NCG210238_COMPLETE FILE - HISTORICAL_20141114

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
DOC TYPE,
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ �b�� �� V
YYYYM M D D

0 ;IWzo
Pat McCrory
Governor
NC®ENR
North Carolina Department of Environment and
November 14, 2014
Natural Resources
John E. Skvarla, III
Secretary
B. Eric Sumner
CT Corporation System, Registered Agent
PalletOne of North Carolina, Inc.
PalletOne of North Carolina, Inc.
010 26rh Street
150 Fayetteville St, Box 1011
Butner, INC 27509
Raleigh, INC 2761
RE:
Request for Remission of Civil Penalty it':>
PalletOne of North Carolina, Inc.
[;
Case No. PC-2014-0011
? (J 1 1 NOW 2U11 it
Granville County
Dear Sirs:
NC DENR Raleigh Regional Office
The Division of Water Quality has received your request for remission of civil penalty dated
October 31, 2014, with accompanying support information. Your request will be presented to
the Director of the Division of Water Quality and you will be notified of the results.
Should you have any questions, please feel free to contact Karen Higgins at [phone] or
me at [phone].
Sincerely,
Niki Maher
401 & Buffer Permitting Unit
cc: Danny Smith / Autumn Romanski— DWQ Raleigh Regional Office
DWR Wetlands Branch- 401 & Buffer Permitting Unit Enforcement File Copy
Howe Q. Wallace, Jr.- PalletOne of North Carolina, Inc., 010 26th Street, Butner, INC 27509
Division of Water Resources - 401 & Buffer Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] \ FAX: [phone]
Internet: www.ncwaterquality.org
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•• FiNCDENR �'� APR 2 1 2015
North Carolina Department of Environment and Natural Resources
Pal McCrory
Governor
CT Corporation System, Registered Agent
PalletOne of North Carolina, Inc.
150 Fayetteville St, Box 1011
Raleigh, NC 27601
B. Eric Sumner
PalletOne of North Carolina, Inc.
10 26" Street
Butner, NC 27509
Subject
Dear Sirs:
NC DENFpobaldlRRvar M� Uaarh
Secretary
April 20, 2015
CERTIFIED MAILRETURN RECEIPT REQUESTED
7003 2260 5380 8115
CERTIFIED MAILRETURN RECEIPT REQUESTED
7003 2260 5380 8108
Request for Remission of Civil Penalty
PalletOne of North Carolina, Inc.
Case No. PC-2014-0011
Granville County
In accordance with North Carolina General Statute 143-215.6A (f) and delegation provided by the
Secretary of the Department of Environment and Natural Resources (DENR) and the Director of the
Division of Water Resources (DWR), I, Jeff Poupart, have considered the information you submitted in
support of your request for remission and did not find grounds to modify the civil penalty assessment.
The civil penalty is therefore a total amount of $22,547.25, which includes $547.25 in investigative
costs.
There are two options available to you:
1) You may pay the penalty.
If you decide to pay the penalty at this stage of the remission process, please make your check
payable to the Department of Environment and Natural Resources (DENR). Send the payment
within thirty (30) calendar days of your receipt of this letter to the following:
If sending via US Postal Service
Karen Higgins
DWR —401 & Buffer Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
ISM
If sending via delivery service (UPS, Fed Ex, etc.)
Karen Higgins
DWR-401 & Buffer Permitting Unit
512 N. Salisbury Street
Raleigh, NC 27604
2) You may decide to have the Environmental Management Commission's Committee on Civil Penalty
Remissions make the final decision on your remission request.
Division of Water Resources - 401 & Buffer Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internal: www,ncwaterquality.org
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®• ®0
PalletOne of North Carolina, Inc.
Case No. PC-2014-0011
Remission Decision
Page 2 of 2
If payment is not received within 30 calendar days from your receipt of this letter, your request for
remission with supporting documents and the recommendation of the Director of the North
Carolina Division of Water Quality will be delivered to the Committee on Civil Penalty Remissions for
final agency decision.
If you or your representative would like to speak before the Committee, you must complete and
return the attached form within thirty (30) calendar days of receipt of this letter. Send the
completed form to:
If sending via US Postal Service
Karen Higgins
DWR —401 & Buffer Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
If sending via delivery service (UPS, Fed Ex, etc.)
Karen Higgins
DWR —401 & Buffer Permitting Unit
512 N. Salisbury Street
Raleigh, NC 27604
The Environmental Management Commission (EMC) Chairman will review the supporting
documents and your request for an oral presentation (if you make the request). If the Chairman
determines that there is a compelling reason to require a presentation, you will be notified of when
and where you should appear. If a presentation is not required, the final decision will be based
upon the written record.
Please be advised that the Environmental Management Commission's (EMC) Committee on Civil
Penalty Remissions will make its remission decision based on the original assessment amount.
Therefore, the EMC may choose to uphold the original penalty amount and offer no remissions,
they may agree with the remission recommendation detailed above, or the penalty amount may
be further remitted.
Thank you for your cooperation in this matter. If you have any questions, please contact Niki Maher at
[phone] or Karen Higgins at [phone].
Sincerely,
Jeff Poupart
Division of Water Resources
Attachments: Remission Factors and Decision
Request for Oral Presentation Form
cc: Danny Smith / Autumn Romanski — DWR Raleigh Regional Office
DWR —401 & Buffer Permitting Unit - File Copy

00
Case Number:
Assessed Entity:
DIVISION OF WATER QUALITY
CIVIL PENALTY REMISSION FACTORS
PC-2014-0011 Region: Raleigh County:
PalletOne of North Carolina, Inc.
Permit:
Granville
❑ (a) Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment
of the petitioner:
® (b) Whether the violator promptly abated continuing environmental damage resulting from the
violation:
The violator believes they responded quickly to the spill & devoted full resources to rectifying the problem
PalletOne caused the spill. They contacted Shamrock jor clean up only after a citizen complaint was received by
local Emergency Management personnel, the pollution had made it 0.5 miles downstream, and DWR staff notified
them of both the spill and extent of the impacts to waters. The spill likely would have been prevented had the
Stormwater Pollution Prevention Plan been fully developed and implemented at the facility by PalletOne as
required by their NPDES Stormwater permit.
[The process water (biocide dip tank water) was initially contained in the secondary containment structure. It
was explained by PalletOne of North Carolina, Inc. that after their staff discovered the overflow, an employee
opened the secondary containment valve allowing the dip tank station water and biocide to be discharged. ]
❑ (c) Whether the violation was inadvertent or a result of an accident:
® (d) Whether the violator had been assessed civil penalties for any previous violations:
The violator has not been assessed civil penalties for any previous violations.
Though the violator has not been assessed civil penalties, a Notice of Violation issued on June 3, 2011 by DWQ
for failure to develop and implement their Stormwater Pollution Prevention Plan (SPPP) which includes
providing training of employees in the proper procedures for secondary containment systems,
documentation of significant spills, and spill response. Had the SPPP been developed and implemented, it
would have likely helped to prevent an employee from releasing biocide from the secondary containment.
❑ (e) Whether payment of the civil penalty will prevent payment for the remaining necessary remedial
actions:
DECISION (Check One)
Request Denied a
Full Remission ❑ Retain Enforcement Costs? Yes ❑ No ❑
Partial Remission❑, $ (Enter Amount)
200r
ff Poupart Date
rev I.0 - 831.09

••
00
STATE OF NORTH CAROLINA
COUNTY OF Granville
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST:
PALLETONE OF NORTH CAROLINA, INC.
ENVIRONMENTAL MANAGEMENT COMMISSION
DWR Case Number PC-2014-0011
REQUEST FOR ORAL PRESENTATION
I hereby request to make an oral presentation before the Environmental Management Commission's Committee On Civil Penalty
Remissions in the matter of the case noted above. In making this request, I assert that I understand all of the following statements:
• This request will be reviewed by the Chairman of the Environmental Management Commission and may be either granted
or denied.
• Making a presentation will require the presence of myself and/or my representative during a Committee meeting held in
Raleigh, North Carolina.
• My presentation will be limited to discussion of issues and information submitted in my original remission request, and
because no factual issues are in dispute, my presentation will be limited to five (5) minutes in length.
The North Carolina State Bar's Authorized Practice of Law Committee has ruled that the appearance in a representative capacity at
quasi-judicial hearings or proceedings is limited to lawyers who are active members of the bar. Proceedings before the Committee
on Remissions are quasi-judicial. You should consider how you intend to present your case to the Committee in light of the State
Bar's opinion and whether anyone will be speaking in a representative capacity for you or a business or governmental entity. If
you or your representative would like to speak before the Committee, you must complete and return this form within thirty (30)
days of receipt of this letter.
Depending on your status as an individual, corporation, partnership or municipality, the State Bar's Opinion affects how you may
proceed with your oral presentation. See www.ncbar.com/ethics, Authorized Practice Advisory Opinion 2006-1 and 2007 Formal
Ethics Opinion 3.
• If you are an individual or business owner and are granted an opportunity to make an oral presentation before the
Committee, then you do not need legal representation before the Committee; however, if you intend on having another
individual speak on your behalf regarding the factual situations, such as an expert, engineer or consultant, then you must
also be present at the meeting in order to avoid violating the State Bar's Opinion on the unauthorized practice of law.
• If you are a corporation, partnership or municipality and are granted an opportunity to make an oral presentation before
the Committee, then your representative must consider the recent State Bar's Opinion and could be considered practicing
law without a license if he or she is not a licensed attorney. Presentation of facts by non -lawyers is permissible.
If you choose to request an oral presentation, please make sure that signatures on the previously submitted Remission Request
form and this Oral Presentation Request form are: 1) for individuals and business owners, your own signature and 2) for
corporations, partnerships and municipalities, signed by individuals who would not violate the State Bar's Opinion on the
unauthorized practice of law.
Also, be advised that the Committee on Civil Penalty Remissions may choose not to proceed with hearing your case if the
Committee is informed that a violation of the State Bar occurs.
This the day of ,20_ SIGNATURE
TITLE (President, Owner,
ADDRES
TELEPHONE

� ' � C' I l � C' c•�
June 26,2014
C G D 2 3 2050 Northpoint Drive • Suite A
Winston-Salem, NC 27106
Phone: [phone]
Fax: [phone]
[e-mail]
www.geotec.com
Mr. Dave Parnell
Division of Energy, Mineral & Land Resources
Raleigh Regional Office
North Carolina Department of Environment and Natural Resources
3800 Barrett Drive
Raleigh, NC 27609
NC DENR Raleigh Regional Office
SUBJECT: NOD-2014-PC-0094 Response; PalletOne-Butner, 10 26" Street, Butner, NC
27509
Dear Mr. Parnell:
Geoscience & Technology, P.A. (GeoSci), on behalf of PalletOne-Butner, is pleased to submit
this response to NOD-2014-PC-0094 postmarked May 31, 2014, hereafter referred to the
"NOD". The NOD was issued following a compliance evaluation inspection of the PalletOne-
Butner facility on April 23, 2014. This document will address the 4 items listed on page 2 of the
NOD.
Item 1
The facility Stormwater Pollution Prevention Plan (SP3) has been updated to include the first
three deficiencies noted in the NOD. Specifically: 1) the list of documented spills has been
updated to include a release from the wood preservative dip tank on February 21, 2014; 2)
annual stormwater and spill prevention employee training was conducted on June 12, 2014 and
was documented in the SP3, and; 3) the SP3 was reviewed and updated with management
approval on June 12, 2014. Please note that some of the SP3 updates are in the publishing stage
and are only in the SP3 as separate pages. This will be completed prior to the end of June 2014.
Item 2
Qualitative monitoring will be performed on a semi-annual basis, concurrent with the collection
of a stormwater sample from the existing outfall. This has not been performed as of the date of
this document as there has been no flow from the outfall since instituting the monitoring plan.
Furthermore, improvements to the sedimentation pond at SDO 001 were completed on June 3-5,
2014 (see Item 4 below) and there has not been a discharge from the pond. Qualitative and
Quantitative monitoring will be performed during the next event in which discharge occurs.

