NCG030382_COMPLETE FILE - HISTORICAL_20120209 (FIX)

BEFC0 INC
PAGE b2
,a2/09/2012 16:26 12529779718
N
L
Fayetteville Division
2592 Hopc Mills Rd
Fovettevillc. NC 28306
910.864.1920 Phone
910.864,8774 Fax
Certificate of Analysis
K (--, a 30 3!S a
BFFCO Date Reported:3anuary 11, 2012
Mr. Edward Vineek Project: Stormwmer samples -Semiannual Date Received! �
1781 South Wesleyan Blvd. December 28. 2011
Rocky Mbunt NC, 27802 Sampled By: E- Vincek Date Samplcd: December 27, 2011
A
eld_Aa t
1112529-01
#1 St'onnwater
Units
Fier
pH
6,8
pH Units
IM7/11
13:20
E. Vincek
Field
Temperature
19
°C
12/27/11
13:20
E. Vincek
Field
Analyzed by: Microbac - FayeMevllle DKtslon
Lead
-1,00
ugllr
12/30/11
1:34
JAW
SM 3113 B
Oil & Grease (HEM)
c5.00
mg/L
1/4/12
11:00
JAVd
EPA 1664
Total Suspended Solids
112
mg/L
12/29/11
14:30
DSK
SM 20th Ed. 2540 D
1112529-02
#2 Stormwater
Field Data
Method Qualifier
p1-1
6.8
pH Unit,-
12/27.!11
13,30
C. Vineek
Field
Temperature
59
cc
12/27/11
13.30
E. Vincek
Field
Analyzed t)y: Mlcrobae - Fayette+ilic DMslon
Lead
25.0
ug/L
12/30/1 l
1:34
JAW
',;M 3113 B
Oil & Grease (HEM)
<5.00
mg/L
1/9/12
I5:00
.JAW
EPA 1664 Al2
Total Suspended Solids
9.40
mg/L
12/28/11
14:30
DSK
SM 20th Ed, 2540 D
SWO Certifieatlons; NCONR #11 Respectfully Submitted
NCDOH 037714 Robert Dormer
USDA #3787
Robc;rt Dermcr, f-iivjcien 4lanagcr
Thank you tw your business. Wr. +nw+e yrn+r lrctilAnt k ern npr lcvd nr crrv+CC ro wu+. !Herne 1linfae+ fife I)il-Won Along¢-• Rnher+ Ik•rmer m 9l4-,ti(,•a-l9.4, Jrsroe Wkc'.'. Yn ddrnf. m
jmnC!'. /i?kc',4 �+niemM1nC.Crsf+i 7f jr: v:u• iiu4t:f, ('Ef). W +R5'4r,hr)NCc�gfrilflFar.enpi vgfF al!v cumn+rnf[ nr,r+l��Cnni::nr.
Page 1 of 2

12529779718
BEFCO INC
PAGE 03
,.02/ 9/2012 16:26
f
1.'
Fayetteville Division
259Z I lops Mills Rd
Favettev,llc, NC 28306
910,864.1920 Phone
910.864,8774 Pax
Certificate of Analysis
BEFCO
Mr. Edward Vincek Project: Stormwater samples - Semiannual Date Repotted: January 11, 2012
1781 South Wesleyan Blvd. Date Receive.&December 2.8, 2011
Rocky Mount NC, 27902 Sampled By: E. vincek 1 Date Sampled; December 27, 2011
Notee and Definitions
A lZ Iv1S/M.SD roil reeovcry, but the LCS passes criteria,
State Certifications:
NCDNR 011 Respectfully Submitted
NCDOH 037714 Robert Dermer
USDA 03707 Rahert Nrmcr, Division mshnager
Thank you br your ouplr*ss, We invite I'rrur lCCdhI77.tii' ern oar Jn el nt service to volt. 1}leuac rnnlpCr the Ulvrefn.1 Muna�,�:r, RnAer! lJererer ar 914-N(1�1420, .;pn�c,r Mdrte, r>n�,vrrlc�nl, nr
/mrr<•r. ttrlt•e�frr7mfCriN�oc•.cnnr nr 71t�y,rr Hr�vrr, CPO, or X?mn„Ao%IgrrOM ,,r)hei,, coal wirer [7n4 aoarmrrnrc nr M4C�.'c.+Finn.�,
Page 2 ar2

02/25/2010 18:01 12529779718
EEFCO INC PAGE 01
RIeFCO, Inc,
P.O. Box 0039
'4 Rocky Mount, NC 27802
er USA
Fax
Tel- 252-977-9920
Fax: [phone]
www.belco.com
V
J� �4
19 60-20 f 0
30 YEARS
To: Office/company: -
Mr. Dave Parnell NCDENR - Division of Water Quality
Fax No:--
919-571-4716
From; .. Date:
Edward Vineek Thursday, February 25, 2010
Number of Pages (including cover sheet): To confirm receipt, or if you do not receive all pages, please call:
2 [phone]
Comments:
Dave,
Attached to this fax are the test results of the water samples we took in January. Please call if
you have any questions about the results. Thanks for your helpl
Conffdentlallty Notice; This page end any accompanying documents contain confidential Information Ineended for a
spec flc individual and purpose. 7»is t@16GDGi9tl informhlinn ih nrivaty and proteclod bylaw. i1 are yeu anot tltie
Intended recipient, you are hereby naKwd that any disclosure, copying or distribution, or the taking of any action
nuB based On the contents of this fntormatlon it strictly prohibited,

02/
BEFCO INC PAGE 02
O' Microbac Laboratories, Inc. Page l of 1
IT F V DIVISION
rt% j " EV
2592 HOPE MILLS ROAD
STATE CERT ID.
FAYET"TEVILLE, NC 28306
NC # t ]
[phone] FAX [phone]
NC #37714
R. W. SANDERS, VICE PRESIDENT
USDA 93787
http://www,mictobac.coma E-'Mail
[e-mail]
uki!✓Ni1�MJLW IJH- I(JLULtr - kUUD �iA?'EI Y ' L;UNJUM-EK l!.KV0UC'["3
WATER • AIR, WAS'J-V.S • VWIJ • FKAY MAC:Er11-1 IC:ALS . NU 1'1tACEUTIC;ALI
Jl
-
CERTIFICATE OF ANALYSIS
BEFCO, Inc
Date Reported;
02/10/2010
Mr. Edward A. Vincek
lute Received:
01 /22/2010
1781 South Wesleyan Blvd
Order Number:
1001.01 128
Rocky Mount, NC 27802
Invoice No.:
71220
Customer #:
6650
Sample Date:
01 /21 /2010
Permit No.
Sample Time:
Ho
Sampler: Vincelc
Subject: Stortnwater Samples - 1st, 2010
SNIP Teu Method Result Date Time Tech
LEAD
SM 3113 B
0.006 mgjL
01/29/2010
8:33
RAS
OIL & GREASE (HEM)
EPA 1664 A
8.091
02/02/2010
9AS
DCR
SOLIDS, TOTAL SUSPENDED
SM 2540 0
<7 mg/L
01/28/2010
9:30
TDA
ININWORKW9
NOW
LEAD
SM 3113 B
0.005 mg/L
01/2912010
8.33
RAS
OIL & GREASE (HEM)
EPA 2664 A
12.3 mg/L
02/02/2010
9:45
DCR
SOLIDS, TOTAL SUSPENDED
SM 2540 D
19 mg/L
0I126/2010
15:30
TDA
TSS QC recovery was 110%, data is valid but qualified.
�'+' sl•; 'Y f� r i iry" , ,y„ F.y � f. oy? t f i5 '„ �..� ., r - `},�.. ti._ `.; ' � _. � s.� r �i-, i f fP" �^ , I :,� r5 1. V'n `�1,. _ r'. t !,'i+,-�,�J'y'yi RtF r yn: t'y}. l ). J,1(li ..I:I �.l i f.•,' �_ �� i uj,• li' .'C" ? .� 1"
LEAD SM 3113 5
OIL & GREASE (HEM) EPA 1654 A
SOLIDS, TOTAI 511.4PrWnFn e14 2cgo D
TSS QC recovery was 110%, dal Is valid but quatifled.
0,008 m911-
01/a/2010
8:33
RAS
14.1 cng/L
02/02/2010
9AS
DCR
cy M911.
01/26/2010
15:30
TDA
RESPECTFULLY SUBMITTED: _�� r►
MICROBAC LABORATORIES, INC.
Tharkyou for your buslnrss, We lnvrla yawr feedback OR Ow Ji'i of"Afri ro you. Pi'enrt conr4a the L4boraeory Aireojor, Ran Sanders ar 910-864-1920 . knhrrj Morgan,
COO, at—argion(`yr7tcrobaacoo" or 7ievo► Boyce, CEO, or rbo}re@MicrabdC,corn wj/h oW Commenis or.arggtsjian.r,
TECH rNTTIALS: CHI-Microbe4. Chicagaland; PIT-Microbac, Pittshurgh,,, CMF-Microhae. Camp Hill: HAP/AJF-Microbac. Grccnsbnrn;
All other initials are Microbac. Faycrtcvillo except as noted.
L.AR CODES; N/D - Nrnte Dctcetcd N/F - Nvne Found < = best than > -Greater than Est. - Tatimstcd
The data end other in%rnutmn mM71fnE on th% end other at mmpt+'Mn4 dtKalmeta, repesa r oMy mo sampto(sl ana11 and L r MOW upon o% MEMO
—dUon ttut R h not to bit retmdu W wi Of In part for adve =era a odwr piopi -tthi wftm eppm W from the waornqvry.
USDA-Evh-fil TO&V rood SgnaV n C M Mq U*Ncal and MkmE(ebgkal AnnIl rand Research Iia[�i

y �y
BEFCO, Inc. - 1781 S. Wesleyan Bkvd, P.O. Box 6036 Rocky Mount, NC 27802-6036, USA
Phone: [phone] Fax. [phone] www.befco.Com
Mr. Danny Smith
Regional Supervisor
Raleigh Regional Office
1628 Mail Service Center
Surface Water Protection
Raleigh, NC 27699-1628
January 12, 2010
Dear Mr. Smith,
This reply is in response to the Notice of Violation sent to BEFCO, INC. dated
December 2, 2009. Included with this letter is the revised and updated
STORMWATER POLLUTION PREVENTION PLAN and Site Map. Water Sampling will
take place as soon as we have a significant rain event. Please review our response
and contact me if you have any questions or comments.
Kind regards,
Edward A. Vincek
Production Engineer
Enclosure: Revised STORMWATER POLLUTION PREVENTION PLAN and Site Map.
L
.BAN I a Zara
fp �
BEFCO

�- Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Stormwater Pollution Prevention Plan
for:
BEFCO, INC.
1781 South Wesleyan Blvd.
Rocky Mount, N.C. 27802-6036
252-977-9920
A
SWPPP Contact(s):
BEFCO, INC.
Edward A. Vincek
1781 South Wesleyan Blvd.
Rocky Mount, N.C, 27802-6036
252-977-9920
[e-mail]
SWPPP Preparation Date:
111 /2010
n

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Contents
SECTION 1: FACILITY DESCRIPTION AND CONTACT INFORMATION......................................................1
1.1 Facility Information............................................................................................................
1
1.2 Contact Information/Responsible Parties.................................................................................. 1
1.3 Stormwater Pollution Prevention Team.................................................................................... 3
1.4 Activities at the Facility........................................................................................................... 3
1.5 General Location Map............................................................................................................
4
1.6 Site Map................................................................................................
.............................. . 5
SECTION 2: POTENTIAL POLLUTANT SOURCES.......................................................................................6
2.1 Industrial Activity and Associated Pollutants.............................................................................
6
2.2 Spills and Leaks....................................................................................................................
6
2.3 Non-Stormwater Discharges Documentation............................................................................
7
2.4 Salt Storage...................................................................................................................
2.5 Sampling Data Summary ........................................................................................................
7
SECTION 3: STORMWATER Control Measures............................................................................................8
3.1 Minimize Exposure.............................................................................................................
8
3.2 Good Housekeeping..............................................................................................................
8
3.3 Maintenance..........................................................................................................................8
3.4 Spill Prevention and Response...............................................................................................
9
3.5 Employee Training......................................................................................................................
9
SECTION 4: SCHEDULES AND PROCEDURES FOR MONITORING.........................................................10
SECTION5: INSPECTIONS..........................................................................................................................11
Daily Facility inspection will be conducted by Edd Roberson. This will include:
.... ....................... I ............ 11
SECTION 6: SWPPP CERTIFICATION.........................................................................................................12
SECTION 7: SWPPP MODIFICATIONS........................................................................................................13
Attachment A — General Location Map
Attachment 8 -- Site Maps
Attachment C — General Permit
Attachment D - Analytical Monitoring Results
Attachment E - Qualitative Monitoring Records of Observation
Attachment F - Prevention Team Meeting and Training of Employees

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
SECTION 1; FACILITY DESCRIPTION AND CONTACT INFORMATION
1.1 Facility Information
Facility Information
Name of Facility:._ SEFCO. INC,
Street: 1781 South Weslevan Blvd.
City: Rocky Mount _ State: N.C. ZIP Code: 27802-6036
County or Similar Subdivision: Nash
Permit Tracking Number: GP NCG030000., COC NCG030382 (if covered under a previous permit)
Latitude/Longitude (Use one of three possible formats, and specify method)
Latitude: Longitude:
1. 35 154' 15" N (degrees, minutes, seconds) 1.77 ° 49' 30" W (degrees, minutes, seconds)
2. _ _ ° _ _ _ _' N (degrees, minutes, decimal) 2. _ _ ° _ _ _ _' W (degrees, minutes, decimal)
3. _ _ . _ _ _ _ ° N (decimal) 3. _ _ . _ _ _ _ ° W (decimal)
Method for determining latitude/longitude (check one):
® USGS topographic map (specify scale: 1" = 1310' ) ❑ EPA Web site ❑ GPS
❑ Other (please specify):
Is the facility located in Indian Country? ❑ Yes ® No
If yes, name of Reservation, or if not part of a Reservation, indicate "not applicable." "not applicable"
Is this facility considered a Federal Facility? ❑ Yes ® No
Estimated area of industrial activity at site exposed to stormwater: 2.5 (acres)
Discharge Information
Does this facility discharge stormwater into an MS4? ❑ Yes ® No
If yes, name of MS4 operator: _
Name(s) of water(s) that receive stormwater from your facility; Little Cokey Swamp to Tar River Basin
Are any of your discharges directly into any segment of an "impaired" water? ❑ Yes ® No
If Yes, identify name of the impaired water (and segment, if applicable):
Identify the pollutant(s) causing the impairment:
For pollutants identified, which do you have reason to believe will be present in your discharge?

