NCGNE0656_COMPLETE FILE - HISTORICAL_20100318

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
NCGNE
DOC TYPE
HISTORICAL FILE
DOC DATE
❑ 3 o I o
YYYYMMDD

NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
March 18, 2010
M. Nancy Be mont
FedFx Gr nd Package System, Inc.
1000 dEx Drive
M n Township, PA 15108
Subject: No -Exposure Certification NCGNE0676
FedeEx Ground
204 South Granby St., Hertford, NC 27944
Perquimans County
Dear Ms. Beaumont:
The Division has reviewed your submittal of the No -Exposure Certification for Exclusion from NPDES
Stormwater Permitting form. Based on your submittal and signed certification of no exposure at the above
referenced facility and on site visit by Mr. Samir Dumpor of the Washington Regional Office of the Division of
Water Quality , the Division is granting your conditional exclusion from permitting as provided for under 40
CFR 126.22(g), which is incorporated by reference in North Carolina regulations.
Please note that by our acceptance of your no -exposure certification, you are obligated to maintain no -exposure
conditions at your facility. If conditions change such that your facility can no longer qualify for a no -exposure
exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater discharge.
Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Your conditional no -
exposure exclusion expires in five years (March 18, 2015). At that time you must re -certify with the Division, or
obtain NPDES permit coverage for any stormwater discharges from your facility.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain
environmental permits that may be required under other federal, state, or local regulations or ordinances.
If you have any questions or need further information, please contact Samir Dumpor at [phone], or
at [e-mail].
Sincerely,
Original Signed by
Al Hodge
f,,r Coleen H. Sullins
cc: /Washington Regional Office
FedEx Ground, Attn. Senior Manager, 204 South Granby St., Hertford, NC 27944
Stormwater Permitting Unit, (Attn. Sarah Young - No -Exposure Files)
North Carolina Division of Water Quality tntemet: w�s��,netvatcrqualit� exb
943 Washington Square Mall Phone: [phone] One
Washingtun, NC 27889 FAX [phone] NorthCarolina
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Division of Water Quality / Surface Water Protection
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
NCGNE0000
NO EXPOSURE CERTIFICATION
FOR AGENCY USE GNIN
Date Received
Year
Month Day
to
b
Cettiricate of Coverage
NICIGINI
Please check here if this is a renewal: ❑ RENEWAL
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials'and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DWQ must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and.similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling; and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is n
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, jvu
certify that a condition of no exposure exists at this facility or site and are obligated to comply with th
terms and conditions of 40 CFR 122.26
(g) P1-1
You are required to reapply for the No Exposure Exclusion once everV five 5 ears.♦
rn cfl C
For questions, please contact the DWO Regional Office for your area. (See page 6) o FA
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name FedEx Gryulk/ )0AGuR6,6
Contact IVRNCY 6E94111D1VT .
Street Address loop f edEx,
City I lR° State )04 ZIP Code /.5109
Telephone No. 1 _?6o2 -7Se17 Fax: 7--1 Ta)
Page 1 of 7 FEB 1 6 2010
SW U-NE•021309
Last revised 2/13/2009

L l
t
NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name , Fea��X
Facility Contact Sen r A (.
Street Address zo'56idAC�ra� f
City 14-ew-7Fozi) State IVC ZIP Code
County er _
Telephone No. Fax: c5�
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). ai3in RF 17 A,) .SE on k 'V P61/1C-C
a -51 ,b.e_ eA Al, Oo tYo
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes "o
5) Is this a Federal facility? ❑ Yes 2<0
0
6) Latitude-�P0/0� /7" Longitude 76 o271 g �J (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
V Existing Date operation began '3 / 2I I zoo
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes ®-No
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code:
10) Provide a brief description of the types of industrial activities and products produced at this facility:
fl)AC_UTA6-` 61h5;chAfl61- n7P [,A-rA V il&e) On -Sift 5u17jf(Arth
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
m` o
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
SW U-NE-021309
Page 2 of 7
Last revised 2/1312009

