 12, 2014 2:13 PM
To: Ventaloro, Julie
Subject: Stormwater Permit
Attachments: Stormwater Permit Leiter to Ms. Ventaloro.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
Ms. Ventaloro:
Please find attached PDF file on the information you requested for year 2014. Also I have enclosed an updated site map
of the facility.
Regards,
Oa4Penc weeeo A
Y awhtw ing and Ywductiost eeevfi
weiytrt,uotC4
(Gne ticcut oW flfaawl., .`Jfx.
1690 XE Zuptft Head
,Le&md, .Ne 28451
910-371-0993 ext 102
91 U-371-2971 fax
CONFIDENTAL
This email transmission and any documents, files or previous email messages attached to it may contain information
that is confidential or legally privileged. If you are not the intended recipient any disclosure, copying, printing,
distribution or use of this transmission is strictly prohibited. If you have received this transmission in error, please
immediately notify the sender by telephone or return email and delete the original transmission and its attachments
without reading or saving in any manner,

AMERICAN DISTILLATION, INC.
1690 NE ROYSTER ROAD
LELAND, NC 28451
910-371-0993 FAX [phone]
November 11, 2014
Ms. Julie Ventaloro
North Carolina Department of Environment and Natural Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
RE: Permit No. NCS000244
Dear Ms. Ventaloro:
This letter is in response to your letter dated October 15, 2014, with respect to line item 8 and analytical stormwater
monitoring. We regret to inform you that there was an omission of testing in parts of 20 i 2 and 2013. The
responsibility for this testing was with the plant manager at that time Mr. Charles Bullard. There was never any
knowledge or indication given that these samples were not gathered in a timely manner and in accordance with
permit mandates.
We had been given notice by Mr. Bullard in late 2013 that he was overwhelmed with plant duties. To that end, we
were able to convince AD1 former retired plant manager and HS&E specialist, Mr. Hugh Croom, to provide part
time services begun December, 2013, to assist specifically with AD[ health, safety, and environmental issues.
Unfortunately, this assistance did not abate the negligence and shortcomings of Mr. Bullard in plant operations, and
apparently on other routine requirements; and Mr. Bullard was terminated in April, 2014.
Again, with embarrassment, we do not have any results for testing in parts of 2012 and 2013. All testing for 2014
was done under the guidance of Mr. Hugh Croom and those results are included again with this report. We have no
reason, other than negligence, for why these tests were not conducted in 2012 and 2013, as there certainly were no
other conditions or limitations at the plant facility that would have restricted such activity. We are very confident of
the job Mr. Croom has done and the plans that he has put in place. Additionally, we have office personnel to
specifically verify period testing and reporting as a backup measure to assure that activities, such as stormwater
testing, are not strictly in the domain of one individual; and to assure that proper monitoring, testing, reporting, etc.
is always maintained in a -responsible, professional, and timely manner.
We appreciate your consideration and pledge to subscribe to all mandates and regulations of our NC stormwater
permit. Please do not hesitate to contact me if there is any assistance I can provide.
Sincerely,
Andrew . Simmons.

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American Distillation, Inc.
1690 NE Royster Road
Leland, NC 28451
910-371-0993 Fax[phone]
March 16, 2014
Walton Engineering
PO Box 895
Burgaw, NC 28425
Subject: ADI Stormwater Permit 15` Quarter
Mr. Walton,
Rain event and stormwater sample:
Light rain started around noon on 3-16-2014. stun off started at 2:15 pm on 3-16-2014. Rain total at this
time was .06" sample taken at 2:30pm on 3-16-2014.
Total rain from 3-16-2014 to 8pm 3-17-2014 was .92".
Sincerely,
i
Hugh Croom r

Environmental Chemists, Inc.
6602 Windmill Way • Wilmington, NC 28405
® (91D) 392-= (Lob) • [phone] (Pax)
710 Bowsertown head • Manteo, NC 27954
(252) 473-SM
ANALYTICAL h CONSULTING
CHEMI T8 NCDENR DWQ CMWECATE M94. DIS CERTIFICATE 037729
American Distillation
Date of Report: Apr 03, 2014
1690 Royster Road
Customer PO tl:
Leland NC 28451
Report m 2014-03101
Attention: Hugh Croom
Report to: Hugh Croom
Project ID: Storrnwater
Lab ID Sample ID:
Collect Date/Tlme Matrix Sampled by
1447551 Site: Stormwater
3/1M014 2:30 PM Water Hugh Croorn
Test
Method
Results Date Analyzed
Oil & Grease (O&G)
EPA IW4
27 mg/L
03/31/2014
Total lgeldahl Nitrogen (TKN)
EPA361.Z
37.1 mg/L
04/02J2014
Residue Suspended (TSS)
sM 2W 0
63.9 mg/L
03/18/2014
pH
SM aw H s
6.27 unit
03/18/2014
BOO su wo s
AD QC mq& merft tar DO depletion not met A#y nd OLftkie of holdtt Um.
�! COD'
Ethanol SW 046 n16W BMS 1790 mg/L 0312012014
lsopropyl alcohol SW W m"Ood a Ms 1320 mg/L 030012014
Methanol 357mg/L 03/20/2014
Tert-butyl alcohol Sw948 BMs 100 mg/L 03120/2014
Comment:
Reviewed by-. [!�(�_
I�
>370 mg/L
7390 mg/L
03/19/2014
03/18/2014
RCportlt ?D14-031D1 Pop 1d1

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AMERICAN DISTILLLATION, INC.
DATE: 4-7.14
Send to: Mark Walton From: Darlene Wells
Attention: Office Location: 1690 NE Royster Road
Office Locatlon:Walton Engineering Phone Number. 910-371-0993
Fax Number: 910-259-1779 Number of Pages, Including Cover: 4
❑ URGENT ❑ REPLY ASAP ❑ PLEASE COMMENT ❑ PLEASE REVIEW
❑ FOR YOUR INFORMATION
COMMENTS:
The following is attached:
Stormwater Permit 1st Quarter
CONFIDENTAL ,
This email transmission and any documents, files or previous email messages
attached to it may contain information that is confidential or legally privileged. If you
are not the intended recipient any disclosure, copying, printing, distribution or use of
this transmission Is strictly prohibited. If you have received this transmission in error,
please immediately notify the sender by telephone or return email and delete the
original transmission and its attachments without reading or saving in any manner.
fax cover

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STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
Perna t Number NCS 00 0 244 SAMPLES COI.LECI'FA DURING,CALENDAR YKA,11:244
('This moaftar14ort shall be received by the Dtvfalon no latertban 30 days from
the da;7 , 'fiktiUty receives ft sampling results from tia laboratory.)
14
FACILITY NAME _ A ft e,L [_ & n . Di ST�t .0 Ln L
PERSON COLLECTING SAMPI.E(S) bu, Gre nh4
CERTIFIED LABORATORY($) eA irs..he19 _ l G,h_-.6Lab# DW Q% 9►1
ieb #
Part A. Specific Monitoring Requirements
C OUNTY s?rVAW, LjC
PHONE NO. ( RID 1 Aq i - Ogg 2
Eu
IVRE OF PERMITTEE OR DESIGNEE
RED ON PAGE 2.
�..,
..
knot
tY��
�ji' • t
. J,
J '
Does this ffscilty perfrm Vehblo Maiwermnoe Act"ies using mane dlma 55 galiow ofnew orator oil per mardW —yes ✓rio
(ifM complete Part B)
PartB: Vehicle Maintemnce AdMty MonWriva Requirtments
Ck"
No.
•
Date '.
Sample
Co1{ected,
'SM
effim
own
00400
Totai )Plow
(itapaicable)
'.
Total
Rainfall
Ofl & Grease
(ifappl.)
- -
Non -polar
OBcG/im
{Method 1"4
SGT-HEMS K
Total
Srapeaded
Soft
PH
New Motor
Oil Usage
jWd&TMG-
Inebee
wzA
writ
Umo
Form SWU-247, last revised 2122012
Page 1 of 2

t. CCo n 4irn \/ e
SPORMWATER DISCHARGE Oii1FALLipDO)
MONITORING REPORT
Permit Ntrouber NCS 0 d O 2_4
mciu TY NAME Appaea, O r s i n i hue r\ t_
PERSON COL LWITNG SAMM EM
CERTUM LABORATORY(S) Lab #
Lab #
Part A: Specific Monitoring Requirements
SAMPIM COLLECTED DURING CALENDAR YEAR: 2_0 S y
(M monif orkS report shall be received by the Divhlon no bier than 30 days from
the date the fae ty receive: titre eampiing resulb from the labontory.)
COUNTY �{ U ns,N +C.I►c
PHONE NO.
SIGNATURE OR PERM IT ME OR DESIGNEE
R6AUIRED ON PAGE Z.
Does t!ts facility perm Vehticia Makft a = Aotevh m cng more than 55 gallop ofmw motor oil per month? —yes --no
(ifyc% complete Part B)
PartB: Vehicle Maintenance Monitoring Requirements
Outfidl
No.
.
Date
Sample
Collected
50050 ,
1
00566
00530
00400
Total Flow
(it applicable)
Total
Rainfall
011 6ti Grease
(Ifappl.)
Non�polar
O&GfM
(Metbod-1664
SGT-HEMS 1f
Total
Swpeoded
Soft
-
pH
NewMotor
onUeage
MG
inches
man
unit
pyvw
Form SW U-247, last revised ZW012
Page I oft

STORM EVENT CHARACT1ERIMCS:
Date 3 b i'i
Total Event Pncii ibtlon (inches):7-
Event Duration (hours): - ' (one ifapplimble — sae perms{.)
(ifnmre than one storm evert was sampled)
Date
Total Event Precipitation (Inches):
Event Duration (bourn}: (o* Wapplicable — see pmrdL)
Mail Original and one copy to:
Division of Water Quality
Attar Central Files
1617 Mail Service Caur
RalBift North Caroleua 27699-1617
"I certify, under penalty of law, that this document and all attachments were pis pared under m' direction or supervision in accordance with a
system designed to anun that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or pemom who mmmap the system, or those persons dinctty responsible forgatheAft the Information` the information submitted is, to the
best of my knowledge and belies, try, accurate, and complete. I am aware fist then are signifleant penalties forsubmitting fabe inforniatlon,
Including the possibility of flumes and lmpr bonnrent for knowing violations."
1�a f L
(signature os e)
J�.23-iy
(Date)
Form SWU-247. last revised W12012
Page 2 oft

EnVIV"- entaal Chemists, Inc.
no bmmwbnftRcmd obbntm%NCZW4
ANAL cu A aoOULnM9
ass Ummkob nwM CsKroc=APL Pas cmvmxcnn
Anwwk= DkdMdko Dabs of RePwt Apr 03, 2014
INC R%IW P424 Cudamer Ro s:
Udand NC 2WI ReMt& 2014-03101
Aftiftm Huo Cron Reparttm Huh CMM
. Projsa! �: Slotrtantt�
tkb iQ sampb V. OMM Dohnin a Mdit Bu npsed by
14-07651 6ft SbmwzWr 2ISW014 2:30 PM WSW Hugh cmw
Test Rwaft one Ac ed
04 & Orem (OW) EM sear
27 M G&
03(311x014
TOW phi NbVm RBI Emma
37.1 mg/L
04l02=4
Rescue W su ssp u
SS.9 tom.
03MaM4
PH sm+eoo;a a
8.2.7 unb
camea 4
D SUMPS
a37D nmll,
0S1191?D14
A4 eaeere+�gr DD dap4aQan eat mat. addft off ume.
COD mazes 7390 MOIL 03MGM4
sg+tmamo sslKs 179UMgX 03J20=4
} sara�ennaweoot8 13z0m91L 03f2Ql ldt
Me"Ould sw ass meem Sore 3671"a& =20=4
raft-w dcow swera a4 eQ+n 'i00 tali. 0312WW4
comrom
RIft awam 1�o1d!

ENVIRONMENTAL k.,kIwJSTS, INC
C.,Ar.�1
•
ol
-wire whm
Br. Ak

American Distillation, Inc.
1690 NE Royster Road
Leland, NC 28451
910-371-0993 Fax[phone]
May 16, 2014
Walton Engineering ,
.PO Box 895
Burgaw, NC 28425
Subject: ADI Stormwater Permit 2N0 Quarter
Mr. Walton,
Rain event and stormwater sample:
Light rain started at 3:30 pm 5-15-20i4 no rain until 11:15pm. Sample taken at 11.30 pm, rain stopped
at 5:00am on 5-16-2014.
Total rain fall during event was 2.32"
Sincerely,
Hugh C om . �

Environmental Chemists, Inc.
%M v%win-du Way • WUmMngkn NC 2t34Q5
® (910) 392-= (Lab) • [phone] (Fax)
710 Bowwxk wn Road • Manteo, NC 27954
ANALYTICAL, & CONSULTING (252) 473-SM
CHEMLM NCDIIdR DWQ C£.RMCATE 0%. DtS CRIMMCATE 437M
American Distillation
Date of Report: Jun 17. 2014
1690 Royster Road
Customer PO 0:
Leland NC 28451
Customer ID: 09010037
Attention: Hugh Croom
Report #: 2014-05711
Project ID: Stormwater
Lab ID Sample ID:
Collect Date/Time Matrix Sampled by.
' 14-13817 Site: stormwater
5/15/2014
11:30 PM Water Hugh Croom
Test
Method
Results Date Analyzed
Oil & Grease (O&G)
EPA 16M
16 mg/L
05/22/2014
Total Neidahl Nitrogen (TKN)
EPA3$1.2
6.0 md/L
05/28/2014
Residue Suspended (TSS)
SM 250 D
91.0 mg/L
05/16/2014
pH-
SM 4= H a
3.69est unfts
05/22/2014
Ezftaft miff is oWside cabttatlan mnga ,
BOD
SM$2108
231 mg/L.
05/16/2014
COD
sMraa
1220 mg/L
05/19/2014
Ethanol
SW eaa ff*naa a0t5
<10 ma/L
06116/2014
Isopropyl alcohol
58.6 mWL
06/16/2014
Methanol
sw W..en,od 8015
28.6 mgtL
06/18/2014
Tert-butyl afoohol
swsaemethod=5
314 mglL
06/16/2014
Comment:
Reviewed by:
AaMn ft: 201aab791 Papa 1 of 1

et��x:f►►;tf►
ENVIRON.NIENT�' PHEMISTS, INC
NCQENR MQCW fWAMW 0 84 Ab.0,46:' M CIrR7 MAT M 0 37T2A
emir- inn ewe CNeffff OF CUSTODY
OOYL ♦n gBllitlll ns� ��u......y..ny.w w+..�
.OFFICE: 8t1.' 11MU4424
Wo@&mdr*n=M
CLIENT:
PROJECT NAME:
RMRT NO,
AbDRESS:
CONTACT NAME:.
PO NO:
REPORT TO:
PHONF.IFAX:
COPY TO:
email•
Sa mnlail'Rw• / wA,— QARffM c TvMr. l C - CSR..e..b w Q LI1e11 iXT d Q4-4 .. 4U%.v.ftnil _ _41 is Shldnr� �r
I
��IIMMM
��■mow■e�������
■ valtynliiWltl ilrll
oeifver@d B,�►:
1
If '
TUIZTIti3UNu:
l

enyhooc.heni
�J
ANALYTICAL & CONSULTING
CHEMISTS
Environmental Chemists, Inc.
6602 Windmig Way • welmington, NC 284015
[phone] (Lab) • [phone] (Fax)
710 Bowsertown Road • Mantm NC 27954 JUN 8 0 2014
[phone]
NCDENR DWQ CERTINCATE M49. OL5 CERTIFICATE 037729
American Distillation Date of Report: Jun 17, 2014
1690 Royster Road Customer PO #:
Leland NC 28451 Customer ID: 09010037
Attention: Hugh Croom Report #: 2014-05711
Project ID: Stormwater
Lab ID Sample ID:
Collect Date/Time
Matrix Sampled by
14-13817 Site: Stormwater
5/15/2014 11:30 PM
Water Hugh Croom
Test
Method
Results Date Analyzed
Oil & Grease (OSG)
EPA 188a
16 mg1L
05/2212014
Total Kieldahi Nitrogen (TKN)
EPA351.2
6.0 mg/L
05/28/2014
Residue Suspended (TSS)
SM2540 °
91.0 mg1L
05/16/2014
pH.
SM 45W H B
3.69est units
05/22/2014
Estimate: result Is outside calibration
range.
.PD
sM $210 B
231 mg/L.
0511612014
COD
sM SMD
1220 mg/L
05/19/2014
Ethanol
SW aae method ao15
<10 mg/L
..0611612014
Isopropyl alcohol
SW sae methW 8015
58.6 mg/L
06/1612014
Methanol
sw sae method sots
28.6 mg/L
06/16/2014
Tert-butyl alcohol
SW W method 8015
314 mg/L
06116/2014
Comment:
Reviewed by:
t-
Reoort Ak: 2014-05711 Pape 1 of 1

E VIRONMENTA �HEM15T5, INC;
NCDENR: DWO CPtItMATION 0 94 h,, r DLS CERiIRCAlwM 0 3"29 Inrodenvirowneka, lsts.com
CO CTIQN.AND. CHAIN. F CUSTODY_
:PTT: PROJECT NAME: REPORT.NO:.
TRESS: CONTACT NAME:_ - PO NO:
REPORT TO: PHONE/FAX:,
COPY TO: emall:
IOW d Bv: — mlt A t LA, SAMPLE T1 *F- 1 hsfluent_ F Fffluertt_ W = We<i_ ST-=.Stream: 90 -AM SL a Sludge. Other:
Sample Identification
s m"twFaulm w
Delivered; gy:
Cor Dents:
i
r
PUN
'l`ime:rJ
:
s m"twFaulm w
Delivered; gy:
Cor Dents:
i
r
PUN
'l`ime:rJ
:

STORMWATER DISCHARGE OUTFALL (SDO)
MONTTORING REPORT
Permit Number NCS_
FACILITY NAME N
PERSON COLLECTING SAMPLES)
CERTIFIED LABORATORY(S) C—,r+ • ^Lab 4-N4 94
Lab #
Part A: Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR:
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
COUNTY ggS'VjfC'k
PHONE NO.( 0) QqCtS
SIGNATURE OF PERMtTTEE OR DESIGNEE
==KID ON PAGE L
Does this, facility perform Vetucle Maintenance Activities using more than 55 gallons of new motor oil per month?_ yes _no
(if yes, complete Pan B)
Part B: Vehicle Maintenance AMvity Monitmina Rfonim.menhc — N A
Oumn'!
'No..
'3?atto :5005$
ptpie.
CdikMd� '.
003M
:005Xf
004M
'Tit "Xiow
;Qfgpplicatile)
:Tagil`,
:Rainfall
Oi!&:Grease.
,[ltappl.) '
;Non -polar
:O&GITP-H,
:(Method=lti54
SGT-HEM), if
a i.
"Tbtal:
Saspeaded
'Solids,
pH- ''New'Notor.
Qil'Ugage
mold"
1.14G'
iiiaches.
m
unit
aftmo
Form SWU-247, last revLwd 2/2✓2012
Page I of 2

V e
STORMWA R DISCHARGE OUTFALL (SDO)
M ORING REPORT
Permit Number NCS 0 0 0 `L L+ L
n �
'FACRn Y NAME h eI + 44"% '') � > ` h a 4
PERSON COLLECTING SAMPLES)
CERTIFIED LABORATORY(S) Lab #
Lab #
Part A: Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR:
(This monitoring report shall be nceived by the Division no Inter than 30 days from
the date the heft receives the sampling results from the laboratory.)
COUNTY (i ►� sc ,t1 i
PHONE NO. f ]
SIGNATURE OF PERMTITEE OR DESIGNEE
R 01MD ON PAGE 2. 11
ITn=
a.ut
f!
IL•
ry �
MA:
i
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?_ yes _no
(if yes, complete Part B)
Part B: Vehicle Maintenance Activity Moultorintt Requirements
'Outlall`
.,No.
;Duty •
Somole
%C07jrcted'
SiioSO:
:o03S5
V530
`o"m
-To%1XJuw,
,(!fiapplicubte), ,?Riajafall,
Total:
s011'.&-Grease
litappi,)
Non-;Wlar
'.O&GIITH.
(Method-1- 66.4
if
-awl.
!Tote!
fSospeaded
.°Solids.
H.
W w.Motor
;O9;Usagn.
mo✓ d
II+I
:inches.
'm '
m
unit
Vm0
Form SWU-247, Jost revised Z72 2012
Page I of 2

STORM EVENT CHARACTERISTICS:
Date 5 LO Iq
Total Event pitation inches):
Event Duration (boars): 5 (only if applicable— see permit.)
(if more than one storm event was sampled)
Date
Total Event Precipitation (inches);
Event Duration (hours); (only if applicable - see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Cater
Raleigh, North Carolina 27699-1617
"I certify, under penalty of law, that this document .and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel property gather and evalnate the information submitted. Based on my inquiry of the person
or persons who manage the system, or those persons directly. responsible for gathering the information, the Information anbmitted is, to the
best of my knowledge and belief; true, accurate, and complete: I am aware that there are significant penalties for submitting false information,
including the possibility of tines and imprisonment for knowing violations."
�k 1 L , Onn�q I 1 4 - -4 �f- � �
(S}gnatn of Fermi (Date)
Form SWU-247, last revised 21212012
Page 2 of 2

Environmental Chemists' Inc.
UO2 Winaaa way • Ica, M 2NO
® MM 396-C= (i.ab) • MM 392.4424 4�wo
no Bcwsadawa ) -ad • Mmet % NC vm �
ANAL a CONW arM
American Distillation Date of Report: .tun 17, 2014
1690 Royster Road. Customer PO p:
Leland NC '28451 Customer ID: 09010037
Attention: Hugh Cmom Report #: 2014-06711
Project ID: Stormwater
Lab ID Sample ID: Coiled CatelTime Matrix Sampled by
1413817 Site: Stcrrnvrater 5/15/2014 11:30 PM Water Hugh Croom.
Test Method Resutts Date Analyzed
Oil & Grease (O&G)
EPA1604
16 mg/L
05=2014
Total IQeldAN Nitrodan OV4j
EPA86t.2
6.0 mgiL.
051281W14
Residue Suspended (TSS)
sa 250 is
91.0 mglL
0511812D14
PH.
3.69est units
05/22/2014
es*nm msuA is occaftratlm rartga
SOD
taaazr0S
231 mall-
05116/2014
COD
serer
1220 mg1L
05119/2014
Ethanoi
SW saa MetCd Ulna
410 mail-
06116=14
Isopropo alcohol
sw Be msawe ama
58.6 mall-
0611 WM14
Methanol
sw so m.awd aria
i
28.6 mail-
06l1612014
Tart -butyl alcohol
Swam meawa W15
314 mgIL
W1612014
comment
Reviewed by.
1
I
FUMI st 2"44NN 1
t4psrdl

ENARONMENT A );HEMISTS, INC
nni i Fmim Amn C"M OF CUSTODY
Lwx
PR"' ,C i NAME• T'
Cw MO;
-
AbMOM '��
CO A ; NAME:.
PO NO:
IiiPOR T TO:
PHOWEIFAi4:
CCjPY m:
sty:
AT
MR
NiNillii
. r ~ iDrl&qJT

American Distillation, Inc.
1690 NE Royster Road
Leland, NC 28451
910-371-0993 Fax[phone]
September 3, 2014
Walton Engineering
PO Box 895
Burgaw, NC 28425
Subject: ADI Stormwater Permit 3`d Quarter
Mr. Walton,
Rain event and stormwater sample:
05:15 Sampled 8-1-14. Rain started 0500 8-1-14. Total rain .58" by 0900 8-1-14.
Sincerely,
Hugh Croom

Environmental Chemists, Incenviroehem .
602 WindraW way • Wilmk%t m KC 28405
(910) 392-022.3 (Lab) • [phone] (Fax)
710 Sowsertown Road • Manteo, NC 27954
[phone]
ANALYTICAL & CONSULTING
CHEMISTS AN $ t 2014 NCDENR: DWQ CERTIFICATE 0%. DL5 CERTMCATE 037729
American Distillation
1690 Royster Road
Leland NC 28451
Attention_ Hugh Croom
Lab ID Sample ID:
14-22684 Site: Stormwater
Tact
Oil & Grease (O&G)
Total Neldahl Nitrogen (TKN)
Residue Suspended (TSS)
BOD
COD
thanol
Isopropyl alcohol
Methanol
Tert-butyl alcohol
Comment:
Reviewed by:
r•
Date of Report: Aug 13, 2014
Customer PO #:
Customer ID: 09010037
Report #: 2014-09214
Project ID: Stormwater.
Collect Date/Time
8/1 /2014 5:15 AM
Method
EPA 1664
EPA 351.2
SM 2540 D
SM 5210 8
SM 5220fl
SW 80 method 8015
SW 84e meVood 8015
SW 848 method 8015
SW US method 8015
Matrix Sampled by
Water laugh Croom
Results Date Analyzed
7 mg/L
OS/0512014
3.5 mg/L
08/1212014
134 mg/L
08/01/2014
92 mg/L
08/01 /2014
128 mg/L
08/12/2014
<10 mg/L
08/05/2014
13.5 mg/L
08/06/2014
<10 mg/L
08105/2014
<10 mg/L
08/05/2014
Report P; 2014.06214 Pagel of 1

s�n��i r�}c:h�axx►
ENVIRONMENTAL CHEMISTS, INC
NCDENR: DWQ CERTIFICAMN 0 94 NCOMS: "CERTIFICAInON 0 3TT2'8
COLLECTION AND CHAIN OF CUSTODY
6602 WlndrWO Way Wilmineton. KC 28W5
OFFICE: 910-392-0223 FAX 910 M-4424
1nfo&nvironr%anta1ctwm ilst•.com
REPORT NO:I
Sampled Bv: so r •')t•A SAMPLE TYPE: I a Influent, E o Effluent, W a Well, ST =Stream. SO = Soil, SL = SiudA% Other:
Tp.mperature whe R iv !Accepted: Rej ted: i Resample R ested:
• Delivered By: Received By: Date: 1 r Time: T, 3b4--
Comments: TURNAROUND:
74
k

I

STORMWATER DISCHARGE OUTFALL tB�oj
MONITORING REPORT
PenmN Number NCS_ QQ �� r# SAMPLES COLLfWM DURING CALENDAR YEAlk �.i
abb moultoring 0aporl shall be reeved by the Division no later tbkn 30 days fim
the date the taeWty recelvea the sampling results fiom the laboratory.)
FACUM NAM. AM e fi''ca •,
MASON COIJAC MG SAMPL M PHONE NO. (qLj l_ 2** r ' 0'1 Z '
CS,D LABORATORY(S) b 0 9 4 r
+ e slab q
SIGNATURR OF PERbffl*B'OR DESIGNEE
RBOUMD QKPAGE L
Part A: Speel$c Moioltoring Requirements ,
�► 7lr/l�1
ifs'■
���
i
j
�■
Does this f3eciltty perform Vehicle Maiatatance Activities using more than 55 gallons of new motor oil per month?
Of yea. Wmglete Part B)
Port Ht Vehicle Maintenwace AdMt9 Monitorim Reaulremente
mill
L n-Y
i Form SWU-247, last mviW ?f2/2012
t Page 1 of 2
i

STORMWATER DISCHARGE OUTFALL(SDO)
MONITORING REPORT
Permit Number NCS 00 2 4
BACi mNAME. —AMBe. "p (`sq II(,'hon
PEBSON C01 LECMG SAMPLES} o
CERTMED LABORATORY(S) c Lab #_A_4_
Lab 0
Part A. Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR:
(Thin manhorlig 'report shall be reeebed by the Division na later ifian 30 days from
the date the facility receives the sampling results !from the laboratory.)
COUNTY AIst -Ie_ .
PHONE NO. I e t
SIGNATURE OF PLRMPI'TEE OR DESIGNEE
REOUH2$D OMPAGE L
.I` I II ''
�
1L
0 i L.I�����
�
�®
. _ .
Does this facility perform Vehicle Maintenance Activities using morn than SS gallons of new motor oil per month? -yes no
(if yes, cwVl to Part B)
Part & Vehicle Maintenance Activity ModkorinQ Renuirements
pb
Qdllbb&#t;ie):
"
.',fops'
.galpfpllfspl►l:)
_QiM.Gresse.
:
.Non -polar.
flOcCfl'PH
,(MethodaG61:
a
Tdta1
IS
f$
4ollds
::QH'
;
1esv otgp
1pii I#see"
.
oId
cites:
xa
:ro
.unit.wo
Form SWU-247, kut revised ZW012
'Page I of 2

STORM ZVFNT CRARACTE8t5 nCS:
Date DhZiplUtion
YTotal � (indus): 0, S$
Event Duration (hours): 3�; (only if applicable — see permit.)
(if more than one storm eva t was sampled)
Date
Tote .Zveet won (luches)
Event Duration (hours): '(only if applicable —am permit)
Mail Original and one copy to:
Division of Water
Attn: central Files
'1617 Mail Sel vice Center
Raleigh, North Carolina 27699-1617
"I car ft, under penalty of law, that this document and all attachments were prepared under my direction or soprenlsfon In auardance with a
system dedgued to =are that qual led personnel properly gather and evaluate the information submitted. Eased an my Inquiry of the person,
or persaw who manage the system, or those pe sous dirceztly responsible for gathering the information, the information submitted 1% to the
but of my knowledge and bellet true, accurate, and complete I am aware that dwrs are significant penalties for submitting false information,
including the possibility of Mee and imprisonment for knowing violations,"
(Signaft Permittee) (Date)
Form SWU-247, last revised 262012
Pago 2 of 2 -

Environmental Chemists,
Inc.
MM WinftM Way • Wilmington, NC 28405
(910) 392-OM (Lab) • [phone] (Fax)
710 Bowsertown Road • Manteo, NC V954
[phone]
CHEMEM E AUG S 9 2014 NCDe : oWQ CERI ff- CAT 4%. DLS CEzrr1l+ICa-M o37M
American OhMadon
Data of Report Aug 13, 2014
1690 Raystsr Road
Customer PO 0:
Leland NC
28451 Customer ID: 09010037
AtteaWn: Hugh Croom
Report I : 2014-09214
Pr�ect 0: Stomrwater
Lab ID Sample ID:
Collect DateMme Matrix Sampled by
14-22W Site: Stonrmater
8/1/2014 5:15 AM Water Hugh Croom
Test
Method Results Date Analyzed
Oil $ Grease (O&G)
EPA IW4 7 mg/L
08/052014
Total Kteldahl Nitrogen (TKN)
EPA 351.2 3.5 rng/L
08/12/2014
Residue Suspended (TSS)
sir 2W c 134 mg/L
08/01/2014
BOO
sM m o s 92 mg/L
08M1 /2014
COD
ssr 52200 128 mg/L
08/12/2014
Ethanol
sw e" ejVnma 8D15 <.10 mg1L
08/05/2014
Isopropyl aloohol
sw"611NO ao1s 13.5mg/L
08/05/2014
Methanol
sw a4e "N wod ems c10 mK/L
O&W7014
Tert-butyl alootrol
<10 mg/L
08105/2014
Comment~
{
Reviewed by:
_ _10<
Report it: 2014-0=4
Paps 1 or 1

