NCG060224_COMPLETE FILE - HISTORICAL_20121204

NORTH CAROLINA
Department of Environmental Qua!
II
0

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V Cc, p a-c3
DOC TYPE
� HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ OSUIci� J a O/
YYYYMMDD

A
�
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Terry Koonce
Alliance One International Inc
PO Box 166
Farmville, NC 27828-0166
Dear Permittee:
Division of Water Quality
Charles Wakild, P. E.
Director
December 4, 2012
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Alliance One International
COC Number NCG060224
Pitt County
In response to your renewal application for continued coverage under stormwater General Permit NCG060000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCG060000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring -Report Form
The General Permit authorizes discharges of Stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://Portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summory,of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://portal.ncdenr.org/web/wq/ws/su/npdessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center, Raleigh, Norlh Carolina 27699.1617
Location! 512 N. Salisbury St. Raleigh, North Carolina 27604
Phon;. 919-807-63001FAX: 91? 807-6492
Internet: v,r,v_w.ncwatemuality.orr,
An Eq . �! Cpo* :ity 1 AfiirmaUve kh. o E .nplopr
One
NorthG irolina
Natmo'Z-711y

Terry Koonce
December 4, 2012
Page 2 of 2
Some of the changes include:
• Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections B, C: Failure to perform analytical stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections B, C: A lower TSS benchmark of SO mg/I for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections B, C: The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections B, C: The term "Representative Storm Event" has been replaced by "Measurable Storm
Event." A measurable storm event is defined in the permit.
• Section D: If the permittee fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal request prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,
far Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files
Washington Regional Office

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060224
STORMWATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Alliance One International Inc
is hereby authorized to discharge stormwater from a facility located at:
Alliance One International
8958 W Marlboro Rd
Farmville
Pitt County
to receiving waters designated as Middle Swamp, a class C;Sw,NSW waterbody in the Neuse
River Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, 11, Ill, and IV of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 41h day of December, 2012.
for Charles Wakild, P.E,, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Mr. Gerald L. Finch
Alliance One International, Inc.
PO Box 166
Farmville, NC 27820
Dear Mr. Finch:
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
February 2, 2007 RECEOVE®
FrB 0 5 2007
DW Q—WAm®
Subject: NPDES General Permit NCG060000
Certificate of Coverage NCG060224
Alliance One International, Inc.
Formerly Dimon International, Inc.
Pitt County
Division personnel have reviewed and approved your request to change your name under the General Permit,
received on January 8, 2007.
Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General
Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of
North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at [phone], extension 502.
Sincerely,
7A
Alan W. Klimek P. E.
cc: DWQ Central Files
Washington Regional Office, Water Quality Section,,
Stormwater Permitting Unit
No ` Carolina
�timally
North Carolina Division of Water Quality . 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.stale.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
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STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060224
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
ALLIANCE ONE INTERNATIONAL, INC.
is hereby authorized to discharge stormwater from a facility located at
ALLIANCE ONE INTERNATIONAL, INC.
8958 W. MARLBORO ROAD
FARMVILLE
PITT COUNTY
to receiving waters designated as a UT to Middle Swamp, a class C NSW stream, in the Neuse River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I,11, III,
IV, V and VI of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective February 2, 2007.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day February 2, 2007. 7-,�� Ls'
v1::INAL 5,-. ,�W
,K-1 cxL
Alan W. Klimek, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Mr. Terry A. Koonce
Dimon International,
PO Box 166
Farmville, NC 27828
Dear Permittee:
Inc. - Farmville
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
May 22, 2006
Subject: Stormwater General Permit NCG060000
Operations and Maintenance Reminder
Dimon International, Inc. - Farmville
COC Number NCG060224
Pitt County
Our records indicate that you have been issued a Stormwater General Permit and a Certificate
of Coverage for your facility. These permits have specific conditions that must be met in order for you
to be in compliance with your permit. It is your responsibility, as the permit holder, to read and
comply with the conditions contained in the permit.
It is our responsibility, as the issuing authority, to make sure that the operation and
maintenance of your facility complies with the conditions contained in your permit. To assist you in
complying with these conditions, we are attaching a Technical Bulletin specific to your permit
requirements. We are currently in the process of developing our inspection schedule. Therefore, you
should have all of your records up to date as we may be contacting you in the near future to set up
an inspection of your facility.
If you have any questions, please do not hesitate to contact Samir Dumpor, Pat Durrett or
myself at [phone],
incerely
Al Hodge, Supervisor
Surface Water Protection Unit
Encl.
CC: WaRO files
North Carolina Division of Water Quality Internet h2o.enr.state. nc.us
943 Washington Square Mall Phone: [phone]
Wash inb on, NC 27889 FAX [phone]
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o1e
NhCarolina
;Vaturall'ff

-------------------------------
(Return This Portion With Check)
ANNUAL PERWr INVOICE
Permit Number: NCGO60224
Pitt County
Dimon International Inc - FarmvMe
'ferry A. Koonce
Engineer
rrc
PO Box 166
Farm0le, NC 27828
II11UI8�II��InIII��InV
Annual Fee Period: 2006-03-01 to 2007-02-2B
Invoice Date: 0402106
Due Date: 05/12/06
Annual Fee: $80,00
Check Number:
MAY 0 S ZOOS

0F WATF Michael F. Easley, Governor
RQG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
co(
� vio IV
o �
August 23, 2002 AUG 2 g 2002
JAMES A CECIL JR
DIMON INTERNATIONAL INC - FARMVILLE DWQ_WAR0
PO BOX 166 �C
FARMVILLE, NC 27828
Subject: NPDES Stormwater Permit Renewal
Dimon International Inc - Farmville
COC Number NCO060224
Pitt County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG060000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued
Pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983.
The following information is included with your permit package:
A new Certificate of Coverage
A copy of General Stormwater Permit NCG060000
A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater
and General Permits Unit at [phone], ext. 578
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Washington Regional Office
ern
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060224
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
DIMON INTERNATIONAL INC
is hereby authorized to discharge stormwater from a facility located at
DIMON INTERNATIONAL INC - FARMVILLE
1200 WEST MARLBORO ROAD
FARMVILLE
PITI' COUNTY
to receiving waters designated as a UT to Middle Swamp, a class C SW NSW stream, in the Neuse River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, II, III,
IV, V, and VI of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective September 1, 2002.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day August 23, 2002.
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
ATTN: TERRY A KOONCE
"DIMON INTERNATIONAL, INC."
POST OFFICE BOX 166
FARMVILLE, NC 27828
Dear Permittee:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
06/06/2002 R Ec A �
DWQ-WARO
Subject: NOTICE OF VIOLATION
FAILURE TO SUBMIT RENEWAL APPLICATION
"DIMON INTERNATIONAL, INC."
NCO060000
COC NUMBER NCG060224
PITT COUNTY
This letter is to inform you that, as of the date of this letter, the Division of Water Quality has not received a
renewal request for the subject permit certificate of coverage. This is a violation of NCGS §143.215.1 (c)(t) which
states "All applications shall be filed with the commission at least 180 days in advance of the date on which it is
desired to commence the discharge of wastes or the date on which an existing permit expires, as the case may be".
Any permittee that has not requested renewal at least 180 days prior to expiration or permittee that does not have a
permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subjected to
enforcement procedures as provided in NCGS §143-215.6 and 33 USC 1251 et. seq.
In order to prevent continued, escalated action, including the assessment of civil penalties you must submit a
completed permit coverage renewal application to the attention of the "Stormwater and General Permits Unit" at
the letterhead address within ten (10) days of your receipt of this letter (renewal application enclosed). If the
subject discharge has been terminated, please complete the enclosed rescission request form. Mailing instructions
are listed on the bottom of the form. You will be notified when the rescission process has been completed.
Thank you for your prompt attention to this situation. If you have any questions regarding this matter, please
contact Aisha Lau of the central office Stormwater and General Permits Unit at 919-733-5083, ext. 578.
Sincerely,
for Alan W. Klimek, P.E.
Director, Division of Water Quality
cc: Stormwater and General Permits Unit Files
Central Files
Washington Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Dcccmher 27, 2001
TERRY A KOONCI
DIMON INTERNATIONAL INCORPORATED
POST OFFICE 13OX 166
f-'ARMVILLE, NC 27828
Dear PcrniiltCC:
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
a_' L E�VF.E
[-IAR - 8 2002
DWQ-WARD
Suhjcct: NPDl Stornnvatcr Permit Renewal
DiMON INTEIZNATIONAL INCOR110RA'1TED
COC Nllmher NCG060224
Pitt County
Your facility is Currently Cowered for stormwatcr dischrn--c under General Permit WC1060000. This pcnnit expires
on August 31, 2002. The Division stall' is Currently in the process of rewriting this permit and is scheduled to have
the permit reissued by lute Sumnicr of 2002. Once the permit is reissued, your Facility would be CligihlC for
continued Coverage under the reissued permit.
In order to assure your Continued CtrvcraIIC under the �,Cr1Cri'tl permit. you must apply to the Division uF Willer
Quality (DWQ) for renewLtl of your permit covera-C. To make this renewal process easier. we arc informing, YOU in
advanCC that your permit will he expiring. l nClused you Will find a General Permit Coverage Renewal
Application Form. The application must he complctcd and returned by March 4, 2002 in order 10 assure Continued
C0vcr.tg10 under 117c general permit
Failure to request rCriewLtl within this time period nuty result in a civil assessment of at least $250.00. Larger
penalties may he assessed depending on the delin(luatcy ol'the request. Discharge of stormwatcr from your facility
without Coverage under it valid stormwatcr NPDES permit would constitute a violation of NCCS 143-215.1 and
could result in assessments of civil penalties of up to $10,000 par day.
Plcasc 1101C that recent I'Cdcrul ICuislation has extended the "no cxpOsurC Cxclusion" to 111 OperatorS of industrial
Facilities in any of the I I catCgorics of' "storm water dischar4t'Cs LLSSOCiatcd with industrial activity." (Cxccpt
Cnnstructinn activitiCS). IFyou feel your' facility Can CCrtify LICondition of "m0 exposure", i.e. ChC klCilty industrial
materials and operations are not Cxposud to stormwatcr, you Can apply for the ncr Cxposuro exclusion, 1701-additional
infrn-mation Contact the Cenlral OFfice Stornrwater Staff rnenlher listed helow or clhcck lhC Storrnwale- &' General
Permits Unit Weh Site al htlpJlh2o.em'.Sta1c.I)C.us/Sulstormwalcr.hlnii
11' the SUillvct stormwatcr dischargC to waters of the state has hccn terminate(l. please complCtC the Cnclosed
Rescission Request Form. Mailing instructions arc listed on the hottum oaf 111C forur. You will be 110111'icd when the
rescission process has hcCn Completed.
11' you have Lilly quaslions regarding the permit WIICWal prnccdures please contact Rorbcri "l imUrd oaf the
Washington Regional Office at 252-946-6481 or Aisha Lau o f ilic Central Ol'l"ice Stormwatur Unit at (919)
733-5W3, ext. 579
Sincerely. II
I.31'101ey 13Cn11eu, Supervisor
SlorrnvaLner and General PCrmils Unit
CC: Central riles
Washirlulon IZC-ion,tl O17icc
®�L.1
NCDENt
N. C Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
John C. Talton, Jr.
DIMON In ternational
Post Office Box 166
Farmville, North Carolina 27828
Dear Mr. Talton:
kT9MA1
IT
10•
— 4 K
71
�r
RECE
WASH lv6i IvelON Frc
F
September 19, 1997 ., SfA �' 5 1997
AEM
Subject: General Permit No. NCG060000
DIMON International
COC NCG060224
Pitt County
In accordance with your application for discharge permit received on August 6, 1997, we are forwarding
herewith the subject certificate of coverage to discharge under the subject state - NPDES general 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 US Environmental Protection agency dated
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the
certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management
Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Tony Evans at telephone number 919/733-5083
ext. 584.
"M"AL SIGNED BY
BRADLEY BEKINFTT
A. Preston Howard, Jr., P. E.
cc: ZWashington_RegionalOffice
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060224
STORMWATER DISCHARGES
NATIONAL POLLUTANT_ DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
DIMON international
is hereby authorized to discharge stormwater from a facility located at
DIMON International
1200 W. Marlboro Road
Farmville, NC
Pitt County
to receiving waters designated as unnamed tributary to Middle Swamp, Class C Sw NSW in the Neuse River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III
and IV of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective September 19, 1997.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day September 19. 1997.
ORIGINAL SIGNED BY
BRADLEY BENNETT
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