Item 3
Based on our understanding of the conversation between you and Eric Sumner on April 23,
2014, the possible additional outfall referred to is located along the eastern property boundary in
the southeast caner of the facility. There are no stormwater conveyances in this area, the
topography is very flat and there is no clearly defined stormwater outfall. The stormwater flow
from this area is to the northeast and is by sheet flow into a wooded area with no surface water
channels and no discernible. outlet to an existing surface water channel. To designate an SDO in
this area would require construction of stormwater conveyances and a sample point, such as a
detention pond. However, the discharge from any such pond will still be into a wooded,
vegetated area with no existing surface water connection. Therefore, the facility seeks DEMLR's
guidance on this matter as to whether or not the Division is directing the facility to construct and
designate an outfall in this area. Based on current site conditions it is not possible to designate a
specific outfall in this area and, therefore, cannot update the current site map to reflect an
additional outfall at this time.
Item 4
On June 3rd through June 51", McClain's Concrete removed accumulated sediment from the
detention pond, enlarged the pond surface area by almost twice the original size, and constructed
rock-check/filter dams and weirs around the pond to filter sediment from incoming and outgoing
stormwater flows. As a result of this work, the pond has not filled enough for a discharge to
occur. A storm event on the evening of June 251h filled the pond and a discharge is anticipated for
the next storm event. Qualitative and Quantitative monitoring is planned for the next available
discharge.
PalletOne and GeoSci appreciate your time and consideration of this response to NOD-2014-13C-
0053. Should you have questions about the information presented or require additional
information, please contact us at 336.896.1300 or ph(]@geotee.com.
Sincerely,
Geoscience &Technology, P.A.
Peter 1-1. DeVries
Project Geologist
PullelOne-Butner NOD Response .tune 2014
GeoSci Job No. 11.269 2

4
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
April 29, 2014
CERTIFIED MAIL #7012 1640 0001 9605 7829
RETURN RECEIPT REQUESTED
Mr. Eric Sumner, Plant Manager
Pallet One of North Carolina, Inc.
10 26th Street
Butner, NC 27509
Subject: NOTICE OF DEFICIENCY — NOD-2014-PC-0094
Pallet One of North Carolina, Inc. - Butner
NPDES STORMWATER PERMIT NCG210238
Granville County
Dear Mr. Sumner:
On April 23, 2014, Dave Parnell, of the Raleigh Regional Office of the North Carolina Division
of Energy, Mineral and Land Resources (DEMLR), conducted a compliance evaluation
inspection (CEI) at the above referenced facility. The site lies in the watershed of an unnamed
tributary (UT) to Picture Creek, Class WS-V, NSW waters, which lies in the Neuse River Basin.
The following observations were noted during the NCG210238 DEMLR inspection:
This facility is a pallet production facility, which stores and ships constructed and treated
pallets. Thank you for your assistance, and the assistance of Lauri Long, during the
inspection, it was appreciated. The inspection began in the conference room, where a
thorough review of the Stormwater Pollution Prevention Plan (SPPP); as well as, the
qualitative and analytical monitoring results, was conducted. Following the monitoring data
review, the Stormwater Discharge Outfall (SDO) was visited. Approximately one-half of the
site flows to the one outfall at the northern corner of the property. The drainage from other
half of the site is shown on the site plan as sheet -flow.
Division of Energy, Mineral, and Land Resources
Energy Section • Geological Survey Section • Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-9200 / FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: hfto://portal.ncdenr.org/web/Ir/
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The following deficiencies discovered during the inspection require your attention:
1. The SPPP requires that your facility include a documented list of significant spills during
the past three years.
2. The SPPP requires that your facility provide and document stormwater and spill
prevention training to employees, annually.
3. The SPPP is required to be reviewed and updated annually.
4. Qualitative Monitoring is not being conducted.
5. As we discussed, there appears to be a necessity for additional SDO in order to capture the
entire production and storage area of the site. Your consultant could assist you with these
issues in your SPPP and monitoring requirements.
6. The existing stormwater pond at the SDO appears to be undersized for the drainage area it
serves.
Requested Response: You are directed to respond to this letter in writing to DEMLR at the
address provided below within 30 days of receipt of this letter addressing the following:.
1. Update the SPPP to include the above items 1, 2 and 3.
2. Institute Qualitative Monitoring. Forward the current sample period results or a proposed
schedule for the sample period monitoring.
3. Provide an updated site map which will include additional Stormwater Discharge Outfalls
(SDO).
4. Maintain the existing stormwater pond at the SOO to allow more storage capacity.
Submit items listed above to:
Dave Parnell
DEMLR Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 2760

This office requires that the violations, as described above, be properly resolved by the
timeline listed. Should you have any questions regarding these matters, please contact Dave
Parnell at [phone].
Sincerely,
VL. Holley, Jr., PErCPESC
al Engineer
Raleigh Regional Office
cc: Stormwater Permitting Program Files - with attachment
DEMLR Raleigh Regional Office Files - with attachment

Permit: NCG210238
SOC:
County: Granville
Region: Raleigh
Compliance Inspection Report
Effective: 08/01/13 Expiration: 07/31/18 Owner: Pallet One of NC Inc
Effective: Expiration: Facility: Pallet One of NC Inc
10 26th St
Contact Person: Gerald Oakley
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/23/2014
Primary Inspector: David R Parnell
Secondary Inspector(s):
Butner NC 27509
Title: Phone: [phone]
Ext.121
Certification: Phone:
Entry Time: 01:30 PM Exit Time: 03:00 PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Timber Products Stormwater Discharge COC
Facility Status: ❑ Compliant M Not Compliant
Question Areas:
Stonn Water
(See attachment summary)
Page: 1

Permit: NCG210238 Owner • Facility: Pallet One of NC Inc
Inspection Date: 04/23/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page:2

Permit: NCG210238 Owner - Facility: Pallet One of NC Inc
Inspection Date: 0412312014 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?
❑
■
❑ ❑
# 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: Discussed the need for a 3 year list of spills, documentation of employee
training and updating of the SPPP annually.
Qualitative Monitoring
Yea
No
NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
❑
■
❑ ❑
Comment: not being conducted - must begin doing this.
Analytical Monitoring
Yes
No
NA NE
Has the facility conducted its Analytical monitoring?
■
❑
❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■
❑
❑ ❑
Comment:
Permit and Outfalls
Yes
No
NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
0011
❑
If Were all outfalls observed during the inspection?
■
❑
,.
❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division?
❑
❑
■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges?
■
❑
❑ ❑
Page: 3

Permll: NCG210238 Owner -Facility: Pallet One of NC Inc
Inspection Date: 04/23/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Asked the facility to ask their facility to evaluate for additional outfalls.
Currently sampling for one, assuming sheetflow for the remainder of the site.
Page: 4

Pat McCrory
Governor
ARA
A&ENR
North Carolina Department of Environment and Natural Resources
April 29, 2014
CERTIFIED MAIL #7012 1640 0001 9605 7829
RETURN RECEIPT REQUESTED
Mr. Eric Sumner, Plant Manager
Pallet One of North Carolina, Inc.
10 26th Street
Butner, NC 27509
Dear Mr. Sumner:
John E. Skvarla, III
Secretary
Subject: NOTICE OF DEFICIENCY — NOD-2014-PC-0094
Pallet One of North Carolina, Inc. - Butner
NPDES STORMWATER PERMIT NCG210238
Granville County
On April 23, 2014, Dave Parnell, of the Raleigh Regional Office of the North Carolina Division
of Energy, Mineral and Land Resources (DEMLR), conducted a compliance evaluation
inspection (CEI) at the above referenced facility. The site lies in the watershed of an unnamed
tributary (UT) to Picture Creek, Class WS-V, NSW waters, which lies in the Neuse River Basin.
The following observations were noted during the NCG210238 DEMLR inspection,
This facility is a pallet production facility, which stores and ships constructed and treated
pallets. Thank you for your assistance, and the assistance of Lauri Long, during the
inspection, it was appreciated. The inspection began in the conference room, where a
thorough review of the Stormwater Pollution Prevention Plan (SPPP); as well as, the
qualitative and analytical monitoring results, was conducted. Following the monitoring data
review, the Stormwater Discharge Outfall (SDO) was visited. Approximately one-half of the
site flows to the one outfall at the northern corner of the property. The drainage from other
half of the site is shown on the site plan as sheet -flow.
Division of Energy, Mineral, and Land Resources
Energy Section • Geological Survey Section • Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919.707-9200 / FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: http://Dortal.ncdenr.org/webAr/
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U.S. Postal Service.,
CERTIFEED6M�11L.M RECEIPT
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Insurance Coverage Provided)
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F C A LEr U:�L
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r=I Ratum Receipt Fee Postmark
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(Endorsement Required)
S Total; At R. I?RIC SUMNER, I'L'r. NI(i R,
..D PALLEI ONE OF NORTH CAROL NA, INCrq .
Sent To
102e^'STREET
I'Ll BU"fNLIi, NC 27509
rR-S`ireeE: LQ-NOD-J1,11-GRANV-2014-PC-0094
0 or POI REC: 7012 1640 0001 9605 7829 N1 5/12/14---------
1` Clry Si
■ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery Is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
m Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
N1R. EIGC SUNINER, PLT. NIGR.
PALLET ONE OF NOR] li CAROLINA, INC.
In2611'$'IREET
BN I'NER, NC. 17509
LQ-NOD-I LlI-GRAN V-2014-PC-0094
Rf?C: 7012 1640 0001 9605 782.9
A. Signature
X ❑ Agen
R ❑ Addm
B. Rece1.'ved by n ted ame) C. Date of De
l',1n ( IDI
D. Is delivery edd(ss different from hem 1? ❑ Yes
If YES, enter delivery address below: Cl No
3. Service Type
❑ Certified Mail
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❑ Return Receipt for Merchandise
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4. Restricted Delivery? (Extra Fee) ❑ Yes
2. Article Number — - — - — - -- - — -- -
(rransferfrom service /abeo 7 012 1640 0 001 9605 7 8 2 9
PS Form 3811, February 2004 Domestic Return Receipt 1025e5-02-M-154o i
L=

the following deficiencies discovered during the inspection require your attention:
1. The SPPP requires that your facility include a documented list of significant spills during
the past three years.
2. The SPPP requires that your facility provide and document stormwater and spill
prevention training to employees, annually.
3. The SPPP is required to be reviewed and updated annually.
4. Qualitative Monitoring is not being conducted.
S. As we discussed, there appears to be a necessity for additional SDO in order to capture the
entire production and storage area of the site. Your consultant could assist you with these
issues in your SPPP and monitoring requirements.
6. The existing stormwater pond at the SDO appears to be undersized for the drainage area it
serves.
Requested Response: You are directed to respond to this letter in writing to LIEMLR at the
address provided below within 30 days of receipt of this letter addressing the following:.
1. Update the SPPP to include the above items 1, 2 and 3.
2. Institute Qualitative Monitoring. Forward the current sample period results or a proposed
schedule for the sample period monitoring.
3. Provide an updated site map which will include additional Stormwater Discharge Outfalls
(SDO).
4. Maintain the existing stormwater pond at the SDO to allow more storage capacity.
Submit items listed above to:
Dave Parnell
DEMLR Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 2760