NCGNE0000 No Exposure Certification
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes [No ❑ NIA
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks ❑ Yes I(No ❑ NIA
c. Materials or products from past industrial activity
❑ Yes
MNo
❑ NIA
d. Material handling equipment (except adequately maintained vehicles)
❑ Yes
11KNo
❑ NIA
e. Materials or products during loading/unloading or transporting activities
❑ Yes
6'No
❑ NIA
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes (.11No ❑ NIA
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes TNo ❑ NIA
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes OKNo ❑ NIA
the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes VINo ❑ NIA
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes 2No ❑ NIA
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not
❑ Yes [;),No ❑ NIA
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
i. Empty containers that previously contained materials that are not properly stored
❑ Yes DrNo ❑ NIA
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers
❑ Yes "o ❑ NIA
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or UK Yes ❑ No ❑ NIA
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any Wl es ❑ No ❑ NIA
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
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Page 3 of 7
S W U-N E-021309
Last revised 2/13/2009

t
NCGNEDD00 No Exposure Certification
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers ❑ Yes ❑ No !fN/A
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored ❑ Yes ❑ No &6N /A
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund ❑ Yes ❑ No I1i'N/A
Amendments and Reauthorization Act (SARA) water priority chemicals`?
d. Is secondary containment provided for hazardous substances" designated in 40 ❑ Yes ❑ No V`N/A
CFR §116?
e. Are release valves on all secondary containment structures locked? VYes ❑ No ❑ N/A
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ YesV4o ❑ N/A
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste ❑ Yes i$'No ❑ NIA
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes WINO ❑ N/A
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
Footnotes to Questions 14) c. & d.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions trom reporting requirements of Title III SARA 313 in 40 CFR
§372,38.
"`Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities
of the hazardous substances listed in 40 CFR §117.3.
5 W U-N E-021309
Page 4 of 7
Last revised 2/13/2009

NCGNEOOOO No Exposure Certification
16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes W No ❑ NIA
b. Does your facility have coal piles on site? ❑ Yes 0//N o . ❑ NIA
c. Does your facility store other fuel sources outside in piles, such as wood chips, ❑ Yes M No ❑ NIA
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g., ❑ Yes ZNo '❑ NIA
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity:
e. If you answered yes to d., are those emissions permitted by an Air Quality Permit? ❑ Yes ®'No ❑ NIA
Please specify:
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Page 5 of 7
SWU-NE-021309 Last revised 2/13/2009

NCGNE0000 No Exposure Certification
17) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to submit a no exposure certification form once every five (5) years to the North Carolina
Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into
which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water
Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
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: ,Wry C. Swart, P.E.
Title: Managing Director -Environmental Servirwc
(Signalu of App ant) (Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
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).
There is currently no fee for a No Exposure Exclusion.
Page 6 of 7
SW U-NE-021309 Last revised 2/13/2009

NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
0 This completed application and all supporting documentation.
A map with the location of the facility clearly marked.
❑ If this is a renewal, indicated current NCGNE number in Question 7.
❑ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWQ Regional Office for your area.
DWQ_Regional Office Contact Information:
Asheville Office ...... [phone]
Fayetteville Office
... [phone]
Mooresville Office
... [phone]
Raleigh Office ........
[phone]
Washington Office ...[phone]
Wilmington Office
... [phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 7 of 7
SWU-NE-021309 Last revised 2/13/2009