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Alliance One International, Inc. Tel: [phone]
8958 West Marlboro Road Fax: [phone]
Post Office Box 166 www.aointl.com
Farmvilie, NC 27828-0166
USA ALLIANCEOne
United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
Region 4
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8460
Re: Response to Notice of Violation/
Alliance One International Inc., NPDES No.: NCG060224 (the "Permit")
Dear Ms. Walker:
Alliance One International, Inc. ("A01" or the "Company") is committed to maintaining its stormwater
program to the levels required by the above -referenced Permit, and would like thank the U.S.
Environmental Protection Agency (the "EPA") for the detail that went into its February 11, 2016
Compliance Stormwater Evaluation Inspection (the "CSWEI") of the Company's Farmville, North
Carolina facility (the "Facility"). In such regard, please be advised that we have made many changes to
our program since February 2016, and intend to continue to improve the Facility and its operations
through employee training and capital projects.
The following response (the "Response") details the changes we have made to the Facility and operations
since the CSWEI, as well as certain information and materials that existed and were available at the time
ofthe CSWEI, but which were not presented to the EPA inspectors by Company personnel.
Cited Violation
Company Response
1. Part H, Section A, Paragraph 1(a) of the
1. An updated site map has been added to both
Permit states that the SPPP shall contain:
the Stormwater Pollution Prevention Plan
"A general location map showing the
(the "SPPP"), and the Spill Prevention
facilitt,'v location in relation to
Control and Countermeasure flan (the
transportation routes and surface waters;
"SPCC"). The updated map, which is
the name of the receiving waters to which
attached as Exhibit 1, includes the latitudes
the stormwater outfalls discharge," and
and longitudes.
"accurate latitude and longitude of the
points of ' stormwater discharge associated
with industrial activity."
The Facility's site map did not identify the
f'� EIVED
receiving water. Also, latitudes and
RE-- L�
long,>rludes were not provided for each
MAR 2
discharge point.
[)ENR LAND QUALITY
PLRM11TTING
sTDRMPPER

United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 2 of 1 l
2. Part If, Section A, Paragraph J(d) of the
Permit states that the SPPP shall contain:
"A list of significant spills or leaks of
pollutants during the previous three (3)
years and any corrective actions taken to
mitigate spill impacts. "
The Facility had no records documenting
whether or not it has any reportable spills
and leaks for the years 2009 to 2015.
2. No reportable spills have occurred at the
Facility in the past three (3) years. The
Company inspects all in-house hydraulic
processing systems on each shift and
exterior systems on a weekly basis.
Representative copies of completed check-
off forms are attached as Exhibit 2.1. These
inspections are part of our ISO Quality
System procedures.
3. Part II, Section A, Paragraph 1(e) of the 3
Permit states: "Tire permittee shall re-
certify annually that the stormwater
outfalls have been evaluated for the
presence of non-stormwater discharges."
The Facility did not have records of annual
re -certification that the stormwater outfalls
have been evaluated for the presence of
non-storinlvater discharges.
4. Part 11, Section A, Paragraph 3 of the
Permit states: "The Spill Prevention and
Response Procedures (SPRP) shall
incorporate an assessment of potential
pollutant sources based on a materials
inventory of the facility. The SRPR must
he site stormwater specific. Therefore, an
oil Spill Prevention Control and
Countermeasure (SPCC) plan ma_y be a
component of the SPRP, but may not be
sufficient to completely address the
stormwater aspects of the SPRRP. "
The Facility has an SPCC plan which
.focuses mainly on oil and petroleum
products. The SPCC does not sufficienlly
address stormwater runoff tiv ough spills or
exposed nialerial.
Going forward the Company will document
the occurrence or absence of significant
spills on the AO1 Storm Water Prevention
Plan Inspections form. A copy of the
completed Storm Water Prevention Plan
Inspections fbrm for 2016 is attached as
Fyhihif 7 7
The stormwater outfalls have been regularly
inspected and maintained, and the Company
will continue to make monthly outfall
inspections and certify the same annually on
the Storm Water Prevention Plan
Inspections form, included in Section 1.5 of
the Company's updated SPPP. See attached
Exhibit 3.
4. The SPPP and SPCC have been updated.
The revised SPPP, which includes the SPCC
as Appendix C thereto, is attached to this
Response as I?xhibit 3.

United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 3 of I
5. Part II, Section A, Paragraph 4 of the 5.
Permit states that: "A preventative
maintenance and n ood housekeeping
program shall be developed and
implemented. "
The SPPP includes a preventative
maintenance and good housekeeping
program, however, the h-acility had no
records for implementation of' this
program.
6. Part II, Section A, Paragraph 5 of the
Permit states that the SPPP shall eontain:
"Inspections of the facility and all
storrn►vater systems shall occur as part of
the Preventative Maintenance and Good
Hotisekeeping Program at a minimum on
a semi-annual schedule. "
The SPPP has an inspection checklist wilh
a once per month schedule, however, the
Facility had no inspection records _for This
program.
During the CSWEI, the Company's
representative did not understand the type of
good housekeeping information that was
being requested. In such regard, please note
that the Company performs regular
preventative maintenance and good
housekeeping under the SPPP and as part of
our ISO Quality System procedures. As an
example, the Company performs daily oil
leak checks on all hydraulic systems, and
has for many years. This is part of our ISO
Quality System program. See attached
Exhibit 2.1 with respect to completed good
housekeeping inspection forms pertaining to
oil leak checks.
In addition, the Company's Central Safety
Program includes monthly housekeeping
inspections and related records that
historically were mainly focused on the
interior of the Facility. Representative
copies of applicable records are attached as
Exhibit 5.1. Since the CSWEI, we have
added monthly grounds inspections in
addition to other tank and outfall
inspections. "These inspections are followed
up by our shift manager to assure that any
negative findings are addressed
appropriately. A representative copy of a
completed Safety and Health Management
System Review "Task report is attached as
Exhibit 5.2.
Further, Yearly Preventative Maintenance is
documented in our Maintenance Assistant
program. Representative copies of
applicable records are attached as Exhibit
5.3.
6. AO1 has implemented a monthly tank
inspection and a monthly outfall/grounds
inspection. See attached Exhibit 2.2 for a
representative copy of a completed Storm
Water Prevention Plan Inspections form, and
attached Exhibit 6 for a representative copy
of a completed Monthly Inspection
Checklist.

United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 4 of l
7. Part II, Section A, Paragraph 7 of' the
Permit states: "The SPPP shall identify a
specific position or positions responsible
for the overall coordination, development,
implementation, and revision of the
SPPP. 0-
The SPPP identifies the plant manager as
responsible for implementing all aspects of
the SPPP. However, in practice, the
Facility has other staff that actually
implement the SPPP, but these positions
and positions assignments sire not
identified on the SPPP.
8. Part II, Section A, Paragraph 8 of the
Permil states: "Tire permitter.' shall amend
the SPPP whenever there is a change in
design, construction, operation, site
drainage, maintenance, or confIguratio►r
of the phvsical features which may have a
signiji-eant effect on the potential for the
discharge of pollutants to surface waters.
All aspects of the SPPP shall he revie►ved
and updated on tt►r annuat basis. "
7. As reflected in Exhibit 3, Section 6.0 of the
SPPP has been updated to identify the other
personnel involved in SPPP implementation,
and provides:
6.0 Responsible Party
The I'lant Alcrnager, Mr. Ben Sherrod, has
been and continues to be the designated
responsible party at the faciliry. He is
responsible for the overall coordination,
development, implementation, and revisions
to this Plan. Additionally, the maintenance
ltlanager and Shift Managers have been
responsible for carrying out the operations
of this plan.
8.a. As reflected in Exhibit 3, the SPPP has
been updated, and we will continue to
make the appropriate changes as indicated
by the Permit.
8.b
a. The SPPP was last updated on October
23, 2008. 77ie Sl'1'I' does not reflect
the current permit requirements
effective December 12, 2012. 8.c.
b. The storrnwater .sample collected on
November 2, 2015, exceeded the
benchmark value for 7SS. This
exceedance of the T.SS benchmark
triggers the Tier One response action
as Specified in the permit. No Tier One
response action was documented in the
file or in the SPPP.
e. Sediment runoff was not evalualed as a
potential pollutant .source in the SPPP.
During the inspection, EIA observed
several areas that do not have
adequate sediment and erosion control
measures.
A 'Pier One response was available at the
time of the CSWEI for the Nov. 2, 2015
exceedance of the benchmark value, but
was not presented by the Company's
personnel. A copy of the Supplement to
SWPPP/ Tier One Evaluation regarding the
November 2, 2015 event is attached as
Exhibit 8-13.
The Company has repaired several areas
and provided a concrete barricade to
prevent vehicles from parking on unpaved
areas, as evidenced by attached Exhibit 8-
C. Additional projects contemplated to
further improve sediment and erosion
control.

United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 5 of 1 1
9. Part 11, Section A, Paragraph 9 of the
Permit states: "Implementation of the
SPPP shall include documentation of all
monitoring, measurements, inspections,
maintenance activities, and training;
provider/ to empl(gees, including the log;
of the sampling data and of actions taken
to implement BMPs associated with the
industrial activities, including vehicle
maintenance activities. Such
documentation shall he kept on -site for a
period of five (S) years. "
The Facility had no records of'
iiplementation of the SPPP:
a. No records were oracle available to
EPA for review pertaining to the
maintenance and housekeeping
activities, maintenance and cleaning
schedules of control systems, handling
of industrial activities, inspection of
outfalls, adjacent waters, drainage
.structures, and BM1's. A Facility
representative ,stated that they do not
sweep the parking lot.
b. The SPPP has an inspection checklist
that is required to he completed once
per inonth, however, no nionlhly
inspection records were made
available for review, Facility
representative stated that they do not
docuinenl routine inspections.
c. The annual employee training that
was conducted on August 13, 201 5,
was Inadequate because only two
einployees attended the training and
all einployees that inipleinent the
SPPP and other einployees that
conduct operational, maintenance and
spill responses should have annual
training,
9.a. As indicated above, the Company
maintains housekeeping and maintenance
records. See Exhibits 2.1, 5.1, 5.2 and 5.3.
9.b. At the time of the CSWEI, the Facility
representative was incorrect in stating that
the Company does not document routine
monthly inspections. Representative copies
of completed inspection records are
attached as Exhibit 6 and Exhibit 9-13.
Although SPPP inspections relating to
health, safety and stormwater overlap
significantly with applicable requirements
of both AOFs Safety and Health program,
and its international "Sustainability in
Tobacco Production" (ST P) program, the
Company has also implemented the SPPP
inspections.
9.c. The training conducted on August 13, 2015
was provided by a former consulting firm
which has been replaced. Storm Water
Training is now part of our annual meeting,
and was last conducted for all relevant
Facility personnel in August 2016. See
attached Exhibit 9-C. Employees involved
in the implementation of the SPPP will
receive additional training.