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
For pollutants identified, which have a completed TMDL?
Do you discharge into a receiving water designated as a Tier 2 (or Tier 2.5) water? ❑ Yes ® No
Are any of your stormwater discharges subject to effluent guidelines? ❑ Yes ® No
If Yes, which guidelines apply?
Primary SIC Code or 2-letter Activity Code: SIC 34
(refer to Appendix D of the 2008 MSGP)
Identify your applicable sector and subsector:
1.2 Contact Information/Responsible Parties
Facility Operator (s):
Name: BEFCO, INC.
Address: 1781 South Wesleyan Blvd.
City, State, Zip Code: Rocky Mount, N.C. 27802-6036
Telephone Number: 252-977-9920
Email address: www.befco.com
Fax number: 252-977-9718
Facility Owner (s):
Name: BEFCO, INC.
Address: 1781 South Wesleyan Blvd.
City, State, Zip Code: Rocky Mount, N.C. 27802-6036
Telephone Number: 252-977-9920
Email address: www.befco.com
Fax number: 252-977-9718
SWPPP Contact:
Name: Edward A. Vincek
Telephone number: 252-977-9920
Email address: [e-mail]
Fax number: 252-977-9718
24 HR. Emergency Contact:
Name: Eastern Environmental Management
Telephone No. 866-443-2225 or 252-443-2224
2

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
1.3 Stormwater Pollution Prevention Team
Staff Names
Individual Responsibilities
Edward A. Vincek
Overall coordination, implementation, and Revision of Plan
Tony Whitley
Housekeeping, Preventative Maintenance, Employee Training, Monthly
Inspection of Facility
Edd Roberson
Receiving, Storage (Finished Goods and Raw Material), Waste Disposal,
Metal Recycling, Daily Inspection of Facility
Mike Cobb
Shipping and Loading Dock Maintenance
Richard Jones
Assistance in Coordination, Recordkeepin
Clifton May
Maintenance Supervisor
1.4 Activities at the Facility
BEFCO, INC. fabricates, assembles, and paints landscaping and agricultural equipment,
Raw material (steel sheets, flat bars, pipe, etc.) is received on the rear concrete area. All raw material is
stored inside the warehouse. This material is then fabricated, formed, and welded. The items waiting to be
assembled and painted are then stored in the warehouse.
Parts, and partially assembled machines from closed containers are unloaded at the front dock and stored
in the warehouse. These items are then moved to the assembly line where they are painted, assembled,
wrapped, and crated. Some finished goods are stored in the warehouse while other finished goods are
stored outside on the rear concrete area until shipment. Shipping is done by either loading flat bed trailers
in the rear concrete area or through the front and side loading docks into closed containers.
BEFCO, INC. also operates a spare parts department which is located inside the main building. Parts are
stored inside until they are shipped by parcel carrier or on flat bed trailers.

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
1.5 General Location Map
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Stormwater Pollution Prevention Plan (SWPPP)
BCFCO, INC.
1.6 Site Map
Befco Inc. Site Map
SIZE OF PROPERTY, 6,86 ACRES
CRAPWC SCAB
(�)
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1IS,
"-OFF-
TEST 9i 7
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(,) MT SITE 1, RUN -pi
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} (A) TEST SITE 4, RW1
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Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
SECTION 2: POTENTIAL POLLUTANT SOURCES
2.1 Industrial Activity and Associated Pollutants
Industrial Activity
Associated Pollutants
Finished goods stored on rear concrete area for
shipment
No pollutants present
Fork lift use on rear concrete area
No pollutants present
Loading and unloading at loading docks
No pollutants present
Trash dumpster
No pollutants present
Scrap metal dumpster
No pollutants present
Bead blaster filter housing
No pollutants present
Bottled gas storage
No pollutants present
2.2 Spills and Leaks
Areas of Site Where Potential Spills/Leaks Could Occur
Location Outfalls
Rear concrete area where finished goods are stored Outfall No. 2 and No. 3
Front and side loading docks Outfall No. 2 and No. 3
Scrap metal dumpster Outfall No. 1
Bead blaster filter housing Outfall No. 2
Description of Past Spills/Leaks
Date Description Outfalls
2007 No spills or leaks occurred during this year None
2008 No spills or leaks occurred during this year None
2009 No spills or leaks occurred during this year None
6

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
2.3 Non-Stormwater Discharges Documentation
Does not apply to this facility as we do not have non-stormwater discharges.
2.4 Salt Storage
Does not apply to this facility as we do not store salt.
2.5 Sampling Data Summary
See Appendix D for sampling data and lab results and Appendix E for qualitative results.
Date
Performed by
Analytical
Qualitative
Outfalls
9/1/2006
MH
YES
NOT DOCUMENTED
Outfall 1
911I2006
MH
YES
NOT DOCUMENTED
Outfall 2
911/2006
MH
YES
NOT DOCUMENTED
Outfall 3

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
SECTION 3: STORMWATER Control Measures
3.1 Minimize Exposure
1. All crated items with gearboxes that are stored on the rear concrete area for shipment are covered in plastic to
prevent exposure to storm water runoff.
2. The 40 ft. every day waste container is emptied on a regular basis to prevent accidental spillage of trash and
debris into the storm water runoff.
I All hazardous and non -hazardous waste is stored in drums under a metal roof on the rear concrete area. This
waste is removed on a regular basis by SAFETY KLEEN.
4. All paints, solvents, and catalysts are stored in an enclosed metal container located on the rear concrete area.
5. All forklifts are stored inside when not in use.
3.2 Good Housekeeping
The hazardous and non -hazardous waste is picked up every three months. The trash dumpster is removed every
month or earlier when full. The metal recycle dumpster is picked up every month or earlier when full.
Daily inspections include:
1. Forklifts for oil leaks
2. Concrete Storage Area for gearbox leaks
3. Hazardous and non -hazardous storage tanks, drums, and containers for leaks
4. Loading and Unloading docks for trash and debris
3.3 Maintenance
Forklifts are inspected for leaks on a daily basis by the Maintenance Supervisor. Forklifts are stored inside the facility
at night and when not in use. Periodic preventative maintenance is performed indoors on a monthly basis by the
Maintenance Supervisor.

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
3.4 Spill Prevention and Response
All containers of paint sludge, paint filters, and bead blast dust are labeled before going into the storage area.
Containers and drums are inspected on a daily basis for leaks and proper labeling.
Hazardous and non -hazardous storage areas are located in a low traffic area.
Handling of waste is conducted by an experienced forklift operator. If a spill does occur, the fork lift operator is to
immediately apply dry absorbent to the spill and then notify the Plant Manager for further instructions.
Edd Roberson is responsible for turning off the pump when loading or unloading containers in the front loading dock.
This will prevent any accidental spill from being pumped into the stormwater drain system. Mike Cobb is responsible
for turning off the pump at the loading dock in the Shipping area when unloading liquid material (Paint, Catalyst,
Solvent, etc.).
3.5 Employee Training
The SWPPP coordinator, Edward Vincek, will initiate a yearly meeting with the Stormwater Pollution
Prevention Team. Each team member will be given an updated copy of the SWPPP. The meeting will
focus on each team member's responsibilities and assigned tasks to help reduce and prevent stormwater
pollution, The coordinator will indicate where potential spills could occur, and discuss methods to help
prevent these spills.
The Factory Manager, Tony Whitley, will initiate a yearly meeting with all personnel involved in outside
activities. This will involve material handlers, forklift operators, and shipping clerks. The purpose of the
meeting is to instruct the personnel on proper procedures to be followed in case of an accidental spillage,
gearbox leak, or forklift leak. They will be instructed as to which Supervisor is to be informed of the spill or
leak. Rules for Good Housekeeping of the facility will also be discussed.
s1

Stormwater Pollution Prevention Plan (SWPPP)
SEFCO, INC.
SECTION 4: SCHEDULES AND PROCEDURES FOR MONITORING
ANALYTICAL MONITORING:
1. Sample Location(s). Samples will be taken at Site No. 1, Site No. 2, and Site No. 3. See the Site map
included with this plan. Site no. 4 will be sampled only if the benchmark values of Site No. 3 are exceeded,
which may indicate Stormwater Pollution running on BEFCO'S Site.
2. Pollutant Parameters to be Sampled. The discharge will be tested for: Lead, Total, pH, Oil and Grease,
and Total Suspended Solids. The total rainfall will be recorded as well as the duration of the event.
3. Monitoring Schedules. Monitoring will be done twice a year. The elapsed time between sampling will be
greater than 90 days.
4. Benchmark values. Lead, Total---------------------------------------------------------------0.033 mgll
pH--------------------------------------------------------------------------6.0-9.0
Oil and Grease----------------------------------------------------------30 mgll
Total Suspended Solids ------------------------------------------------ 100 mgll
5. Procedures. Samples will be taken by the "grab" method during the rain event. The samples will then be
placed in a cooler. Southern Testing in Wilson, N.C. will be notified to come and pick up the samples for
testing.
See Attachment "D" for analytical monitoring results.
QUALITATIVE MONITORING:
A visual inspection of each stormwater outfall will be conducted twice a year. The following Discharge
Characteristics will be observed and recorded.
1. Color
6,
Foam
2. Odor
7.
Oil sheen
3. Clarity
8.
Erosion or deposition at the outfall
4. Floating Solids
9.
Other obvious indicators
5. Suspended Solids
See Attachment "F" for qualitative monitoring records of observation.
H

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
SECTION 5: INSPECTIONS
Daily Facility inspection will be conducted by Edd Roberson. This will include:
1. Inspecting waste containers
2. Inspecting metal recycling containers
3. Inspecting outside storage area for leaks
4. Inspecting hazardous waste storage area and paint drums
5. Inspecting loading and unloading areas for trash
Monthly Facility inspection will be conducted by Tony Whitley and is documented below:
Date
Performed by
Inspection Results
Action Taken
1/11/2010
Tony Whitley &
Edward Vincek
No spills or gearbox leaks. Several
empty wood crates on concrete area
were full of paper trash. There was
trash and debris in the loading dock
in shipping.
Told Mike Cobb to clean the
loading dock and reiterated the
importance of good housekeeping.
1/12/2010
Tony Whitley &
Edward Vincek
Revisited loading dock and concrete
area. All trash and debris had been
removed.

Stormwater Pollution Prevention Plan (SWPPP)
BEPCO, INC.
SECTION 6: SWPPP CERTIFICATION
I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gathered and
evaluated the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is, to
the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations.
Name: 4 (, <� f►A Title: G F^)CRAZ- 1-rA-JA C, F4
Signature:
Date: of /11 r0
12

SECTION 7: SWPPP MODIFICATIONS
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
13

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment A — Genera! Location Map
_ �
R
r
03
Nu g
9 BEPCO '
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EEI.
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14

Befco
SZE OF PI
c
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment B — Site Map
c�Y F#>•tl
SYMBOL&.
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15

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment C — 2007 General Permit
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030382
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,
Befco Inc
is hereby authorized to discharge stormwater from a facility located at
Befco Incorporated
1781 S Wesleyan Blvd
Rocky Mount
Nash County
to receiving waters designated as a UT to Little Cokey Swamp, a Class C NSW water in the Tar -Pamlico
River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set
forth in Parts 1, 11, III, IV, V, and VI of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective November 1, 2007.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day November 1, 2007.
for Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission
16

Storniwater Pollution Prevention Plan (SWI'PP)
BEFCO, INC.
Southern 7 ,sting & Xe,Tcarch lnhdrutnrics
A Division of Microbac Laboratorles
®� 3809 Airpert Drive, Wilson, NC 27896;
,,, . Phone: [phone] Fax: [phone]
WobeSiW www,soulhorotesling.carn !
Attachment D
Page 1
C:IIAIN OF CUSTODY
& Analyses RV(lnest
page -or-
- - — - — - — - — - — - — - — - — - — - — - — - — - — - I
Lab Use Only
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n Ar-r,n. 4Ity. I?[lfl4"firm.,
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Contact Parson: Isnmr�W r
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See Pe-,Orse for Codes
SAPn001.0i (4103)
FIELD COPY
17

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment D
Page 2
Microbac Laboratories, Inc.
SOUTHERN TESTING dr RESEARCII DIVISION
3809 AIRPORT DRIVE, NW
' 1
WILSON, NC 27896-8649
[phone] (252) 237--9341 (fax)
www.southerniesting, cant
SAMPLE No.: 07161-001 1 AA94392
REPORT of ANALYSIS
Date Reported: Thursday, September 14. 2006
MATT HUTCHISON
BEFCO
PO BOX 6036
Phone! Fax: [phone]
ROCKY MOUNT NC 27802
P. 0.:
Client Sample Marks: OUTFALL 1
Sample Collection Dale: 9/1/2006
11:15:00 AM
1 Matrix:
STW
Lab Submittal Date: 9/1/2006
2:05:00 PIM
1 Classification:
E
CAT No. ANALYSES
METHOD
ANALYZED
by POL RESULT
UNIT
EM-082-L Lead (ICP)
EPA 20D.7
9I6I2006
GAR 0.010 <0.010
mg1L
EP-001 Digestion (ICPlFAAS)
EPA 200.7
9/1/2006
DJS Yes
EW-032-04 Oil and Grease (HEM)
EPA 1664
9/6l2006
JAB 5.0 <5.0
mg1L
EW-034.02 pH (Field)
EPA 150.1
911l2006
DLW 7.45
SU
EW-040-01 Solids: Total Suspended
EPA 160.2
915l2006
PEB 5 14
mglL
EW052.01 Temperature (Field)
EPA 170.1
9/1/2006
DLW 22.6
deg C
Sample Comments:
Rand Approved by:
i nan
Manager, Analytical Sciences Department
Page 1 of 3 Admin 9114/2006 11:40:05 AM
Wilson Division - NCO0120 Certification: Drinking Water #37708 Wastewater #21
(-G) Greensboro Division - NCO01754 Certification: Drinking Water 937795 Wastewater #637
Chemical and Microbiological Analysis: Environmental + Agrochemical • hoods • Pharmaceuticals

Stormwater Pollution Prevention Plan (SWPPP)
00, BEFCO, INC.
0
REPORT of ANALYSIS
MATT HUTCHISON
BEFCO
PO BOX 6036
ROCKY MOUNT NC 27802
Client Sample Marks: OUTFALL 2
Attachment D
Page 3
Mierobac Laboratories, Inc.
SOUTHERN TESTING & RESEARCH DIVISION
3809 AIRPORT DRl VE, NW
WILSON, NC 27896-8649
[phone] [phone] (Jr..)
www.so,utherntesting.com
SAMPLE No.: Q7161-002 / AA94393
Date Reported: Thursday, September 14, 2006
Phone / Fax: [phone]
P. O_:
Sample Collection Date: 9/1/2006
11:34:00 AM
Matrix:
STW
Lab Submittal Date: 9/1/2006
2:05:00 PM
I Classification:
E
CAT No. ANALYSES
METHOD
ANALYZED
by
POL
RESULT
UNIT
EM-062-L Lead (ICP)
EPA 200.7
9/6/2006
GAR
0.010
<0.010
mg/L
EP-001 Digestion (ICP/FAAS)
EPA 200.7
9/1/2006
DJS
Yes
EW-032-04 oil and Grease (HEM)
EPA 1664
9/6/2006
JAB
5.5
<5.5
mg/L
EW-034-02 pH (Field)
EPA 150.1
9/1/2006
OLW
6.96
SU
EW-040-01 Solids: Total Suspended
EPA 160.2
9/5/2006
PEB
2
4
mg/L
EW-052-01 Tomporature (Field)
EPA 170.1
9/1/2006
DLW
22.9
deg C
Sample Comments:
MR i moved by:
Innant
Manager, Analytical Sciences Department
Page 2 of 3 Admin 9/14/2006 11:40:05 AM
Wilson Division - NCO0120 Certification: Drinking Water #37708 Wastewater #21
(-G) Greensboro Division - NCO01754 Certification: Drinking Water #37795 Wastewater 4637
Chemical'and Microbiological Analysis: Environmental • Agrochemical , Foods - Pharmaceuticals