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FedEx Ground
Environmental Services
P.O. Box 108
Pittsburgh, PA 15230
PHONE [phone] FAX [phone]
LETTER OF TRANSMITTAL
.BAN x 9
SENT: 11 FedEx I CERTIFIED MAII, x
TO:
Stormwater Permiting Unit
DATE:
January 12, 2010
Division of Water Quality
No Exposure Certification
1617 Mail Service Center
RE:
Ralei h, North Carolina 27699-1617
WE ARE SENDING YOU:
x Enclosed
File
Partially Executed
Drawings
copies
x
I Fully Executed
COPIES
DATE
DESCRIPTION
A lication for exclusion from a Stormwater Permit based on No Exposure.
THESE ARE TRANSMITTED as checked below:
For Execution
A rcrved as Submitted
Rctum Co s for File
For Your Records
A roved as Noted
Resubmit for Approval
x
As Requested
Returned for Correction
Return Corrected
x
As Required
Other turned
For Your Signature
REMARKS:
CC: File
FROM: Nancy Beaumont
Environmental Compliance Specialists
412-262-7347
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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen N. Sullins Dee Freeman
Governor Director Secretary
October 20, 2009
Ms. Nancy Vincek
Crop Production Services
1160 Brake Road
Rocky Mount, North Carolina.27801
Subject: Conditional No Exposure Exclusion NCGNE0656
NOV-2007-DV-0298
Crop Production Services, Princeton
Wayne County
Dear Ms. Vincek;
The Division has considered your second No Exposure Certification received August 25, 2009, for
your Princeton facility. Your submittal included a three -page transmittal letter, a completed five -
page DWQ No Exposure Certification form, a three -page Conceptual Environmental Plan Narrative
by Bay Environmental with appended figures showing the layout and construction details of your
proposed site modifications for no exposure. (There is no permitting fee for the No Exposure
Exclusion from permitting, and appropriately none was included in your submittal.) As I conveyed
to you by phone last month, DWQ has determined to grant your second request for the
Conditional No Exposure Exclusion from Permitting. I apologize for my delay in following up with
this written notification. Our determination was based on the following considerations.
-Recall-that"in`response to-DWQ's-November f7; 2008, inspection for tf 6 specific purpose of
determining whether no exposure conditions had been achieved at the site, DWQ denied
your previous first request, based in part on the reported and observed problems with
deploying a tarp over the large lime pile on your site. We feel that your more recent
submittal provides a more reliable stormwater control approach.. We commend your
resourcefulness in subsequently responding to what we all should have recognized at the
time as an inadequate initial approach.
• We believe that your proposal to install stormwater treatment and control measures as
described in the transmittal letter and in the Conceptual Environmental Plan Narrative, and
generally consisting of re -grading specific site areas, planting grassed and otherwise
vegetated areas, windbreaks, and infiltration areas, represents an innovative and effective
approach to stormwater and nutrient discharge control given the site circumstances at
Princeton. Some aspects also represent a -new approach for North Carolina's NPDES
stormwater permitting program.
• Your transmittal letter reported site modifications already achieved to reduce exposure in
response to our discussions about your first request for No Exposure. And, this second
submittal also included additional minor modifications and improvements on several other
of the potential exposure areas as identified in subsequent correspondence with DWQ.
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 919-807-M k FAx: [phone] Customer Service:1-877-623-6748
Internet: www rvvaterquality.org
An Equal opportunity 4 Affirmafve Action Employer
One
NorthCarolina
Natumlly

Ms. Nancy Vincek
Crop Production Services
October 20, 2009
Page 2bf2
• We considered both the sensitivity of the receiving water, and the realistic constraints at
the Princeton site. The receiving water is classified as WS-IV (Water Supply Watershed IV)
and NSW (Nutrient Sensitive Water). North Carolina has stormwater control programs
especially crafted to protect selected sensitive waters in both of these classifications.
Generally We try to pay special attention to these waters. We believe your proposals will
prove to provide exemplary protection for'this sensitive receiving water.
As far as our. consideration of realistic site constraints,. our perspective is that it is not
realistic to expect that no exposure conditions could be fully achieved and perfectly
maintained in the long run without considerable expense, given the site configuration and
site activities at Princeton. Our granting of the Conditional No Exposure Exclusion from
Permitting for Princeton is somewhat experimental for us in that while the site may not
fully meet our previous and conventional concept of no exposure, we believe your
proposals provide a degree of protection that might not be so readily achievable under the
conventional elements of a stormwater permit. Consequently, for the moment we consider
our agreement to grant the requested exclusion from permitting For Princeton as a one
time regulatory arrangement that we intend to track to see if it will prove as protective as
we hope. Thanks for working with us in this regard.
Please note that by our acceptance of your No Exposure Certification you are obligated to maintain
the. conditions, features, and improvements identified in your submittal package included with
your signed No Exposure Certification received August 25, 2009. Your Conditional No Exposure
Exclusion from Permitting expires in five years (October 19, 2014). At that time you -must re-
certify with the Division, or obtain NPDES discharge permit coverage for any stormwater
discharges from the Princeton site.
Your conditional exclusion from permitting does not affect your facility's legal requirements to
obtain environmental permits that may be required under'other federal, state, or local regulations
or ordinances.
- - If--you-have-any-questions,-please-contact either—Thom-Edgerton-in-Washington-at-(252)-94
6481, or me in the Raleigh central office at [phone].
Sincerely,
Ken Pickle
DWQ Stormwater Permitting Unit '
cc: DWQ Washington Regional Office, AI Hodge
DWQ Washington Regional Office, Thom Edgerton
DWQ NPS Assistahce and Compliance, Shelton Sullivan
"DWQ SPU, Bradley. Bennett.
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Markers
Name: Discharge Site - NCG020631
Short Name: Dschrg
Coordinates: 035' 27' 22.9" N, 0780 07' 43.7" W ,
Comment: Martin Marietta Materials, Inc. Goldsboro Quarry, subbasin 03-04-06, Neuse
River Basin, Wayne County, unnamed_trib_utdr to=Cittle River-,C-class=WS
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Location of Washington Regional Office
Page 1 of I
YWASHR"*�ON
V WA�C
000
Regional Office
943 Washington Square Mall • Washington, NC 27889
Phone: [phone] • Fax: [phone] • Courier: 16-04-
01
DENR HOME WASHINGTON HOME
Directions:
Going east: Take US 64 from Raleigh to US 17 in Williamston. Go south on US 17 approximately 18 miles. Turn
left at the second traffic signal (at McDonalds) into the Mall property. Pass Belk and we're located on the left.
Going west: Take US 264 into Washington. Turn right at US 17 North. Turn right at the 2nd traffic signal (at
McDonalds) into the Mall property. Pass Belk and we're located on the left.
Going north: Take US 17 North into Washington. Turn right at the 7th traffic signal (at McDonalds) into the Mall
property. Pass Belk and we're located on the left.
Going south: Take US 17 South into Washington. Turn left at the 2nd traffic signal (at McDonalds) into the Mall
property_ Pass Belk and we're located on the left.
http://www.enr.state.ne.us/regionaloffices/offices/washwhere.htmi 2/18/2008