United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 6 of 1 1
10. Part 11, Section B of the Permit specifies
that stormwater samples shall be
collected after a dry weather interval of
at least 72-hours from previous storm
event and within first 30 minutes of
discharge (first flush condition).
The sampling records that EPA reviewed
did not document that the samples were
collected within the first 30 minutes of
discharge and conducted after a dry
period of' 72 hours from the previous
storm event.
11. Part II, Section B of the Permit specifies
that: "For each sampled measurable
storm event, the total precipitation must
he recorded An on -site rain gauge or
local rain gauge reading must be
recorded. Where isolated sites are
unmanned for extended periods of time,
a local rain gauge reading may be
substituted for an on -site reading.
Facility representatives stated that the
rain gauge on site is not used and that
rainfall values have all been estimates.
The rainfall events were consistently
reported as 0.5 inches of rainfall in the
Facility's records.
10. This will be corrected in the future and
noted on the Stormwater Discharge Outfall
(SDO) Qualitative Monitoring Report (the
"SDO Report").
11. The Company is now using the rain gauge to
accurately document rainfall events.

United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 7 of 1 l
12. Part II, Section B of the Permit states: "If
the first valid sampling results are above a
benchmark value, or outside of the
benchmark ranee, for any parameter at
any outfall; Then the permittee shall
conduct a stormwater management
inspection of the facility, identify and
evaluate possible causes of'the benchmark
value exceedance, identify potential and
select the specific: source controls,
operational controls, or pl{vsical
improvements to reduce concentrations of
the parameters of concern, and/or to bring
concentration within the benchmark range,
implement the selected actions within two
months of the inspection, and record each
instance of a Tier One response in the
SPPP. Include the date and value of the
benchmark exceedance, the inspection
date, the personnel conducting; the
inspection, the selected actions, and the
date the selected actions were
implemented "
Alliance exceeded benchmark values on
three occasions during the !cart three years.
In these three instances of benchmark
exceedances, Alliance did not fallow the
Tier One protocol to address exceedances.
The facility representative stated that a
consultant is contacted to ask if the facility
needs to collect another sample. The facility
representative does not dociunent a visual
inspection to look for issues related to the
exceedance. The exceedances were as
follows:
a. The benchmark value for Total
Suspended Solids (TSS) of 100 mg/L was
exceeded with a resull of 184 inglL at
orttfall 41 on November 2, 2015.
b. The benchmark range , for pH (bet weep 6-
9 standard units) was exceeded with a
result of pH of 5.84 at outfall #3 on
August 19, 2015.
c. The benchmark value for Chemical
Oxygen Demand (COD) of 120 nag/L was
exceeded with a result of 132 mg/L at
outfall 41 on October 14, 2013,
12.a. Although not presented by Company
personnel in the course of the CSWEI , as
evidenced by Exhibit 8-B, a Tier One
evaluation was performed with respect to
the November 2, 2015 event.
12.b. We believe that a 'Pier One evaluation
was performed with respect to the event
on August 19, 2015: however, we have
been unable to locate the same.
12.c. We believe that a Tier One evaluation
was performed with respect to the event
on October 14, 2013, however, we have
been unable to locate the same.

United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 8ofiI
13
Part II, Section D, of the Permit requires
that: "Qualitative monitoring of
stormwater outfialls must be performed
during a measurable storm event. " and
"Qualitative monitoring shall be
performed semi-annually and during
analytical monitoring, events. "
Qualitative visual observations of
stormwater discharges at each of the three
ouffalls were last conducted on June 10,
2010. No records of qualitative visual
observations of stormwater discharges at
outalls were available for review from
June 2010 to the time of inspection in
February 2016.
14. Part III, Section C, Paragraph 1 of the
Permit states: "The permittee shall at all
times properly operate and maintain all
facilities and systems of treatment and
control (and related appurtenances)
which are installed or used b y the
permittee to achieve compliance with the
conditions of this Permit. "
During El"A's on -site evaluation of
pollutant sources and SlIPP
implementation, several operation and
maintenance deficiencies were observed
and are outlined in detail in Section 5 of
the inspection report. A summary of the
deficiencies include:
a. A large quantity of sediment was
observed throughout the site including
around the loading and unloading
area and specifically around the storm
drain in this area, along the curb
leading to ouffall 93, in an unloading
area that leads to a ditch draining to
the city's stormwater system, and on
the ground of the berg hoarse (See 5(A-
C) of the inspection report).
b. The west storm drain was clogged
which caused water to pool in that
area. The storm drain in the receiving
area did not have inlet protection to
prevent sediment and other particles
from directly entering the storm drain
(See 5(13) of the inspection report).
13. The Company's employee that performs this
evaluation misunderstood from a previous
EPA inspection that records of qualitative
visual observations were not necessary and
no longer needed to be implemented. We
regret the misunderstanding, and have
corrected the employee's understanding and
have re -implemented this procedure. A
representative sample of an SDO Report is
attached as I3xhibit 13.
14.a. Much of the sediment observed during the
CSWEI resulted from floodwaters
produced by over four inches of rainfall in
Farmville during the nine days preceding
the CSWL1. The sediment was removed
from the affected area shortly after the
CSWEI, and is no longer present. See
attached Exhibit 14-A. Per our
housekeeping procedures, we will
continue to monitor and clean this area.
14.b. '['his drain was temporarily plugged by a
subterranean cave-in, and was repaired
shortly following the CSWEI. See
attached Exhibit 14-B, evidencing the
repaired drain.
14.c. The unlocked valve observed during the
CSWEI was an unusual occurrence, and
all relevant personnel have again been
instructed to keep this valve locked at all
times. See 1:xhibit 14-C, evidencing the
locked valve.
14.d. Barriers have been added to keep traffic
on the pavement and prevent further
degradation of' the soil adjacent to the
roadway. See Exhibit 8-C, evidencing the
barriers and improved condition of the
area.
14.e. Oil -stained areas have been cleaned, and
oil waste area has been moved to the wash
pit area. See attached Exhibit 14-E.1,
evidencing the improvements.

United States Environmental Protection Agency
Attn! Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 9of' II
C. Secondary containment had an
unlocked valve which could result in
an accidental spill of material inside
the secondary containment (See 5(D)
of the inspection report).
An air/water separator has also been added
to the wash pit area. See attached Exhibit
14-E.2, showing the air/water separator,
which has been added to the air
compressor.
d. ,Sediment and erosion controls were
14.f. Exterior dumpsters have either been
absent or ineffective, such as bare soil
removed or covered. See attached Exhibit
and gullies near the loading and
14-F. evidencing the covered exterior
unloading area, disturbed soil near
dumpsters.
the gated area at the unloading area
which leads to outfall 93, and tire
14.g. Employees had been instructed to only
trucking and bare soil along an
wash fork lifts and vehicles in the truck
unpaved area of the roadway near the
shop wash pit. The Facility has a wash pit
east employee parking area (See 5(E)
with an oil separator available. All Truck
of the inspection report).
Shop personnel have received renewed
instruction to only allow forklifts to be
e. Spills and leaks handling was
washed in the wash pit.
deficient, including oily waste
observed leaking out of a metal
framed building, waste oil staining at
the material storage area, and a patch
of grass stained with leaking oil near
the air compressor building (See 5(F)
of the inspection report).
f. Uncovered trash bins and dumpsters
were observed on site, one dumpster
near the factory and .storage buildings
was actively leaking (See 5(G) of the
inspection report).
g. EPA observed an employee washing a
fork lift with soap and water which
was allowed to drain freely onto the
ground without any BA4P to prevent
process water from entering the
stormlvater (See 5(1-1) ofthe inspection
report).

United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 10 of l
15. Part III, Section D, Paragraph I of the
Permit requires that: "samples collected
shall he characteristic of the volume and
nature of the permitted discharge. "
Alliance slops processing materials in
March, however, samples are collected in
April and early .September before
processing resumes. For a sample to he
representalive and characteristic of the
volume and nature of the permitted
discharge, sampling must he conducted
during operational periods•.
15. AOI will collect samples during operational
periods provided that a representative storm
event has occurred.
16. Part 111, Section D, Paragraph 4 of the
16. Company personnel had been collecting the
Permit requires that: "Test procedures
water samples in a plastic pail to avoid
for the analvsis of pollutants conform
safety risks associated with potential glass
to... 40 C.F.R. 136." 40 C.F.R. 136
breakage, and then transferring the samples
specifies that Oil and Grease ( 0 & G)
into a glass bottle. Going forward the
samples shall he collected in a glass
samples will be collected in a glass
container
container.
Alliance collects samples for oil and
grease in aplastic bottle instead of'a glass
container.
17. Part III, Section E, Paragraph 7 of the
17. The Company has not experienced any
Permit requires that: "Tire permittee
reportable leaks or spills at the Facility from
report to the local D WQ Regional Office,
2009 through 2016. AOI inspects, as part of
within 24 hours, all significant spills as
our ISO Quality System program, all ill-
defined in Part IV of the General Permit.
house hydraulic processing systems on each
The permittee shall report spills
shift and exterior systems weekly. Going
including: any oil spill of 25 gallons or
lorward, the Company will record the
more, rury spill regardless of the amount
occurrence or absence of any significant
that causes a sheen on surface waters,
spill(s) on the AOI Storm Water Prevention
any oil drill regardless of amount
Plan Inspections form,
occurring within 100 feet of surface
waters, and any spill less than 25 gallons
that cannot he cleared up within 24
hours."
Alliance has no records documenting
whether or not it has any reportahle spills
and leaks for years 2009 to 2015.

United States Environmental Protection Agency
Attn: Mary S. Walker - Director, Water Protection Division
March 17, 2017
Page 11 of 11
We trust this Response appropriately supplements and updates information provided to the EPA during
the CSWEI, and further responds to the deficiencies cited in the February15, 2017 Notice of Violation,
Once EPA has had an opportunity to review this Response, please feel free to contact me at your
convenience with any questions that you may have.
Further, in view of the Company's substantial compliance with the Permit and the fact that there have
been no releases or discharges that would cause environmental harm, it is our hope that EPA is not
considering enforcement action; however, if such course is being considered, I would ask that you please
contact me at [phone] so that we may discuss the matter.
Sincerely,
William L. Lloyd, Operations Director
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 properly 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 fine and imprisonment for knowing
violations.
William L. Lloyd, Operations lector
Exhibits
cc: Ms. Becky Garnett, NPDES Permitting and Enforcement Branch (via e-mail)
Mr. Mike Randall, N.C. Department of Environmental Quality
Glenn Dunn, Esq.