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment D
Page 4
cp?)
Microbac Laboratories, Inc.
SOUTHERN TESTING A RESEARCH DIVISION
a
3809 AIRPORT DRIVE, NW
1
WILSON, NC 27896-8649
[phone] [phone] (fear)
www.southerntesting.com
SAMPLE No.: Q7161-003 / AA94394
REPORT of ANALYSIS
Date Reported: Thursday, September 14, 2006
MATT HUTCHISON
BEFCO
PO BOX 6036
Phone/Fax: [phone]
ROCKY MOUNT NC 27802
P. O.:
Client Sample Marks: OUTFALL 3
Sample Collection Date: 911/2006 11:51:00 AM Matrix: STW
Lab Submittal Date: 9/1/2006 2:05:00 PM Classification: E
CAT No.
ANALYSES
METHOD
ANALYZED
by
PQL
RESULT
UNIT
EM-082-L
Lead (ICP)
EPA 200.7
9/612006
GAR
0.010
<0.010
mg/L
EP-001
Digestion (ICPIFAAS)
EPA 200.7
9l1I2006
DJS
Yes
EW-032-04
Oil and Grease (HEM)
EPA 1664
9/612006
JAB
5.1
<5.1
mg/L
EW-034-02
pH (Field)
EPA 150.1
9I112006
OLW
7.83
SU
EW-040-01
Solids: Total Suspended
EPA 160.2
9l512006
PEB
2
29
mg/L
EW-052-01
Temperature (Field)
EPA 170.1
911/2006
DLW
22.1
deg C
Sample Comments:
R` APP oved by:
innant
Manager, Analytical Sciences Department
Page 3 of 3 Admin 9114l2006 11:40:05 AM
Wilson Division - NCO0120 Certification: Drinking Water #37708 Wastewater #21
(-G) Greensboro Division - NCO01154 Certification: Drinking Water #37795 Wastewater #637
Chemical and Microbiological Analysis: Environmental • Agrochemical • Foods • Pharmaceuticals
20

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
... ............
Attachment E
Page 1
�O�pP w A r,�qQG
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: N1C/_I /_/ /_/_/_1 or Certificate of Coverage No.:
Facility Name:
County: Phone No.
Inspector:
Date of Inspection:
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permittee or Designee)
1. Outfall Description
Outfall No. Structure (pipe, ditch, etc.)
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
. 2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium,
dark) as descriptors:
3. Odor
Describe any distinct odors that the discharge may have (i.e., smelts strongly of oil, weak chlorine odor,
etc.)
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very
cloudy:
1 2 3 4 5 6 7 8 9 10
Page I
5 WL-242-020705
21

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment E
Page 2
5. Floating Solids
Choose the number which best describes the amount of floating solids in the Stormwater discharge where
1 is no solids and 10 is the surface covered with floating solids:
1 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge
where 1 is no solids and 10 is extremely muddy:
1 2 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? Yes No
9. Deposition at Outfail
Is there deposition of material (sediment, etc.) at or immediately below the outfall7 Yes No
10. Erosion at Outfall
Is there erosion at or immediately below the outfall? Yes No
11. Other Obvious Indicators of Stormwater Pollution
List and describe
Nate: Low clarity, high solids, and/or the presence of foam. oil sheen, deposition or erosion maybe
indicative of conditions that warrant further investigation and corrective action.
Page 2
S WU-242-020705

Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment F
Page 1
Stormwater Pollution Prevention Team Meeting
Date
Team Member ...
S'gnature
1-11-2010
Edward V incek
1-11-2010
Tony Whitley
1-11-2010
Edd Roberson
1-11-2010
Mike Cobb
1-11-2010
Richard Jones
1-11-2010
Clifton May
}
The yearly meeting of the Pollution Prevention Team took place on Monday 11, 2010. All members of the
team were present. Every member of the team was given a copy of the newly revised STORMWATER
POLLUTION PREVENTION PLAN and a copy of the Site Map. The following items were discussed:
1. The direction of flow of stormwater on to and off of the BEFCO Site.
2. The individual responsibilities of each Team member.
3. Potential areas for spills and what to do if one occurs.
4. Good Housekeeping practices.
5. Proper procedures for loading and unloading at the shipping docks.
6. Monthly inspection of the Facility.
7. Daily inspection of the Facility.
8. Proper handling of Hazardous and Non -Hazardous waste.
9. Preventative Maintenance
10. Maintaining and updating the STORMWATER POLLUTION PREVENTION PLAN.
23

Stormwater Pollution Prevention Plan (SWPPP)
BBFCO, INC.
Attachment F
Page 2
Minutes of Employee Training
Date
Employee Name
Signature
1-11-2010
Otha Rae Lynch
1-11-2010
Larry Marks
'
_.'.
On 1-11-2010 Tony Whitley conducted an employee training meeting with Otha Rae Lynch and Larry
Marks. Otha Rae and Larry are forklift operators who handle all material movement outside on the rear
concrete storage area and loading docks. The following items were discussed;
1. The importance of proper outdoor material handling and its relationship to possible stormwater pollution.
2. Where possible spills and leaks can occur, and what measures to take in the case of a spill or leak.
3. Proper handling of Hazardous and Non -Hazardous Waste.
4. Hydraulic leaks from forklifts.
5, The storage of forklifts inside the building at night or when not in use.
6. Good Houskeeping Practices.
7. Trash accumulation on drainage grates,
24

Befco Inc. Site Map
SIZE OF PROPERTY: 6.86 ACRES
GRAPHIC SCALE
40 a an +o so +w
IN FEET
1 inch d 40 tt
\ � 1
(1)
TEST SI; E 1
"RUN --ON \
,
zo oti.
r
(3)
TEST SITE 3
"RUN—OFF"
(2)
TEST SITE 2
"RUN—OFF"
DITCH
(4)
TEST SITE 4
"RUN—ON"
SYMBOLS:
FLOW PATH
DRAIN PIPE
INDOOR (COVERED AREA)
IP
IRON PIPE
CID
CALCULATED POINT
(1)
TEST SITE 1, RUN—ON
(2)
TEST SITE 2, RUN—OFF
(3)
TEST SITE 3, RUN—OFF
(4)
TEST SITE 4, RUN—ON
(ONLY IF NECESSARY)
Cooley Road
(sR,72z-a#FvO,a»")

01/12/2010 15:19 1252977971E BEFCO INC PAGE 02
Dear Mr. Parnell, January 12, 2010
This package contains the revised and updated STORMWATER POLLUTION
PREVENTION PLAN that is being mailed to Mr. Danny Smith in Raleigh, NC. please
note the changes made to the Site Map_ I was not aware of two storage tanks located in
the left rear corner of the site. One is a kerosene tank on legs, and the other is a Propane
storage tank. Please contact me if you have any comments or questions.
Sincerely,
F.,dward A. Vincek
SWPPP contact @ BETCO, rNC.

01/12/2010 15:19 12529779718 BEFCO INC PAGE 03
Stormwater Pollution Prevention Plan {SWPPP}
BEFCO, MC.
Stormwater Pollution Prevention Plan
for:
BEFCO, INC.
1781 South Wesleyan Blvd.
Rocky Mount, N.C. 27802-6036
252-977-9920
SWPPP Contact(s):
BEFCO, INC.
Edward A. Vineek
1781 South Wesleyan Blvd.
Rocky Mount, N.C. 27802-6036
252-977-9920
[e-mail]
SWPPP Preparation Date:
111/2010
F

01/12/2010 15:19 12529779718 BEFCO INC PAGE 04
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Contents
SECTION 1: FACILITY DESCRIPTION AND CONTACT INFORMATION......................................................1
1.1 Facility Information............................................................................................................ 1
1.2 Contact Information/Responsible Parties..................................................................................
1
1,3 Stormwater Pollution Prevention Team ................... .................. ............................................_..
;
1.4 Activities at the Facility ............................. . .....................................................................
3
1.5 General Location Map............................................................... ................... .................... ......
4
1.6 Site Map...................................................................................................................
5
SECTION 2: POTENTIAL POLLUTANT SOURCES.......................................................................................6
2.1 Industrial Activity and Associated Pollutants.............................................................................
6
2.2 Spills and Leaks...................................................................................................................
6
2.3 Non-Stormwater Discharges Documentation ......................
..... 7
2.4 Salt Storage.....................................................................................................................
7
2.5 Sampling Data Summary ......... ........ .....................................................................
7
SECTION 3: STORMWATER Control Measures............................................................................................8
3.1 Minimize Exposure.............................................................................................................
8
3.2 Good Housekeeping...............................................................................----.--....._..................
8
3.3 Maintenance ................ ...........................................................................................................
8
3A Spill Prevention and Response . .......... ......................... ................................. - ...... ..................
9
3.5 Employee Training ......................................................................................................................
9
SECTION 4: SCHEDULES AND PROCEDURES FOR MONITORING.........................................................10
SECTION 5: INSPECTIONS. ......................................................................................................................... 11
Daily Facility inspection will be conducted by Edd Roberson. This will include: ........................................
11
SECTION 6: SWPPP CERTIFICATION..........................................................................................................12
SECTION 7: SWPPP MODIFICATIONS .......................................................................................................13
Attachment A -General Location Map
Attachment B - Site Maps
Attachment C - General Permit
Attachment D -Analytical Monitoring Results
Attachment E - Qualitative Monitoring Records of Observation
Attachment F - Prevention Team Meeting and Training of Employees
I1

01/12/2010 15:19 12529779718 BEFCQ INC PAGE 05
Stormwater Pollution Prevention Plan (SWPPP)
BF-FCO, ITC.
SECTION 1: FACILITY DESCRIPTION AND CONTACT INFORMATION
1. 1 Facility Information
Facility Information
Name of Facility: _BEFCO, INC, _
Street: 1781_South Wesleyan Blvd,
City: Rocky Mount State: N.C. ZIP Code: 27802-6036
County or Similar Subdivision: Nash
Permit Tracking Number: GP.NCG030000, COC NCGO30382 (if covered under a previous permit)
Latitude/Longitude (Use one of three possible formats, and specify method)
Latitude:
1, 35 054' 15" N (degrees, minutes, seconds)
2. _ _ ° _ _ _ _' N (degrees, minutes, decimal)
3, _ _ . _ _ _ _ ° N (decimal)
Method for determining latitudellongitude (check one)
Longitude:
1.77 ° 49' 30" W (degrees, minutes, seconds)
2. _ —I _ _ _' W (degrees, minutes, decimal)
3. _ _ _ _ _ _ ° W (decimal)
® USGS topographic map (specify scale: 1" =1310` ) ❑ EPA Web site ❑ GPS
❑ Other (please specify).
Is the facility located in Indian Country? ❑ Yes ® No
If yes, name of Reservation, or if not part of a Reservation, indicate "not applicable." "not applicable"
Is this facility considered a Federal Facility? ❑ Yes ® No
Estimated area of industrial activity at site exposed to stormwater: 2.5 (acres)
Discharge Information
Does this facility discharge stormwater into an M34? ❑ Yes ® No
If yes, name of MS4 operator:
Name(s) of water(s) that receive stormwater from your facility: Little Cokey Swamp to Tar River Basin
Are any of your discharges directly into any segment of an "impaired" water? [J Yes ® No
If Yes, identify name of the impaired water (and segment, if applicable):
Identify the pollutant(s) causing the impairment:
For pollutants identified, which do you have reason to believe will be present in your discharge?
i

01/12/2010 15:19 12529779718 BEFCO INC PAGE 06
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, TNC.
For pollutants identified, which have a completed TMDL?
Do you discharge into a receiving water designated as a Tier 2 (or.Tier 25) water? ❑ Yes ® No
Are any of your stormwater discharges subject to effluent guidelines? ❑ Yes ® No
If Yes, which guidelines apply?
Primary SIC Code or 2-letter Activity Code: SIC 34
refer to Appendix D of the 2008 MSGP
Identify your applicable sector and subsector:
1.2 Contact Information/Responsible Parties
Facility Operator (s):
Name: BEFCO, INC.
Address: 1781 South Wesleyan Blvd.
City, State, Zip Code: Rocky Mount, N.C. 27802-6036
Telephone Number: 252-977-9920
Email address: www.befco.com
Fax number: 252-977-9718
Facility Owner (s):
Name: BEFCO, INC.
Address: 1781 South Wesleyan Blvd.
City, State, Zip Code: Rocky Mount, N.C. 27802-6036
Telephone Number: 252-977-9920
Email address: www.befco.com
Fax number: 252-977-9718
SWPPP Contact:
Name: Edward A. Vincek
Telephone number., 252-977-9920
Email address: [e-mail]
Fax number. 252-977-9718
24 HR. Emergency Contact:
Name: Eastern Environmental Management
Telephone No. 866-443-2225 or 252-443-2224
2

01/12/2010 15.19 12529779718 BEFCO INC PAGE 07
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO. INC-
1.3 Stormwater Pollution Prevention Team
Staff Names
Individual Res nsibilities
Edward A. Vincek
Overall coordination, im l entation, and Revision of Plan
Tony Whitley
Housekeeping, Preventative Maintenance, Employee Training, Monthly
Ins ection facility
Edd Roberson
Receiving, Storage (Finished Goods and Raw Material), Waste Disposal,
Metal Recycling, Daily Inspection of Facility
Mike Cobb
ShippingShippigg and Loading Dock Maintenance
Richard Jones
Assistance in Coordination, Recordkee in
Clifton May
Maintenance Supervisor
1.4 Activities at the Facility
BEFCO, INC, fabricates, assembles, and paints landscaping and agricultural equipment.
Raw material (steel sheets, fiat bars, pipe, etc.) is received on the rear concrete area. All raw material is
stored inside the warehouse. This material is then fabricated, formed, and welded. The items waiting to be
assembled and painted are then stored in the warehouse.
Parts, and partially assembled machines from closed containers are unloaded at the front dock and stored
in the warehouse. These items are then moved to the assembly line where they are painted, assembled,
wrapped, and crated. Some finished goods are stored in the warehouse while other finished goods are
stored outside on the rear concrete area until shipment. Shipping is done by either loading fiat bed trailers
in the rear concrete area or through the front and side loading docks into closed containers.
BEFCO, INC. also operates a spare parts department which is located inside the main building. Parts are
stored inside until they are shipped by parcel carver or on flat bed trailers.

