NCG210192_COMPLETE FILE - HISTORICAL_20151123

r-
STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
IV c, a 1 d l a�
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ pgal � 11 93
YYYYMMDD

North Carolina Department of Environmental Quality
Pat McCrory
Governor
November 23, 2015
Brian Dyson
Pallet One, Inc
165 Turkeyfoot Road
Mocksville, NC 27028
Subject Compliance Evaluation Inspection
NPDES General Stormwater Permit NCG210000
Certificate of Coverage NCG210192
Pallet One, Inc
Davie County
Dear Mr Dyson
Donald R van der Vaart
Secretary
On November 12, 2015 Gien White of the Winston-Salem Regional Office of the NC Division of Energy,
Mineral, and Land Resources (DEMLR) conducted a compliance evaluation inspection at the subject facility
located on Turkeyfoot Road Your assistance with the inspection was greatly appreciated The facility was
found to be in compliance with its permit requirements An inspection report is attached for your records
and the inspection findings are summarized below
1 Permit
This facility holds General Storm water Permit No NC210192 to discharge Storm water from activities
associated with Lumber and Wood Products Except Furniture under the National Pollutant Discharge
Elimination System (NPDES) The permit became effective August 1, 2013 and expires July 31, 2018 Your
permit renewal package must be received in the Central Office in Raleigh no later than 180 days prior to the
expiration date of the permit
2 Records/Reports
Part il, Section A of the permit requires the development of a Stormwater Pollution Prevention Plan (SPPP)
The plan must include all nine (9) subsections of Part il, Section A of the permit The SPPP plan must be
updated annually and qualitative and analytical monitoring must be conducted and properly documented
semi-annually to retain compliance with the permit Training and maintenance procedures must be current
and updated annually The SPPP was kept In one file cabinet and contained all required information
Records were easily accessed for review The facility conducts required training and documents once yearly
Next training event due to be completed by December 2015 No spills were noted
Division of Energy Mineral and Land Resources
Energy Section • Geological Survey Section • Land Quality Section
1612 Mail Service Center Raieigh North Carolina 27699-1612 • 919 707 9200 / EAX 919 715 8801
S12 North Sal isbury Street, Raleigh North Carolina 27604 • Internet http //portal ncdenr org/web/Ir/
An Equal Opportunity \ Affirmative Action Employer — 50% Recycled \ 10% Post Consumer Paper

3 Facility Site Review
The facility manufactures wood pallets used by a variety of vendors throughout industry and builds standard
and specialized pallets for their clients There is a fuel tank and a dip tank located onsite Both have
secondary containment The dip tank is used to dip pallet lumber for preservation and mold prevention The
site does perform vehicle maintenance but stays below 55 gal/mo as records indicate All areas for parking
and drives are covered in gravel or concrete All other areas are covered with established grass The site has
(3) three outfalls Two converge just below the sediment pond and could be combined
4 Effluent/Receiving Waters
Stormwater from outfalls 2 and 3 combine before reaching Hunting Creek, Class "WS III" waters of the
Yadkin Pee -Dee River Outfall 1 drams to Bear Creek, Class "C" waters of the Yadkin Pee -Dee River Basin
5 Self -Monitoring Program
Analytical Monitoring Analytical monitoring has been conducted per permit requirements since the 2011
inspection Facility has in the past had high TSS readings and was required to enter Tier 2 Response:or
monitoring Current and recent results show TSS within parameters but pH results have been below
parameters in recent samples The next testing result should be available around the time this letter is
received If pH continues to be low, operating procedures may need to be modified
6 Qual_itative Monitoring All qualitative records do not need to be submitted to DEMLR, however, the
records must be kept on file at the facility for a period of five years This site is required to complete
qualitative monitoring twice annually Monitoring records were current and available for review at the time
of inspection
Please continue to monitor analytical results closely to ensure compliance within required
parameters including pH reading Ensure pH meter is calibrated regularly and pH is read at the time
of collection This result will not be accurate if read when sample reaches the lab
If you have any questions concerning this letter or the attached Inspection report, please contact Glen White
at [phone]
Sincerely,
Matthew E Gantt, P E
Regional Engineer
Land Quality Section
Attachments
1 BIMS inspection Checklist
CC Division of Land Quality — WSRO

Permit NCG210192 Owner Facility Pallet One Inc
Inspection Date 11112t2015 Inspection Type Compliance Evaluation
Reason for Visit Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
® ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
® ❑1 ❑ ❑
# Does the Plan include a Narrative Description of Practices ?
Is ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
® ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ ®❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
IN ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
® ❑ ❑ ❑
# Does the Plan include a BMP summary?
® ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
ON ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeepmg Plan?
® ❑ ❑ ❑
# Does the facility provide and document Employee Training?
® ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
®❑ ❑ ❑
# is the Plan reviewed and updated annually?
®❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
®❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
® ❑ ❑ ❑
Comment No Spills noted Facility does conduct training that Includes spill response
All records were
kept In a file cabinet together and were easily found by Mr Dyson
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi annually?
®❑ ❑ ❑
Comment Monitorinq performed twice annually per permit requirements
Analytical Monitoring
Has the facility conducted its Analytical monitonng?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment This facility is required to conduct analytical monitormq and does so twice annuallv Has had
Yes No NA NE
® ❑ ❑ ❑
❑❑®❑
elevated TSS in the past but within parameters In last few monitoring events pH was low In last
samples taken Newest results should be available in week or two If results below parameters
continue, may need to look for the cause and make modification
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site's ® ❑ ❑ ❑
# Were all outfalls observed during the inspection? ®❑ ❑ ❑
# If the facility has representative outfall status is it property documented by the Division? ❑ ❑ ® Cl
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ® ❑
Comment Current copy of the permit was available in the file
Page 3

Mickey, Mike
From Peter DeVries [phd@geotec com]
Sent Friday, May 13, 2011 3 47 PM
To Mickey, Mike
Subject PalletOne Mocksville
Mike,
I indicated in previous correspondence that I would have the SP3 plan for PalletOne in
Mocksville done today However, I have spent so much time on the E&SC plans that the SP3 plan
is not completed However, it is almost done and I will have it to the client by the end of
next week
Brian Dyson at PalletOne sent me lab results for the April sampling and outfalls 1 and 3 are
still slightly over the 100 benchmark, but # 2 was way below We gave Brian completed E&SC
plans about a week ago and the contractor that will be doing the E&SC improvements was
supposed to look at the site today and get working next week So we should see some
improvement, perhaps in the May sampling, if we can wait until late in the month But surely
next month
Thanks for your help and patience
Sincerely,
Peter H DeVries
Geoscience & Technology, P A
2050 Northpoint Dr
Winston-Salem, NC 27106
336 896 1300
336 896 1020 (fax)
ghd(@geotec com
I

2050 Northpoint Onve • Suite A
RECEI p
N C Dept of ENR
JUL 1 1 20H
Mnston�Salem
Regicnal Office
July 7, 2011
Mr Corey Basinger
Water Quality Regional Supervisor
DIVISLOD of Water Quality
North Carolina Department of Environment and Natural Resources
585 Waughtown Street
Winston-Salem, NC 27107
ston-Salem NC 27106
Phone [phone]
Fax [phone]
geosci@geotec com
www geotec com
SUBJECT Notification of Stormwater I otal Suspended Solids in Excess of Benchmark Value
for PaIletOne of North Carolina, Mocksville, Certificate of Coverage #NCG210192
Dear Mr Basinger
On behalf of PalletOne of North Carolina, Mocksville (Pallet0ne), Gcoscience and Technology, P A
(GeoSci) is pleased to submit this notification of stormwater Total Suspended Solids (TSS) in excess
of benchmark value for two outfalls Part II, Section B of the Certificate of Coverage requires written
notification to the Regional Office of the NC Division of Water Quality (DWQ) if any specific
parameter exceeds the benchmark value at any outfall on more than four occasions I he benchmark
value for Total Suspended Solids (TSS) for outfall 3 was exceeded on 6/23/10, 1/26/11, 3/28/11,
4/22/l l and 5/27/11 hSS for outfall 2 was exceeded on 6/23/10, 1/26/11, 3/28/11, and 5/27!11 The
following table summarizes historical results for the three outfalls at the facility through the May
sampling event
Ranrhmrk
10000 17 nn - q n0 120 on
Outfall #
Date Collected
Total Rainfall
TSS
pH
COD
1
6/23/10
075
5880
679
4700
2
6/23/10
075
11800
685
4600
3
6/23/10
075
62500
681
4300
1
1/26/11
050
11200
635
<25
2
1/26/11
050
18500
631
<25
3
1/26/11
050
16500
640
<25
1
n/a
n/a
n/a
n/a
n/a
2
3/28/11
060
11300
694
<25
3
3/28/11
060
13200
724
<25
1
4/22/11
070
12000
653
6600
2
4/22/11
070
2950
650
7300
3
4/22/11
070
11530
643
4500
1
5/27/11
063
31600
647
<25
2
5/27111
063
22500
643
2600
3
5/27/11
063
48600
645
<25

Tier lI responses were instituted in March 2011 in response to two consecutive TSS concentrations in
excess of benchmark values Those responses included a facility stormwater inspection on March 30,
2011, institution of monthly sampling and preparation of sediment and erosion control (E&SC) plans
to mitigate offsite transportation of sediment The engineering staff at GeoSci prepaied the E&SC
plans l311an Dyson, Plant Manager for PalletOne, indicated that a contractor has been hired to
implement the E&SC plans with a proposed completion date of August 1, 2011, weathei permitting
It is GeoSci's opinion that the E&SC improvements should significantly deciease offsite transport of
sediment Mr Dyson indicated that PalletOne is also in the process of placing washed #57 stone on
areas within parking lots where high concentrations of fine-grained sediment are present to reduce
stormwater sediment transport
Assuming the E&SC measures are completed by August I", Pallet0ne and GeoSci anticipate
significant decreases in ISS values at all outfalls for the August sampling event PalletOne considers
the stormwater sediment issue a priority and begs DWQ's indulgence and patience as the E&SC
measures are implemented and the effects evaluated
Please call us at 336 896 1300 if you have questions concerning this response or require additional
information
With best regards,
GEOSCIENCE AND TECHNOLOGY, P A
Vt
eter H DeVries
Project Geologist
cc
Brian Dyson
Plant Manager
PalletOne of North Carolina
165 furkey Foot Road
Mocksville, NC 27028
Mike Mickey
Division of Water Quality
North Carolina Department of Environment and Natural Resources
585 Waughtown Street
Winston-Salem, NC 27107
PallctOne Mocksville July 7, 2011
1 SS in Excess of Benchmark 2

Mickey, Mike
From
Peter DeVnes [phd@geotec corn]
Sent
Friday, April 15, 2011 3 34 PM
To
Homewood, Sue, Mickey, Mike
Cc
Brian Dyson
Subject
FW PalletOne (UNCLASSIFIED)
------ Forwarded Message
From "Thomas, John T JR SAW" <John T Thomas JR@usace army mil>
Date Fri, 15 Apr 2011 13 37 57 -0400
To "Peter DeVries" <phd@geotec com>
Cc "Homewood, Sue" <sue homewood@ncdenr gov>
Subject RE PalletOne (UNCLASSIFIED)
Classification UNCLASSIFIED
Caveats NONE
Peter
As we discussed Google earth's aerial photo shows no pond dated Jan 27, 1993
The March 12, 1998 photo does show the pond So, the pond would have been built between
those dates The 1993 aerial does not show any evidence the site of the pond included a
stream channel Therefore based on that photo, the quad map for the site, and the fact that
you have provided me a plan showing the pond was constructed for soil and erosion control, it
is my determination that the pond is a treatment system and not a Jurisdictional water
subject to Department of the Army permitting
John Thomas
Raleigh Regulatory Field Office
919 554-4884 ext 25
-----Original Message-----
FromPeter DeVries [mailto phd@geotec com]
Sent Friday, April 15, 2011 10 28 AM
To Thomas, John T JR SAW
Subject PalletOne
John,
Attached is a pdf of the site plan we talked about for the PalletOne site in Mocksville
Thanks for your assistance with this matter
Peter H DeVries
Geoscience & Technology, P A
2050 Northpoint Dr
Winston-Salem, NC 27106
336 896 1300
336 896 1020 (fax)
phd(@geotec _com
Classification UNCLASSIFIED
Caveats NONE
1

Mickey, Mike
From Peter DeVries [phd@geotec com]
Sent Friday, April 15, 2011 3 13 PM
To Homewood, Sue, Mickey, Mike
Cc Brian Dyson
Subject Re PalletOne
Sue,
I have been corresponding with John Thomas regarding the sediment pond at this facility The
pond was apparently constructed sometime between 1993 and
1997 as part of an E&SC plan and we have a plan drawing to that effect I sent that to John
at his request John also looked at historical USGS maps and historical aerials on Google
Earth and he is pretty much convinced that the pond was constructed for that purpose He is
supposed to send me an email stating that the Corps will not claim Jurisdiction since it is a
treatment unit and that we can go ahead with plans for a forebay without a permit I will
forward that to you in case he does not Do you need anything else from us in that regard?
Thanks,
Peter H DeVries
Geoscience & Technology, P A
2050 Northpoint Dr
Winston-Salem, NC 27106
336 896 1300
336 896 1020 (fax)
phditeotec com
> Hi Peter,
> After talking to Mike it appears that you may be able to make a case
> to the USACE that the pond is a "treatment unit" and therefore the
> USACE would allow you to modify it without the need for permits That
> call is really John Thomas's to make so I suggest you contact him to
> determine if there will be a need for any permits If so, find out
> which Nationwide Permit he is going to cover the work under and then we
need anything from DWQ
> If you have any follow-up questions, please call or email anytime
> Sue Homewood
> NC DENR Winston-Salem Regional Office
> Division of Water Quality
> 585 Waughtown Street
> Winston-Salem, NC 27107
> Voice [phone]
> FAX [phone]
> E-mail correspondence to and from this address may be subject to the
> North Carolina Public Records Law and may be disclosed to third parties
> -----Original Message-----
> From Mickey, Mike
> Sent Wednesday, April 13, 2011 9 12 AM
> To Peter DeVries
> Cc Brian Dyson, Homewood, Sue
can decide of you