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EXHIBIT 2.1

Form Id: PRZM-F021
Issue Date: 2005-09-22
Procedure #: PRZM-P021
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(continued)
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EXHIBIT2.2
AWANCE ONE INTERNATIONAL
STORM WATER PALVEUMN PLAN INSPECTIGNS
YEAR
FACLUT1
!AN FEB MARCH AP1TlL MAY DUNE JULY AUG SEPT OCT Nov DEC
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DICSCAIIIE ANY REMEDIAL ACTIONS TAKEN WIT44 GATE:

EXH I BIT 3
STORMWATER .POLLUTION PREVENTION PLAN
Alliance One International, Inc.
8958 West Marlboro Road
Farmville, North Carolina 27828
Pitt County
February 2017
General Permit No. NCG060000
COC No. NCG060224
February 2017

EXHIBIT 3
(continued)
Table of Contents
1.0 Site Plan....................................................................................................
1.1
General Location Map.............................................................................................1
1.2
Narrative Description of Facility Processes.............................................................1
1.3
Site Map and Outfalls..............................................................................................2
1.4
Significant Spills..........................................................................
1.5
Certification............................................................................... ..... 3
2.0 Stormwater Management Plan.........................................................................................3
2.1
Technical and Economic Feasibility........................................................................3
2.1.1 Storage Practices..........................................................................................3
2.1.2 Loading and Unloading Areas.....................................................................4
2.1.3 Outdoor Process Areas.................................................................................4
2.1.4 Emission Sources.........................................................................................4
2.1.5 Waste Disposal Practices.............................................................................4
2.2
Secondary Containment...........................................................................................5
2.3
Best Management Practices.....................................................................................5
2.3. I Prevention....................................................................................................5
2.3.2 Containment.................................................................................................5
2.3.3 Mitigation.....................................................................................................5
2.3.4 Disposal........................................................................................................5
3.0 Spill Prevention and Response Plan.................................................................................6
4.0 Preventive Maintenance and Good Housekeeping.........................................................6
4.1 Preventive Maintenance PrograEn.............................................................................6
4.2 Good Housekeeping Program..................................................................................6
5.0 Training Schedules............................................................................................................7
5.1 Spill Prevention and Response.................................................................................7
5.2 Good Housekeeping.................................................................................................7
5.3 Materials Management Practices.............................................................................7
5.4 Water Pollution Regulations....................................................................................7
6.0 Responsible Party...............................................................................................................7

EXHIBIT 3
(continued)
This Stormwater Pollution Prevention Plan (S W PPP) has been prepared for the Alliance One
International, Inc. facility located at 8958 West Marlboro Road in Farmville, North Carolina,
The SWPPP is designed to meet the requirements of the U. S. EPA's National Pollutant
Discharge Elimination System (NPDES) program for stormwater discharges and North
Carolina's General Permit No. NCG060000 (COC NCG060224) that was renewed in 2012.
1.0 Site Plan
1.1 General Location Map
A map showing the location of the facility, the major transportation and water routes, and the
receiving waters for stormwater discharges is presented in Appendix A. Stormwater is discharged at
one outfall on the west side of the plant, one outfall on Marlboro Road in front of the plant, and one
outfall on the east side of the plant property.
1.2 Narrative Descrintion of Facility Processes
Alliance One International, Inc. operates a 224,000 square foot facility on 47.16 acres located at
8958 West Marlboro Road in Farmvil le, North Carolina for the storage and processing of flue -cured
and Burley tobaccos. Green tobacco, intermediate products, and finished tobacco are processed and
stored either inside the facility or in adjacent storage buildings. Green tobacco is unloaded under a
roof and should not be exposed to stormwater. Finished tobacco, in cardboard boxes, is loaded from
a loading dock that is also covered. The loading of finished product should not be a potential source
of stormwater pollution.
Twenty tanks for the storage of various oil products are located at the facility as shown below.
Tank Capacity
( al)
Contents
Location *
Secondary
Containment
20,0002
92 Fuel Oil
W, O, A
Yes
500
Diesel
W, O, A
Yes
225
Waste Oils
W, O, A
Partial
250
Hydraulic
Roof
**
250
Hydraulic
Roof
**
150
Hydraulic
E.I
**
150
Hydraulic
E, I
**
150
Hydraulic draulic
E, I
**
150
Hydraulic
E, I
**
400
Hydraulic
W, I
**
800
H draulic
W, I
**
1,000
Hydraulic
W, I
**

EXHIBIT 3
(continued)
800
Hydraulic
W, I
**
250
Cube
W
Nonc
240
500 kVA (Mineral)
S, O
None
215
300 kVA (Mineral)
N, O
None
1,356
3,750 kVA (Mineral)
W. O
None
1,163
3,750 kVA (Mineral)
W, O
None
* W = west side of plant, E — east side, O = outside, I = inside, U = UST, A = AST
** Qualified oil -filled operational equipment. Many also have drip pans.
Z Shop -fabricated, double -walled tank.
Waste materials are dirt collected from the baghouses and sweepings from the plant floor and waste
oils. Dirt is composed of sand, vegetative matter, and tobacco fines. Waste oils are used motor oil
from plant vehicles and used hydraulic oil from the tobacco presses.
1.3 Site Map and_Outfalls
The site map is located in Appendix B. Three outfalls have been identified for the facility as shown
in the following table.
Outfall
Source
Flow
Receiving Water
Pollutants
Direction
Grounds, oil
W & N
Large open area
Hydrocarbons,
tanks, shop,
fines, & general
parking lot,
runoff
storage & roof
2
Grounds,
E & S
barge open area
General runoff
storage, roof, &
then Middle
& fines
dirt transport
Swamp (> 1 mile
area
away)
3
Roof, parking
W & S
Drainage ditch
Fines & general
lot, plant yard,
then across road to
runoff
& grounds
Middle Swamp
(> 1 m i le away)
1.4 Significant Spills
In the past three years, no spills have occurred at the facility.

EXHIBIT 3
(continued)
1.5 Certification
"I certify that the three stormwater outfalls have been evaluated, and only stormwater
discharges are present."
Ben Sherrod Date
2.0 Stormwater Management Flan
2.1 Technical and Economic Feasibilit
The protection of stormwater from contamination through process modification is addressed in this
section. In most areas, protection is already in place.
2.1.1 Storage Practices
Storage of raw tobacco materials, intermediate products, and final products occurs under roof` or
inside buildings.
No. 2 fuel oil is stored in a shop -built, double -walled tank on the West side of the facility. Visible
inspections of this tank are conducted monthly.
Waste motor oils from forklift maintenance and waste hydraulic fluid from the presses are stored in a
225-gallon above ground polyethylene tank located to the north of the forklift maintenance shop in
the northwest portion of the property. 'There is a concrete containment structure (70" x 75" x 9"
high) around the tank.
A 500-gallon diesel AS"T is also at that location. The diesel tank also has secondary containment.
Two hydraulic oil tanks used to supply fluid to the tobacco presses arc located on the roof of the
facility. These tanks have capacities of 250 gallons of fluid each with no secondary containment.
"These tanks supply hydraulic fluid to the tobacco presses. Any leakage of fluid would be noticed

EXHIBIT 3
(continued)
immediately and would be repaired. Cleanup would also be immediate. Flow from this roof can be
controlled by cut off valves.
The other hydraulic tanks are located inside the plant building. Drip pans are provided for most of
these inside tanks to capture any leaks before fluid enters the drains. Cleanup of' any spills is
immediate.
Dirt from the baghouses and floor sweepings is loaded directly in enclosed dirt containers and hauled
off to a land application area. This loading area and spillage from hauling trucks are partially
exposed to stormwater. In the loading area, the slope of the land is toward the building to the west.
Therefore, most of the stormwater runoff is toward the building and away from the stormwater
outfall.
2.1.2 Loading and Unloading Areas
The loading and unloading of raw materials and products are conducted under roof and are not
exposed to stormwater. The filling of the No. 2 AST, the diesel UST are conducted outside and can
be exposed to stormwater. The two hydraulic oil tanks on the roof are filled from inside the plant and
should not be exposed to stormwater.
2.1.3 Outdoor Process Areas
All processing is conducted indoors or under roof.
2.1.4 Emission Sources
Emissions from the processes are summarized in the following table.
Emission Source
Emissions
Boilers
TSP, PM-10, SOx, NOx, VOC, CO, & HAPS/'PAPS
Threshing Lines
TSP & PM-10
Strip Redryers
TSP, PM-10, VOC, Acetic Acid, & Ammonia
Stem Dryers
VOC, Acetic Acid, & Ammonia
Fumigation
Phosphine
2.1.5 Waste Disposal Practices
Wastes generated by the Facility consist of dirt, waste motor oil, and waste hydraulic oil. Dirt is
hauled directly to a land application area by a contractor. The dirt is loaded directly into enclosed
dirt containers and is partially exposed to rainfall.

EXHIBIT 3
(continued)
The waste oils result from the changing of motor oil in forklifts and trucks. They are stored in an
enclosed tank until hauled off by a recycling contractor. Waste hydraulic oils from the tobacco
presses are stored in the same tank. 'These oils are not directly exposed to stormwater.
2.2 Secondary Containment
The No. 2 oil tank is a shop -built, double -walled tank. Secondary containment is provided for the
waste -oil and diesel tanks. The containment structure is described above and in Section 1.2.
Stormwater accumulated in the containment structures is observed, and any petroleum products arc
removed prior to release. .
2.3 Best Management Practices
Best Management Practices are described under four sections: prevention, containment, mitigation,
and disposal.
2.3.1 Prevention
Prevention of stormwater contamination is provided by the covering of the raw material and product
unloading and loading areas. Therefore, raw materials and products are not exposed to stormwater.
The facility is surrounded by grassy and Forested areas that serve as vegetative filter strips.
2.3.2 Containment
Containment of'possiblc spill areas around the waste storage area is provided by a concrete structure
described above. Air discharges have been reduced by controlling emissions with baghouses.
2.3.3 Mitigation
Spills of petroleum products are cleaned up immediately under the guidelines of the Spill Prevention
Control and Countermeasure Plan (SPCC). Ample equipment is available to remove hydrocarbons
from water prior to discharge. The SPCC is included in Appendix C.
2.3.4 Disposal
The wastes generated by the facility are dirt, waste motor oils, and waste hydraulic oils. Dirt is
disposed of offsite in land application areas. Tile waste oils arc hauled away by contractors and
recycled.
3.0 Spill Prevention and Response Plan

EXHIBIT 3
(continued)
The Spill Prevention Control and Countermeasure Plan is provided in Appendix C.
4.0 Preventive Maintenance and Good Housekeeping
Preventive maintenance and good housekeeping programs have been developed and are included
below. The programs have developed schedules of inspections of plant equipment, materials
handling areas, and stormwater conveyance systems and pathways.
4.1 Preventive Maintenance Program
The preventive maintenance program involves the regular inspection of plant equipment and
operational systems combined with immediate repair or maintenance of faulty equipment. The first
step is the identification of which equipment that may mallunction and cause spills, leaks or other
situations that could lead to stormwater contamination.
Of primary concern is the petroleum product storage and delivery area. An inspection of the tanks,
containment, piping, control valves, and pressure relief valves is conducted monthly. In addition, the
waste motor oil and the waste hydraulic oil storage area, the baghouses, and the stormwater
collection systems are inspected monthly.
Equipment is examined for leaks, corrosion, support or foundation failure, and other forms of
deterioration. Spots or puddles of liquids, smoke, fumes, and other signs of leaks are reported and
repaired.
Defective equipment is repaired or replaced immediately. A record of repairs and replacements, as
well as the inspections, is kept in a logbook. Spare parts for equipment that needs frequent repairs
are kept onsite. An inspection checklist is included in Appendix D.
In addition the site shall be monitored for sediment potentially contaminating water and maintained.
4.2 Good Flousekee in , Pro cram
A good housekeeping program can help minimize the number of spills and other releases of
pollutants to stormwater. The program involves operation and maintenance, material storage
practices, material inventory procedures, and employee participation.
Basic good housekeeping is conducted at the facility through the use of regular sweeping of the
plant's floor, regular disposal of waste materials, and routine inspections of the operation of process
equipment. Sweeping and disposal of waste materials is conducted continuously during plant
operation. Process equipment is inspected at least daily for proper operation, and any maintenance
is conducted immediately. Spills are cleaned up immediately.
Process materials and products are stored in well-defined areas. Chemicals are not used.