American Distillation, Inc.
1590 NE Royster Road
Leland, NC 28451
910-371-0993 Fax[phone]M
September 3, 2014
Walton Engineering
PO Box 895
Burgaw, NC 28425
Subject: ADI Stormwater Permit Yd Quarter
Mr. Walton,
Rain event and stormwater sample:
05:1S Sampled 8-1-14. Rain started 0500 8-1-14. Total rain .58' by 0900 8-1-14.
Sincerely,
Hugh Croom

-.
Ventaloro, Julie
From:
Ventaloro, Julie
Sent:
Tuesday, October 28, 2014 1:28 PM
To:
'Mark Walton'
Subject: -
RE: NPDES Stormwater Draft Permit - NCS000244
Mark,
Responses to your questions are below in red.
Also, for your information, the public notice for this draft permit was published in the Wilmington Star News on October
24, 2014. The public comment period goes until November 28, 2014.
Julie Ventaloro
Stormwater Permitting Program
NC Division of Energy, Mineral, and Land Resources
161.2 Mail Service Center, Raleigh, INC 27699-t6i2
Phone: [phone]o Fax: (gig) 8o7-6494
Website: http://watersupplv�atershed.nc.gov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Low and may be disclosed to third
parties.
From: Mark Walton fmailto:marc@waltonen4ineerin, ,netl
Sent: Friday, October 24, 2014 12:00 PM
To: Ventaloro, Julie
Subject: Re: NPDES Stormwater Draft Permit - NCS000244
Julie,
We would like to know if the following permit items are now being included in all NPDES Industrial Stormwater Permits
or just American Distillation`s permit:
Part II Section A.2(b) The first part of this paragraph which talks about secondary containment being required is
standard language and is included in all individual NPDES Industrial Stormwater permits. The second part of this
paragraph which describes the specific parameters that must be monitored is tailored to each individual permit.
Tier One, Tier Two and Tier Three Tiered responses are now required in all NPDES industrial stormwater permits.
apologize for not having pointed this out specifically in the cover letter with your draft permit. We first began
implementing tiered responses in 2007, after your permit was last renewed, it appears.
Part III Section A.2 This section on Compliance and Liability is standard language and is included in all NPDES Industrial
Stormwater permits.
Also, we will be responding to the items requested in your letter next week. Thank you.
Thank You,
Mark Walton
On 10/15/20141:36 PM, Ventaloro, Julie wrote:
Mr. Simmons,

We are seeking your comments on the attached draft permit for the American Distillation,. Inc facility in
Brunswick County. The cover letter outlines significant changes that were made to the permit since it
was last issued as well as some outstanding issues that need your attention. Please review the draft
permit and send your comments and required documents (site map, data) to me either by email or
regular mail. I've dropped a hard copy in the mail to you as well.
The draft has not gone out for public notice yet, but l anticipate that happening by the end of October.
I'll let you know when that happens.
Please give me a call if you have any questions.
Mark and Allen — let me know if you would also like to receive a hard copy of the draft permit in
addition to the attached electronic copy.
Julie Ventaloro
Stormwater Permitting Program
NC Division of Energy, Mineral, and Land Resources
1612 Mail Service Center, Raleigh, NC 27699-1612
Phone: [phone] Pax: [phone]
Website: http://watersupplvwatershed.nc.gov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
R. Mark Walton
Licensed Professionsal Engineer
Walton Engineering
PO Box 895
Burgaw, NC 28425
Tel: [phone]
Fax: [phone]
e-mail: [e-mail]
_VROVOStf This email is free from.viruses and malware because avast! Antivirus protection is active,
_ �7 a fm

Ventaloro, Julie
From:
Pusey, Steven
Sent:
Tuesday, September 30, 2014 5:37 PM
To:
Ventaloro, Julie
Cc:
Scott, Georgette; Sams, Dan
Subject:
RE: Review Request NCS000244 American Distillation Inc
Attachments:
DOC-ADI NCS 000244.pdf
Follow Up Flag:
Follow up
Flag Status:
Flagged
Julie,
Please find attached a copy of our report from an inspection last year for NCS000244. Let me know if you have any
questions.
I will be looking over the materials you sent and will fill in what I can on the Staff Report Request.
Steve Pusey
DEMLR
From: Ventaloro, Julie
Sent: Tuesday, September 30, 2014 4:25 PM
To: Pusey, Steven
Subject: FW: Review Request NCS000244 American Distillation Inc
Steve,
Thanks for talking with me about your findings at your recent SSW inspection of this facility. I'll be very interested to see
your inspection report from this most recent inspection as well as past inspections.
As we discussed, please look over the attached materials and fill out what you can on the Staff Report Request. It needs
your signature and Dan's before sending back to me.
And, fyi, I spoke to Mark Walton with Walton Engineering on 8/13/2014. He said they were going to prepare a new site
map that has the topo lines and outfall location They were also going to try to track down the missing data from 2012-
2014. Apparently, there were some problems with the old management at the facility, and sampling may not have been
getting done. But I haven't receiv'ed any of these things from them yet. I'll follow up with them again, but if you happen
to talk to them sooner, please ask them about these items if you don't mind.
Thank you!!
Julie
From: Ventaloro, Julie
Sent: Wednesday, August 13, 2014 10:19 AM
To: Sams, Dan
Cc: Scott, Georgette
Subject: Review Request NCS000244 American Distillation Inc
Dan and Georgette,
Please find attached the following documents for your review and comment:
0 Staff Review and Evaluation

• Draft Individual Stormwater Permit NCS000244, American Distillation Inc
• Permittee's renewal application
There could be some issues with this site — see included monitoring data (BOD,COD, TKN, TSS) and notes about things
missing from their renewal application. I've spoken with the permittee's consultant at Walton Engineering — they're
involved only in the application preparation and not in site management. I've left a message with Andy Simmons, who I
believe is one of the owners, but haven't heard back from him yet. I wanted to get some information from him about
where exactly they're taking the sample, as well as the other issues I outline in the attached staff report. Please let me
know if you have success getting in touch with him.
I also need to get verification from the company about the correct contacts for the permit/facility. Here's what I got
from their consultant, but need verification:
Owner: Andrew J Simmons, Jr; 910-371-0993 (office); 910-512-4772 (phone)
Permit contact: Hugh Croom, Plant Manager; 910-371-0993
Facility contact: Andrew J Simmons, Jr
**I noted that Kelly Johnson worked on the 2007 version of this permit, so she might be a good resource for the
renewal.
Please return the staff review and evaluation form with your comments to me by September 13, 2014.
Thanks!
Julie Ventaloro
Stormwater Permitting, Program
NC Division of Energy. Mineral, and Land Resources
161z Mail Service Center, Raleigh, NC 27699-1612
Phone: [phone]o Fax: [phone]
Wehsite: http://watersup2plv3matershed.ne,gov
&mail correspondence to andfran this uddress may be subject to the North C'urolina Public Records Law and may be disclosed to third
Parties.

NO R
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pal McCrory Charles Wakild, P. E.
Governor Director
May 10, 2013
Mr. Andy Simmons, President
American Distillation Company, Inc.
P.O. Box 400
Leland, NC 28451
SUBJECT: Compliance Evaluation Inspection — NPDES Stormwater Permit NCS000244
American Distillation
Brunswick County
Dear Mr. Simmons:
John E. Skvarla, ill
Secretary
On March 20, 2013, Steve Pusey and Tom Tharrington, of the Division of Water Quality, Wilmington Regional
office, performed an inspection of the subject facility. This inspection covered both the requirements of the
Individual Stormwater permit NCS000.244, and the General Wastewater permit NCG500148 for cooling tower 1
boiler blowdown.
Previously on April 22, 2010, a Notice of Violation was issued for permit and stream standard conditions on the
General Wastewater permit NCG500148. At that time, process wastewater was being discharged to the cooling
towers, which was in violation of the permit. The General Permit NCG500148 allows discharge of non -contact
water only. The piping from the process wastewater to the cooling towers has now been disconnected, and all
process wastewater is sent to the Northeast Brunswick Wastewater Treatment Facility. The inspection report for this
permit will be issued separately.
In reference to the Individual Stormwater Permit NCS000244, the following items should be addressed to prevent
problems in the future:
Although there is only one outfall shown on the current site plan where the swale enters the stream, there is
also a valve at south end of the stormwater containment pond that, if opened, could drain to a vegetated
area, then to the stream, if this is an outfall, it should be identified as an outfall on the site map. Note that
this outlet and other outlets can be consolidated to drain into the State stormwater pond, once it is
constructed. However, all water must be tested and meet approved pollutant limits before being discharged
to the State stormwater pond. The site plan should be updated to include the complete State stormwater
pond and its associated inlet / outlet connections. If all outlets from the plant site are consolidated to drain
to this pond, the.new outfall would be located at the vegetated filter strip near the pond outlet.
2. Tank 23, which contains distillation process wastewater, and several other above ground storage tanks,
which may have product or waste in them, located in the area behind the cooling towers, do not have
secondary containment. Tapk 23 and possibly the other adjacent tanks should be evaluated for requirement
of secondary containment. Wherever feasible, above ground storage tanks should be surrounded by some
type of physical containment (impervious dike, berm, or concrete retaining structure) to prevent runoff in
the event of a failure or leaking transfer valve. Note that any resulting unpermitted discharge would be a
violation of the Clean Water Act
3. Qualitative inspection records should be provided on current DWQ forms in future.
4. Significant erosion was noticed in two (2) places, one area at the north end of the stormwater containment
pond on the berm, and the other one further north along the berm. These areas should be repaired and
stabilized with vegetation as soon as possible. The liner in the stormwater containment pond shows
significant wear and is torn in several places. This could allow contaminated stormwater to leak out
through the bottom and/or through the adjacent berm. It was discussed that the liner would be replaced.
Wilmington Regional Office
127 cardinal Drive Extension, Wilmington, North Carolina 28405 n 1
Phone; 910-796.7215 t FAX: 910.350.M 1 DENR Assistance: 1-877-623-6748 Orth C arol i n a
internef: www.nrwateiqua!lfy.org a%��yrjyrdl//�
An Equal oppor[=4IA�irmaliveAction Employer jJ y

Nnuy annmons, r,rwwCm 11
NPDES Stormwater Pen -nit NCS000244 s �'
May W, 2013 -- -
As part of the inspection, a taur of your facility was conducted. All observations and recommendations are noted in \ '
the (Summary of findings/comments) of this inspection report. Remember, it is our goal to ensure the quality of the
surface waters of this State.
Please review the attached report. If you or your staff has any questions, do not hesitate to contact Steve Pusey, Tom
Tharrington, or myself at 910-796-7215.
Sincerely,
Jim Gregson
Water Quality Regional Supervisor
Enclosures
cc: (✓W,IRO files (Brunswick stortpwat-er inspection file) .
Central files
f.NPS
tormwater Permitting Uni
and Compliance Oversi ht
Page 2of2

� JN%- Li.rftlX i MULI l UC iaV V IMUMVIGIV 1 /1IV11 1NH 1 Ur'^j' 1lClJUUI<� 1
MR INDUSTRIAL STORM WATER INSPECTION FORM
Wti.Nlfl\G'lON REGIONAL OFFICE
acility: American Distillation _ Date: 3/20/2013
Location Aauress: I OYU Nt; Koyster Koaa, Leiana, rvL L84?k
k-vu 0: NUS UUU244
Contact Name: Charles (Chuck) Bullard, Supervisor
Andy Simmons, President
Phone Number: 910-371-0993
Contact Mailing Address: See Above
County: Brunswick
Directions:
From Leland, take Old Mill Rd to Navassa, then turn right onto Rayster, go to gate, push button, request entry
X
Routine Compliance Inspection
Rescission Request
Complaint Investigation
Other - Explain
A.
.STORM WATER•POLLUTION PREVENTION PLAN
Yes
No
NIA
Comments
1.
Is a copy of the signed and certified SWPPP at the facility?
X
Rev. 3-15-14 & 2-22-12
Tank 23 area may need.
2.
Does the facility's SWPPP address the minimum BMP requirements?
x
3.
Are amendments to the SWPPP clearly documented?
X
4.
Is the current SWPPP complete?
x
R.
VEHICLE EQUIPMENT
Yes
No
NIA
1.
Were the vehicle/equipment maintenance areas inspected?
x
2.
Are vehicle/machinery leaks and drips properly managed?
x
3.
Is vehicle/equipment washing done in a designed area so that wash water
can be properly managed?
x
4.
Was the vehicle fueling area inspected?
x
5.
Are vehicle maintenance activities kept indoors?
x
6.
Were the vehicle/equipment storage areas inspected?
x
7.
Are current BMPs in vehicle/equipment/fueling areas adequate?
x
C.
WASTE MANAGEMENT
Yes
No
NIA
1.
Are containers for temporary storage of wastes labeled?
x
2.
Are waste materials recycled?
x
3.
Are hazardous wastes properly handled and disposed of?
x
4.
Is processed debris removed regularly?
x
5.
Is there secondary containment for liquid wastes?
x
6.
Are current waste management BMPs adequate?
x
D.
MATERIAL STORAGE
Yes
No
NIA
1.
Are there appropriate BMPs for outdoor storage of raw materials,
products, and byproducts?
X
2.
Are containers for chemical substances labeled?
x
3.
Is there secondary containment for liquid storage?
X
4.
Are current BMPs in material storage areas adequate?
x

E.
SPILL CONTROL
Yes
No
NIA
Comments
1.
Are there procedures for spill response and cleanup?
X
2.
Are appropriate spill containment and cleanup materials kept on -site and
X
in convenient locations?
Significant erosion was
3.
Are used absorbent materials disposed of in a timely manner?
X
4.
Are current spill BMPs adequate?
X
F.
EROSION
Yes
No
NIA
1.
Are unpaved outdoor areas protected fi-om water/wind erosion?
X
2.
Are drainage ditches or the areas around the outfalls free of erosion?
X
noticed in two (2)
places, one area at the
north end of the
stormwater containment
pond on the bean, and
the other one further
north along the berm.
The stormwater Swale
3.
Do implemented BMPs appear effective in controlling erosion?
X
had some erosion. This
area will be improved
with the construction of
the State stormwater
pond. The previously
excavated soil from this
area, currently stored on
a concrete pad with
secondary containment,
should be disposed of
properly.
G.
NON -STORM WATER MANAGEMENT
Yes
No
NIA
1.
Have all illicit water. discharges been eliminated or permitted?
X
2.
Are BMPs for authorized non -storm water discharges properly
X
implemented?
3.
Are current BMPs adequate for management of authorized non-stonrn
X
water discharges?
Wastewater treatment
H.
PROCESS WASTEWATER CONTROLS AND MONITORING
Yes
No
NIA
].
Are wastewater treatment facilities properly maintained?
X
units are being prepared
for future use as pre-
treatment of wastewater
before sending to POTW
2.
Has monitoring been done?
X
1€.
STREAM OBSERVATIONAMPACTS
Yes
No
N/A
1.
Were there any stream impacts?
X
2.
Were field parameters taken for pH or DO?
X
3.
Were there any stream standard violations/
X
4.
Were there excessive solids in the stream?
X
5.
Were pictures taken?
X
6.
Were samples taken?
X

/SUMMARY
/ ADDITIONAL COMMENTS
There are two (2) locations in the yard area that contain stonnwater runoff. Each area has a locked valve. The water here must.
ae sampled and determined as "clean" before it is released through the valves to the outfall. There is also a discharge valve at the
south end of the stormwater containment pond that, if opened, would drain to a vegetated area and then to the stream. If this valve
is ever opened, it should be evaluated as an outfall and shown on the site map. Alternately, it can be routed to the State stormwater
pond once it is constructed.
2. Tank 23 contains distillation process wastewater. Therefore, it has been physically disconnected from the cooling towers. It also
has a locked valve so that the wastewater is not sent to the stormwater containment pond. Instead, the contents of this tank are sent
to the POTW for treatment. This tank and possibly other adjacent tanks should be evaluated for requirement of secondary
containment.
3. lender Section C, Qualitative Monitoring, the permit states that all qualitative monitoring will be performed twice per year,
however Table 4 of this section states that monitoring will be performed quarterly. Please perform quarterly monitoring until
further notice.
K.
RATING LEVEL (CIRCLE ONE: 1-6)
I.
Industry in substantial compliance
2.
Minor deficiencies noted. Revisit scheduled for (date).
3.
Major deficiencies or discharges noted and require prompt correction. Revisit scheduled for (date).
4.
Critical deficiencies or discharges noted and require immediate correctioin. Revisit scheduled (date).
for
5.
Rescission is appropriate.
6.
Rescission is not appropriate. Permit is in process of being renewed.

L. include a Map of the facility. This drawing should depict the building, parking, process, and storage areas. If you dormt,_..,
have a map, draw one or request that the facility provide you one in your written correspondence.
Map on file. This map should be updated to include the new State Stormwater pond once it is constructed.
M. Develop a Vicinity Map for the file.
Map on file.
N. Identify all records that were reviewed.
Qualitative records through 0311112013 have been reviewed. Qualitative inspection records should be provided on current
DWQ forms in future.
O. Explain how Secondary Containment is being used and whether these measures are being properly maintained. [Did you
observe that the secondary containment had release valves (were they open, locked etc.), was there water, waste product,
sheen, etc observed within the secondary containment area? Explain your observations]
No wasteivater was found within containment areas. Several large bulk tanks with product or waste in them, including Tank
23, are located outside ofsecondary containment areas behind the cooling towers.
P. Housekeeping and best management practices (maintenance of BMPs) status.
Fair. Drummed storage areas need secondary containment where drums have product or waste in them. Airy hazardous
waste storage pads require secondary containment.
Q. Identify outfalls and receiving waters. List any observation or concerns.
There is one outfall on the plan where the Swale enters a vegetated area and then stream. There is also a valve at south end
of the stormwater containment pond that could drain to a vegetated area then stream. If this is an outfall, it should be
identified as an outfall on the site map. Note that this outlet and other outlets can be consolidated to drain into the State
stormwater pond, once it is constructed However, all water must be tested and meet approved pollutant limits before being
discharged to the State stormwater pond.
R. Take digital photographs to support staff report observations and to provide assistance to future inspectors).
Digital photographs are on file.
Logged by: Inspectors: Steve Puse_y and Tom Iharrineton

Ventaloro, Julie
From:
Pusey, Steven
Sent:
Tuesday, September 30, 2014 5:25 PM
To:
Ventaloro, Julie
Subject:
FW: American Distillation
Follow Up Flag,
Fallow up
Flag Status:
Flagged
Julie,
FYI, see attached email from Mark Walton in August of 2013. This explains the contents of Tank 23.
Steve
From: Mark Walton fmailto:markCalwaltonengineering_net]
Sent: Friday, August 23, 2013 11:12 AM
To: Pusey, Steven
Cc: [e-mail]
Subject: Re: American Distillation
Steve,
I talked to Chuck Bullard and Tank 23 holds treated wastewater for sampling prior to discharge to the POTW. It is non-
hazardous. AD] is not a permitted Hazardous Waste TSD facility and as such cannot treat hazardous waste. Also, the
Brunsick POTW cannot accept hazardous waste.
AD] operates under the jurisdiction of the Divsion of Waste Management, Hazardous Waste Section regading hazardous
waste. Bobby Nelms is the facility inpsector. if you have any questions about ADI's hazardous waste generation, storage
and disposal, Bobby would be a good person to contact.
Thanks,
Mark
----- Originai Message --- _ — - - --
From:- Puse . Steven _
To: Mark Walton
Sent: Thursday, August 22, 2013 3:59 PM
Subject: RE: American Distillation
Mark,
Secondary containment applies to oil and hazardous waste. It was my understanding that Tank 23 contained waste
material. Can you advise the contents of this tank and whether it is classified as hazardous?
Thanks,
Steve
From: Mark Walton rmailto: mark(a)waltonenaineering.net]
Sent: Wednesday, August 21, 2013 12:47 PM
To: Pusey, Steven
Subject: American Distillation
Steve,
1

In the Inspection Report for ADI, you mentioned adding secondary containment for some tanks in the vicinity of the air
stripper.
I am not aware of a regulation or law that requires secondary containment for non -oil storage tanks. If there is one, could
you please let me know the regllaw that requires it.
Thanks,
Mark Walton
R. Mark Walton
Licensed Professionsal Engineer
Walton Engineering
PO Box 895
Burgaw, NC 28425
Tel: [phone]
Fax: [phone]
e-mail: mark(@-waltonengineering.net

Ventaloro Julie
From: Ventaloro, Julie
Sent: Wednesday, August 13, 2014 2:17 PM
To: ' mark@waltoneng i nee ring. net'; 'alien @waltonengineering.net'
Subject: NPDES Industrial Stormwater application - American Distillation Inc
Attachments: NCS000244—AmericanDistillationCo—RenewalAppl. pdf
Mark and Allen,
Thank you for your help with getting together materials for the renewal of American Distillation's NPDES Stormwater
permit NCS000244. For your records, attached is a scan of the renewal application you submitted on behalf of American
Distillation Inc in 2012. Mark —Thank you for looking into whether there is DMR data for the 2012-2014 period, and for
preparing a new site map with the outfall location indicated and topo lines. One of the issues we'll need to look into is
why the reported values for COD, BOD, TKN, and TSS are elevated on numerous occasions. It would be helpful to know
exactly where the sample is being collected.
Julie Ventaloro
Stnrniwater Permitting Program
NC Di-Osion of Energy, Mineral, and [.and Resources
1612 Mail Service Center, Raleigh, NC 27699-1612
Plinne: [phone] Fax: (919) 807-E494
Website: h t w r ater h v
P.-mail correspondence to and from this address mov he cuhirr rn rho I%t-,) t r _ +: Public Records La", and may be disclosed to third
parties.

7
WALToNENGINEENNG
March 5, 2012
Stormwater Permitting Unit
Attn: Brian Lowther
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Stormwater Permit Renewal, American Distillation Co., Inc.
Mr, Lowther:
Enclosed in the information pertaining to the renewal of the NPDES Stormwater Permit, No.
NCS000244, for American Distillation Co., Inc. (ADI). A renewal application form is
enclosed along with the required supplemental information, included and/or explained as
follows:
1. A current site map from the Stormwater Pollution Prevention Plan is included.
2. A summary of Analytical Monitoring results is included.
3. A summary of Visual Monitoring results is included.
4. A summary of the Best Management Practices utilized at the facility is included.
5. There have been no significant -changes in industrial activities at the facility. ADI has
started to send their wastewater to Brunwick County's POTW. Their permit.for this
began August 9, 2010.
6. Certification of the development and.implementation of a Stormwater Pollution
Prevention Plan for the facility is signed and enclosed.
Two copies of all required information have been included with this submittal.
If you have any questions -or need additional information please call me at 910-259-4800.
Sincerely,
Allen Thomton
Tel: [phone] PO Box 895, Burgaw, North Carolina, 29425 Fax: [phone]

N
STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Water Quality - 5tornlwater Permitting Unit
Facility Name: CNA Holdings, Inc. 7icona Plant
Permit Number: NCS000244
Location Address: 1690 Rooster Rd NE
Leland, NC 28451
County: Brunswick
"I certify, under penalty of law, that the 5tormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a systern designed to assure that
qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the person
or persons Who manage the system, or those persons directly responsible for gathering the infornation, the information
gathered is, to the best of my knowledge and belief; true, accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at tSe named facility location. and the SPPP has been
fully implemented at this facility location in accordance with the terms and conditions of the stormwater discharge
permit."
And
"I am aware that there are .significant penalties for fasifying information, including the possibility of fines and
imprisonment for knowing viotations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date
4� ak
Print or type name of person signing above Title
SPPP Certification 5109
ti•d 999Z-LL£-0L6 pJeline)lon4o e1.£'•60Zi.LVuef

, Perinft,Coverage
Rf[feWai AppffCaflon Fora'! Permit Number
Nation at pollutant Discharge Etfl,rt�nation System
Stormwater Discharge Permit NC2a4
The following Is the information currently in our database for your racitity. Please review this information carefully and make all
correctiorsladditions as necessary in the space provided to the right of the currient Infomwon.
Owner Affilia4aan tnfw7& = ' Reissued Permit will be rnciled to the owner address
Owner / Organization Name:
American Distillation Inc
Owner Contact:
Edward Cart Simmons
Mailing Address:
PO Box 400
Leland NC, 28451
Phone Number -
Fax Number:
E-mail address:
Facir !permit Contact Information
Facifi ty Name:
American Distillation - Navassa
Fatuity Physical Address:
I Raysrer Rd NE
Leland, NC 28451
Facility Contact:
Mailing Address:
Phone number:
Fax Number.
E-mail address:
ME5t@= ht><a ma cn
Receiving Stream
Cartwheel Branch
18-72
Stream Class:
SC; SW
Basin:
Cape Fear River Basin
Sub -Basin:
03-06-17
Numt er of OntfaUs:
irrivaifred WatarslilYWi
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? C1 Yes ❑ No ❑ Don't Know
( for ir#bMwtlon on these waters refer to http:llh26-enr.swte_nc-uslsulfmfwired Wuters_TMDLI )
CERTIFICATION
I certify that I am familiar with the information contained In the application and that to the lest of my knowledge and belief such
information is trueLIte and accurate.
Signature ' Date
Print or type name of Pemr signing above Title
Please return this completed renewaI application'furm to:
Stormwater Permitting lint
Attu: Brian Lowther
1617 Mail Service Center
Raleigh, North Carafina 27699-1617
C'd R98Z-LL£-0 Li3
pielln8 jon40 e0£:60 ZL L L UBF

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Storrnwater Pollution Prevention Plan)
Initials
1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall.
building locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). ❑o not submit individual lab reports.
The summary can consist of a table including such items as outfall number.
parameters sampled, lab results, date sampled, and storm event data. H
] � 3. A summary of the Visual Monitoring results. Do not submit individuai monitoring
reports. The surnrnary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at.the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
_ 5: A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of .
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
- b. Certification of the development and implementation of a'Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the.last.years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)
9'd 898Z-tL£-0W pialingNon4o - gl£mnLL,uer

Summary of Ana"cai Monitoring
NPDES Permit No.: NCS000245 Outfail No.: 001
Facility Name: American Distlllatlon, Inc. Class: D
Certiflod Laboratory: Envfronmental Chemists. Inc.
Parameters Units
BODS
TSS m
COD L
TKN L
Oil & Grease L
TertAtchl m L
Methanol L
Ethanol M L
Iso I Alchl M
Toluene u
H S.U.
Total Rainfall
Event Duration
Code
00310
00530
00340
00825
00560
1
34010
00400
Inches
Min.
Quarter
Sample
3
91291201 t
989
138
1520
NA
BQL
<10
<10
1340
<10
NA
5.54
2.43
.24
1
1117=11
128
288
483
NA
38
120
<50
<50
106
NA
8.31
NA
NA
3
9/28/2010
148
154
353
NA
<5
21.5
62.3
<2
<2
NA
6.46
0.59
6
2
7N4/2010
904
21.8
1460
25.1
<5
27.1
70A
360
250
NA
8.79
0.15
0.5
1
1/17/2010
122
52
447
<0.5
11
8.24
4.04
35.8
12.9
NA
6.89
6.92
0.5
4
11 /10/2009
2360
43
3500
70
<5
180
105
121
<20
NA
7.17
0.5
30
3
91=009
44
73
314
3
<5
<1.0
88.9
0.0
<1.0
NA
8.84
7.2
48
2
6/9/2009
8e0
25
2720
3.8
<5
33.6
72.3
11.7
37.8
NA
8.59
OAS
2
1
4/9/2009
28
15
280
1.8
<5
BQL
BQL
BQL
BQL
NA
8.85
1.15
16
4
11/13/2008
103
18
185
4
<5
BQL
BQL
2.88
1.76
NA
8.75
1.85
5.5
3
9/2912008
13a
1585
420
7.1
<5
BQL
BQL
30
11.4
NA
7.28
0.85
5
2
7/11/2008
319
218
998
10.3
<5
BQL
20.7
3.1
24.6
NA
8.88
0.48
3.5
1
2/21/2000
64
304
480
5
<5
BQL
100
BQL
NA
6.8
1.5
10.5
4
12/16/2007
517
472
1234
t8.2
2
BQL
14.8
NEW
28.1
21.1
NA
7.1
1.4
8.5

SummaEy of Visual -Monitoring
NPDES Permit No.: NCS000245 ' Outfall No.: 001
Facility Name: American Distillation, Inc. Class: D
Certified Laboratory: Environmental Chemists~ Inc.
Inspection Date
Rainfall Amt.
Inspector
Remarks
12/27/1999
None
Hugh Croom H.C.
No Comment
1/10/2000
None
H.C.
No Comment
1/18/2000
None
H.C.
No Comment
1/24/2000
None
H.C.
No Comment
1/31/2000
None
H.C.
No Comment
2/6/2000
None
H.C.
No Comment
2/14/2000
None
H.C.
No Comment
2/21/2000
None
H.C.
No Comment
2/28/2000
None
H.C.
No Comment
3/6/2000
None
H.C.
No Comment
3/14/2000
None
H.C.
No Comment
3/20/2000
None
H.C.
No Comment
3/27/2000
None
H.C.
No Comment
4/3/2000
None
H.C.
No Comment
4/10/2000
None
H.C.
No Comment
4/17/2000
None
H.C.
No Comment
4/24/2000
None
H.C.
No Comment
5/1/2000
None
R.C.
No Comment
6/9/2000
None
H.C.
No Comment
5/15/2000
None
H.C.
No Comment
5/22/2000
None
H.C.
No Comment
5/29/2000
None
H.C.
No Comment
6/5/2000
None
H.C.
No Comment
6/12/2000
None
H.C.
No Comment
6/26/2000
None
H.C.
No Comment
7/3/2000
None
H.C.
No Comment
7/10/2000
None
H.C.
No Comment
7/17/2000
None
H.C.
No Comment
7/24/2000
None
H.C.
No Comment
7/30/2000
NIA
H.C.
Observed during heavy rainfall. Some cloudy water.
7/31/2000
None
H.C.
No Comment
8/7/2000
None
H.C.
No Comment
8/14/2000
None
H.C.
No Comment
8/22/2000
None
H.C.
No Comment
8/28/2000
None_
H.C.
No Comment
.915/2000
None
H.C.
No Comment
9/11/2000
None
H.C.
No Comment
9/18/2000
None
H.C.
No Comment
9/25/2000
None
H.C.
No Comment
10/2/2000
None
W.C.
No Comment
10/9/2000
None
H.C.
No Comment
10/10/2000
None
H.C.
No Comment
10/23/2000
None
H.C.
No Comment
10/30/2000
None
H.C.
No Comment
11/6/2000
None
H.C.
No Comment
11/1312000
None
H.C.
No Comment