Mickey, Mike
From Peter DeVries [phd@geotec coml
Sent Wednesday, April 13, 2011 11 22 AM
To Mickey, Mike
Cc Brian Dyson
Subject Re PalletOne
Thanks Mike Sue Homewood sent me a response as well and I have contacted John Thomas to see
what he thinks I am awaiting his reply but we are going ahead with details on the other
erosion control measures so they can get a contractor
Peter H DeVries
Geoscience & Technology, P A
2050 Northpoint Dr
Winston-Salem, NC 27106
336 896 1300
336 896 1020 (fax)
phd(@eeotec com
> Peter - The proposed measures should help lower TSS levels by reducing
> velocity and adding storage The forebay will definitely make future
> maintenance of the larger sediment pond easier Sue Homewood
> (771-4964) would be the contact in our office for the wetland issue Thanks for the update
> Mike
> --------------------------------------------------
--------------------
> Mike Mickey
> Mike_Mickey(@NCDENR gov
> NC Division of Water Quality
> 585 Waughtown Street
> Winston-Salem, NC 27107
> Phone [phone]
> FAX [phone]
> E-mail correspondence to and from this address may be subject to the
> North Carolina Public Records Law and may be disclosed to third parties
> -----Original Message -----
> From Peter DeVries [mailto phd@geotec com]
> Sent Tuesday, April 12, 2011 4 15 PM
> To Mickey, Mike
> Cc Brian Dyson
> Subject PalletOne
> Mike,
> I sent an engineer out to PalletOne last
> and short-term erosion control measures
> He recommended
week to determine immediate
> 1) A washed stone and riprap ditch along the tree line at the east
> side of the site at the edge of the parking lot that will discharge to Outfall i
> 2) Washed stone in a 30' radius from the intake and silt fence around
> the intake to Outfall 1
> 3) A grass lined ditch at the northwest edge of the storage parking

> lot that discharges to the intake to Outfall 2
> 4) Rock check dams below the discharge of Outfall 2 in the existing
> riprap ditch
> 5) Create a forebay across the inlet to the existing sediment pond
> that discharges to outfall 3
> Attached is a pdf of the site with an aerial photo You can get scale
> from the lot dimensions on the drawing I roughed in the control
> measures as indicated above
> what do you think of these measures? If you are in agreement, at least
> in principal, we will draw up plans and specs so PalletOne can get started
> The forebay is going to require filling and dredging in the pond and
> possibly ad3acent wetlands The impacted area is less than 0 1 acres
> (approx 75'X35'), so I am assuming that it will not require a permit or mitigation
> In fact we are proposing to improve the water quality and at is
> something that should have been installed when the pond was built Who handles this area
re
> stream/wetland impacts, Sue Homewood? Amy Euliss?
> Brian Dyson also sent me results from the March sampling, which I
> think he has sent to you as well The results are again over the
> benchmarks, which puts them in Tier III We are doing everything we
> can to mitigate the sediment, so I feel that PalletOne is complying with their obligations
> Sincerely,
> Peter H DeVries
> Geoscience & Technology, P A
> 2050 Northpoint Dr
> Winston-Salem, NC 27106
> 336 896 1300
> 336 896 1020 (fax)
> phd(@geotec com
2

Mickey, Mike
From
Peter DeVnes [phd@geotec com)
Sent
Tuesday, April 12, 2011 4 15 PM
To
Mickey Mike
Cc
Brian Dyson
Subject
PalletOne
Attachments
Prelim ESC pdf
Mike,
I sent an engineer out to PalletOne last week to determine immediate and short-term erosion
control measures
He recommended
1) A washed stone and raprap ditch along the tree line at the east side of the site at the
edge of the parking lot that will discharge to Outfall 1
2) washed stone in a 30' radius from the intake and silt fence around the intake to Outfall
1
3) A grass lined ditch at the northwest edge of the storage parking lot that discharges to
the intake to Outfall 2
4) Rock check dams below the discharge of Outfall 2 in the existing riprap ditch
5) Create a forebay across the inlet to the existing sediment pond that discharges to outfall
3
Attached as a pdf of the site with an aerial photo You can get scale from the lot dimensions
on the drawing I roughed in the control measures as indicated above
What do you think of these measures? If you are in agreement, at least in principal, we will
draw up plans and specs so PalletOne can get started
The forebay is going to require falling and dredging in the pond and possibly adjacent
wetlands The impacted area is less than 0 1 acres (approx 75'X35'), so I am assuming that it
will not require a permit or mitigation
In fact we are proposing to improve the water quality and at is something that should have
been installed when the pond was built Who handles this area re stream/wetland impacts, Sue
Homewood? Amy Eulass?
Brian Dyson also sent me results from the March sampling, which I thank he has sent to you as
well The results are again over the benchmarks, which puts them an Tier III We are doing
everything we can to mitigate the sediment, so I feel that PalletOne as complying with their
obligations
Sincerely,
Peter H DeVries
Geoscaence & Technology, P A
2050 Northpoant Dr
Winston-Salem, NC 27106
336 896 1300
336 896 1020 (fax)
phdOgeotec cam
1

Mickey, Mike
From Homewood Sue
Sent Wednesday, April 13, 2011 9 34 AM
To Mickey Mike, Peter DeVries, Thomas John T JR SAW
Cc Brian Dyson
Subject RE PalletOne
Hi Peter,
After talking to Mike it appears that you may be able to make a case to the USACE that the
pond is a "treatment unit" and therefore the USACE would allow you to modify it without the
need for permits That call is really John Thomas's to make so I suggest you contact him to
determine if there will be a need for any permits If so, find out which Nationwide Permit
he is going to cover the work under and then we can decide of you need anything from DWQ
If you have any follow-up questions, please call or email anytime
Sue Homewood
NC DENR Winston-Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Voice [phone]
FAX [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
-----Original Message -----
From Mickey, Mike
Sent Wednesday, April 13, 2011 9 12 AM
To Peter DeVries
Cc Brian Dyson, Homewood, Sue
Subject RE PalletOne
Peter - The proposed measures should help lower TSS levels by reducing velocity and adding
storage The forebay will definitely make future maintenance of the larger sediment pond
easier Sue Homewood (771-4964) would be the contact in our office for the wetland issue
Thanks for the update Mike
Mike Mickey
Mike MickevQNCDENR eov
NC Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Phone [phone]
FAX [phone]
E-mail correspondence to and from this address may be subject to the North
Carolina Public Records Law and may be disclosed to third parties
-----Original Message-----
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March 31, 2011
REcr I � r'
NO d,at of LNR
APR 0 4 2011
W Won 5akem
Regionni Of ice
Mr Corey Basinger
Water Quality Regional Supervisor
Division of Water Quality
North Carolina Department of Environment and Natural Resources
585 Waughtown Street
Winston-Salem, NC 27107
2050 Northpomt Dnve • Suite A
Winston-Salem NC 27106
Phone [phone]
Fax [phone]
geosci@geotec com
www geotec com
SUBJECT Response to NOV for PalletOne of North Carolina Mocksville, Certificate of
Coverage #NCG210192
Dear Mr Basinger
On behalf of PalletOne of North Carolina, Mocksville (PalletOne), Geoscience and Technology, P A
(GeoSci) is pleased to submit this response to an NOV from your office dated March 8, 2011
Based on the laboratory analytical results for outfalls 2 and 3, benchmark values were exceeded for
Total Suspended Solids (TSS) for two consecutive events, therefore, these outfalls require a Tier 11
response The benchmark value for TSS was also exceeded at outfall 1 in the 1126111 sampling event
and is therefore subject to a Tier 1 response Pursuant to the Tier 1 and Tier 11 requirements the
following actions have been taken
Brian Dyson, PalletOne Plant Manager, and Mike Spry, PalletOne Human Resources/Safety Director
and Peter DeVries, of GeoSci, conducted a stormwater management inspection of the facility on
March 30, 2011 This inspection was conducted during a rainfall event and stormwater runoff patterns
were easily observed Possible causes of the exceedances noted include
1 The primary source of TSS foi outfall 1 appears to be fine-grained sediment from `crusher
run', which covers the main parking lot
2 The primary source of TSS for outfall 2 appears to be fine-grained sediment from `crusher
run', which covers the trader parking lot
3 The primary source of TSS for outfall 3 dppeais to be fine-grained sediment from `crusher
run', which covers the majority of the storage yards and other unpaved areas
4 A secondary source of TSS for outfall 3 appears to be fine-grained sediment from the mulch
piles
The inspection and subsequent discussions resulted in specific actions to reduce stormwatei sediment
at all outfalls that include

I Construction of sediment traps around the stormwater intakes to filter fine-grained sediment
2 Construction of grass -lined ditches with incrementally placed rock -check dams and silt fences,
where possible
3 Relocate the mulch pile away from the stormwater intakes and place silt fence around the pile,
where possible
Relocation of the mulch pile was previously planned following the sale of the existing mulch pile in
the next few weeks and months Accumulated mulch is typically sold during the spring months and
then accumulated through the summer, fall and winter GeoSci plans to send a civil engineer to the
site during the week of April 4t' to perform a reconnaissance prior to design of the sediment traps,
grass -lined ditches, silt fences and rock -check dams
Additional actions were also discussed, however, they are more economically significant and will he
considered if and when the immediate actions are not effective These additional actions include
I Removal of crusher i un and replacement with washed stone
2 Paving the parking areas
Tiei I and II actions taken as of the date of this report include
I A facility stormwater management inspection on March 30, 2011, as noted above
2 Institution of monthly sampling The most recent sampling event was performed on March 28,
2011
The NOV also mentions that qualitative monitoring reports were only available for one sampling
event Mr Dyson is aware of the requirement to perform visual monitoring during a sampling event
and will document the monitoring on the proper form Qualitative monitoring was performed and
documented for the March 2011 sampling
PalletOne and GeoSci are now to the process of upgrading their Stoimwater Pollution Prevention
Plan (SP3) that will include all the sections referenced in Part 11, Section A of the permit GeoSci
anticipates completion of the SP3 by May 13, 2011
As noted in the NOV, oil usage records were not available during the inspection conducted by Mike
Mickey on 318/11 Mr Dyson provided the oil usage data to GeoSci and it is presented in the
following table
Date
Oil On Hand
Gallons
Oil
Purchased
Gallons
Annual Oil
Usage
Gallons
Monthly Oil
Usage
Gallons
2/3/09
200
4/23/09
200
8/11 /09
100
12/3/09
150
12/31 /10
75
575
48
3/25/10
200
5/4/10
100
9/9/10
200
12/31 /10
20
1
555
46
PalletOnc, NOV Response March 31, 2011
2

Based on the oil usage data, it appears that Pait II, Section D of the permit is not applicable, as
PalletOne has not used more than 55 gallons of oil per month in 2009 and 2010 PalletOne is now
documenting oil usage on a regular basis and the tecords will be maintained with all other pertinent
stormwater records
Based on the facility stormwater management inspection, subsequent discussion and a conversation
between Mike Mickey and Mr Dyson, it appears that outfalls 2 and 3 could be combined for
sampling purposes as they both ultimately discharge to the titbutary at the same point It is GeoSci's
opinion that this is feasibly, and desirable as it would reduce laboratory expenses and sampling time
and the data should essentially be the same as combining the curient numbers from the two outfalls It
is also GeoSci's opinion that it would be desirable to rcioute outfall 2 direc-tly into the containment
pond as this would provide detainment time and possibly ieduc,e the amount of sediment dischaiged
to the tributary Accomplishing this will require installation of a pipe and an outfall pad, which will
require some engineering However, lot the time being, PalletOne requests that outfalls 2 and 3 be
combined for sampling purposes, with a designation as outfall 2
Please call us at 336 896 1300 if you have questions concerning this response of require additional
information
With best regaid,,,
GEOSCIENCE AND TECHNOLOGY, P A
Peter H DeVries
Project Geologist
cc
Brian Dyson
Plant gland-yer
PalletOne of North Carolina
165 Turkey Foot Road
Mocksville, NC 27028
PalletOne NOV Responst, March 31 2011
3

Mickey, Mike
From Peter DeVries [phd@geotec com]
Sent Friday, April 01, 2011 9 19 AM
To Basinger, Corey, Mickey, Mike, Brian Dyson
Subject FW Message from "RNP0026732346E4"
Attachments 20110331165848110 pdf
Corey and bike,
PalletOne of North Carolina (Mocksville) has retained Geoscience & Technology, P A to assist
them with stormwater management Attached is a response to the NOV issued relative to their
stormwater permit on March 8, 2011 1 have also sent hard copy via snail mail Please call or
email if you have any questions
Thanks for your assistance and attention to this matter
Peter H DeVraes
Geoscience & Technology, P A
2050 Northpoint Dr
Winston-Salem, NC 27106
336 896 1300
336 896 1020 (fax)
phdogeotec com
1

Fumva.---
Ti actrc al Engineering &
Enwnnnrental Solutions"
Match 31, 2011
Mi Coicy Basinget
Water Quality Regional Supervisot
Division of Water Quality
North Carolina Department of Envnasvnent and Natural Resources
585 Waughtown Street
Winston-Salem, NC 27107
2050 Northpornt Dnve • Suite A
Winston-Salem, NC 27106
Phone [phone]
Fax [phone]
geosci@geotec corn
www geotec com
SUBJECT Response to NOV for PalletOne ofNoith Catolina, Mocksville, Ceitificate of
Covetage 4NCO210192
Deat Mr Basingei
On behalf of Pallet0ne of Not th Catolina, Mocksville (PalletOne), Geoscience and `1 echnology, P A
(GeoScr) is pleased to submit this response to an NOV ftoin your office dated Match 8, 2011
Based on the laboiatoiy analytical results for outfalls 2 and 3, benchmark values were exceeded for
I otal Suspended Solids (TSS) for two conset utrve events, therefore, these outfalls iequne a Ttei Il
response The betichmaik value foi TSS was also exceeded at outfall i in the 1/26/11 sampling event
and is therefore subject to a Tier I response Pursuant to the Tiei I and Tiei 11 iequnements the
following actions have been taken
Brian Dyson, PalletOne Plant Manager, and Mike Spry, Pallet0iie Human ResotriceslSafety Director
and Peter DeVnes, of GeoScr, conducted a stormwatei management inspection of the facility on
Match 30, 2011 This inspection was conducted doting a rainfall event and stoirnwatet runoff patterns
were easily observed Possible causes of the exceedances noted include
I The ptimaiy source of TSS for outfall 1 appears to be fine-grained sediment from `crasher
run', which covers the main parking lot
2 The primacy source of TSS for outfall 2 appears to be fine-grained sediment from `crusher
tun', which covets the trailer parking lot
3 The primary source of TSS for outfall 3 appears to be fine-grained sediment from `crusher
itnt', which covets the majority of the storage yards and other unpaved areas
4 A secondary source of TSS fot outfall 3 appears to be fine-grained sediment fiom the mulch
piles
The inspection and subsequent discussions tesulted in specific actions to reduce stotmwatei sediment
at all outfalls that include