01/12/2010 15:19 1252977971B BEFCO INC PAGE 09
Stormwater Pollution Prevention Flan (SWPPP)
BEFCO, INC.
1.6 Site Map
aefco Inc, Site Map M w
M OF FRWERTt! MS- ACRES E3 �_ I
y
r
sP+YM��
i�7
TOT 9A �
oawx
(11
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uo-
TyT sc a Rlh-dr
(s1
Ts.T srt a "-w
F
(4j
TCT AT. Mwm
fMLV F MD=2PT1
5

01/12/2010 15:19 12529779718 BEFCO INC PAGE 10
S�ormwater Pollution Prevention Plan (SWPPP)
BEFCO, TNC.
SECTION 2: POTENTIAL POLLUTANT SOURCES
2.1 Industrial Activity and Associated Pollutants
Industrial Activi
Associated Pollutants
Finished goods stored on rear concrete area for
shipment
No pollutants present
Fork lift use on rear concrete area
No
pollutants
present
Loading and unloading at loading docks
No
pollutantspresent
Trash dum ster
No
Ilutants
present
Scrap metal dum ster
Na
pollutants
present
Bead blaster filter housing_No
pollutants
present
Bottled gas stor a
Na
pollutants
present
2.2 Spills and Leaks
Areas of Site Where Potential SpilWl_eaks Could Occur
Location I Outfalls
Rear concrete area where finished goods are stored I Outfall No. 2 and No. 3
Front and side loading docks Outfall No. 2 and No. 3
Scrap metal dum ster Outfall No. 1
Bead blaster filter housing Outfaff No. 2
Descdptlon of Past SpillslLeaks
Date Description Malls
2007 Nos ills or leaks occurred during this year None
2008 No spills or leaks occurred durin 'this y,ear None
2009 No spills or leaks occurred dudnq this Year None
x

01/12/2010 15:19 12529779718 BEFCO INC PAGE 11
Stormwater Pollution Prevention Plan (SWPPP)
BE CO, INC_
2.3 Non-Stormwater Discharges Documentation
Does not apply to this facility as we do not have non-stormwater discharges.
2.4 Salt Storage
Does not apply to this facility as we do not store salt.
2.5 Sampling Data Summary
See Appendix D for sampling data and lab results and Appendix E for qualitative results.
Date
Performed by
Analytical
Qualitative
Outfalls
9/1/2006
MH
YES
NOT DOCUMENTED
Outfali 1
9/112006
MH
YES
NOT DOCUMENTED
Outfall 2
. 911/2006
MH
YES
NOT DOCUMENTED
Outfall 3
7

01/12/2010 15:19 12529779718 BEFCO INC PAGE 12
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
SECTION 3: STORMWATER Control Measures
3.1 Minimize Exposure
1. All crated items with gearboxes that are stored on the rear concrete area for shipment are covered in plastic to
prevent exposure to storm water runoff.
2. The 40 ft. every day waste container is emptied on a regular basis to prevent accidental spillage of trash and
debris into the storm water nmoff.
3. All hazardous and norFhazardous waste is stored in drums under a metal roof on the rear concrete area. This
waste is removed on a regular basis by SAFETY KLEEN.
4_ All paints, solvents, and catalysts are stored in an enclosed metal container located on the rear concrete area,
5. All forklifts are stored inside when not in use.
3.2 Good Housekeeping
The hazardous and non -hazardous waste is picked up every three months. The trash dumpster is removed every
month or earlier when full. The metal recycle dumpster is picked up every month or earlier when full.
Daily inspections include:
1. Forklifts for oil leaks
2, Concrete Storage Area for gearbox leaks
3. Hazardous and non -hazardous storage tanks, drums, and containers for leaks
4. Loading and Unloading docks for trash and debris
3.3 Maintenance
Forklifts are inspected for leaks on a daily basis by the Maintenance Supervisor. Forklifts are stored inside the facility
at night and when not in use. Periodic preventative maintenance is performed indoors on a monthly basis by the
Maintenance Supervisor.
8

01/12/2010 15:19 1252977971B BEFCO INC PAGE 13
Stormwater Pollution Prevcntion Plan (SWPPP)
B£1"CO, INC.
3A Spill Prevention and Response
All containers of paint sludge, paint filters, and bead blast dust are labeled before going into the storage area.
Containers and drums are inspected on a daily basis for leaks and proper labeling.
Hazardous and non -hazardous storage areas are located in a low traffic area,
Handling of waste is conducted by an experienced forklift operator. If a spill does occur, the fork lift operator is to
immediately apply dry absorbent to the spill and then notify the Plant Manager for further instructions.
Edd Roberson is responsible far tuming off the pump when loading or unloading containers in the front loading dock.
This will prevent any accidental spill from being pumped into the stormwater drain system. Mike Cobb is responsible
for tuming off the pump at the loading dock in the Shipping area when unloading liquid material (Paint, Catalyst,
£olvcnt, cto.).
3.5 Employee Training
The SWPPP coordinator, Edward Uncek, will initiate a yearly meeting with the Stormwater Pollution
Prevention Team. Each team member will be given an updated copy of the SWPPP. The meeting will
focus on each team member's responsibilities and assigned tasks to help reduce and prevent stormwater
pollution. The coordinator will indicate where potential spills could occur, and discuss methods to help
prevent these spills.
The Factory Manager, Tony Whitley, will initiate a yearly meeting with all personnel involved in outside
activities. This will involve material handlers, forklift operators, and shipping clerks. The purpose of the
meeting is to instruct the personnel on proper procedures to be followed in case of an accidental spillage,
gearbox leak, or forklift leak. They will be instructed as to which Supervisor is to be informed of the spill or
leak. Rules fui Guud Housekeeping of Ow faullIty wlll also be dlscussed.
0

01/12/2010 15:19 12529779718 BEFCO INC PAGE 14
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, TNC.
SECTION 4; SCHEDULES AND PROCEDURES FOR MONITORING
ANALYTICAL MONITORING:
1. Sample Location(s). Samples will be taken at Site No. 1, Site No. 2, and Site No. 3. See the Site map
included with this plan. Site no. 4 will be sampled only if the benchmark values of Site No. 3 are exceeded,
which may indicate Stormwater Pollution running on BEFCO'S Site.
2. Pollutant Parameters to be Sampled. The discharge will be tested for, Lead, Total, pH, Oil and Grease,
and Total Suspended Solids. The total rainfall will be recorded as well as the duration of the event.
3. Monitoring Schedules. Monitoring will be done twice a year. The elapsed time between sampling will be
greater than 90 days.
4. Benchmark values, Lead, Total ---------------------- ------ ------------- —-------- -------0.033 mgll
PH._____-----_--_...-----------_----------------------------6.g-9.0
Oil and Grease ------------------- mg/l
Total Suspended Solids ------ ------------ ------------------------ --.ip0 mg/I
5. Procedures. Samples will be taken by the "grab" method during the rain event. The samples W11 then be
placed in a cooler, Southern Testing in Wilson, N.C. will be notified to come and pick up the samples for
testing.
See Attachment "D" for analytical monitoring results.
QUALITATIVE MONITORING:
A visual inspection of each stormwater outfall will be conducted twice a year. The following Discharge
Characteristics 411 be observed and recorded.
I -
Color
6.
Foam
2.
Odor
7.
Oil sheen
3.
Clarity
8.
Erosion or deposition at the outfall
4.
Floating Solids
9.
Other obvious indicators
5.
Suspended Solids
See Attachment " E" for qualitative monitoring records of observation.
to

01/12/20ie 15:19 12529779718 BEFCO INC PAGE 15
Stormwater Pottution Prevention Plan (SWPPP)
SEFCO, INC.
SECTION 5: INSPECTIONS
Daily Facilityinspection will be conducted by Edd Roberson. This will il I
RUlude:
1. Inspecting waste containers
2. Inspecting metal recycling containers
3. Inspecting outside storage area for leaks
4. Inspecting hazardous waste storage area and paint drums
5. Inspecting loading and unloading areas for trash
Monthly Facility inspection will be conducted by Tony Whitley and is doturnented
below:
Bate Performed by Inspection Results
Action Taken
1 /11/2010
Tony Whitley &
No spills or gearbox leaks. Several
Told Mike Cobb to clean the
Edward Vineek
empty wood crates on concrete
rea
loading dock and reiterated the
were full of paper trash. There
as
importance of good housekeeping.
trash and debris in the loading
in shipping.
�ock
1/1212010
Tony Whitley &
Revisited loading dock and con
rete
Edward Vincek
area. All trash and debris had Leen
removed.
tt

01/12/2010 15:19 12529779718 BEFCQ INC PAGE 16
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
SECTION 6; SWPPP CERTIFICATION
I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gathered and
evaluated the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is, to
the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations.
Name: )Pik A �14rjA Title: -rA jA a r'A
Signature: Date
ethzlrfl
12

01/12/2010 15:19 12529779718 BEFCO INC PAGE 17
Stormwater Pollution Prevention flan (SWPPP)
BEFCO, INC.
SECTION 7: SWPPP MODIFICATIONS
_ Date Performed by Modification
Date INT. I Results
13

01/12/2010 15:19 1252977971B BEFCO INC PAGE 19
Stortnwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
MCC
SW OF P
C
Attachment B — Site Map
—"- !t
moo e.b
/// Ms�Cn {CGS NS+S
7 dltlM`�S IfMT
n) Mt SIR'. &M.Ch
Q! tpt AN 7. M-W
[A ARI AN 11 37 "r
{�! mr as 4 erwel
15

01/12/2010 15:19 12529779718 BEFCO INC PAGE .2e
Stormwater Pollution Prevention Plan (SWPPP)
BEI:CO, INC.
Attachment C — 2007 General Permit
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIM SION OF WATER QUALITY
GENERAL. PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCGO30382
STOkMWATER 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,
Befco Inc
is fiereby .authorized to discharge stormwater From a facility located at
%foo Incorporated
1781 SWesleyan Blvd
Rocky Mount
Nash County
to receiving wal;efs designated as a UT to Little Cokey Swamp, a Class C NSW water in the Tar-Pamlico
River Basin in-aecordahGe wttlh the. effluent limitations, monitoring requirements, and other conditions set
forth in Parts I, 11, 111, JV, V. and M of General' Permit No. 'NCG030040 as attached:
This certificate of coverage shall became effective November 1, -2007.
This Cerlificatc of Coverage shall romain in effect for the duration of the General Permit.
Signed this stay November 1, 2007_
for Coleen H. SuIGr%, Director
Division of Water Onlity
By Auttmirity of the Environmental Management Commission
ro

01/12/2010 15:19 12529779718 BEFCO INC PAGE 21
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment 0
Page I
. ,0 ft,
&*&erm MQV & Rerarch Lalmirrilorl" CIA OF CUSTODY
A MUM of Mkrob" Labogotoo lee
300 Airpa4 Drhvv, Wisan, NC 27996& AnalyRequest Lab Use Only
..WOr Phone: 9W4,37-4175 - Par. 262-937-9341
rq
011OW101 Row 10,
0"100
L
NC
Walla
time
tft=* NJON (Aw? -
YMA ART
Mij.F000k"ImAl.
i:19rd Requok.w Due DOW
k7.
•
'N"i
ir4 Coft Club St"Ow
1k,
p
I&
3
L
7,
Atrz dk.
i. L
�A LL
f03,
AV
Ry
2
.3
Field P.Ci. FWA 7q M.: Mid FA Weld 60
46 O#TA TO K WSED POR FM47flA"Y COWII&WE MFOGM LM OW IF IfM VMCM RLIGUIAXW AAA OW:
PIRD COPY
17

01/12/2010 15:19 12529779718 BEFCO INC PAGE 22
Stormwater Pollution Prevention Plan (SWPPP)
BErco, TNC.
Attachment D
Page 2
Microbac Laboratories, In
SO[7'rWIt'i N nr SrINC Ai REST4A 01 DIY7SION
■
380i1 � r>Qp,pR'r DJplYS. NW
•
WflSON, NC 279P"649
{252) 2S7-4I.75 (252) 237-934J 044
"nM.Sor rwernresring cons
REPORT of ANALYSIS
SAMPLE No.. Q7161-OC11 r AAa4392
_
Date Reported: Tnur.0day, Septemrier 14, 2006.
MATT HUTCHISON
t
POO B07( 603B
BOX
Phone f Fax: [phone]-&6171252-977- 971 a
ROCKY.. MOUNT NC 27802
P. O.:
Giant Sample Marks: OUTFALL 1
5dmple Collection Dale: 9/1f2006 . 11 15:00 AM f Matrix: S-rw
Lab submittal Dare: 9/1/2006 2:05,00 PM I Classification: E.
CAT No. ANALYSES METHOD ANALYZED by PQL RESULT UNIT
EM-M8 L
Lead (iCP)
EPA 200.7
91WOOO
GAR 0-010 e0.010
mglL
5p-ot71
Dfgestion (ICPtFAAS)
EPA 200-7
9I112006
i7JS Y"
6W-03270A
00 end Grease (HEM)
EPA 1664
9/812006
JAB S.0 c5,o
mg7L
EW-024-02
pH (Field)
EPA 160.1
9012006
QLW 7.0
SU
EW-040-01
5oRds: Total Suspended
(EPA 160.2
9V2006
PEB 5 44
mg(L
ew-052.01
Temperature (Plaid)
FPA 170.1
9/1I2006
DLW 22.6
deg C
Sample Comments-
_.
..
�.
RaWawad andApprnved by:
rlan
Manager; Analytioai Sciences Oeowtment
Page 1 of 3 Admin 9116/20W 11:40:05 AM
Wlison DMsion - NCO0120 Certification: Drinking Water 037708 Wastewdier #21
(-G) Greensboro Oivi5ion - NCO01754 Certification: Drinking Water #37793 Wa3tewater #637
Chemical -and Micmb;ologicat Analysis: Envbmnfncntal • Agtichemiaal - Fooda • Fharmaceut+calc

61/12/2010 15:19 12529779718 BEi=CO INC PAGE 23
Sto mwator Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment D
Page 3
® Microbic Laboratories, Inc.
V0VrffffAWV TIES rI NCi do RJ54RnRCHDI9/1.u101V
3809AfRP0RrD UVZ NW
WZ"ON, Are 2789"649
[phone] [phone] IY#=)
www."Urherpgr�wing.com
REPORT of ANALYSIS SAMPLE No._ 07161-002 1 AA94393
Date Reported: Thursday, September 14, 2006
MATT 11UTGH180N
BF-FOO
PO BOX 6036 Phone 1 Fax: [phone]
ROCKY MOUNT NC 27802 P. 0-
-
Client Sample Marks: OUTFALL 2
Sample CCIIeCtlon Data: 91112006 11.34,00 AM Matrix-. STW
Lab Submittal Clete: 9/1/2006 2:05:00 PM Clasepneation: E
CAT No.
ANALYSES
METHOD
ANALYZED
by PQL
RESULT
U141T
EM-002-L
Land (ICP)
-EPA 200.7
016/2006
OAR 0.010
<0,010
mp1L
EP-001
Digestion(ICP/FAAS)
EPA200.7
9/1/2006.
OJS
Yes
EW-032-04
Oil and Grease (HEM)
EPA 1604
9/6/2006
JA3 5.5
<'5'.5
mg/L
EW-034-02
pH (Field)
EPA 150.1
9/112006
DI,W
6.96
5U
EW-040-01
$Dllds. Total Suspeneeo
EPA 160.2
9/512000
PEB2
4
mgfL
E.tN4052-01
Temperature (Field).
EPA 17QA
.9111200$
DLW
22.9
dcg C
—^
Sample Comments:
�R nd A roved by:
Irtnanf�
Managear, .h�talytl��,l
9c.isr os Departrmant
Page 2 of 3 Admin 9//412005 1 1:40:D5 AM
Wilson'bhrlglon - NC00120 Certification; Drinking Water 437708 Wastewater #21
(.-G) Greensboro Division - NC001754 C crlifiG*Vcrn; Drinking Wistet #3779$ Wa5tawater *637
CheMical'and Microbiological Analysis: F_nviromnental ` AgrodhamicMj • Foods, Pharrnaceuticaj5
19