This office requires that the violations, as described above, be properly resolved by the
timeline listed. Should you have any questions regarding these matters, please contact Dave
Parnell at [phone].
Sincerely,
Raleigh Regional Office
cc: Stormwater Permitting Program Files - with attachment
DEMLR Raleigh Regional Office Files - with attachment

Compliance Inspection Report
Permit: NCG210238 Effective: 08/01/13 Expiration: 07/31/18 Owner: Pallet One of NC Inc
SOC: Effective: Expiration: Facility: Pallet One of NC Inc
County: Granville 10 26th St
Region: Raleigh .
Butner NC 27509
Contact Person: Gerald Oakley Title: Phone: [phone]
Ext.121
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/23/2014
Primary Inspector: David R Parnell
Secondary Inspector(s):
Certification:
Entry Time: 01:30 PM Exit Time: 03:00 PM
Phone:
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Timber Products Stormwater Discharge COC
Facility Status: I] Compliant 0 Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

1
Permit: NCG210238 Owner - Facility: Pallet One of NC Inc -
Inspection Date: 04/2312014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: NCG210238 Owner - Facillty: Pallet One of NC Inc
Inspection Date: 04/23/2014 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?
❑
■
❑ ❑
# 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: Discussed the need for a 3 year list of spills, documentation of employee
training and updating of the SPPP annually.
Qualitative Monitoring
Yes No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
❑ ■
❑
❑
Comment: not being conducted - must begin doing this.
Analytical Monitoring
Yes No
NA
NE
Has the facility conducted its Analytical monitoring?
■ ❑
❑
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
NOO
❑
Comment:
Permit and Outfalls
Yes No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ■ ❑ ❑
# Were all outfalls observed during the inspection? ■ ❑ ❑ ❑
L.
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ® ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑
Page: 3

Penult: NCG210238 Owner -Facility: Pallet One of NC Inc
Inspection Date: 04/23/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Asked the facility to ask their facility to evaluate for additional outfalls.
Currently sampling for one, assuming sheetflow for the remainder of the site.
Page: 4

June 28, 2011
Reference: Case No. NOV-2011-PC-0333
Dear Mr. Zhang and Mr. Smith
o c"PalletOne
PalletOne of North Carolina, Inc.
010 26". Street
Butner, N. , C. 27509
Tel [phone]
Fax [phone]
U UEcr,-j EC'O
JUN 2 9 2011
galstp0;P91nnR
This letter is to notify you that I have received the notice of violation and stormwater
compliance evaluation inspection that you sent out.
A site audit took place at our facility on June 10, 2011 by GeoScience and
Technology out of Winston Salem, NC. We are using this firm to help us develop our
SPPP.
As we get the completed, I will send a copy to you all and a letter showing that we
have become compliant.
I thank you for your time, help and patience with us on this matter.
Sincerely,
Danny Brooks
General Manager
PalletOne - Butner

North Carolina
Beverly Eaves Perdue
Governor
NCDENR
Department of Environment and
Division of Water Quality
Coleen H. Sullins
Director
June 3, 2011
CERTIFIED MAIL 70081300000011314702
RETURN RECEIPT REQUESTED
Mr. Danny Brooks
Pallet One of NC Inc.
10 26th Street
Butner, NC 27509
Natural Resources
Subject: Notice of Violation and Stormwater Compliance Evaluation Inspection
Case No. NOV-2011-PC-0233 0333
Certificate of Coverage No. NCG210238
Pallet One of NC Inc.
Granville County
Dear Mr. Brooks:
Dee Freeman
Secretary
On May 25, 2011, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Stormwater
Compliance Evaluation Inspection at Pallet One of NC Inc. Your assistance was greatly
appreciated. The inspection report is attached. Findings during the inspection were as follows:
Certificate of Coverage (COC) No. NCG210238 of NPDES general permit
NCG210000 was issued to Pallet One of NC Inc., to discharge stormwater runoff to
an unnamed tributary to Picture Creek, a class WS-IV NSW stream, in the Neuse
River Basin.
2. Pallet One NC Inc. was found to have violated Part 1l Section A of the General
Permit for failure to develop and implement a Stormwater Pollution Prevention
Plan (SPPP). The facility must develop a SPPP within 90 days of receipt of this
notice. It was noted that the facility had hired a consultant to develop the plan.
Since the beginning of 2009, the facility had conducted qualitative and analytical
monitoring semi-annually at the only stormwater discharge outfall (SDO). The
monitoring reports were reviewed during the inspection. All analytical parameters
were below (or within the range of) benchmarks with an exception of one TSS
exceeding in May 2009.
4. The secondary containment for the two I0,000-gallon diesel tanks was adequate.
Vehicle maintenance was conducted in the workshop; used motor oil was stored in
drums with adequate secondary containment.
North Carolina Division of Water Qua Itry 1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone] Customer Service
Internet: w vw.newaterquality org Location: 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]-R77-623-6748
An Equal Opportunity/A(firmaove Action Employer- 50% Recycled/10% Post Consumer Paper

Palled Oneuof.NC.Inc.�
Per
nut No. NCG210238'
Compliance Evaluation Inspection
mwv arnmwmecm.Nw.u*+�
The SDO was observed during the inspection, it was well maintained and in good
condition.
Please address Item 2 above and respond in writing to RRO within 30 days of receipt of
this letter. If you have any questions regarding the attached report or any of the findings, please
contact Cheng Zhang at 919-791-4200 (or email: [e-mail]).
Sincerely
S. Daniel Smith, Supervisor
Surface Water Protection
Raleigh Regional Office
Enclosure: Compliance Evaluation Inspection Form
cc: Central Files
CRRO S W P files,

Permit: NCG210238
SOC:
County: Granville
Region: Raleigh
Compliance Inspection Report.
Effective: 08/O1/08 Expiration: 07/31/13 Owner: Pallet One of NC Inc
Effective: Expiration: Facility: Pallet One of NC Inc
10 26th St
Contact Person: Gerald Oakley
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Represer ive(s):
Related Permits:
Inspection Date: 05125/2011
Primary Inspector: Chang Zhang
Secondary Inspector(s):
Title:
Entry Time: 01:00 PM
Butner NC 27509
Phone: [phone]
Ext.121
Certification:
Exit Time: 03:00 PM
Phone:
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Timber Products Stormwater Discharge CDC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
M Storm Water
(See attachment summary)
Page:1

Permit: NCG210238 Owner- Facility: Pallet One of NC Inc
Inspection Date: 05/25/2011 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?
❑ ■ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ ■ ❑ ❑
# Does the facility provide all necessary secondary containment?
■ ❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ■ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
Cl ■ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ■ ❑ ❑
# Does the facility provide and document Employee Training?
❑ ■ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
❑ ■ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ■ ❑ 0
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ■ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ■ ❑ ❑
Comment: The facility has not developed and implemented a SPPP. A consultant will
be hired to develop the plan,
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■ ❑ ❑ ❑
Comment:
Analytical Monitoring
Yes No NA NE
Has the facility conducted its Analytical monitoring?
■ ❑ 110
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑ ❑ ■ ❑
Comment: Vehicle maintenance was conducted in the shop, used motor oil was
stored in drums with adequate secondary containment.
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■ ❑ ❑ ❑
# Were all outfalls observed during the inspection?
■ ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division?
❑ ❑ ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges?
❑ ■ ❑ ❑
Page:3

Permit: NCG210238 Owner- Facility: Pallet One of NC Inc
Inspection Date: 05/25/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Non stormwater will be evaluated when the SPPP is developed.
Page: 4

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 3. 2011
CERTIFIED MAIL 70081300000011314702
RETURN RECEIPT REQUESTED
Mr. Danny Brooks
Pallet One of NC Inc.
10 26lh Street
Butner, NC 27509
Subject: Notice of Violation and Stormwater Compliance Evaluation Inspection
Case No. NOV-2011-PC-0333
Certificate of Coverage No. NCG210238
Pallet One of NC Inc.
Granville County
Dear Mr. Brooks:
On May 25, 2011, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Stormwater
Compliance Evaluation Inspection at Pallet One of NC Inc. Your assistance Was greatly
appreciated. The inspection report is attached. Findings during the inspection were as follows:
Certificate of Coverage (COC) No. NCG210238 of NPDES general permit
NCG210000 was issued to Pallet One of NC Inc., to discharge stormwater runoff to
an unnamed tributary to Picture Creek, a class WS-IV NSW stream, in the Neuse
River Basin.
2. Pallet One NC Inc. was found to have violated Part II Section A of the General
Permit for failure to develop and implement a Stormwater Pollution Prevention
Plan (SPPP). The facility must develop a SPPP within 90 days of receipt of this
notice. It was noted that the facility had hired a consultant to develop the plan.
Since the beginning of 2009, the facility had conducted qualitative and analytical
monitoring semi-annually at the only stonmwater discharge outfall (SDO). The
monitoring reports were reviewed during the inspection. All analytical parameters
were below (or within the range of) benchmarks with an exception of one TSS
exceeding in May 2009.
4. The secondary containment for the two I0,000-gallon diesel tanks was adequate.
Vehicle maintenance was conducted in the workshop; used motor oil was stored in
drums with adequate secondary containment.
North Carolina Division of Water Quality 1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone] Customer Service
Internet: w wncwaterquality.org Location: 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affor alive Action Employer- 50% Recycled/l 0% Post Consumer Paper

Pallet One oMC Inc.
Permit No. NCG210238
Compliance Evaluation Inspection
5. The SDO was observed during the inspection, it was well maintained and in good
condition.
Please address Item 2 above and respond in writing to RRO within 30 days of receipt of
this letter. If you have any questions regarding the attached report or any of the findings, please
contact Cheng Zhang at 919-791-4200 (or email: [e-mail]).
Sincerely,
S. Daniel Smith, Supervisor
Surface Water Protection
Raleigh Regional Office
Enclosure: Compliance Evaluation Inspection Form
cc: Central Piles
RRO SWP files

Permit: NCG210238 Owner- Facility: Pallet One of NC Inc
Inspection Date: 05/25/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Non stormwater will be evaluated when the SPPP is developed.
Page:4

Zhang, Cheng
From: Danny Brooks [[e-mail]]
Sent: Tuesday, August 30, 2011 5:46 AM
To: Zhang,Cheng
Subject: SP3 - PalletOne Butner, NC
Cheng,
We are now compliant with all parts of the Storm water program. Our Storm Water Prevention and Pollution Plan is in
place.
Regards,
Danny Brooks
PalletOne-Butner