11
1 Construction of sediment traps around the stoimwatet intakes to filter fine-grained sediment
2 Construction of glass-Inted ditches with incrementally placed Lock -check dams and silt fences,
wheie possible
3 Relocate the mulch pile away ftom the stotmwatei Intakes and place silt fence around the pile,
whet c possible
Relocation of the mulch pile was pieviousiy planned following the sale of the existing mulch pile in
the next few weeks and months Accumulated mulch is typically sold during the spring months and
then accumulated through the sumnici, fall and wintei GeoSct plans to send a civil enginect to the
site during the week of Apitl 4" to perfotm a reconnaissance piioi to design of the sediment traps,
grass -lined ditches, silt fences and lock-clieek dams
Additional actions were also discussed, however, they ate more economically significant and will be
considered if and when the immediate actions are not effective These additional actions include
1 Removal of ctushei run and replacement with washed stone
2 Paving the parking aicas
Ttei I and If actions taken as of the date of this iepoit include
I A facility stoiinwatei inanagcment inspection on Match 30, 2011, as noted above
2 Institution of monthly sampling The most recent sampling event was performed on Match 28,
2011
The NOV also metitions that qualitative monttoting tepoits were only available foi one sampling
event Mi Dyson is awate of the requitement to perfoim visual monitoring daring a sampling event
and will document the monitoring on the propet form Qualitative monitoring was performed and
documented foi the March 2011 sampling
Pallet0ne and GeoSct ate now in the process of upgrading then Stoirawatet Pollution Prevention
Plan (SP3) that will include all the sections iefeienced in Pait I1, Section A of the permit GeoSct
anticipates completion of the SP3 by May 13, 2011
As noted in the NOV, oil usage records were not available duung the inspection conducted by Mike
Mickey on 318/11 Mi Dyson provided the oil usage data to GeoSct and it is presented in the
following table
Date
Oil On Nand
Gallons
Oil
Purchased
Gallons
Annual Oil
Usage
Gallons
Monthly Oil
Usage
Gallons
2/3109
200
4/23/09
200
8111/09
100
1213/09
150
12/31 /10
75
575
48
3/25/10
200
5/4/10
100
919/10
200
12 1/101
20
555
46
PalletOne NOV Response March 31, 2011
2

Based on the oil usage data, it appeals that Pait Il, Section D of the peimit is not applicable, as
Pallet0 ne has not used moic than 55 gallons of oil pei month in 2009 and 2010 PalletOne is now
documenting oil usage on a regulat basis and the tecoids will be maintained with all other pe►tinent
stotmwatei iecoids
Based on the facility stoiinwatet management inspection, subsequent discussion and a conversation
between Mike Mickey and Mi Dyson, it appeais that outfalls 2 and 3 could be combined foi
sampling putposes as they both ultimately discharge to the bibutaty at the same point It is GeoSci's
opinion that this is feasible and desirable as it would seduce laboiatoiy expenses and sampling tune
and the data should essentially be the same as combining the current numbeis from the two outfalls It
is also GeoSci's opinion that it would be desnable to ietoute outfall 2 dneetly into the containment
pond as this would piovide detanunent time and possibly ieduce the amount of sediment discharged
to the ttibutaly Accomplishing this will requne installation of a pipe and an outfall pad, which will
iequiie some engineeiing Howevei, foi the time being, PalletOne iequests that outtaIls 2 and 3 be
combined foi sampling purposes, with a designation as outfall 2
Please (Alt us at 336 896 1300 if you have questions conceining this iesponse of iequrie additional
information
With best tegards,
GhOSCIENCE AND TECHNOLOGY, P A
Petet H DeViies
Pioject Geologist
cc
Brun Dyson
Plant Manager
Pallet0ne of North Carolina
165 "hn key Foot Road
Mocksville, NC 27023
PalletOne NOV Response March 31, 2011

Aria
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H Sullins Dee Freeman
Governor Director Secretary
March 8, 2011
Mr Howe Wallace, CEO
PalletOne, Inc
1470 Hwy 17 South
Bartow, FL 33830
Subject NOTICE OF VIOLATION
General Stormwater Permit Inspection
PalletOne of North Carolina, Inc — Mocksville Facility
Certificate of Coverage No NCG210192
Davie County
Dear Mr Howe
On March 2, 2011, Mike Mickey of our office met with Brian Dyson, Plant Manager, to perform a
General Stormwater Permit Inspection at the PalletOne facility in Davie County, NC The inspection
evaluated the five (5) areas designated on the attached inspection form and found PalletOne to be in violation
of the state issued stormwater permit Specifically, the required semi-annual analytical and qualitative
monitoring was not performed in 2010 and a Tier Two response was not initiated for the TSS benchmark
values that were exceeded Observations from each area are addressed below
1 Permit
PalletOne holds Certificate of Coverage # NCG210192 which allows for the discharge of stormwater from
the site The permit expires next on July 31, 2013
2 Records/Re orts
Part 1I, Section A of the permit requires that a Stormwater Pollution Prevention Plan (SPPP) be prepared To
date, a complete SPPP has not been developed The plan should address all applicable items listed in Section
A of the permit and must be kept on file at the facility for review during inspections The plan can be
prepared in-house or you may wish to hire a consultant
3 Facility Site Review
A site map had been prepared showing the three separate stormwater outfalls at the PalletOne site Outfall
# 1 receives stormwater from part of the property along Turkey Foot Road, outfall 42 receives the bulk of the
stormwater from the mill and mulch pile areas and outfall #3 receives stormwater from the trailer parking lot
Observations below each outfall did not reveal any problems or concerns
4 Effluent/Receiving Waters
Stormwater from outfall #'s 2 and 3 combine after the sediment basin and eventually reach Hunting Creek,
Class "WS-I11" Waters in the Yadkin -Pee Dee River Basin Stormwater from outfall # 1 eventually reaches
Bear Creek, Class "C" waters in the Yadkin -Pee Dee River Basin
North Carolina Dimon of water Quality Winston Salem Regional Office
Location 585 Waughtown St Kriston Salem North Carolina 27107 One
Phone [phone] FAX 336 771 A530 1 Customer Service 1 877-623 6748 NorthCarollna
Internet www rimaterquality org Aatura&y
An Equal Opportunity 1 Affirmative Action Employer

;alluOnt. Inc
rage 92
5 Monitoring Program
Part II Section B of the permit requires collection of semi-annual analytical samples at all outfalls during a
representative storm event However, only one monitoring occurred in 2010 A review of data from samples
collected on 6/23/10 and 1/26/11 showed that the TSS values from outfall 4's 2 and 3 were above the
benchmark range of 100 mgll The permit states that a Tier Two response must be initiated if two
consecutive samples of a parameter exceed a benchmark value This involves the immediate institution of
monthly monitoring for all parameters at every outfall where a sampling result exceeded the benchmark (see
page 7 of permit)
PalletOne should initiate the monthly sampling specified in the Tier Two response Sampling must continue
until three consecutive sample results are below the benchmark value if future sampling shows benchmark
values to be exceeded for a specific parameter at any specific outfall on more than four occasions, then the
DWQ Water Quality Regional Supervisor must be notified in writing within 30 days of receipt of the fourth
analytical result DWQ then may require PalletOne to 1) increase or decrease the monitoring frequency, 2)
apply for an individual stormwater permit, 3) install structural stormwater controls, or 4) install other
stormwater control measures
Part 11, Section C of the permit requires that qualitative (visual) monitoring be performed and documented
semi-annually This monitoring was only performed once in 2010 Please make sure this monitoring is
performed and documented in accordance with the schedule in Table 2 of the permit
Part 11, Section D of the permit only applies if the facility uses more than 55 gallons of new motor oil per
month when averaged over the calendar year No recent records were available to determine the exact usage
Please provide our office with the average oil usage for 2009 and 2010
Failure to comply with any permit conditions is a violation of the General Permit Per the permit text
in Part III, Section A (2) `Fhe permittee must comply with all conditions of this general permit Any permit
noncompliance constitutes a violation of the Clean Water Act and is grounds for enforcement action "
Additionally, Part III, Section A (2)(c) states that, "Under state law, a daily civil penalty of not more than
twenty-five thousand dollars ($25,000) per violation may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit [Ref NC General Statute 143-
215 6A]"
You are requested to respond in writing to this office on or before April 8, 2011, providing the oil
usage data requested above and a proposed date for completion of the SPPP
5000
If you have any questions concerning this Notice, please contact Mike Mickey or me at (336) 771-
Sincerely,
W Corey Basinger
Interim Regional Supervisor
Surface Water Protection Section
cc Brian Dyson (PalletOne, Inc 165 Turkey 1 oot Road, Mocksville, NC 27028)
NI'S Assistance and Compliance Oversight Unit
Central Files— SWP
WSRO'

Form Approved
ram"+
OMB No 2040-0057
Approval Expires
8 31 98
United States Environmental Protection Agency Washington D C 20460
Section A National Data System Coding
Transaction Code NPDES No
Yr/Mo/Day Inspection Type Inspector
FacdityType
N 5 NCG210192
11 03-02 C 5
1
Facility Evaluation Rating
131 QA
Reserved
N N
Section B Facility Data
Name and Location of Facility Inspected
Entry Time
Permit Effective
0920 hrs
Date Aug 1, 2008
PalletOne of NorthCarolma, Inc
16) Turkey Foot Road
Mocksville, NC 27028
Exit Time
Permit Expiration
1020 hrs
Date July 31, 2013
Name(s) of On -Site Representative(s)
Title(s) Phone No(s)
Mr Brian Dyson
Plant Manager [phone]
Name, Address of Responsible Official
Title CEO
Mr Howe Wallace
Phone No (800) 771-1 148
Contacted' No
Pallet One, Inc
1470 Hwy 17 South
Bartow, FL 33830
Section C Areas Evaluated During Inspection (check only those areas evaluated)
X Permit NA
Flow Measurement NA Operations/Maintenance NA Sewer Overflow
X Records/Reports X
Monitoring Program NA Sludge Hand Iing/DEsposal NA Pollution Prevention
X Facility Site Review NA
Compliance Schedules NA Pretreatment
X Effluent/Receiving Waters NA
Laboratory X Stormwater
Section D Summary of Findings/Comments
See the cover letter and attached inspection form for specific comments
Name(s) and Signature(s) of Inspectors
Agency/Office/ Telephone
Date
DWQ 1 WSRO / [phone]
1`
Signature of Reviewer
Agency/Office
Date
ADWQ
I WSKO I [phone]
EPA Form 3566-3 (Rev 9-94)

fi'Paht4ne
Brian Dyson
Plant Manager
165 Turkeyioot Road
Mocksville NC 27028
Phone [phone] ext 303
Coll [phone]
Fax [phone]
bdyson@palletone com
www pallotone com

Permit NCG210192 Owner Facility Pallet One Inc
Inspection Date 03I0212011 Inspection Type Compliance Evaluation Reason for Visit Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
n
■
n
❑
# Does the Plan include a General Location (USGS) map?
❑
■
❑
❑
# Does the Plan include a Narrative Description of Practices"?
❑
■
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
Cl
■
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
❑
■
❑
❑
# Does the facility provide all necessary secondary containment?
❑
❑
❑
■
# Does the Plan include a BMP summary?
❑
■
❑
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
Cl
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑
■
❑
❑
# Does the facility provide and document Employee Training?
❑
■
0
Cl
# Does the Plan include a list of Responsible Party(s)?
❑
■
❑
❑
# Is the Plan reviewed and updated annually?
❑
■
❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
Cl
❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑
0
❑
Cl
Comment Part II (A) of the permit requires the development of a Stormwater Pollution
Prevention Plan (SPPP) that, at a minimum, should include the items listed above Only
three of the above components were available for review during the inspection
In regards to the list of significant spills occuring in the last 3 years, the 2010 event
involving the spill of paint residue should be included on this list
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi annually? ❑ ■ Cl ❑
Comment The semi-annual visual monitoring required in Part 11 (C) of the permit was
only performed once in 2010 The last two qualitative monitoring events occurred on
June 23, 2010 and January 26, 2011 Visual monitoring should be performed and
documented semi-annually in accordance with the schedule in Table 2 of the permit
Analytical Monitorrn
Yes
No NA
NE
Has the facility conducted its Analytical monitoring?
❑
M ❑
Cl
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
■ fi
❑
Page 3

Permit NCG210192 Owner Facility Pallet One lnc
Inspection Date 03/02/2011 Inspection Type Compliance Evaluation
Reason for Visit Routine
Comment The semi-annual analytical monitoring decribed in Part II (B) of the permit
was only performed once in 2010 A review of sample data collected on 6/23/10 and
1126/11 showed TSS values that were above the benchmark range of 100 mg/I at
outfall #'s 2 and 3 The permit states that if two consecutive samples exceed the
benchmark value, then a Tier Two response should be initiated The Tier Two requires
monthly monitoring for all parameters at every outfall where a sampling result exceeded
the benchmark This sampling must continue until three consecutive sample results are
below benchmark values
If sample results exceed benchmark values for any specific parameter at any specific
outfall on more than four occasions you are required to notify this office in writing within
30 days of the fourth analytical result
Part II, Section D On -Site Vehicle Maintenance monitoring is only required if the
average usage of new motor oil is > 55 gallons per month
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment The facility has three outfalls
Yes No NA NE
■nnp
nnl■n
Cl Q ❑ ■
Page 4

Mich ILI I Easley Governor
w AT F�Q�
September 12 2008
Howe wake
Pallet One Inc
j185 Turke' Foot Ftd _
Mocksville NC 27028
William G Ross Jr Secretary
North Carolina DLpartme nt of I m iron ntcnt and Natural Resources
C011en Fl Sullins Director
Division of Water Quality
Subject NPDES Stormwater Permit Coverage Renewal
PalletPallet 0 e ncle ncl
COC Number IVCG210192
Davie County
Dear Permittee
In response to your renewal application for continued coverage under stormwater General Permit NCG210000 the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater General Permit This permit has been 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
The following information is Included with your permit package
• A new Certificate of Coverage
• A copy of stormwater General Stormwater Permit NCG210000
• A copy of the Technical Bulletin for the General Permit
• Five copies of the Discharge Monitoring Report (DMR) Form
• Five copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater only and it specifies your obligations with respect to stormwater
discharge controls management monitoring and record keeping Please review the new permit to familiarize yourself with all
the changes in the reissued permit
The more significant changes to the General Permit include the following
• Permit cover page second paragraph — The General Permit now may cover activities that DWQ determines to be similar in
either the process or in the exposed materials to the Timber Products Industry
• Part I Section A — A new provision that facilities draining to 303(d) listed waters or in watersheds with an approved TMDL
may not be eligible for continued coverage at the next renewal of the General Permit
• Part I Section B second paragraph — A new clarification that the permit does not authorize discharges that DWQ determines
are wastewaters
• Part I I Section A — The required contents of the Stormwater Pollution Prevention Plan have been expanded and clarified
• Part 11 Section 8 Table 1 —A new requirement to sample stormwater discharges twice per year for those facilities with
exposed piles of certain materials remaining on site longer than seven days
• Part 11 Section B Tables 2 and 3 and following — For permittees with exposed piles there are new provisions requiring the
permittee to execute Tier One and Tier Two response actions based on the first benchmark exceedence (Tier One) and the
second consecutive benchmark exceedence (Tier Two) Tier Two requires that the permittee institute monthly monitoring
instead of twice per -year monitoring until three consecutive monitoring events show no benchmark exceedences
• Part 11 Section B — For permittees with exposed piles a new provision that four exceedences of any particular benchmark
will trigger increased DWQ Involvement in the permittee s stormwater management and control actions DWQ may direct
the permittee to apply for an Individual permit or may direct the Implementation or installation of specific stormwater control
measures
• Part 11 Section C — Clarification that under the qualitative monitoring provisions of the permit the permittee is obligated to
respond to repeated observations of stormwater pollution DWQ may impose additional stormwater management
requirements if the permittee is non -responsive or if the responses are ineffective
Your coverage under the General Permit is transferable only through the specific action of DWQ
NorthCarolina
vVatura!!y
North Carolina DiN ision of Water Quahty 1617 M td Service CetttLr Ralugh NC 27699 1617 Phone [phone] Customer Service
Intemet h2o enr state nc uslsulstormwater html 012 N Snlisbun tit Ralugh NC 27604 FAX [phone] 623 6748
An Equal OpportunitylAffirmative Action Employer — 50% Recycled/10% Post Consumer Paper