01/12/2010 15:19 1252977971E BEFCO INC PAGE 24
Stormwatelr Pollution Prevention Plant (SWPPP)
BEFCO, INC.
Affachment D
Page 4
Micr•eba+c Laboratories, Inc.
SOUTHERNTE3:77Nt; A MEARCHDIKS1ON
3809.09 PORT DRIP , NW
07LSON, NC 27ffP"649
(252) 337-417S (252) 237--9341(fa4
arww. svYah ermesting, ev m
R IE P O R T of ANALYSIS
SAMPLE No.: 07181-003 1 AA94394
Elate Reported; Thursday, -September 14, 2006
MATT HUTCHISON
CO
PO BOX sons
PO
Phone Fax: [phone].977-9718
ROCKY MOUNT NC 27802
P. O,:
Cliant Sample Mark9: O TFALL 3
Sample CuRectlon Date: 8/V200B
11:51.,00 AM
I Matrix:
STW
Lab Submmal Dater: 911/2W6
2:45_o0 PM-1
Classificatlon:
E
CAT No. ANALYSES
METHOD
ANALYZED
by ML RESULT
UNIT
EM-082-L Lr3ad(ICP)
EPA200.7
91ZW2000
GAR 6.010 c4,010
mg1L
EP-001 Digestion (ICPtFA LS)
EPA 200.7
9012006
WS Yes
EW-032.04 OR and Grease Q-1EM)
EPA 1664
9W.006
JAB SA cs.1
mg11-
EW-034-02 pH �51eld)
EPA 150.1
911/2006
DLL 7.S3
SV
EW-D40-01 -Sauds; Total Suspended
EPA 160:2
915120U6
PEB 2 29
m9k
EW-052-01 Temperature (Pleld)
EPA 170.1
91412U06
DLW 22.1
dog C
Sample Comments:
Rgy"A7ed by:
In ant
Manager, Analytical ScienOes Department
Page 3 of 3 Admirl 9114/2W6 11:40:05 AM
Wlh2on division - NCo0120 Cerliftcol lan: Drinking Water #37708 Wastewater #21
(-G) Greensboro Divislon - NC001754 Certification, Drtnking Water NZ7796 Wastewater 9637
Chemical,and Mk"biolcgicsl Aaalyais: Environmanrsl • ggroehemical - Fooda - Pharmaceuticals
20

01/12/2010 15:19 12529779718 BEFCO INC PAGE 25
Storrnwater Pollution Prevention Plan (SWPPP)
SEFCO, INC.
Attachment E
Page 1
YJArF9
Stermwatelr Discharge Outfall (SDO)
Quatitatlive Mariitornng Report
Permit No.c d+il£l I_/_/ 1 / I 1 or Oertificau of Covomgc No.:
Facility Namc;
County: -- _ - - Phme No.
Inspector:
Date of Inspection:
By. this signature, I certify that this .clm, is accurate and'complete to the nest of my kwwledgc:
(Signature of Pcrmifte or Designee)
1. dutfAll D¢scription
Ou fall Me, structure (pipe, ditch, etc.) _
ReceivingStream:
Describe the industrial activitiea that occur within the outfall drainage tuea:
2. Color
Describe the color of the discharge using basic colors:(rcd, brown, bhte. etc.) and tint (light, medium
dark) as descriptors:
3. Odor
Describe any diSfinet odors that the dioehargc utay have (i.e., wriells strongly of oil, weak chlorine odor,
etc.)
a. Clarity
Choose the number which best describes the clarity of the discharge when I is clear and 10 is very
cloudy:
1 2 3 4 5 6 7 a 9 10
Papa I
awu-2+z.02070
21

01/12/2010 15:19 12529779718 BEFCO INC
PAGE 26
Stormwater Pollution Prevention Plan (SWPPP)
BEFC0, INC.
Attachment E
Page 2
& Floating Solids
Choose the number which bast describes the amount of flouting solids to the storrniWater discharge whew
I is no Solids and 10 is the surface covered with floating solids:
1 2 3 4 S 6 7 8 9 10
d Srspgnded Solids
Choose.the number which brat describes the amount of suspended m ids -in the stormwater discharge
when I is no solids and 10 is exurow y muddy:
1 2 3 4 S 6 7 8 9 10
7. Foam
is there any foam in the stortnwater discharge? Yes r%
S. Oil Sheen
1s there an oil sheen in the stormwatcr dischargc7 Yes No
9. Deposition at Oatfall
Is there deposition of material (sediment, etc.) at or immediately below ttre oudall? Yes No
fa. Erosion atowall '
is there erosion at or immediately below the outf8ll? Yes No
11. Other Obvious bidlcators of StotwwOer Pollution
List and describc
Nigh!: Low clarity, high solids, and/or the preser= of•.fvaM oil shaer, deposition or erosion tnay be
indicative of conditions that warrant further investigation sintt corn;ptive action.
Page 2
5wu-242.OW76$
0

01/12/2010 15:19 12529779718 BEFCO INC PAGE 27
Stormwater Pollution Prevention Plan (SWPPP)
BEFCO, INC.
Attachment F
Page 1
Stormwater Pollution Prevention Team Meeting
Date
Team Member -..
Signature
1-11-2010
Edward Vinuek
�.
1-I1-2010
Tony Wluiley
1-11-2010
Fdd Robeson
1-11-2010
Mike Cobb
Richard Jones
�.
1-.11-2010
0-i Ron may
\,
The yearly meeting of the Pollution Prevention Team took place on Monday 11, 2010. All members of the
team were present. Every member of the team was given a copy of the newly revised STORMWATER
POLLUTION PREVENTION PLAN and a copy of the Site Map. The following items were discussed:
1. The direction of flow of stormwater on to and off of the BEFCO Site.
2. The individual responsibilities of each Team member.
3. Potential areas for spills and what to do if one occurs.
4. Good Housekeeping practices.
5. Proper procedures for loading and unloading at the shipping docks.
6. Monthly inspection of the Facility.
7. Daily inspection of the Facility,
8. Proper handling of Hazardous and Non -Hazardous waste.
9. Preventative Maintenance
10. Maintaining and updating the STORMWATER POLLUTION PREVENTION PLAN.
23

01/12/2010 15:19 12529779718 BEFCO INC PAGE 28
StormwMer Pollution Prevention Plan (SWPPP)
BEFC0, TNC.
Attachment F
Page 2
Minutes. of Employee Training
Date
ti ;l'!�yee Name
Signature
1- 11-20 to
Otha Rae Lynch
1- l l -:Z010
Arty M-4rks
On 1-11-2010 Tony Whitley conducted an employee training meeting with Otha Rae Lynch and Larry
Marks. Otha Rae and Lary are forklift operators who handle all material movement outside on the rear
concrete storage area and loading docks. The following items were discussed:
1. The importance of proper outdoor material handling and its relationship to possible stormwater pollution.
2. Where possible spills and leaks can occur, and what measures to take in the case of a spill or leak.
3. Proper handling of Hazardous and Non -Hazardous Waste.
4. hydraulic leaks from forklifts.
5. The storage of forklifts inside the building at night or when not in use.
6. Good Houskeeping Practices,
7. Trash accumulation on drainage grates.
24

iLTIF
PA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
December 2, 2009
CERTIFIED MAIL 7008 1300 0000 1133 9002
RETURN RECEIPT REQUESTED
Mr. Edward Vincek
Production Engineer
BEFCO, Inc.
1781 South Wesleyan Blvd.
P. O. Box 6036
Rocky Mount, NC 27802-6036
Subject: Notice of Violation
Case No. NOV-2009-PC-0955
Compliance Evaluation Inspection"
NPDES Stormwater Permit NCG030382
BEFCO, Inc.
Rocky Mount, NC
Nash County
Dear Mr. Vincek:
Dee Freeman
Secretary
On November 23, 2009, Dave Parnell of the Raleigh Regional Office of the Division of Water Quality,
performed a compliance evaluation inspection (CEI) at the referenced manufacturer of landscaping and
farming equipment. Your assistance was appreciated. This inspection was conducted to determine
BEFCO, Inc.'s compliance with its NPDES stormwater permit. Observations during the inspection are as
follows:
1. The NPDES stormwater permit was available during the CEI.
2. The Stormwater Pollution Prevention Plan (SP3) was not available during the CEI, but was faxed to
this office on December 1, 2009. The issue date for the SP3 is 09/06/06. The SP3 was reviewed at
the time of the CEI, as well as in this office upon receipt of the faxed SP3. The following
deficiencies were noted and must be addressed within the response time noted in the last paragraph:
A. Although the absence of significant spills was referenced in the 9.6.06 version of the SP3, there
was no list of significant spills during the last three years available during the inspection.
Nort`hCarolina
Natumli'm
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: www,ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone].623-6748
An Equal Opportunity/Afflrmabve Action Employer — 50% Recycled/10% Post Consumer Paper

BEFCO, Ir�c,,�¢,- +, T - Page 2
iWW
S. The stormwater program is not being facilitated, and therefore, no feasible
alternatives to the program are being evaluated.
C. There is no BMP summary available within the SP3
D. Employee training for the stormwater program is not documented within the SP3 or elsewhere.
E. The SP3 does not contain a specific list of responsible parties with contact information.
F. There is no evidence that the plan is being reviewed nor updated annually.
I Based on these and other findings during the CEI, the Stormwater Pollution Prevention Plan is
iricomplete, and not considered to be implemented.
3. Analytical monitoring is required semi-annually by the permit. The monitoring is not currently
being conducted and reported as specified in your stormwater permit. Follow Table 2 in your
Stormwater Permit, for analytical monitoring frequency requirements.
4. Qualitative monitoring is also required semi-annually. No records, indicating that monitoring is
being conducted, were produced during the inspection.
5. The Stormwater Discharge Outfall (SDO) was inspected, as was secondary containment. After
some confusion concerning the location and number of SDO(s), the evaluation of the discharge
revealed no odor, nor visual signs of pollution. Clearly designate the SDO on site map and include
the map within the SP3.
If you need assistance with understanding any aspects of your permit, please contact Mr. Parnell at the
phone number listed below. Please be aware that all violations may result in the assessment of civil
penalties in an amount of up to $25,000 per day per violation. Please reply within 30 days of your
receipt of this letter with a narrative and your planned schedule to achieve compliance with all
permit requirements. If you have any questions or comments, please contact Dave Parnell at 919 791-
4200.
Valy,
x/-7LLDannySmRegionalsor
Surface Water Protection Section
Enclosure: November 23, 2009 Compliance Evaluation Inspection
cc:,�RRO/SWP files
Water Quality Central Files

�r
Compliance Inspection Report
Permit: NCG030382 Effective: 11/01/07 Expiration: 10/31/12 Owner: Befco Inc
SOC: Effective: Expiration: Facility: Befco Incorporated
County: Nash 1781 S Wesleyan Blvd
Region: Raleigh
Rocky Mount NC 27802
Contact Person: Matt Hutchison Title: Phone:[phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 11/2312009 Entry Time: 01:30 PM Exit Time: 03:30 PM
Primary Inspector: David R Parnell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG030382 Owner- Facility: Befco Inc
Inspection Date: 11/23/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: NCG030382 Owner - Facility: 8efco Inc
Inspection Date: 11/23/2009 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?
■
❑
❑
❑
# 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)?
■
❑
❑
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping 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: There was no SP3 available during the inspection. A faxed copy was
received by RRO on December 1, 2009. The plan was dated 9.6.06. The following
requirements of the permit are omitted from the SP3: 1. Although the absense of
significant spills was referenced in the 9.6.06 version of the SP3, there was no list of
significant spills within the SP3 or available during the inspection, 2. The stormwater
program is not currently in place, and therefore, no feasible alternatives are being
evaluated, 3. There is no BMP summary available within the SP3, 4. Employee
training for the stormwater program is not documented within the SP3 or elsewhere, 5.
The SP3 does not contain a specific list of responsible parties, 6. There is no evidence
that the plan is being reviewed nor updated annually, 7. Based on these and other
findings during the CEI, the Stormwater Pollution Prevention Plan is incomplete, and
has not been implemented.
Qualitative MonqRE!!j9
Yes
No
NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
❑
■
❑ ❑
Comment: No records of qualitative monitoring for this facility are available during the
inspection.
Analytical Monitoring
Yes
No
NA NE
Has the facility conducted its Analytical monitoring?
OROO
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
❑
■ ❑
Page: 3

Permit: NCG030382 Owner - Facility: Befco Inc
Inspection Date: 11/23/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: There are no recent (since 9.1.06) records available, indicating that this
facility is conducting its analytical monitoring.
Permit and Outfalis Yes No NA NE
# is a copy of the Permit and the Certificate of Coverage available at the site? ■ Cl ❑ ❑
# Were all outfalis 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: There was confusion during the inspection concerning the number of and
location of the SDO(s).
Page: 4

t12/01/2009 11:35 1252977971E BEFC❑ INC PAGE 15
Permit No. NCG030000
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL
RESOURCES -
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
TO DISCHARGE STORMWATER UNDER THE
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, this permit
is hereby issued to all owners or operators, hereafter permittees, which are covered by this permit
as evidenced by receipt of a Certificate of Coverage by the Environmental Management
Commission to allow the.discharge of stormwater to the surface waters of North Carolina or
separate storm sewer systems conveying stormwatcr to surfacd waters in accordance with the
teams and conditions set forth herein.
Coverage under this general permit is applicable to all owners or operators of stormwater point
source discharges associated with activities classified as establishments primarily engaged in the
rolling, drawing, and extruding of nonferrous metals [standard industrial classification (SIC)
335), beat treating of metal (SIC 3398),.fabricating of metal products (SIC 34), manufacturing of
industrial and commercial machinery (SIC 35), manufacturing of electronic equipment (SIC 36),
manufacturing of transportation equipment (SIC 37), and the manufacturing of measuring and
analyzing instruments (SIC 38).
The following activities are specifically excluded fromcoverage under this General Permit: Ship
and boat building and repairing (SIC 373), which is covered by general stormwater permit
NCG 190000.
The General Permit shall become effective on November 1, 2007.
The General Permit shall expire at midnight on October 31, 2012.
Signed this day October 17, 20
Coleen H. Sullins, Director
Division of Water Quality
By the Authority of the Environmental Management Commission

12/01/2009 11:35 12529779718 BEFCO INC PAGE 16
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO, NCG030000
CERTIFICATE OF COVERAGE No. NCO030382
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,
Befco Inc
is hereby authorized to discharge stormwater from a facility located at
Befco Incorporated
1781 S Wesleyan Blvd
Rocky Mount
Nash County
to receiving waters designated as a UT to Little Cokey Swamp, a Class C NSW water in the Tar -Pamlico
River Basin In accordance with the effluent limitations, monitoring requirements, and other conditions set
forth in Parts I, 11, 111, IV, V, and V! of General Permit No. NCGO30000 as attached.
This certificate of coverage shall become effective November 1, 2007.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day November 1, 2007_
for Coleen H, Sullins, Director
aivislon of Water Quality
By Authority of the Environmental Management Commission