4'
-LX� f�
(.1. J
-LLP ECS CAROLINAS, LLP "Setting the Standard for Service"
Geotechnlcal • Construction Materials •Environmental •Facilities NC Registered Engineering ro-m F-107e
April 4, 2011
Mr. Larry Draughn
Regional Manager
PalletOne
165 Turkey Foot Road
Mocksville, NC 27028-5930
Reference: Proposal for Limited Environmental Compliance Audit
PalletOne
Newton, North Carolina; Mocksville, North Carolina; Siler City, North
Carolina; Butner, North Carolina; and Chase City, Virginia
ECS Proposal No. 09-17554-P
Dear Mr. Draughn
ECS Carolinas LLP (ECS) is pleased to submit this proposal for conducting limited
environmental compliance audits of PalietOne facilities located in North Carolina and
Virginia. Included in this proposal is a summary of our understanding of the project
information, proposed scope of services, fees, schedule, and authorization.
PROJECT INFORMATION
PalletOne manufactures new pallets, recycles pallets and produces mulch.
Manufacturing locations include Newton, North Carolina; Mocksville, North Carolina;
Siler City, North Carolina; Butner, North Carolina; and Chase City, Virginia. Each facility
has environmental permits and is subject to environmental programs requiring
compliance activities. PalletOne has elected to have each facility evaluated for
environmental compliance.
PROPOSED SCOPE OF SERVICES
This limited environmental compliance audit will evaluate facility operations, records and
reporting with respect to environmental permits and programs. The objective of the
limited environmental compliance assessment is to identify areas of non-compliance or
concern and suggest improvements to the existing programs. Where appropriate, the
assessment will include a site inspection and record review. To efficiently use our time
during the site visit, we will review relevant permits and plans (e.g., wastewater,
stormwater, air, spill prevention, etc) prior to the site visit.
The environmental compliance audit has been limited in scope to one -day site visits at
each facility. The environmental programs of concern- are expected to be air,
4811 Koger Boulevard • Greensboro, NC 27407 • T: 336-856-7150 • F: 336-856-7160 www.ecslirnited.com
ECS Carolinas, LLP • ECS Florida, LLC ECS Mid -Atlantic, LLC • ECS Southeast, LLC ECS Texas, LLP

PalletOne
ECS Proposal No. 09-17554
April4, 2011
wastewater, stormwater and spill prevention. Other identified areas may be assessed if
there is sufficient time during the site visit.
The environmental audit process will include the following activities
1. Audit Preparation
Prior to beginning the audit, preparation is necessary to ensure that the audit is
conducted in an efficient manner. Prior preparation will consist of ECS' review of
documents provided by PalletOne. These documents may include permits (e.g., air,
wastewater, stormwater); Plans (e.g., Spill Prevention Control and Countermeasure
(SPCC), and Stormwater Pollution Prevention Plans (SPPP)); monitoring data (e.g.,
wastewater, stormwater, etc.) and reports submitted to the State.
2. Site Visit
We will visit areas of the facility necessary to assess compliance with permit and plan
requirements and conditions. We will review documents that were not available during
audit preparation. This may include wastewater monitoring reports; air permit
compliance reports; SPCC inspection logs; and training records for SPCC and SPPP.
For the purposes of providing project costs, each facility site visit has been limited to one
day.
3. Audit Report
We will prepare a'letter report for each facility documenting our findings. Program
deficiencies and areas of concern will be identified. As necessary, applicable regulations
will be researched to determine specific remedial actions that may be required including
permitting, operating practices, training, reporting, etc.
FEE ESTIMATE
The time to complete the audit process will depend on the number of areas requiring
physical inspection and the quantity of documents requiring review. This time can only
be accurately determined during the auditing process. We have, therefore, provided a
range for the expected fees. Fees will be invoiced on a time and materials basis in
accordance with the attached Fee Schedule
Both the minimum estimate and not to exceed estimates provide for one -day site visits at
each facility. Additional time spent at a facility is not included in the maximum not to
exceed fee and will be invoiced in accordance with the attached Fee Schedule.
Fees for each facility are estimated as follows. Based on travel time costs, fees are
somewhat less for facilities located closer to our offices.
Newton, North Carolina ...................................... $2,100 to $2,900
Mocksville, North Carolina .................................. $1,900 to $2,700

PatletOns
ECS Proposal No. 09-17554
April4, 2011
Slier City, North Carolina .................................... $1,900 to $2,700
Butner, North Carolina ....................................... $,1900 to $2,700
Chase City, Virginia .......................................... $2,100 to $2,900
SCHEDULE
Based on our current schedule, we can begin audit preparation within one to two weeks
of receiving your written authorization to proceed. Reports will be provided within one to
two weeks of each site visit.
CLOSURE
This letter is the agreement for our services. Your acceptance of this proposal may by
indicated by signing and returning one of the duplicates to us. Please note that attached
to this letter, and an integral part of our proposal, are our "General Conditions of
Service."
We are pleased to have the opportunity to offer our services and look forward to working
with you on this project. If you have any questions or comments concerning the contents
of the enclosed documents or other related topics, please do not hesitate to contact us
at [phone] or [phone].
Respectfully submitted,
ECS Carolinas, LLP
61 lw-k�lac
Miriam S. White, P.E.
Senior Environmental Engineer
Denise Poulos, LSS, PWS
Environmental Department Manager
Enclosures: Fee Schedule
Proposal Acceptance Sheet
Terms and Conditions of Service

PalletOne
ECS Proposal No. 09-17554
April 4, 2011
PROPOSAL ACCEPTANCE
Client Signature:
Printed Name:
Title/Firm:
Date of Acceptance:
Please complete and return this page to ECS to indicate acceptance of this proposal and
to initiate work on the above -referenced project. The Client's signature above also
indicates that he/she has read or has had the opportunity to read the accompanying
Terms and Conditions of Service and agrees to be bound by such Terms and Conditions
of Service.
BILLING INFORMATION
(Please Print or Type)
Party Responsible for Payment:
Name of Contact Person/Title:
Billing Address:
Telephone Number:
Email Address:
Fax Number:
Client Project/Account Number:
Special Conditions for Invoice:
Site Owners Name & Telephone #:
Site Access Name & Telephone #:

PalletOne
ECS Proposal No. 09-17554
April 4, 2011
ECS Carolinas, LLP
Greensboro, North Carolina
2011 Environmental Services -Fee Schedule
PROFESSIONAL SERVICES
RATEIHOUR
Principal Engineer/Scientist
$ 130.00
Senior Engineer/Scientist
$ 110.00
Project Engineer/Scientist
$ 80.00
Staff Engineer/Scientist
$ 75.00
Environmental Technician
$ 55.00
Draftsman
$ 50.00
CAD Operator
$ 50.00
Word Processor
$ 40.00
EXPENSES
Direct Expenses, Supplies
COST + 15%
Express Mail (for lab samples only)
Mileage (per mile)
COST + 15%
$ 0.60
SUBCONTRACTOR CHARGES
Drilling
COST +
15%
Laboratory Analyses
COST + 15%
Tank Removals
COST + 15%
Pumping & Disposal of Tank Contents
COST + 15%
Excavation/Transportation of Contaminated Soil
COST + 15%
Free Product Recovery (from open tank excavation, emergency response)—
COST + 15%
Construction/Materials/Maintenance of Remediation System
COST + 15%
Treatment/Disposal of Contaminated Soil
COST + 15%
Construction Equipment
COST + 15%
Asbestos/Lead Air Monitoring
COST + 15%
Asbestos/Lead Bulk Samples
COST + 15%
FIELD EQUIPMENT
/DAY
Lead XRF Analyzer
$ 100.00
Well sampling equipment per well
$ 15.00
Explosimeter, per day
$ 50.00
Flame ionization Detector (OVA); per day
$ 75.00
Photoionization Detector (PID); per day
$ 75.00
Water Level Meter; per day
$ 50.00
Oil/Water Interface Probe; per day
$ 50.00
2-inch Variable Speed Groundwater pump
$ 100.00
Hermit Data Logger (2 probe)
$ 150.00
Electric Generator; per day
$ 50.00
Steam Cleaner Rental; per day
COST+ 15%
Field Monitoring Equipment
COST+ 15%
HEALTH & SAFETY EQUIPMENT
/DAY
Level "D" Equipment; per man day
$ 20.00
Level "C" Equipment; per man day
$ 75.00
SCBA: per man day
COST + 17%
Half Face Respirators
COST+ 15%
Individual Hygiene Sampling Pump; per day
$ 25.00