EXHIBIT 3
(continued)
5.0 Training Schedules
Training will be conducted onetime per year for personnel involved with this plan. Training results
are included at the end of this report.
Training will include spill prevention and response, good housekeeping, materials management, and
the basics of water pollution regulations. All employees involved in the processing operation will
undergo this training. The plant management team conducts the training.
5.1 Spill Prevention and Response
The Spill Prevention Control and Countermeasure Plan is discussed; and response procedures are
addressed. This discussion includes the identification of potential spill areas and drainage routes, the
procedures and necessities of promptly reporting spills without a penalty to the individual, the
identification and handling procedures forall hazardous and waste materials, and the implementation
of' spiII response procedures.
5.2 Good Housekeeping
The importance of good housekeeping to the proper operation of the facility and to employee safety
is emphasized in the training. Regular sweeping and cleaning of the plant are normal requirements
of Alliance One International and must be maintained. Other areas emphasized include the
immediate clean up of spills to prevent more serious problems, the identification of areas where
cleaning materials are kept, the proper methods of opening and securing containers of hazardous
materials, and the implementation of supervisory overviews.
5.3 Materials Management Practices
The implementation of an effective materials management program is dependent on the proper
training of personnel. All hazardous materials used in the facility, their storage locations, and special
handling procedures are discussed with personnel during the training.
5.4 Water Pollution Regulations
The water pollution laws and regulations that require these procedures are discussed in a general
way. The penalties provided by these laws are also presented.
6.0 Responsible Party
The Plant Manager, Mr. Ben Sherrod, is the designated responsible party at the facility. He is
responsible for the overall coordination, development, implementation, and revisions to this Plan.
Additionally, the maintenance Manager and Shift Managers are responsible for carrying out the
operations of this plan.

EXHIRI T 3
(continued)
Plant Manager Certification
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
properly 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.
am aware that there are significant penalties for submitting false information, including the
possibility of fine or imprisonment for knowing violations.
Name and Official Title (type or print) -- Ben Sherrod, Plant Manager
Signature
Date Signed: t/
Reviewed:
Reviewed:
Reviewed:

EXHIBIT 3
(continued)
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APPENDIX C — tiPCC PI..AN

EXlllBlT 3
(continued)
Spill Prevention, Control, and
Countermeasure (SPCC) Plan
Certification Page
iDetermine wheiheryour SPCCplan musl he cerd led; Tnot, delete this certykadon page and add a
slaremen, that cerq 7cadon of the plan h not required or include a self-certtfieatlon page. I
1.0 Professional Engineering Certification
In accordance with the requirements, a professional engineer has reviewed this plan, has walked the site,
and has reviewed the calculations made as part ofthis plan preparation. Because of these activities, the
following certification is made:
1 hereby certify that] have examined the facility and, being familiar with the provisions of40 CFR 112 and
state regulations attest that this SPCC plan has been prepared in accordance with good engineering
practices. In preparation of the plan, consideration of applicable industry standards has been accounted for
along with procedures for required inspections and testing. The plan is adequate for the facility. However,
in no way does this certification relieve the owner or operator of a facility of his duty to prepare and fully
implement the plan.
Certifying en name (print):
Y g engineer / $ lP
Signature:
Date: ! l
Registration Number:
State: [insert state where registered]
2.0 Management Certification
[DPS] has prepared this SPCC plan in accordance with best practices and regulatory
standards. Our facility is n tobacco processing and has been in operation for many years.
The person in ouir organization that has been designated as our oil spill prevention
manager is Ben Sherrod and can be reached at Site.
"Phis plan was reviewed by and has the approval of management at a level and authority
to commit the necessary resources toward spill prevention. In addition, management
supports and assists with the timely training of all employees that handle oil at our
facility. This plan will be maintained on -site in a readily accessible location for use in
emergencies and agency inspections.
e (p`—,
rint)s'
1
Ttt.
C .mil j f t 4.,t) ._...."e.~...: ......-_...
Signature
17

EXHIBIT 3
(continued)
SPILL PREVENTION CONTROL AND
COUNTERMEASURE PLAN
Alliance One International, Inc.
8958 West Marlboro Road
Farrnville. NC' 27828
I'M County

I{;Xt111UT 3
(continued)
Oetosber 2016
Section 1 - F3CilitN' LOCiltiOn
Namc - Alliance One International. Inc.
Address - 8958 Wcst Marlboro Read
Farniville. NC 27828
Pitt (`01,111tV
Directions - from I li"hway 264 tale I lighway 264 Alt. East approximately
2.0 miles. Turn lent into the plant property. A topographic nuol)
showing the t'acility location is located in Appendix A.
Section 2 - Operator Information
Name - One International. Inc.
Address - 89�8 West Marlboro Road
Farms II1e. NC 27828
Phone- (272)75i-8300
[phone] Fax
Facility Contact - Mr, 13c11 Sherrod
Plant Manaocr
Mr. "ferry Koonce
Plrl"Chasin-, Manaucr
Address - 89�8 West Marlboro Road
Farmvillc. NC 27828
Phone - (252) 773--8 00
Section 3 - Facility Description
Alliance One lnterimtional. Inc. operates a 224.000 square tort on 47.16 acre." located on
West Marlboros Road in Farmville. NC for processim-, and storim, tyre-ctu-Ld and lit11-10
tobaccos. The Facility has thirteen tanks to store o it products. The f6l10nkin�, (,I[ IC lists the tan:�S.
the products stored. and the tank locations.

F,XHI131"I' 3
(continued)
Tank Capacity
[�al)
Contents
Location
Scuondar%
(Walnnlellt
12,ON
02 1% (-)il
W, 0. A
Yes
500
Diesel
W, O, A
None
225
Waste (_)ils
Q 0, A
Partial
250
1 Ivdraulic
Roo
250
l l -draulic
hoof
**
150
livdraulic
F, I
*
150
1lvdraulic
l: I
*
150
I I -draulic
In I
**
150
1 lvdraulic
400
1lvdraulic
W, I
800
I{ drmdic
W. I
11000
I {vdi aul is
W, I
k.
800
1-I draulic
W, I
**
550
I Ivdraulic { 10 dnnns}
W. I
WE Pans
240
500 kVA (Mineral)
S, O
None
215
300 kVA (Mineral)
N. {)
None
1.356
0 kVA (Mineral)
W',()
None
K1G3
mOWA (Mineral)
W, O
Now
W west side of'hlant. F: - east side, N - north side, S south side, U --- outsic{e, I inside. U -
LIST, A ::::::: AST
* `bank with shop -fabricated. double -"celled cmistructio.�n meeting rcquirenienis (0' 1 1200 X-
1 I2A (cK2)
** QuaMed WIT operational equipment. ' an{ also have drip pens.
A 12000-gall)n, shop -built. douhle-walled tank has been installed on the west side of'the facility
to provide hoick -up t'uel to a newly installed boiler and I= existing hollers, This tank stores 02
Me! oil. At smue point, the fired y plans to add additional tanks in this area hi prcwide hackup
fuel to the b{vilers. Ite tank farm cunt guration and date of installation are unkno"n at this time.
4

EXHIBIT 3
(continued)
I:)iesel for facility vehicles is stored in a 50TgAlon lank on the north side Of the vehicle -
maintenance shop that is Iocated on the Nvest side ofthe property. also at this location is a 225-
gallon tank used to store waste mils from the shop.
Ten hydraulic. oil tanks (total capacity of 4.100 gallons) are used fur the tohacco presses and are
located 1111-OUghOUt the facility. Most of these tanks have drip pans.
Section 4 - Oil Products
Oil products at the: facility are 02 fuel oil, hydraulic oil. kwaste Hinter oil bus vehicle
maintenance, and waste hydraulic oil. The 'VISIY�4 lbr the 02 fuel Oil and the I1yd3'aulic fiuid arc
shown in :Appendix R.
Section 5 - Storage Information
No. 2 Duel (Al - 12,000 gallon
Diesel - 500 gallon
Waste Motor (Al X Hydmuhc OH - 225 gallons
Iydraulic Fluid - ten tanks (150 to IMOD gallons) and drum storage area
Section 6 - 24-hour Notification Phone Numbers
In the event of spill. certain Federal. State, and local authorities must he no itied. the
responsibility of notification rests with the Spill (!Kwdinatur or his assistant or designed The
following litit ofcontacts and phone numhers must he QUIt-rcted. A checklist vNith these contacts
and the necessary reporting information follows Section 7.
rivlor d
National Response Center (SOO) 424-8802
Coast Guard & FYA
State
I)cpt. Ol I:nvironntent. Ilealth K Natural Reso�tsrees (919) 7,3-529I
(810 am to 510 pm)
Office of Fnicrgencv Management (field) 358Q368
5

EXHIBIT 3
(Contintred)
(5:00 pm to 8:00 am)
I.,oCaI
Dept. Of I lealth (E'itt Comm')
arniville Public Work's
l�al-mvillc W istcwatcr°'I rcatilaent 1 acility
Tar-mv ille Tire. Policc. & Rescue
Ocan-UP COntl"aetllr'
:PS ol' Vermont. Inc.
ld Merritt
('01-Iorate
I err, A. Koonce
Section 7 - Notification Procedures
4 13- 1 100
75 3-4f )42
753- 3')13
911
[phone] (24-hr)
(919) 8 52-3595
(2521) 258-8817 {cell}
The first person becoming; awarc ofa spill or discharge of oil %%ill immcdiately contact the Shill
Coordinator and follow his instructions until he arrives. lf'the Coordinatnr- is not availahlc. the
Assistant Coordinator (Mr. 13ohhy Raspberry during, the day or Niolit Shift Manager during
second shift) will he notified. The Spill Coordinator will assess the hai,arcl to human health or
the environment resulting Crom the discharge. 'I lie Spill Coordinator or his assistartt or designee
rntrst notify the appropriate authorities ill the went of a spill. A checklist Ol'the;e authorities and
the neccssal-N reporting, inforniation follows.
Spill Coordinator
Ben Shcrrod
Fxt. 8317
24-hr t 252-258-9974
Assistant Shill Coordinators
13ohhy Raspberry (Days)
I:xt. 8323
24-hr Ii 257-258-48'
6

aaurildtiloa .ion a ysuodsa.l sl .ioltmilmooa I !(Is ,)ql
(11ii{S I)LlOaaS} Al ,mja,{ III)JYJ
(I3JIli11)i111J�
f �.I�111IX.�1

(Continued)
Oil Spill Reporting Checklist
Facility Nanle:
Facility !Address:
Contact: Telephone:
Date of Spill/Dischar,>e
Fime ol'Spill/Discharge
Type of ()il Spilled:
!Amount of'()il Spilled:
Location ol'Spill:
Cause of Spill:
Status ol'Spill:
Name ofNotilier: Date ot-Notificatinrl:
Agency/Telephone Number
I,inle
Name of Pcrson Receivirlyv, Call
National Response Center
[phone] (24-hr)
NC DI;IINR
[phone] (0800-1700)
N(' ()Mice of l"nlergencv M,,t.
[phone] (1700-0800)
PolICC, 111-C. K Rescue
911
Farmville Wastewater Treatmctlt
75 3-3913
1'armN"111e PLIbhC Works
753-4042
Alliance One I'_nVlron. - Terry
Koonce
[phone]
[phone]