NPDES Stormwater Permit Coverage Renewal
PermitNumber NCG21 6192
Page 2
This permit does not affect the legal requirements to obtain other permits which may be required by NCDENR 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 Jennifer Jones of the Central Office Stormwater
Permitting Unit at [phone]
Sincerely
for Coleen H Sullins
cc DWQ Central Files
Stormwater Permitting Unit Files
Winston-Salem Regional Office

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO NCG210000
CERTIFICATE OF COVERAGE No NCG210192
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
Pallet One Inc
is hereby authorized to discharge stormwater from a Facility located at
Pallet One-lnc
65 Turkey Foot Rd
Mocksville
Davie County
to receiving waters designated as a UT to Hunting Creek, a class WSIll stream in the Yadkin-P ee Dee
River Basin in accordance with the effluent limitations, monitoring requirements and other conditions set
forth in Parts I, II Ill, IV, V, and VI of General Permit No NCG210000 as attached
This certificate of coverage shall become effective September 15 2008
This Certificate of Coverage shall remain in effect for the duration of the General Permit
Signed this day September 12, 2008
for Coleen H Sullins Director
Division of Water Quality
By Authority of the Environmental Management Commission

V4A]�C Michael F Easley Governor
`oho �QpG William G Ross Jr Secretary
North Carolina Department of Environment and Natural Resources
C%J r Alan W Klimek P E Director
--f Division of Water Quality
v �
April 28, 2003
Daniel A Reaves
Sheffield Lumber & Pallet -Dave
PO Box 819
Bartow, FL 27028
Subject NPDES Stormwater Permit Renewal
Sheffield Lumber & Pallet -Dave
COC Number NCG210192
Davie County
Dear Permittee
In response to your renewal application for continued coverage under general permit NCG210000, 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 NCG210000
A copy of the Analytical Monitoring Form (DMR)
• A copy of the Qualitativel Monitoring Form
• 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 the Department of
Environment and Natural Resources, 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 Bill Mills of the Central Office
Stormwater and General Permits Unit at [phone], ext 548
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc Central Files
Stormwater & General Permits Unit Files
Winston-Salem Regional Office
N C Division of Water Quality 1617 Mad Service Center Raleigh NC 27699 1617 [phone]
NCDENR
Customer Service
1 800 623 7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO NCG210000
CERTIFICATE OF COVERAGE No NCG210192
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-2151, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Pallet One Inc
is hereby authorized to discharge stormwater from a facility located at
Sheffield Lumber & Pallet -Dave
165 Turkeyfoot Rd
Mocksville
Davie County
to receiving waters designated as a UT to Hunting Creek, a class WS-III stream, in the Yadkin -
Pee Dee River Basin in accordance with the effluent limitations, monitoring requirements, and
other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No NCG210000 as
attached
This certificate of coverage shall become effective May 1, 2003
This Certificate of Coverage shall remain in effect for the duration of the General Permit
Signed this day April 28, 2003
J64',ul6, & �,�7#--
for Alan W Klimek, P E , Director
Division of Water Quality
By Authority of the Environmental Management Commission

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
SLptunlhu 4 2002
DANILL A RFAVlS
SHLFF'IE] D LUMBI-R & PALLLT-DAVI
PO BOX 819
BAR I OW FL 27029
SuhILU NPDES Storulw ow Pcrnlrt Co) Lr i-L RLnLw it
ShulliCld L1.1i & Plilul d Ivi
COC NurnhLr nLg210192
D IVI . COUIl1V
Dt if PCrniatut
't our I suhty 1s Lurri tili LO�L[Ld Ior ,toinlw ii dlldl ngL li Gunus 11 Pcrnlrt NC6210000 I III,, purmlt L\pnLs
on M uch ;1 200'3 1 h►, D1� rvon si 111 n Luiruntly in thL ProCLss of rcwlltlng thiy I)crnlrt Ind lti ,chc,dLjILd to h lvL.
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In order to 1su1rL your LOIN Ill Lorur igL under the, ,LnLr it pump you must iplik to ihL Dlvimon of W ALI
QLl 11 ]IV (DWQ) 101 1 ,IIL.W,ll 01 your pc[ init tovLl ILL to In ikL this lLn(w It proLLss L IsiLr WL urL lnic111n1n1� you in
ldv wLL th it your pLnnit Low I-L, will hu Lxplring DILlosLd you will Ilnd I P(,rmrt Coverage Renewal
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COntnttlud LOVLI wu unclur thL ocnLrit pulnit DuC to st 111 Ind IlUdI'Lt Lonstr ants luaus Lonlirmin« Our rucuipl of
thu uomplLtLd ipplic iturn will not hL ,Lnt
F IIlUIL to ILquLst rCnLWJ1 within li tunL ptrlod spLCIIILd nl ry rusult In I uvll assLssrtlLlIt of It ILast $250 00
L trgcl PLTI tlllLs nldy hL &,'sLssud dtpLndulg on i dclulqutnLy (it li rLquLst D11,Ch iii of stoi nlw rtur Ilonl yowl
f iciIity without LovLr 1ft, L11iI a v Ihd stounw itLr NPDhS PLI11111 would LOnstitutu I % rnl Ilion of NCGti 143 2 ] 5 1
Ind Lould 1L14111 In IssLssnlwlts 01 LIVII PLn dtlus Of up to' 10 000 par d iv
PluasL notu that ruccnt iudLr It 1Luislatlon his Lxtunduc] li no CxposwL CrLluslon to ill npLi hors of lndustl i 11
ILII IIILs III Illy 01 thL I I L t1L�ortLS of storm w uur dish n "us ISSOL I 1ILd with Industrl 11 1Ltn ity (LxLLPt
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Illtol In Moll LOW ILt thL CLnti It OHILL ILL Sto1 lll4% Itur St 111 InL1nhL[ hslLd hLlow or LhLLk thL Stoi inw ilL.r & GLnur I]
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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
James B Hunt, Jr , Governor
Wayne McDevitt, Secretary
A Preston Howard, Jr, P E , Director
May 1, 1998
DANIEL A REAVIS
SHEFFIELD LUMBER & PALLET-DAVI
P O BOX 819
BARTOW, FL 33830
Subject Reissued Stormwater General Perrrut for
Certificate of Coverage No NCG210192
Davie County
Dear Pernuttee
AILT."FAOM%
[D E N F1
In response to your renewal application for continued coverage under the General Permit
NCG040000, the Division of Water Quality (DWQ) is forwarding herewith the General Permit
NCG210000 which is anew General Permit to cover most of the Timber Products Industry You
have now been given coverage under NCG210000 and your coverage under NCGO40000 is hereby
terminated 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
The following information is included with your perrrut package
■ A copy of the stormwater general permit NCG210000
■ A new Certificate of Coverage under general permit NCG210000
■ A Stormwater Pollution Prevention Plan Certification Form This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit (both NCG040000 and NCG210000) This form must be completed and returned to the
Division within 30 days of receipt of this letter DO NOT send the SPPP with the signed form
■ Five copies of Analytical Monitoring forms
■ Five copies of Qualitative Monitoring forms
■ A copy of a Technical Bulletin on the stormwater program which outlines program components
and addresses frequently asked questions
Your certificate of coverage is not transferable except after notice to DWQ The Division of Water
Quality may require modification or revocation and reissuance of the certificate of coverage
This perrrut does not affect the legal requirements to obtain other permits which may be required by
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater and General Permits Unit at telephone number [phone]
Sincerely,
b���
Svc
f o r A Preston Howard, Jr, P E
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 AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO NCG210000
CERTIFICATE OF COVERAGE NO NCG210192
STORMWATER DISCHARGES
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
SHEFFIELD LUMBER & PALLET-DAVI
is herby authorized to discharge stormwater from a facility located at
165 TURKEYFOOT ROAD
MOCKSVILLE, NC
DAVIE COUNTY
to receiving waters designated as UT To Hunting Creek in the Yadkin -Pee Dee River Bann
in accordance with the effluent limitations, monitoring requirements and other conditions set forth in Parts 1,
II III and IV of General Permit No NCG210000 as attached
This Certificate of Coverage shall become effective May 1, 1998
This Certificate of Coverage shall remain in effect for the duration of the General Pemut
Signed this day May 1,1998
b4,tA
for A Preston Howard, Jr, P E , Director
Division of Water Quality
By Authonzation of the Environmental Management Commission

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B Hunt, Jr , Governor
Wayne McDevitt, Secretary
A Preston Howard, Jr , P E , Director
August 28, 1997
William K McGreevey
Hunton and Williams
600 Peachtree Street, N E
Atlanta, GA 30308-2216
A4.1
C)EHNR
Subject Corporate Merger Issues
Sheffield Lumber & Pallet Company, Inc
Perrrut No NCG040I92
Davie County
Dear Mr McGreevey
We have completed our review of your July 22, 1997 letter outlining the corporate merger issues
associated with the above referenced facility After review by the Attorney General's Office, it is our
understanding that with the merger Sheffield Lumber and Pallet Company will continue to be the permit
holder and to have full responsibility for all permit conditions Since the same corporate entity will
continue to own and operate the facility after the merger we do not feel that any name/ownership change is
necessary for this facility
You previously submitted Name/Ownership change requests for this facility and a facility in Stier City
(NCG040199) along with a processing fee of $200 ($100 per facility) The Siler City facility required a
permit reissuance and was processed on July 3I, 1997 Because the Mocksville facility does not require a
permit reissuance, we will refund the $100 processing fee previously submitted for this change You will
receive this refund under separate cover
Thank you for your patience while we reviewed this information If you have any additional questions or
need more information please contact me at [phone] ext 525
Sincerely,
d mi_
Bradley Bennett
Stormwater Supervisor
cc Central Files
Winston-Salem Ret>ional Office
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

4
`tate of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B Hunt, Jr, Governor
Jonathan B Howes, Secretary
A Preston Howard, Jr, P E , Director
April 29, 1994
Mr Daniel A Reavis
Sheffield Lumber & Pallet Co Inc
Rt 6 Box 153
Mocksville, NC 27028
Subject General Permit No NCG040000
Sheffield Lumber & Pallet Co
COC NCG040192
Davie County
Dear Mr Reavis
In accordance with your application for discharge permit received on March 23, 1994, 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 Environmental Management The Division of Environmental Management 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 Environmental Management 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 Mr Bill Mills at telephone number 919/733-
5083
Sincerely,
Original Signed P„
A roeston Howai�s Jr , P E
cc Winston SalemRegional Office
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 ENVIRONMENTAL MANAGEMENT
STORMWATER DISCHARGES
In compliance with the provision of North Carolina General Statute 143-215 I, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Sheffield Lumber & Pallet Co, Inc
is hereby authorized to discharge stormwater from a facility located at
Sheffield Lumber & Pallet Co, Inc
Route 6
Mocksville
Davie County
to receiving waters designated as an unnamed tributary to Hunting Creek in the Yadkin - Pee Dee River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, II, III
and IV of General Permit No NCGO40000 as attached
This certificate of coverage shall become effective April 29, 1994
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 29, 1994
,-1 tgmal Stgt,ed By
t'.oleor H Sullins
A Preston Howard, Jr , P.E
Division of Environmental Management
By Authority of the Environmental Management Commission

o i0
1 \rS 1 lam' ° \1l/J^\1UU

FACILITY SNEenELn WrVIGE2 8 PALLee-r CA--> i Inc
COUNTY VAVil�
NPDES NCCIogoIga
MAP # tLo 0 uJ
DSN FLOW 0l'4
'I 4!,AUB BASIN 03 oZ ocv
LATTITUDE
LONGITUDE
RECEIVING STREAM
STREAM CLASS
DISCHARGE TYPE
EXPIRATION DATE
WSJ
b
06 Is t [aq,

STORMWATER POLLUTION PREVENTION PLAN
FOR
PALLETONE OF NORTH CAROLINA
MOCKSVILLE PLANT
165 Turkey Foot Road
Mocksville, NC
Prepared for
PalletOne of North Carolina-Mocksville
Mocksville, NC
by
Geoscience & Technology, P A
Winston-Salem, NC
Tune 2011

*t"zad
i�
r IPo� ouceevg�
JIln�nryneirY�lSr�idrau
2050 Northpolnt Drive • Sulte A • Winston Salem NC 27106
A-�e Mlcke�

STORMWATER POLLUTION PREVENTION PLAN
PalletOne of North Carolina
Mocksville, NC Facility
RECEIVED
N C Dept of ENR
JUN 3 0 2011
Winston Salem
Regional OtFce
TABLE OF CONTENTS
ITEM
10 INTRODUCTION
1 1 Management Approval
2 0 FACILITY DESCRIP rION
2 1 Site Drainage Characteristics
2 2 Pollution Prevention Team
2 3 Environmental Contacts
3 0 SITE MAP
3 1 Exposed Areas Identified As Potential S0111CeS of Pollutants
3 2 Significant Leaks and Spills
4 0 NON-S I ORMWAfER DISCHARGE ASSESSMENT AND CERTIFICA1 ION
4 1 Assessment
5 0 BEST MANAGEMENT PRACTICES (BMPs)
5 1 Feasibility Study
5 2 Best Management Practices
5 3 Monitoring Data
6 0 GOOD HOUSEKEEPING PROGRAM
7 0 PREVENTIVE MAINTENANCE
8 0 SPILL PREVENTION AND RESPONSE
FIGURES
APPENDICES
SPILL PREVENTION AND RESPONSE PLAN
PAGE
2
2
3
3
4
4
5
5
6
7
7
8
8
10
10
12
13
PalletOne Mocksville SP3