PalletOne
ECS Proposal No. 09-17554
April4, 2011
ECS C.I.. I1Y
TERMS AND CONDITIONS OF SERVICE
Theo Tetras and Ciottido. of Smicc. including "n,pplunems not may be agreed m, aloep with the emempanvwg Scope of Smarts" professional Ines mmfume the ¢tux Agreement
AGREEMENT') mderwhich Services are to he provided by ECS Cantle., LLP CECS " I fmcli ding a mtpldyres. efficmt suce.sori and mimm) for Client ("CLIENT I lindudo, ha
employs, officer, sucoeuon a assigns).
1,4DEPENDECrLC9Ni'SULTANT STATUS
E.c,l an ay be mherww pored himem. ECS shall ame w m indryadeot pmfnsmml comuhmt to Q1ENI' and Wall than control over and responsibility fiR, the means a methods for
,ol the Smica under that AGREEMENT, including the rnention of Subcontractors a Subconsulteor. Unless expressly stated in ECS' Scope of Snvie.. ECS Wall ism sane no
CLIENI's agent err rcpre eranwe.
S('OPF. OF SERVICES
h o Understood that the Scope of Smica. Profammil Fee, and time schedule def Ind in We Scope of Si ere based on'mformalm. provided by CLIENT andmar CLIENT'S coensem,
and coosuluou. CLIENT aakoewbdges that if that inhmatiuv is Or Woman. 6 brmmpine or inaccurate, or if mMitbns ate discovered that could not be foreseen by a reganable pmoo, the
Scope of5ervices may clams., mason, while the Smices are on pram.,.
STANDARD OF CARE
ECS sell mivIn to Onfmm hW poor aba Smica m a ma.q consistent with that heart of bill and cue ordinarily caveucd bysompnent rremhm of the > me profession providing similar
Sereneor, is the same region. under similar vioniem during We rams Were period. No other rrpmemawucapmWed or Implied. me In w.rtmly err goarmme is inclubmi or mtcodcd W this
AGREEMENT. orw any FCS report. church, plan or otlser Document in Service, W emmenion with ECS' Savbq,
CLIENT mdmruW and amen that ECSpmfctionaljcdcmm must rely no the f ... 4uurd durng pnfonnarce ofilm Scope of smdces. CLIENT aWowledgca hit such 6. collenion b
Boded to We ietmcdutc era that is ..,Ind. msdd.4or obcrvcd. Commumtly. CLIENT agrees that it shall not bring a claim, basil upon facts suhscqucmly learned, rewinding conditions
Mween sampaFlrnird points, iv era not evrlu viol by ECS, in which were rat pm of the immediate seas) Inapl'cilly evaluated by ECS.
ECS' pmfawnal Smice, &hall be provided or a tranner comutmt with sound engineering and professional ptnairu. If a situation arum Who tames ECS to believe compliance with
CLIENT with. could r.1r W ECS violating mphable laws or Regulations, Or wdl expose ECS or claims or abler chum.ECS shall I. advise CLIENT. If CLIENT'S ..in. .1 much at,
result or a violation of applicable Laws or Regulations. ECS Wall axe the right to terminate its Services in importuner with the TERb11NATTON provuitins of Won AGREEMENT.
IF CLIENT dgide to dhmgnrd ECS' rmnmmendawm with nomecs to complying with applicable Laws or Rrgulaoow. ECS shall chro m or if ECS it required to notify to appropriate public
efficlad. CLIENT after We: also derimimoom ate ECS' care rigs to cake. CLIENT abo ems tar ECS tall not bear ability for tailors to Trpon conditions that are CLIENT'S
r.possibibuy to repro.
QZNLD15CLOS RES
CLIENT roll forrim avNe, Wall direct CLIENT'S comrbant(,) or agents) to lhmivh ECS information identifying We type and locations of utility Ern and Orbit, mounumc objects Imown,
aupated, or atmtad bengW the Sm. surface, where We Scope of Smica incomes ECS as pme¢uethe Site surface.
CLIENT Will run fy ECS of my known. gaumed....mpcoined regulated, comamwnal, or Hemrdous Materials tat ray exist it We Site prior In ECS mobilizing to We She Such hazardous
wohmis Wall include but not be limited to any substance which posy or may at Is orem, or potential hoard or human heaIb or We ovimrwrm whiter mmaued or as Mon., oateia 1. by-
Mdua. came. or sample. and -harbor it mina Or a solid, liquid. scmi solid or gumu Wren I -Notorious Materials"],
If—, Hamardous Mnmsu arc d'acovmd or ere mwonably tupeered by ECS after a Smicea arc ciliated. at Changed Caadh oo tall exert
ICFORSIATION PROVI EIZ@V OTHERS
CLI EN I waiv. any claim of liability agar. ECS repardmg my claim for injury or bat allegedly arising dam errors. auditions, or bacemacim w hatummb and other information w my from
provided I. ECS, including such wfoimsawn IN, become bmrporated into ECS Documents of Smim.
CONCE�ITIc c
CLIENT apkmowledgn that rpecial rotor are waoclated with We, idcnsificaior of corm ol cordaiens IIn. auaurfam emArriom. contain. behind a wall ate., War ace hidden bum view, ate
rat readily apparent, or rarmot be accrued for cenlplinytmay),
Conditions gut ECS info m exist between samplWgnesting Paioa may differ tigotfinotly mom the raMitioo that Insist a the sa nclingnating wino. Sin" same Critchlow can change
sohtumielly nv ime, the CLIENT recid noes Wit. because of natural occunepce, or human son —in .. al or raw the Sae amW coMbinm dlumvered through samplon,iti ing ray be
rub)co to Wid or marlin change.
ECS will make reasonable eHmd to arricipa¢ a idemify pormtul mnccoled conditions Wr enplosatioo, gmpling or Irving. However, CLIENT undernams that such risks no, be
clivigmed a agree Wit Was Scope of Sen'ias u Inal which CLIENT amea suits CLIENT'S own risk Interaction. CLIENT my request ECS to evaluate We this and provide a higher level of
esplo.atio, to reduce suchride, ifdcahcd orapprep rmrc
RIGHT OF ENTRV�cf'I ZR.'G FROM SERVICES
CLIENT wmmts that it porn a We authority to .... ide'i,hi a entry permission Ibr We performmce of ECS' Stryker. CLIENT hereby mend GCS and or IUM1counetors ender worm. We
tight is, nab from lime to time onto the progeny owned by CLIENT aline other(.) or order for ECS to perform the Scope ofSmicer
Except where ECS' Scope of See ices cN,lic ly includes obreming permits, limvwe. andor uhlity character for the piehmunee of ECS' ServR.. CLIENT watnma that is posses all
pgesWany pnmhs. be...&In tasty clearances for We Services to be provided by ECS.
ECS w01 sake maso.Me precautions to their damage to We Site and Improvcmena during We perfmma¢c of ECS' Smile. CLIENT ommtae War lee of esplmetloo, sampling, Or om mtg
Inqutpm.I may coax sonar damage th, toreador and ornicifwv of which is.1 pmofdpw AGREEMENT. use. eapliehlysurd I. ECS' Scope ofSmica. and Infected W We prof rwml
Fees.
CLIENT whites that it will not brbrg any claims for liability or for injury m bit allegedly visas, mom pmcedurns mociemd wills esplorauon. sampling or emog anivhie, or dumim of
t4ardo w Materiels, or supected Hawrdom Maeials. or ECS' findings, conclusionsoPivwm, rccommadntiom. phvs,.der Wponfi.1m. routndm dueove , ofmm.mmalert
IINDERGROOND ❑TILITI ES
In addituo to CLIENT-firpished inforomion ,,i ued.rmound utilities. ECS serf at reasonable and Inglly customary pccanima, possibly including mnranmg loll public .Nor
privy<rthr, Wichinp ,crymns, atWar cenduning rn.nit ofpuhlidy avwbble b(aroutior to dmtiry underground utWtia, a dared appoPtote W ECS' profmiom.1 s pimor. The prat of
such prm.utam shall be as ECS'sob dwr.iop
CMENTmmmlrn tat despite due cart. ECS may be arable m identify the locadona rfag mamf utility fires rod mwade fqw.. a War W formelwn obtained by ECS ear ECS'
subco maram(W) car provided Ins ECS fiom my emit, may contain amrs or be incomplete.
CLIP 7 agrees that ECS Wall not he liable Car drainage m injury, consequential economic damages..Nor prnaltiti resulting door damage to wlnrmansrm stmclorta (pips, tmka, gbles. or
other utilities, ran) which we not called to ECS' merlion'm school aotl correctly shown on 'be dwa rnam(a Wmohed by CLIENT car CLIENT'S mnsuhmd, or for undM,O.d unions nor
mu#cd. m improp.Iy boned by govemmemd or q.Wi-gntemmenW landors,.ility awn., m pivam utility location smicer.
SAMPLES
Suit. no&. water, boil o, nu¢ruls anNur clhm samples and trmplag by products oEtabM form We Sac are, Ia pnhor, of CLIENT. ECS wed more simples not command in laboratory
testing for up in siny (60) cilmd. days an, We iuu.ce of any document containing data obained form 'host worries. mess older mrsng.ems.ro omually amccd upon m wdthy. Stop lit
consumed by lebdramry testing proccdmes will not he sound u outlined above.
Unless CLIENT three mhervrue. CLIENT amboia.s ECS W dispose of CLIENT'S card-hawddw s.otpin evil aacoplog or .It, protons bloodury in accord.rn with appfirable Law,

PalletOne
ECS Proposal No. 09-17554
April4, 2011
FAV IRO"FNTar RISKS
All suimnres on, in. m mder CLIENT'S Site. at abttiocd from CLIENT'S She as samples or as byprod.e othere sampling proms, are and will remain CLIENT'S pvpmy.
V/Iren Havadom Immortals we known, assumed, of Im,ni,b d 10 exist w the Silo. EC vbull bike appropriate prcauliom doomed prudev in ECS role read pmferioval opinion on marry with
applicable laws wed Rebvlatiom. and to reduce the naW to ECS' eroplayc., public - mth. ssf.y, and voltaic. and the environment. CLIENT agree ro mmpemgc ECS far such prtteulimo,
When Harmdua tdoe'als me koawv. assumed, or c,p.m m obit at the She. ECS will handle such materials a Hatdm o glawish. ECS or ECS' subcontractors w01 anni.beri , antl label
soon Materials in remfdmce wins applicable law, and out hive be cc barren on Site. CLIENT is nomination for We retrieval and lawful remavtl, transport rod da mil ofsmch mntrminated
samples, and .Ivpa, present byprodumr.
Unless erplihilly tancd in ECS' Scope ofS,,icm. ECS mall o, .1commact or urmge far fiembi dimodual.arn.w of Hawdour Miter.], M CLIENTS raa..I. ECS may amiss
CLIENT as identifying appropriate ahemativm for monsoon. aITsho v.tment, storagem tluposel of such r u storm, but CLIF fF. bit ECS. dull make foal selmtlo s of monad, and firm W
provide such services. CLIENT 'stall cgr, all mmi fears fir the disposal of bit craze affected by Hatdom Mamia4 magnanimous and shall mbeavue mttouc prudence in mrr,mg for lawful
dupe.).
fa table Mnanca whme ECS is cam ally ,tamed by CLIENT to main CLIENT in be disposal of Hismdvu:. Nationals. temples, or wastes. ECS shall do so Only as CLIENT'S agent
(votwuhsWdwg any other pmvisioa Of b. AGREEMENT Ia be canonry) antat ECS mall not assume the bile of not be obt idcted a genmlm. mor. vaeponer, or testator of Ha.rdom
Marais):
Subsurface sampling my r.uh in umvoidable mars-muunmatioo of term wbsufface smas. an when a probe or ezcavatwNMliel device mavv through a cantemimiled coo and Iwkr it
m muirrr. unattgmunz steam, or clear hydmo body bit previously comgilinsl ed. or mmecls m unenmaminged same with • motamwled men Bmauu gtmalieg is an mat e)emcm or
ECS' Services indicated herni CLIENT ekmm this chat random M enmwnod. CLIENT will bit boll ECS liable for won crow-manum lesion if ECS provides as Smile w accordance with the
epplicrble Sanded of Care.
CLIENT odcrnands tau Phase 1 Environmental Site As .... treat (ESA) u conducted mkly to p .son ECS to header a pralesiaml opinion about the fischii arWe sue baying r nood,ued
EnvramarmiI Conditions ors mi bev.W, or nor the See as de. time the Services one conducted, No comer ham thorough a Phase I ESA swdy may be, findings arrivM from its madder sure
highly )mot and ECS canner low er stem form ahmlme fact that We Site a umffeted by roe or more Recalocal Environmental Conditions. Gives IM b.regow{. CUM S aemplwuee of
this AGREEMENT shall signify tat CLIENT understands be limitations associated who Plu.1 ESAs.
O W VERSHIP OF DOCUME ITS
With the exception of the copies of the ECS Documenu of Smica provided la the CLIENT. Ag d.enmetua, t¢hniul room. 4Ras, phmm. Mrin, lags, field cards. field rim.. lab.wary tw
dais,ralmmwm. designs. plans. ayccifbermm. reports, a,timor doonmmm sad atim e, of on, kind iumuid by ECS I' Documents of Service' I mewbiiom m soy him deemed appropriate
by ECS, we and remain, the pmpmv of ECS.
My eaplorelioa remvmlaanm, data mviev. ab crv.,wm. ewbill smneys or similar Swoo e.. aneMa and 1¢.mnendiumm gsacvted wish the Services sal) be provided by ECS (including
mbacrunc ed Smiles) for We CLIENT'S sole me. CLIENT dnderslmds and allm MI any me of We Documents ofSmim by myorw odrcf tan the CLIENT u of pmueted.
CLIENT gees to not me ECS' Documents of Service for any other pmjms. at for the Project which has ebavged On some. m emnslom of to Project. Gem be details mmemplaad in ECS'
Docurocmm of Servile. Any race w'vhmn ECS' xThrm mmml salt M q CLIENT'S sat risk sod whlbm lubilicy m ECS ar e. ECS' mbcomn.or(s).
CLIENT Woos tat ECS' Combat ofSwice rosy her coda any c}mmmwee M Ahmed by my party acept ECS, CLIENT warrants last ECS' Mom= of Service shall M used only end
exactly u mbmwed by ECS.
game firs, daily field retbns and emote tat r,pons sent clmmnkel)v by ECS to CLIENT and CLIENTS daignm. We following mall apply to of electronic film: File in electronic media
formal oflere dais, graphic. er aM typo tat are fuwiued by ECS ate fumuhed only forxonv<vi<nee. of renames by We aemWbil party. My conclusion at wfamwio. Obtained Or derived
from such ehetrouc film mid M at the mat a role rut Ifthm it a duclepmcy bmrwn the clmmnic film and the hod colic.. the hood mom soli {mora.
SAFETY
CLIENT vgvom had ECS is co,,mibk ankly for the bswic anfcty of ECS' employees on the Project She These responsibilities ball not M wf .red by my poly to moan tho ECS as
mpomibJuy Por any portion of site safety bar my reason. United mherwi a "rmsly µToed m m wram,. ECS' Smile of Smilem manim res,cro bilBy form, open ofahc aehry nWrf ran
for ECS' awn employees. and nothing bwin call he emitted m mlieve CLIENT m lbw its oNv e.mmnnn, omWeact , or .,for pvuw from their rmpnnribii ty for bestiality of tM¢ over
empwycer. For active meamuawm air.. CLIENT Ann W. flaw Ili: Gmersl U.Or is solely cosNa ibk for Project Site safety. and @et ECS personnel rely an ,he safety mimes
mavwed by tithe General Contractor
In tM even ECS mpfmsly asumes health and safety reyoneibilhim for north or Other reactors specified. the acceptance of soh mpomibilay, does mat and mall not M deemed an wm, tor,
ofr.pooibilny far soy ocher Foallh and safety requrmmu, ruck as thaw alarw, to..vatiid , become, ilmrb , driller& bukfillivg, timing, or oWa a m iumm. wt,iti m.
CONSTRUMON TESTING AND REMEDIATtON SERVICES
CLIENT colors ... m that <vmtmmwn coning and om,ivar ion Smiles we conducted to reduce, not elimMte. the risk of problems eruwg during or after m.munwn or ravedurbn and that
provuian af.ch Services does act owe a wmemy or guarmtce of any, type.
Murdering sndlor t.ring Services provided by ECS ball bit Or my way «lien. the CLIENT'S c.mtaaonsf from NA raDomibilities and obligsc.. far We quality Or mmplmenm of
consa ion oarfir complying with epplluble law, and coder.
The professional activities of ECS, or We presence of ECS =play. srN su so mrw,ms, shall cot be construct to imply ECS has any reapmihil , far the arm.. methods. cehoiques
whitener, of construction, Or macedbes of mmtedNon sdmW, far.fm, arm....... and yroglnm incidental no We Contractor , Work. Fah rt. ECS des. not and ,If not have or
omega sumrhy tos,i iC, drat, enmol arm" Contmcro's Work.
1.
ECS nmoodily reconmoMs faI CLIENT maw ECS to Foredo b Smic. and •fug Ime hasis to loam ife oak ofdefective or Incomplete Work being installed by CLIENT "S ennmaons). If
CLIENT cl.v t. retain ECS on a pen time hail far my aspect of ro.vmvon announcing, bill.( maug. CLIENT saaryrs the maeasN risks that A signlficmlly wwa kvd of camvuctioo
goliy my atom and that such defects ty not be odnured by ECS' part time obaroverea. Therefor, CLIENT wuv. my and all claims against ECS felAmd to umeWfenory, mle, or
performmce of elements observed or tensed by ECS on a pm time asks.
CERTIFICATIONS
CLU.NT may request..1 governing jurisdimwn may oquime ECS to provide a "ens ifintion" regud'mg S.. provided by ECS My "ens ification' rcgo'ved of ECS by for CLIENT, as
jurisdo wn(s) avbg 0mhonty over wme or ell opceu of W, frajan, shall Gamut of ECS' mhmvcm shad professional Opinions based an limited sampling, abervgkm. tau, mi amlv,m
performed by ECS at discrete localiam said twos. ECS' 'amif'cetlon' wall consist of ECS' mold enual opinion of a mutation's existence, but ECS does not Incorrect tat mob mudiliac
xut, at doe it relieve Other patio Of..... bi)ifin or obligation such much, love CLIEfvT aknm not to mske rmalmien of any dispute arm ECS or gyrace, of my amomt due m ECS
in my may eamin,mruM ECS ..,am, say wan"cmufcaresn' �.
BILLINGS AND PAYMENTS
C'llugs will he based m We due me, vend coo and other rcmbdrsebls hmenrm stead in the Profwaird Fm. My Estimate of lies fesajnml Fees 111 m Wu AGREEMENT sill bit be
camidcad as, a oedm.ved or lump ado amount unlm aWmwuc mphchly muted I. but AGREEMENT.
Should ECS idemify A Changed Cenobitic.. ECS sill otify We CLIENT ofmc Clamped Cvodhion(s) that in ECS' professional Winston «quo, an amendment of the professional Fees, time
schedule. arbor Scope of Services. ECS and CLIENT sill prontri and in good faith net an amendment m his AGREEMENT,
CLIENT remgvus Pn lime is of the essence whh rapes of peymev of ECS" --it-
in U.S. funds down upon U.S, trucks and Or accordance mith We rates sued charge set Anch in We Pmfsioml Fm. Invoices sill as it. and payable ......eio,
If CIIENT disputes all Or pan of an make. CLI F.NI'sall provide ECS wish verinm noire tali., in d.eil the faces of We dispute wjWw Iwml,cre (il) Mender days tar W, invoice dart and
slim to pay the undupmed summit of seen invoice prounhi),
ECS ¢arum We right to charge CL.IEN m Md'nioml charge ofoneand one-half (1.5) percent (m Inc meaim,m percev.ge dlewed by haw, mhich-er u Iowa) of lbe.,.iced coat per
omb for my 0N%Ment received by ECS mow Nan Fr" (10) calendar days from the dart of the; rmbec. meeg'wg any potion of to wvo rod commit w dispute and resolved m favor of
CLIENT'. Payment win first M eppbed ea von<d wtcrnt end ikon m the respond prwcipJ anises, Pssment of mwkm Bill bit be object to unilateral diwouming orsmof5 by CLIENT.