EXHIBITS
(continued)
Section S - Contahiment and Cleanup Information (24-hour)
The Coordinator must initiatly assess the severity orthe spill. and must protect human health and
safety. If the incident cannot he controlled by plant spill response. personnel 4"�ithOut incurrinZ"
undue risk. the coordinator will evacuate workers at risk and will contact the: appropriate
authorities and the outside clean-up contractor. also. if persons outside the facility are at risk,
the appropriate agencies will he advised of this situaOon and the possible need to evacuate oN
site personnel.
To assess the incidea the following steps will he completed:
Rcvicw the MSDS for the product and mite the health and chemical enns.
2. Record the source of the spill and estimate the quantity released and the rate.
3. Record the direction of rnovernem and estimate the: area under influence.
4. f.valuatt the potential for fire or explosion. and
5. I ;valuate the nixed tier medical attention to We personnel arfccted.
In the event ora spill. all non -essential personnel will be evacuated from the immediate area. ant.]
the site will be roped off.
If the Coordinator determines that the accident is it spill that does not pose a threat orexplosion
but does post: a threat to sudice andAw gvund"ater. he vkill attempt to contain. treat, and
dispose of the affected material by:
1. ]n1rncdiatcly mobilize the lit-mville Plant spill response personnel under his
direction to take 4vhatcvcr measures are necessary Ri clean up the spill and wnwvc
Ow contaminated soil andMr water. Appropriate measures include the use or
absorbents, pumps. and earth handling ecydpnwnt such a5 shovels. etc.
2. Wthe spill is beyond the capabilities of the on -site personnel and equipment, the
Coordinator shall retain the services of the olbsite convactur mentioned in Section
10 of, this Flan.
3. lfthe spill escapes into navigable waters. the: Coordinator hill contact the
appropriate Federal. State. and local agencies.
4. Retain the services of an analytical laboratory to test the Spill clean-up to

EX111BI 3
(continual)
determine the eflieicncy ofthr cle<.tn-up process.
5. WIN; the North Carr d&a. I) pw1- off of End nm nwnL I health. and Natural
Resources, the Office of'Emcrgency Management. and the Natkinal Asponse
Center with the 015wing inArmation:
A Name and telephone number of reporter.
13 Name and address of facility.
[.` Time and type of discharcc.
D "hype and quantity of materials involved.
I-; '['Ile ctitent of injuries. if <. n .
F The possible hazards to hunurn health or the environment. and
Ci Clean-up procedures.
Section 9 - Compliance Responsibility
The Spill Coordinator has the responsihdhy to ensure compliance with the discharge
requirements.
Section 1.0 - Private Personnel and Equipment 1"Aable
Alliance One International. Inc. has an agreement with I -:PS of Vermont. Inc. located in Raleigh
to provide assistance with a clean-up. ITS can respond within ? hours if the need arises. An
equipment inventory and a IN of personnel who are trained to trsc this equipment are presented
in Appendix 1.).
FTS of Vermont. Inc.
6001 Chapel hill Road. SLritC 108
Raleigh, NC 27606
Phone: [phone]
(A 9) 8520595
Section l f - Discharges
In the event of a discharge from the No, `? storage tank or the waste oil W. oil would flan.\.
slowly down the shght slope toward the drAnage ditch that Orms the vwwcrn harder of the
property. A discharge tiara one of We roof tanks would HOW west across the roof. into the rout
drains. and then west into the ditch.
The INt containment point Ar a discharge from any of the tank, would be in the plant ywd pHor
to entering the ditch. The next containment point ,would be in the ditch toward the northern end
ofthe lacility. The ditch Ilows north at this poin and a spill should he contained prN to
enterN M fiddle Swamp.

F:XMBIT 3
(continued)
Chicken wire. straw. absorbent materials, and hoomS would be the primary containment method
on the plant sites and in the dry ditch. These materials are stored inside the plant i❑ the bolter
room.
Section 12 - Facility Containment/Recovery Equipment
The waste oil tank has a 70" x 75" k 9" hioll concrete containmert structure around the tank. flit
No. 2 nil tank is douhle-walled. The pipin- system connecting the tank to the boilers is also
double -walled. The rooftanks do not have containment.
The futility retains a supply of sand and land tools Stich as rakes. hoes. and shovels for
inimediate clean tip of small spills. n supple of' up to 30 floater blankets is also retained at the
facility fir cleatl tip of small spills resulting from tank filling operatit>ns.
Bales of stray, iron stakes, rolls ofchicken wire. absorbent material,. and booms are stored in
the hailer room. In addition, two over packs are being purchased to provide more protection.
`['he maintenance anti the receiving floor personnel are trained to use the equiprrrent. The
maintenance personnel will he the primar} response team. Elie receiving floor personnel are the
primary backup crew. Additional personnel can he called from elseMicre in the plant as necdcd.
Section 13 - Natural Resources at Risk
Groundwater cotrld possibly he at risk in the event of an oil spill or tank/supply line rupture.
SUrfaC:e water is pr'ohably riot at risk. The drainage pattern ofthe site from the tanks and piping
is west. The slope is slight. If oil escapes from the containment Structures, it would move slowly
into a drainage ditch that runs north/South on the vveSt side cif the property.
Groundwater could be at risk hCCatiSC of the nature of the soil series it) (lie area. fAccordin to the
soil survey 60r Pitt Count%. the soils in the area of the plant are of tvvo separate series. Stains and
Goldsboro. Characteristics of these soils are shown in the lollowing table.

XIIJBI i 3
(Continued)
lie . t(� h t o
Water Tahle
De atll
I'crineahiIiK
LiEA
hn of Soil
in./Ilr
Rains 0
0-9
Silt loam
0.63-2m
9-42
(,[av loans. Silty clay Il1afY1, clay
0.06-0.21
42-74
Loamy t me sand. lowly sand, sand
6.3-20.0
Goldsboro .
0-17
Loam
10-6.3
17-75
Sand, coarse sand
0.63-2.0
From the table, the t?roundwat.er is very shallow and the pernleabllity rites for water are relatively
hi(near the surface. Thus. the risk to �ground�yater could he Ili�zh.
We are not aware of any public or private wells that would he impacted by it dischargc.
Section 14 - Municipal or Other Seneices at Risk
The risks to municipal services that could result h-om a spill are low. 'I he water supply system
and the sanitar- sew�:r line are not located near ,inv potential Sources. The storm drainakle systrul
consists of surface runol1f with curb and iuttcr.
The City of [=arnlyille's waste\\ater treatment faeilit\ is Ideated downstream on the Far Riycr.
However, any potential discharge is not expected to reach this area.
Section 15 - Vessel Mooring
This Section does not apply to this facility.
Section 16 - Facility Training ami `Testing
All maintenance personnel at the facility have been trainees in the procedures to 1611o�v it a spill is
detected. Maintenance team has been established and trained in these procedures. Since limited
equipment to contain a spill is available at the fa6lity, limited training in its use is needed.
Safety training has been provided to these personnel. Disc:har-e drills have not hecn eclndueted.
12

EX111BIT 3
(continued)
Section 17 - Inventory Control
An oil inventory is taken daily by reading a float -hall indicator on the side ofthe flail, and
reconciled daily duril7L! process operation. Records are kept in a computer.
Section I8 - Leak Detection
Leak detection I'm- all the tanks is conducted visually. Inspections arcs conducted Monthly drarin��
plant operation, and the: results are recorded in a hook.
Section 19 - Locating a Leak (all tanks, piping, and transfer equipment)
Visible inspection is the only proposed method oficstin{g and inspecting all tail handling
eeluipiTtent in the event of a discharge. If an oil dischat-c occurs, the tank and pipeline ,vould he
inspected first to insure: their integrity.
If hydraulic fluid is discharged, the roof tanks and associated hose, �yould be inspected lirst.
Section 20 - Preventive Maintenance
Preventive maintenance is conducted yearly during plant sllrtt clown, usually April to .tune.
[)wring; that time, all stora-c, transfer, and holier fuel systems are inspected. tested, repaired. and
tuned as necessary. Records on these operations arc kept.
The tltaxitnum pressure fin- the transt�r system is 20 p«unds.
Section 21 - Facility Security
1,acillty security is provided by a six-foot chain -linked lencc with a Barbed-wire top. Access is
provided by -ates which arc open during the &m. Security perstrnnel are available on the site.
Master flow and drain valves and the starter pump are not locked. Translcr comlections are
capped wlien not in use. The iacility has adequate liohtin"
N

EXHIBIT 3
(continued)
Section 22 - In-house Post -discharge Review Plans
Ill the event of a spill requiring the ilnplelrlcntatiorl of the: procedures in this plan, the Cvent V, ill
be critiqued internally and a report kill he submitted to the NC Department ol'I"riviromrlcnt.
I-lealth, and Natural Re50u1'CCS arxf to Alliance management "ithin 15 drys. "I Ile r-cpL)l-t Mll
include
The name, address, and phone ntllnhclr elf the facility.
2. The -late. time. and tvpe of incident,
3. the e:sUmatcd gUantity ol'product involved and the exact IOCati011 01'tllc illCidClIt.
4. The nature and extent Of injuries. if anv.
5. All ISSCSSrnent Of aCtual Or j)0tC11tral ha/arClS tit 111-1man health Or the em ironment.
li applicable,
6. The estimated glrantlty and llltllllille dISpUSItr011 0l [-CC0VC1-C'd prOdlrCt 111d
contaminated materials r-esultill" FrOM the illCidcrlt, 211d
i. Other pertinent infOrmaticul.
14

EXIIIIJIT 3
(Continued)
Table of Contents
Section I - Facility Location....................................................................
Section 2 - Operator Information .............................................................
Section 3 - Facility Description...............................................................
Section 4 - Oil Products...........................................................................
Section 5 - Storage lntormation...............................................................
Section 6 - ?4-hour Notification Phone Numbers ....................................
Section 7 - Notification ProcedU['Cs.........................................................
SCC 01l 8 - C'ontainrnent and Cleanup Inf-Ormation (24-hou1-).................
Section 9 - Compliance Responsihilit%....................................................
Section 10 - Private Personnel and Fquipment Availahle .......................
Section I I - Worst Case Discharge... ............. - .......... ---- ...................
Section 12 - facility Containment/Reci)yer\I'quipment .........................
Section I - Natural Resources atRisk.........
Section 14 - Municipal or Other Services at Risk ....................................
Section 15 - Vessel Moorinti...................................................................
Section 16 - Facility Training and Tcsting...............................................
Section 17 - inventory Control.................................................................
Section 18 - Leak DetectiOn..........................................
Section 19 - Locating a teak (all tank,. pipin+;, and trantifel' CgUipricrit)
15
...............................'
...............................2
I.......................2
...............................4
...............................4
...............................4
...............................
...............................8
i;
......9
t)

9[
...................................................................... SLllgd ma1, Q t��s[p-lsc�(�snc�tI-uE - ZZ uc�[13')S
...................................................................... [,-1 " L1U[1')"),
..................................................... � ll(11I;1;1ti
(pan1I1;11UJ)

FXIiJBl'1' 3
(continued)
APPENDIX A - SI"I'E. MAI"
� E
3xtu rT efar.ous
€
71
wmmw
Tc WXE € j
wr f mm� l I
wtwm
shncz E
r� �� �f�Ot 111�pOC
iI� E _
"�lf qL I
%AWJJ%�KT� / - �. aTt�Ts_.. € b*Al"E44D
L. l x5srn.: � ► I lAT � y' Itl
E
T
FlIOIw1Y � °'s ( .I�; oau
4T FUUAC
-'�
1 "j;3
um
nays
Xx €rP 4----_
:,RAMNC; TITLE -
A APPEWIX . H
OUTFALL SITE VAP
�, , Q Ch e InraTr3attcn SCALE: DRAWNG NUMBER REV.
F�Lin.:e,':,o hCaraLw—A N.T.S. US;2—SITE OJTFALL 1

