NCG210450_CEI_20200224

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ROY COOPER
Governor
MICHAEL S.REGAN UM .
Secretary
BRIAN WRENN NORTH CAROLINA
Acting Director Environmental Quality -
February 24, 2020
Enviva Pellets Sampson LLC
Attn: Bill Simon, EHS Manager
5 Connector Road
Faison, NC 28341
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG210000
Enviva Pellets Sampson LLC
Enviva Pellets Sampson, LLC, Certificate of Coverage NCG210450
Sampson County
Dear Mr. Simon:
On January 29, 2020 and February 19, 2020, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy,
Mineral and Land Resources (DEMLR) conducted an inspection for the Enviva Pellets Sampson, LLC facility located at 5
Connector Road, Faison, Sampson County, North Carolina. A copy of the Compliance Inspection Report is enclosed for
your review. Mr. Justin Spencer, Environmental Compliance Manager was also present during the inspection and his time
and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES
Stormwater General Permit NCG210000 under Certificate of Coverage NCG210450. Permit coverage authorizes the
discharge of stormwater from the facility to receiving waters designated as Panther Creek, a Class C. Sw water in the Cape
Fear River Basin.
As a result of the inspection, the facility was found to be compliant with the conditions of the NCG210000 permit. Please
refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs
assistance with understanding any aspect of your permit, please contact me at [phone] or via e-mail at
[e-mail].
Sincerely,
7u4� A'*i
Melissa Joyner
Environmental Specialist
DEMLR
Enclosure: Compliance Inspection Report
Representative Outfall Status (ROS) Request Form
ec: Justin Spencer, Environmental Compliance Manager(via email)
cc: FRO —DEMLR, Stormwater Files
North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street,Suite 7141 Fayetteville,.North Carolina 28301
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Compliance Inspection Report
Permit: NCG210450 Effective: 08/01/18 Expiration: 07/31/23 Owner: Enviva Pellets Sampson LLC
SOC: Effective: Expiration: Facility: Enviva Pellets Sampson,LLC
5 Connector Rd Us117
County: Sampson
Region: Fayetteville Faison NC 28341
Contact Person: William Bill Simon Title: Phone: [phone]
Directions to Facility:
plant is located off us 117 south,across from state highway 403 and 1000 yards from interstate 40 exit 355.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
On-site representative Justin Spencer 304-654-2054
On-site representative William Bill Simon 919-717-4933
Related Permits:
Inspection Date: ot/2912020 Entry Time: 01:30PM Exit Time: 04:58PM
Primary Inspector: Melissa A Joyner /"Cr Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Timber Products Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG210450 Owner-Facility:Enviva Pellets Sampson LLC
Inspection Date: 01/29/2020 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Ms. Melissa Joyner met with Mr.Bill Simon, EHS Manager and Mr.Justin Spencer, Environmental Compliance Manager, at
the Enviva Pellets Sampson, LLC facility to conduct an industrial stormwater inspection.The Stormwater Pollution
Prevention Plan (SPPP)was reviewed and appeared orderly.The site map will need to show the percentage of each
drainage area which is impervious.The Pollution Prevention Team will need to be updated, removing Mr.Steve Schaan and
replacing him with Mr.Jason Ansley,the new General Manager.The statement that there have been spills or no spills for
the past three years should be annually documented in the SPPP. Under the Spill Prevention and Response Procedures,
the individuals involved should sign and date their names in a written list which has been updated to remove Mr.Steve
Schaan as a secondary emergency contact, replacing him with Mr.Jason Ansley.The semi-annual facility inspections
should include inspections of the ditches, riprap dissipators and the silt fence.The Analytical and Qualitative monitoring
records were reviewed, indicating"No Flog'.
The facility outdoor grounds were inspected.The AST should have a secured locking mechanism on the valve when it is not
in use.The ditch leading to Pond 2 has erosion on a side slope which should be stabilized.There was a slight discoloration
of the water in this Pond and in the water being discharged from Outfalls 3 and 4 at Pond 2 due to a freshwater pipe break
the previous day. Booms were in the process of being installed during the inspection. Outfalls 1 and 2, located at Pond 1
were not able to be inspected due to time and location constraints.A second inspection occurred on February 19,2020 to
inspect these Outfalls which were not discharging.
Only Qualitative monitoring has occurred at Pond 1,with Outfalls 1 and 2 because there was a misunderstanding that the
facility had representative outfall status and that Analytical monitoring was not required. Both Analytical and Qualitative
monitoring has occurred at Pond 2,with Outfalls 3 and 4.A Representative Outfall Status Request(ROS)Form will need to
be submitted to the Fayetteville Regional Office. Until Representative Outfall Status is requested, both Analytical and
Qualitative monitoring needs to occur at one of the outfalls at Pond 1 and Pond 2.
Page 2 of 3