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12/01/2009 11:35 12529779718
BEFCO INC
PAGE 02
Dear Mr. ParncIl, December 1, 2009
This package contains the STORMWATE•R POLLUTION PREVENTION PLAN
created by BEFCO, INC. after the response to Mr. Boone's report in 2006. It also
includes test results from sampling done in September 2006. Sampling was done again
in late March 2008, but the containers were found to be contaminated so the testing was
cancelled. Due to the dry summer of 2008, no more samples were taken. Because of Mr.
lohnson's illness and the change m: personnel, no samples were taken in 2009.
As you could see from our tour of the facilities, the only discharge from the property is
rainwater. Our hazardous waste is removed on a regular basis by SAFETY KLEEN, We
can verify this with documents if you deem it necessary. Also, we pay particular
attention to our housekeeping to keep the facility clean and in order. Our everyday waste
is put in a 40' container and is removed on a regular basis by WASTE INDUSTRIES.
Our scrap rectal is stored in a metal container and is removed by ROCKY MOUNT
RECYCLERS,
We are currently in the process of updating our STORM POLLUTION PREVENTION
PLAN. We will be sampling as soon as the weather permits. You will receive the
updated PLAN as soon as we complete it. Please let us know if we can be of any more
assistance.
Sincerely,
Edward A. Vincck
LOO SWPPP contact @ BEFCO, INC.
Edward Vincek
Production Engineer
BEFCO, Inc.
1781 S. Wesleyan Blvd.
P.O. Box 6036
Rocky Mount, NO 27802-6036, USA
Phone:[phone]
Fax:[phone]
Email: edward.vincek®befco.com
wwW.befco,ccm

'� 12I0112009 1:35
BEFCO, I nc.
P.O. Box 6036
Rocky Mount. NC 27602
USA
Fax
12529779718
Tel: [phone]
Fax: [phone]a
www.trefco,corn
To: Mr. Dave Parnell
Fax Na: 919-571-4718
BEFCO INC
Office/Company: NCDENR
PAGE 01
BEFCO
From: Edward Vineek Date', 12/1/2009 —
Number of Pages (irrJuding cover sheet): 19 To contrm receipt, or If you do not receive all pages, please call:
*1-252-977-9920
Comments:
Cortfidentlality Notico: This page and any accompanying d mum" contain confldantial Information intended for a
specific indlvldual and purpose, This telecoVed information is private and protected by Ism If you are not the Intended
reclpiant, you are hereby notified (hat any dlsdorure, copyAg or distribution, or the taking of arty aOon based on the
contents at this inbrmatlon is strio{ly prohiblied.
I—kww

,12/01/2009 11:35 12529779718 BEFCO INC PAGE 03
BEFCO Inc.
STORM WATER PROGRAM!
Issue Date: 09/06/06

12/01/2009 11:35 12529779718 BEFCO INC PAGE 04
Table of Contents
1. STORMWATER POLLUTION PREVENTION PLAN
A. Site Plain
B. Stormwater Management Plan
C. Spill Prevention and Response Plan
D. Preventative Maintenance and Good Housekeeping Program
E. Employee Training
r. , R,66k.,ia161u Paily
G. Plan Amendment
H. Facl% Inspections
I. Implementation

• .12/61I2009 11:35 12529779718
BEFCO INC PAGE 05
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1 112/01/2009 11:35 12529779718 BEFCO INC PAGE 06
7"L I'M

12/01/2009 11:35 12529779710 BEFCD INC PAGE 07
STORAGE PRACTICES"
Only painted goods are stored outside. These items are completely painted as well as
covered with plastic_ Raw goods are stored inside the third warehouse, which prevents
` any stormwater from contacting the raw steel surfaces. '
LOADING AND UNLOADING ACTIVITIES:
All inbound shipments are unloaded through the front dock in the second warehouse.
These consist of approximately 50 Imported containers carrying components to assemble
our equipment None of these items have any potential contaminants that could be
spilled into the bottom of the receiving dock_ We also receive about 12 shipments that
consist of our painting materials. These are unloaded using a dock ramp that Inserts Into
the back of the delivery truck. The drums are shipped on pallets that prevent for the most
part; any punctures that could lead to any spills. The warehouse personnel that have
been properly trained on handling these potentially hazardous materials only complete
these activities.
OUTDOORS PROCESS AREAS:
The are no activities completed outside where any exposure to storm water can occur.
DUST GENERATING EQUIPMENT:
Our raw steel is prepared through a shot blasting method that will emit a dust as the
material is stFipped. This dust Is processed through sixteen filters that capture this dust.
The unit will periodically vibrate the filter storage compartment that will loosen most of the
collected dust and drop it into a collection drum. As the drums are filled they are sent to
an Industrial waste facility (Safety-Kleen) for proper disposal. All other equipment used in
this facility does not produce and measurable dust.
WASTE DISPOSAL_ PROCEDURE:
All of our hazardous and non -hazardous waste is sent to an industrial waste disposal
center (Safely-Kleen) for proper disposal.
All regular produced trash Is placed into a 40' Dumpster that is kept on site at all times
and is carried of to a municipal dump, as the container is full. This service is provided by
Waste industries.

12/01/2009 11:35 12529779718 BEFCO INC PACE 08
Significant Spills:
There have been no significant spills during the last three years,
Certification of 5tormwater Contaminants:
Southern laboratories out of Wilson, NC is certifying our samples and will provide the
requested certification.
5tormwater Management Plan
BEFCO has very little exposure for the potential of polluting the stormwater discharges.
The potential areas of exposure consist of the following: oil leaks from forklifts, oil leaks
from complete equipment gearboxes, spills at receiving or shipping docks.
In an attempt to reduce our exposure to the above -mentioned items we have taken the
following steps.
< All foM-fts are stoned inside out of the elements. They are inspected daily by a
supervisor_ An outside company completes all routine and emergency repairs and or
maintenance.
< All manufactured equipment is processed with environmental hazards in mind. The
gearboxes mounted on our equipment are processed without exposure to the shot
blasting equipment_ This maintains the seals in the up most secure condition.
< All receiving or shipping docks are kept clean to the highest standards. The
stormwater that are received into our docks are from areas off of our property, for
example, Cooley Rd. and Highway 301. This water is removed from the points with the
use of a sump pump. These pumps are activated only after an inspection of the water
has been evaluated by a properly trained individual and the date and time of this
discharge. These pumps can only be activated from inside our facility and are off limits to
all but properly trained individuals. Although we have very little control over what
pollutants are being discharged onto us from off property locations we still maintain these
records in an attempt to be as helpful to maintain a level of environmental safety,
Spill Prevention and Response Plan
In the event of a spill when unloading materials the pumps do not operate automatically.
This would allow proper clean up before operating the pumps again. Our record history
with out a spill helps to assure the successfulness of this program.
Any other spills are cleaned up Immediately by any or all maintenance and warehouse
personnel.
Preventative Maintenance and Good Housekeeping Program
All forklift maintenance is completed by an outside maintenance company. Forklifts are
inspected daily by a supervisor and if any leaks are found the unit will be placed out of
operation until the maintenance company has completed the repair.
Any and all occurrences of discharges of stormwater out of our docks are documented
with the data, time, and authorized employee's name. These records shall be maintained
for five years.
All areas of completed goods storage is inspected periodically each week and any issues
are clean up immediately.
Each of the storage docks is to be kept clean by the department that utilizes the dock.
These areas are to be inspected dally and any debris must be cleaned up Immediately,
Employee Training
All effected personnel will review training of this policy annually. These individuals shall
Include all material handling persons, maintenance employees, and shipping employees.
Responsible Party
Overall coordination, development, implementation, and revision to the plan are the
responsibility of the production manager.

12/01/2809 11:35 1252977971E BEFCO INC PAGE 09
Plan Amendment
Any modifications of this facility would require that the Stormwater Pollution Prevention
Program is re-evaluated and any necessary changes are made.
Facility Inspection
The limited exposure we have makes it easy to complete inspections of stormwater
removal systems on a monthly basis. The inspection will be documented and shall be
performed by the lead maintenance person.
As stated in the Preventative Maintenance and Good Housekeeping Program section of
this document all discharges from our docks will be inspected and documented.
Implementation
All records of maintenance, discharges, and spills will be kept on site and be available for
inspection upon request.
ANALYTICAL MONITORING REQUIREMENTS
Below is a chart that represents the monitoring requirements for each of our three
outfalls.
Outfall #A 'I
Discharge
Characteristics
Units _.
Measurement
frequency
Sample
Type
Lead. Total
mg/I
annually_
grab
standard
;annually
cirab
Oil and Grease
mall
annually
grab
Iota[ SysgendeO Solids
Lng/1
§Onually-grab
Total Rainfall
inches
annually
Event Duration
minutes
annually
Total Flow
MG
_
annually
Outfall # 2
Discharge
Characteristics
Units
Measurement
Freclueno
Sample
Tyse
Lead, Total
m !4 I - _
annually
_ 90111 _
pH
standard
annually _
_
grab
Oil and -Grease
prtga
annual►
grab
Total Suggeo gd Solids
_ _mgll__
_
annually _
rab_
Total Rainfall
aches
_
annuallv_�.
,
Event.0goliont
annuall
Total Flow
MG
annually
Outfall # 3
Discharge
Chem
Wags-
Units
Measurement
Freouency
Sample
Tvp@
Lead,Total
m )l
,
annually---
grab
standard
_
QEab
0 I and Grease-
m /I
_annually
annually
grab
101 usDended Solids
mull
annually
grab
Total Rainfall _ _
inches
_
annually
Eve4uration _
_
___ minutes
annually
Total Flow
MG
annually

12/01/2009 11:35 12529779718 BEFCO INC PAGE 10
QUALITATIVE MONITORING REQUIREMENTS
Discharge
Measurement
Sample
Characteristics _
Fre uency
Description
Color
as discharged
Odor _
as discharged
_
_
Clarity,
as discharged
Floatinci Solids
_
as discharged
Suspended Solids
as discha ed
Foam _
as discharged
Oil Sheen
as discharged
tither pollutions
as discharged
This chart shaff be maintained at each dock and shall be filled out every time any
storrnwater is discharged.

�. r Southern Testing & Research Lubomlories
° A Division of Microbac Laboratories
3BD9 AlrpDrt Drive, Wilson, NC 27896
Phone: [phone] • Fax: [phone]
Webesite: >yww.soulhemiesting-oom
a->VInd Aepori To:
F e�a- _.
CHANT OF CUSTODY Page —of
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& Analyses Request Lab Use Only
r'Rosh APWovcg By: Data/TIrne;
' ►DepR: 1
Contact Person f? CII� ` r kccr_a Tr�pt� } f
�cidress Phone � r! IY Reed on ice Ras.G. /r/ l`
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IJ hri8: it �i. N81s �S, Orher.
' rnpled By. I n f L L ASS Pit ID: Analyses Requested
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tom slCrt End CaTp Grab SU"Ple g95CLlptfanJSarrrple iAarks G � � �f � �j
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DATEME NO
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12/01/2009 11:35 12529779718 BEFCO INC PAGE 12
Microbac Laboratories, Inc.
SOUrYEAN ,1r". -SIING do RESEARCH DIVISION
3909 A1RP0N7'DA1Fr, NW
WILSON, NC 27996-R649
(252) 237-417s (252) a37 9341 (fax)
www.southernt.esting.com
REPORT of ANALYSIS SAMPLE No.: 07161-001 / AA94392
Date Reported' Thursday, September 14, 2006
MATT HUTCHISON
BEFCO
PO BOX 6036 Phone/Fax: [phone]
ROCKY MOUNT NC 27802 P. 0.:
Client Sample Marks. OUTFALL 1
Sample Collection Date: 9/1/2006 11:15:00 AM Matrix: STW
Lab Submittal Date_ 9/1/2006 2:05:00 PM I Classification: E
CAT No.
ANALYSES
METHOD
ANALYZED
by
PQL
RESULT
KNIT
EM-082-L
Lead (ICP)
EPA 200.7
9/612006
GAR
0.010
<0.010
mgfL
EP-001
Digestion (ICPIFAAS)
EPA 200.7
9/1/2006
' Dis
Yes
EW-032-04
Oil and Grease (HEM)
EPA 1664
9/6/2006
JAB
5.0
<5.0
mg/L
EW-034-02
pH (Field)
EPA 150.1
9/1/2006
DLW
7.45
SU
EW-040-01
Solids: Total Suspended
EPA 160.2
915/2006
PEB
5
14
mg/L
EW-052-01
Temperature (Field)
EPA 170.1
911/2006
DLW
22.6
deg C
Sample Comments:
Rey"
e ' and App owed by:
nani-"
Manager, Analytical Sciences Department
Page 1 of 3 Admin 9/14/2006 11:40:05 AM
Wilson Division - NCO0120 Certification; Drinking Water #37708 Wastewater ##21
(-G) Greensboro Division - NCO01754 Certification, Drinking Water ##37795 Wastewater #637
Chemical and Microbiological Analysis: Environmental 0 Agmchemical • Foods 0 Pharmaceuticals

12/01/2009 11:35 1252977971E BEFCO INC PAGE 13
M crobac Laboratories, Inc.
SOUTHERN TESTING & RESE4RCH DIVISION
3809 AIRPORT DRIVE, Nit'
W,r.LSON, NC 27896-8649
(252) 237-d175 [phone](fax)
www.sotdhL-ristestitgg.com
REPORT of ANALYSIS SAMPLE No.: 07161-002 1 AA94393
Date Reported: Thursday, September 14, 2006
MATT HUTCHISON
BEFCO
PO BOX 6036
ROCKY MOUNT NC 27802
Client Sample Marks: OUTFALL 2
Phone / Fax: [phone]
P. 0.:
Sample Collection Date: 91/1/2006 11:34:00 AM } Matrix: STW —
Lab Submittal Date: 911/2006 2:05:00 PM I Classification: E
CAT No.
ANALYSES
METHOD
ANALYZED
by
POL
RESULT
UNIT
EM-082-L
Lead (ICP)
EPA 200.7
9/6/2006
GAR
0.010
<0.010
mg/L
EP-001
Digestion (ICP/FAAS)
EPA 200.7
9/1/2006
DJS
Yes
EW-032-04
OII and Grease (HEM)
EPA 1664
9/6/2006
JAB
5.5
<5.5
mg/L
EW-034-02
pH (Field)
EPA 150A
9/1/2006
DLW
6.96
SU
EVV-040-01
Solids: Total Suspended
EPA 160.2
9/612006
PEB
2
4
mg/L
EW-052-01
Temperature (Field)
EPA 170.1
9/1/2006
DLW
22.9
deg C
Sample Comments:
Minp d Approved by:
nant
Manager, Analytical Sciences Department
Page 2 of 3 Admin 911412006 11:40:05 AM
Wilson Division - N000120 Certification: Drinking Water #37708 Wastewater #21
(-G) Greensboro Division - NCO01754 Certification: Drinking Water #37795 Wastewater #637
Chemical and Microbiological Analysis: Environmental • Agroehernical • Foods • Pharmaceuticals