11/21/2000
None
H.C.
No Comment
11/27/2000
None
H.C.
No Comment
12/4/2000 .
None
H.C.
No Comment
12/12/2000
None
H.C.
No Comment
12/18/2000
None
H.C.
No Comment
12/26/2000
None
H.C.
No Comment
. 1/2/2001
None
H.C.
No Comment
1/8/2001
None
H.C.
No Comment
1/16/2001
None
H.C.
No Comment
1/22/2001
None
H.C.
No Comment
1/30/2001
None
H.C.
No Comment
2/6/2001
None
H.C.
No Comment
2/12/2001
None
H.C.
No Comment
3/5/2001
None
H.C.
No Comment
3/12/2001
None
H.C.
No Comment
3/19/2001
None
H.C.
No Comment
3/26/2001
None
M.C.
No Comment
4/2/2001
None
H.C.
No Comment
4/9/2001
None
H.C.
No Comment
4/16/2001
None
H.C.
No Comment
4/23/2001
None
N.C.
No Comment
4/30/2001
None
H.C.
No Comment
5/7/2001
None
H.C.
No Comment
5/14/2001
None
H.C.
No Comment
5/21/2001
None
H.C.
No Comment
5/28/2001
None
H.C.
No Comment
6/5/2001
None
H.C.
No Comment
6/11/2001
None
H.C.
No Comment
6/18/2001
None
H.C.
No Comment
6/26/2001
None
H.C.
No Comment
7/2/2001
None
H.C.
No Comment
7/9/2001
None
H.C:
No Comment
7/17/2001
None
H.C.
No Comment
7/24/2001
None
H.C.
No Comment
7/30/2001
None
H.C.
No Comment
8/6/2001
None
H.C.
No Comment
8/14/2001
None
H.C.'
No Comment
8/23/2001
None
H.C.
No Comment
8/27/2001
None
- H-C.
No Comment
9/5/2001
None
H.C.
No Comment
9/10/2001
None
H.C.
No Comment
9/17/2001
None
H.C.
No Comment
9/24/2001
None
H.C.
No Comment
10/2/2001
None
H.C.
No Comment
10/15/2001
None
H.C.
No Comment
10/22/2001
None
H.C.
No Comment
10/29/2001
None .
H.C.
No Comment
11/6/2001
None
H.C.
No Comment
11/12/2001
None
H.C.
No Comment
11/19/2001
None
H.C.
No Comment
11/25/2001
-•1"
'H.C.
Some discoloring of water.
11/26/2001
None
H.C.
No Comment
12/4/2001
None
H.C. I
No Comment

12/10/2001
None
H.C.
No Comment
12/31/2001
None
H.C. r
No Comment
12/26/2001
None
H.C.
No Comment
1/2/2002
None
H.C.
No Comment
1/9/2002
None
H.C.
No Comment
1/14/2002
None
H.C.
No Comment
1/21/2002
None
H.C.
No Comment
1/28/2002
None
H.C.
No Comment
2/4/2002
None
H.C.
No.Comment
2/11/2002
None
H.C.
No Comment
2/18/2002
None
..H.C.
No Comment
2/25/2002
None
H.C.
No Comment
3/4/2002
None
H.C.
No Comment
3/11/2002
None
H.C.
No Comment
3/18/2002
None
H.C.
No Comment
3/25/2002
None
H.C.
No Comment
4/1/2002
None
H.C.
No Comment
4/8/2002
None
H.C.
No Comment
4/16/2002
None
H.C.
No Comment
4/24/2002
None
H.C.
No Comment
4/30/2002
None
H.C.
No Comment
5/6/2002
None
H.C.
No Comment
5/11/2002
NIA
H.C.
OK - Observed during rain event.
5/13/2002
None
H.C.
No Comment
5/20/2002
None
H.C.
No Comment
5/29/2002
None
H.C.
No Comment
6/4/2002
None
H.C.
No Comment
6/11/2002
None
H.C.
No Comment
6/17/2002
None
H.C.
No Comment
6/24/2002
None
H.C.
No Comment
7/3/2002
None
H.C.
No Comment
7/8/2002
None
H.C.
No Comment
7/15/2002
None
H.C.
No Comment
7/22/2002
None
H.C.
No Comment
7/29/2002
None
H.C.
No Comment
8/5/2002
None
H.C.
No Comment
8/12/2002
None
H.C.
No Comment
81119?2002
None
H.C.
No Comment
8/28/2002
-4"
H.C.
OK - Observed during rain event.
9/3/2002
None
H.C.
No Comment
9/9/2002
None
H.C.-
No Comment
9/16/2002
None
H.C.
No Comment
9/23/2002
None
H.C.
No Comment
9/30/2002
None
H.C.
No Comment
10l7/2002
None
H.C.
No Comment
10/15/2002
None
H.C.
No Comment
10/21/2002
None
N.C.
No Comment
10/28/2002
None
H.C.
No Comment
11/5/2002
None
H.C.
No Comment
11/12/2002
None
H.C.
No Comment
11/18/2002
None
H.C.
No Comment
11/25/2002
None
H.C.
No Comment
12/4/2002
None
H.C.
No Comment

12/10/2002
None
H.C.
No Comment
12/13/2002
NIA
H.C.
Some off color of water. Observed during rain event.
12/17/2002
None
H.C.
No Comment
12/23/2002
None
H.C.
No Comment
12/30/2002
None
H.C.
No Comment
1/6/2003
None
H.C.
No Comment
1/14/2003
None
H.C.
No Comment
1/20/2003
None
H.C.
No Comment
1/28/2003
None
H.C.
No Comment
2/6/2003
None
H.C.
No Comment
2/11/2003
None
H.C.
No Comment
2/18/2003
None
H.C.
No Comment
2/24/2003
None
H.C.
No Comment
3/4/2003
None
H.C.
No Comment
3/11/2003
None
H.C.
No Comment
3/17/2003
None
H.C.
No Comment
3/25/2003
None
H.C.
No Comment
4/3/2003
None
H.C.
No Comment
4/7/2003
None
H.C.
No Comment
4/14/2003
None
H.C.
No Comment
4/22/2003
None
H.C.
No Comment
4/29/2003
None
H.C.
No Comment
5/5/2003
None
H.C.
No Comment
5/12/2003
None
N.C.
No Comment
5/12/2003
None
H.C.
No Comment
5/27/2003
None
H.C.
No Comment
5/29/2003
-2"
H.C.
Morning, heayy rain, some off color of water.
6/3/2003
None.
H.C.
No Comment
9/18/2003
NIA
H.C.
Heavy rain, some cloudy water.
9/23/2003
N/A
H.C.
Heayy rain, water clear.
10/10/2003
None
H.C.
Some runoff. Clear water.
10/20/2003
None
H.C.
No Comment
2/12/2004
--1"
H.C.
Some mud - OK.
2/25/2004
w1" - 2"
H.C.
Some off color_
5/1/2004
--4"
H.C.
Heavy rain, some off color of water.
6/4/2004
None
H.C.
No Comment
7/5/2004
None.
H.C.
No Comment
8/13/2004
H.C.
Heavy rain,some off color over 8" total. 8113-8/14
8/14/2004
8"
H.C.
Heavy rain, some off oolor
10/25/2004
None
H.C.
No Comment
5/23/2005
2" -
H.C.
Heavy rain 2" some off color
7/612005
None
H.C.
No Comment
8/12/2005
None
H.C.
No Comment
10/20/2005
None
H.C.
No Comment
1/16/2006
None
H.C.
No Comment
4/5/2006
None
H.C.
No Comment .
8/31/2006 .
10-12"
H.C.
Hem rain. Some off color. 10-12" rain
9/14/2006
2-4"
H.C.
Heavy rain. Some off color.
10/15/2006
None
H.C.
No Comment
12/20/2006
None
H.C.
No Comment
12/1212007-
None
H.C.
No Comment
3/15/2007
None
H.C.
No Comment
8/20/2007
None
H.C.
No Comment

11/15/2007
None
H.C.
No -Comment
12/16/2007
NIA
H.C.
Heavy Rain. Stormwater QT. Sample
2/21/2008
NIA
H.C.
Stormwater Qt. Sample
6/23/2008
NIA
H.C.
Rain event. Stormwater Qt. Sam le.
9/10/2008
NIA
H.C.
Rain event. StomTwater Qt. Sample.
11/13/2008
NIA
H.C.
Stormwater Qt. Sample
2/18/2009
NIA
H.C.
Stormwater Qt. Sample
6/9/2009
NIA
H.C.
Stormwater Qt. Sample
9/22/2009
NIA
H.C.
Stormwater Qt. Sample
11/10/2009
N/A
H.C:
Stormwater Qt. Sample
1/12/2010
NIA
H.C.
Stormwater Qt. Sample
2/18/2010
N/A
Chuck Bullard C.B.
Changed out 2 booms. Stormwater Qt. Sample
5/25/2010
NIA
C.B.
Rain
7/14/2010
NIA
C.B.
Rain
12/14/2010
3.5"
C.B.
No Comment
11/17/2011
4"
C.B.
No Comment
4/5/2011
0.25"
C.B.
No Comment
9/27/2011
.75"
C.B.
jNo,
Sample
1/11/2012
1"
C.B.
Comment

STORMWATER MANAGEMENT AND BMP SUMMARY
2.3 Secondary Containment
Concrete block secondary containment walls are provided around the West Tank Farm,
Production Pad Area, Utility Area (tanks) and South tank Farm. Each of the four
containment areas on these pads are equipped with a sump pit and pump. The Railside
Tank Farm does have concrete block containment but without the sump pump system.
Procedures for releasing stormwater accumulating in these areas will be described in the
Spill Prevention and Response section below.
2.4 Best Management Practices (BMPs)
A Stormwater Management system has been designed, permitted and is currently under
construction. Stormwater will be conveyed through swales to a wet detention pond.
After drawdown, runoff will be conveyed by outlet spreader through a vegetated filter
strip.
There is a stormwater pond that is currently in use on site. The pond is designed to catch
runnoff from the ground's natural slope.
Stormwater collected from ADI's tank areas and sampled to determine if it is to be
released or must be treated. The following chart shows the requirements for water to be
discharged.
2.5 Benchmark Values for Analytical Monitoring
Dischar a Characteristics
Units
Benchmark
Biological Oxygen Demand, 5 day
m /L
30
Chemical ORgen Demand
m 1L
120
Total K'eldahl Nitrogen
m IL
20
Oil and Grease
m IL
30
H
Standard
4.3-9
Total Suspended Solids
m IL
100
Iso ro al Alcohol
m /L
4,300
Methanol
m /L
7,700
Ethanol
m IL
3,900
T-Butyl Alcohol
rrm IL
3,200
If sampled stormwater that does not meet the standards listed in their stormwater permit,
then it is pumped -to Tank 50 where it is enters a cleaning process. The stormwater is air

stripped to remove volatilds, then it is run through a sand filter. 'At this point it is ready to
be retested and sent to POTW if below the discharge limits.
Stormwater that meets the stated discharge limits'is discharged through a Swale that nuns
into the Cartwheel Branch Creek.
Inspection of Stormwater Conveyances
The following procedure will be used to limit or prevent erosion associated with
stormwater systems.
A) 1. Periodic inspections (semi-annual minimum) will be performed on the entire
stormwater system in conjunction with log sheets
2. A Log sheet will contain:
Date and time
Signature of inspector
Work order number for any required repairs
Work required under remarks
Work completed date
3. These records will be kept in the main control room for a period of five years.
B) All tanks and equipment will be inspected during the 6 A.M. daily inventory for any
signs of leakage. Any leaks detected will be reported as outlined in the spill
prevention/response program in this manual.
C) A preventative maintenance program is outlined in the American Distillation, Inc.
Process Safety Management (PSM) manual for process equipment reliability.

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
March 19, 2007
American Distillation, Inc.
Attn: Mr. Croom
1690 NE Royster Road
Leland, NC 28451
SUBJECT: Compliance Evaluation Inspection
American Distillation
NCS000244/NCG500148
Brunswick
Dear Mr. Croom:
On March 15, 2007, Ken Pickle, Kelly Johnson and Linda Willis, of the Division of Water Quality
Central and Wilmington Regional Offices, performed an inspection of the subject facility. As part of the
inspection, a tour of your facility was conducted. All observations and recommendations are noted in
the (Summary of findings/comments) of this inspection report. Remember, it is our goal to insure the
quality of the surface waters of this State.
Please review the attached report. If you or your staff have any questions, do not hesitate to
contact me at 796-7343.
Sincerely,
Linda Willis
Environmental Engineer
Wilmington Regional Office
Enclosures
cc: WiRO files (Brunswick stormwater inspection file)(rr�
Central fles(W ariz)
'RO/DWQ Stormwater Compliance Files
Stormwater Permitting Unit
NPS and Compliance Oversight
N( Car+o " a
aaturrr�
North Carolina Division of Water Quality 127 Cardmal Drive Extension Wilmington, NC 28405 Phone [phone] Customer Service
Internet: www.ncwaterquality,org Fax [phone]
An Equal Opportun4lAffirmative Aclion Employer— 50% Recycled110% Post Consumer Paper

,f
®��' NC DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
NCDENR INDUSTRIAL STORM WATER INSPECTION FORM
WII_MINGTON REGIONAL OFFICE
Facility: American Distillation
Date: 03/15/2007
Location Address: 1690 NE Royster Rd, Leland NC 28451
COC ##: NCS000244
NCG500148
Contact Name: Hugh Croom
Phone Number: 910-371-0993
Contact Mailing Address: See above
County: Brunswick
Directions:
From Leland take Old Mill Rd to Navassa, turn right onto Royster, go to gate push button, request entry
x
Routine Compliance Inspection
Rescission Request
Complaint Investigation
x
Other — Explain Permit Renewal
A.
. STORM WATER POLLUTION PREVENTIONPLAN
Yes
No
NIA
Comments
1.
Is a copy of the signed and certified SWPPP at the facility?
x
Plan needs updating with
2.
Does the facility's SWPPP address the minimum BMP requirements?
better BMPs to address
issues stated in cover
letter and.inspection
report.
No amendments appear
3.
Are amendments to the SWPPP clearly documented?
x
to have been done to
plan and the annual
review has not been
documented.
Plan needs some
4.
Is the current SWPPP complete?
x
improvement
BX
WE] ICLUIPMENTr �'-L` zY�
E Enlll
Yes
No
NIA
1.
Were the vehicle/equipment maintenance areas inspected?
x
2.
Are vehicle/machinery leaks and drips properly managed?
x
3.
Is vehicle/equipment washing done in a designed area so that wash water
x
can be properly managed?
Tanker pad does not
4.
Was the vehicle fueling area inspected?
x
5..
Are vehicle maintenance activities kept indoors?
x
6.
Were the vehicle/equipment storage areas inspected?
x
provide secondary
containment. If tankers
are empty, no problem
If storing recyclable
product, secondary
containment should be
provided
7.
Are current BMPs in vehicle/equipment/fueling areas adequate?
x
C
WASTEMANAGEMENT Fes; �� s " `
Yes
No
NIA
ry y H�
1.
Are containers for temporary storage of wastes labeled?
x
2.
Are waste materials recycled?
x
3.
Are hazardous wastes properly handled and disposed oV
x

4.
Is pr6cessed debris removed regularly?
x
Secondary containment
5.
is there secondary containment for liquid wastes?
x
is not provided for
storage of hazardous
substances in 55 gallon
drums. Large tanks
located outside the
secondary containment
(near small stormwater
containment pond) had
no locked valves.
Need to modify and
6.
Are current waste management BMPs adequate?
x
implement additional
BMPs.
See previous comments
D
MATERIALSTORAGE:'
Yes
No
NIA
L
Are there appropriate BMPs for outdoor storage of raw materials,
x
products, and byproducts?
See previous comments
See previous comments
2.
Are containers for chemical substances labeled?
x
3.
Is there secondary containment for liquid storage?
x
4.
Are current BMPs in material storage areas adequate?
x
E:`
SPIU, CONTROL .
Yes
No
NIA
Comments
1.
Are there procedures for spill response and cleanup?
x
2.
Are appropriate spill containment and cleanup materials kept on -site and
x
in convenient locations?
3.
Are used absorbent materials disposed of in a tirrmely manner?
x
4.
Are current spill BMPs adequate?
x
Yes
No
NIA
1.
Are unpaved.outdoor areas protected from water/wind erosion?
x
2.
Are drainage ditches or the areas around the outfalls free of erosion?
x
3.
Do implemented BMPs appear effective in controlling erosion?
x
G
4 NON STORM WATER iVIANAGEMENT� x ;
Yes
No
NIA
>3,
J. ., . x ,r :
One unidentified outfall
1.
Have all illicit water discharges been eliminated or permitted?
x
exists at the west end of
the large stomrwater
containment pond
controlled by a release
valvedirectly to the
adjacent wetlands
2.
Are BMPs for authorized non -storm water discharges properly
x
implemented?
3.
Are current BMPs adequate for management of authorized non -storm
x
water discharges?
� :
S *- -.; Y - ; : .ax"s ,.:z�,ry�s+x ..� "", �s --•-,'"'��,�.,�..-r:.r,. x'
A
4PROCESS WASTER'ATER CONTROLSAND MONITORING';
t • ,-_
Yes
No
NIA
Regional Office requests
1,
Are wastewater treatment facilities properly maintained?
x
2.
Has monitoring been done?
x
the quantitative and
qualitative monitoring
reports since 2004 to

present time.
I
�, .-
.STREAM OBSERVATION/IMPA= GTS 'a
Yes
NO
NIA
+,.�_ Ala• .�!
Ditches are used as the
1.
Were there any stream impacts?
x
conveyance in most
instances with the
exception of the release
valve at the west end of
large stormwater
containment pond.
There was a small
2-
Were field parameters taken for pH or DO?
x
3.
Were there any stream standard violations/
x
amount of petroleum oil
in the stormwater ditch.
Representatives asked
Mr. Croom to be sure to
have someone put an
absorbent boom in the
ditch to remove the oil.
4.
Were there excessive solids in the stream?
x
5.
Were pictures taken?
x
5.
Were samples taken?
x
1 -
J
SUMLMARY / ADDITIONACOMMENTS
1. Please put locks on all large tanks outside of secondary containment immediately. 2. Provide the Regional Office with a copy of
all monitoring reports since 2004 for review. 3. Valve leading to wetlands located at the west end of the large stormwater retention
pond needs to be identified as an outfall and included on the site reap. Monitoring will be required prior to any release. 4. Adjacent
to the Stormwater swale is an area of old equipment and metal parts. It appeared there was a spill of petroleum products to the
ground which requires proper clean up and disposal. 5. There was a discharge of oil to the swale in the proximity of the petroleum
spill on the ground. Division Representative asked that it be cleaned up from the swale immediately using booms, please verify that
this has been done. b. Many bulk tanks are used on site for storage of product to be tolled and final product. The tanks in some
cases are in extremely corroded condition. Mr. Croom indicated the tanks are inspected and the structural integrity monitored on a
regular basis. Please include the dates of inspections and the results of the inspections in the SWPPP amendments each time this
activity is conducted. Comment on the actions taken as a result of the recommendations from those inspections. 7.—Divi non
dkgm sentatives=re twn&-d-that-analytical=rmnitonng�of-storniwgter°in-clude,anslyses-that,demonstraiethe absence`o€organics-
that�canacat�be:detected.by=site:(sheen,Soam, c� olor,.miscibility}.prier=to:any--release from:secondary:enntain=uv.smxtures!in�
accordance=with Tablecl:�- Analytical Monitoring requirements. Results should be compared to the benchmark cutoffs given in Table
3 of your new permit. Should values exceed the benchmark, the permittee should identify an appropriate disposal option rather than
discharge to surface waters of the State. Mr. Croom was informed that the upcoming benchmarks in the renewed permit should
serve as an indicator for concern should stormwater analytical results exceed those levels. Division Representatives discussed the
high concentrations present in the discharges'in July and October of 2003, indicating this was an example of a slug of organics that
had been discharged with stormwater. Those levels indicate*Vili accuued;but.water,documented-in,the�qualltative:urspsetions:
' supports:the.request.ta_ranai the-contentt%f-1 e-s6C6ndafy containment-structur se p o�'to-any~release. It is possible
that the organics'present in that stormwater discharge may have not been obvious by visual inspection alone. 8. The stormwater
pollution prevention plan also requires an SPRP (Spill Prevention and Response Plan) component identifying potential pollutant
sources based upon a materials inventory. That was not seen in the SPRP. 9. Hazardous waste storage area needs to have
secondary containment. Drum storage area needs secondary containment due to the hazardous nature of the materials and is a
requirement of the SPRP. 10. Distillation process wastewater is sent to Tank 23 for recycle if contaminants are too high to
discharge or sent to the cooling towers and boilers for reuse- The blowdown is sent to the small stormwater pond.
Boiler Blowdown is sent to the small stormwater pond and reused in the cooling towers. The Wilmington Regional Office requests
that NCG500148 be consolidated under NCS000255 and monitored in accordance with that permit since the source water is of
questionable quality and pass through and concentration of contaminants may pose problems. It is also co mingled with stormwater.
The NCG500000 permit does not provide stringent enough monitoring to ensure protection of surface waters.
..,you,�r yi ai-. v.,�.:zja �7 i i`i� �r�,'i°:,7. " fi4� ai YF•°Y r ;S rt f
RATING {CIRCLE ONE tYt x
KLEVEL ..�o .._. `s'r{y
1., .uk'� _ M:,' a•, y ,
1.
Indusry in substantial compliance
r2m I
June 2007
Minor deficiencies noted. Revist scheduled for

3. Major- deficiencies or discharges noted and require prompt correction. Revisit scheduled for (date).
4. Critical deficiencies or discharges noted.and require immediate correction. Revisit scheduled for (date).
5. Rescission is appropriate.
6. Rescission is not appropriate. Please renew permit in accordance with the draft prepared March
March 5, 2007 and include the boiler blowdown and cooling tower condensate into 19, 2007
NCS000244, eliminating NCG500148. (Note: permit ## is NCS000244)
- -Logged by:_
Inspected by Linda Willis
L. Include a Map of the facility. This drawing should depict the building, parking, process, and storage areas.
If you do not have a map, draw one or request that the facility provide you one in your written
correspondence.
Map included
M. Develop a Vicinity Map for the file.
Map included
N. Identify all records that were reviewed.
Qualitative records through July 2004 (no notice of visible contaminants) Records should show visual
observations for the month of March 2007, in lieu of the findings on site during the inspection.
Quantitative analyses shows significant contamination left the site via stormwater discharge on in July and
October of 2003.
O. Explain how Secondary Containment is being used and whether these measures are bring properly
maintained. (Did you observe that the secondary containment had release valves (were they open, locked
etc.), was there water, waste product, sheen, etc observed within the secondary containment area? Explain
your observations]
No wastewater within containment areas. Several large bulk tanks outside of the secondary containment
areas had product or waste material in them with no locking mechanisms. There were indications of past
spills -on the tank pad -areas outside the containment area. The tanks located near the small stormwater
containment pond did not have a surface graded towards a sump that could isolate a spill. If a spill were to
occur it would make it to sandy soil and if large enough to the stormwater ditch.
P. House keeping and best management practices (maintenance of BMPs) status.
Fairly good, however drummed storage areas need secondary containment considering the hazardous nature
of the materials. The hazardous waste storage pad requires secondary containment.
Q. Identify outfalls and receiving waters. List any observation or concerns.
One outfall•near the large stormwater containment pond needs to be identified in the plan.and in the permit.
R. Take digital photographs,to support staff report observations and to provide assistance to future inspectors).
No pictures were taken during this visit.
Logged by: Inspector: Linda Willis WiRO, Ken Pickle
and Kelly Johnson CO

,9Cl •IEtR;o t71,!,R IrI•,-Le:l:anri t,Joifh .,arr�llri:l
-_N__-- --_
',� 4••, - r•`}` c, 'EI. � fr. �� .,,.r �,tr Sys 'I —. .15 . -. . — / / �.
ic
,�� •���I �!'-;, � _ ��E77 E�Ivti::'T�c.tt[,`uiuJiu�� .r � � �� ___
�_, r ln,ayc _ 204� E`luib H 11lu +:1 CoulltY NC ( L
PUinter. 34= 1� 4 5M".W 73 ft.S�ir4G'25`4 ri II11III1II Z Qv E_lt2,
0 13 It-

Figure Project Tide: ���,�jj �+
American Distillation, Inc. Site Plan Yi'ALT4N LVGMEERING
Date: 11/15/99 1 Scale: i" = 60' Drawn by: RMW Project #7 95002
0 30' 60' 120'
LEaEN
.W. Eye wash
.S. Sa(elyy Shower
E- Fire Extin wisher
Drainage Outfoll
MAP BASED ON PROPERTY SURVEY BY
STUART Y. BENSON & ASSOC.
Stormwoter Swales
DONALD SNEEDEN
-PPS
ZL vr-Z
N
i J
5.0acres ti
a i`1QtaToti Gas �- '
Fas��,ent �I
! Vqks
h!�Tan�lSrEQAti SUQ� -j2•• Fii oHlgr,k wa
Revision Date: 7/08/04
Al
e['4GNE7J'C �
R
FII('>H f l")F: S RVICF ('0., INC.
0
BRUNSWICK
A m
COUNTY
w �
pp
I
0 C?
N
3
ro _
U
O
r—

North Carolina Department of Environmental Quality
Pat McCrory Donald R. van der Vaas
Governor Secretary
October 28, 2015
Mr. Andy Simmons, President
American Distillation Company, Inc.
P.O. Box 400
Leland, NC 28451
SUBJECT: Compliance Evaluation Inspection — NPDES Stormwater Permit NCS000244
American Distillation
Brunswick County
Dear Mr. Simmons:
On October 23, 2015, Steve Pusey of the Division of Energy, Mineral and Land Resources, Land Quality
Section, Wilmington Regional office, performed an inspection of the.subject facility. This inspection
covered the requirements of the Individual Stormwater permit NCS000244. Since the construction of the
new State stormwater pond, the site has changed significantly; therefore many features have been revised on
the site plan.
In reference to the Individual Stormwater Permit NCS000244, the following items are required and have
been accomplished:
1. At least two (2) internal sample points are needed in order to effectively monitor the stormwater
discharge; one for the eastern drainage and one for the western drainage area. Three (3) sampling
points are noted on the site plan. We recommend that a shutoff valve and a method for bypassing the
stormwater for further treatment be supplied for each of these sampling points. Valves should be
normally locked and opened only after water is tested and determined to meet the benchmarks shown
in the permit. A separate single sample point is required for the DMR report, located either at the
pond outlet structure or at the outlet.pipe flared end section (FES). By sampling from all these
points, you will be able to determine if the BMPs are working effectively.
2. The location on the vicinity map references the main entrance gate and is noted on the map of the
facility.
The site plan has been updated to include the completed State stormwater pond and its associated
inlet / outlet connections and vegetative filter strip. The plan also shows the drainage ditch and
piping that connects to the filter strip, and it shows the locations of all sample points, labeled
appropriately. Under no circumstances should wastewater be allowed to enter the State stormwater
pond. Note that any resulting unpermitted discharge would be a violation of State Stormwater
Permit SW8 930501 per 15A North Carolina Administrative Code (NCAC) 2H .1003, and it would
require a wastewater permit. As stated above in item 1, there are three (3) internal sample points
noted on the site plan to monitor the stormwater discharge before it gets to the pond.
4. The berm along west side of property and the adjacent area has been graded and seeded.
5. The area where the old stormwater containment pond was located (behind old boiler house) was
graded and seeded. This area is adjacent to a sampling location.
6. Riprap has been added at the western inlet pipe in the stormwater pond and in the swale on the other
side of the pond berm.
7. A temporary pipe near the yard inlet at middle of drainage ditch has been removed.
Division of Energy, Mineral, and Land Resources
Land Quality Section — Wilmington Regional Office
127 Cardinal Drive Extension, Wilmington, North Carolina 28405
[phone] f Fak: [phone] - Internet: httlx0ortal.nedemoratweblfrl
An Fniml nnnnehinifv % AffinnaHve Anlinn Frmmnvar — Made in n9il by rpi-MFid nay

S. Wherever feasible, above ground storage tanks should be surrounded by some type of physical
containment (impervious dike, berm, or concrete retaining structure) to prevent runoff in the event of
a failure or leaking transfer valve. Note that any resulting unpermitted discharge would be a
violation of the Clean Water Act.
9. Qualitative monitoring reports should be provided on current DEMLR forms available on our
website at htt�/(portal.nedenr.org/web/lr/npdes-stormwater.
10. Both qualitative and analytical monitoring reports are to be performed quarterly.
For further details, please reference the attached inspection report. if you or your staff has any questions,
please do not hesitate to contact Steve Pusey or myself 910-796-7215.
Sincerely,
r\ r
For Dan Sam's, FM` "
Regional Supervisor
DEMLR, Wilmington Office
For Tracy Davis, P.E., Director
Division of Energy, Mineral and Land Resources
Attachments:
• Compliance Inspection Report— RIMS
DS/sp: G:1LRILQINPDES\BrunswickWCS-0002441 Cover Letter 1023 NCS 000244
cc: Mark Walton — Walton Engineering
WIRO files (Brunswick stormwater inspection file)
Bradley Bennett — Raleigh office
Page 2 of 2

,ON
6
Compliance Inspection Report
Permit: NCS000244 Effective: 01/01/15 Expiration: 1213111 B Owner: American Distillation Inc
SOC: Effective: Expiration: Facility: American Distillation - Navassa
County: Brunswick 1690 Royster Rd NE
Region: Wilmington
Leland NC 28451
Contact Person: Andrew J Simmons Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits.
Inspection Date: 10/23/2015
Primary Inspector: Steven G Pusey
Secondary Inspector(s):
Entry Time: 11:00AIVI
Reason for Inspection: Follow-up
Permit Inspection Type: Slormwater Discharge, Individual
Facility Status: ® Compliant Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Certification:
Phone:
Exit Time: 12:30PM
Phone:
inspection Type: Compliance Evaluation
Page: 1

permit; NCS000244 Owner - Facility: American Distillation Inc /+
Inspection Date: 1 DI23/2015 Inspection Type: Compliance Evaluation . Reason for Visit: Follow-up
Inspection Summary:
This site meets the minimum requirements for compliance with the permit.
Page: 2

I�'4
parMit: NCS000244
a
Owner -Facility: American Distillation Inc
Inspection Date: 10/23/2015 Inspection Type : Compliance Evaluation Reason for Visit 1`011ow-up
Stormwater Pollution Prevention Plan
Y No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
i ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
® ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices'?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
E ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ ❑ ❑ 0
# Has the facility evaluated feasible alternatives to current practices?
®❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
N ❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
. ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
e ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
❑ ❑ ❑
# Is the Plan reviewed and updated annually?-
e ❑ ❑ ❑
# Does the Plan include a Stormwater Facility inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
® ❑ EY ❑
Comment:
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ® ❑ ❑ ❑
Comment: This is done on a quarterly basis.
Analytical Monitoring — n Yes No NA NE
Has the facility conducted its Analytical monitoring? ® ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ® ❑
Comment:
Permit and Outfalls
- Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ® ❑ ❑ ❑
# Were all outfalls observed during the inspection? ® ❑ ❑ ❑
# If the facility has representative outtall status, is it properly documented by the Division? ❑ ❑ ® ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ® ❑
Comment:
Page: 3