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OKI
MATERIAL SAFETY DATA SHEET
Effective Date: 1-1-98
1 - IDENTIFICATION
CHEMICAL NAMr CHEMICAL :=ORMULA
MOLECULAR WEIGHT
Limestone Not a tthcable
Not applicable
TRADE NAME
Crusted Stone,
SYNONYMS
DOT IDENTIFICATION NO.
Aggrolal9, AgGtno, flntrt Lime, Flem(Ae Bawl,
None
FFiiwn qI dnt, ManUtaCturatt Sartd. MinorA Filler_ Screoninc s
2 - PRODUCT AND COMPONENT DATA
COMPONENT(S) CHEMICAL NAME
CAS REGISTRY NO.
% (APPROX.)
EXPOSURE
I IMITS
I.irneslorre'
1317-65-3
10D
See
SHclion
6
'Composition varies naturally - typically contains quartz (cryslaiiina silica)
I
148013-60-7
3 - PHYSICAL DATA
APPEARANCE AND ODOR
SPECIFIC GRAVITY
Angular gray, vAtito and tan particles ranging In size from
7..,' - 2.8
powder to boulders. No odor.
BOILING POINT JAI 1 Afm.):
VAPOH ;DENSITY IN AIR (Air W 1)
No, apphuible
Nel appticado
VAPOR PRESSURE (mm Fig 0 20' C)
% VOLATILE BY VOLUME (C 1CO- F)
No, appltcable
()°ro
[vAPORATION RATE (at 1 Aim, and 4' C: n-outyl acetate = I)'
SOLUBILITY IN WATER
0
0
4 - REACTIVITY DATA
STABILITY
CONDITIONS TO AVOID
Stable
AV6d cwtact : im incompatible materials (See bdtow).
INCOMPATIBILITY avoiay
(,A)alad N'qh powArttrl oxidiAnj ageols such as flaurirwe, txxon trifiuorlde, morine tnfluoride, manganese trittotimle, arttl oxygen difluorido may cause too
arKVw extrlo",ions, Stlica dissofVes in hydrollLIOM acid PfOdudngl a COMSi1te gas-r0con totrat uodde.
HAZARDOUS DECOMPOSITION PRODUCTS
Silica -containing iospirable dust panicles may be generated by ttandi;ntg.
HAZARDOUS POLYMERIZATION
Net known to polymerize
Iv1SDS•ROC 1.1.98