12/01/2009 11:35 12529779718
BEFCO INC PAGE 14
Afierobac Laboratories, Inc.
SOUTHERN TESTING do RESEARCH DI t7SION
3809 AIRPORT DRiFF., NW
FF7LSON, NC 27896-8649
[phone] [phone](jax)
www.southerniesfing.com
REPORT Of ANALYSIS SAMPLE No.: 07161-003 1 AA94394
Date Reported: Thursday, September 14, 2006
MATT HUTCHISON
BEFCO
PO BOX 6036 Phone/Fax: [phone]
ROCKY MOUNT NC 27802 P. 0.:
Client Sample Marks: OUTFALL 3
Sample Collection Date: 9/1/2006
Lab Submittal Date: 9/1/2006
11:51:00 AM
2:05:00 PM
j Matrix:
I Classification:�
STW
E
CAT No.
ANALYSES'
METHOD ANALYZED
by
PQL
RESULT
UNIT
EM-082-L
Lead (ICP)
EPA 200.7
916/2006
GAR
0.010
90A10
mglh
EP-001
Digestion (1CP/FAAS)
EPA 200.7
9/1/2006
DJS
Yes
EW-032-04
Oil and Grease (TEEM)
EPA 1664
9/6/2006
JAB
5.1
c5.1
mg/L
EW-034-02
pH (Field)
EPA 150.1
9/1/2006
DLW
7.83
SU
EW-040-01
Solids: Total Suspended
EPA 160.2
9/5/2006
PE6
2
29
mg1L
EW-052-01
Temperature (Field)
EPA 170.1
9/112006
DLW
22.1
deg C
Sample Comments:
R� APR ved by:
innank
Manager, Analytical Sciences Department
Page 3 of 3 Admin 9/14/2006 11-40:05 AM
Wilson Division - NCO0120 Certification: Drinking Water #37708 Wastewater #21
(-G) Greensboro Division - NC001754 Certification: Drinking Water #37795 Wastewater #637
Chemical and Microbiological Analysis: lanvirOnmental • Agrochemical - Foods • Pharmaceuticals

r
Driving Directions from 3800 Barrett Dr, Raleigh, NC to 1781 S Wesleyan Blvd, Rocky ... Page 1 of 2
4
MAPQUEST --�
Total Travel Estimates: 58 minutes / 58.80 miles
A: 3800 Barrett Dr, Raleigh, NC 27609-7222
1: Start out going WEST on BARRETT DR toward HAWORTH 0.1 mi
DR.
2: Turn RIGHT onto SIX FORKS RD. 0.4 mi
rf
3: Merge onto 1-440 E.
5.0 mi
fms
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cAS
6 `
Merge onto US-64 E via EXIT 14 toward
4' GREENVILLEIWILSON/ROCKY MOUNT.
47.6 mi
+� 1^
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5: US-64 E becomes US-64 BYP E.
1.0 mi
®
Take the WESLEYAN BLVDIUS-301-BYP exit, EXIT 468A,
6' toward WILSON,
0.3 mi
�'►
a r
3
Turn RIGHT onto N WESLEYAN BLVDIUS-301 BYP S.
7. Continue to follow US-301 BYP S.
4.3 mi
O30
8: Make a U-TURN at PORTER RD onto US-301 BYP N.
0.2 mi
0
9: 1781 S WESLEYAN BLVD.
0.0 mi
B: 1781 S Wesleyan Blvd, Rocky Mount, NC 27803-5629
http:llwww.mapquest.comlmaps? 1 c=Raleigh& i s=NC& l a=3 800+Barrett+Dr& l z=27609-... I 1 /20/2009

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Ju1,14. 2006 11:32AM BEFCO
No - 2 081 P - I
'I i6
DATE: 07/14/06
TO: Mr, Ronald Boone
riamsciviniq and perfarmar= improving eq*ment
'REFCO Pn, - I' 7pi Vqve- hykr. Blvd. W- 27�!
Pb 8ox 6036 , Ao: r; Unor... 4K, 21,18C24h)36
FROM: Matt Hutchison JUL 1 4 2006'
NO. OF PAGES TNCLITDTNG THIS ONE: 1
Dear Mr. Boone,
On the following pages you will find a copy of our response to the NOV that was sent to s dated
06/08/06, Please review and if you have any quations, please let me know.
IF ANY PART OF THIS TRANSMISSION IS POORLY LEGIBLE OR MISSING, PLEASE CALL
IMMEDIATLEY.
Best Regards,
, 24 arz 4*51�
Matt Hutchison
We emphasize customer support in all (mr deparimenki.

Ju 1 -14. 2006 11: HAM BEECO
No, 208} P- 2
Mr. Ronald Boone
NC Division of Water Quality
Storm Water Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: NOV-2006-PC-0187
Befco Inc.
Dear Mr. Ronald Boone,
On June 19, 2006 1 received your NOV dated 06/05/06. We have
reviewed the list of specified deficiencies on page 4 of the NOV. We are
currently elaborating on the copy of the SP3 that was shown to you during your
visit. Below are the responses to the list of deficiencies.
a. Our site plan is being added to our existing SP3 as requested in the
permit and shall be completed within 60 days of the receipt of this
letter.
b. Our stormwater management plan is being expanded as requested in
the permit and shall be completed within 60 days of the receipt of this
letter.
c_ Our spill prevention and response plan (SPRP) is being expanded as
requested in the permit and shall be completed within 60 days of the
receipt of this letter.
d. Our s#ormwater preventative maintenance and good housekeeping
plan is being added to our existing SP3 as requested in the permit and
shall be completed within 60 days of the receipt of this letter.
e. Our stormwater employee -training program is being added to our
existing SP3 as requested in the permit and shall be completed within
60 days of the receipt of this letter.
f. Our update/amendment program is being Implemented as requested in
the permit and shall be completed within 60 days of the receipt of this
letter.
g. Our stormwater facility inspection program Is being implemented as
requested in the permit and shall be completed within 60 days of the
receipt of this letter.
h. Our SP3 is being revised as requested in the permit and shall be
completed within 60 days of the receipt of this letter.
i. Analytical monitoring requirements are being currently fulfilled and will
be included in our final response letter. Our samples are being tested
and certified by a licensed laboratory.
j. A Qualitative monitoring program is being created and implemented as
requested in the permit and shall be completed within 60 days of the
receipt of this letter.

Ju1.14. 2006 11:34AM BEFGO No-M l P. 3
•
The completion of this process may conclude prior to the 60 days stated
above. Some factors for calculating this time line is for example obtaining
results of our samples being tested. Our testing Is being completed by
Southern Testing and Research Laboratories out of Wilson, North
Carolina. As soon as the SP3 is completed and implemented as
requested a copy of necessary documentation will be forwarded.
If you have any further questions, please let me know.
Sincerely,
Matt Hutchison
Production Manager
Befco Inc.

►6
Timesaving and performance improving equipment
BEFCO Inc. • 1781 S.Wesleyan Blvd. • Rocky Mount, NC 27803
P.O. Box 6036 • Rocky Mount, NC 27802-6036
O Telephone [phone] Teletax (252) 977_97.18
N
Mr. Ronald Boone
NC Division of Water Quality
Storm Water Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: NOV-2006-PC-0187
Befco Inc.
1
. ter• , r�
Dear Mr. Ronald Boone,
On June 19, 2006 1 received your NOV dated 06/08/06. We have
reviewed the list of specified deficiencies on page 4 of the NOV. We are
currently elaborating on the copy of the SP3 that was shown to you during your
visit. Below are the responses to the list of deficiencies.
a. Our site plan is being added to our existing SP3 as requested in the
permit and shall be completed within 60 days of the receipt of this
letter.
b. Our stormwater management plan is being expanded as requested in
the permit and shall be completed within 60 days of the receipt of this
letter.
c. Our spill prevention and response plan (SPRP) is being expanded as
requested in the permit and shall be completed within 60 days of the
receipt of this letter.
d. Our stormwater preventative maintenance and good housekeeping
plan is being added to our existing SP3 as requested in the permit and
shall be completed within 60 days of the receipt of this letter.
e. Our stormwater employee -training program is being added to our
existing SP3 as requested in the permit and shall be completed within
60 days of the receipt of this letter.
f. Our update/amendment program is being implemented as requested in
the permit and shall be completed within 60 days of the receipt of this
letter.
g. Our stormwater facility inspection program is being implemented as
requested in the permit and shall be completed within 60 days of the
receipt of this letter.
h. Our SP3 is being revised as requested in the permit and shall be
completed within 60 days of the receipt of this letter.
We ernphasi;e customer- support in all our departments.

Timesaving and performonce improving equipment
BEFCO Inc. • 1781 S.Wesleyan Blvd. • Rocky Mount, NC 27803
P.O. Box 6036 • Rocky Mount, NC 27802-6036
Telephone [phone] • Telefax [phone]
ft
i. Analytical monitoring requirements are being currently fulfilled and will
be included in our final response letter. Our samples are being tested
and certified by a licensed laboratory.
j. A Qualitative monitoring program is being created and implemented as
requested in the permit and shall be completed within 60 days of the
receipt of this letter.
The completion of this process may conclude prior to the 60 days stated
above. Some factors for calculating this time line is for example obtaining
results of our samples being tested. Our testing is being completed by
Southern Testing and Research Laboratories out of Wilson, North
Carolina. As soon as the SP3 is completed and implemented as
requested a copy of necessary documentation will be forwarded.
If you have any further questions, please let me know.
Sincerely,
Matt Hutchison
Production Manager
Befco Inc.
We emphasize customer support in all our departments.

WA r�9Q
6
r
4
Mr. Matthew R. Hutchison
Production Manager
Befco Incorporated
1781 South Wesleyan Blvd
P.O. Box 6036
Rocky Mount, NC 27802-6036
Dear Mr. Hutchison:
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
8 June, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Subject: NOV-2006-PC-0187
Notice of Violation Resulting from Compliance
Evaluation Inspection on 04/18/2006
NPDES Stormwater General Permit NCG030000
Certificate of Coverage NCG030382
Befco Incorporated -Rocky Mount
Nash County
On April 18, 2006, Ronald Boone of the NC Division of Water Quality (DWQ), Raleigh Regional
Office (RRO), conducted a stormwater compliance evaluation inspection (CET) of your Befco
Incorporated facility located at 1781 South Wesleyan Blvd, Rocky Mount, Nash County, NC. Your
assistance and cooperation was very helpful and appreciated. During the inspection the following
items were noted. Please use the permit references cited throughout this report for further details as
needed.
I. INDUSTRY AND SITE DESCRIPTION
A. Befco Incorporated (Befco) assembles and paints landscaping and agricultural equipment at
this facility, placing it under standard industrial classification code (SIC) 34, fabricating of
metal products. Stormwater run-off generated at such facilities is regulated by general
NPDES stormwater permit NCG030000. As such, DWQ has issued Befco certificate of
coverage (COC) NCG030382, which became effective on 1 September 2002 and expires on
31 August 2007.
B. Stormwater generated at the site is collected via a system of in -ground drains and stormwater
ditches that surround most of the property. The drains and ditches convey stormwater to one
outfall located just beyond the fence line on the north side of the main building and storage
yard. Discharged stormwater flows into an unnamed tributary to Little Cokey Swamp, a
Class C, Nutrient Sensitive Water (NSW) in the Tar -Pamlico River Basin.
N'cP'r'thCaro1ina
tmallif
North Carolina Division of Water Quality Raleigh Regional Off -ice Surface Water Protection Phone [phone]
Customer Service
lntemet: h2o.enr.state..nc.us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]-
623-6748
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Befco Incorporated, Compliance Evaluation Inspection, June 8, 2006, NCG030382 Page 2 of 5 14
II. INSPECTION SUMMARY
A. SITEXACILITY
1. The stormwater system and stormwater discharge outfall (SDO) were observed. There
was no visible evidence of spills, overflows or similar incidents in the system. No
significant erosion was found.
2. In general, the site was clean and well maintained. However, areas around the loading
docks and the storage yard on the north side of the facility could be better maintained.
Trash should not be permitted to accumulate in these areas, as it creates pollution,
nuisances and unsanitary conditions.
3. You currently have three loading/unloading docks, one of which is no longer in use.
These docks have historically received a large amount of stormwater run-off from your
own site as well as significant amounts of run-on from neighboring facilities, streets, etc.
As such, you have installed sump pumps in each of the loading docks. These pumps
operate on automatic float switches and pump all accumulated stormwater to nearby
stormwater drainage ditches that ultimately discharge to your SDO.
This practice must be well documented and controlled through your stormwater pollution
prevention plan (SP3) as it presents considerable risk of polluting State waters should
there be any accidental spills of any kind in the loading/unloading dock areas. With the
current configuration, any pollutants that are spilled in the dock areas could easily be
pumped into the stormwater drainage system, and ultimately State waters, before your
personnel could turn the pumps off.
You should consider taking the pumps out of automatic mode, i.e. disconnecting the
electrical supply, during plant operations and especially during loading/unloading
activities. Any stormwater that accumulates in the docks at these times should be
inspected for possible contaminants and then pumped out if found to be uncontaminated.
The pumps and loading/unloading docks should be tightly controlled and management of
the system should be documented, just as drainage procedures for secondary
containments are controlled and documented through the SP3. The only personnel who
should be authorized to operate the pumps and manage the docks are those who are fully
trained through the SP3 and understand the restricted use of the pumps.
4. The storage yard on the north side of the building is used primarily to store finished
products that are crated, wrapped in plastic and waiting to be shipped. Maintaining these
practices and keeping all raw materials, intermediate products, by products and waste
products under shelter will help you meet permit requirements in the future. Should these
practices be altered in any way, other best management practices (BMP) may have to be
implemented to ensure you continue to meet permit requirements.
5. You mentioned during the inspection that your site experiences a great deal of run-on and
run-in during storm events primarily due to the topography of the area and the layout of
the stormwater drainage system. Consequently, this run-on/run-in commingles with run-
off from your site and is then discharged through your SDO. You voiced concern that
you have no control over these waters and therefore should not be held responsible for
their content and effect on receiving waters.