WALToArENGLAEER�iN-G-
May 15'', 2015
ATTN: Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
To Whom 1t May Concern,
Enclosed is the quarterly discharge report for American. Distillation Inc. for the I" quarter of
2015.
On the original sampling date (03/19/15) samples were incorrectly taken directly from the
stormwater pond resulting in very high levels of BOD and COD. Therefore, an additional
sample was taken from the correct outfall date on the later date (04/09/15). This was the first
sampling event since the new stormwater pond and system has been in place, future sampling
events will not have this problem.
If you have any questions, please call me at 910-259-4800.
Sincerely,
Nkww�
Allen Thornton
Len" D WQ. 051515
Tel: [phone] PO Box 895, Burgaw, North Carolina,.28425 Fax: [phone]

STORMWATER DISCHARGE OUTFALL (SOO)
MONITORING REPORT
Permit Number NCS 000 Z 4 Lf SAMPLES COLLECTED DURING CALENDAR YEAR: So 15—
T (This monitoring report shall be received by the Division no.later than 30 days from
the date the facility receives the sampling results from the laboratory.)
FACILITY NAME - A_ M -r( CAXA p S j 1 7 COUNTY b rynsw ;CSC _
PERSON COLLECTING SAMPLE(S) W1 .yr1non S,2,4G1, F� PHONE NO. C5 o) . :y ^ 09 9 3
CERTIFIED LABORATORY(S) Env it,oAg e,-6.,\
SIGNATURE OF PERMITTEE OR DESIGNEE
REOU -Q ON PACE 2.
Part A: Specific Monitoring Requirements
� i
is
'Sample
11 1
W60A
I
Does this facility perform Vehicle Maintenance.Activities using more than 55 gallons of new motor oil per month? _ yes . _no
(if yes, complete Part B) ,
Part B: Vehicle Maintenance Activity Monitoring Requirements
Outia!! '
'No: '.
:'Date,
`Sautple
,Collided
d050,
,00556:
00530
00400.
''.T6tid'FIOW' • '
zfispplienble): `,Rahn
4Tbtal
fill
°:011'&:Grease.
'(!Lapel.)
Non -polar
:O&Gf PH
(Method 1664
:SGT-HEM), if
a I.
Total
Suspended
Solids
; pH
New Motor
Oil'Usage
:moldines
MG
allmo
Form SW11-247, last revised 21212012
see- C-0j4.r Ve-}+ec - f�Sa+�+�l�� fi-�ar CCop Page Iof2

STORMWATER DISC.RARCF. OUTFALL (SDO)
MONITORING REPORT
Permit Nnmlber NCS 0 0 0 12-14 (A SAMPLES co1.LxwmD i RIN(., CALENDAR YEAR:
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receiven the sampling results from the laboratory.)
FACILITY NAME _ A M t f l 64 ^
PERSON COLLECTING SAMPLE(S)
CERTIFIED LABORATORY(S) Lab #
I-ab # _
-Part A: Specific Monitoring Requirements
COUNTY
PHONE NO.
SIGNATUR&OF PER.MITTEE OR DESIGNEE
AEOUJRED ON, PAG 2.
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new Hector oil per cox+nth? _ yes _ _,1eo
(if yes, complete Part B)
Part.'R: Vehicle Maintenance Activity Monitoring Requirements
-an#lall
No..
:Date: ;'
;Sample, '
Colleciefl
` U5q
:00586
00530.
00400
TbUFFloW
(lf;applicable); ::Rainfall'
•':Tbtal'•
'.Oil & Grense
iilappl.)
:'Non -polar
:0&GfJ'PII'
(Method`1664
a 1
Total
,Suspended
Solids
PH'
Ni%r.Motor
0I1 Usage
:.dsold r.
` it
hidhes:
l[t 11
y
mg,ll
11111t
a111"o;
Form SWU-247, Iasi revised212/2012
Page I of 2

STORM EVENT CHARACTERISTICS:
Date C i Q r 1 S
r t
Total Event Precipitation (inches):
Event Duration (hours): _ _,
(only if applicnhte —see Fermin:)
(if more than one storm event was sampled)
Date __� y l c�a /It:;
Total Even Precipitation (inches):
0. L4
Event Duration (hours): _R
_
(unly it"nppiicnhle-- ice permit.)
Mail Original and one copy to:
O; V%S+a n
Attn: Central files
1617 Mnil Service tenter
Raleigh, Noah Carolina 27(i99-1b17
a�C ls'f r (%-,,,.rtLQ.S
"I certify, under penalty of law, that this document and all nitachments were prepared under my direction or supervision in accordance with n
system designed to assure that qualified lie rsonnel properly gather and evaluate the InI'minatIon snIon itted. Rased on my inquiry of the person
or poruous who manage the system, or those persons directly responsible for gathrrinp the information, the inforinntion submitted is, to the
best of my knowledge and belief, true, necurntc, and complete. I am aware that there Ore significant pennitle.9 for submitting false Information,
Including theyossibility of fines and imprisonment for knowing violations."
4 �- �Aj 4-a -ice
(signature of rermittee) i Date)
Form SWU-247, last rev4sed 2122012
Page 2 of 2

Environmental Chemists, Inc.
"M WmdnnM way - Wi7mir;gtM NC 28405
[phone] (Ub) - [phone] (Fax)
710 Bowserhmn Road * Manieo, NC 27954
[phone]
ANALYTICAl:B CONSULTING
CHEMISTS NCDENR DWQ CQtTIMATE 444. MS CERMCAT$ 937M
American Distillation Date of Report: Apr 09, 2015
1690 Royster Road Customer PO M
Leland NC 28451 Customer ID: 09010037
Attention: Darlene Wells Report #: 2015-03452
Project ID: Stormwater
Lab ID Sample ID: Collect DateMme Mabix Sampled by
15-07960 Site: Stormv4ater "3/20/2015 9:00 AM Water . WES
Test
Method
Results Date Analyzed
Oil & Grease (O&G)
EPA 1864 VM SM= Gel
<5 mg/L
03124/2015
Total K4eldahl Nitrogen (TKN)
SPA351.2
14.8mg/L
04/07/2015
Residue Suspended (TSS)
SM25Q °
15.6 mg/L
03/23/2016
Temperature
SM2550 B
65.0 C
03/20/2015
pH
Sty 455oo H B
8.11 units
03/27/2015
BOD
spa szo s
>73 mg1L
03/20/2015
M QC reqtkenmls tar DO depletion not met.
COD
see &ZW
1360 m.a
03/25/2015
Ethanol.
sw B46 method 8015
35.7 mg/L
03/24/2015
Isopropyl alcohol
SW 846 method sass
45.7 mg/L
03/24/2015
Methanol
SW 846 nuMt od 8015
27.3 mg/L
03/24/2015
Tert-butyl alcohol
SW 846 meowd 8015
83.6 mg/L
03/24/2015
Lab ID Sample ID:
Coiled DatelTime
matrix Sampled by
15-07960A Site: Stomtwater
3/2012015 9:00 AM
Water WES
Test Method
BO D SIM 5210 8
Reanalyzed outside of holding thee.
Comment:
Reviewed by:'
Results Date. Analyzed
310 mg/L 04/01/2015
Report#:: 2D154)3452 Page t of 1

Analyfical 8 Consulting Chemists
ENVIRONMENTAL CHEMISTS, INC �Windmill 39z Wilmington, .�;
NCDENR: DWO CERTIFICATION # 94 NCDHHS: DL8 CERTIFICATION # 3T729 Into&nv1ronmentu1chwnhM com
COLLECTION AND CHAIN OF CUSTODY "
CLIENT.%
PROJECT NAME:
REPORT NO: is - y
ADDRESS: (2. Q b ,
CONTACT NAME:
PO NO:
11) �►
REPORT TO:
PHONE/FAX: 10-37J-D99-5
COPYTO: harbme WIrL a
emall:c tgdl e.,G(2natl r►.)c1 id*bilk
Samnied Bv: SAMPLF TYPE: I a lnfluent_ E a Effluant W rrWall. ST a Stream. 30 b Sall. SL Sludaa. Other:
Sample Identification
MM
M
ANALYSIS REQUESTED
�==�■ate■�wn���
Relinquished ky:
IMM
Delivered
Comments:
Time:_/�_��

Environmental Chemists, Inc,
66M will Way, wmfrW� NC 28405 • 910.392.0223 Lab • 910.392.4424 Fax
® 710 Bowserbown React Manteo, NC 279% • 252.473.5702 Lab /Fax
25rAWilmirg FUghway, jarksonvBle, NC 28W • 910.3475843 Lab/Fax
ANALYTICAL & CONWLTiNG CHEMISTS info(a miroamentaicbemismeom
American Distillation
Date of Report:
Apr 23, 2015
1690 Royster Road
Customer PO #:
Leland NC 28451
Customer ID:
09010037
Attention: Darlene Wells
Report #:
20154 317
Project ID: Storrrtwater
Lab ID Sample ID:
Collect Date!*[* Matrix
Sampled by
15-09901 Site: Stommader
4WO15 12.30 PM Water
Darlene Wells
Test
Method
BOD SM 5210 8
COD see 5=D
Comment
Reviewed by:
Results Date Analyzed
7 mg1L W10/2015
93 rng/L 04/14/2015
Reporter 2015-04317 Poo, Or1

4ow ENVIRONMENTAL CHEMISTS, INC �,' �.9"° ;
Anal I & CwMddng ChaMISW NCDENR: DWO CERMCATION S 94 NCOHNS: DLS CERTIRCATION S 371 bvfo@mvlronnumbtWhwmkftxm
AMMUCAN IDISTTLL4TTON, INC.
'PO BOX 400
LELAND, NC 28451
COLLECTION AND CHAIN OF CUSTODY
NAME:
NO: 1 —
�o
ELM
��wpi
9 10 eW+:.
Towipersture
Deuvemd By
Comments:

AMERICAN' DISTILLATION INC.
1690 NE Royster Road
Leland, NC 28451
March 19, 2015
Walton Engineering
PO Box.895
Burgaw, NC 28425
Subject: AD[ Stormwater Permit 11 Quarter
Mr. Walton,
Light Rain started around noon on 3.19-15. Run off started at 6.00pm on 3-19-15, Rain total at this time
was .06" sample taken at 9:60am on 3-20-15.
Total rain from 3-19-15'to lam 3-20-15 am was .54"
Sincerely,

NC®EHR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
January 14, 2015
Mr. Andy Simmons, President
American Distillation Company, Inc.
P.O. Box 400
Leland, NC 28451
SUBJECT: Compliance Evaluation Inspection - NPDES Stormwater Permit NCS000244
American Distillation
Brunswick. County
Dear Mr. Simmons:
On January 7, 2015, Steve Pusey of the Division of Energy, Mineral and Land Resources, Land Quality Section,
Wilmington Regional office, performed an inspection of the subject facility. This inspection covered the
requirements of the Individual Stormwater permit NCS000244. Due to the issuance of a renewed permit effective
Jan. 1, 2015, an amendment to the SWPPP is due within 90 days or by the end of March, 2015. In addition, since
the construction of the new State stormwater pond, the site is changing significantly; therefore many features must
be revised on the site plan.
In reference to the Individual Stormwater Permit NCS000244, the following items should be addressed to prevent
problems in the future:
,/I All stormwater must be tested and meet approved pollutant limits before being discharged to waters of the
State. It appears that two (2) sample points are needed in order to effectively monitor the stormwater
discharge; one for the eastern drainage and one for the western drainage:area. We recommend that a
shutoff valve and a method for bypassing the stormwater for further treatment be supplied for each of
these sampling points. Valves should be normally locked and opened only after water is tested and
t� J-'' ' a��i • determined to meet the benchmarks shown in the permit., A separate single sample point is required for
the DMR report, located either at the pond outlet structure or at the outlet pipe flared end section (FES).
1`v By sampling from all these points, you will be able to determine if the BMPs are working effectively.
(2.) The GPS coordinates to be used for location on the USGS vicinity map should reference the centerline of
the main entrance at the gate. The reference note on the map should point to the facility.
(3 The site plan should be updated to include the completed State stormwater pond and its associated inlet /
outlet connections and vegetative filter strip. The plan should also show the drainage ditch and piping
thatconnects to the filter strip, and it should show the locations of all sample points, labeled
appropriately. Under no circumstances should wastewater be:allowed to enter the State stormwater pond.
Note that any resulting unpermitted discharge would be a violation of State Stormwater Permit SW8
930501 per 15A North Carolina Administrative Code (NCAC) 2H .1003, and it would require a
wastewater permit. As stated above in item 1, there should be two (2)samplepoints, one for each pond
inlet, to monitor the stormwater discharge before it gets to the pond.
,/4. The berm along west side of property and the adjacent area should be graded and seeded.
�5 The area where the old stormwater containment pond was located (behind old boiler house) needs to be
graded and repaired as needed. It should be able to transport runoff from the cooling tower area and
a ' possibly be-used-for'storage-o€--stormwaterof-prier-to;a-controhvalve. It appears that this area could be used
as a sampling point if so desired. Another potential location for sampling would be at one of the new
drop inlets prior to the stormwater pond.
Division of Energy, Mineral, and Land Resources
Land Quality Section - Wilmington Regional Office
127 Cardinal Drive Extension, Wilmington, North Carolina 28405 - [phone]/ Fax: [phone]

Mr. Andy Simmons
January 13, 2015
J 6. Riprap should be added at the western inlet pipe in the stormwater pond and in the swale on the other side
of the pond berm.
1 7. A temporary pipe near the yard inlet at middle of drainage ditch should be removed.
./ 8. Wherever feasible, above ground storage tanks should be surrounded by some type of physical
containment (impervious dike, berm, or concrete retaining structure) to prevent runoff in the event of a
failure or Ieaking transfer valve. Note that any resulting unpermitted discharge would be a violation of
the Clean Water Act.
19. Qualitative monitoring reports should be provided on current DEMLR forms available on our website at
hn:Hpgrta l . neden r. orp/web/I r/npdes-storm water.
L10� Both qualitative and analytical monitoring reports are to be performed quarterly.
For further details, please reference the attached inspection report. If you or your staff has any questions, please
do not hesitate to contact Steve Pusey or myself 910-796-7215.
Far an s, P.E.
Regional Supervisor
DEMLR, Wilmington Office
For Tracy Davis, P.E., Director
Division of Energy, Mineral and Land Resources
Attachments:
e Compliance Inspection Report - BIMS
m Industrial Storm Water Inspection Form
DS/sp: G:1LRILQINPDES1BrunswicklNCS-0002441 NCS 000244 - Stormwater site inspection and letter
cc: Mark Walton - Walton Engineering
WIRO files (Brunswick stormwater inspection file)
Bradley Bennett - Raleigh office
Page 2 of 2

Compliance Inspection Report
Permit: NCS000244 Effective: 01/01/15 Expiration: 12/31/18 Owner. American Distillation Inc
SOC: Effective: Expiration: Facility: American Distillation - Navassa
County: Brunswick 1690 Royster Rd NE
Region: Wilmington
Leland NC 28451
Contact Person: Andrew J Simmons Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-S to Representative(s):
Related Permits:
SW8930501 American Distillation Inc - American Distillation - Navassa
Inspection Date: 01/07/2015 Entry Time: 10:30AM Exit Time: 01:30PM
Primary Inspector: Steven G Pusey Phone:
Secondary Inspector(s):
Tom Tharrington
Reason for Inspection: Follow-up
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Phone:
Inspection Type: - Compliance Evaluation
Page: 1

permit: NCS0002" Owner - Facility: American Distillation Inc
Inspection Date: 01/07/2015 Inspection Typo: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
Due to the issuance of a renewed permit effective Jan. 1, 2015, an amendment to the SWPPP is due by the end of March,
2015. In addition, since the construction of the new State stormwater pond, the site is changing significantly, therefore
many features must be revised on the site plan.
Comments:
1. The vicinity map shows the location of the facility in the wrong place. The coordinates to be used for location should
reference the centerline of the main entrance at the gate. The reference note on the map should point to the facility.
2. New sample points must be shown on the revised plan. Two (2)sample points are recommended to be located prior to
the inlets of the stormwater pond in order to prevent contamination; one for the eastern drainage are and one for the western
area. A shutoff valve and a bypass method should be utilized at each of these sample points. Valves should be normally
locked and only opened after the water is tested and determined to meet the benchmarks shown in the permit. One (1)
DMR sampling point is required at either the outlet structure or the outlet pipe FES of the stormwater pond.
c./ 3. The berm along west side of property should be graded and seeded.
4. Area where the old stormwater containment pond was located (behind old boiler house) needs to be re -graded and
repaired. It should be able to transport runoff from the cooling tower area and possibly be used for storage of stormwater
prior to a control valve. It appears that this area could be used as a sampling location if so desired.
5. Riprap should be added at the western inlet pipe in the stormwater pond and in the swale on the other side of the pond
berm where the pipe intersects.
6. Temporary pipe near yard inlet at middle of drainage ditch should be removed.
Page: 2

r
Ilk
permit: NCSOD0244 Owner- Facility: American Distillation Inc
Inspection Date: 01107/2015 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a'Stormwater Pollution Prevention Plan?
N ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
❑ ❑ ❑
# Does the Plan include a 'Narrative Description of Practices'?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0 ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
E ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
0 ❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ❑ ❑ 0
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
N ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
N ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
■ ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ 0 ❑
Has the Stormwater Pollution Prevention Plan been implemented?
E ❑ ❑ ❑
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Yes No NA NE
❑ M ❑ ❑
Comment: Qualitative monitoring must be conducted on a quarterly basis for this facility. Please reference
and use the latest qualitative monitoring inspection forms which can be found on the DENR
website under Division of Land Qualitv.
Anaivtical Monitoring
Ye6_Na_NA HE
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ® ❑
Comment:
Permit and Outfalis
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? N ❑ ❑ ❑
# Were all outfalls observed during the inspection? ■ ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ E ❑
# Has the facility evaluated all illicit (non Stormwater) discharges? ❑ ❑ ■ ❑
Comment:
Page: 3

EEL'NC DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
4 WWR INDUSTRIAL STORM WATER INSPECTION FORM
W1LMINGTON REGIONAL OFFICE
Facility: American Distillation
Date: 1/7/2015
Location Address: 1690 NE Royster Road, Leland, NC 28451
COC #: NCS 000244
Contact Name: Andy Simmons, President
Phone Number: 910-371-0993
Contact Mailing Address: - See Above
County: Brunswick'
Directions: From Leland, take Old Mill Rd to Navassa, then turn right onto Royster, go to gate, push button, request entry
X Routine Compliance Inspection
Rescission Request
Complaint Investigation
Other - Explain
-ate::
�A fi
���-�� =� ,•� T .,-^��'���a�? ram'>.�� �- ti�,:_��'�:-e
tSTORM A�'EIt LL'I'1EOL�iEVffiV3�Q1'LI
ox�wnazw�5�r-:sewn>�: .W W- »�[xir.c• nyr.:er -. va-r itiKe�^z:H.}..s.r.w •., r, 1.4
Yes
No
NIA
Comments
1.
Is a copy of the signed and certified SWPPP at the facility?
X
Amendment pending.
Waste sent to POTW
Process, tanks
2.
Does the facility's SWPPP address the minimum BMP requirements?
X
3.
Are amendments to the SWPPP clearly documented?
X
4.
Is the current SWPPP complete?
X
fB.
EHI<C1E�EQI7Rrt:
Yes
No
NIA
1.
Were the vehicle/equipment maintenance areas inspected?
X
2.
Are vehicle/machinery leaks and drips properly managed?
X
3.
Is vehicle/equipment washing done in a designed area so that wash water
can be properly managed?
X
4.
Was the vehicle fueling area inspected?
X
5.
Are vehicle maintenance activities kept indoors?
X
6.
Were the vehicle/equipment storage areas inspected?
X
7.
Are current BMPs in vehicle/equipment/fueling areas adequate?
X
.�-.w -�
r�.
Lb.rt-a- w•r-., a.,z .a.. -.a.'- tiFx, i. 1. ,�,. ,a,:
Yes
No
N/A
1.
Are containers for temporary storage of wastes labeled?
X
2.
Are waste materials recycled?
X
3.
Are hazardous wastes properly handled and disposed of?
X
4.
Is processed debris removed regularly?
X
5.
Is there secondary containment for liquid wastes?
X
6.
Are current waste management BMPs adequate?
X
Yes
No
NIA
1
Are there appropriate BMPs for outdoor storage of raw materials,
products, and byproducts?
X
2.
Are containers for chemical 'substances labeled?
X
3.
Is there secondary containment for liquid storage?
X
4.
Are current BMPs in material storage areas adequate?
X
of 4

rj
�111112
Yes
No
NIA
Comments
1.
Are there procedures for spill response and cleanup?
X
2.
Are appropriate spill containment and cleanup materials kept on -site and
X
in convenient locations?
3.
Are used absorbent materials disposed of in a timely manner?
X
4.
Are current spill BU Ps,�adequate?
X
1
{
Yes
No
NIA
-�:.` >�
Site under construction
"
1.
Are unpaved outdoor areas protected from water/wind erosion?
X
2.
Are drainage ditches or the areas around the outfalls free of erosion?
X
3.
Do implemented BMPs appear effective in controlling erosion?
X
a
PIMA`�Yes
N
N/<r
�'.'�
o?(Q'
A
1.
Have all illicit water discharges been eliminated or permitted?
X
2,
Are BMPs for authorized non -storm water discharges properly
X
implemented?
3.
Are current BMPs adequate for management of authorized non -storm
X
water discharges?
^
Yes
No
NIA
ta..�,4ti£``t0.s
Pre-treatment units only
1.
Are wastewater treatment facilities properly maintained?
X
2.
Has monitoring been done?
X
ti19,
Yes
No
NIA
�.wae'xas4=#a.ca.x.F�1 -
1.
Were there any stream impacts?
X
2.
Were field parameters taken for pH or DO?
X
3.
Were there any stream standard violations/
X
4.
Were there excessive solids in the stream?
X
5.
Were pictures taken?
X
6.
Were samples taken?
X
I. M110-1114
U t
1. There appears to be a need for two (2) sample locations for stormwater runoff. Each area is to have a locked valve. The water
here must be sampled and determined as "clean" before it is released through the valves to the stormwater pond. If not "clean",
water must be sent to the POTW. One (1) DMR sample location is required at either the pond outlet structure or the pond outlet
pipe FES. All sample locations must be clearly identified on the site plan.
2. Tank 23 contains distillation process wastewater. It has been physically disconnected from the cooling towers. It also has a
locked valve so that the wastewater will not be sent to the stormwater pond. Instead, the contents of this tank are sent to the POTW
for treatment. Tank 50 (air stripper) is used to clean the process wastewater before being sent to the POTW.
3. In accordance with the permit, all monitoring is to be performed quarterly.
of 4

�- :
s.S♦^'.�[A.i�'�.r�r.-T� s Y�i%n'Y.u"�i+#'?T3�;�"„zv Sc'aY.- _i°`�--.-t�`�:1''C 4'`ti''t'.�ee�a ' 'j`T�'�a-?��.'.d``-��"r.
���:�rrC'���
1.
Industry in substantial compliance
2
Minor deficiencies noted. Revisit scheduled for next quarter.
(date).
3.
Major deficiencies or discharges noted and require prompt correction. Revisit scheduled for
(date).
4.
Critical deficiencies or discharges noted and require immediate correction. Revisit scheduled for
(date).
5.
Rescission is appropriate.
6.
Rescission is not appropriate.
of 4

L, Include a Map of the facility. This drawing should depict the building, parking, process, and storage areas. If you do :,bt
have a map, draw one or request that the facility provide you one in your written correspondence.
Map on file. It is currently being revised to include changes to the stormwater pond and drainage features.
M. Develop a Vicinity Map for the file.
Map on file. The facility location is being revised to be more accurate.
N. Identify all records that were reviewed.
Analytical records were reviewed through 811114. Analytical records for the last quarter of 2014 were not taken. Reference
the email to Mark Walton of 12130114 regarding "No flow ".
Qualitative records were not found Qualitative inspection records should be provided in future on current DWQ forms
which can be found on our website_
0. Explain how Secondary Containment is being used and whether these measures are being properly maintained. [Did you
observe that the secondary containment had release valves (were they open, locked etc.), was there water, waste product,
sheen, etc observed within the secondary containment area? Explain your observations]
Secondary containment is used for the process area, tank farm, and other small containment areas. No wastewater was
found within these containment areas. Several large bulk tanks with product or waste in them (including Tank 23 which
holds process wastewater which is sent to the POTW for treatment), are located outside of secondary containment near the
cooling towers.
P. Housekeeping and best management practices (maintenance of BMPs) status.
Fair. State Stormwater pond is under construction.
Q. Identify outfalls and receiving waters. List any observation or concerns.
Previously, there was but one outfall on the plan where the swale entered a vegetated area and then stream. This is the
location where samples were taken. Due to changes at the site in 2014, it appears that there will now be two (2) sample
locations at areas prior to entering the stormwater pond and one DMR sample point at the pond outlet. All runoff water
must be tested and meet approved pollutant limits before being discharged to waters of the State.
R. Take digital photographs to support staff report observations and to provide assistance to future inspectors).
Digital photographs are on file.
Logged by: Inspectors: Steve Pusey
Date:
4 of 4

Posey, Steven
From: Pusey, Steven
Sent: Wednesday, July 29, 2015 4:33 PM
To: Andy Simmons([e-mail]); Mark Walton
(mark(s m tonengineering.net)
Subject: NPDES Stomw ater permit NCS 000244
Importance: High
I recently conducted a file review of the subject permit. After my recent inspection for the State Stormwater
permit and after going over the comments in our last inspection of January 14, 2015,1 have the following new
comments:
1. Per our conversation, multiple internal sample points are being taken in order to determine whether
the stormwater runoff meets the criteria to be released. Please verify that sample points for the
eastern drainage area and the western drainage area are being taken. These samples are used to
monitor the stormwater discharge going to each inlet of the pond. In addition, please verify that
samples are being recorded for the discharge outlet of the pond and being submitted for the DMR
report.
2. Please verify that a sample is being taken in the area behind the old boiler house. This point is needed
to monitor the runoff from the cooling towers.
3. Both qualitative and analytical monitoring reports are to be performed quarterly. Please verify that
these reports are being submitted.
Please send us a response on these items within thirty (30) days. This is necessary to ensure compliance with
the NPDES Stormwater Permit NCS 000244. if you have any comments or questions, please don't hesitate to
call.
Thanks,
Steve
q.PhAaW
Environmental Engineer
Land Quality Section
Wilmington Regional Office
NC DENR, Division of Energy, Mineral and Land Resources
127 Cardinal Drive Ext.
Wilmington, NC 28406
Phone: [phone]
Fax: 910-s50-2oo4
Website: www.ncdenr. ov
E-Mail: steven.puseyAncdenr.gov
N;' Before printing this email, please consider your budget and the environment
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties unless the content is exempt by statute or other regulation.

Pusey, Steven
From:
Pusey, Steven
Sent:
Tuesday, December 30, 2014 1:32 PM
To:
'Mark Walton'
Cc:
Nancy Neale; Barry White; Darlene Wells
Subject:
RE: NPDES Stormwater Draft Permit - NCS000244
Per our telecon of yesterday, I have the following information for you regarding the NPDES permit at American
Distillation. If there is no measurable storm event during a sampling period, they should write something like "no flow"
on the DMR. In addition, I reviewed the letter you referenced about the missing data.
Let me know if you have any more questions before our meeting next Tuesday, Jan. 6.
Thanks,
Steve
From: Marie Walton [ma ilto: mark@waltonengi neering. net]
Sent: Tuesday, December 16, 2014 12:35 PM
To: Pusey, Steven
Cc: Nancy Neale; Barry White; Darlene Wells
Subject: Re: NPDES Stormwater Draft Permit - NCS000244
Steve,
Could we meet at ADI next Wednesday for your inspection?
Thanks,
Mark
On 12/4/2014 3:40 PM, Pusey, Steven wrote:
Mark,
Would you like to meet me at the site next week sometime for an inspection? Please advise when this
can be arranged. I would like to inspect for both State Stormwater and NPDES Stormwater permits at
the same time if possible.
Thanks,
Steve
From: Mark Walton rmailto:[e-mail]
Sent: Monday, November 24, 2014 11:44 AM
To: Pusey, Steven .
Subject: Re: NPDES Stormwater Draft Permit-.NCS000244
Steve,
I just talked to Andy Simmons. He said the pond would be ready for inspection by the latter part of next
week, depending on the weather.
Thanks,

Pusey, Steen
From: Pusey, Steven
Sent: Tuesday, December 30, 2014 11:06 AM
To: Ventaloro, Julie
Subject: RE: American Distillation NPDES stormwater permit
Much thanks. Happy New Year to you too!
Steve
From: Ventaloro, Julie
Sent: Tuesday, December 30, 2014 10:22 AM
To: Pusey, Steven
Subject: RE: American Distillation NPDES stormwater permit
Hi Steve,
Attached is the letter from American Distillation.
If there is no measurable storm event during a sampling period, they should write something like "no flow" on the DMR.
In case you haven't seen this, there is a helpful collection of guidance, templates, etc regarding our industrial
stormwater program on our internal website: http://portal.ncdenr.orp/group/ir/stormwater-guidance. You have to be
signed in to see it. Bethany maintains it and has to keep reminding me that it's there. I'm still learning my way around
the program, but some of it is finally starting to sink in. (-: I think adding an "FAQ" section with questions like the one
you posed about rainfall would be useful for all of us.
Happy New Year,
Julie
From: Pusey, Steven
Sent: Monday, December 29, 2014 3:50 PM
To: Ventaloro, Julie
Subject: American Distillation NPDES stormwater permit
Julie,
I am planning an inspection of American Distillation next week on January 6. The engineer, Mark Walton, told me that
Andy Simmons of American Distillation had sent you a letter explaining the lapse in monitoring data. Can you send me a
copy of this letter? Also, what other questions were answered in this letter?
Another question is what should they do if there hasn't been much rainfall and they don't have anything to
monitor? How should they show this on their monitoring data report?
Thanks,
Steve
Steyeng. flirfey
Environmental Engineer
NCDENR - Division of Energy, Mineral and Land Resources
127 Cardinal Drive Ext.