PalletOne
ECS Proposal No. 09-17554
April 4, 2011
CLIENT spree that its obli,le ran an pay for the Smices is not demingned upon CLIENT'S ability to oblaly fisanciµ. mninp. approval of,cmer emal or regulatory e8encim, peooree. fiml
adjudication ofa lawwir in a Lid. ECS u not involved. upon CLIENT'S summit compaction aRh project, sentenced ofa real estate transaction, receipt of payment from CLIENT'S client, or
any Other nett. Rmishrge Ihill not he withheld Gem any paymm,, we sell arty deduction be mite fiom any invoice on account of pdi liquidated dmaga, or other taw imvtrW by
CLIENT. It is agreed that all carts ad IdbI fees oclud., mnal moan y', feu, and e,pema incurred by ECS in mfntcc, any pmvnion of the AGREEMENT, is paharva, or bouncing e
lice cosi them a bei mlimm, any delinquen: armtm, dueor emest rg,dpmms, shell h reirrourad by CLIENT.
Paymem story invoice by the CLIENr all be teku to into thal We CLIENT a,. m ter pcb—pnm of,M AGREEMENT and in tall find with ECS' Smices and is her awes Of.y defect
in these Smices. unless CLIENT hu provided notice to ECS in auordmee with the Def.a to Smicn provitiom af,Na AGREEMENT.
DEFECTS I5ERVpCF
CLIENT ad CLIENT'S personnel and cannon absll prompob dons ECS bf any moral or mpeded dcfms or ECS' Smices. to hey ECS take their pmmq, cfmt,,O mermres thud in
ECSopinion will help reduce or clubhouse the conroqueaea D: my such defer. Cancdiom afdcfred ediil rub), to ECS' Smicea shell be provided at no coat to CLIENT, cmayt in the cue
tat the deficiency u directly etbibution to CLIENT. fiunuh i inlnrmetma CLIENT shall compme,e ECS for the data of mrrmkg such a feet,.
Modifiufmns to reports. docarmis and plot, required as a react, ofjuri,divboal rOcim or CLIENT requvd shall not he din idered,. the defms is Smices. CLIENT shell cmpemare ECS
for Additonel Servicearmubed m a result ofjuredictional review requkemw,s.
INSURANCE
ECS rmramu than it and do subcaemdon ad subcnmunmu ere Fronded by Workm Compression insurance, aM that ECS is covered by general liability. cour ile and profevioual
liability ka deme policies,,h. I hew Womble sad adryuem.
ECS shall fiunuh cenifiatn of icruemm upon requnt. The CLIENT u rapomiblr for....tk, aodifc echoic. or amps of covmpe tan m on, present it ECS ins.'.. the con of,uch
W duiou or coverage inhearm. if available. will he an We eepeeae of the CLIENT.
LI;AIQATIOV OE LIABILITY
CLIENT aorta m alloum « von ofthe risks associated wuh tom Projm by limning ECS' toed liability m CLIENT, subject to available imuamce procvds, aNc, from ECS' professional aces.
hrov. of e.r.1,mn and for airy n A ell came inducting eBElw¢, nrid habiliry, beach of comm�, err brraca of wmmty. uUmin. damages. draw. Imses, eapemu, or Nita tape s.
(including remomhle auniso, a feu) under thu AGREEMENT to to fuller .1. pnmiaed by law, as fink... Foe projects when ECS' Fee Esoua or proposed fen me:
$ I O.M or kn. ECS' total a go gnu liability'. CLIENT shall not exceedS5.t100. or the odal fee for the rmicer raWned. wbicbevne or pater.
le eaters of $10,000. ECS' told gMmrgate ability to CLIENT still net embed S50.01o, or the lots] fen for fire mrvicd retched, whichewd u greater,
CLIENT sores this ECS shall net be responsible per badly unitary ad propedy dmaec o, b,au main, directly Or Indirectly, in wWk or a pan. prom ens or amuaiou by tie CLIENT, or
mmby,, mri mR. camubmu err subcanmmn or by any other person or mmbitation of person to 'be -be'such 'miury, denote, or loss a mall by m, or codsskm of CLIENT, its
mpkyces, al mb, dell. menulunu at mbchadracton.
IINDEMN LCATl4N
ECSafoe< subject to the limiatunofliability provisions ofmis AGREEMENT. to hold hamlem ad undcmnify CUEOTtram and egaimt danager mecg form ECS negligent par demote
of Its Survives to the eatem hanuch injury is found Ib he caused by ECS' delalmt and. ender or omusiam, spmiimlly eW,olinp any demapes dud by any hied party or by the CLIENT.
To We hllot tatter pertained by grylkable law. CLIENT agrms to ndcmnify. ddcnd and hold ECS hatmiers fiom ad around my and all liholhy. Nims. damage, dnmapN, form, peraires,
cost and erped'um.(includng remnabb summers fees and mate of litiFn no defame and or amlemml) I Dameyer-1..and c whole or is ad by We neClilmt awmen or omusiam of
the CLIENT and CLIENT'S employ,, n,mu, nalC contractors, vubcunmctun. constraints, and direct, provided such Corsi m amibutable to. (a) con baldly unitary pdaaml injury,
sickens. disease did,or death of my person : (b) injury to or bra of value to 'tuition pdmnal propmy,, m (c) a bench af&ua AGREEMENT, eacryt N the eaten inch Damage a uusd by the
able neglilwce or w41ful bhimoduct ofECS.
It is specifically udentmd and apml that in no me shell ECS he required to pay an mount of Dnmagcs dupmponional to ECS' culpability, or my more of any moue levied to resapahe
mare tan adml mommic damages, subject to any Limitations of liability and iudemificukn provisona detrained c ihn AGREEMENT.
If CLIENT is a mccoownm. hemmwnm' nmcidim, mndomivim owns. condominium owner's association. or aimilar residential owed. ECS mcommcdo teat legal ne oad to rebind by
CLIENT Ware tiering• ivo this AGREEMENT to dtplaa CLIENT'S rights. and the limhatiamand ressrniom unposed by lhu AGREEMENT. CLIENT ag car had, Tanta of CUENI' to
men avch marvel aFall be a knowing waives of legal course] and shall nor be allowed on lro, am of avbidor abyymvuion of the AGREEMENT.
YCLEENf is a rescemial builder or residential dcvclmpd, CLIENT shell cdeuwify, defend and hold bred, ECS -Im- any ed all ellims or ddbmds due to value, or Imes initiated by One or
more homwwners, udrownerserr than bommwmen' associukn, caapenriw board, or sunJar mt'ny almost CLIENT which mule is ECS here, oracular into We dispute.
CONSEOLIENTI AL DAMAGE
CU ENT mail wt an liable to ECS and ECS shall not he ahlc to CLIENT for may eonscommul daor,m incurred by enlace due to the fault of the LWd. re4ddlem of the natm of Ibc fault. or
whdtvd committed by the CLIENT or EC& tab employees, mmuhanb, spend, comnaan or subcome..., or whdhr such liabil'ny are. is Scratch of mmtm or wormy, tan (it¢Iud W,
oegiilmt4Slatme.manymWerumcafenkn Ccmequmteldamagesi lee, but mtathmiaid W. Wes crusted loss eforoh.
ECS mall Out be table la CLIENT, or, my hairy engorged diurnally or indirectly by CLIENT, for any liquidated member due to my huh. or reduce to ad. in part or in total by ECS. era mpkyms,
µcod, or subwalnnon.
All Cauca lot damages related m tie Soviet provided anon, ehis AGREEMENT sall be made against We ECS mttty eonmeWt, with the CLIENT foe the Smicc, and w Other pmon err
entity. CLIENT red, IWt it shall not tame by affiliated entity including palm,, peer, of moaidivy entity or my individual Office, deeetia, or mpleyec of ECS. unless such ahcu us bud
an am uortlud m to provision ofSOt seder this AGREEMENT.
CLIENT armed that it will tat seek Dami from any individual usocuted with ECS as an oMe.. priocyaL poorer, amkycc, or owes. Gam ray and all clads tar hastily for injury Or Inc
,that would touch such individual Ian cicquuh personal uaea to satisfy much claim,
THIRD PARTY CLAIMSE_XCLUSION
This AGREEMENT shall van tend. any rob i ierr benefits to partnd other then CLIENT mud ECS. No third pmy shall have the right to rely on ECS' opinkm rcodded is comet with ECS'
Services without bold CLIENT'S ad ECS' written contains and the tbkd panys afrodumr to h band to the same terw and coditiam mnWond'or this AGREEMENT u CLIENT. and thbd-
pmy s apnmer l Was ECS' Scope ofSmices phformal Is adequate.
DISPUTE RESOLUTION
All chines. dinpmes u denvmia ("Eapum'I vifie, om of, a in felmioo to has k,eryretvibn, arbitration or wfoeumm, of" AGREEMENT tall be dnidd u follows:
CLIENT ad ECS agra to mend a duputc malurion =e. wuwn fatmern (14) d.er o(kmtifiutkn of a Duputc any cirlrcr party. CLIFM and ECS sgrte to vµoate k pod hhh to
mmlve the Depute.
Should mgotia,cn had to remove the d'uw,e CLIENT and ECS epee to mediate think depute vie in mediator selected by c0cr Fury. and anptablc to bath parties,
Shored medic ma tut Io tuts, in taolidurs of the Dissent. CLIENT and ECS W. hat fujou ban rosy be brought by either Fury.
Should ih diary, dispute re union be resuaed, through mdmmar or hilation ohc norvpnvailm6 puny sell reimbmeto pr,vallin, puny foe the prevailin, pray', dormcnted kral m,a.
in demon to waterer other judgments or smlmmt sums may h due Such k,al coati we ludo. but m oat h Ilmiad to, ramnable enomeyi fees. tam tans. forensic diabolism and earn
wimas fees, and mincer do loomed expenses.