Permit: NCG210450 Owner-Facility:Enviva Pellets Sampson LLC
Inspection Date: 01/29/2020 Inspection Type:Compliance Evaluation Reason for Visit: Routine IF
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? 0 ❑ ❑ ❑
#Does the Plan include a General Location(USGS)map? E ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? 0 ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? 0 ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ 0 ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? N ❑ ❑ ❑
#Does the Plan include a BMP summary? E ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan(SPRP)? 0 ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? E ❑ ❑ ❑
#Does the facility provide and document Employee Training? E ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
#Is the Plan reviewed and updated annually? M ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? E ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment: Qualitative monitoring has been occurring at Ponds 1 and 2 with Outfalls 1 2 3 and 4
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ N ❑
Comment: Analytical monitoring was not conducted at Pond 1 with Outfalls 1 and 2 because there was a
misunderstanding that the facility had representative outfall status and that Analytical monitoring
was not required It was conducted at Pond 2 with Outfalls 3 and 4
Permit and Outfalls Yes No NA NE
#Is a copy of the Permit and the Certificate of Coverage available at the site? E ❑ ❑ ❑
#Were all outfalls observed during the inspection? E ❑ ❑ ❑
#If the facility has representative outfall status,is it property documented by the Division? ❑ ❑ 0 ❑
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ ❑ E ❑
Comment:
Page 3 of 3

FOR AGENCY USE !DLy
Division of Energy,Mineral & Land Resources Dare Received
Yeaz Month ay
Stormwater Program
National Pollutant Discharge Elimination System
Environmental REPRESENTATIVE OUTFALL STATUS (ROS)
Quality REQUEST FORM
If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the
permittee may petition the Director for Representative Outfall Status(ROS). DEQ may grant Representative
Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
If Representative Outfall Status is granted,ALL outfalls are still subject to the qualitative monitoring
requirements of the facility's permit—unless otherwise allowed by the permit(such as NCGO20000)and DEQ
approval. The approval letter from DEQ must be kept on site with the facility's Stormwater Pollution
Prevention Plan. The facility must notify DEQ in writing if any changes affect representative status.
For questions, please contact the DEQ Regional Office for your area (see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (or) Certificate of Coverage
2) Facility Information:
Owner/Facility Name
Facility Contact
Street Address
City State ZIP Code
County E-mail Address
Telephone No. Fax:
3) List the representative outfall(s)information (attach additional sheets if necessary):
Outfall(s) is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities? ❑Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? ❑Yes ❑ No
Outfalls have similar monitoring results? ❑ Yes ❑ No ❑ No data*
Outfall(s) is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities? ❑Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? ❑ Yes ❑ No
Outfalls have similar monitoring results? ❑Yes ❑ No ❑ No data*
Outfall(s) is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities? ❑Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? ❑Yes ❑ No
Outfalls have similar monitoring results? ❑ Yes ❑ No ❑ No data*
*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
circumstances will be considered by the Regional Office responsible for review.
Page t of 3
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or, attach a letter or narrative to discuss this information.) For example,describe how activities and/or
materials are similar.
5) Certification:
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application,record,
report, plan,or other document filed or required to be maintained under this Article or a rule implementing this
Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case
under this Article;or who falsifies,tampers with,or knowingly renders inaccurate any recording or monitoring device
or method required to be operated or maintained under this Article or rules of the [Environmental Management]
Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed
ten thousand dollars($10,000).
I hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit
and regional office approval. I must notify DEQ in writing if any changes to the facility or its operations
take place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must
resume monitoring of all outfalls as specified in my NPDES permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing:
Title:
(Signature of Applicant) (Date Signed)
Please note: This application for Representative Outfall Status is subject to
approval by the NCDEQ Regional Office. The Regional Office may inspect your
facility for compliance with the conditions of the permit prior to that approval.
Final Checklist for ROS Request
This application should include the following items:
❑ This completed form.
❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status, unless all information can be included in Question 4.
❑ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas, industrial activities, and raw materials/finished products within each drainage area.
❑ Summary of results from monitoring conducted at the outfalls listed in Question 3.
❑ Any other supporting documentation.
Page 2 of 3
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request t
Mail the entire package to:
NCDEQ DEMLR at the appropriate Regional Office (See map and
addresses below)
Notes
The submission of this document does not guarantee Representative Outfall Status(ROS)will be granted as
requested. Analytical monitoring as per your current permit must be continued,at all outfalls, until written
approval of this request is granted by DEQ. Non-compliance with analytical monitoring prior to this request
may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for
review.
For questions, please contact the DEQ Regional Office for your area.
nptan
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778 Washington Regional Office
943 Washington Square Mall
Phone [phone] Washington, NC 27889
FAX [phone]
Phone [phone]
Fayetteville Regional Office FAX [phone]
Systel Building,
225 Green St., Suite 714 Wilmington Regional Office
Fayetteville, NC 28301-5094 127 Cardinal Drive Extension
Wilmington, NC 28405
Phone [phone]
FAX [phone] Phone [phone]
FAX [phone]
Mooresville Regional Office
610 East Center Ave. Winston-Salem Regional Office
Mooresville, NC 28115 585 Waughtown Street
Winston-Salem, NC 27107
Phone [phone] Phone [phone]
FAX [phone] Water Quality Main FAX [phone]
Raleigh Regional Office Central Office
1628 Mail Service Center 1612 Mail Service Center
Raleigh, NC 27699-1628 Raleigh, NC 27699-1612
Phone [phone] Phone [phone]
FAX [phone] FAX [phone]
Page 3 of 3
SWU-ROS-2009 Last revised 12/30/2009