NCDEFIR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. Andy Simmons, President
American Distillation Company, Inc.
P.O. Box 400
Leland, NC 28451
Division of Water Quality
Charles Wakild, P. E.
Director
May 10, 2013
SUBJECT: Compliance Evaluation Inspection — NPDES Stormwater Permit NCS000244
American Distillation
Brunswick County
Dear Mr. Simmons:
Jahn E. Skvarla, Ill
. Secretary
On March 20, 2013, Steve Pusey and Torn Tharrington, of the Division of Water Quality, Wilmington Regional
office, performed an inspection of the subject facility.. This inspection covered both the requirements of the
individual Stormwater permit NCS000244, and the General Wastewater permit NCG500148 for cooling tower /
boiler blowdown.
Previously on April 22, 2010, a Notice of Violation was issued for permit and stream standard conditions on the
General Wastewater permit NCG500148. At that time, process wastewater was being discharged to the cooling
towers, which was in violation of the permit. The General Permit NCG500148 allows discharge of non -contact
water only. The piping from the process wastewater to the cooling towers has now been disconnected, and all
process wastewater is sent to the Northeast Brunswick Wastewater Treatment Facility. The inspection report for this
permit will be issued. separately.
In reference to the Individual Stormwater Permit NCS000244, the following items should be addressed to prevent
problems in the future:
Although there is only one outfall shown on the current site plan where the swale enters the stream, there is
also. a valve at south end of the stormwater containment pond that, if opened, could drain to a vegetated
area, then to the stream. if this is an outfall, it should be identified as an outfall on the site map. Note that
this outlet and other outlets can be consolidated to drain into the State stormwater pond, once it is
constructed. However, all water must be tested and meet approved pollutantlimits before being discharged
to the State Stormwater pond. The°site plan should be updated to include the complete State stormwater
pond and its associated inlet / outlet connections. if all outlets from the plant site are consolidated to drain
to this pond, the new outfall would be located at -the vegetated filter strip near the pond outlet.
2. Tank 23,, which'contains distillation process wastewater, and several other above ground storage tanks,
which may have product or waste in them, located in the area behind the -cooling towers, do not have
secondary containment. Tank 23 and possibly the other adjacent tanks should be evaluated for requirement
of secondary containment. Wherever feasible, above ground storage tanks. should be surrounded by some
type of physical containment (impervious dike, berm, or concrete retaining structure) to prevent runoff in
the event of a failure or leaking transfer valve. Note that any resulting unpermitted discharge would be a
violation of the Clean Water Act
3. Qualitative inspection records should be provided on current DWQ forms in future.
4. Significant erosion was noticed in two (2) places, one area at the north end of the Stormwater containment
pond on the berm, and the other one further north along the berm. These areas,should be repaired and
stabilized with vegetation as soon as possible. The liner in the stormwater containment pond shows
significant wear and.is torn in several places. This could allow contaminated stormwater to leak out
through the bottom and/or through the adjacent berm. It was discussed that the liner would be replaced.
Wilmington Regional Office
127 Cardinal Drive Extension, Wilmington, North Carolina 28405 One
Phone: [phone] FAX [phone] DENR Assistance: 1-877-623-6748 NofffiCarolina
Internet: vrww.ncwaterquality.org
An Equal Opportunity.l A(firrnalive Action Fmpbyer

Andy Simmons, President_r --�� _
NPDES Stormwater Permit NCS000244 1
May 10, 2013
sF
As part of the inspection, a tour of your facility was conducted. All observations and recommendations are noted in
the (Summary of findings/comments) of this inspection report. Remember, it is our goal to ensure the quality of the
surface waters of this State.
Please review the attached report. if you or your staff has any questions, do not hesitate to contact Steve Pusey, Tom
Tharrington, or mvself at 910-796-7215.
Sincerely,
Ji�gson
Water Quality Regional Supervisor
Enclosures
cc: /W1RO files (Brunswick stormwater inspection file)
Central files
Stormvrater Permitting
• NPS and Compliance Oversi ht
Page 2 of 2

®�A NC DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
a1CP�ENR INDUSTRIAL STORM WATER INSPECTION FORM
• WILMINGTON REGIONAL OFFICE
Facility: American Distillation
Date: 3/20/2013
Location Address: 1690 NE Royster Road, Leland, NC 28451
COC #: NCS 000244
Contact Name: Charles (Chuck) Bullard, Supervisor
Andy Simmons, President
Phone Number: 910-371-0993
Contact Mailing Address: See Above
County: Brunswick
Directions:
From Leland, take Old Mill Rd to Navassa, then turn right onto Royster, go to gate, push button, request entry
X
Routine Compliance Inspection
Rescission Request
Complaint Investigation
Other - Explain
A
STORM WATER'POLLU7TON PREVENTiON,PLAN = i
Yes
No
NIA
Comments
1.
Is a copy of the signed and certified SWPPP at the facility?
X
Rev. 3-15-1 1 & 2-22-12
-
Tank-2-3-area-may-need.-0 i-1
2.
Does the facility's SWPPP address the minimum BMP requirements?
X
3.
Are amendments to the SWPPP clearly documented?
X
4.
Is the current SWPPP complete?
X
'B
VEHICLE EQUIPMENT�y
Yes
No
N/A
1.
Were the vehicle/equipment maintenance areas inspected?
X
2.
Are vehicle/machinery leaks and drips properly managed?
X
3.
is vehicle/equipment washing done in a designed area so that wash water
can be properly managed?
X
4.
Was the vehicle fueling area inspected?
X
5.
Are vehicle maintenance activities kept indoors? -
X
6.
Were the vehicle/equipment storage areas inspected?
X
7.
Are current BMPs in vehicle/equipment/fueling areas adequate?
X
C
'WASTErMANAGEMENT�' ^ , M �a r=
Yes
No
NIA
1.
Are containers for temporary storage of wastes labeled?
X
2.
Are waste materials recycled?
X
3.
Are hazardous wastes properly handled and disposed of?
X
4.
Is processed debris removed regularly?
X
5_
Is there secondary containment for liquid wastes?
X
6. j
Are current waste management BMPs adequate?
X
D:
:;MATER[AG"rSTQRAGE
Yes
No
NIA
1.
Are there appropriate BMPs. for outdoor storage of raw materials,
products, and byproducts?
X
2.
Are containers for chemical substances labeled?
X
3.
Is there secondary containment for liquid storage?
X
4.
Are current BMPs in material storage areas adequate?
X

E
SPILL CONTROL:Y
Yes
No
NIA
Comments
1.
Are there procedures for spill response and cleanup?
X
2.
Are appropriate spill containment and cleanup materials kept on -site and
X
in convenient locations?
Significant erosion was
r3. I
Are used absorbent materials disposed of in a timely manner?
X
4.
Are current spill BMPs adequate?
X
Yes
No
NIA
1.
Are unpaved outdoor areas protected from water/wind erosion?
X
2.
Are drainage ditches or the areas around the outfalls free of erosion?
X
noticed in two (2)
places, one area at the
north end of the
stormwater containment
pond on the berm, and
the other one further
north along the berm.
The stormwater swale
3.
Do implemented BMPs appear effective in controlling erosion?
X
had some erosion. This
area will be improved
with the construction of
the State stormwater
pond. The previously
excavated soil from this
area, currently stored on
a concrete pad with
secondary containment,
should be disposed of
properly.
G
NON=STORM WATER`MANAGEMENT
Yes
No
NIA
i.
Have all illicit water discharges been eliminated or permitted?
X
2.
Are BMPs for authorized non -storm water discharges properly
X
implemented?
3.
Are current BMPs adequate for management of authorized non -storm
X
water discharges?
Wastewater treatment
PROCESS:WASTEWATERCONTROLS AND.MONITORING
Yes
No
NIA
1.
Are wastewater treatment facilities properly maintained?
X
units are being prepared
for future use as pre-
treatment of wastewater
before sending to POTW
2.
Has monitoring been done?
X
I.
..STREAM OBSERVATION/IMPACTS
Yes
No
NIA
1.
Were there any stream impacts?
X
2.
Were field parameters taken for pH or DO?
X
3.
Were there any stream standard violations/
X
4.
Were there excessive solids in the stream?
X
5.
Were pictures taken?
X
b.
Were samples taken?
X

J
SUMMARY /ADDITIONAL COMINEIYTS
1. There are two (2) locations in the yard area that contain stormwater runoff. Each area has a locked valve. The water here must
be sampled and determined as "clean" before it is released through the valves to the outfall. There is also a discharge valve at the
south end of the stormwater containment pond that, if opened, would drain to a vegetated area and then to the stream. If this valve
is ever opened, it should be evaluated as an outfall and shown on the site map. Alternately, it can be routed to the State stormwater
pond once it is constructed.
2. Tank 23 contains distillation process wastewater. Therefore, it has been physically disconnected from the cooling towers. It also
has a locked valve so that the wastewater is not sent to the stormwater containment pond. Instead, the contents of this tank are sent
to the POTW for treatment. This-tank•and-possibly-otheradjacent-tanks-should•be-evaluated'for requirement- of secondary
,containment-,
3. Under Section C, Qualitative Monitoring, the permit states that all qualitative monitoring will be performed twice per year,
however Table 4 of this section states that monitoring will be performed quarterly_ Please perform quarterly monitoring until
further notice.
:`K.
=RATING LEVEL (CIRCLE ONE:,1-� �; c
1.
Industry in substantial compliance
2.
Minor deficiencies noted. Revisit scheduled for (date).
3.
Major deficiencies or discharges noted and require prompt correction. Revisit scheduled for (date).
4.
Critical deficiencies or discharges noted and require immediate correctioin. Revisit scheduled (date).
for
5.
Rescission is appropriate.
6.
Rescission is not appropriate. Permit is in process of being renewed.

L. Include a Map of the facility_ This drawing should depict the building, parking, process, and storage areas. If you Wriet
have a map, draw one or request that the facility provide you one in your written correspondence.
Map on f le. This map should be updated to include the new State Stormwater pond once it is constructed.
M. Develop a Vicinity Map for the file.
Map onfle.
N. Identify all records that were reviewed.
Qualitative records through 0311112013 have been reviewed Qualitative inspection records should be provided on current
DWQ forms in future.
O. Explain how Secondary Containment is being used and whether these measures are being properly maintained_ [Did you
observe that the secondary containment had release valves (were they open, locked etc.), was there water, waste product,
sheen, etc observed within.the secondary containment area? Explain your observations]
No wastewater was found within containment areas. Several large bulk tanks with product or waste in them, including Tank
23, are located outside of secondary containment areas behind the cooling towers.
P. Housekeeping and best management practices (maintenance of BMPs) status.
Fair. Drummed storage areas need secondary containment where drums have product or waste in them. Any hazardous
waste storage pads require secondary containment.
Q. Identify outfalls and receiving waters. List any observation or concerns.
There is one outfall on the plan where the Swale enters a vegetated area and then stream. There is also a valve at south end
of the stormwater containment pond that could drain to a vegetated area then stream. If this is an outfall, it should be
identified as an out/all on the site map. Note that this outlet and other outlets can be consolidated to drain into the State
stormwater pond, once it is constructed. However, all water must be tested and meet approved pollutant limits before being
discharged to the State stormwater pond.
R. Take digital photographs to support staff report observations and to provide assistance to future inspectors).
Digital photographs are on file.
Logged by: Inspectors: Steve Pusey and Tom Tharrin ton

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� TVA L ToN ENGINEERING
May 18, 2010
Linda Willis
NC DENR
Division of Water Quality
127 Cardinal Dr. Extension
Wilmington, NC 28405
Re: American Distillation — NOV response
Dear Ms. Willis,
This letter is to serve as a response to the NOV issued on April 22" d 2010.
Mq y 2 vr��
zp10
American Distillation (ADI) has been using treated water along with either county water or well water as
cooling tower makeup water since the installation of the air stripper in 2006. After the installation of the air
stripper, ADI used it to remove the small quantities of VOC's present in the process wastewater. After running it
through the air stripper the wastewater is then filtered through a sand filter and is added to the cooling tower
makeup water. As the water is circulated through the cooling tower, additional VOC's are removed through
evaporation. Discharge of the makeup water results when the cooling tower blow down is discharged through
the bottom of the cooling tower. At this point in the system, the cooling tower blow down is a mixture of
makeup well water and the treated process wastewater circulating through the cooling tower. In theory this
process should produce a compliant discharge except for the fact that they were discharging treated process
water, along with non -contact water through a non -contact permit.
When the General Permit COC NCG500148 was originally issued in 1992, ADI was operating without an air
stripper. The cooling tower was being operated with county snake -up water and the blowdown was being
discharged render NCG500148. The process wastewater was sent to High Rise Service Co. to be treated by
complete evaporation. With the increase in business and the high cost of evaporation led ADI to build an air
stripper to treat the process wastewater in 2006. At this time the treated water was then added to the cooling
tower in place. of the county make-up water. This was done for two reasons. First it reduced operating costs by
reducing the need for large scale evaporation and second it reduced the amount of county water used, thus
lowering the amount of chlorine m the discharge. This was important because the county water chlorine content
exceeded the NCG500148 chlorine limit. This was a concern that NCDENR had expressed to ADI. ADI at no
point was trying to hide the fad that the treated process water was being added to the cooling tower. They were
simply trying to find an economically viable solution to the chlorine issue and their growing wastewater costs.
While reviewing the Compliance Evaluation Inspections for 2007 & 2008, NCDENR inspectors make reference
to the process wastewater being added to the cooling tower for rem, Additionally, the inspection reports
mention review of the SPRP, which contained a schematic of the cooling tower discharge showing the addition
of process wastewater to the air stripper (Figure 3). These inspections reports serve as records that ADI
disclosed its operating practices to NCDENR
American Distillation has currently ceased all process wastewater discharges. They have physically
disconnected the air stripper from the cooling towers. They are currently storing all their process wastewater
_—Xe ite., until they can locate a facility that will accept it They are looking into EC FLO bamnxk
Both facilities have samples of ADI's wastewater and we are just waiting for the firms sr�As soon as a
decision has been made on where to take the wastewater, We will contact you with that information.
Additionally we have been performing an array of sampling and testing to try and identify the source of theme
BOD levels. The con nt from the gvj&fl has been rmmmd and is currently being stored in a
d k area on top p c as well as covered by plastic.
Tel: [phone] PO Box 895, Burpw, North Carolina, 28425 Fax: [phone]

,�ALTON ENGINEERING
During out meeting on May I I'h 2010, pe d tended a over our BOD l !
discharge w tlt l� We should have the new system in place by the end of the week and we have
scheduled sampling for the beginning of next week. Additionally we have prepared another IUP application and
with favorable sampling results we should have an IUP in place by the end of next month. Until the NP is irk
place ADI will be storing and eventually trucking all
We have enclosed the stormwater inspection logs, air stripper inspection logs, sampling results, a copy of the
original cooling tower discharge (Figure 3), and a copy of the lilP application that we nresemed to the Norihc
BOD Ievls.- Since that time we have been sampling different locations in their system to try and identify the
source of the high BOD levels. Those results are included as well.
If you have any questions or need additional information, please call me at 910-2594800.
Sincerely, .�
R. Mark Walton
Professional Engineer
Walton Engineering
Tel: [phone] PO Box 895, Burpw, North Carolina, 29425 Fax [phone]

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UNITED STATES POSTAL SERVICE
• Sender: Please print your name, address, and ZIP+*4n,thlsi'box •
NE OENR - Division of Water Quality
Surface Water Protection Section
127 Cardinal Drive Extension
Wilmington, NC 29405

NAM
DGHR
North'Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
April 22, 2010
CERTIFIED MAIL #7006 0810 0004 4480 9087
RETURN RECEIPT REQUESTED
American Distillation Company, Inc.
Mr. Andy Simmons, President
P.O. Box 400
Leland, NC 28451
Subject: NOTICE OF VIOLATION
NOTICE OF INTENT TO ENFORCE
NOV-2010-PC-0454
American Distillation Company, Inc.
NPDES Permit No. NCG500148
Violation of Permit Conditions
Stream Standard Violation
Brunswick County
Dear Sir:
While conducting a complaint investigation on March 16, 2010, Linda Willis from the Division of Water
Quality, Surface Water Protection Section in the Wilmington Regional Office, noticed a sheen in a
continuous discharge to Cartwheel Branch from the American Distillation Company, Inc. facility located at
1690 N.E. Royster Road in Leland, North Carolina. Cartwheel Branch is a Class SC, Sw water of the State
in the Cape Fear River. Basin.
The discharge of wastewater from the tolling operations are routed through the cooling tower and/or boiler
which is in violation of the North Carolina General Permit NCG500000. The General Permit
(NCG500000) allows the discharge of non contact water only. You are hereby -required to discontinue this
discharge immediately (upon receipt of this notification) and pursue: 1). either the disposal of the process
wastewater at an approved disposal facility; or 2). apply for and secure an Industrial User Permit from the
Northeast Brunswick Wastewater Treatment Facility for discharge and treatment of the process wastewater
at the regional plant; or 3). apply for an Individual NPDES Permit with the Division of Water Quality.
Samples were collected in stream'in Cartwheel Branch that indicated pollutants have been discharged to the
receiving stream from your facility and have resulted in impacts to the surface waters. Dissolved oxygen
was measured to be 0.16 milligrams per liter in the vicinity of the discharge from the cooling tower. The
water quality standard for dissolved oxygen for class Sw waters is an instantaneous value of no less than
4.0 milligrams per liter. As a result of the complaint investigation, the following violations are described
below:
I. Permit Condition Violation
II. Stream Standard Violation
N. C. Division of Water Quality
Wilmington Regional Office
127 Cardinal Drive Extension, NC 28405
Phone: [phone] FAX: 91"50-20041
Customer Service: 1-877-623-6748
Internet: www.nom1erqual4.org
An Equal Opportunity S Affirmative Fiction Employar
NoI thCarolina
Naturallw

Page 2 of 3
American Distillation Company, Inc.
Brunswick County ,
Item I. Permit Condition Violation
The NPDES Permit NCG500000 is specifically for non -contact cooling water, boiler blowdown, cooling
tower blowdown, condensate, and similar point source discharges. Contact cooling water discharges
require an individual NPDES permit. Non -contact cooling water is defined as water used for cooling
which does not come into direct contact with any raw material, intermediate product, waste product
or finished product.
Item II. Stream Standards
15A NCAC 02H.0211 (3)(b) and 15A NCAC 0211.0220 (3)(b) apply due to the classification of the
receiving stream (SC, Sw): Dissolved oxygen: not less than 5.0 milligrams per liter, except that
swamp waters (with a minimum instantaneous value of not less than 4.0 milligrams per liter), poorly
flushed tidally influenced streams or embayments, or estuaring bottom waters may have lower values
if caused by natural conditions.
The discharge of process wastewater to the receiving stream caused a pollutant load to the stream that
depressed the dissolved oxygen content to 0.16 milligrams per liter in violation of the water quality
standard of 4.0 milligrams per liter.
Requested Response
You are directed to respond to this letter in writing within 30 calendar days of receipt of this Notice.
Your response should be sent to both this office at the letterhead address and to the Wetlands and
Stormwater Branch, NPS Assistance and Compliance Oversight Unit, attention John Hennessy, 1617 Mail
Service Center, Raleigh, NC 27699-1617. Your response should include the following:
1. Please explain why process wastewater was discharged by way of the cooling tower. Explain in
detail how long the process wastewater has been discharged to the cooling tower and provide all
analyses demonstrating the characteristics of the wastewater prior to introduction to the cooling
tower. Also provide all daily monitoring reports for both NPDES Permits NCG500148 and
NCS000244 since 2006.
2. Provide the analyses requested by the Division on March 16, 20I0, of the soils excavated from the
stormwater discharge outfall. Explain how and where the excavated soils from the stormwater
outfall were disposed.
3. Provide the analyses of the discharge from the cooling tower requested by the Division on March 16,
2010.
4. Have you applied for an industrial user permit with the Northeast Brunswick Wastewater Treatment
Plant? Provide this office with documentation that application had been made. If not, explain why
application was not made.
5. Upon receipt of this notice, you are required to discontinue the discharge of process wastewater to
the cooling tower and/or boiler. You must eliminate all potential means for introducing process
wastewater to the cooling tower. You are riot allowed to discharge wastewater via the NCG500148.
You must explain in detail, how you intend to properly dispose of the process wastewater.
6. Please indicate how the wastewater in the receiving stream will be removed and disposed of
appropriately.
Process for applying for an individual wastewater permit:
The person who will be legally responsible for the permit should sign the application form. That person,
and/or company may designate a consultant and/or firm [in writing] to act as their Authorized
Representative. If so, that person can then sign the permit application.
The permit application fee will be $860.00. Fees must be paid by check to NC DENR.
Submit the original (signed) application and two copies, any designation of Authorized Representative[s]
and two copies, along with three copies of any of documents listed below:
1. An evaluation of alternatives to discharge is required for all new or expanding
facilities. Consult the guidance document for preparation of Engineering Alternatives
Analyses (EAAs).

Page 3 of 3
1 American Distillation Company, Inc.
Brunswick County
2. Supply the most current USGS flow data available for the receiving stream. Contact Curtis
Weaver at USGS [(919) 5714043] if you do not have current flow data.
3. Consult the Cape Fear River Basin plan on the Division's website
(hqp://h2o.enr.state.nc.us/basinwide/drafCPFARri]2005.htm) for the status of the
receiving stream segment. If the stream is impaired from its stated uses, this may prevent
the issuance of a new NPDES permit.
4. Attach a site map clearly showing the proposed discharge point (a section of a USGS
topographic map is preferred).
5. A process flow diagram of the treatment system, including proposed components sizes
and a facility layout.
6. A completed Local Government Review form [included in the EAA Guidance
Document].
Visit our website[http://www.ncwaterquality.org/NPDES/] for more information on NPDES permitting. If
you have technical questions during preparation of the EAA, contact Dr. Sergei Chernikov at 919 807-
6393.
Thank you for your attention to this matter. This office is considering a recommendation to enforce to the
Division Director. Your above -mentioned response to this correspondence will be considered in this
process_ This office requires that the violations, as detailed above, be abated immediately. These
violations and any future violations are subject to a civil penalty assessment of up to $25,000.00 per
day for each violation. Should you have any questions regarding these matters, please contact me at (910)
796-7215.
Sincerely,
Rick Shiver
Wilmington Regional Supervisor
Division of Water Quality
Surface Water Protection Section
cc: WiRO Enf File NPDES NCG500/NCS000244 Brunswick NOV-2010-PC-0454
John Hennessy — NPS-ACO Unit, Archdale Building
DWQ Central Files
DWQ CO NPDES Permitting Unit Attn: Matt Matthews
DWQ WiRO Air Quality Attn: Brad Newland
DWQ WiRO Attn: Kipp Glazier
AD[, Barry White P.O. Box 400 Leland, NC 28451

A.
�s�
NCDERR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Coleen H. Sullins
Director
April 22, 2010
CERTIFIED MAIL #7006 0810 0004 4480 9087
RETURN RECEIPT REQUESTED
American Distillation Company, Inc.
Mr. Andy Simmons, President
P.O. Box 400
Leland, NC 28451
Subject: NOTICE OF VIOLATION
NOTICE OF INTENT TO ENFORCE
NOV-2010-PC-0454
NPDES Permit No. NCG500148
Violation of Permit Conditions
Stream Standard Violation
Brunswick County
Dear Sir:
Dee Freeman
Secretary
While conducting a complaint investigation on March 16, 2010, Linda Willis from the Division of Water
Quality, Surface Water Protection Section in the Wilmington Regional Office, noticed a sheen:in a
continuous discharge to Cartwheel Branch from the American Distillation Company, Inc. facility located at
1690 N.E. Royster Road in Leland, North Carolina. Cartwheel Branch is a Class SC, Sw water of the State
in the Cape Pear River Basin.
The discharge of wastewater from the tolling operations are routed through the cooling tower and/or boiler
which is in violation of the North Carolina General Permit NCG500000. The General Permit
(NCG500000) allows the discharge of non contact water only. You are hereby required to discontinue this
discharge immediately (upon receipt of this notification) and pursue: 1). either the disposal of the process
wastewater at an approved disposal facility; or 2). apply for and secure an Industrial User Permit from the
Northeast Brunswick Wastewater Treatment Facility for discharge and treatment of the process wastewater
at the regional plant; or 3). apply for an Individual NPDES Permit with the Division of Water Quality.
Samples were collected in stream in Cartwheel Branch that indicated pollutants have been discharged to the
receiving stream from your facility and have resulted in impacts to the surface waters. Dissolved oxygen
was measured to be 0.16 milligrams per liter in the vicinity of the discharge from the cooling tower. The
water quality standard for dissolved oxygen for class Sw waters is an instantaneous value of no less than
4.0 milligrams per liter. As a result of the complaint investigation, the following violations are described
below:
I. Permit Condition Violation
11. Stream Standard Violation
N. C. Division of Water Cluality
Wilmington Regional Office
127 Cardinal Drive Extension, NC 28405
Phone: [phone] FAX: 910-W-20041
Customer Service: 1-877-623-6748
intemet www.nmaterquality.org
An Equal Opportunity 1 AHtmiative Action Employer
N&ffiCarolina
Natura!!r,

Page 2 of 3
American Distillation Company, Inc.
Brunswick County
Item I. Permit Condition Violation
The NPDES Permit NCG500000 is specifically for non -contact cooling water, boiler blowdown, cooling
tower blowdown, condensate, and similar point source discharges. Contact cooling water discharges
require an individual NPDES permit. Non -contact cooling water is defined as water used for cooling
which does not come into direct contact with any raw material, intermediate product, waste product
or finished product.
Item II. Stream Standards
15A NCAC 0211.0211(3)(b) and 15A NCAC 02B.0220 (3)(b) apply due to the classification of the
receiving stream (SC, Sw): Dissolved oxygen: not less than 5.0 milligrams per liter, except that
swamp waters (with a minimum instantaneous value of not less than 4.0.milligrams'per liter), poorly
flushed tidally influenced streams or embsyments, or estuaring bottom waters may have lower values
if caused by natural conditions.
The discharge of process wastewater to the receiving stream caused a pollutant load to the stream that
depressed the dissolved oxygen content to 0.16 milligrams per liter in violation of the water quality
standard of 4.0 milligrams per liter.
Requested Response
You are directed to respond to this letter in writing within 30 calendar days of receipt of this Notice.
Your response should be sent to both this office at the letterhead address and to the Wetlands and
Stormwater Branch, NPS Assistance and Compliance Oversight Unit, attention John Hennessy, 1617 Mail
Service Center, Raleigh, NC 27699-1617. Your response should include the following:
1. Please explain why process wastewater was discharged by way of the cooling tower. Explain in
detail how long the process wastewater has been discharged to the cooling tower and provide all
analyses demonstrating the characteristics of the wastewater prior to introduction to the cooling
tower. Also provide all daily monitoring reports for both NPDES Permits NCG500148 and
NCS000244 since 2006..
2. Provide the analyses requested by the Division on March 16, 2010, of the soils excavated from the
stormwater discharge outfall. Explain how and where the excavated soils from the stormwater
outfall were disposed.
3. Provide the analyses of the discharge from the cooling tower requested by the Division on March 16,
2010.
4. Have you applied for an industrial user permit with the Northeast Brunswick Wastewater Treatment
Plant? Provide this office with documentation that application had been made. If not, explain why
application was not made.
5. Upon receipt of this notice, you are required to discontinue the discharge of process wastewater to
the cooling tower and/or boiler. You must eliminate all potential means for introducing process
wastewater to the cooling tower. You are not allowed to discharge wastewater via the NCG500148.
You must explain in detail, how you intend to properly dispose of the process wastewater.
6. Please indicate how the wastewater in the receiving stream will be removed and disposed of
appropriately.
Process for applying for an individual wastewater permit:
The person who will be legally responsible for the permit should sign the application form. That person,
and/or company may designate a consultant and/or firm [in writing] to act as their Authorized
Representative. If so, that person can then sign the permit application.
The permit application fee will be $860.00. Fees must be paid by check to NC DENR.
Submit the original (signed) application and two copies, any designation of Authorized Representatives]
and two copies, along with three copies of any of documents listed below:
1. An evaluation of alternatives to discharge is required for all new or expanding
facilities. Consult the guidance document for preparation of Engineering Alternatives
Analyses (EAAs). `

Page 3 of 3
American Distillation Company, Inc.
• Brunswick County
2. Supply the most current USGS flow data available for the receiving stream. Contact Curtis
Weaver at USGS [(919) 5714043] if you do not have current flow data.
3. Consult the Cape Fear River Basin plan on the Division's website
(http://h2o.enr,state.nc.us/basinwide/draftCPFApnl2005.htnt) for the status of the
receiving stream segment. If the stream is unpaired fiom'its stated uses, this may prevent
the issuance of a new NPDES permit.
4. Attach a site map clearly showing the proposed discharge point (a section of a USGS
topographic map is preferred).
5. A process flow diagram of the treatment system, including proposed components sizes
and a facility layout.
6. A completed Local Government Review form [included in the EAA Guidance
Document].
Visit our website[http://www.ncwaterquality.org/NPDES/I for more information on NPDES permitting. If
you have technical questions during preparation of the EAA, contact Dr. Sergei Chernikov at 919 807-
6393.
Thank you for your attention to this matter. This office is considering a recommendation to enforce to the
Division Director. Your above -mentioned response to this correspondence will be considered in this
process. This office requires that the violations, as detailed above, be abated immediately. These
violations and any future violations are subject to a civil penalty assessment of up to $25,000.00 per
day for each violation. Should you have any questions regarding these matters, please contact me at (910)
796-7215.
Sincerely,
Rick Shiver
Wilmington Regional Supervisor
Division of Water Quality
Surface Water Protection Section
cc: WiRO Enf File NPDES NCG500INCS000244 Brunswick NOV-2010-PC-0454
John Hennessy — NPS-ACO Unit, Archdale Building
DWQ Central Files
DWQ CO NPDES Permitting Unit Attn: Matt Matthews
DWQ WiRO Air Quality Attn: Brad Newland
DWQ WiRO Attn. Kipp Glazier
ADI, Barry White P.O. Box 400 Leland, NC 28451