10 INTRODUCTION
Stormwater discharges from industrial sites have been identified as a significant source of water
pollution nationwide To address this problem, The Clean Water Act Amendments of 1987 required
the Environmental Protection Agency (USEPA) to publish regulations controlling stormwater
discharges to Waters of the United States Waters of the United States are all surface waters
including lakes, rivers, streams, wetlands, and coastal waters The regulations iequiie "stormwater
discharges associated with industrial activity" to obtain a stormwater permit undet the National
Pollutant Dischaige Elimination System (NPDES) NPDES stormwater discharge permits will
allow the individual states and the USEPA to track and monitor sources of stormwater pollution
The State of North Carolina has developed General Permits to regulate various types of industry
The USEPA has approved North Carolina's General Permit Piogram and all requirements
established in the General Permit must be met by the facility to comply with the regulations This
facility currently operates under NC General permit #NCG210000 The Stormwater Pollution
Prevention Plan (SP3) is the method chosen by USEPA (and adopted by the State NPDES piogiam)
for which facilities governed by an NPDES permit, will meet these requirements The SP3 is not
required for submittal to the state, local, or other authority unless requested, but must be retained on
site and updated as opeiational changes are made that might affect stoi mwater discharges
11 Management Approval
The SP3 will be implemented as herein described
Signature.
Name and Official Title Brian Dyson, Plant Manager
Pal letOne-Mocksville
Date �6 `% l/ w
PalletOne Mocksville SP3 -2-

20 FACILITY DESCRIPTION
PalletOne-Mocksville (PalletOne) is located at the intersection of Turkey Foot Road (SR 1317)
and Sheffield Road (SR 1306) approximately 9 miles northwest of the Town of Mocksville in
Davie County, NC The street address is 165 Turkey Foot Road The facility consists of 42 acres
and is identified on the Davie County GIS website as PIN# 5801215621 There ale a total of
seven buildings on the site Figure 1 is a general site location map Figuie 2 is an adaptation of a
site plan with topogiaphy piepared toi site improvements in 1997 and contains stormwater
relevant features
The PaIletOne facility operates as a pallet manufactuitng, pallet iecycling and mulch
manufacturing facility Wood waste such as, sawdust, shavings and chips aie stoied in piles in
the noithwest portion of the facility The wood waste is converted to mulch that is sold for
landscaping purposes Finished pallets are stoied at various locations on the subject site
Hydraulic fluid, lubricating oil and grease, paits cleaning solvents and coolant (antifieeze) are
stored on the premises in 55-gallon drums and 5-gallon buckets located in the maintenance shop
Diesel fuel and gasoline are stored in two, 1,000-gallon aboveground storage tanks (UST), which
are double -walled tent -type tanks that are exposed to stormwater A 4,500-gallon `dip' tank used
to apply wood preservative is also exposed to stormwater Waste oil is stored in a 55-gallon
drum at the maintenance shop that is exposed to stormwater and does not have secondary
containment
The site is partially paved with asphalt and gravel There are floor drains located in the
bathrooms and break areas of three buildings All floor drains connect to three onsite wastewater
systems Roof drains either discharge to subsurface stormwater conveyances or to surface
stormwater intakes Figure 3 is a detailed site map indicating the locations of buildings and
relevant stormwater features
21 Site Drainage Characteristics
The subject facility is located on the crests of two northeast to southwest trending ridges A natural
drainage valley separates the two ridges The total drainage area is approxiinately 42-acres,
comprised of the seven buildings, storage yards, parking areas and unused vegetated spaces
Runoff from the approximately 2 4-acre parking aiea in the southeast cornet of the subject property
drains to an outfall located on the west side of Turkey Foot Road Runoff tiom the 0 8-acre area
adjacent to Turkey Foot Road also drains to this outfall This outfall is designated as Outfall #1 for
stormwater monitoring purposes and discharges via an unnamed tributary to Bear Creek, a Class `C'
surface water, approximately 1 mile east of the subject site This pai king area is primarily paved
with `crushes -run' gravel and contains a considerable amount of fine-grained material The area
adjacent to Turkey Foot Road is mostly giassed and also contains a portion of the asphalt -paved
main access to the site
Runoff fiorn the approximately 3 7 acre trades parking area in the southwest cornei of the subject
property drains to an intake located at the northwest corner of the lot The intake discharges to an
18-inch pipe (RCP) on the west facing slope below the intake The pipe discharge then follows a
nprap ditch to a point just below the dam for the sediment pond mentioned below This outfall is
designated as Outfall #2 for stormwater monitoring purposes and discharges via an unnamed
PalletOne Mocksville S113 -3-

tributary to Hunting Creek Hunting Creek is a WS-Ill surface water located approximately 2 6
miles west of the subject site This parking area is primarily paved with `crushes -run' gravel and
contains a considerable amount of fine-grained material
The remainder of the developed portion of the subject property, approximately 25 3 acres, drains to
a sediment pond originally constructed as part of an Erosion & Sediment Contiol (E&SC) plan
during development of the site The sediment pond is located in a natural drainage valley in the
central portion of the property and discharges through a 48-inch pipe (RCP) to an unnamed tributary
of Hunting Creek This dischaige is designated as Outfall #3 foi stormwatei momtonng purposes
There are several Stormwater intakes located in this drainage area, piimarily in the gravel -paved
areas and dischaige through pipes of various sizes, ranging from 15-inches to 24-inches to the
sediment pond Stormwater intakes on indicated on 1~igure 2 by red circles around the grates This
laige drainage area consists of giavel-paved areas, buildings, mulch and wood waste storage areas
and vegetated at eas
The remainder of the pioperty is relatively undeveloped and is either sown in grass of is vegetated
with trees and shrubs Impervious aiea constitutes appioximately 39% or 16 3 acres and includes the
buildings, asphalt -paved drives and gravel -paved areas Peivious area consists of the mulch and
wood -waste stot age areas and vegetated areas
22 Pollution Prevention Team
'PERSON -
RESPONSMLITY�-
Brian Dyson, Plant Manager
Overall responsibility for implementation of
PalletOne of North Carol i na-Mocksville
PalletOne Storinwatei Pollution Prevention
336 492 5565 Ext 303 (facility)
Plan
919 353 0336 (cellular)
Michael Spiy, Safety Manager
Shares overall responsibility for
PalletOne of Noith Carol ina-MocksviIle
implementation of PalletOne Stoimwater
336 492 5565 Ext 303 (facility)
Pollution Prevention Plan with Brian Dyson
919 353 0336 (cellular)
Rogei Wooten, Maintenance Supervisor
Responsible for shop and facility
PalletOne of North Carol ina-MocksviIle
maintenance and day-to-day operations, and
336 492 5565 Ext 303 (facility)
assisting with implementation of PalletOne
919 353 0336 (cellulai)
Stormwater Pollution Prevention Plan
23 Environmental Contacts
CONTACT ,' 1RESPONSIBILI'PY
Mike Mitchell Regional Stormwater
USEPA Regton IV Representative, NPDES Permit Unit
Watei Management Division
345 Courtland Street, N E
Atlanta, GA 30365
[phone]
PalletOne Mocksville 5113 -4-

CONTACT rt
`QSP0NSff(1L1TY
N C Department of Environment and Natural
State/local regulatory officials for
Resouices
stormwater permitting and
Corey Basinger
management
585 Waughtown Stieet
Winston-Salem, NC 27107
[phone]
Office of Emergency Management, Davie County
Notify if reportable quantity of
114 Doctor Slate Drive
hazardous waste is spilled
Mocksville, NC 27105
[phone]
National Response Center
Notify if reportable quantity of
[phone]
hazardous waste is spilled
A&D Environmental/Industrial Services
Contact if facility personnel cannot
P O Box 484
contain spill of hazardous material
High Point, NC 27261
[phone], Cell [phone]
- Stormwatei Hotline
Stormwater Regulation clarification
1USEPA
[phone]
and nnteipietation
30 SITE MAP
In addition to buildings, ,tructuies, paved areas, and parking lots, the General Permit requires that
this additional information be shown on the site map
1 All outfalls and stormwater discharges from adjacent property
2 Drainage areas of each stormwater outfall
3 Structural stormwater pollution control measures
4 Name of receiving waters (or if through a municipal separate storm sewer system)
5 Locations of exposed significant materials
6 Locations of past spills and leaks
7 Locations of high -risk, waste -generating areas and activities common on industrial
sites (see Section 3 1)
If any of the above items are affected by changes in operation, storage practices, of facility additions
during the permit duration, the site map attached with this plan shall be modified as such
31 Exposed Areas Identified As Potential Sources of Pollutants
Based on USEPA regulations and site inspections, these areas will be managed throughout the
duration of this permit Existing conditions and descriptions for these areas are addressed in Section
5 1 and are shown on the site map (see Figure 2)
Gasoline and diesel fuel are stored in two 1,000-gallon tent tanks located at the maintenance
shop Just west of the office building Since these products are stored in double -walled tent -type
tanks, they are not directly exposed to stormwater Best Management Practices (BMPs) for
prevention and containment of spillage from the dispensers during fuel loading and unloading
PalletOne Mocksville SP3 -5-

ate described in the BMP section and in the appended Spill Prevention and Response Plan
(SPRP)
A 4,500-gallon `dip' tank used to apply wood preservative is also exposed to stormwater The
preservative contains chemicals that aie toxic to fish and other aquatic life A minimum
freeboard of 18-inches is maintained in this tank, therefore, the potential for overflow is
considered minimal The tank has no secondary containment, therefore, a catastrophic spill from
this tank is potentially hazardous to surface water Secondary containment is recommended for
this tank Best Management Practices (BMPs) for prevention and containment of spillage fiom
the dip tank are described in the BMP section and in the appended Spill Prevention and Response
Plan (SPRP)
Waste oil is stored in a 55-gallon drum at the maintenance shop that is exposed to stormwater
and does not have secondary containment A waste oil recycler pumps out the dium at regular
intervals Secondary containment is recommended for this drum Best Management Practices
(BMPs) for prevention and containment of spillage fiom the waste oil drum aie described in the
BMP section and in the appended Spill Prevention and Response Plan (SPRP)
The gravel -paved parking and storage areas have the greatest potential to provide pollutants in the
form of fine-grained sediment The potential for stormwater pollution resulting from spills of
cleaning solvents, petroleum products and/or dntlfreeze occurring in the maintenance shop is
considered minimal Best Management Practices (BMPs) for the containment of sediment from the
parking areas are described in the BMP section and in the appended Spill Prevention and Response
Plan (SPRP)
Sawdust and other wood wastes are stoied in uncovered piles in the northwest corner of the facility
The wood waste is converted to mulch, which is also stored in piles in the same area These piles are
all potential sources for solids in stormwater The mulch is dyed using a non -toxic environmentally
safe dye and is not considered a source of toxic pollutants
32 Significant Leaks and Spills
Significant leaks and spills are defined as releases within a 24-hour period of reportable quantities
(RQ) under Section 311 of the Clean Water Act and Section 102 of the Comprehensive
Environmental Response Compensation and Liability Act (CERCLA) Reportable quantities are set
amounts of substances in pounds, gallons, or other units Significant leaks and spills of hazardous
and toxic pollutants occurring over the duration of General Permit #NCG210000 shall follow
correct procedures outlined in Section 8 0
A release of an undeteimined volume of paint iesidue occurred in May of 2009 that was reported to
the Winston-Salem Regional Office (WSRO) of the NC Division of Water Quality (DWQ) With
the exception of the paint residue release have been no significant spills or leaks within the last three
years
A Spill Prevention and Response Plan (SPRP), which describes spill iesponse procedures, is
included in the Appendices Please note that the federal regulations governing this plan are found
in 40CFR Part 112 This regulation requires facilities with a potential to discharge petroleum or
hazardous materials to have a Spill Prevention Control and Countermeasures Plan (SPCC)
Current North Carolina General Stormwater pc,rmit language uses Spill Pi evention and Response
Plan (SPRP) instead of SPCC This plan contains an SPRP
NlletOne Mocksville SP3 -6-

4 0 NON-STORMWATER DISCHARGE ASSESSMENT AND CERTIFICATION
The follownig testing methods were used in determining the presence of non-stormwater
discharges (check all that apply)
✓ Field Observation
✓ Analysis of Schematics
Smoke Tests
✓ Fluorometric Dye Tests
Indicator Parametei Sampling
Other
A review of historical parameter sampling analyses did not indicate the presence of contaminants in
stoimwater runoff toi this facility Field observation and analysis of facility schematics did not
indicate the presence of non-stormwater discharges in the stormwater conveyance system at this
site A Professional Engineer should complete the following certification if a dye test is performed
41 Assessment
On April 6, 2011, a dye test was conducted at Pal letOne-Mocksvi lie Liquid fluorescent dye
was mixed with five gallons of water and poured into one toilet, one sink and one floor drain in each
of the buildmgs with iestroom facilities Additional water was added to the floor drains and sinks to
ensure complete flushing of the dye There are no floor diains in any of the manufacturing or
maintenance areas None of the dye colored water was observed in any of the stormwater
conveyances, therefore, it appears that there are no non-stormwater discharges emanating from
within the facility piesent in the site stormwater system
NON-STORMWATER DISCHARGE CERTIFICATION
I, Carl von Isenburg P E , certify undei penalty of law that this document and all attachments were
prepared under my direction or supervision according to 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 duectly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accuiate,
and complete I am aware that there aie significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations
NAME AND OFFIC1A�r i 3iEI_fan°'�� ,Cai l von Isenburg, P E , Senior Civil Engineei
COMPANY �oQ�,or"""'o lice & Technology, P A
SEAS
- `
Signature 0 0246�7- -
NAME AND 0FFI(--1Ai5QJ.J SE50'�.Brian Dyson, Plant Managei
PalletOne-Mocksvdle
Brian Dyson Date
PalletOne Mocksville SP3 -7-