PallelOne
ECS Proposal No. 09.17554
April4, 2011
When Icwl anion a broupht by either perry to reolve a dbpule. the drlen'Nll be bmugM and tried to the judicieljurLdiction of the county in which ECSOffice contracting with the CLIENT
u baled. CIJENTwviva the right In remove coy dtig.l'a-onion 1. my otMjurudinion. inL•n mutwlly rt,recd to by both ponies.
This AGREEMENT Ewluding aIt mule coined to prfinnmu end rmdimloa'hall he I croc,d according I. the substantive Lwf of the sum of VtrCivi. (hot not including IB choice of
law rvka).
CUPIN AUEACH
A party that bcticves the other hY conic tlly breached this AGREEMENT shell issue a written tattiimtivn nonce In the other, identifving the awe for temirutim within rive (5)bwbte'days
of id'mifying Loch cause. Both Dania shell then I.....lr. IMIFi y cad im 6o.d faith to sure rich cit., If m tacepuble ewe can be 'chilled vv.Krr fauncen (14) alendn drys ham the date of
the tnrviatun home. the pertie still mohair thah unocnundiag. to wrhuC ad t.Mlion still cos Dean.
Either petty MY waive envy right providd by acts AGREEMENT in curing m cowl or id.'m mach: Iwwever. Loch weivn'lull not ertan futon, "Latin. of'uch P'"ion or any other
pravhioo.
LLltmI`IATIOH
CLIEM m ECS may tmninata Wu AGREEMENT for touch of th� AGREEMENT, ar for any atheoreaow which mey visa In Wt, cvcnt of tetminetnn, th pmY a@min0 rcrmivatiov dull
xo nodfY We oWe pony in writinti. end urm'tvetiov shell bmaox aRmive foentem I141 relcvdv dap rfle remryt oftbc tcniation hnwe.
Incxncmbm of'vh'h pmy shell affect mtminerlan. or We count, thuefore. ECS shall promptly rmd<r to CLIENT a Feet mvoiac end CLIENT shall hnmdinddy eumperuete ECS for Smice
rtMered sad costs ivcurted. in ... odance with ECS' pmreilim, Fee Schdule end upnt, aind unernent polity. Service stint Ivaluda Wme anderal IF to the time of terion.L.O. u wall a
thou mutoted with terminetlon a,elf. including without limiutorr damobilkiag, modifying schduk, end nmiCoivg Personnel.
TIME BAR TO LEGAL ACTION
Se"Ic prohibited by Irw..d con t be anted cop my Surma that may provide a. ilia I l Proton Wv. CLIENT cod ECS epee that claim' by ondo pity inning out of the AGREEMENT or tan
Smicu niidd heeundar ro ll cot be ()enmore then two f2) yam hole to tw, the pony Yam, or should hive known a(the candhioa Giving rva w iu Beim. avtl still toner w
<inumstm<e h ipitiehd coon, Wevthrce (J) yin film the dam ofxuhmntial wmpkuon of ECS' Smiles.
ACSLGNMFNT
E.ecpt far Srnke normally or ewtomarily shbcommn<d by ECS m the pa forr, racr, of its Smvicu induditi but cot limited to xw Byars, npcieliz'd'.yotd x, other, .d eec'vming
Nkomo eaten. W'.'I, htanhanes, vmatter We CLIENT vat ECS may ildrgme, reig, tablet or oenfor it dutiu, raspomibilidet or mmruu on Nis AGREEMENT without to, corium
commt of lM other perry.
SEVERABILITY
Any Pmvufon of that AGREEMENT btm Mid to viclatz a liw. Starve. or Regulation a1Wl be deemd void. W all mmalntiC arovuivm'1Wl catiore a &II forted effect. CLIENT aM
ECS stall anothi 1. quietly rrybee. vhidd pvrvao.. web. valid substimu that atpreved the i.I.I of, or n Seat .ddtmu, the uswr wailed by the original provuiov
TEO cc
The tble and in Wat AGREEMENT ere for gmnrl mfnc<ec Doty ad m oat Pars of the AGREEMENT.
SIIRVIVA
All obliguVon arising prior to the tmvinmiov of the AGREEMENT W .11 Pro viom of thin AGREE1,1EM Jbeting tespawibiLte el4abiiVy b.cia tlr CLIENT and ECS still aurvivv,
W<mMumW compl<twn o(Smi<cs end the tcrminetnn v(tLu AGIIEEMFNi.
ETTIREAGREEMENL
Thin AGREEMENT LIENTag rho Scope of Smicn raid cryrmdond Fen ad nt . one , .cd I, rod GUdmENT, C appended m h, mMhute We cord AOR. by r between
CLIENT ad ECS. CLIENT n.I. Ea.gn the all prior untlmmwdwgr.M negmutwa m enupmdd by ddr AGREEA¢M'. CLIENT edmowkdgu acmmna oflhne term' by submhting
• CLIENT Work AUWovatiov I. ECS.
CLIENT W ECS epee tat vuWt,qucm modifitiun. w Wat AGREEMENT sWl not bt, bindbtg calm ttud<N writing and signd by authorial re heramatim of both pmiu.
Ail ptepmtd Terms and Condom. on CLIENT'S punts, order or Work Ahtlwr'mitam. mother 'mice aauhrodedgamemforen,.rt iapplicable coal supmdd by Wb AGREEMENT.
If CLIENT bib 1. provide ECS whh . signed copy of dAr AGREE1,IENT or a Wary Aur orivtiaa by the act of authorizing and eccaptiag the'uvim of ECS, CLIEM epee to be fully
bound by tot, intend of this AGREEMENT a if signal by CLIENT.
e END OF TERMS AND CONDITIONS OF SERVICE I

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
April 28, 2003
Howe Wallace
Pallet One of NC Inc
165 Turkey Foot Road
Mocksville, NC 27028
Subject: NPDES Stormwater Permit Renewal
Pallet One of NC Inc
COC Number NCG210238
Granville County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG210000, the
Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This
permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection
Agency, dated December 6, 1983.
The following information is included with your permit package:
• A new Certificate of Coverage
• A copy of General Stormwater Permit NCG210000
• A copy of the Analytical Monitoring Form (DMR)
• A copy of the Qualitativel Monitoring Form
• A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division
may require modification or revocation and reissuance of the Certificate of Coverage. This permit does
not affect the legal requirements to obtain other permits which may be required by the Department of
Environment and Natural Resources, or relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
If you have any questions regarding this permit package please contact Bill Mills of the Central Office
Stormwater and General Permits Unit at [phone], ext. 548.
Sincerely,
�1/� S'41'�e`
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]
AY
NCDENR
Customer Service
1 800 623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG210000
CERTIFICATE OF COVERAGE No. NCG210238
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Pallet One Inc
is hereby authorized to discharge stormwater from a facility located at
Pallet One of NC Inc
10 26Th Street
Butner
Granville County
to receiving waters designated as a UT to Picture Creek, a class WS-IV NSW stream, in the
Neuse River Basin in accordance with the effluent limitations, monitoring requirements, and
other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCG210000 as
attached.
This certificate of coverage shall become effective May 1, 2003.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 28, 2003.
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Aro R
�Or
KENNETFI G REAVIS
PALLET ONE OF NC INC
2340IKE BROOKS ROAD
SILER CITY, NC 27344
Dear PcnnitcC:
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
September 4. 2002
Subject: NPDES Slurmwatcr Per Coverage Renewal
Pallet One OI' Nc Inc
COC Number ncg210235
Granville County
Your facility is currently covered lot storinwater discharge under General Permit NCG210000. This permit expires
on March 31, 2003. The Division staff is currently in the process of rewriting this Permit and is scheduled to have
the permit reissued by curly spring of 2003. Once the perinit is reissued, your facility would he eligible for
continued coverage under tile rcissucd permit.
In order to assure your continued cuvCrugC under the gcncral permit, you must apply to the Division of Water
Quality (DWQ) fur rcncwal of your per covuruge. To nmke this renewal process easier, we ere informing you in
advance that your permit covcragc will be expiring. Enclosed you will f ind a Permit Coverage Renewal
Application Form. The application muss be completed and returned by Ocluhcr 2. 2002 in order to assure
continued covcragc under the gcncral permit. Due to swdd';uul budget constraints, letters confirming Our ICccipt of
the completed application will not be sent.
Failure to request rcncwal within the limo period specified, may result in a civil assessment of at least $250.00.
Larger penalties play be assessed depending on the dclinqucncy of the request. Discharge of stonnwatcr Iron your
I:rciIIIy wiIhuut covcragc under a valid stornlwater NPDES permit would constitute a violation of NCGS 143-215.1
❑nd could resell in assessments of civil penallics of up to $ 10,(H)U per day.
Plcuse note that recent Icdcral ICgislation has Cxtcnded the "no exposure exclusion' to all operators of industrial
facilities in any of the I I calcgones of "storm water discharges associaled with industrial activity." (except
construction activities). If you feel your facility can certify a condition of "no exposure". i.e. the facility industrial
materials and operations are not exposed to sturnIwater, you can apply fur the no axpusure axolusion- For additional
nilinmation contact the Cmnr:l Off ice Slormwoler Stafl' member listed below or check the Slurmwatcr & General
Pennits Unit Well Site at help://h2o.car.stutc.nc.us/su/slonnwalcr.hUnl
If die subject skxmwalm discharge to waters of the state has been lerminated, please complete the enclosed
Rescission Request Form. Mailing instructions are listed on the bottom 01*111e form. You will be notified when the
rescission process has been cumplCled.
II you have any questions regarding the permit rcncwal procedures please contact Joe Alhision of the Rulcigh
Rc,sional Office ❑t 919-571-4700 or Bill Mills of the Cenral Of lice Stormwutcr Unit at [phone], ext. 548
sincerely,
Bradley Bonnets, Supervisor
Stormwutcr and General Permits Unit
cc Central Files
Stormwutcr and General Permits Unit Files
2aluigh Rcgional Ofhcc ©-ja
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-523-7748