-��i
�r� r � '�

��
i,
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Coleen H. Sullins
Director
April 22, 2010
CERTIFIED MAIL ##7006 0810 0004 4480 9087
RETURN RECEIPT REQUESTED
American Distillation Company, Inc.
Mr. Andy Simmons, President
F.O. Box 400
Leland, NC 28451
Subject: NOTICE OF VIOLATION
NOTICE OF INTENT TO ENFORCE
NOV-2010-PC-0454
American Distillation Company, Inc.
NPDES Permit No. NCG500148
Violation of Permit Conditions
Stream Standard Violation
Brunswick County
Dear Sir:
Dee Freeman
Secretary
While conducting a complaint investigation on March 16, 2010, Linda Willis from the Division of Water
Quality, Surface Water Protection Section in the Wilmington Regional Office, noticed a sheen in a
continuous discharge to Cartwheel Branch from the American. Distillation Company, Inc. facility located at
1690 N.E. Royster Road in Leland, North Carolina. Cartwheel Branch is a Class SC, Sw water of the State
in the Cape Fear River Basin.
The discharge of wastewater from the tolling operations are routed through the cooling tower and/or boiler
which is in violation of the North Carolina General_ Permit NCG500000. The General Permit
(NCG5.00000) allows the discharge of non contact water only. You are hereby required to discontinue this
discharge immediately (upon receipt of this notification) and pursue: 1). either the disposal of the process
wastewater at an approved disposal facility; or 2). apply for and secure an Industrial User Permit from the
Northeast Brunswick Wastewater Treatment Facility for discharge and treatment of the process wastewater
at the regional plant; or 3). apply for an Individual NPDES Permit with the Division of Water Quality.
Samples were collected in stream in Cartwheel Branch that indicated pollutants have been discharged to the
receiving stream from your facility and have resulted in impacts to the surface waters. Dissolved oxygen
was measured to be 0.16 milligrams per liter in the vicinity of the discharge from the cooling tower. The
water quality standard for dissolved oxygen for class Sw waters is an instantaneous value of no less than
4.0 milligrams per liter. As a result of the complaint investigation, the following violations are described
below:
I. Permit Condition Violation
11I. Stream Standard Violation
N. C. Division of Water Ouuardy
Wilmington Regional Of6oe
127 Cardinal Drive Extension. NC 28405
Phone: [phone] FAX: 9103%20041
Customer Service: 1$77-623-6748
Internet www.rxxraterquaky.org
An Equal Opportunity %AilinnaM Action Employer
N6-f Carolina
Naturally

Page 2 of 3
American Distillation Company, Inc.
Brunswick County
Item 1. Permit Condition Violation
The NPDES Permit NCG500000 is specifically for non -contact cooling water, boiler blowdown, cooling
/ r B tower blowdown, condensate, and similar point source discharges. Contact cooling water discharges
require an individual NPDES permit. Non -contact cooling water is defined as water used for cooling
` which does not come into direct contact with any raw material, intermediate product, waste product
or finished product.
Item 11. Stream Standards
15A NCAC 02B.0211 (3)(b) and 15A NCAC 02B.0220 (3)(b) apply due to the classification of the
receiving stream (SC, Sw): Dissolved oxygen: not less than 5.0 milligrams per liter, except that
swamp waters (with a minimum instantaneous value of not less than 4.0 milligrams per liter), poorly
flushed tidally influenced streams or embayments, or estuaring bottom waters may have lower values
if caused by natural conditions.
The discharge of process wastewater to the receiving stream caused a pollutant load to the stream that
depressed the dissolved oxygen content to 0.16 milligrams per liter in violation of the water quality
standard of 4.0 milligrams per liter.
Requested Response
You are directed to respond to this letter in writing within 30 calendar days of receipt of this Notice.
Your response should be sent to both this office at the letterhead address and to the Wetlands and
Stormwater Branch, NPS Assistance and Compliance Oversight Unit, attention John Hennessy, 1617 Mail
Service Center, Raleigh, NC 27699-1617. Your response should include the following:
f 1. Please explain why process wastewater was discharged by way of the cooling tower. Explain in
detail how long the process wastewater has been discharged to the cooling tower and provide all
analyses demonstrating the characteristics of the wastewater prior to introduction to the cooling
tower. Also RLqvide all daily monitoring for both NPDES Permits NCG500148 and
NCS000244 since 2006.
Provide the any sse�alrequested by the Division on March 16,.2010, of the soils excavated from the
stormwater discharge outfall. Explain how and where the excavated soils from the stormwater
outfall were disposed. T-t a eC ke.A arty xjr,-. jnR vf! 6 plcs4-,-c
�3 Provide the analyses of the discharge from the cooling tower requested b� the Division on March 16,
f 2010.
l5 • = Have you applied for an industrial user permit with the Northeast Brunswick Wastewater Treatment
Plant? Provide this office with documentation that application had been made. If not, explain why
application was not made.
f 5. Upon receipt of this notice, you are required to discontinue the discharge of process wastewater to
the cooling tower and/or boiler. You must eliminate all potential means for introducing process
wastewater to the cooling tower. You are not allowed to discharge wastewater via the NCG500148.
You must explain in detail, how . ou intend to properly dispose of the process wastewater. _ Pt7 T�
6. Please indicate how the wastewater in the receiving stream will be removed and disposed of iro
appropriately.
Process for applying for an individual wastewater permit:
The person who will be legally responsible for the permit should sign the application form. That person,
and/or company may designate a consultant and/or firm [in writing] to act as their Authorized
Representative. If so, that person can then sign the permit application.
The permit application fee will be $860.00. Fees must be paid by check to NC DENR.
Submit the original (signed) application and two copies, any designation of Authorized Representative[s]
and two copies, along with three copies of any of documents listed below:
1. An evaluation of alternatives to discharge is required for all new or expanding
facilities. Consult the guidance document for preparation of Engineering Alternatives
Analyses (EAAs).

Page 3 of 3
American Distillation Company, Inc.
Brunswick County
2. Supply the most current USGS flow data available for the receiving stream. Contact Curtis
Weaver at USGS [(919) 5714043] if you do not have current flow data.
3. Consult the Cape Fear River Basin plan on the Division's website
://h2o.enr.state.nc.us/basinwide/draftCPFA ri12005.htm for the status of the
receiving stream segment. If the stream is impaircd from its stated uses, this may prevent
the issuance of a new NPDES permit.
4. Attach a site map clearly showing the proposed discharge point (a section of a USGS
topographic map is preferred).
5. A process flow diagram of the treatment system, including proposed components sizes
and a facility layout.
6. A completed Local Government Review form [included in the EAA Guidance
Document].
Visit our website [http://www.ncwaterquality.org(KPDES/] for more information on NPDES permitting. If
you have technical questions during preparation of the EAA, contact Dr. Sergei Chemikov at 919 807-
6393.
Thank you for your attention to this matter. This office is considering a recommendation to enforce to the
Division Director. Your above -mentioned response to this correspondence will be considered in this
process. This office requires that the violations, as detailed above, be abated immediately. These
violations and any future violations are subject to a civil penalty assessment of up to $25,000.00 per
day for each violation. Should you have any questions regarding these matters, please contact me at (910)
796-7215.
Sincerely,
Rick Shiver
Wilmington Regional Supervisor
Division of -Water Quality
Surface Water Protection Section
CC' WiRO Enf File NPDES NCG500/NCS000244 Brunswick NOV-2010-PC-0454
John Hennessy — NPS-ACO Unit, Archdale Building
DWQ Central Files
DWQ CO NPDES Permitting Unit Attn: Matt Matthews
DWQ WiRO Air Quality Attn: Brad Newland
DWQ WiRO Attn: Kipp Glazier
AD[, Barry White P.O. Box 400 Leland, NC 29451

a
PLocess Water Collection Inventory & Availabil
Tank Trucks
7-20-10 0830
Trailer#
§M:Locathm
0
Parked In HRS Trdiff Yard
CSH 17
�t:a
5,000
5 ow
ALH 26
8,000'
--=L7--
8000
0
Behind %. Tk FarmALH
22
CIE
d
0
Behind So. Tk Farm (SpedW Process H2O
ALH 24
8,000
-, 8,000
0
Behind So. Tk Farm
ALH 20
8,000-- -
"i-
0
East Pad So. Tk Farm (Needs Landing Gear R&M)
ALH 19
8,000
0
0
High Rise has Powession
,Totals
45,000
37
0
Tank Trucks Oad-of-Service
Trailer #
lCapaeft
Iftrw Amftm
jAvailable SpacelLaggM
STH 14
5,500
SSW
0
1 Loaded; U25Lng Grear R&M Required
Totals
515W
SPO
0
Tanks
Tank 9
Cahwwobiv
Aval-lable Space
Loca*m
HRS Tk-51
20,000
20,000
0
HRS Fuel Ptunp Area
HRS Tk-50
16,500
16,500
0
HRS Fuel Pump-Arem
HRS Horn. Tk.
101000
10,000r..,
0
HRS Tank Farm (3rd Hord. Tk) Next to Old Boiler Hs
Prax*.TK
5,500
1 6,500'--"-
0
Behind South Tk Farm (Horizontal Tk)
Tk 249
m000
10,000
0
Behind Boller House (FtW 01 Area
-,
HRS,Bi)x Tk
13,500
8,050
5,450
Egg Side of HRS Tk-14
Insulated Tk
6.000-
610M
0' `'
Across from St _*perew Tk
Tk 64
9,000
9,000
0
So. Tk Farm bSbipper
Tk 65
10,000
1,503'
8,497
So. Tk Farm by-2!!!pper
Water Tk 1
9,000'
.979
8,021
Behind Cooft Tower
Water Tk 2
9,000
7,829
1,171
Behind Cooing Tower
Water Tk 23'
1 OiOOO
7.000'
3,000
Behind Coo Mg Tower (Well Water Tk)
HRS Tk-I 1
",w
30,584
0
HRS Tank Farm
Water Tk 50
:39,000
16,888
13,112
So. Tk Farm by Stripper
HRS 17_
20,000
20,000
0
HRS Tank Farm
HRS 15_20,000
20,000
0
HRS Tank Farm
HRS 4
9,500'
9,500
0
HRS Tank Farm
TOWS
236,5"
I!MW
39,251

ANALYTICAL & CONSULTING
CHEMISTS
Environmental Chemists, Inc.
6602 Windmill Way • Wilmington, NC 28405
[phone] (Lab) • [phone] (Fax)
710 Bowsertown Road • Manteo, NC 27954
[phone]
NCDENR: DWQ CERTIFICATE #94. DLS CERTIFICATE #37729
Customer:
AMERICAN DISTILLATION, INC. Date of Report: May 18, 2009
1690 Royster Road Revised: June 2, 2009. T1Cs added.
Leland, NC 28451 Purchase Order No:
Attn: Hugh Croom
Report Number: 9-3597
REPORT OF ANALYSIS
Date Sampled: 04/23/09
Sampled By: Jay Baker ( Envirochem)
WASTEWATER:
Copy To: Walton Engineering — Ruger Hoech
Pape 1 of 7
Parameter
# 9"1 Method Code
Date
A lry
Biochemical Oxygen Demand, BODi as O-� mg/L
1280
SK 5210 E
04/24/09
Chemical Oxygen Demand, COD mg/L
2-520
SM 5220 D
04/27/09
Ammonia, NH3-N mg/L
< 0?
EPA 350.1
0444/09
Nitrite Nitrogen, NO2-N mg/L
0.23
SM 4500 N42-B
04/24/09
Nitrate Nitrogen, NO3-N mg/L
< 0.02
EPA 353.2,
SM 4500 NO2-B
04/28/09
Total Kjeldahl.Nitrogen, TKN mg/L
75.2
EPA 35L2
04/29/09
Oil & Grease, mg/L
< 5
EPA 1664 A
05/01/09
Phosphorus; as P mg/L
1.68
SM 4500 P IF
04/29/09
Total Dissolved Solids, TDS mg/L
2070
SM 2540 C
04/27/09
Hardness as CaC% mg/L
686
SM 2340 C
05/04/09
Antimony, Sb mg/L
< 0.001
EPA 200.8
05/14/09 , .
Arsenic, As mg/L
0.007
EPA 200.7
04/30/09
Beryllium, Be mg/L
< 0.001
EPA 200.8
05/14/09;
Cadmium, Cd mg/L,
< 0.001
EPA 200.8
05/14/09
Chromium, Cr mg/L
0.005
EPA 200.8
05/14/"
Copper, Cu mg/L
0.104
EPA 200.8
05/14/09'
Lead, Pb mg/L
0.005
EPA 200.8
05/14/09'
Mercury, Kg mg/L
< 0.0002
EPA 245.1
04/27/0
Nickel, Ni mg/L
0.049
EPA 200.9
05/14/09'
Selenium, Se mg/L
< 0.005
EPA 200.7
04/28/04
Silver, Ag mg/L
< 0.001
EPA 200.8
05/14LOI
Thallium. T[ mg/L i
< 0.001
EPA 200.9
05/14/09
Zinc, Zn nig/L I
1.19
EPA 200.9
.05/14/09
Cyanide, CN - mg/L
< 0.005
SM 4500 CN E 1
04/28/
Phenol, mg/L
< 0.004
EPA 420.1 1
05/04/09f
Comment:

Environmental Chemists, Inc.
eiivirochem
ANALYTICAL & CONSULTING
CHEMISTS
6602 Windmill Way • Wilmington, NC 28405
[phone] (Lab) + [phone] (Fax)
710 Bowsertown Road • Manteo, NC 27954
[phone]
NCDENR: DWQ CERTIFICATE #94. DLS CERTIFICATE #37729
Customer: American Distillation Report 9-3597 Page 2 of 7
WASTEWATER: EFFLUENT
Volatiles By EPA 624
I.D. # 9441
Quantitation
Limit ggAL
Analyte pg/L
Acrolein
BQL
20
Acrylonitrile
BQL
4
Benzene
BQL
4
Bromoform
BQL
4
Carbon Tetrachloride
BQL
4
Chlorobenzene
BQL
4
Chlorodibromomethane
BQL
4
Chloroethane "
BQL
4
2-chloroethylvinyl ether
BQL
a
ChloroformBQL.
I 4 I
Dichlorobromomethane
I BQL
4
1,1-dichloroethane
BQL
4
1,2-dichloroethane
BQL
4
Trans-1,2-dichloroethylene
BQL
4
1,1-dichloroethylene
BQL
4
1,2-dichloropropane
BQL
4
1,3-dichloropropyiene
BQL
4
Ethylbenzene
BQL
4
Methyl bromide
BQL
4
Methyl Chloride
BQL
4
Methylene chloride
BQL
4
1,1,2,2-tetrachloroethane ;
BQL
4
Tetrachloroethylene i
BQL
4
Toluene
BQL
4
1,1,1-trichloroethane
BQL
4
1,1,2-trichloroetbane
BQL
4
Trichloroethylene
BQL
4
'vinyl Chloride ;
BQL
4
Analysis Started
04/23/09
i Ana[ysis Comp[etgd
04/27/09
Comments: Quantitatio limit elevated due to sample matrix.
BQL = Below Qua titation Limit
f

PIPP
enviroehem-�
J
ANALYTICAL S CONSULTING
CHEMISTS
Environmental Chemists, Inc.
6602 Windmill Way - Wilmington, NC 28405
[phone] (Lab) • [phone] (Fax)
710 Bowsertown Road- Manteo, NC 27954
[phone]
NCDENR: DWQ CERTIFICATE #94. DLS CERTIFICATE *37729
Customer: American Distillation Report 9-3597 Page 3 of 7
WASTEWATER:
Acid Extractable Compounds
B EPA 625
I.D. # 9411
Quantitation
Limit pgAL
P-Chloro-m-Cresol
BQL '
5.0
2-Chloro henol
BQL
5.0
2,4-dichloro henol
BQL
5.0
24-dimeth l henol
BQL
5.0
4,6-dinitro-o-cresol
BQL
5.0
2,4-dinitro henol
BQL
5.0
2-nitro henol
BQL
5.6
4-nitrophenol
BQL
5.0
Pentachloro henoi
BQL
5.0
Phenol
BQL ,
5.0
i 2,4,b-trichioronhenoE
BQL
5.0
Semi Voiatiies h p EPA 02 5 µx/L
Base -Neutral: Com:..pounds
.,.:
Acena hthene
BQL,
5.0
Acena hth lease
BQL
5.0
Anthracene
BQL
5.0
BenAdine
BQL '
5.0
Benzo a anthracene
BQL
5.0
Benzo a rene
BQL
5.0
3,4-benzofluoranthene
BQL
5.0
Benzo(gio)peryiene
BQL
5.0
Benzo fluoranthene
BQL
5.0
Bis 2-chloroetho methane
BQL
5.0
His 2-chloeoeth 1 ether
BQL
5.0
Bis 2-chloroiso ro 1 ether
BQL ,
5.0
Bis 2-eth the 1 hthalate
BQL
5.0
4-bromo hen 1 phenyl ether
BQL
5.0
Butyl benzyl phthalate
BQL
5.0
2-chlorona hthalene
BQL
5.0
4-chloro hen 1 phenyl ether
BQL)
5.0
Eh serve
BQLe
5.0
D i-n-butyl phthaiate
BQLf
5.0
Di-n-o& hthalate
BQL'
5.0
j Dibenzo(s,b)anthracene ! BQL,' _ - -- -J
5.0
Comments: - -
BQL = Below Quantitation Limit

envirochem
�J
ANALYTICAL & CONSULTING
CHEMISTS
Customer: American Distillation
WASTEWATER: EFFLUENT
Environmental Chemists, Inc.
6662 Windmill Way • Wilmington, NC 28405
[phone] (Lab) • [phone] (Fax)
710 Bowsertown Road • Manteo, NC 27954
[phone]
NCDENR: DWQ CERTIFICATE #94. DLS CERTIFICATE #37729
Report 9-3597
Page 4 of 7
Base Neutral Compounds
I.D. # 9441
Ltitatian
imi
Limit µglL`
1,2-dichlorobenzene
BQL
5.0
1,3-dichlorobenzene
BQL
5.0
1,4-dichlorobenzene
BQL
5.0
3,3'-dichlorobenzidine
BQL
5.0
Diethyl phthalate
BQL
5.0
Dimeth l phthaiate
BQL
5.0
2,4-dinitrotoluene
BQL
5.0
2,6-dinitrotoluene
BQL
5.0
1,2-di hen 1h rdrazine
BQL
5.0
Fiuoranthene
BQL
5.0
Fiuorene
BQL
5.0
Hexachlorobenzene
BQL
5.0
Hexachlorobutadiene
BQL
5.0
Hexachloro elo- entadiene
BQL
5.0
Hexachloroethane
BQL
5.0
lndeno 1,2,3-cd rene
BQL
5.0
Iso horone
BQL
5.0
Naphthalene
BQL
5.0
Nitrobenzene
BQL
5.0
N-nitrosodi-n- ro lamine
BQL
5.0
N-nitrosodimeth lamine
BQL
5.0
N-nitrosodi hen lamine
BQL
5.0
Phenanthrene
BQL
5.0
rene
BQL
5.0
1,2,4-trichlorobenzene
BQL
5.0
Date Extracted
04.423/09
Date Analyzed
04/29/09
Comments:
BQL = Bdow Quantitation Limit

Environmental Chemists, Inc.
enviroc
J
ANALYTICAL & CONSULTING
CHEMISTS
Customer: American Distillation
WASTEWATER: EFFLUENT I
6602 Windmill Way - Wilmington, NC 28405
[phone] (Lab) - (910)3924424(Fax)
710 Bowsertown Road • Manteo, NC 27954
[phone]
NCDENR: DWQ CERTIFICATE #94, DL5 CERTIFICATE #37729
Report 9-3597 Page 5 of 7
Analyte mg/L
# 9441
Date
PQL
Method
Analyzed
mg/L
Codes
Tert-butyl Alcohol
BQL
05/06/09
1.0
SW-846
8015
Tert-butyl hydroxyperoxide
BQL
05/06/09
1.0
SW-846
8015
Methanol
BQL
05/06/09
1.0
SW-846
8015
Ethanol
BQL
05/06/00,
1.0 SW-846 i
8015
isopropy! Aiconoi
BQL
05/06/09
SW-846 �
LC `
8015
Acetone ,
; 3.38
I
04127/09
-
0.005 ' EPA 524.
Comments:
BQL: Below Quantitation Limit
PQL: Practical Quantitation Limit,
Reviewed by: /

envirochiem
isw
ANALYTICAL & CONSULTING
CHEMISTS
Environmental Chemists, Inc.
6602 Windmill Way • Wilmington, NC 28405
(910) 392=0223 (Lab) • [phone] (Fax)
710 Bowsertown Road • Manteo, NC 27954
[phone]
NCDENR: DWQ CERTIFICATE #94. DLS CERTIFICATE 437729
Customer: American Distillation Report No. 9-3597 Page 6 of 7
Effluent Lab LD. # 9441 - Results of Library Search Compounds for 624
Number
1
2
3
4
Compound
Isopropyl alcohol
tert-Butyl alcohol
Comment:
CAS #
67-63-0
75-65-0
Match
Result
Probability
µg/L
93
160
74
22.2
Tentatively Identified Compound (TIC) refers to substances which are not present in
the list of target compounds. Therefore, not all TICS are identified and quantitated
using individual standards. TIC listings are prepared utilizing a computerized library
search of electron impact mass spectral data and evaluation of the relevant data by a
mass spectral data specialist. S..
Quantitation is accomplished by relative peak height of the comp®und compared
to that of the nearest internal standard from the total ion chroma)ograph. TICS are
identified and quantitated only if the peak height is equal to or greater than 10%
of the nearest internal standard. Quantitation provided is as estimate.
r"

r
s'sMl
ANALYTICAL & CONSULTING
CHEMISTS
Environmental Chemists, Inc.
6602 Windmill Way • Wilmington, NC 28405
[phone] (Lab) (910)-392-4424 (Fax)
710 Bowsertown Road • Manteo, NC 27954
(252)'473-5702
NCDENR: DWQ CERTIFICATE #94. DLS CERTIFICATE #37729
Customer: American Distillation Report No. 9-3597 Page 7 of 7
Effluent Lab LD. # 9441 - Results of Library Search Compounds for 625
Number Compound CAS # Match Result
Probability µglL
1
Methyl sulfoxide
67-68-5
82.7
47.2
2
Diethylformamide
617-84-5
84.8
21.7
3
Unknown
NA
NA
16.3
f
Unknown
NA
NA
12.7
5
Unknown
NA
NA
18.7
Piperdinooxy- 4-hydro-2,2,6,E--
6
tetramethyl
2226-8(-2
81.3
69.?:
7
Tributyl-phosphine oxide
814-�29-9
91.8'
64.4
8
Unknown
NA
NA
21.7
9
Unknown
NA
NA
21.1
1.0
Unknown
NA
NA
14.2
c
Comment:
Tentatively Identified. Compound (TIC) refers to substances which are not present in
the list of target compounds. Therefore, not all TICs are identified and quantitated
4.. using individual standards. TIC listings are prepared utilizing a computerized library
search of electron impact mass -spectral data and evaluation of the relevant data by a
. mass spectral spectral data specialist.
Quantitation is accomplished by relative peak height of the compound compared
{I to that of the nearest internal standard from the total ion chromatograph. TICS are
identified and quantitated only if the peak height is equal to or.greater than 10%
r of the nearest internal standard. Quantitation provided is an estimate.

ENVIRONMENTAL. CHEMISTS, INC
Analytical ACoii4ultincq Chemists NCDENR; DWQ CERTERICATION 9 94 NCDHI IS: nl_S CEnitrICATION 0 37729
COLLECTION AND CHAIN QF CUSTODY
CLIENT: ` ` f ' PROJECT NAME: T
1IN6602 Windmill Way WiimingtM NC 20405
OFFICE: 910-392-0223 FAX [phone] ,
REPORT NO:
ADDRESS:—.— CONTACT NAME:PO NO:
REPORT TO r'i� ^� £'��,�! a<r+ ,. PHONEWAX•
� r
COPY TO: �4•!fa� �� _ E-MAIL:
Sampled Bv: t� SAMPLE TYPE. I = Influent, E = Efiiuent. W a Well, ST a Stream, SO - Soil. SL a Sludtla. Other.
PRESERVATION
UffAwm
��mm�Mm
Iloilo
1111
NINO
]NOTICE - DECHLORINATION: Samples for Amamnk, TKk. Clanl+ds, Pbw4awAaectarts must be dechlorinsted f0.2 ppm or Ines) In We IFeld at tlro tlme of cotlactlon. Sae reverse Ior Instructlant
Transfer Reli felted Detelfime Recefved`13 ; DateMme
[Z.-
Temperature wheiw Received: Accepted:
Delivered
Br:=..G_�.yP�' Received Byt
Comments:
Resample Requested:
Date: y ya3-0 Time;
TURNAROUNn-

K. envirochem
ANALYTICAL &CONSULTING
CHEMISTS
Date: June 2, 2009
American Distillaton ID: Effluent
Envirochem ID: 9-3597
Environmental Chemists, Inc.
6602 Windmill Way • Wilmington, NC 28405
[phone] (Lab) - [phone] (fax)
710 Bowsertown Road • Manteo, NC 27954
[phone]
NCDENR: DWQ CERTIFICATE #94. DLS CERTIFICATE #37729
CASE NARRATIVE
An effluent sample was received from American Distillation April 23 for analysis of various
water quality parameters, trace metals and organics by methods 624 (volatiles) and 625 (semi-
volatiles.)
The original report on May 18 was issued showing the 624 and 625 below quantitation limit for
ali the targei'anaiytes. I-loweve:. nor -target compounds were detected.
Tentativeiv identified compounds (TICS) were measured in the 624 and 625 analyses to loop for
organic compounds that may have contributed to the BOD detected at 1280 mg/L.
Two alcohols were tentatively identified in the 624. While the compounds listed were shown as
below quantitation iimit in the original report, the GUMS used in 624 was able to detect these
analytes at lower concentrations than the original method (8015) used.
(..
Ten tentatively identified compounds were quantified in the 625 analysis. However, this analysis
showed dozens of individual compounds in addition to the ones listed on the TIC report. The
chromatogram created by the 625 analysis is similar in appearance to a chromatogram expected
for a material such as aged diesel or heating oil.
The additional compounds not included in the original report may -have had a significant
contribution to the BOD measured in the sample.
Additionally, the BOD is confirmed by the COD value, 2520 mg/L.
between the two parameters.
This is good �greement
1
1
I :
I
�I
C:
- I

AWA NC DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
MCDEM INDUSTRIAL STORM WATER INSPECTION FORM
WILMINGTON REGIONAL OFFICE
Facility: American Distillation
Date: 03/200
Location Address: 1690 NE Royster Rd, Leland NC 28451
COC #: CNCS000244
M-G50
Contact Name: af14 - Ic-Wom°
Phone Number: 9I0-371-0993
Contact Mailing Address: See above
County: Brunswick
Directions:
From Leland take Old Mill Rd to Navassa, turn right onto Royster, go to gatepush button, request entry
x
fiance} 7RautinepGom _
p l�ispbefio
Rescission Request
Complaint Investigation
x
Other— Explain a -R `waU
A.
STORM WATER POLLUTION PREVENTION PLAN
Yes
No
NIA
Comments
1.
Is a copy of the signed and certified SWPPP at the facility?
x
Plan needs updating with
2.
Does the facility's SWPPP address the minimum BMP requirements?
better BMPs to address
issues stated in cover J
letter and inspection
report.
No amendments appear
3.
Are amendments to the SWPPP clearly documented?
x
to have been done to
plan and the annual
review has not been
documented.
Plan needs some
4.
Is the current SWPPP complete?
x
improvement
B.
VEHICLE EQUIPMENT
Yes
No
NIA
1.
Were the vehicle/equipment maintenance areas inspected?
x
2.
Are vehicle/machinery leaks and drips properly managed?
x
3.
Is vehicle/equipment washing done in a designed area so that wash water
x
can be properly managed?
Tanker pad does not
4.
Was the vehicle fueling area inspected?
x
5.
Are vehicle maintenance activities kept indoors?
x
6.
Were the vehicle/equipment storage areas inspected?
x
provide secondary
containment. If tankers
are empty, no problem.
If storing recyclable
product, secondary
containment should be
provided
7.
Are current BMPs in vehicle/equipment/fueling areas adequate?
x
C.
`WASTE MANAGEMENT
Yes
No
N/A
1.
Are containers for temporary storage of wastes labeled?
x
2.
Are waste materials recycled?
x
3.
Are hazardous wastes properly handled and disposed of?
x

4.
Is processed debris removed regularly?
x
Secondary containment
5.
Is there secondary containment for liquid wastes?
x
is not provided for
storage of hazardous
substances in 55 ��' 11
drums. Large tanks
located outside the
secondary containment
(near small stormwater
containment pond) had
no locked valves.
Need to modify and
6.
Are current waste management BMPs adequate?
x
implement additional
BMPs
See previous comments
D.
MATERIAL STORAGE
Yes
No
N/A
1.
Are there appropriate BMPs for outdoor storage of raw materials,
x
products, and byproducts?
See previous comments
See previous comments
2.
Are containers for chemical substances labeled?
x
3.
Is there secondary containment for liquid storage?
x
4.
Are current BMPs in material storage areas adequate?
x
E.
SPILL CONTROL
Yes
No
NIA
Comments
1.
Are there procedures for spill response and cleanup?
x
2.
Are appropriate spill containment and cleanup materials kept on -site and
x
in convenient locations?
One unidentified outfall
3.
Are used absorbent materials disposed of in a timely manner?
x
4.
Are current spill BMPs adequate?
x
F.
EROSION
Yes
No
NIA
1.
Are unpaved outdoor areas protected from water/wind erosion?
x
2.
Are drainage ditches or the areas around the outfalls free of erosion?
x
3.
Do. implemented BMPs appear effective in controlling erosion?
x
G.
NON -STORM WATER MANAGEMENT
Yes
No
N/A
1.
Have all illicit water discharges been eliminated or permitted?
x
exists at the west end of
the large stomrwater
containment pond
controlled by a release
valve directly to the
adjacent wetlands
2.
Are BMPs for authorized non -storm water discharges properly
x
implemented?
3.
Are current BMPs adequate for management of authorized norworm
x
water discharges?
Regional Office requests
.14.
PROCESS' '.WAS TEWATER'CONTROLS.AND MONITORING
Yes
No
NIA
1.
Are wastewater treatment facilities properly maintained?
x
2.
Has monitoring been done?
x
the quantitative and
qualitative monitoring
reports since 2004 to

present time.
Ditches are used as the
I.
STREAM OBSERVATIONAWACTS
Yes
No
NIA
1.
Were there any stream impacts?
x
conveyance in most
instances with the
exception of the release
valve at the west end of
large stormwater
containment pond.
There was a small
2.
Were field parameters taken for pH or DO?
x
3.
Were there any stream standard violations/
x
amount of petroleum oil
in the stormwater ditch.
Representatives asked
Mr. Croom to be sure to
have someone put an
absorbent boom in the
ditch to remove the oil.
4.
Were there excessive solids in the -stream?
x
5.
Were pictures taken?
x
6.
Were samples taken?
x
J.
SUMMARY / ADDITIONAL COMMENTS
1. Please put locks on all large tanks outside of secondary containment immediately. 2. Provide the Regional Office with a copy of
all monitoring reports since 2604 for review. 3. Valve leading to wetlands located at the west end of the large stormwater retention
pond needs to be identified as an outfall and included on the site map. Monitoring will be required prior to any release. 4. Adjacent
to the Stormwater swale is an area of old equipment and metal parts. It appeared there was a spill of petroleum products tothe
ground which requires proper clean up and disposal. S. There was a discharge of oil to the swale in the proximity of the petroleum
spill on -the ground. Division Representative asked that it be cleaned up from the swale immediately using booms, please verfy that
this has been done. 6. Many bulk tanks are used on.site for storage of product to be tolled and final product. The tanks in some
cases are in extremely corroded condition. Mr. Croom indicated the tanks are inspected and the structural integritymonitored on a
regular basis. Please include the dates of inspections and the results of the inspections in the SWPPP amendments each timethis
activity is conducted. Comment on the actions taken as a result of the recommendations. from those inspections 7. Division
Representatives recommended that analytical monitoring of stormwater include analyses that demonstrate the absence of organis
that cannot be detected by site (sheen, foam, color, miscibility) prior to any release from secondary containmentstructures in
accordance with Table 1. An#]3qical Monitoring re u' Results should be compared to the benchmark cutoffs given in Tible
o ermtt. Should values' exceed the benchmark, the permittee should identify an appropriate disposabption rather than
discharge to surface waters of the State. Mr. Croom was informed that the upcoming benchmarks in the renewed permit should
serve as an indicator for concern should stormwater analytical results. exceed those levels. Division Representaives discussed the
high concentrations present in the discharges in July and October of 2003, indicating this was an example of a slug of organs that
had been discharged with stormwater. Those levels indicate a spill occurred but was not documented inthe qualitative inspections.
This supports the request to analyze the contents of the secondary containment structures prior to any release. It is possible
that the organics present in that stormwater discharge may have not been obvious by visual.inspetion alone. S. The stormwater
pollution prevention plan also requires an SPRP (Spill Prevention and Response Plan) component identifying potential.pollutait
sources based upon a materials inventory: That was not seen in the SPRP. 9. Hazardous waste storage area needs to have
secondary containment. Drum storage area needs secondary containment due to the hazardous nature of the materials and is a
requirement of the SPRP. 10. _ �, -recycle-i€rontamts
odischer �s and bailers for rrn 'z�
Boiler Blowdown is sent to the small stormwater nond and reused in, the cooling towers. The R is
qluesdangWqgn :V and pass through and concentration of contaminants may pose problems. 1t is also co mingled with atom water.
The NCG500000 permit does not provide stringent enough monitoring to ensure protection of surface waters.
K.
RATING LEVEL (CIRCLE ONE:1
l .
Indusry in substantial compliance
2.
Minor deficiencies noted. Revist scheduled for June 2007