5 0 STORMWATER MANAGEMENT PLAN
51 Feasibility Study
Section 5 1 contains a review of the feasibility for mitigation of potential stormwater pollutants
Fine-grained sediment washing from the gravel -paved areas is a primary source of pollutants as
Total Suspended Solids (TSS) at this facility There are several options for mitigation of sediment
transport from this source
1) Installation of erosion control measures such as, grass -lured ditches, placement of rip -rap in
existing gravel ditches, placement of Lock check dams in rip -rap ditches, diversion of run-
off trom gravel -paved parking areas to grass -vegetated areas instead of to hard structures,
and installation of a forebay in the existing sediment pond These measures have been
undertaken in 2011
2) Removal of the existing crusher -run gravel in the parking lots and replacement with washed
stone This measure involves considerable expense compared to Option 1 and will only be
undertaken if Option 1 measures do not successfully mitigate sediment pollution
3) Re -paving the existing gravel -paved areas with either asphalt or concrete fhis option is
considered to be economically unfeasible at this time and will only be considered if Option
2 does not successfully mitigate sediment pollution, if instigated
Solids from the mulch and wood waste piles do not appear to be contributing to the off site sediment
load in the stormwater discharge Runoff from the storage piles is diiected to the sediment pond and
does not appear to be leaving the site Therefore, there are no plans to change procedures related to
mulch and wood waste storage Coveiing these piles with roofs is considered to be economically
and logistically unfeasible
Wood preservative used in the dip tanks is toxic to aquatic life The potential to reach surface water
by overflow is considered minimal, however, there is a potential for surface water pollution in the
event of a catastrophic failure such as, a damaged drain valve or an accidental impact from a
vehicle Based on this potential, a secondary containment for this tank is under construction For the
same reason, secondary containment is proposed for the waste oil drum outside the maintenance
shop Since the gasoline and diesel fuels are stoied in double -walled tent tanks, it appears that the
potential for stoi mwater pollution is minimal except dining unloading and fuel dispensing activities
Fuel unloading and dispensing activities are part of the SP3 and SPRP, therefoie, no changes are
recommended foi this potential source All othei possible sources of pollutants such as, paint, new
motor oil, hydraulic oil, and cleaning products are stored undei roof and are not ditectly exposed to
stormwater Any spills occurring within buildings where these products ate stoied will be handled
accoiding to the SPRP Changing procedures related to these products does not appear to be
warranted at this time
52 Best Management Practices
Section 5 2 contains narrative descriptions of tiaditional stormwater management piactices used
to direct, infiltrate, reuse, or otherwise manage stormwater runoff in a way that reduces
PalletOnc Mocksville SP3 -8-

pollutants from the discharge BMPs discussed in the Stormwater Management Plan will
essentially try to eliminate stotmwater contamination A the source rather than treat stormwater
after contamination A Spill Prevention and Response Plan (SPRP) that describes spill response
procedures is included in the Appendices
A site evaluation was conducted of the existing conditions and runoff characteristics of the exposed
areas/potential pollutant sources identified in Section 3 1 The Good Housekeeping and Preventive
Maintenance Piograin actions apply to all potential pollutant sources
Gasoline and Diesel ASTs, Fuel Dispensers and Fuel Unloading Area -
Contaminants expected fiom this area include diesel fuel, oil and grease, engine
coolant and particulate matter The ASTs are supplied by deliveries using highway
transport tankers and/or tank wagons Unloading for the ASTs is by gravity drop,
which requires the driver -attendant to stand by and monitor the operation There are
no secondary containment structures or stormwater diversion structures in the
unloading area If a hose ruptures, or any other component causes a spill, the
attendant must close the valves manually The transport is parked in a gtavel-paved
area while unloading
If a hose ruptures, or any other component causes a spill during unloading or the
AST overfilled, it would discharge west-northwest toward a stormwater drop inlet
approximately 180 feet west-northwest of the tanks (See Figure 2) The stoi mwater
conveyance then ultimately discharges to the sediment pond and then to Outfall 3
If spilled petroleum leaves the property, then the Davie County Emergency
Management Agency and the local stormwater authority shall be notified (see pg 4
and SPRP) Due to its abundant availability at this facility, sawdust is the primary
absorbent material used and is stored in containers in every building where the
potential for spillage exists
2 Maintenance Shop - Contaminants expected from this area include gasoline, diesel
fuel, oil and grease, cleaning solvents, engine coolant and particulate matter There
ate no containers larger than 55-gallon drums in this area, theiefore, the largest
single spill is not expected to be largei than 55--gallons As indicated above spills
originating within the shop are not likely to enter the stormwater system as there are
no floor drains and the spills ate expected to be contained within the shop Sawdust
is kept in the shop in case of spills Sawdust used to absorb petroleum spills is
collected and sold for use as boiler fuel
3 Waste Oil — Waste oil is collected in the maintenance shop and stored in a 55-
gallon drum located outside the building The waste oil is collected from the drum
at regular intervals by a iecyclei Secondary containment toi this drum is under
construction Sawdust is kept in the shop in case of spills
4 Wood Preservative — A 4,500-gallon `dip' tank used to apply wood preservative is
also exposed to stormwater The pieservative contains chemicals that are toxic to
PalletOne Mocksville SP3 -9-

fish and other aquatic life A minimum freeboard of 1 8-inches is maintained in this
tank, therefore, the potential for overflow is considered minimal The tank has no
secondary containment, therefore, a catastrophic spill from this tank is potentially
hazardous to surface water Secondary containment foi this tank is under
construction as of the wrrtrng of the document Due to its abundant availability at
this facility, sawdust is the primary absorbent material used and is stored in
container s in every building where the potential for spillage exists
5 Parking Lots and Storage Areas - Contaminants expected from this area include
diesel fuel, oil and grease, engine coolant and particulate matter Stormwater runoff
from the parking areas flows over gravel and asphalt either to the east or west (see
Figuie 2) Stot mwater from the eastern parking lot discharges to the drop inlet, Outfall
1 Stormwater conveyances on the east side of this parking lot are being unproved to
mitigate the transport of sediment from this lot A grass -lined ditch along the west side
of Turkey Foot Road also discharges to Outfall 1, however, the potential For pollutants
to this area is considered minimal Stormwater from the western tiailer parking lot
discharges to the drop inlet at the northwest corner of the lot and discharges at Outfall
2 At least half of the runoff fiom this lot is being diverted to the grassy slope to the
west of the lot and the stormwater ditch at the north end of the lot is being improved to
mitigate the transport of sediment fiom this lot The SPRP included in the
appendices, provides procedures to avoid washing obvious oil, grease or fuel
accumulations onto the ground surface Historical and recent laboratory analyses
data for stormwater outfalls indicates discharges of sediment in excess of
benchmark values set up in the General Permit The facility is instigating changes to
stormwater conveyances and controls to reduce the sediment in stormwater Every
effort will be made to stop or control spillage before it leaves the property or enters
storm drainage systems by use of hay bales, absorbents, dram plugs or other
approved means Sediment accumulated behind rock check dams, in the sediment
pond and any other erosion control structures will be cleaned out on a regular basis
to mitigate transport to stor mwater outfalls
53 Monitoring Data
Specific monitoring requirements for the facility, under existing General Permit #NCG210000 are
as described in Part I1, Sections B and C Monitoring records aie maintained at the site As indicated
above, historical and recent monitoring data indicates sediment (TSS) loads in excess of benchmark
values in the discharges
6 0 GOOD HOUSEKEEPING PROGRAM
Good housekeeping is a BMP with the intention of maintaining a clean and oidetly work
environment To reduce potential stormwater contamination, areas identified as potential pollutant
sources shall conform to the following procedures All employees working in these areas shall
become familiar with good housekeeping procedures and be accountable for keeping their work
area clean
PalletOne Mocksville SP3 -10-

Operations and maintenance areas (includes fuel loading and unloading area, trash
disposal, waste oil storage area, lubricating oil storage area, and vehicle maintenance
areas)
• Regularly pick up garbage in all areas, especially around trash receptacles and
immediately after transferring material to or from them
• If absorbent materials are used to clean minor oil leaks under trucks, sweep up
the material shortly after placement Patrol these areas daily and clean as
necessary
• Assure that trucks are dock locked or chocked dw ing the loading/unloading
procedure
• T1 Lick drivers shall shut off engines before unloading material
• Maintain clean areas by sweeping or vacuuming Do not hose down these areas
• Inspect and clean out, as necessary any stormwatei ditches and drop inlets after
each stoi in event
2 Matei ial storage areas (vehicle maintenance area)
• Maintain a clean and orderly work area by sweeping or cleaning as needed, and
keep brooms or vacuums in the immediate area
• Keep absorbent materials in areas where potential liquid spills could occur
• During inspections, ensure that all drums are secured and check for the presence
of leaks
• Adequate aisle space shall be available for easy access and inspections in storage
areas
• Transfer of stored materials (hydraulic oil, lubricating oil and waste oil) will be
performed only by employees that are trained and assigned to these areas
3 Parking Areas
• Maintain a clean and orderly area by removing discarded material
• Keep absorbent materials to areas where potential liquid spills could occur
• Remove accumulated sediment from hard erosion control shucthnes at regular
i ntei vats
• No transfer of stored materials (hydraulic oil, lubricating oil and waste oil) will
be performed in these areas
4 Materials Inventory Procedures
• On -site stored material shall be labeled appropriately
• The facility has a complete chemical inventory and MSDS sheets of each
PalletOne Mocksville SP3 -1 1-

S Employee Training Program - Employees involved with inspections or operations
in the areas identified in Section 3 1 will be required to attend site -specific SP3
training annually Training session material will be developed and delivered to
affected employees by training personnel identified in Section 2 2
70 PREVENTIVE MAINTENANCE
Preventive maintenance involves the inspection and testing of facility equipment and operations, to
prevent breakdowns and failuies by adjustment, repair, replacement, of long-term usage of
equipment and systems Also, good loading/unloading procedures shall be established and followed
to reduce the potential for leaks, spills and material exposure
• Peisons shipping fuel, oil, cleaning solvent or coolant are responsible for ensuring that
the receiving party will be able to unload the material on airival Undeliverable
shipments will be immediately returned to the person originating the shipment
• A manifest should accompany each material shipment The shipper should record the
material's physical properties and chemical narne as well as other information required
on the manifest
• The shipper is responsible for ensuring that the vehicle is properly placarded for the
material loaded
• Persons shipping or receiving hazardous and non -hazardous drummed liquids should
maintain a supply of "oil dry" type absorbent in their area and have it available in case
of spills
• Peisons handling (loading, unloading, etc ) chernicals should be familiar with the
hazardous properties of that material as required by the company's "Hazard
Communication Program " Refer to the Material Safety Data Sheet for the material
being shipped or contact your facility Hazard Communication Coordmatoi for hazard
information
• Drivers should be trained to the degree and frequency necessary to maintain a working
knowledge of the safety and regulatory requirements for transporting flammable or
hazardous materials
• investigate and periodically review procedures and equipment used for shipping
flammable of hazardous materials for areas where changes can be made to improve
safety and reduce the potential for accidents
• Peisons transferring materials by forklift shall be sure to secure contarnei to torklift with
straps, ropes or chains
• Ensure that loadrnglunloading shall occur only in designated areas
• Instruct truck drivers to shut off engine~ during loading/unloading and periods of non-
use
The inspection reports attached in the appendices will contain information necessary for the regular
visual inspections (which will also addiess good housekeeping practices) and the semi-annual
inspections on all areas addressed in Section 3 0 Regular visual inspections shall be conducted and
documented by a designated employee every two weeks
PalletOne Mocksville SP3 -12-

80 SPILL PREVENTION AND RESPONSE
The facility maintains a SPRP that documents procedures for spill prevention and response (see
Appendices) Personnel identified in Section 22 annually review the SPRP The SPRP contains
facility and equipment inspection frequencies and inspection record for ins related to stormwater and
Pollution control
11allet0ne Mock-wille SP3 -13-

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Title Site Location Map Project Job No Location Scale Date
Calahaln NC USGS I = 2000 5/18/2011 aosci�1phc
Quadrangles PalletOne of North Carolina ocksville, NC Flguri, No Revision No � �®!I -
Dated 1969 Stormwater Plan 11 202 PracuralEngineering&
Mocksville NC 1 O Ent tronmenrat 5odueon
Winston Salem NC [phone]

SPILL PREVENTION AND
RESPONSE PLAN
_w
PALLETONE OF NORTH CAROLINA
MOCKSVILLE PLANT
165 Turkey Foot Road
Mocksville, NC
Prepared for
PallelOne of North Carolina-Mocksville
Mocksville, NC
by
Geoscience & Technology, P A
Winston-Salem, NC
May 2011

Reference Federal Regulation 40CFR Part 112 July 17 2002
Type of Facility Pallet Manufacturing and Wood Waste Rec cling
Facility PalletOne of North Carolina-Mocksville
Street Address 165 Turkey Foot Road
City, State, Zip Mocksville, North Carolina 27028
MANAGEMENT APPROVAL
Authorized Agents Name Brian Dyson Title Plant Manager
Signature zgar
Signature indicates compliance w4te contents of this plan and authority to carr} out these requirements
ENGINEERING CERTIFICATION
The undersigned certifies and attests that he is (1) familiar with this Regulation (2) that he has
visited and examined this facility, (3) that the Plan has been prepared in accordance with good
engineering practice and with the requirements of this regulation and Industiy Standards, (4) that
procedures for required inspections & testing have been established, (5) the Plan is adequate for the
above -named facility Engineering Certification does not relieve owner/operator of their
responsibility of implementing the requirements of this regulation
Name Carl von Isenburg_ P E
Geoscience & Technology,"P'A ,,20�!
336 896 1300 ��''114 CA
Signature
(SEAL): SUL `
024697
llate
/� ffff.Nfff• J
t'01V
orthpoint Dr, Winston-Salem, NC 27106, phone
2

TABLE OF CONTENTS
ITEM PAGE
I Contact List and Telephone Numbers 4
II General Description of Physical Plant 5
III General Spill Prevention Contiols and Countermeasuies Requirements 5
IV Spill Reporting Documentation 7
V Piedic,tion of Spill Characteristics 8
VI Alternative Oil Spill Contingency Plan 10
VII Inspections, rests, Records 12
V1II Peisonnel Training and Spill Prevention Procedures 13
IX Loading and Unloading Facilities 14
X Secui Ety 14
Certification of Substantial Harm Determination Form 15
Annual Training Form 16
3

CONTACT LIST AND TELEPHONE NUMBERS
Local Fire Department 911
2 "Pei son-In-Chaige" of Facility Spill Response Brian Dyson
Facility Phone [phone] Ext 303
Local Emergency Planning Committee or Haz-Mat Response Team, Telephone
Number Davie County Emergency Management, 336 753 6163
4 Emergency Cleanup Contractor or Response Facility Name, Telephone Number
A&D Environmental and Industrial Services, 2718 Uwhaiiie Rd , Archdale_, NC 27263,
800 849 4700
6 NC Department of Environment and Natural Resources, Aquifer P10tection Unit, Winston-
Salem Regional Office. 336 7715000 (must call)
7 State Emergency Operations Center 800 858 0368 (must call)
Downstream Water Suppliers who need to be notified None
9 National Response Center 800 424 8802 (must call)
(See page 6 for Documentation)
You must report a spill if
Discharges that cause a sheen or discoloration on the surface of a body of water,
Discharges that violate applicable water quality standards, and
Discharges cause a sludge or emulsion to be deposited beneath the surface of the water or
on adjoining shorelines
Reporting a hazardous substance release or oil spill takes only a few minutes To report a release or
spill, contact the federal government's centralized reporting center, the National Response Center
(NRC), at 1 800 424 8802 The NRC is staffed 24 hours a day by U S Coast Guard personnel,
who will ask you to provide as much information about the incident as possible If possible, you
should be ready to report the following
Your name, location, organization, and telephone number
Name and address of the party responsible for the incident
Date and time of the incident
Location of the incident Source and cause of the release or spill
Types of matey ral(s) released or spilled
Quantity of materials released or spilled
Danger or threat posed by the release or spill
Number and types of injuries (if any)
Weather conditions at the incident location
Any other information that may help emergency personnel responds to the incident
4