5 - FIRE AND EXPLOSION HAZARD DATA
ITLASHPO1NT (Methtkl usod)
FLAMMABLE LIMITS IN AIR
Not (terrlrnatAP j
Not tlamrrlablo
EXTINGUISHING AGENTS
None fr!qulred
UNUSUAL FIRE AND EXPLOSION HAZARDS
Contaci with powerful oxidizing agents may cause fire andlor explosions (Sea SActo) 4 of this MSDS).
6 -TOXICITY AND FIRST AID
EXPOSURE LIMITS (wr%en exposure it) this Inuducl and olher chnmtcals is ccncutr®nt, the exposure firm mrtsl De clefintrd in tho workplace,)
Unless specified othemise. limits are expressed as eigtll•hour LmR•:veighted averages ;TWA). Limits for crislobarile and iddymile) other forms of
cq-talline : iliva) are equai 10 one-half of the limits for quan2,
ABBREVIATIONS: TLV = threstlold limit value of the American Contprpnco et Governmental Industrial Hygionisls IACGIH); MSHA PEL - permissible
oxposuro limit of tho Mine Safety and malth Administration (NISHA); OSHA PEL - penrr(Sciblu exposure limit of the Octupaticrial Safely and Hsalth
Administration (OSHA): mgfm'- milllgrams of substance per tunic moler of air.
Limestone (Calcium Carbonate): TLV = 10 mg/rri': OSHA PEL - 15 mglrn' (total dust); OSHA PEL = 5 mglm' (respirable traction)
Other Particulates- TLV = 10 rrig!m) (inhalablOotal particulate, not othorwiso classifiod), TLV a 3 mq!m' (+espirabte particular not othemise cfassiheci);
OSHA PEL = 15 m9W (total particuar, not other%rise regulated), OSHA PEL - 5 mp.4n' (respiraolo particular, not otherv.ise regulated)
Respirable Crystalline Sltice (quartz): TLV = 0.1 mgrm'; MSHA and OSHA PEL = 10 r1g4n3 + (%SiO, * 2). MSHA-Proposed afxl OSHA -Proposed PEL
0.1 m0n,
Respirable Dust: MSHA rtrxi OSHA PEL - 101ngim, + ( sio, + 2)
Total Dust: MSHA PEL w 30 rnWrns r (N.SiO? + 3) OSHA VEL = 30 mvrn' + ( siO2 , 2)
ACGIH, h1SHA, and OSHA have eerpim4VU ullecu ere n7t h4p.1y to occur in me wnftuice ptoviucd mpo:trro 1ovul* Ua Nm aAc mrt the appmprui:n TLVsfPELs.
H"evet, tecau9V ul thv W0Q vpr0t Vrr In irrUrv�tutr su:,cCpuW6ry, krw¢: cr ave ir-xis may to ap rrcllrTd:o 101 srlrm tn*v0;.11: urclydirxy persanls Aim pfa-oxi5Ur,1 riVbcnl
cova:t*ns Srrc1 its those. QF?5` *ea netdw.
MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE
InWiling respirable du%t andror crystalline silica may aggravato existing respiratory sysiom disease(s) andior dysfunctions, Exposure to dust may
aggravate exist ng skin 8rxJlor eye conditions.
PRIMARY ROUTES) OF EXPOSURE: 21 Inhalaw; 0 skin [0 Ingestion
ACUTE TOXICITY
EYE CONTACT: Direct mnlact Aith dust may cause irritation by mechanical abrasion.
SKIN CONTACT: Direct contact may cause irritation by mechanical abrasion.
SKIN ABSORPTION: Not expKied to be a significant exposure route.
INGESTION: Expected to he practically non -toxic. Ingesbon of large amounts may cause gastrointestinal irritation and blockage,
INHALATION: Dusts may irritatil the nose, Ihroal, and iespsratory trait by mechancial abrasion, Cougning, sneezing, and shortness, of breath may nocur
follov ng exposures in excess of appropriate exposure limils.
FIRST AID
EYES. Immediately flush eye(s) with plenty of clean v.-aioy for al least 15 minulos, :vhile hdlc;ng the oyalkf(s) Open. OCCaSronaiiy fill the cyolld(s) to ensure
thorough rinsing. Beyond flushing, do not attempt to remove rnaterar groin trip eyels). Contact a physician if irritation persists or Ulm develops.
SKIN: Wash with soap and water. Contact a physician if irritation persists OF later develops.
tNGESTION: It person is <rOnscruus, UivQ large quantity of vWr f and induce vomiting; noavever, never atlempt to make an unconscious person drink nr
vomit, Gat immediate medical a :ontivn,
INHALATION: Remove 10 Umn air. Dust in throat and nasal passages sWuld rsew spontarwously. Contact a physician 4 irritation persists or later
develops.
MSDS-ROC 1-1-98