13. _ , I Major deficiencies or discharges noted and require prompt correction. Revisit scheduled for
4. 1 Critical deficiencies or discharges noted and require immediate correction. Revisit scheduled for
(date).
(date).
5. Rescission'is appropriate.
6. Rescission is not appropriate. Please d
Logged by:
Inspected by Linda Willis
March
19, 2007
L. Include a Map of the facility. This drawing should depict the building, parking, process, and storage areas.
If you do not have a.map, draw one or request that the facility provide you one in your written
correspondence.
Map included
M. Develop a Vicinity Map for the file.
Map included
N. Identify all records that were reviewed.
Qualitative records hrough July 2004 (no notice of visible contaminants) Records should show visual
observations for the month of March 2007, in lieu of the findings on site during the inspection.
Quantitative analyses shows significant contamination left the site via stormater discharge on in July and
October of 2003.
O. Explain how Secondary Containment is being used and whether these measures are bring properly
maintained. [Did you observe that the secondary containment had release valves (were they open, locked
etc.), was there water, waste product, sheen, etc observed within the secondary containment area? Explain
your observations] _
No wastewater within containment areas. Several large bulk tanks outside of the secondary containment
areas had product or waste material inthem with no locking mechanisms. There were indications of past
spills on the tank pad areas outside the containment area. The tanks located near the small stormwater
containment pond did not have a surface graded towards a sump that could isolate a spll If a spill were to
occur it would make it to sandy soil and if large enough to the stormwater ditch.
P. House keeping and best management practices (maintenance of BMPs) status.
Fairly good, however drummed storage areas need secondary containment consisting the hazardous nature
of the materials. The hazardous waste storage pad requires secondary containment.
Q. Identify outfalls and receiving waters. List any observation or concerns.
One outfall near the large stormwater containment pond needs to be idatified in the plan and in the permit.
R. Take digital photographs to support staff report observations and to provide assistance to future inspectors).
Io- ictur m-wereFtaken.during.this-visit
Logged by: Inspector: Linda Willis WiRO, Ken Pickle
and Kelly Johnson CO

1
. 0� wAT�q pG
N*MOP IF,
American Distillation, Inc.
Attn: Mr. Hugh Croom
1690 NE Royster Road
Leland, NC 28451
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Departn=t.of Environment and Natural Resources
March 27, 2008
SUBJECT: Compliance Evaluation Inspection
American Distillation
NCS0002441NCG500148
Brunswick
Dear Mr. Croom:
Alan W. Klimek, RE. Director
Division of Water Quality
On March 24, 2008 staff of the Division of Water Quality Central and Wilmington Regional
Offices, performed an inspection of the subject facility. As part of the inspection, a tour of your facility
was conducted. All observations and recommendations are noted in the (Summary of
findingslcomments) of this inspection report. Remember, it is our goal to insure the quality of the
surface waters of this State.
Please review the attached report. If you or your staff have any questions, do not hesitate to
contact me at 796-7333.
Sincere y,
Wes Hare
Wilmington Regional Office
cc: DWQIRaleigh Central Files
NPDESYGenera!"Permit:lnspectiod"Files t8runswick'County)�
NPS Assistance and Compliance Oversight/Raleigh
None Carolina
Nturu!!y
North Carolina Division of Water Quality 127 Cardinal Drive Extension Wilmington, NC 28405 Phone [phone]
Internet: wwA-.ncwaterquality.org Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycted110% Post Consumer Paper
Customer Service
1-877-623-6748

United states Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 204W
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 UN 2 ) .9 31 NCG500148 111 121 -- 08/03/24 117
U i L
181 rl 191 c! 20U
J U
Remarks
2111111111111111111111.1111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
-----Reserved - - - - --
67 L 169 70! f 71 I I 72 UN
73 L1J 74 751 I I I I 1 i 180
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 permit Number)
09:05 AM 08/03/24
07/08/01
American Distillation Company
Exit Time/Dale
Permit Expiration Date
1690 Ne RoyBter Rd
Leland NC 28451
10:30 AM 08/03/24
12/07/31
Name(s) of Onsite Representafive(s)lTtles(syPhone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/TitlelPhone and Fax Number
Contacted
Earl SiMMOnS,PO Box 400 Leland NC 2B452//910-371-0993/9103712971
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Records/Reports Facility Site Review
Effluent/Receiving Waters
Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of inspecto ) Agency/Office/Phone and Fax Numbers Date
Wes Hare WIRO WQ//910-796-7215/
Ol f
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3I NCG500148 I11 12� 08/03/24 J 17 isUC
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
There were no compliance issues regarding permit NCG5000148.
Page # 2

Permit: NCG500148 Owner - Faculty: American Distillation Company
Inspection Date: 03/24/2008 Inspection Type: Compliance Evaluation
V.. IJn MA WF
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ■ ❑ 0 0
Is the facility as described in the permit? ■ ❑ ❑ ❑
# Are there any special conditions for the permit? ■ ❑ Q ❑
Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑
Is'the inspector granted access to all areas for inspection? ■ ❑ Q Q
Comment:
Page # 3

Permit: NCS000244
SOC:
County: Brunswick
Region: Wilmington
Compliance Inspection Report
Effective: 09/01 /07
Effective:
Contact Person: Joseph Spahr
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
Expiration: 08/31/12 Owner: American Distillation Co Inc
Expiration: Facility: American Distillation Co Inc
Prs16- Rd
L..ec 4Nb 2t3'fs-/
J+l WmiaA� NC-R h
Title: Phone: [phone]
On -Site Representative(s): ff 6C0V-A�
/!?.hex "t7-dN
Related Permits:
Inspection Date: 03/24/2008 Entry Time: 09:05 AM
Primary Inspector: Wes Hare
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
0 Other
(See attachment summary)
Certification: Phone:
Exit Time: 10:30 AM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000244 Owner - Facility: American Distillation Co Inc
Inspection Date: 03/24/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Laboratory data for this facility displays a history of benchmark exceedances for BOD, COD and TSS. While these are not
permit "limits", the permit states the permittee shall investigate sources and remedies to any exceedances. It is noted that
the site staff (Hugh Croom and Mark Walton) has been looking into the source(s) of BOD and COD contribution, as well
reengineering the stormwater containment and discharge appurtenances.
Other
Comment:
Yes No NA NE
Page: 2

i�
x - t
�0 WATF�p
O � G
1 c
7 �
0
American Distillation, Inc.
Attn: Mr. Croom
1690 NE Royster Road
Leland, NC 28451
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
March 19, 2007
SUBJECT: Compliance Evaluation Inspection
American Distillation
NCS0002441NCG500148
Brunswick
Dear Mr. Croom:
Alan W. Klimek, P.E. Director
Division of Water Quality
On March 15, 2007, Ken Pickle, Kelly Johnson and Linda Willis, of the Division of Water Quality
Central and Wilmington Regional Offices, performed an inspection of the subject facility. As part of the
inspection, a tour of your facility was conducted. All observations and recommendations are noted in
the (Summary of findings/comments) of this inspection report. Remember, it is our goal to insure the
quality of the surface waters of this State.
Please review the attached report. If you or your staff have any questions, do not hesitate to
contact me at 796-7343.
Sincerely,
Linda Willis
Environmental Engineer
Wilmington Regional Office
Enclosures
cc: WiRO files (Brunswick stormwater inspection file)(YIP
Central files(I�
*RO/DWQ Stormwater Compliance Files
Stormwater Permitting Unit
NPS and Compliance Oversight
r4o Caro ina
,�atura�ly
North Carolina Division of Water Quality 127 Cardinal Drive Extension Wilmington, NC 28405 Phone [phone] Customer Service
Internet: www.ncwatcrauality.ora Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

NC DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
}' 4 ENR INDUSTRIAL STORM WATER INSPECTION FORM
WILMINGTON REGIONAL OFFICE
Facility: American Distillation
Date: 03/15/2007
Location Address: 1690 NE Royster Rd, Leland NC 28451
COC #: NCS000244
NCG500148
Contact Name: Hugh Croom
one Number: 910-371-0993
Contact Mailing Address: See above
County: Brunswick
Directions:
From Leland take Old Mill Rd to Navassa, turn right onto Royster, go to gate push button, request entry
x
Routine Compliance Inspection
Rescission Request
Complaint Investigation
x
Other — Explain Permit Renewal
STORM.WATER'POLLUTION PREVENTIIOM I AN
Yes
No
NIA
Comments
1.
Is a copy of the signed and certified SWPPP at the facility?
x
Plan needs updating with
2.
Does the facility's SWPPP address the minimum BMP requirements?
better BMPs to address
issues stated in cover
letter and inspection
report.
No amendments appear
3.
Are amendments to the SWPPP clearly documented?
x
to have been done to
plan and the annual
review has not been
documented.
PIan needs some
4.
Is the current SWPPP complete?
x
improvement
B�
VEHICLE EQ[FIPMENT;�f"Y. :`,
Yes
No
NIA
1.
Were the vehicle/equipment maintenance areas inspected?
x
2.
Are vehicle/machinery leaks and drips properly managed?
x
3.
Is vehicle/equipment washing done in a designed area so that wash water
x
can be properly managed?
Tanker pad does not
4.
Was the vehicle fueling area inspected?
x
5.
Are vehicle maintenance activities kept indoors?
x
6.
Were the vehicle/equipment storage areas inspected?
x
provide secondary
containment. If tankers
are empty, no problem.
If storing recyclable
product, secondary
containment should be
provided
7.
Are current BMPs in vehicle/equipmentlfueling areas adequate?
x
`C N
. �'.�. ,: �z 5.- �-.x a-yv;'t.�,�:
MANAGEMENT �r �� y ` `; �5
Yes
No
NIA
ssy:WASTE
.1'
'
1.
Are containers for temporary storage of wastes labeled?
x
2.
Are waste materials recycled?
x
3.
Are hazardous wastes properly handled and disposed of?
x

4.
Is processed debris removed regularly?
x
Secondary containment
5.
Is there secondary containment for liquid wastes?
x
is not provided for
storage of hazardous
substances in 55 gallon
drums. Large tanks
located outside the
secondary containment
(near small stormwater
containment pond) had
no locked valves.
Need to modify and
6.
Are current waste management BMPs adequate?
x
implement additional
BMPs
See previous comments
D
MATERIAL STORAGE:-
Yes
No
NIA'�
1 .
Are there appropriate BMPs for outdoor storage of raw materials,
x
products, and byproducts?
See previous comments
See previous comments
2.
Are containers for chemical substances labeled?
x
3.
Is there secondary containment for liquid storage?
x
4.
Are current BMPs in material storage areas adequate?
x
E:
spf". C ON TROL..r!
es
N o
N/A
Comments
1.
Are there procedures for spill response and cleanup?
x
2.
Are appropriate spill containment and cleanup materials kept on -site and
x
in convenient locations?
3.
Are used absorbent materials disposed of in a timely manner?
X
4.
Are current spill BMPs adequate?
X
,E
Yes
No
N/A
1.
Are unpaved outdoor areas protected from water/wind erosion?
x
2.
Are drainage ditches or the areas around the outfalls free of erosion?
x
3.
Do implemented BMPs appear effective in controlling erosion?
x
V,
STOR
M ORMWATER MANAGEMENT'
Yes
No
N/A
One unidentified outfall
I
Have all illicit water discharges been eliminated or permitted?
x
exists at the west end of
the large stonirwater
containment pond
controlled by a release
valve directly to the
adjacent wetlands
2.
Are BMPs for authorized non -storm water discharges properly
x
implemented?
3.
Are current BMPs adequate for management of authorized non -storm
x
water discharges?
0 S5"TEWAJM'C0NTR0LS;"�
CONTROLS
Yes
No
N/A
, S " 4-.- ­­ .. , -Mmimp . —
Regional Office requests
1.
Are wastewater treatment facilities properly maintained?
—
—
x
2.
Has monitoring been done?
x
the quantitative and
qualitative monitoring
reports since 2004 to

present time.
I f
STREAM OBSER pATION/IMPACTS nw
Yes
No
NIA
,
ru
Ditches are used as the
1.
Were there any stream impacts?
x
conveyance in most
instances with the
exception of the release
valve at the west end of
large stormwater
containment pond.
There was a small
2.
Were field parameters taken for pH or DO?
x
3.
Were there any stream standard violations/
x
amount of petroleum oil
in the stormwater ditch.
Representatives asked
Mr. Croom to be sure to
have someone put an
absorbent boom in the
ditch to remove the oil.
4.
Were there excessive solids in the stream?
x
5.
Were pictures taken?
x
6.
Were samples taken?
x
SUMMARY /,ADDITIONAL:COMMENTS`
1. Please put locks on all large tanks outside of secondary containment immediately. 2. Provide the Regional Office with a copy of
all monitoring reports since 2004 for review. 3. Valve leading to wetlands located at the west end of the large stormwater retention
pond needs to be identified as an outfall and included on the site map. Monitoring will be required prior to any release. 4. Adjacent
to the Stormwater swale is an area of old equipment and metal parts. It appeared there was a spill of petroleum products to the
ground which requires proper clean up and disposal. 5. There was a discharge of oil to the swale in the proximity of the petroleum
spill on the ground. Division Representative asked that it be cleaned up from.the swale immediately using booms, please verify that
this has been done. 6. Many bulk tanks are used on site for storage of product to be tolled and final product. The tanks in some
cases are in extremely corroded condition. Mr. Croom indicated the tanks are inspected and the structural integrity monitored on a
regular basis. Please include the dates of inspections and the results of the inspections in the SWPPP amendments each time this
activity is conducted. Comment on the actions taken as a result of the recommendations from those inspections. 7. Division
Representatives recommended that analytical monitoring of stormwater include analyses that demonstrate the absence of organics
that cannot be detected by site (sheen, foam, color, niiscibility) prior to any release from secondary containment structures in
accordance with Table 1. Analytical Monitoring requirements. Results should be compared to the benchmark cutoffs given in Table
3 of your new permit. Should values exceed the benchmark, the permittee should identify an appropriate disposal option rather than
discharge to surface waters of the State. Mr. Croom was informed that the upcoming benchmarks in the renewed permit should
serve as an indicator for concern should stormwater analytical results exceed those levels. Division Representatives discussed the
high concentrations present in the discharges in July and October of 2003, indicating this was an example of a slug of organics that
had been discharged with stormwater. Those levels indicate a spill occurred but was not documented in the qualitative inspections.
This supports the request to analyze the contents of the secondary containment structures prior to any release. It is possible
that the organics present in that stormwater discharge may have not been obvious by visual inspection alone. 8. The stormwater
pollution prevention plan also requires an SPRP (Spill Prevention and Response Plan) component identifying potential pollutant
sources based upon a materials inventory. That was not seen in the SPRP. 4. Hazardous waste storage area needs to have
secondary containment. Drum storage area needs secondary containment due to the hazardous nature of the materials and is a
requirement of the SPRP. 10. Distillation process wastewater is sent to Tank 23 for recycle if contaminants are too high to
discharge or sent to the cooling towers and boilers for reuse. The blowdown is sent to the small stormwater pond.
Boiler Blowdown is sent to the small stormwater pond and reused in the cooling towers. The Wilmington Regional Office requests
that NCG500148 be consolidated under NCS000255 and monitored in accordance with that permit since the source water is of
questionable quality and pass through and concentration of contaminants may pose problems. It is also co mingled with stormwater.
The NCG500000 permit does not provide stringent enough monitoring to ensure protection of surface waters.
K
--
i v
MA G LEVEL. (CIRCLE ONE 1-6 r,'c., �� >Y�h
.i^.^a �FRfc ��''tN
ice.. 9'-� i1 ,i,•
.Gr �.:�`x.��...�sr fa. M'C�;,°?1. .,,ie!�
1.
Indusry in substantial compliance
June 2007
2.
Minor deficiencies noted. Revist scheduled for

Major deficiencies or discharges noted and require prompt correction. Revisit scheduled for (date).
4. 1 Critical deficiencies or discharges noted and require immediate correction. Revisit scheduled for (date).
Rescission is appropriate.
6. Rescission is not appropriate. Please renew permit in accordance with the draft prepared March
March 5, 2007 and include the boiler blowdown and cooling tower condensate into 1 g, 2007
NCS000244, eliminating NCG500148. (Note: permit # is NCS000244)
Logged by: Inspected by Linda Willis
L. Include a Map of the facility. This drawing should depict the building, parking, process, and storage areas.
If you do not have a map, draw one or request that the facility provide you one in your written
correspondence.
Map included
M. Develop a Vicinity Map for the file.
Map included
N. Identify all records that were reviewed.
Qualitative records through July 2004 (no notice of visible contaminants) Records should show visual
observations for the month of March 2007, in lieu of the findings on site during the inspection.
Quantitative analyses shows significant contamination left the site via stormwater on in July and
October of 2003.
O. Explain how Secondary Containment is being used and whether these measurer _ ; _operly
maintained. [Did you observe that the secondary containment had relear- , gives (were they open, locked
ctc.), was there water, waste product, sheen, etc observed within .L •�,:ondary containment area? Explain
u wastewater within containnit:i— " ; : ;urge bulk tanks outside of the secondary containment
areas had product or waste material in them wi no locking mechanisms. There were indications of past
spills -on the tank pad areas outside the containment area. The tanks located near the small.stormwater
containment pond did not have a surface graded towards a sump that could isolate a spill. If a spill were to
occur it would make it to sandy soil and if large enough to the stormwater ditch.
P. House keeping and best management practices (maintenance of BMPs) status.
Fairly good, however drummed storage areas need secondary containment considering the hazardous nature
of the materials. The. hazardous waste storage pad requires secondary containment.
Q. Identify outfalls and receiving waters. List any observation or concerns.
One outfall near the large stormwater containment pond needs to be identified in the plan and in the permit.
R. Take digital photographs to support staff report observations and to provide assistance to future inspectors).
No pictures were taken during this visit.
Logged by: Inspector: Linda Willis WiRO, Ken Pickle
and Kelly Johnson CO

691)f'IE=fioy�:t \ �cr;l(I.;_Lr lnd..r•foith a i iri
44
IL
,, ` •. i, ' „ - -•� � Cji -.I} l,, J' .' tst r�' � r�V % -� . � ` j .l!
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;PuiMe'l '4='15'42'.j.:` N .'•78, 4b'25.4d_ V-J ulu'f' 23 11-.'.-.- -- "�_Jtrc,�sriin;=;I#llll#II= 1QU5c E ;o': DII 2L i3 [I

��Z t •, P�,4}� �y., -"L'1 :Sep
ANALYTICAL & CONSULTING
CHEMISTS
Customer:
AMERICAN DISTILLATION, INC.
1690 M E. Royster Road
Leland, NC 28425
Attn: Hugh Croom
Date Sampled: 01/26/09
Sampled By. Client
C00UNG TOWER: Blow Down
Environmental Chemists, Inc.
6602 Windmill Wav • Wilmington. NC 2$ 405
(')10) 392-G223 (L,ib) (9111)392•-442-i (Fax?
710 Bowscrtntvn Road a Manteo, NC 27Q,-4
(252) :173-5702
NCDENR: DWQ1 CER11FICATi: 094, I)I.S CEP.f1FIC ATE k37:24
Date of Report: February 9, 2009
Purchase Order No:
Report Number: 9-701
REPORT OF ANALYSIS
Pace I of 2
Paralg4leter
L .-N-24U
Method Code
Analyzed
Biochemical Oxygen Demand,BOD$ as OZ mg/L
1400 '
SM 5210 B
01/28/09
Total -Suspended Solids, TSS mg/L
61
SM 2540 D
01/26/09
Chemical Oxygen Demand, COD as OZ mg/L
3540
SM 5220 D
02/02/09
moma gen, 3- mg/L
2.3
EPA 350.1
01/28/09
Cyanide, CN- mg/L
0.005
SM 45M CN E
02/05/09
Arsenic, As, mg/L
< 0.002
EPA 200.9
01129/09
Cadmium, Cd mg/L
< 0.001
EPA 200.7
02/03/09
Chromium, Cr mg/L
0.041
EPA 200.7
02/02/09
Copper, Cu mg/L
0.187
EPA 200.7
02/02/09
Lead, Pb mg/L
0.086
EPA 200.7
02/02/09
Mercury, Hg mg/L
< 0.0002
EPA 245.1
02/03/09
Nickel, Ni mg/L
0.021
EPA 2W.7
02/02/09
Silver, Ag mg/L
< 0.005
EPA 200.7
02/03/09
Zinc, Zn mg/L
0.404
EPA 200.7
02/02/09
61 & Grease, mg/L
11
SM 1664 A_
02/02/09
Comments:
itECEIVED EEB 2 0 NO#
T -d 98*UTLE0T6 uaNi T T TW uynC e65:60 60 ♦,2 qaj

ANALYTICAL & CONSULTING
CHEMISTS
Customer: American Distillation
UnnlinF Tnwer- Blow Down
Environmental Chemists, Inc.
6602 Windtnili l'V�n Wilminglntl. KC 2S405
710 i3owscrto n Road • Wntev, KC 27q!;4
VCC-4=\R- DWQ CERTIFICATE N'44- EiLtiC FRTIFiCAT1: 4.;; i_c)
9-701
Page 2 of 2
Quantitation
Parameter, mg/L
LD. # 2418
Limit /L
ni
Tert-butyl alcohol
BQL
1.0
Tert-butyl hydroxyperoxide
BQL
1.0
Methanol
BQL
1.0
Ethanol
BQL
1.0
Isopropyl Alcohol
BQL
. 1.0
Date Analyzed
02/06/09
Method Code
EPA 80153
+�
Parameter, m91L
LD. # 2418
Quantitation
Limit m /L
Acetone
4.74
0.005
Date Analyzed
01 /09
", G; : # fi`
Method Code
EPA 8260
Comments:
E = Estimated. Above calibration range.
BQL = Below. Quantitation Limit
Reviewed by: /�C A�,f`,t.,c.�0�
z-d S8V0TLCoT6 "A iiTi14 uyor ess:so 6D ba

AMERICAN DISTILLATION, INC.
P.O. BOX 400
LELAND, NC 28451
[phone] FAX [phone]
May 1, 2007
Linda Willis
Compliance Evaluation Inspection
For NCS000244 / NCG500148
March 15, 2007 Inspection
The following is a list of corrected actions taken of inspection personals
recommendations.
Recommendations:
I. Locks were placed on all valves on tanks locked outside of containment
area as of 3/16/07
2. Copies are attached -
3. Both outlet valves and lines located on the west dike have been removed
and the dike has been repaired as of 4/11/07.
4. Areas in question have been cleaned up as of 3/19/07.
5. Boom was put in place as of 3/16/07 - and area cleaned up by 4/2/07.
6. Tanks are inspected visually each day and a total integrity inspection is
done every 5 years. These integrity inspection sheets will be placed in the
manual containing the SPRP Plan.
7, Item 7 will be addressed in the new permit.
8. The updated SPRP was updated on 9/27/07 was not reviewed by the
inspection group. The manual containing this plan is located in the main.
control room.
9. All containment and unloading pads have the proper containments as of
4/30/07.
10. No comments -
Also, attached is a copy of a letter sent to Linda Lewis from Mark Walton Engineering on
4/26/07 for your info.
Sincerely,
)�Al &W_V�
Hugh Croom
DECEIVED
MAY 0 4 2007

WAL ToAi .EA1 1A'EERIN
April 26, 2007
Linda Lewis
NC Division of Water Quality
127 Cardinal Drive Extension
Wilmington, NC 28405
REC
E>�VED APR 3 0 1
5
07
RE: NOTICE OF INSPECTION, American Distillation, Permit No. SW8 930501
Dear Linda,
In response to the Notice of Inspection dated March 29, 2007; we have updated the site plan
to include all built -upon area on the site.
We determined that the existing built -upon area is 92,267 square feet. The total property area
is 264,029 square feet. (One acre was added to the property a number of years ago, but after
issuance of the Stormwater Management Permit.) The percent impervious is 34.9 percent.
After discussions with ADI officials, it is not feasible to reduce the percentage to less than 30
percent.
Therefore, we will prepare a high -density permit modification with BMPs.
I estimate it will take 60 — 90 days to complete the revised plans and permit modification
application.
If you have any questions, please call me at 910-259-4800.
-Sincerely; 31:f
---
cw�lj
Mark Walton
cc: Andy Simmons
WTmtion respmm
Tel: [phone] PO Box 895, Burgaw, North Carolina, 28425 Fax. [phone]

[B 1151-ENV-2
STORM WATER SYSTEM 1'Y INSPECTION
- ,t•� et�1
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kTE ;TIME ;REMARKS ;ORDER # COMPLETED; SIGNATURE'[
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STORM WATER SYSTEM WHAUk INSPECTION
i
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WORK DATE WORK:
DATE ;TIME :REMARKS 'ORDER # COMPLETED:
--------- --- ------
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n�-TITO C��rri ,
ENVIRONMENTAL CHEMISTS, INC.
NCDENR: DWQ Certificate 694, DLS Certificate #37729
Sample Collection and Chain of Custody
Sample Tvoe: I = Influent. E = Etiluent. W =Well. ST =Stream. SO =Soil. Sir- Sludge Other:
6602 Windmill Way
Wilmington, NC 28405
Phone: [phone]
10-392-4424
[e-mail]
vo: y-75.
Sample Identification
j
Collection
�
u
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v A.
,� �
4
PRESERVATION
ANALYSIS REQUESTED
x
x
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D3
ATE
TIME
f�
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P
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G
G
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G
G
C
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G
G
NOTICE — DECHLORINATION : Samples for Ammonia, TKN,' Cyanide, Phenol, and Bacteria must be dechlorinated
0.2 ppm or less in the field at the time of collection. See reverse side for instructions.
Transfer
Relinquished By:
Date/Time
Received By:
Date/T"ime
1.
2.
Temperature w�ec0d: �lc Accepted: Re' ted: Resample Requested:
Delivered By: I
Received By: f�C ' LyLJa— Date: •L q Time: d. a4 _A'1-1
Comments:

vnunro i .� NCDENR: DWQ CERTIFICATE #94, DLS CERTIFICATE #37729
--._. ------ —
Customer:
AMERICAN DISTE LLATION, INC.
1690 Royster Road
Leland, NC 28425
Attn: Earl Simmons
REPORT OF ANALYSIS
Date Sampled: 02/12/04
Sampled By: Hugh Croom
STORMWATER: Outfall 001
Date of Report: February 25, 2004
Purchase Order No:
Report Number: 4-0752
Report To: Earl Simmons
Parameter I LD. # 1635
Biochemical Oxygen Demand, BODs as % mg/L 1 152
Total Suspended Solids, TSS mg/L 1 59
Chemical Oxygen Demand, COD mg/L 1 570
Total Kjeldahl Nitrogen, TKN mg/L J 18.2
Oil and Grease mg/L 11
EPA 602
Quantitation Limit LD. # 1635
Analyte µg/L I PWL
Toluene 1 0.5 1 BQL
Comments:
BQL = Below Quantitation Limit
Reviewed b CvJ�i

Analytical &Consulting Chemists
'I`'��L
ENVIRONMENTAL CHEMISTS, INC.
NCDENR: DWQ Certificate #94, OLS Certificate #37729
Sawle Collection and Chain Hof Cus[od
Ca.nnis Tuna• 1 = Tnituaut F - FMupimi_ W =WFIL RT._Cfrnsrm- fin =finil_ Cie. Cl An^ f)thar-
6602 Windnrili Way
Wilmington, NC 28405
Phone:[phone]
Fax: [phone]
Email: [e-mail]
Report No q - ' L;,1
Sample Identification_
a
Collection
n
e
°
G�
Ga
e a°.
4
a
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9A.
PRESERVATION
0
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d
o acg I ANALYSIS REQUE5TED
z F p
DATE
TIME
C
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I X�.
)P
V
6-
TO
—
F—
G
�-
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C
G
P
G
G
G
_
NOTICE w DECHLORINATION : Samples for Ammonia, TKN, Cyanide, Phenol, and Bacteria must be dechlorinated
0.2 ppm or less) in the field at the time of collection. See reverse side for instructions.
Transfer Relinquished By: Date/Time Received By: DateMme
1.
2.
Temperature wh n eceiv d: .,` Accepted: ✓ Rlk-
ected: Resample Re nested:
Delivered By: � i-. Received By: _ 1 u - _ Date:. -! .-r Time:_ a ,.��t fil
Comments:
i