II GENERAL DESCRIPTION OF PHYSICAL PLANT
PalletOne-Mocksville (Pallet0ne) is located at the intersection of Turkey Foot Road (SR 1317) and
Sheffield Road (SR 1306) approximately 9 miles northwest of the Town of Mocksville in Davie
County, NC The street address is 165 Turkey Foot Road The facility consists of 42 acres and is
identified on the Davie County G1S website as PIN# 5801215621 There are a total of seven
buildings on the site Figure t is a general site location map Figure 2 is a detailed site map with
stormwater related features noted
The PalletOne facility operates as a pallet manufacturing, pallet recycling and mulch manufacturing
facility Wood waste such as, sawdust, shavings and chips are stored in piles in the northwest
portion of the facility Finished pallets are stored at various locations on the subject site Hydraulic
fluid, lubricating oil and grease, parts cleaning solvents and coolant (antifreeze) are stored on the
premises in 55-gallon drums and 5-gallon buckets located in the maintenance shop Diesel fuel and
gasoline are stored in two, 1,000-gallon aboveground storage tanks (UST), which are double -walled
tent -type tanks that aie exposed to stormwater A 4,500-gallon `dip' tank used to apply wood
preservative is also exposed to stormwater A 55-gallon drum used to store waste oil is located
outside the maintenance shop and is exposed to stormwater
The site is partially paved with asphalt and gravel There aie floor drains located in the bathrooms
and break areas of three buildings All floor drains connect to three onsite wastewater systems
Roof drains eidnei dischaige to subsurface stormwater conveyances or to surface stormwater
intakes Figure 2 is a detailed site map indicating the locations of buildings and relevant stormwater
teatures
III GENERAL, SPILL PREVENTION AND RESPONSE PLAN REQUIRMENTS
Title 40, Part 112 of the Code of Federal Regulations, July 3, 2003, Edition, final rule amending
requirements under 40 CFR 112, April 18, 2011 This part establishes procedures, methods and
equipment, and other requirements for equipment to prevent the discharge of oil from non -
transportation -related onshore and offshore facilities into or upon the navigable waters of the
United States or adjoining shorelines These regulations are applicable to owners or operators of
onshore and offshore facilities engaged in producing, storing, transfeiring, distributing, and/or
consuming oil and oil products EPA has published final amendments to the Spill Prevention
Control and Countermeasures Plan (SPCC) rule Please note that curtent North Carolina General
Stormwater permit language uses Spill Pi evenlzon and Response Plan (SPRP) and indicates that
an SPCC may be part of an SPRP This rule amended an existing rule that had been in effect since
1974 1 his final rule was effective on August 16, 2002 and included dates by which a facility
would have to amend and implement its SPCC plan The EPA subsequently extended the
compliance dates The compliance deadline for revision and professional engineer (PE)
certification of SPRP plans is November 10, 2011 The Plans must be implemented by November
10, 201 1
5

Key Provisions of the Oil Pollution Prevention Re gulf
Subpart A - Applicability, Definitions, and General Requirements For All Facilities and All
Types of Oil
Section 112 1 General Applicability Section 112 2 Definitions Section 112 3 Requirement to
prepare and implement a Spill Prevention, Control, and Countermeasure Plan Section 112 4
Amendment of Spill Prevention, Contiol, and Countermeasure Plan by Regional Administrator
Section 112 5 Amendment of Spill Prevention, Control, and Countermeasure Plan by owners or
operators Section 112 7 General iequiiements for Spill Prevention, Control and Countermeasure
Plans
Subpart B - Requirements for Pettoleuin Oils and Non -Petroleum Oils, Except Animal rats and
Oils and Greases, and Fish and Marine Mammal Oils, and Vegetable Oils (Including Oils from
Seeds, Nuts, Fruits and Kernels)
Section 112 8 Spill Prevention, Control, and Countermeasure Plan requirements for onshore
facilities (excluding production facilities) Section 112 9 Spill Prevention, Control, and
Countermeasure Plan requirements for onshore oil production facilities Section 112 10 Spill
Prevention, Control, and Countermeasure Plan requirements for onshore oil drilling and workover
facilities Section 112 11 Spill Prevention, Control, and Countermeasure Plan requirements for
offshore oil drilling, production, or workover facilities
Physical facilities feature storage designs which include provisions to pievent unauthorized
access and thereby unsure accountability Storage tank ullages can be determined, both to prevent
overfilling as well as to serve as leak detection capability Spillage resulting from equipment
failure such as broken valves, hose failure, etc will be contained within secondary containments
or diverted too such The secondary containments are described in subsequent paragraphs
Although operating procedures include precautionary measures to prevent or anticipate overfills,
unexpected discharges due to equipment failure, and smaller "house -keeping" diippages, this Plan
also addresses contingent and emergency situations which will relate to spill reporting, emergency
containment, spill stoppage, safety assurance, and remedial action If physical facilities do not
meet 40-CFR 112 specifications regarding fully effective discharge collection and containment, a
full -scope contingency plan, reference 112 7(d) & part 109, will be developed as part of this
PIan Regardless, an adequate amount of contingency planning is made for this facility to provide
for personnel responsibilities and contact information, spill -response resources and telephone
numbers, spill -reporting telephone numbers, and access to dedicated spill -response equipment
6

IV SPILL REPORTING DOCUMENTATION
ON SITE SPILLS WITHIN THE LAST 12 MONTHS
Spills less than 25 gallons that do not cause a sheen on neaiby navigable (surface) waters, and are
dischajged more than 100 feet from all surface water bodies do not have to be reported in North
Carolina NC Law requires that spills less than 25 gallons must be cleaned up within 24 hours of
the spill for a non -reportable offense
Whenever this facility has discharged moie than 1,000 gallons of oil in a single discharge or
dischaiged more than 42 gallons of oil in each of two discharges occuiiing within any 12-month
period, then the facility must submit thus page to EPA Region IV, Atlanta, Georgia, within 60 days
from the time the facility becomes subject to reporting No reportable spills have occurred at this
facility within the last 12 months In the event of a spill, the following documentation form is
provided to assist facility personnel with ieportmg and corrective action procedures
Name of Facility
Address, Geographic
Address, Mailing
Telephone Number of Facility
Spill Date
Type of material spilled
Time -of -Day
Estimated Total Quantity spilled
Estimated Quantity Spilled into Navigable Water
Source of spill
Description of Aftected Medium
Cause of Spill
Damages or injuries caused by spill
Actions used to stop, remove, and mitigate spill effects
Names of Persons or 01ganizations who have been contacted

V PREDICTION OF SPILL CHARACTERISTICS
This SPRP plan describes existing and proposed spill collection and containment facilities, which
ate intended to prevent spillage from reaching and entering surface water Therefore, the predictions
desci abed as follows are based upon the failure of normal storage and/or piping equipment and the
additional failure of collection and/or containment features to prevent spillage from escaping the
facility The following predictions include direction, rate of flow, and total quantity of oil that could
be discharged as a result of each major type of failure
1 AST Gasoline and Diesel Fuel Unloading and Dispensing Direction, route, including type of
teltain, flow velocity of spills, intersected roads and culverts, name of stream or body or water,
distance to water
Contaminants expected from this area Include diesel fuel, oil and grease, engine coolant and
particulate matter The ASTs are supplied by deliveries using highway transport tankers and/or tank
wagons Unloading for the ASTs is by gravity chop, which requires the driver -attendant to stand by
and monitor the operation There are no secondary containment structures or stormwatei diversion
structures in the unloading area If a hose ruptures, of any other component causes a spill, the
attendant must close the valves manually the transport is parked in a gravel -paved area while
unloading
If a hose ruptures, or any other component causes a spill during unloading or the AST overfilled, it
would discharge west-northwest toward a stormwatei drop inlet approximately 180 feet west-
northwest of the tanks (See Figure 2) The stormwater conveyance then discharges to the sediment
pond and then to Outfall 3 If spilled petroleum leaves the property, then the Davie County
Emergency Management Agency and the local stormwater authority shall be notified (see pg 4)
Every effort will be made to stop or control spillage before it leaves the property of enters storm
drainage systems by use of absorbent material Due to its abundant availability at this facility,
sawdust Is the primary absorbent material used and is stored in containers in every building where
the potential for spillage exists
la Estimated Quantity and Rate of Spillage in tine Fueling Area
(I) The maximum tanker transport compartment volume is 2,000 gallons, with an estimated
release rate of 200 to 300 gallons per minute in a catastrophic failure
(II) Facility vehicles typically have fuel compartment capacities of 100 gallons or less,
therefore a worst -case scenario failure would result in a spill of 100 gallons of diesel
fuel
(III) Other sources of spillage Hose failure, piping connection leaks, overfills during fleet
truck fueling, spills occurring during connection/disconnection to the tanker
2 Lubricatm2 Oil and Hvdraulic Oil Direction, route, including tvoe of terrain, flow velocity of
wills, intersected roads and culverts, name of stream or bodv or water, distance to water Estimated
Quantity and Rate of Spillage of Lubricating Oil
Lubricating oil and hydraulic oil are stored in the maintenance shop in 55-gallon drums Transfers
from the dI ums are accomplished with a manual valve and/or a pneumatic pump If a pipe of fitting
I uptules or any other component causes a spill, the attendants must shutoff the pump and/oi close
valves manually All lubricating oil is located inside the maintenance building
Spills within the maintenance shop are not expected to reach the stormwater drainage system
However, every effort will be made to stop or control spillage before it leaves the building or enters
storm drainage systems by use of sawdust of other approved means
The surface flow velocity in the gravel parking area is estimated to be less than one foot per second
The slope of surrounding area is initially westward to a stonnwater drop inlet approximately 180
feet from the shop The inlet connects to a pipe that discharges to tine sediment pond and then to

Outfall 3 However, every effort will be made to stop or control spillage before it leaves the building
or enters stoim drainage systems by use of absorbent material Due to its abundant availability at
this facility, sawdust Is the primary absorbent material used and is stored in containers in every
building where the potential for spillage exists
A maximum of five 55-gallon drums of lubricating and/or hydraulic oil are stored In the
maintenance building Transfers from the drums to the tr ticks are accomplished with a pneumatic
pump PalletOne employees monitor the transfers If a pipe or fitting ruptures of any other
component causes a spill, the attendants must shutoff the pump and close valves manually
2a Estimated Quantity and Rate of Spillage from Drum Storaae
(I) Drum Failure 55 gallons @ 100 gallons per minute Total drum failure would be 55
gallons of fluid, assuming only one drum failure
(u) Other sources of spillage overfill, or hose/piping failure
3 _Waste Oil Direction, route, including type of terrain, flow velocity of spills intersected roads and
Culverts, name of stream or body or water, distance to water
Lubricating oil is stored outside of the maintenance shop in a 55-gallon drum All waste oil is
collected at regular intervals by a recycler The maximum amount of waste oil stored onsite is 55-
gallons Transfers to the drum are accomplished manually If a spill occurs, then the attendant must
apply absorbent material immediately
The slope of surrounding area is initially westward to a stormwater drop inlet approximately 180
feet from the shop The inlet connects to a pipe that discharges to the sediment pond and then to
Outfall 3 However, every effort will be made to stop or control spillage before it leaves it enters
storm drainage systems by use of absorbent material Due to its abundant availability at this facility,
sawdust is the primary absorbent material used and is stored in containers in every building where
the potential for spillage exists
3a Estimated Quantity and Rate of Spillage from Drum Storage
(I) Drum Failure 55 gallons @ 100 gallons per minute Total drum failure would be 55
gallons of fluid, assuming only one drum failure
(II) Other sources of spillage overfill, or hose/piping failure,
4 Cleaning Solvent Direction, route, including type of terrain, flow velocity of spills, intersected
roads and culverts, name of stream or body or water, distance to water
Cleaning solvent is stored in the maintenance shop in the reservoir of the parts cleaning station The
maximum amount of cleaning solvent stored onsite is 30-gallons Transfers to and fiom the parts
cleaning station is accomplished by a solvent supplier/iecycler If a pipe or fitting ruptures or any
other component causes a spill, the attendants must shutoff the pump and/oi close valves manually
All cleaning solvent is located inside the maintenance building All surface flow within the
maintenance area is directed to a containment trench of service pit Spills within the maintenance
shop aie not expected to leach the stoimwater drainage system However, every effort will be made
to stop of control spillage before it leaves the building or enters storm drainage systems by use of
absorbent material Due to its abundant availability at this facility, sawdust is the primary absorbent
material used and is stored in containers in every building where the potential for spillage exists
The slope of surrounding area is initially westward to a stormwater drop inlet approximately 180
feet fiom the shop The Inlet connects to a pipe that discharges to the sediment pond and then to
Outfall 3
5 Wood Preservative Direction, route, Including type of terrain flow velocity of spills, intersected
roads and culverts, narne of stream or body or water, distance to water