Befco Incorporated, Compliance Evaluation Inspection, June 8, 2006, NCGO30382
Page 3 of 5
You can consult with the NC Department of Transportation (DOT) to propose changes to
the layout of the stormwater system in the area. However, regardless of system
configuration and topography, you are ultimately responsible for all stormwater and
pollutants discharged through your SDO(s). Alternatively, you can build berms to divert
the run-on to a different location and prevent it from entering your property.
If altering the drainage system and/or constructing berms is not possible or feasible, you
can address this situation by sampling all waters that enter your site from neighboring
streets and properties (run-on) at the same time that you sample your own SDO(s) for
annual testing. You can then hold the run-on samples until you receive the results of
your run-off samples. If results of your run-off samples are within permit limits, the run-
on samples can be discarded. If results exceed the limits, you can then have the run-on
samples analyzed to help determine whether the pollutants are coming from your site or
from neighboring streets and/or facilities.
Please note that these samples, depending on the parameter(s) being analyzed, have
limited hold times and must be stored under controlled conditions in order to be valid.
The certified laboratory that you use to analyze these samples will know the specific
holding times and conditions.
Also, alterations to the stormwater drainage system or the construction of berms may
require pre -approval from DWQ. Please consult Part III, Section E, Paragraph 5 of your
permit for specific conditions.
6. Wastes generated at your site include wastewater and paint sludge from a paint
booth/water curtain. Water used for the water curtain is constantly recirculated and very
rarely wasted. When it is wasted, it is discharged into the sanitary sewer. Industrial
waste haulers pick up the sludge from the water curtain and dispose of it properly.
Such industrial wastewater discharges can detrimentally affect the receiving collection
system and/or treatment plant. If not already done, you must contact the city of Rocky
Mount Wastewater Department to notify them of these discharges and any others that
may be classified as industrial discharges.
7. You mentioned during the inspection that you were interested in obtaining a no -exposure
certification (NEC). This is a self -certification process that DWQ will review and
approve or disapprove after receiving the necessary documents from you and performing
a site visit to confirm the conditions of no -exposure. Information is attached that will
help you decide whether you can self -certify.
If you feel you can self -certify, please use EPA Form 3519-11 No Exposure
Certification, which can be accessed on DWQ's website at:
http://h2o.enr.state.nc.us/su/FormsDocuments.htm#stormwaterGP
Please ensure you follow completely all instructions on the form. When complete, mail
the form to:

r
Befco Incorporated, Compliance Evaluation Inspection, June 8, 2006, NCG030382 Page 4 of 5
North Carolina Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh NC 27699-1617
Please be aware that a NEC does not relieve you of any responsibilities regarding
stormwater generated at your site and its effects on receiving streams. Once you self -
certify NEC, you still remain in DWQ's database and are subject to inspections at any
time. You must maintain practices you undertake to self -certify NEC in order to
maintain favorable NEC status.
B. STORMWATER PROGRAM
1. The list below shows numerous conditions observed during inspection of your SP3
a. Your SP3 does not have a site plan as required in Part II, Section A, Paragraph 1 and
subparagraphs.
b. Your SP3 does not have a stormwater management plan as required in Part H,
Section A, Paragraph 2 and subparagraphs.
c. Your SP3 does not have a spill prevention and response plan (SPRP) as required in
Part II, Section A, Paragraph 3.
d. Your SP3 does not have a stormwater preventative maintenance and good
housekeeping plan as required in Part 11, Section A, Paragraph 4.
e. Your SP3 does not have a stormwater employee -training program as required in Part
11, Section A, Paragraph 5.
f. Your SP3 does not have an update/amendment program as required in Part II, Section
A, Paragraph 7.
g. Your SP3 does not have a stormwater facility inspection program as required in Part
H, Section A, Paragraph 8.
h. You have not implemented an effective SP3 as required in Part H, Section A,
Paragraph 8.
L You are not performing analytical monitoring as required in Part H, Section B.
j. You are not performing qualitative monitoring as required in Part H, Section C.
The above -mentioned discrepancies constitute violations of your permit and demonstrate
mismanagement of your stormwater program and/or a misunderstanding of permit requirements.
Please be aware that violations of the conditions of your permit could result in the assessment of civil
penalties in an amount of up to $25,000 per day per violation.
Please reply to this office within 30 days of your receipt of this letter. Please include a narrative that
addresses all deficiencies as well as your planned schedule to achieve compliance with all permit

Befco Incorporated, Compliance Evaluation Inspection, June 8, 2006, NCGO30382
Page 5 of 5
requirements. Please contact Ronald Boone at 919-791-4200, with any questions or comments you
may have regarding the inspection, this letter or the NEC process/procedure,
Sincerel
4
Eric Kulz
Acting Ral
cc: Stormwater Permitting Unit
Central Files
Non -Point Source Compliance Enforcement Unit
(RRO.Eile—s-3
Attachments:
Water Quality Supervisor
1. EPA Fact Sheet 833-F-00-015, Conditional No Exposure Exclusion for Industrial Activity
2. NC Division of Water Quality Guidelines for No Exposure Certification (Draft)
3. Water Compliance Inspection Report

United States Environmental Protection Agency
Form Approved,
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 1 NI 2 IJ 31 NCG030382 ' 11 121 06/04/18 1.17 181 rl 191 cl 201U
J -!
Remarks
211 1 1 1 I 1 I 1 1 1 1 L I I I__L I I I I I I I I__t I I I_[ I I I I I I I I I I I I I I I I. 1 1656
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA -------------- ------------ Reserved-------------
67 I 169 701 1 711 1 721 N 1 73I I 174 .751 1, I I 11 1 180
LTt�
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
02:00 PM 06/04/18
02/09/01
Befco incorporated
Exit Time/Date
Permit Expiration Date
1761 s Wesleyan Blvd
Rocky Mount NC 27802
04:00 PM 06/04/18
07/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
///
Name, Address of Responsible OfficiallTitlelPhone and Fax Number
Contacted
William Scott,1781 9 Wesleyan Blvd Rocky Mount NC 27602//919-977-9920/
0
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Storm Water
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) AgencylOffice/Phone and Fax Numbers Date
Ron 6o RRO WQ//919-791-4200/
0 5 -1y_ 0�
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDE5 yrlmolday Inspection Type
31 NCG030382 11 12` 06/04/18 !17 18`CI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
i
�r•�<�iArF9 f
r
MATTHEW R HUTCHINSON
BEFCO INCORPORATED
1781 S WESLEYAN BOULEVARD
ROCKY MOUNT, NC 27802
Dear Permittee:
Alan W. Klimek, P.E., Director
Division of Water Quality
August 23.2002
Subject: NPDES Stormwater Permit Renewal
BEFCO INCORPORATED
COC Number NCG030392
Nash County
In response to your renewal application for continued coverage under general permit NCG030000, 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 143-215A 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 NCG030000
* A copy of the Analytical Monitoring Form (DMR)
* A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
if you have any questions regarding this permit package please contact 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
Raleigh Regional Office
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

�OF WAYF9Q
�0
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
WILLIAM SCOTI'
BEFCO INCORPORATED
1781 S WESLEYAN BLVD
ROCKY MOUNT, NC 27802
Dear Permittee:
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
December 27, 2001
Subject: NPDES Stormwater Permit Renewal
BEFCO INCORPORATED
COC Number NCG030382
Nash County
Your facility is currently covered Ibr stormwater discharge under General Permit NCG030000. This permit expires
on August 31, 2002. The Division staff is currently in the process of rewriting this permit and is scheduled to have
the permit reissued by late summer ol' 2002. Once the permit is reissued, your facility would be eligible for
continued coverage under the reissued permit.
In order to assure your continued coverage under the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, we are informing you in
advance that your permit will he expiring. Enclosed you will find a General Permit Coverage Renewal
Application Form. The application must be completed and returned by March 4, 2002 in order to assure continued
coverage under the general permit.
Failure to request renewal within this time period may result in a civil assessment of at least $250,00. Larger
penalties may he assessed depending on the delinquency of the request. Discharge of stormwater from your facility
without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to $10,000 per day.
Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial
facilities in any of the I I categories of "storm water discharges associated with industrial activity," (except
construction activities). If you feet your facility can certify a condition of "no exposure", i.e. the facilty industrial
materials and operations are not exposed to stormwater, you can apply for the no exposure cxcltrsion. For additional
information contact the Central Office Stormwater Staff mcmher listed below or check the Stormwater & General
Permits Unit Web Site at http://h2o.enr.state,nc.us/su/stormwater.html
If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed
Rescission Request Form. Mailing instructions are listed on [lie bottom of the form. You will be notified when the
rescission process has been completed.
If you have any questions regarding the permit renewal procedures please contact Joe Albiston of the Raleigh
Regional Office at 919-571-4700 or Bill Mills of the Central Office Stornlwatcr Unit at [phone], ext. 548
Sincerely,
Bradley Bcnnetl, Supervisor
Slormwater and General Permits Unit
cc: Central Files
Raleigh Regional Office
e*�
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-623-7748

St-ac2 of North Carolina
"De"partment 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
William Scott
Befco Inc
1781 S Wesleyan Blvd �, w
RockyMount, NC 27802
cO
cc tiCb
�4 c'
.. c�
Dear William Scott:
March 22, 1996
1••
Ad
ID FE
bject: General Permit No. NCG030000
Befco Inc
COC NCG030382
Nash County
In accordance with your. application for discharge permit received on December, 27, 1995, 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 question concerning this permit, please contact MR. ANTONIO EVANS at telephone
number 919/733-5083. ORIGNAl- SIGNET? BY
BRADLEY BENNE T
Sincerely,
c_c Raleigh_Regional OMECe- '
EPA
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% recydedl 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030 82
SI'ORMWATER 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, is amended,
Befco, Inc.
is hereby authorized to discharge stor rtwater from a facility located at
Befco, Inc.
1781 S. Wesleyan
Rocky Mount, NC
Nash County
to receiving waters designated as an unnamed tributary to little Coley Swamp, Class C NSW in the Catawba River
Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in farts 1, II, 111
and IV of General Permit No. NCG030000 as attached.
"fliis certificate of coverage shall become effective March 22, 1996,
This Certificate of Coverage shall remain in effect for thn dzirAtion of thc-. G,.ncral
Signed this day March 22, 1996.
()PJ 1U— S+GNED BY
BRADLEY BENN-PIT
A. Preston Howard, .lr.. 1'.E., Director
Division of Environmental Management
By Authority 01'the F nvironniental iManagement Commission

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Facility Name: BEFCO INC
Certificate of Coverage Number: NCG030382
Location Address: 1781 S WESLEYAN BLVD
ROCKY MOUNT, NC 27802
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information required by
.the SPPP. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information gathered, is, to the best of my
knowledge and belief, true, accurate, and complete."
"I certify that the SPPP has been developed, signed and retained at the facility location and the SPPP has
been fully implemented at the named facility location in accordance with the terms and conditions of the
storinwater general permit."
"I am aware that there are significant penalties for falsifying information, including the possibility of fines
and imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. Return
within 30 days of receipt if the date on your initial Certificate of Coverage is before
September 1, 1996. If your initial Certificate of Coverage was issued after September
1, 1996, sign and return this certification within 30 days of implementation of your
Stomwater Pollution Prevention Plan. DO NOT SEND THE STORMWATER
POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
(signature)
( %1\�7• Scal� r/L
(print/type name)
(title)
Return To:
Division of Water Quality
Stormwater Group
P.O. Box 29535
Raleigh, NC 27626-0535
SPPP Certification 9/97

STORMWATER POLLUTION PREVENTION PLAN
1. Location map.
2. Raw Goods are unloaded at the front dock from a closed container and stored under cover
in the middle warehouse. Raw goods are transported through the inside door to the 1 st
warehouse where they are painted, assembled, wrapped and crated for shipping. Most
units are stored under cover in the 3rd warehouse until shipment, though some are stored
outside. Shipping is done by either loading flat bed trailer in the rear concrete area or
through the front loading dock into enclosed trailers.
A 40' dumpster is on hand always and carried off to the municipal dump when full. Some
wood and paper products are normally disposed of this way.
Paint is stored in closed 55 gallon drums in a closed 20' container in the back, as is paint
sludge from the paint water curtain until it is carried away to an industrial disposal facility.
3. D= Dumpster
S= Storage area for finished Goods
L= Loading of finished Goods
U= Unloading Dock (Under cover)
4. No spills during the previous 3 years.
No pollutants present
Possible oil leaks from defective seals
Possible oil leaks from defective seals
No pollutants present
5. Certification of Stormwater Dutfalls for the evaluation of presence of
Non-Stormwater Discharges.
STORMWATER MANAGEMENT PLAN
1. Befco has very little exposure for the potential for Polluting Stormwater. The leakage we
have is from forklifts and Finished Goods seals. Preventative steps have been taken to
reduce the temperatures at which the oil seals are subjected to in order to reduce this
failure rate. Forklifts undergo a daily inspection for leaks and are stored inside when not
in use.
2. Not applicable.
3. Not applicable.
4. Not applicable.

0
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BEFCO
Bradlev Bennett
DEHNR
3800 Barrett Dr., Suite 101
Raleigh. NC 27609
Dear Mr. Bennett:
Timesaving and performance improving equipment
BEFCO Inc. • 1781 S. Wesleyan Blvd. e Rocky Mount, NC 27803
P. 0. Box 6036 • Rocky Mount, NC 27802-6036
Telephone [phone] . Telefax [phone]
October 21, 1997
I have just received a visit from Mr. Steve Mitchell of your office. He said I should write _you in regards to
our situation here at BEFCO. He sees no reason for us to monitor. based on the following conditions:
1. We. although fall under the metal fabrication SIC code, do no manufacturing here.
2. We do no parts cleaning. as we use a recycling dry shot blast cleaning system prior to painting.
Our only monitoring point is a collection site which gathers concrete sheet flow from HWY. 301 and two
other smaller roads; and Hines Tractor. Hines Tractor sells and services tractors and many other types of
agricultural products on their facility. There is no way for us to separate our stormwater from these other
sources.
4. BEFCO paints and assembles finished landscaping and agricultural equipment. All our raw materials are
stored inside our enclosed warehouses. Almost everything outside is crated up and covered by plastic
wrap.
5. Our trucks are teased through Ryder and serviced at their facility. Forklifts are also leased through a
forklift company along witlt a Preventative Maintenance Program. Maintenance on the forklifts are
performed by this company. No maintenance is perform by BEFCO.
We are very careful in our housekeeping and take the utmost caution in prey -tinting any type of pollution.
We welcome },our people here at any time to inspect our facility. but feel for us to monitor at a location which we
arc unable to control ghat is washed down front a major highway and a facility which performs tractor
maintenance is unfair and inv results will undoubted be contaminated from these other sources.
I have enclosed a copy of our Stormwater Pollution Prevention Plan for your review and welcome any
comments or suggestions. .
Sincerely.
William F. Scott Jr.
Production Managcr
Eric: Storm Water Pollution Prevention Plan
Development and lmplementaion Certification
We emphasize customer support in all our departments.

OCT-14--1997 13:19 FROM DEM WATER QUALITY SECTION TO RRO P.01i01
-Timesaving and performance improving equipment
M1 y�
BEFCO Inc- e 1781 S. Wesleyan Blvd. Rocky Mount, NC 27803 .
�EF�� TeP. O. Box 6036 • Rocky Mount, NC 27602-6036
lephone {919) 977-9920 + Teletax [phone]
Tony Evans
State of NC Department of Environment,
Health and Natural Resources
_ Divisim.ofWver Qv;.0ity i
P.O. Box 29535
Raleigh, NC 27626-0535
October 9, 1997
Dear Tony,
k
I spoke to Steve Mitchell and would like him to come out to our plant so he. can see if we can N£
exempt from the 05 permit.
It appears to me that it will be very difficult to monitor our output as we get drainage from man)
points which we have no control over, one of which is Hwy, 301
He will be in the area next week, and it would be very convenient for him to stop by.
Thank you,
Sincerely,
William✓)~ . Scott
Production Manager
Post-[Y Fax Note 7671
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OCT 13 1997
POIN7 SOURCE BRANCH a
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We emphasize customer support in all our departments.
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TOTAL P_01
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Timesaving and performance improving equipment
BEFCO Inc. . 1781 S. Wesleyan Blvd. • Rocky Mount, NC 27803
P. C. Box 6036 . Rocky Mount, NC 27802-6036
Telephone [phone] • Telefax [phone]
Tony Evans October 9, 1997
State of NC Department of Environment,
Health and Natural Resources
Division of Water Quality
P.O. Box 29535
Raleigh, NC 27626-0535
Dear Tony,
I spoke to Steve Mitchell and would like him to come out to our plant so he can see if we can be
exempt from the 05 permit.
It appears to me that it will be very difficult to monitor our output 'as we get drainage from many
points which we have no control over, one of which is Hwy. 301.
He will be in the area next week and it would be very convenient for him to stop by.
Thank you,
Sincerely,
r
WillianyF. Scott
Production Manager
We emphasize customer support in all our departments.