ENVIRONMENTAL -CHEMISTS, INC.
NCDENR: DWQ Certificate #94, DIS Certificate #37729
Analytical &Consulting (far ists Sample Collection and Chain off dX
6602 Windmill ,
Wilmington, NC 29405
Phone: [phone]
Fax: [phone]
Email: EchemW@aoLcom
eport No; _ - - _ .,
Sample Identifleation
Collection
1A
Do
10
I a
1
� 1
Q
�
PRESERVATION
ANALYSE REQUEff=
�
z
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z
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DATE
TIlHE
3V Fq
f
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TSS
to
G
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P,
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x
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NOTICE — DECHLORINATION : Samples for Ammonia, TKN, Cyanide, Phenol, and Bacteria must be dechlorinated
0.2 ppm or Ines in the field at the time of collection. See reverse side for instructions.
Transfer
Relinquished By:
DateMme
Received By:
Dateflime
1.
12.
Temperature wh n eceiv d: Accepted: Rejgcted: Resample Re nested:
Delivered By: L% Received By: G` lt)jT --- Date: X/JO4 Time: J -, jN4 PPI
Comments: - .r..ge -.��..t�� 1

.] T: ■T,T/Ar ■ !1 -AZF-1 iT, I
j4RtljC
SLIME;
TEMP
RAIN:
uA;,ut:
TIME:
TEMPJ ;
,RAIN:
SAMPLE
DAi. LE;
TIME:
TEMPJ I
RAIN:
e•e'�uol � �

Mar 11 04 08:02a
American Distillation 510-371-2485
p. 2
j
r- I
L
AMERICAN DIST ILLATION, INC.
1690 NE ROYSTER ROAD
P.O. BOX 400
LELAND, NC 28451
TEL [phone] FAX [phone]
STORM WATER SAMPLING
DATE: ®2 -
TIME: e. 6
TEMP) PH:
RAIN'
SAMPLE:
DATE:
TIME:
41
TEMP.! PH:
RAIN:
SAMPLE:
cf
DATE:
TIME:
TEMP) pH:
RAIN:
SAMPLE:
DATE:
TIME:
TEMP) PH:
RAIN:
SAMPLE:

t
Mar 11 04 08:02a American Distillation 910-371-2485 p.3
o s Environmental Chemists, Inc.
,Lenyir6601- Windmill Way • :Vi:mington. North C;;rohna 2,4405
(910) NI-p213 (Lobl • (M) +92-4124 (Ful
E01tM C--)aol.M1n
ANALYi1CAL & CONSULTING
CHEMIM NCDENK: L)WQ CERTIFICATE #94, ©LS CERTIFiCAT1? 07729
.— ----- . _ •. _ .- _ .....� i.. u .
Customer:
AMERICAN DISTILLATION, INC. Date of Report: February 25, 2004
1690 :Royster Road
Leland, NC 28425 Purchase Order No:
Attu: Earl Simmons
REPORT OF ANALYSIS
Date Sampled: 02112(04
Sampled By: Hugh Croom
ST0104WATER: O utla ll 001
Report Number: 4-075:
Report To: Earl Simmons
Parameter
LD. # t635
Biochemical Oxygen Demand, BODs as 02 mg/L
152
Total Suspended Solids, TSS mg/L
59
Chemical Oxygen Demand, COD mg1L
570
Total Kjeldahl Nitrogen, TKN mg/L
19.2
Oil and Grease mg/L
11
rr'� -eY , a.ZY n ask ti: s. "-�« r {.. ;u�'..•,:wW'a$ 1... :-.. V:: .. _ - - �-.� +T"�"
:- .is•l t W ,-Y :i+ �.l -,;,., f. �tiyq.l�-..5:'Y :� ..Y1-.41"..2 •. , fy' - '. _
EPA 60.2
Qnantitation Limit
Pg/L
Y.D. # 1635
Analyte µg/L
Toluene
0.5
BQL
Comments:
BQL = Below Qaantitation Limit
Reviewed by. C1

NPDESPERMIT NO. NC S OU1Z4I
FACILITYNAME AMErJcSarLdili
OPERATOR IN RESPONSIBLE CHARGE 1
CERTIFIED LABORATORIES (l) Env'- r
CHECK BOX ff ORC HAS CHANCEDn
EFFLUENT
DISCHARGE NO.00 I MONTHLhA2 y YEAR D `f
q l 'y /1� (n c. GLAS52 COUNTY n w i e
�) N /w GRADEPA/ A PRONE 9 I - 3' 1 1 - Cciq 3
I+ncn�4i C11[,+ni1�5,�s1[(2)
PERSON(S) COLLECTING SAMPLES Na4 /I ^ '"M
Mail ORIGINAL and ONE COPY to: N ��
ATTN: CENTRAL PILES x
DIVISION OF WATER QUALITY (S GNA'IVRE OF OPERATOR IN RESPONSIBLE C GE) DATE
1617 MAIL SERVICE CENTER BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
RALE3GH, NC 276"4617 ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
_
-
m
m
DWQ Farm MR-1.1(01/00)
3 NIGD�X inckcS raln
V.
ii4� hrea = 015 ss, MGD = F(1,93 xID ;„�

I.
• ' Facility Status: (Please check one pf the following)
All monitoring data and sampling frequencies meet permit requirements Lil
Compliant
All monitoring data and stunpling frequencies do NOT meet permit requircntenU F]
Noncomplian I
if the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time -table for improvements to be made.
`7 certify, under penalty of law, that this document and all attachments were prepared tinder my direction or supervision in accordance
with a system designed to assure that qualified personnel property gather and evaluate the information submitted. Based on my inquiry
of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information
submitted is, to the best of my knowledge and belief, true, accurate, and complete- I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations."
lbt4N—,�. GReanq
Permittee (Please print or type)
Sigpauiri of Permittee** date
(Required)
1�so c AVYS k _gzwn__ 49 &&W 1, A�C„(gi6) 71- 099 i 2 31-- zv© 4
Peimittee Address Zeji rj'/ Phone Nummfier Permit Exp. Date
PARAMETER CODES
O0010 Temperature
00556 Oil & Grease
00951 Total Fluoride
01067 Nickel
50060 Total
00076 Turbidity
WM Total Nitrogeo
01002 Total Arsenic
01077 Silver
Residual
00080 Color (Pt -CD)
00610 Ammonia Nitrogen
01092 Zinc
Chlorine
00082 Color (ADW
00625 Total Kjeldhal
OI 027 Cadmium
01105 Aluminum
Nitrogen
00095 Conductivity
00630 NtzatesJNitrites
01032 Hexavaient Chromium
01147 Total Selenium
71880 Formaldehyde
00300 Dissolved Oxygen
01034 Chromium
31616 Fecal Colifortn
71900 Mercury
00310 BOD5
00665 Total Phosphorous
32730 Total Phenolics
81551 Xylem
00340 COD
00720 Cyanide
01037 Total Cobalt
34233 Benzene
00400 pH
00745 Total Sulfide
01042 Copper
34481 Toluene
00530 Total Suspended
00927 Total Magnesium
01045 Iron
38260 MBAS
Residue
00929 Total Sodium
01051 Lead
39516 PCBs
00545 Settleable Matter
00940 Total Chloride
01062 Molybdenum
50050 Flow
Parameter Code assistance
may obtained by calling the Point Source Compliame/,Enforcement Unit at (9I9) 733-5083 or by visifng
the Water Quality Section's
web site at h2o.ennstate.nc_ustwas and linking to the Unit's information pages.
Use only units designated in the reporting facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
rt*' If signed by other than the ps rmimoe, delegation of signatory au ttority must be on file with the state per 15A NCAC 211 .05M (b)
(2) (D).

L
RECEIVIED GrI U 1 2003
Environmental Chemists, Inc.
6602 Windmill Way - Wilmington, Nonh Carolina 28405
[phone] (Lab) - [phone] (Fax)
[e-mail]
NCDENR: DWQ CERTIFICATE #94, DLS CERTIFICATE #37729
Customer:
AMERICAN DISTILLATION, INC.
1690 Royster Road
Leland, NC 28425
REPORT OF ANALYSIS
Date Sampled: 09/04/03
Sampled By: Client
WASTEWATER: High Rise
Date of Report: September 29, 2003
Purchase Order No:
Report Number: 3-5025
Report To:
Page 1 of 2
Sample ID
# 11806
EMS 14 TANK
Monitoring
Limit LnpE
BODS as az mg/L
3960
200
Total Suspended Solids, TSS mg/L
13
150
Chemical Oxygen Demand, COD mg1L
5625
Rw
-Ammonia Nitrogen as NE6 -N mg/L
19.6
15.0
Chloride, Cl- mg/L
700
tno
Total Kjeldahl Nitrogen, TKN mg/L
1.19
mo
Nitrate + Nitrite Nitrogen, N%+N%-N mg1L
3.63
mn"
Total Nitrogen, N mg/L
122.6
rao
Oil and Grease mg/L
305
100
Total Phosphorus as P mg/L
43.4
mn
Aluminum, Al mg/L
0.517
0.087
Antimony, Sb nWA
< 0.003
0.014
Arsenic, As mg/L
< 0.005
0.050
Barium, Ba mg/L
0.013
1.0
Cadmium, Cd mg/L
< 0.001
0.010
Chromium as Cr mg/L
0.032
0050
llexavalent Chromium, Cr mg/L
< 0.1 *
0.011
Cobalt, Co mg1L
< 0.005
0.065
Copperas Cu mg/L
0.020
0.050
Cyanide as CN mg/L
< 0.005
0.010
Iron, Fe mg/I.
7.83
L 0
Lead as Pb mg/L
< 0.005
0.025

er�Virochem`
ANALYTICAL & CONSULTING
CHEMISTS
Customer: American Distillation, Inc.
WASTEWATER:
Environmental Chemists, Inc.
6602 Windmill Way • Wilmington. North Carolina 28405
[phone] (Lab) • (910, 392-4424 (Fax)
[e-mail]
NCDENR: DWQ CERTIFICATE #94, DLS CERTIFICATE ##37729
Report 3-5025
Page 2 of 2
Sample ID
# 11806
HRS 14 TANK
Monitoring
Liorit mglL
Magnesium, Mg mg/L
1.19
3.24
Manganese, Mn mg/L
0.227
0.2
Mercury, Hg mg/L
< 0.0062
mo
Nickel as Ni mg/L
0.026
0.088
Silver as Ag mg/L
< 0.005
0.010
Titanium, Ti mg/L
0.403
mo
Trialkyl- Tin, Sn mgfL
< 0.003 * *
mo
Zinc as jai mg/L
0.023
0.300
Comments: MO = Monitor Only
* - 0.1 mg/L is. the detection limit for method
- Represents the sum of 9 tin compounds
Reviewed b-�G-,-: 4<.
L

►i
ENVIRONMENTAL CHEMISTS, INC 6M Windmill Way
NCnsxa: mvQ Cr,dfiede tom, US Cntffla" #a77D Wilmington, NC 28405
Sample Collection and Chafe of Custody Phone: [phone]
n cow ram. Far (910) 392-44U
Email: EchemWC�a06com
n . �,� :11R' INC? ill- ,c �� ,�l.C�,
r' 7j... 04-
a
Sample Identification
1 RA t [a.4K�
_��flCi=tl��l
V
t�
a
Imm"M
�011lllm
C P
G G
C P
G G
C i P
P
G
PRESERVATION
1111
ANALYSIS REQUESTED
cx99;'wAe1
NOTICE— DECHIARUJATION : Samples for Ammonia, TKN, Cyanide, Phenol, and Bacteria must be dechlorinated
0.2 ppm or less in the field at the time of collection. See reverse side for instructions.
Transfer Relinquished By: DateMme Received By: DateMme
1.
2.
Temperature whe R yeti: Accepted: =Ojod: example Requested:
$ek ed By: Received By: Date: a Time:
.omments:
y
M

1151—ENV-2
STORM WATER SYSTEM wNSIBY INSPECTION
-------+-------+ ---------+WORK ----- DATE WORK:'ENPLOYSE—}
'RF�lARKS ;ORDER # ; COMPLETED, SIGNATURE.:
,DATE ,TIME r /
_� _ _ - - .' }
' 7.1_-- )�% ���----------+----------}— — ----+
'-+-----------+- - + - -+- 1
-
_
-' ��-�1 `?fir' ` �.1:�._`_� }_�'�]=Y�i-^_'' 1 C%_��+-�14�-�"n �y`�+� r- t�, [ 5 ��'-���• ��
t ((�� ' _ ✓ ' _ '� ' ---�--_ r ---- -----j 1 ' _------- •r 1
1 _
+
4= f-42�--}---------+ ----- -+ -+-- - -
-+---------+.----L1r+____-------if---1; _--�,� f
tom`= 71 �5- - —V— —f----+-- r r -- r- --- •--- —� —+--_ J------t-----------t
--------- 1 -------lr — 1— ---- { /--
-.._ .__-------_ �___+__---_-___.}_�-_____�
tp
—__}—_—_—_--__+_--_____—.}_____—__—_}—_—_ _ _ + /
-+
__+-------___}_-- ___-+----------+-.-----.----+
+-------}_------+------- +---- +----------+-------
a'c t_______-—_____}__________+—_____--_+—__--___—_.F___-----_—_t
'1 1 1 I 1 1 1• -- '_ - _
♦--------------+----------+---------+----------+-----------

A Ak�
--ADIB -2
.-N, .7,
STORM WATER SYSTEM UJIMM
JINSPEMON
% 4 — — — - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - — — — — — — — — — - - — — --- — — --- — — — -
WORK DATE WORK:
',DATE TIME REMARKS 'ORDER # COMPLETED -_S4 GNATURE
-ice .. --kfi --
-- --------- ---- •------
- --- - -------------
- ---
-----------
IV o3;
---------------------- -Gib -- -- -------------
-------------- -----
--------------- ----------- $A ......... r --------- t.
01C
------------- -----
4f
+
tat_, --------------------------
A(o---------------
7r------------
­1 IrF I j :1
Lo1p..w g I
- l---o ----4c-----
--- +
of el
-rdF'Y-Y
------)---lD--6M-------I AL
e) goo
a ---- - -- ---------------
Ar, 660 4j e
------ ---- ---------------------
------- ----
-ce— - - ------ - - -------- -----------------------
--
km ----------
e
Ills— I
------- ----
------ N4
-- ---------
------------------------------------------

W44
�ADIB 1151-ENV-2
STORM WATER SYSTEM WEEKLY INSPECTION
---------------
------------ ------------
----------------
WORK DATE WORK,, 7EMP-LOYEE.
SIGNATURE;
,ORDER COMPLETED,'.
DATE T IME :REMARKS
------------------------
---- ----------------------
10 ---------------------- ------------
----------------------------
- - - - - - - - - - - - - - - - - - - - 4 -- - - - - - - - - - -
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
vK------------ ------- L ------------------
---------- I ------------- ------- I
.3 t'7j
+ r -----------+---------+----------+--a--n ------
-------------- ---------------- --------
---------------------------
or
----- ------------- ---
--------------------------- ------
AM. 1, k-
----------------------------
_____--+
- - - - - -- - - - - - - - - - - - - - - -
-- ----- - -------------------
r--------
------ --------- -----------------------------
dr-------- -- -----------
7;. +
- - - - - - - - - - - - - - - - - - - - - - d)r - - - - - - - - - - - - - - - - - - - - - - - - - - -
--- ------------ -------------- -- --

Zr
�ti ' '-' y T f G.. G tJ •�a-ir � - Y
VMS4
'= STORH WATER SYSTEM WEEKLY INSPRG ow x
+.= ------------------------------------------
WORK ' DATE WORN' Ed�iPI:OYSE `:'
;DATE ;TIME ;RF�i.4RKS ;ORDER # ; COMPLETED; SIGNATURE
----------------}____--_---+---------+------__—_+_
MI-
3--+-'----------+---------+----------+-------
-+----------+---------+----------+-------+
��+ ' ----- } --- ------ ' ----- -- 1
f... + -+ -+ -- -+ ----+
+�- - - ---- -- - - - -' -'--- --* - - - -- '- - - - - - - - -
+ -------Y--+------�--------------+----------+- --+
+-L=� o +----+---- -----+------_-_+--------=-+-------+
+__--------+---------+---------
-�--------t---'-------+---------f---------
---- --+----- ----+------- -+ ----- ---+ � f.
F---------------------- +----------
r'-----`---------+----------+ ----+
+_ ) _ICL+'-alva+----------t.----------+----------
---------+---------+-------_
_+_- --------+------ -f- '
J y ' -+--+--_------+----------+-----_ -_+
:t_L � _0'�3- +---- -----+--------+---------
. �♦-�'�-��- �-dab -� - `' -- � --___ - - --- } -
:
z, a
>
r,.

- S r- �y}'r 'cf .'�-aFt'' - tr.j_ 15.yf• .
x'�$'rn�,.-' .. i. y ]` fys: ,r���•'i VA
ffil
�'}f'L'•�'Yr#r-di�t�
tr• 'ti xvl
a`7 ADIB 1151-ENV-2
STORN WATER SYSTEM WEEKLY INSPB=ON.
+-----+-------+----------+---------+------- -+ -- -+� + '
WORK ' DATE W6RK $NPLOYEE '
, r ,
A$; rDATE :TIME 'REMARKS 'ORDER # ' COMPLETED' :SIGNATURE'
♦,._------------+----------+---------}----------+---y=___---+
lr310 i r r r rFt
eOe
+s-1---+-------+----------+---------+----------+ ------ /l
�n j S 1� r Q r r r r
.. ♦? "�` ,F J�? _+-_---+------__-k----------+-_r--
-- 1-------- '--------
ter•• ' } —�_ —+ _'}— —+__
_- +b--+-_---_+---------+--«_----- +-----
+«-�--+------___----------+-
—+
6 --
---- --- -ham - _
% ----- -- ------ ' ----- lc'o ck-
* -----+ --t --- - -------------+----------♦ - ----_ }
}_r ----_+---------} Jt
e)k
- - +- ___+__r_______}r_ -- �r4tit
+----------+---------'-------- '
,(� -- ._ ' -----+---------t-------f
- ;-------- +----------+
t--------+----------+-_ -- i'

ADIB 1151-ENV-2
STORM WATER SYSTEM WEEKLY INSPECTION
t-------t-------}-_---------+WQRK-----+-DATE WORK:-
-FMPLOYEE-+
;DATE ;TIME ;REMARKS ;ORDER # ; COMPLETED,' SIGNATURE:
r �— ,
r r ,
a
+- h +-j`-+-------+---------}----------t - -----+
*- `--+---=------+---------+----------+-------- +
--+---------+---------+---------+=------+
-+--------+----------+---__--+
+-----+---------+----------+ - ----+
�.
--+---------+----------+----------+
— I Sgc �� , --- r r r r
r ` r r �/� � r r � r
�- +------}---------+----------+-
� r
�----+---------+----------#=-----'-----+
��._�_E��--+__----+---------+----------+---------+
r r r r r
r r i r e r
`-------- '-------- k- ----
r i r r i
--- ------ '-------- -----
r ,- -------
,
Z r i i
t——t--------- i
+r-�-_�♦- ___ '________ '____-____ `__ +
-+ -+ -- ----- dA
----+
f- ----+- -+------+---------+----------+--------+
-- ------------- '-------- ' - '=---- '

ADID 1151-EM-2
STORM WATER SYSTEM MEEKLY INSPECTION
+-------+-------+----------+---------+----------+-----------+
@ WORK DATE WORK ; EMPLOYEE ;
'DATE ;TIME ;REMARKS ;ORDER 0 ; COMPLETED; SIGNATURE,
+ -- +-------+---------+---------+----------+ ----------+
t 1 1 1 1 1 1
1 1 1 _/)
♦------♦+►'+------+---------+----------+— --+
t 1 1 r 1 1 1
------------------------------ 6 &, --------
1 1 1 1 1 1 1
r 1 r e 1 1
♦��+� -+ ----+---------♦----------♦ _ - +
1- 1
AIL
1 p r 1 1 { 1
1 1 t 1 i 1
�� ---+—� � _+ ---+---------+----------+--
♦ i + r 1
r j 1
_ 1
__4—,2mQ—
+ __�__♦____—____♦______--__}— t
----7—+
+
--�---+---------+----------♦
1
----+---------*----------+--� —#
+1=?� 11! +-- - 1 --------+
+11--------
� } -++
�- ------ ---f------------------- ---
- --- +--- ---+--------+---------+--- ---�— r
+---------+----------
��A &OK
r p�
{]/�] 1
+1-.---�+- ��-+--=---+ --- _+_
-+ +----------+-----------+

ADIB 1151-ENV-2
STORM WATER SYSTEM SLY INSPECTION
+-------+-------+----------+---------+----------+------------+
WORK ; DATE WORK,- EMPLOYEE ;
,DATE 'TIME 'REMARKS ;ORDER # ; COMPLETED,, SIGNATURE;
i 1 1 i i t i
+___-___+1__--_--}___--_-_--+-__-__---+..____-----+-_-- -_-__+
i 1
lovio F 1 1 F k
. +---•••_h-/�---{f -+--- --+--------+------------ ------
+-}-L� t--- - 1-------- 1--------- 1 ---- i
-- 1------- 1-------- 1 ----- opg
k i i 1 1
+ ----_{' - +- _ .F. _----+---__----__--__-_--+- ------
1 1 1 1 1 _1
-+---- -f--+----------+- At- ----
r �1y : 1 j 1- 1 -�-�- /
+ �L +�� -+------------------+--------- 1 ---- 1
-+- -+
1p-.50--------_--+---------+-----_--- ------
' ------}---------+-- -} _;
+ &-- +-----+---------+----------+-- -----+
l
---© -__ 1 1
F 1 -+' --+-- -----+
4C 1
! -+-- ----+---------♦-------- ♦-_
t
1 � 1
+--------+---------f----- 1
1 _
+-- +-------;--- _---+--------------------+-- +
1
♦------- --+----+---------+-------- t

ADIB 1151-ENV-2
STORM WATER SYSTEM WILY INSPECTION
+-------+-------f----------f---------+----------+-----------+
;WORK DATE WORK; EMPLOYEE ',
;DATE 'TIME 'REHA.RKS 1ORDER ; COMPLETED; SIGNATURE,'
1 I 1 1 1 1 1
t-------+-------+----------+---------+----------+-- -----t
------------------------------------
1 1r a7 1 1 O 1 f i 1 !
1 1 1 1
}------� t-------+---------+----------t-------t
+� -- QQ� ' -- --- '-------- '--------- ' ---- '
1 I r r i
0 730
�/ �,��/
+_----_-+ _-�.J,�/__}___ ____+_-__--_--+-r____-__-+-
+ II ----{_ 1�1 '___ -- '-------- '-------- ' - _---- '
--- -+--C---t------+--------------------f----------+
t-��-- +- O-f---+- ---+---_-_-_---__-_- '-+- ----- '
_}
------+---------+----------+=---=-f
----+---------+---------+- - ---------+
+Iz-�d�-+__�+------+---------+----------f- ----
+-�-'�-----------------------------------
It ---
+- D � +-- -- ------- `---- - — - �
f__o�3� ' _per--- ----
-- -+- ----- ----
ok 1 1 1
1
1_2
-G {b 1 +-o_9_D-+---�----t---------+----------+--------+
vt{_L`� p _ 1 _--- 1 '
-+--+---------+----------+-----------+

ADIB 1251-ENV-2
STORM WATER SYSTEM[ SLY iNSPEcrioN
------------------------------------------------------------
'WORK^^--+ DATE^WORN+ !FlSpLOYSE_+
,DATE ;TIME ',REMARKS ,ORDER # ; COMPLETED, SIGNATURE:
+----__pII+�YY_ ---------------------------- O 3 },F_-----+---------+----------+---- --
= + 1- -+^----+---------+----------+-- -`� =---+
' -- r
+G_ SAD + --$-i_+-�------+---------+----------+-------+
+.Q21 +-'-----+---------{----------+-- -{
�j t i i
+ -----+-=x�+ --------}---------t----------t-----------:
2�e !
r �i
- --+ ---- F+ _D----f---------+----------+-`------- `
! -.l
-3i-� o ' - -- '---------------
f_ _7 -------+----------+--__-----+--------- `- ----=
+-------+--------------------t- ------ - +d
-
-----+---------*---^-------------+
}=',°-----------------t----------f-------.
+ `-----�+_43o +_p ____--+---------+--_-------`------- e�
+-------+-�-+------+---------+----------+ --- - -+
+-----+h ---+--- - ---------------^- '- e 3
+ ---- -+ -- 5 ' - - --- '------- ' 1
+-----'--------- }-------+--------+----------+-----------+

ADID 1151-EMY-2
STORM WATER SYSTEM MEEKLY INSPECTION
4-------+----------------------------+----------+------------
i e i ;WORK ; DATE WORK; EMPLOYEE i
,DATE 'TIME ;REMARKS ;ORDER # ; COMPLETED; SIGNATURE,
1 1 '
'- l
} }-- ---}- a -�- +_ _+
+�b-} �----------------------------
AD ------+--- -----+
+ _ +_-�_- _____}--_r_r___+-__--_----
- -----}------------------ } - -------
- - - ® --+------+-------------------f-
L--}------------------ - ----+- ---.�
1 1 1 1 1 1 1
y 10
----------------------------}- --+
y 1 1 1 1 1
f }y i �i 1 1 1
} --- _ _}_#�_ _______________+_-- t_____+----,,.r_---_-
j lee
}
♦ - � -}- -----♦- - - - - - - - 4 --------}rrJ - - - - - ----♦
p� _/7
1 /fp��Q�1W'��J
- - --- ' ----- 1-------- 1 -I
---- '
1 1 1
--- -------------------------+- -----+
r�}�--_+�_-f---------+----------+-- +
+ D£----+--t---------------+----------+------+
+- -----+ +---+--------------------+- -----+
+--- ---+ ---- °�-----+---------+---------+-`- ------
+`- - + -+- ------------------------------ -------
+-------+ ?� ---+_---------------------------+- -- -+
079- ', 0* 1 i e i
------------------------------------- +------------ ------+

� h.� NC bEPARTMENT OF ENVIRONMENT AND NATURAL RESOUR ES..; .
NCDENR INDUSTRIAL STORM WATER INSPECTION FORM
REGIONAL OFFICE
Facility:.'
Dater
Location Address: ' ,
COC #:: LS600
Contact Name: - .; :. " :. _ ... ..
. 7 �..:. .
Phone Number. 3-
9�
Coun#y::
Contact Mailing Address::' (e O -:
Directioris:..
al-D rr� t C
Routine Compliance Inspection
Rescission Request :
Complaint Investigation ..:: : :. :... . ... :..
Other . -,Explain'.:.. no
'
A:
;, -i., ,f r, „ - � r r �f {,.:. 'V `?Y .- iY i.r F. `�,rL`� '.'•f,/!r: .35
STORM WATER POLLUTION PREyENTION ALAI '�--`,a�' * i
c._ ,.r. •. �ar'.fr.'+. S`
Yes
.
No
N1A .
:Comments .
1. ' ,
Is a copy of the-sigried and certified SWPPP at the facility?
vy-
'.
6# . .
A
2...'
Does the facility's SWPPP address the minimum SMP.::
requirements?
3.' .
Are amendments to the SWPPP clearly. documented?.
4.:
Is the current SWPPP. complete? :..CwrriP,
� r•'kl� __ h -y, �y.. f -..a � !-7s.'3•'.,�i A � Z _
VEHICI.EEQUIPMENT Y Cse�r`'
Yes
No
NIA
1.
Were the vehiclelequipment.maintenance areas inspected? .
.2. . -
Are vehicle/machinery leaks and drips property managed?
3:-::-
Is vehicle/equipmehtwashing done`in a designed, area so that
wash water can be properly managed? :.
4.
Was the vehicle fueling area inspected?':.
5.
Are vehicle maintenance activities kept indoors? _ .'. ,. _
6.
Were the vehicle/equipment storage areas inspected?.,
7.
Are current BMPs in vehicle/equipment/fueling areas adequate?
.0
WASTE MANAGEMENT' �s �Jr, h.:,' _ ,, s, �'
r r�': r,,u 4e.: .f . .F,.
Yes
No
NIA
1: :
Are containers for temporary, storage'of wastes labeled?
2.
Are waste materials recycle d?'�
_ '
3..- :
Are hazardous wastes properly handled and disposed of?
4.
Is processed debris removed regularly?
7G.:`
S.
Is there secondary containment for liquid wastes? '.
x '
6.
Are current waste management BMPs adequate?,
is
.:-•, k
D r M
;.,: r..:. �; ' �, ::=:, �,, §:� -k� � ati � -� �,A , � ;"� �.�
-
II�IATERIAL STORAGE =4 ry,. ! sir.
.
Yes
No
NIA
1. ,
Are there a ppropriate BMPs for outdoor storage. of raw rnatehals,
products, and byproducts?
2.
Are containers for chemical substances labeled?
}C .
3..
Is there seconda containment for liuid stora eT.
rY q' g
4. `' ..
Are current BMPs in material storage areas adequate?
-
er -,--. °`'�'

I
Yes,No NIA Comments:
1: Are there procedures .for spill response and cleanup?
2. Are appropriate, spill containment and cleanup materials kept on -site and in
cbnvenient locations? �"9 •""
-3..- Are used absorbentmaterlals disposed of ina timely manner?
4. Are current spilt BMFp . adequate?'
�.
Yes No,NlA
1. Are, unpaved outdoor.areas protected fro n'waterlwirnd erosion? 7L '
2..: Are drainage ditches or the areas around the outfalls free of erosion?
3. Do Implemented BMPs appear effective in controlling erosion? [
j r +vim N.ty
NONSJdRMNATERMANAGEMINi'�"�lWG,j=��v�;i` Yes No N!A
1. ` Have'all illicit water discharges been eliminated or permitted?
2. Are BMPs for authorized_ non -storm water discharges properly implemented?
3. Are current BMPs adequatifor management of authorized non -storm water
discharges? .. TC
_t.. '.,� -
H;r f P OCE55WASTEWATERCONTitOLSA#dbMONITOR1t+iGY�_ ���� Yes No NIA
�?
Are wastewater tireatnient facilities properly maintained?
2.. Has monitorin9 been done?
�- ., ram. -•=F1: :�='•'a,�7`.- -r r --' .A ' c a -. � ; �, � T .�,
t?; STREAM 085EE;:VATIONlIMPACTS `� 'b x'`.s•."'Yv= Yes` No N!Ak{�-r#
-
1. Were there any stream impacts?. X
2. Were field parameters taken for pH or DO?.-... '
3. Were there any stream standard violations) : }C
4. Were there excessive s 'Eds'in the stream?
5. Were pictures,taken? ?c''
6. Were samples taken? :
J SUMMARY l ADi]ITIONAL COMMENTS
el
IF
':. _ 1 -v i.7- - r r - , f s - i71 �f" rr �!- '� � '�� Y , 'i �,r ^ �'- i.�Z'• .,t 7' a�.`S 4 s6 .
K = RATING LIcVEL (CIRCLE ONE
1. Industry in substantial compliance
2. Minor deficiencies noted., Revisit scheduled for (date).
I. Major deficiencies or discharges noted and require prompt correction: Revisit scheduled for . (date).
4. Critical deficiencies or discharges noted and require immediate correction. Revisit scheduled for,' (date).
5. ' Rescission is appropriate.
6: Rescission is not appropriate. .
r