EXHIBIT 3
(continued)
Monthly Inspection Checklist
This inspection record must be completed each month except 'the month in which an annual
inspection is performed. Provide further description and comments, if necessary, on a separate
sheet of paper and attach to this sheet. *Any item that receives "yes" as an answer must be
described and addressed immediately.
Y* N
escri tion & Comments
Storage tank
Tank surtacesshow signs of leakage
✓
Tank is derma ed, rusted or deteriorated
Bolts, rivets, or seams are damn ed
Tank supports are deteriorated or buckled
VII
Tankfoundations have eroded or settled
Level Euges or alarms are inoperative
/V
Vents are obstructed
✓
Secondary containment is damaged or stained
Water/ roduct in interstice of double -walled tank
Piping
Valve seals, gaskets, or other appurtenances are
leaking
✓
Pipelines or supports are damaged or deteriorated
✓
Joints, valves and other a urtenances are leaking
✓
Buriedpiping is exposed
✓
Unloading and transfer equipment
Connections are not capped or blank- an ed ✓
Security
Fencing, gates, or lighting is non-functional
✓
Puns and valves are locked i not in use
/, Ct r G o c K r C
Response Equipment
espouse equipment inventory is complete t/ We- a✓e— Ln,.r .fie
Date:3 /D—/L Signature:
19

EXHIBIT 3
(continued)
€ Annual Facility Inspection Checklist
This inspection record must be completed each year. If any response requires further
elaboration, provide comments in Description & Comments space provided. Further description
and comments, if necessary, must be provided on a separate sheet of paper and attached to this
sheet. *Any item that receives "yes" as an answer must be described and addressed immediately,
Y' N Description & Comments
Storage tank
Tank surfaces show signs of leakage
Tank is damaged, rusted or deteriorated
Bolts, rivets or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative _
Vents are obstructed
Oil is present in the interstice
Bolts, rivets, or seams
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Piping
Valve seals or gaskets are leaking
Pipelines or supports are damaged or deteriorated
Joints, valves and other appurtenances are leaking
Buried piping is exposed
Out -of -service pipes are not capped
Warning signs are missing or damaged
Loading/unloading and transfer equipment
Connections are not capped or blank -flanged
Drip pans have accumulated oil or are leaking _
Security
Fencing, gates, or lighting is non-functional
Pumps and valves are not locked (and not in u_se) _
Response equipment
Response equipment inventory is incomplete
Annual reminders:
• Hold SPCC Briefing for all oil -handling personnel (and update briefing log in the Plan),
< Check contact information for key employees and response/cleanup contractors and
( update them in the Plan as needed,
20

EXHIBIT 3
(continued)
Record of Annual Discharge Prevention
Briefings and Training
Briefings will be scheduled and conducted by the facility owner or operator for operating
personnel at regular intervals to ensure adequate understanding of this SPCC Plan. The briefings
will also highlight and describe known discharge events or failures, malfunctioning components,
and recently implemented precautionary measures and best practices. Personnel will also be
instructed in operation and maintenance of equipment to prevent the discharge of oil, and in
applicable pollution laws, rules, and regulations. Facility operations and other personnel will
have an opportunity during the briefings to share recommendations concerning health, safety,
and environmental issues encountered during facility operations.
Date
Subjects
Employees in Attendance
Instructors)
Covered
B. Liles, B. Petty, C. Purcell, B. Rasberry, J. Lewis, T.
7/16/2012
All
Koonce, M. Ethridge, K. Cone, W. Evans, C. Beale,
G. Weant
Stanley, A. Murray, F. Gallinoto, J. Elliot, P. Von Arx, R.
Ledbetter and C. Johnson
B. Liles, B. Petty, B. Rasberry, J. Lewis, T. Koonce, R.
8/13/2013
All
Jones, A. Murray, R. Ledbetter
G. Weant
8/20/2014
All
B. Liles, C. Purcell, B, Rasberry, M. Webb, T. Koonce, S.
G. Weant
Brown, P, Von Ark
B. Liles, C. Purcell, B. Rasberry, M. Webb, T. Koonce, S.
8/13/2015
All
Brown, P. Von Ark, A, Kouris, T. Vandiford
G. Weant
D. Bridges, A. Kouris, F. Gallinoto, J. Elliot, D. Gardner,
M. Thomas, J. Atkinson, R. Perry, J. Warner, K. Langley,
8/04/2Dl6
All
Z. Kindlesparker, V. Moss, T. Vester, A. Tyree, S. Garcia,
B. Hicks
A. Murray, H. Mitchell, T. Simonet, R. Ledbetter, J. West,
R. Petty, B. Eaunon, J. Lewis, B. Liles
22

EXHIBIT 3
(continued)
APPENDIX D - EPS EQUIPMENT & PERSONNEL
20 response technicians
Spill Response Trailer
2 Spill Response Vans
2 Box Trucks
2 Vacuum Trucks
3 Pick-up Trucks
2 Spill -response boats (1 motorized, 1 paddle/oar operated)
1 Roll -off truck
3, 20-yd. rolI-off boxes
24 Hr. a day access to assorted heavy equipment (Excavators, Backhoes, etc.)
All necessary spill supplies, containers, pumps, personal protective equipment.
Permits for transporting hazardous waste, oil, non -hazardous materials, septage, & food grease.
A registered NC Ten-day Hazardous Waste Transfer Facility, Used Oil Transfer Facility, Small
Quantity Handler of Universal Waste, and licensed septage & grease transporter. All facilities
are registered and operated in accordance with USEPA, NCDENR and local regulations.
Secondary support for larger events within 2 hours travel time from our branch with access to
additional equipment similar to list above.
23

EXHIBIT 3
(continued)
Inspection Checklist
The following areas are to be inspected on a monthly basis and this checklist signed and dated bythe
inspector and his supervisor.
YEAR
�
i
.
IFACILITY
1 MAN
FEB
MARCH
I APRIL
MAY
1 JUNE JULY�
_ AUG t SEPT
OCT i NOV I DEC
OUTFALL 1
OUTFALL 2
OUTFALL 3
GROUNDS OVERALL
BAG HOUSE AREA
DIRT DUMPSTER AREA
ROOFTOP
SPILLS: I F YES DESCR[8E SELMY
DESCRIBE ANY REMEDIAL ACnONSTAKEN W[THDATE:
__..._4
_.___-_
f
I
i
-
-- -- -- --- - -
--- -r -
- - -- - -
#
L '
t
1
i

EXHIBIT 5.1
rtwrisonr. Blending Department Cleaning Checklist
�/o
ROMChamber
Vacuum
Ordering
Cylinder
Conveyor
DA Pans
quipment
Over Product
Blow Dawn
Equipment
Slaw Down
Under Feeders
Ordering
Cylinders
Conveyor
Bottoms
Walls and
Ceiling
Dusthouse
(Farmver Only)
Weeld
8i-mwrthl
Semi-Annuafl
Annuall
Annuall
Annual?
AnnuaR?
-v
3-l(
3��
3/y
Date
i/��
ila
ai,_
W
Date
3/�c
3/�L
�/L
?//<
s �G
s ii
3/ie
r!
A
a iE
Date
'/.z
3%Z Y
3/-1 v
7/2
Date
3/?;
I/s
3/3,
r
Date
Y/ ;
y/7
111/7
Y / 7
Date
Y/, l
`T/2 r
+//z I
Date
ZY
1.s
�/. `•
Y112 S'
--Late-
Date
; /l `}
5'r's
511 p
57/j
Date
S/t6
S/16
S 1G
�Jz(,
Date
�r Z
i l2
C z
t! 2c
Data
Date
6 12.1
fA'S
(i3
Qz3
Date
Date
7i !
'i, `•+
7/, 'ti
7!"1
?y Y
Date
7�zd
17IL-7
—t o
-a-;a
7-1n
Date
7/x'
7/s 1
7/i 7

EXHIBIT 5.1
(continued)
tlSIIC UCb �`�3-1G2< ��
Blending ©epartmeni Meaning Checklist
Item
Vacuum
Ct%amber
Ordering
(.yonder
Convayar
Dirt Pens
wpmen
Over Product
BICNDawn
I
Equipment
BtawDaum
Isarni-MnUaNy
Under Feeders
Ordering
CyMders
Conveyor
bottoms
Walls and
ceging
Ousthouse
IFer..:vaeQ*j
Fre
Wee
Woeld
Wo Id
067wtmy
IAnmmify
Ann
Mnua#y
A22ua
Date
$/s
411-
SIr
s
Dale
V"
4 / u
Ph
o +!
Date
f�'-1
��_ r
1 /,:.
U,Z. l:
Date
q•2�
S-i?
4-Z7
y-G•7
Dab
Daa
4ir1
Q/4
-i A
9
Date
Date
J
Daba•�
to/,
/C r
to 1
/0 J
D
oh
Jo 9
/a q
Date
/c •r
c I rY
la rY
,c r r
Date
Jt/'t--
iof.
Date
I/-r
Date
Ti`JZ
1J-12
it-I2
Data
II-;�
r!•l S
if
Date
jl-2Y
1i.24
n-lfr
if-2of
Date
17-2
Il-2
i1-•Z
tZ -L
t
cr Re
r2--4
12-i
rz-T
12-
t-11-22-
!Z-!6
Iz-19
It-/6
i2-J6
IL.12
it. -2Z
12-42-

EXHIBIT 5.1
(continued)
Inue oet•^"1s.to-z� ��
Revhbn1• Blending Department Cleaning Checklist
Item
Vacwm
Chamber
Ordering
Cybder
iim
ent
oduct
awn
Equipment
Blow Dawn
Under Foodem
Ordering
Cytlnders
Conveyor
Bottoms
Wally and
Calling
DySL=3e
(FW—Me 0"
F uenC
Wee
Woo
&-monthly
Semi-AnnuaR
Annua
AnnuaF
Annua
Annua
Dae
T7.-19
11-19
9
Dam'
E /Y
r Y
+l`I
! 9
Date
I r a
1 r 7
1/13
1! t 3
Date
rfr j
1/+°
I/Irt
Da;o.
z/ 4
�!
Date
;-/rJ
2i r
?frr
1/,1
Dete
n l )
1-1`l
Date
'/2`/.
a/zY
Zlz
{/Zy
1/tyr,��
Dare
3/3
�/3
3/3
r17
3/3
3�T [''[ r
C�'4�(hui`
;et"i~
Data
3/io/ro
3jro
Date
3 11
3/l?
3/,-7
r
3
7r17
! S�
Date
Date
Dato
Date
Date
Date
Date
Dale
Date
Dale

EXHIBIT 5.1
(continued)

EXHIBIT 5.1
(continued)
Pnm,la, t•F773
Issut 4°. Ju2�to-za
Prizeroorn Department Cleaning Checklist
��
AliM
s

EXHIBIT 5.1
(continued)
Farm IC. I-FD23
1SiuG pa, �t`3.1G .4
'°•�° H Prizercom Department Cleaning Checklist

EXH113IT 5.2
' SAFETY AND HEALTH MANAGEMENT SYSTEM
REVIEW TASK
STORM
WATER DRAINS
TASK REVIEWED: Housekeeping
Reviewer(s): Tal Dixon, Jesse Speight
Review Date(s): 218117
Item
Findings and Conclusions
Recommendations
Entrance to Parking lot— loll side
OK
Side of M8
OK
Clean
In front of'M8 in parking lot
OK
Ml Behind bridge across ditch
OK/SLIGHT EROSION ON
PREVENT EROSION
BANK
Parked lifts and grabs in lot
OK
Ditch along fence where trucks are
MUN AND PINE STRAW
Clean
waiting to be loaded
Dirt Houses
SMALL. AMOUNT OF DIRT
Clean
Back parking lot
OK
T cam Leader's Signaturc:Eddie Petway
Date: 2/20/2017