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
KENNETH G REAVIS
PALLET ONE OF NC INC
23401KE BROOKS ROAD
SILER CITY, NC 27344
Dear Permittee:
1�
NC®ENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
7/12/2002 , LF
Subject:. NPDES Permit Modification -Name and/or Ownership Change
Permit Number NCG210238
Pallet One of NC Inc
Granville County
In accordance with your request received December 20, 2001, the Division is forwarding the subject permit
modification. This modification documents the change in the ownership of the subject facility. All other terms and
conditions in the original permit remain unchanged and in full effect. This permit modification is issued under the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U. S. Environmental Protection Agency dated December 6, 1983.
This permit modification does not affect the legal requirement to obtain other permits which may be
required by the Division of Water Quality, the Division of Land Resources, Coastal Area Management Act, or any
other Federal or Local government permit that may be required. If you have any questions concerning this permit,
please contact Valery Stephens at the telephone number or address listed below.
Sincerely,
for Alan W. Klimek, P.E.
cc: Central Files
Raleigh Regional Office, Water Quality Section
Stormwaler and General Permits Unit Files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

� r
1
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG210000
CERTIFICATE OF COVERAGE No. NCG210238
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.I, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
PALLET ONE
is hereby authorized to discharge stormwater from a facility located at
PALLET ONE OF NC INC
10 26TH STREET
BUTNER
GRANVILLE COUNTY
to receiving waters designated as UT To Picture Creek, a class WSIV NSW stream; in the Neuse River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts t, II, III,
W, V, and VI of General Permit No. as attached.
This certificate of coverage shall become effective July 12, 2002.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day July 12, 2002.
for Alan W. Klimek, P.E. Director
Division of Water Quality
By Authority of the Environmental Management Commission

N�K)
RState of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
May 1, 1998
BETTY FOGLEMAN
SOUTHERN PALLET, INC.
10 26TH STREET
BUTNER, NC 27509
Subject: Reissued Stormwater General Permit for
Certificate of Coverage No. NCG210238
Granville County
Dear Permittee:
A40
AM
� E N R
��JMAY - 5 log
In response to your renewal application for continued coverage under the General Permit
NCGO40000, the Division of Water Quality (DWQ) is forwarding herewith the General Permit
NCG210000 which is a new General Permit to cover most of the Timber Products Industry. You
have now been given coverage under NCG210000 and your coverage under NCGO40000 is hereby
terminated. This permit is issued pursuant to the requirements of North Carolina General Statute
143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental
Protection Agency dated December 6, 1983.
The following information is included with your permit package:
■ A copy of the stormwater general permit NCG210000.
■ A new Certificate of Coverage under general permit NCG210000.
■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit (both NCGO40000 and NCG210000). This form must be completed and returned to the
Division within 30 days of receipt of this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
■ Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program which outlines program components
and addresses frequently asked questions.
Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water
Quality may require modification or revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater and General Permits Unit at telephone number [phone].
Sincerely, /•
�/LcLtG��
for A. Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

f � f
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG210000
CERTIFICATE OF COVERAGE NO. NCG210238
STORMWATER DISCHARGES
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and
the Federal Water Pollution Control Act, as amended,
SOUTHERN PALLET, INC.
is herby authorized to discharge stormwater from a facility located at:
10 26TH STREET
BUTNER,NC
GRANVILLE COUNTY
to receiving waters designated as UT To Picture Creek in the Neuse River Basin
in accordance with the effluent limitations, monitoring requirements and other conditions set forth in Parts I,
II, I1I and IV of General Permit No. NCG210000 as attached.
This Certificate of Coverage shall become effective May 1, 1998.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day May 1,1998
b
for A Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authorization of the Environmental Management Commission

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
April 28, 2003
J Glenn Watkins
Granville Pallet Co Incorporated
3566 Highway 15
Oxford, NC 27565
Subject: NPDES Stormwater Permit Renewal
Granville Pallet Co Incorporated
COC Number NCG210015
Granville County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG210000, the
Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This
permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection
Agency, dated December 6, 1983.
The following information is included with your permit package:
• A new Certificate of Coverage
• A copy of General Stormwater Permit NCG210000
• A copy of the Analytical Monitoring Form (DMR)
• A copy of the Qualitativel Monitoring Form
• A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division
may require modification or revocation and reissuance of the Certificate of Coverage. This permit does
not affect the legal requirements to obtain other permits which may be required by the Department of
Environment and Natural Resources, or relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
If you have any questions regarding this permit package please contact Bill Mills of the Central Office
Stormwater and General Permits Unit at [phone], ext. 548.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Raleigh Regional Office
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
N( DENR
Customer Service
1 800 623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG210000
CERTIFICATE OF COVERAGE No. NCG210015
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,
Granville Pallet Co Inc
is hereby authorized to discharge stormwater from a facility located at
Granville Pallet Co Incorporated
3566 Hwy 15
Oxford
Granville County
to receiving waters designated as a UT to Johnson Creek, a class C NSW stream, in the Tar -
Pamlico River Basin in accordance with the effluent limitations, monitoring requirements, and
other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCG210000 as
attached.
This certificate of coverage shall become effective May 1, 2003.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 28, 2003.
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

-1
Y
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
September 4, 2002
J GLENN WATKINS
GRANVILLE PALLET CO INCORPORATED
3566 FI W Y 15
OXFORD, NC 27565
Dear Peinlittec:
Alan W. Klimek, P.E., Director
Division of Water ®uality
Subject: NPDES Slormwatcr Permil Coverage Renewal
Glanville Pallet Co Incorporated
COC Number ncg210015
Granville County
Your facility is currently covered hx sUmnwater discharge under General Permit NCG210000. This permit cxpires
on March 31. 2003. -Pile Division staff is currently in the process of rewriting this permit and is scheduled to have
the permit rcissuctl by carly spring o1'2003. Once the permit is rCISStlell, your racility would be cligihlc 101
continued coverage under the reissued permit.
In order to assure your continued coven's under the general [lei miL you must apply to the Division or Water
Qualily (DWQ) for renewal of your permit coverage. To make this renewal pruccss easier. we arc inronning you in
advance that your permit coverage will he expiring. Enclosed you will find a Permit Coverage Renewal
Application Form. "hhc application must be conglletcrl and relUrned by Oclohci 2.2002 in order to assure
continued coverage under the general permiL Due to stal't and budget eonsm'aill s, letters confirming out' receipt or
the completed application will not he sent.
Fuilurc to raluusl rcncwal within the time perind spccilied, may result in a civil asscssnlent.of al (cast $250.W.
Larger penalties nury be assessed depending on the delinquency of the rcqucse. Discir,ogu oP�!orn:vatcr 1'ro!'�1 your
facility without coverage undera valid stortuwaler NPDES permit would constitute a violation of NCGS 141-215.1
and could result in assessments of civil penalties of to $10.000 per day.
Plcasc note that recant f-C&Ml Icgislulion has exlcnrlcd the "no cxposurc exclusion' to all operators of industrial
lacilities in any o1 the I I categories of "storm water discharges associated with industrial activity." (except
construction activities). II you ICC1 your 1i1611ly can certify a condition of "no exposure". i.e. the facility industrial
malarial$' and operations are not exposed to siorunwater, you can apply for the no cxposurc exclusion. Far additional
information contact the Urinal Of Tice Simrnwater Staff member listed below or check the Slormwatcr K General
Penuits Unit Web Site at htlp://h2o.enr.saItC.ne.us/su/S(ornlwater.hunl
If the subject sturmwatcr discharge to waters of the state has been terminated, please complete file enclosed
Rescission Request Form. Mailing inslruclions are listed on the hottom of the form. You will he notified when the
rescission process has been completed.
It' you have any questions icg:uding the permit rcncwal prtccdures please contact Joe Alhislon of the Raleigh '
Rc�ional Office at 919-571-4700 or Bill Mills of the Central Office Stonnwale Unit at [phone]. ext. 548
Sincerely.
Bradley Bcnnclt, Supervisor
Slormwatcr and Gcncral Permits Unit
cc: Cenlril Files
Slormwatcr and Gcncral Permits Unit Files
Raleigh kegional Office ©G
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-623-7748

State of North Carolina
Department of Environment
and Natural Resources I ,) 51W J' ) I ,
Division of Water Quality( I__--- 1
YINR RALEIGH REGIONAL OFFICE
James B. Hunt, Jr., Governor i
Wayne McDevitt, Secretary ID E N
A. Preston Howard, Jr., P.E., Director
May 1, 1998
J GLENN WATKINS
GRANVILLE PALLET CO INC
3566 HIGHWAY 15
OXFORD, NC 27565
Subject: Reissued Stormwater General Permit for
Certificate of Coverage No. NCG210015
Granville County
Dear Permittee:
In response to your renewal application for continued coverage under the General Permit
NCG040000, the Division of Water Quality (DWQ) is forwarding herewith the General Permit
NCG210000 which is a new General Permit to cover most of the Timber Products Industry. You
have now been given coverage under NCG210000 and your coverage under NCGO40000 is hereby
terminated. This permit is issued pursuant to the requirements of North Carolina General Statute
143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental
Protection Agency dated December 6, 1983.
The following information is included with your permit package:
■ A copy of the stormwater general permit NCG210000.
■ A new Certificate of Coverage under general permit NCG210000.
■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit (both NCG040000 and NCG210000). This form must be completed and returned to the
Division within 30 days of receipt of this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
■ Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program which outlines program components
and addresses frequently asked questions.
Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water
Quality may require modification or revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater and General Permits Unit at telephone number [phone]. -.
Sincerely,
t5
for A. Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh, North.Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

4-'
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG210000
CERTIFICATE OF COVERAGE NO. NCG210015
STORMWATER DISCHARGES
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and
the Federal Water Pollution Control Act, as amended,
GRANVILLE PALLET CO INC
is herby authorized to discharge stormwater from a facility located at:
3566 HIGHWAY 15
OXFORD, NC
GRANVILLE COUNTY
to receiving waters designated as UT To Johnson Creek in the Tar -Pamlico River Basin
in accordance with the effluent limitations, monitoring requirements and other conditions set forth in Parts 1,
II, III and IV of General Permit No. NCG210000 as attached.
This Certificate of Coverage shall become effective May 1, 1998.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day May 1,1998
b IA� tic" j6L—
for A Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authorization of the Environmental Management Commission