A 4,500-gallon `dip' tank used to apply wood preservative is also exposed to stormwatei The
preservative contains chemicals that are toxic to fish and other aquatic life A mniunilrn tieeboard of
18-inches is maintained in this tank, therefore, the potential for overflow is considered minimal The
tank has no secondary containment, however, instillation of secondary containment for this tank is
underway as of the wiiting of this document A catastrophic spill from this tank is potentially
hazardous to surface water, however, every effort will be made to stop or control spillage before it
leaves the immediate area of enters storm drainage systems by use of absorbent material Due to its
abundant availability at this facility, sawdust is the primary absorbent material used and is stored in
containers in every building where the potential for spillage exists
5a Estimated Ouantitv and Rate of Suillaae fiom the DID Tank
(lii)Catastrophic Failure 4,500 gallons @ 100 gallons pei minute Total failure would be
4,500 gallons of fluid
(iv)Other sources of spillage overfill, or hose/pi pin far Iuie,
The slope of surrounding area Is Initially westward to a stormwater drop inlet appioximately 280
feet from the tank location The inlet connects to a pipe that dischaiges to the sediment pond and
then to Outfall 3
5 Parking, and Areas Direction, route, Including type of terrain, flow velocity of spills, intersected
roads and culverts, name of stream or body or water, distance to water
The only spills anticipated from parked vehicles are catastrophic failure of fuel tanks, radiators, or
hydraulic line or reservoirs, the potential for spills from these sources is considered minimal
Obvious oil, grease or fuel accumulations on trucks and trailers will be absorbed with appropriate
materials prior to washing with an environmentally safe cleaner, therefore, `spills' oil, grease or fuel
from wasting activities are expected to be minimal
The slope of surrounding area in the eastern parking lot is to the east where it enters a drop inlet to
Outfall 1 The surface flow velocity in this is estimated to be less than three feet per second The
slope of surrounding area in the western trailer parking lot is to the northwest where it enters a drop
inlet to Outfall 2 The surface flow velocity in this lot is estimated to be less than one foot per
second The slope of surrounding area in all other gravel and asphalt paved areas is variable in both
degree and direction but ultimately toward the west either by sheet flow or stormwater drop inlets
that drain to the sediment pond and Outfall 3 The surface flow velocity ui these areas is estimated
to be from one to three feet per second Sediment control measures such as rrprap ditches,
absorbent booms and rock check dams are being instituted as of the writing of this document and
will significantly mitigate offsite sediment transport
VI PalletOne-Mocksville
ALTERNATIVE OIL SPILL CONTINGENCY PLAN
for
Fleet Fuel Dispensing Area
Under 40 CFR 112 7 (d) If you determine that the installation of any of the structures or pieces of
equipment listed in paragraphs (c) and (b)(1) of this section, and §§ 112 8(e)(2), 112 8(c)(1 1),
112 9(c)(2), 112 10(c), 112 12(c)(2), 112 12(c)(11), 112 13(c)(2), and 112 14(c) to prevent a
discharge as described in § 112 1(b) from any onshore or offshore facility is not practicable, you
must clearly explain In your Plan why such measures are not practicable, for bulk storage
containers, conduct both periodic integrity testing of the containers and pei iodic integrity and leak
testing of the valves and piping, and, unless you have submitted a response plan under § 112 20,
provide in your Plan the following (1) An oil spill contingency plan following the provisions of
part 109 of this chapter (2) A written commitment of manpower, equipment, and materials required
to expeditiously control and remove any quantity of oil discharged that may be harmful
to

EPA believes that it may be appropriate for an owner of operator to consider costs or economic
impacts in determining whether he can meet a specific iequirennent that falls within the general
deviation provision of §1127(a)(2) EPA states that cost can be considered but cannot be the only
consideration EPA believes so because under this section, the owner or operator will still have to
utilize good enginceiing practices and come up with an alternative that provides "equivalent
environmental protection " However, EPA believes that the secondary containment requitement in
§ 112 7(d) is an important component in preventing discharges as described in § 112 l(b) and is
environmentally preferable to a contingency plan prepared under 40 CFR part 109 The owner or
operator may only provide a contingency Plan in his SPRP and otherwise comply with § 112 7(d)
Therefore, the purpose of a determination of impracticability is to examine whether space or other
geogiaphic limitations of the facility would accommodate secondary containment, ot, if local zoning
ordinances or fire prevention standards or safety considerations would not allow secondary
containment, or, if installing secondary containment would defeat the overall goal of the regulation
to prevent discharges as described in §112 I(b) EPA clatitics their main point that marketers must
not opt for a contingency plan in place of containment simply because contingency plans are
cheaper Without question, secondary containment is a top priority of the EPA and marketers must
demonstrate best eftoils in attempting to piovide containment where practical
(A) Reason of Impracticability
The part of this facility without secondary containment backup is the unloading of transport tankers
in the fuel dispensing area According to NFPA-30A, the standard and iefeience for state and local
building codes, petroleum draining control systems are not generally required at "service stations",
except for urgent environmental concerns
Because fuel unloading is an attended operation and typical spills would be considered small, the
owner believes that any spillage occurring can be handled on contingency basis
It is the owner's judgment that the total facility arrangement is satisfactory because
- All Aboveground Storage Tanks ate provided with secondary containment
- The transport unloading area has fully attended operations, indicating swift
emergency action to stop and contain spills
(B) Commitment of Spill Response Capability
(Describe sources, locations, commitment arrangements, dedicated equipment and materials,
mobility )
Even though the spill contingency plan is required, the owner has established the following plan of
action If a major spill occurs, the following steps will be enacted
1 Spill source will be stopped if possible
2 Office will be notified concurrent with stoppage effort
3 Local Fire Department will be summoned, if circumstances require their presence
4 Spill will be contained on site if sate and possible (See section C)
5 Absorbent, sand and dedicated tools are stored on site at the facility
6 State and Federal oil spill notifications will be made (see page 3)
7 Cleanup and restoration measure will be performed
NOTE A written and rehearsed plan of the above steps will include telephone numbers, names, and
responsibilities of staff persons (Contingency plan not included heiem )
Every effort must be made to contain the spill on the property The petroleum spill must not leave
the property and must not enter storm drains, or tributaries to creeks and streams If spill reaches
open ditching or storm drain catchment basins, then sand, absorbents, drain plugs, hay bales, or
other mateiral must be used to seal the drains and prevent further downstream migration If spilled
petroleum leaves the property then Davie County Emergency Management must be notified ASAP
(see pg 4)

VII INSPECTIONS, TESTS, RECORDS
The inspections are the basic part of the Plan All inspection records ate to be kept for a pet tod of
five years All Integrity Testing documentation should be kept for the life of the facility Copies of
this Form should be made for futuie use This engineer has used Steel Tank Institutes (STI)
Standard for "Inspection of In -Service Shop Fabricated Aboveground Tanks for Storage of
Combustible & Flammable Liquids" SPOOI-00 for testing and inspection standards For a copy
contact STI, 570 Oakwood Road, Lake Zui ich, IL 60047, plione--8471438-8265,
Periodic tank inspections are to be perfoimed by the tank owner or ]its designate Qualified tank
inspectors are to perform the certified tank testing./inspections Qualified tank inspectors are those
who are certified by API or STI Field Erected Tanks must comply with inspection and testing
intervals specified in API 653, "Tank Inspection, Repan, Alternation, & Reconstruction "
FACILI fY
(All inspections monthly except as noted inspector initials require in monthly boxes ) YEAR-
JAN
iLB
MAR
APR
MAY
J N
JUL
AUG
SEP
OM
NOV
DEC
LIQUID S1ORAGE
Drum/Bucket I.Lakagc, (visual)
Absorbent Materials Onsite
Lubrication Equipment Leakage
{� isual)
FUELING AREA
Area Free of accumulated tia,,h
Fueling HOSLS, Dry Rotting
Pipmg Vaves, Integrity & Leak
Testing eti cry I cn Years
Piping Abo� eground
Gaskets Finergc.nc.y Vents (Yearly)
Pumps, Lubiication, Supports
Hydrostatic Rchef Valves
Stormwater Drop Inlet Grates Clean
and free of accumulated trash
Absorbent Materials Onsite
PARKING AREAS
Sediment remoi ed from control
structures (quarterly)
SEDIMENT POND
Sediment removed from forebay
(minimally every five years)
12

VIII PERSONNEL TRAINING ANI) SPILL PREVENTION PROCEDURES
Facilities Designated Person for Oil Spill_ Prevention Brian Dyson
NAME Pa[letOne-Mocksvilie
Twining Scope and Frequency
At least annually all personnel aie given training in oil spill prevention, including operation and
maintenance of equipment They are given thoiough reviews of all parts of this SPRP, both for
routine operations and foi emergency situations Where specific responsibilities are assigned, these
requirements will be reviewed All such training occasions will be documented with an employee
roster that is signed by each employee This document will be kept in the master binder of file of
the SPRP A copy of the Plan will be on display, accessible to all employees at all trines
New employees will be given as much spill prevention training as is commensurate with his new
status and ability to be effective This training will be provided within one week of his employment
Training for all employees will include references and analysis of any past spills and the experience
resulting therefrom
The Person -in -Charge of Oil Prevention (generally, the same for supervising oil spill reactions and
counter- measures) will designate specific personnel to (1) make contacts and report spills in a spill
incident, (2) undertake control of spillage, assure containment, retrieve spillage, (3) restore pioperty
and remediate contaminated pioperty except where an outside cleanup contractor may perform this
function The designated spill response employees, with the Person -in -Charge in command, will
undertake a rehearsal of a spill incident The rehearsal will include an investigation of the potential
flow route of spillage with special attention given to strategic points to achieve bariicading, sealing,
and containment curbs, drains, culverts, and open ditches
The Person -in -Charge will utilize the "Contact List and Telephone Numbers" on page 4 u]
developing a training session foi oil -spill response
This plan shall be reviewed and signed every five years Documentation to review shall state "I
have completed review and evaluation of the SPCC plan for this facility and will (will riot) amend
Plan as a result "
Review by
Date /'� :�2-//
Review by
Date
Review by
Date
Review by
Date
Review by
Date
Review by
Date
13

IX LOADING AND UNLOADING FACILITIES
Transportation rules In addition to the EPA UST and SPCC regulations, the U S Depaitment of
Transportation has hazardous material iegulations related to driver training, emergency preparation,
and incident reporting and emergency response Training regulations, for example, can be found at
49 CFR part 172, and loading and unloading regulations can be found at 49 CFR 177 834 and 49
CFR I77 837
Under 40 CFR 1127 (h) Facility tank car and tank a tick loaduzglunloading 1 ack (1) Where
unloading areas You must design any containment system to hold at least the raaaxamum capacity
of an,ysingle (ompartment of a tank car or tank truck loaded or unloaded at the fa0lit-y) The US
EPA does not inter pret § 112 7(h) to apply beyond activities and/or equipment associated with tank
car and tank truck loadinglunloading racks Theretoie, loading and unloading activities that take
place beyond the rack area would not be subject to the requirements of 40 CFR § 112 7(h) (but, of
course, would be Subject, where applicable, to the general containment requirements of 40 CFR
§ 112 7(c))
US EPA interprets §112 7(h) only to apply to loading and unloading "racks " Undei this
interpretation, if a facility does not have a loading 01 unloading "rack," § 112 7(h) does not apply
(A) Dispensing Units
Dispensing units aie approved, and UL listed Positive displacement pumps for the diesel fuel
dispensing units are installed Supply connections are made with impact -disconnect shut-off valves
Units have automatic shut-off nozzles
(B) Unloading -Transport or Tank Wagons
Tankers are unloaded into aboveground tanks through flexible hoses connecting the compartments
with tank connections During the unloading, the driver -attendant stands by If for any reason he
must leave, pumps aie stopped and valves are closed
Before filling any tank, its gauge or electronic meter is read to determine its available reserve
capacity At conclusion of filling, the compartment valve is closed, the hose is disconnected and
elevated so that it can be completely emptied, and then the hose is disconnected from the tank There
are overfilling devices installed to prevent petroleum spillage during unloading
Stage one vapor recovery is also installed on the gasoline tanks
X SECURITY
Access to the facility is controlled by gates at the two driveways from Turkey Foot Road The gates
are locked when facility personnel are not present The tacility Is surrounded by chainlink fencing
With the exception of two 1000-gallon fuel storage tanks, the preservative dip tank and a 55-gallon
drum of waste oil, all other petroleum products and cleaning agents used at the facility are stored in
the Maintenance shop, which is locked when facility personnel are not present
14

ATTACHMENT C-II
CERTIFICATION OF SUBSTANTIAL HARM
DETERMINATION FORM
FACILITY NAME PalletOne of North Carolina-Mocksville
FACILITY ADDRESS 165 Turkey Foot Road. NC 27028
Does the facility have a maximum storage capacity greater than or cqual to 42,000 gallons
YES NOS and,
2 Do the operation4 include over water transfers of oil to of from vessels
NO X
3 Does the facility have a maximum storage capacity greater than or equal to one million
(1,000,000) gallons and is the facility without secondary containment for each aboveground storage
area sufficiently large to contain the capacity of the largest aboveground storage tank within the
storage area? YES NO X
4 Does the facility have a maximum storage capacity greater than or equal to one million
(1,000,000) gallons and is the facility located at a distance as calculated using the appropitate
formula in Attachment C-111 or an *alternative formula such that a discharge from the facility could
cause injury to fish and wildlife and sensitive environment9 For further description of fish and
wildlite and sensitive environments, see Appendices I, 11, and III to DOCINOAA's "Guidance for
Facility and Vessel Response Plans Fish and Wildlife and Sensitive Environments" (see Appendix
E to this part, section 10, for availability) and the applicable Area Contingency Plan
YES NO X
5 Does the facility have a maximum storage capacity greater than or equal to one million
(1,000,000) gallons and is the facility located at a distance as calculated using the appropriate
formula in Attachment C-Ill to this appendix or a comparable formula, such that a discharge from
the facility would shut down a public drinking water intake9
YES NO X
6 Does the facility have a maximum storage capacity greater than or equal to one million
(1,000,000) gallons and within the past 5 years, has the facility experienced a reportable spill in an
amount greater than or equal to 10,000 gallons9
YES NO X
*If an alternative formula is used, documentation of the reliability and analytical soundness of the
alternative formula must be attached to this form
CERTIFICATION
I certify under penalty of law that I have personally examined and am familiar with the information
submitted in this document, and that based on my injury of those individuals responsible for
obtaining this information, I believe that the submitted information is true, accurate, and complete
Signature i-e . 4i -- Title Plant Manager
Name Brian Dyson Date j i
(Please type or piitit)
15

Spill Prevention and Response _Plan
Annual Training
The Spill Prevention and Response Plan Team listed below has accepted the responsibility to
implement and c my out the established spill containment and cleanup procedures in order to
prevent any environmental contamination by the potential contamination hazards listed in the
PalletOne — Mocksvi Ile SP3 and SPRP They will monitor the areas at the Mocksville plant, have
regular meetings to discuss any potential problems, and plan a solution in oidei to help prevent any
spill or contamination In the event of a spill, they will take the necessary steps to help contain the
spill, remove any contarrunated soil, and take the necessary measures to dispose of it to the proper
manner, according to current guidelines set forth by the NCDENR
June 2011
Team Members
Michael Spry
Roger Wooten
Les Gilpin
Roy Hurt
Delbert Ramsey
Randy Talley
Plant Safety Manager
Maintenance Supervisor
Maintenance
Maintenance
Maintenance
Maintenance
My signature below certifies my attendance at an annual stormwater pollution prevention meeting
conducted at the PalletOne-Mocksville facility on the date indicated
Team Membet
Signature
Date
Michael Spry
Roger Wooten
Les Gilpin
Roy Hurt
Delbert Ramsey
Randy Talley
1«