CHRONIC 1 OXtCt l'y
Prolonged and repeatrrd trrtralation of respirable crystalline ailica-wntaining Gust in excess of appropriato axpo sort) limits ha% ratr!Ee(i sift( JSis, a lung
rdisea,%a. Not all individuals with silicosis will exhibit symptoms (sigms) of the disea"e. However, silicosis can be progressive, aril symptoms can appear al
any time, evon yoars after oxpmuro has coasee. Symptoms of silkxmis may hw.ludea, but are not limitoa le, the IoII( .ving; Shprtrurss of breath: diBicu4y
brealhiny mlh or wilhoul exertion; coughing; diminishod work capacitf* diminished chest expansion; reduction of lung vdurme; right heart entargerneni
an(Vor Mihrre. Smoking may increase the risk at <;aveloping lung disorders, includ,n omphyrmMa anri lung cartcoc Parsons with silicosis Niue :err
increased risk of pulmonary inleCli0n,
Hw.tpratrlc dust witaining ntrMj broken silica particics has boon shcrwr3 to be more hazardous to animals in laboratory tests than respirable uu:tf
containing older sitica partirles of similar size. Respbabrie silica parlidas which had agod for sixty days pr tore Showed k sn lung injury in animals titan
equal exposures of respirable dust containing newly bmken particles of silica,
l here? Tire reports in the liserature sugge0ng that excessive crystalline silica exposure may ue associaled with advorso health ottects involving the kidney,
sclerodcrrna (thickening of tnet skin caused by swelfintf aril thickening of fibrous (issue) and other autoirnmune drsarders. Hcnvevor, this ovldence has
been obtained primarily from case: reports involving individuals workirN in high exposure sili)atmns or IhoSo who have already developed silicosis; acid
tllerrelow, tills evi(1Hnce (d(leS not ConclusiAly prove a Glsual folatiorzhip between silica or silicosis and these adverse healln effects. Several stucies of
pi'r ens with silicosis also indicate an increnswIl risii of i1ti'.vAfUt)rrlg ttrrtg cancer, a risk thal u)Creasos Mtn ihD duta;= of exposure. Many 01 tfef(S sweliei
Of $11lf,`ptiCS &.1 rX)t aCX' t)lrrt tot Italtj caret confo rrulem. esPKIlrlly smoking.
Lirnesiono is not fisted a$ a carcinogen oy the Interrtat+or•,al Agency ar Cancer (IAAC), the National Toxicology Program (N1 ills or the Occupatiprual Safety
and Healtn Administrako (OSHA), In OV000r 1996, an IAHC Y:orking Group re-asws%ing cr:sollmo silica, a component of this paxlkirl, des;gnaleo
crysttaFino silica as carcinogenic (Group t). The NTP indicates that crystalline silica is reasonably anlicipaloo to be a carcinogen (Croup 2).'thesti
cdawQ- iwtoxm are based on tneirassassmeni of sufficiont evidence of carr inogenicity in conain experimental animals anc on selected epidemiological
studios of watkers Exposed to crystalline Silica,
7 - PERSONAL PROTECTION AND CONTROLS
RESPIRATION PROTECTION
For re;spirabto quartz levots that exceed cr are likely to exreetd err 8ht•711:A of i?.1 rnlym', a NIOSHi MSHA approved dust respir,7lor must be worn. For
respirablo quartz levels that exceed or are likely to exceed an 8hr-TWA of 0.5 nrgrrol, a \IOSHlh4SHAapproved HEPA litter respirator must be worn. If
ie9pirabie quartz levels exceed or aro fikofy to exceed an 8hr-T1r° A of 0.5 mg?rn°, a NIOSWNISHA adrproveld positive pressuro, full face respiotor or
equivalent is required, Resdsimlot use must comply v.iM applicable MSHA or OSHA standards, which include provisions for a user training pm9ram,
respirator repair and clearing, respirator fit testing, and ottier rec}uirernorrty,
VENTILATION
LC I exhaust Or general ventilation adoquato to maintain exposures t)elp.v appropriale sxposuro Irtnim,
SKIN PROTECTION
See -Hy(jieno- section below.
EYE PROTECTION
Safety gtasf:es Wilh side 5hiekdS should W worn as minimum protection. Dust goggles should he worn wrson excessively (visible) musty roomons are
presoot or aro anticipated,
HYGIENE
Wash dust•oxposed skin with soap and wat9r before eating, drinking, smoking, ano using ILAet lacIi€ies. Wash work clothes atlw each use.
OTHER CONTROL MEASURES
Raspir{rble must and quartz levels should be morutorod regularly. Dust and quart] levels in excess of appropriate exposur© limits should be redrx;ed by all
foauible engineering controls, inducting (bul not limited IC) well suppression, ventilation, tsnx;ess enclosure, and enclosed erntgoyoo work S1,3 011S,
MSOS-ROC 1.1.98