EXFI I BIT 5.3
COMPLETED WORK ORDERS
2015-10-02 00:00M to 2017.03-02 23:59:59
Wo # Desc./Tech. Equipment Completed
L2-TR-720 L2-TR-720: Ctr FlawslAir 9116115 9.20 AM
Locks s Shakers
L2-TR-722-A
L2-TR-722-A: Incline
W1116 1.41 PM
Product Come. From Shakers
L2-TR-713
L2-TR-713: Ctr FlovniAir
1212115 4.10 AM
Locks & Shakers
L1-TR-603-D
L 1-TR-603-D: Scrap collect
11119115 3:11 PM
Conv. tMM A88 Side
L2-TR-712
L2-TR-712: Ctr FloewslAir
1 OaW15 3:39 AN4
Locks S Shakers
L1-PI.404
L1-PI.404-: Scrap Feed
31117 1 1:18 AM
Li-Pi403
Li-PI-403: HSS Picking
3d1117 11.IS AM
L1-TR-618-E
11ne ul airlock In dun room
Lt-TR-618-E Airlock
1=15 10,12 AM
has a hole In the top of
screen Sep.
BL1
Repair broken tight over
Line 1 Blending
10121t5 10:12 At-1
platform for dust. collect
L2-STM-813
5552 Some of the roller belts
L2-STNI-813: Line 2 Stalk
10015 10:12 AM
on the stalk separator are
Remover
wearing thin
L2
BLENDING 2
Line 2
102115 10:12 A13
EXCESSIVE WATER LEAK
FROM COILS OVERHEAD
ONTO AISLE BETWEEN
BLENDING 1
AND BLENDING 2
Li-TR--60D-D
Replace selvage ondelivery
LI-TR--600.1}:Qrder
1Q2r1510:12AM
end of drum.
L1-PR-808
LI-PR-8flat. Dryer #I Unload
1012115 10:07 AM
Oonve'yor3

EXHIBIT G
" Monthly Inspection Checklist
This inspection record must be completed each month except -the month in which an annual
inspection is performed. Provide further description and comments, if necessary, on a separate
sheet of paper and attach to this sheet. *Any item that receives "yes" as are answer must be
described and addressed immediately. J
Y* N escription & Comments
Storage tank
Tank surfaces show si s of leakage
Tank is damaged, rusted or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gay,es or alarms are inoperative
Vents are obstructed
Secondary containment is damaged or stained
Waterproduct in interstice of double -walled tank
Piping
Valve seals, gaskets, or other appurtenances are
leaking
Pipelines or supports are damaged or deteriorated
Joints, valves and other appurtenances are leaking
Buriedpiping is exposed
✓
Unloading and transfer equipment
Connections are not capped or blank -flanged
✓
Security
Fencing, gates, or lighting is non-functional
✓
Pumps and valves are locked if not in use {, r� a, ,G ac iCr�
Response Equipment
Response equipment inventory is complete t/
Cr se— Cawr z/ C-
Date: Signature:

EXHIBIT S-B
To be attached to the Farmville SWPPP
Supplement to SWPPP
Tier one Evaluation
Alliance one International, Inc.
Farmville Facility
Farmville, NC
CQC - NCG060224
November 2, 2015

EXHIBIT 8-I3
(continued)
Purpose
The purpose of this supplement is to define the steps taken by AOI in response to the
exceedence of the benchmark values for Total Suspended Solids (TSS) discovered in
the analyses of stormwater samples at its Farmville facility in Farmville, NC.
Timeline
Date Samples Taken - November 2, 2015
Date Results Received - November 13, 2015
Date Results Sent to NC DWC - Results not sent to DWC per Tom Edgerton,
Washington Region, November 20, 2015. Results filed in SWPPP.
Date of Site Inspection (Tier One) - December 13, 2015
Stormwater Management Inspection
On December 13, 2013, a stormwater management inspection of the facility was
conducted by Terry Koonce. Each of the outfalls and the areas between outfalls was
examined to determine if anything unusual could be observed.
No unusual activities or events were observed. Therefore, no direct reason for the
increased TSS value at Outfall #1 could be found.
Potential Causes of COD High TSS Levels
The cause of the high TSS level is probably high truck traffic at the facility next door,
Corrective Action
Since no reason could be found for the TSS levels, corrective actions were not started.

)-43 .1.14.i I I1 X;I

EXHI131T 9-B
SAFETY AND HEALTH MANAGEMENT SYSTEM
REVIEW TASK
PUMP ROOM
TASK REVIEWED: Housekeeping
Reviewer(s): Bob Arsenault, Jessie Speight. Eric Thomas
Review Date(s): 6/24/14
Item
Findings and Conclusions
Recommendations
A. Are ~walking and working surfaces
Yes
clean and Irce of obstructions
including excess dirt & .eater?
13. Are aisles defined?
Yes
C. Are racks, dirt/trash hoppers stored
Yes
in assigned locations & not
overflowing?
D. Are hoses and cords offthe floor?
Yes
17. Are machines and areas around
Yes
machines clean?
P. Are needed items in their assigned
No. Mangers needed for brooms
Install hungers per 5S
location?
and shovels.
program.
Co. Are unnecessary items removed from
No. Various pipes and screens
Remove un-needed items.
the work area?
propped against West wall.
1-1. Are items stored in front ol'and
Yes. Bag of oil dry is on floor in
Remove bag ol'oil dry.
obstructing electrical switches. fire
front of extinguisher PR35
extinguishers. fire hoses, fire doors or
other emergency equipment'?
I. Are chain guards properly installed?
Yes
J. Are storage cabinets & closets clean
Yes
& orderly?
K. Are all overhead areas clean &
Yes
secure'?
L. Miscellaneous
Fire extinguisher 11105 not
Inspect PR35
inspected in June.
Oil seeping through South hall,
Repair leaks and clean up oil.
Oil on floor from stem press
Repair leaks and clean up oil.
Pump unit 4639. Oil and saturated
oil dry under unit.
Tcam Leader's Signature: Date:

EXHIBIT 9-B
(continued)
SAFETY AND HEALTH TASK GROUP
MEETING MINUTES
Task Group: HOUSEKEEPING
Chairperson: Eddie Petway
Meeting Date:1/6/2014
Meeting Location: Conference room
Meeting Time:
Began 3:30 pm
Ended 3:45 prn
Attendees: Jessie Speight, Tal Dixon , Eddie Petway, Derek Vincent,
Bob Arsenuault Tim smith , Richard Barnes Eric Thomas
Absent:
Visitors:
Subject(s) Discussed: Went over last month's inspections and feedback from follow up.
New assignments were assigned.
Recommendations:
Other Items-, This month's inspection due by 24th
Next Meeting:
Date: 2110/2014 Time:3:30
Location: Classroom
Assignments:
Eric, Tat, Jessie, Parking lots, vehicles, parts room, boiler room, lifts, truck shop,
maintence shop.
Bob, Richard, Tim- threshing 1 and 2, dust bags dirt room,
Minutes Prepared By: Derek Vincent
Date: 1/8/14
Route Copies to: I —Task Group Members 2 — Safety Committee Chairperson
3 — Safety Coordinator 4 — Pile

EXHIBIT 9-B
SAFETY AND HEALTH TASK GROUP
Number: 43
MEETING MINUTES
Date:2/27114
Task Group: Fire & Emergency
Chairperson: Bobby Rasberry
Meeting Date: 2127/14
Meeting Location:
Plant Conference Room
Meeting Time:
Began am/pm
Ended am/pm
3:30 PM
3:30 PM
3:50 PM
Attendees:
Bobby Rasberry, Russell Beaman, Jack Griffin, Bruce Morrison, Danny Dunn, J.C. McNeil,
Robert May
Absent: NONE
Visitors: NONE
Subject(s) Discussed:
I. Installed thermometers in valve houses for temperature monitoring purposes.
2. Williams completed the yearly inspection of the sprinkler system.
3. Starter on air compressor in F2 storage was repaired.
4. Replaced 2 sprinkler system regulators in the main plant.
5. Reviewed the following ongoing assignments:
Russell -- Emergency and exit lighting
Danny — Fire water systems
J.C. — Dire extinguishers
Bruce — Fire doors
Recommendations:
Other Items:
Inspection of emergency system speakers.
Inspection of valve house bells.
Next Meeting
Date:
Time:
Location:
3/26/14
3:30 PM
Plant Conference Room
Assignments:
Continue ongoing assignments
Minutes Prepared By: Jack Griffin
Date: 3/4/14
Route Copies to: I —Task Group Members 2 — Safety Committee Chairperson
3 — Safety Coordinator 4 — File

EXH 113IT 9-C
Annual Storm Water Training Sign In Sheet
Instructor � A v % �_ _ PG Date
avlaL��
Subjects Covered a . W.
Attendees
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(continued)
Annual Storm Water 'Training Sign In Sheet
Instructor
Subjects Covered
Date
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EXHIBIT 13
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: or Certificate of Coverage No.: NICIGI
Facility Name: QLk1-► Q D CC ®PL- .111 Vf f' CIGilf L 1 PC f C.
County: 101`-- Phone No.
Inspector: �i1 �1 4 Yl i L 2 f h �C� h ti�vi J R S EJ
Date of Inspection: � a — 5 — 1
Time of Inspection: D `. 5'5 0�
Total Event Precipitation (inches): Q .
Was this a Representative Storm Event? (See information below) Z/Yes ❑ No
Please check your permit to verify if Qualitative Monitoring must be perfornzed during a representative
storm event (requirements vary).
A "Representative Storm Event" is a storm event that measures greater than 0.1 inches of rainfall and that
is preceded by at least 72 hours (3 days) in which no storm event measuring greater than 0.1 inches has
occurred. A single storm event may contain up to 10 consecutive hours of no precipitation.
By this signature, I certify that this report is accurate and complete to the best�)f my knowledge:
k.
of Permittee or Designee)
L Outfall Description: p,
Outfall No. 3 Structure (pipe, ditch, etc.) l -1�"C
Receiving Stream: i as l t, Sw ab-,
Describe the industrial activities that occur within the outfaIl drainage area: T0_•-� ' �-
2. Color: Describe the color of the discharge usin basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:. ewp, IYI Al Ldi _ j2n
3. Odor: Describe any distinct odors that the discharge may have (i.e„ smells strongly of oil, weak
chlorine odor, etc.): IQ O !�!�
Page I of 2
SWU-242-051308

EXHIBIT 13
(continued)
4. Clarity: Choose the number which best describes the clarity of the discharge, where I is clear
and 5 is very cloudy;
1 a 3 4 5
5. Floating Solids: Choose the number which best describes the amount of floating solids in the
stormwater discharge, where 1 is no solids and 5 is the surface covered with floating solids;
D 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in
the stormwater discharge, where 1 is no solids and 5 is extremely muddy;
2 3 4 5
7. Is there any foam in the stormwater discharge? Yes o
8. Is there an oil sheen in the stormwater discharge? Yes f CVO
9. Is there evidence of erosion or deposition at the outfall? Yes Q
10. Other Obvious Indicators of Stormwater Pollution:
List and describe N U
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosiotVdeposition may be
indicative of pollutant exposure. These conditions warrant further investigation.
Page 2 of 2
SWU-242-051308

Q
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I?XII I IA I' 14-11

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X
W.

l'A-t l .I.IHIIIX 1

EXHIBIT 14-F