Respirabfo crystalline aica•conWriing oust rn,1y be generate* during proceswig, twndliny. and storage. The por!;oirtl prolaction and autUsNx Womstupu ur
Section 7 of Me fASDS slwuld Do applied as appf0pnalo.
Do not stare near IOW and Deletages or wMittog materials.
STEPS ro 6E TAKEN IN CASE VATERIAL 15 RELEASED OR SPILLED
I ho pemonal vicitectlon and contras tda3ntifiea in Soctmn 7 of Me MSOS should co apoliod as appropriato.
Spilled materials, where dust can go generaled, mayoverexpose cleanup personnel to iosl*aMe crystalline sifica-cornairrrlg dust. Wearrlrt of smiled
material anVnr use nl rospiralor p;wective equipment may be necessary. Do not dry Sweep Spilteo material.
Nan- of she congXU*nts in Irks product ale subject t0lhe rerouting I&ILlirP.mtenlS 01 Title ill of SARA, 1986, and 40 (.f R 172.
WASTE DISPOSAL METHOD
Pickup Ant: muse clean malorials. Dssposo of wasw malu)nals only in accordance -milli applicable ledoral. Sttilo, aM k=l laws and regulations,
10 -TRANSPORTATION
DOT HAZARD CLASSIFICATION
NonI4
PLACARD REQUIRED
None
LABEL REQUIRED
Label as requuad Dy the OSHA Ha2.aid Cot—urnrabDri standard 129 CFR 1yt0,iZD I)j and applicable state and local larvs and regdatrats.
For Further Information Contact-
Rockydele Quarries Corporation
P.O. Box 8425
Roanoke, VA 24018
Phone. [phone]
Date of Preparation: January. 1998
NOTICE: Rockyd ate 1Juarrles Corporation believes that the Informatfon contained on this Material Safety Data Sheet is accurate. The suggested
proceaurea are based on experience as of the date of publicatlon.They are not necessarlly all-inclusive nor fully adequate In every Circumstance.
Also. the suggestions should not be confused wlth nor followed in violation of applicable laws, regafatlona, rules or insurance requirements.
NO WARRANTY IS MADE, EXPRESSED OR IMPLIED, OF MERCHANTABILIM FrTNESS FOR A PARTICULAR PUROSE OR OTHERWISE.
MSDS-ROC 1.1-98

Pickle, Ken
From: Pickle, Ken
Sent: Monday, April 05, 2010 10:57 AM
To: 'kirk.►[e-mail]'
Cc: dolman, Sheila; Hopkins, Arni; Hodge, Al; Overcash, Keith; Fisher, Robert; Edgerton, Thom;
Bennett, Bradley
Subject: CPS Princeton, NC DWQ
Kirk,
Nice to talk with you last Thursday. As I reported to you verbally Thursday, DWQ's Washington Regional Office and
DWQ's central office Stormwater Permitting Unit, have discussed the requested extension, and we are both agreeable
to an extension to April 30 for the work you are undertaking for stormwater controls at Princeton, in accordance with
our previous agreement under a stormwater No Exposure Exclusion from Permitting. Thanks for your continuing efforts
on this project.
Ken Pickle
DWQ Stormwater Permitting Unit
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties.

Dollar General, Fairview, North Carolina
ATC Job # 45.27739.0047 — December 23, 2009
Page 16
experienced soils engineer to provide information on which to base a decision as to
whether the design requirements are fulfilled in the actual construction. If you wish,
we would welcome the opportunity to provide field construction services for you
during construction.
The analysis and recommendations submitted in this report are based upon the data
obtained from the soil borings and tests performed at the locations as indicated on
the Boring Location Diagram and other information referenced in this report. This
report does not reflect any variations which may occur between the borings. In the
performance of the subsurface exploration, specific information is obtained at
specific locations at specific times. However, it is a well known fact that variations in
soil and rock conditions exist on most sites between boring locations and also such
situations as groundwater levels vary from time to time. The nature and extent of
variations may not become evident until the course of construction. If variations then
appear evident, it will become necessary for a reevaluation of the recommendations
for this report after performing on -site observations during the construction period
and noting characteristics and variations.
IT ASSOCIATES INC. Environmental, Geotechnical and Materials Professionals
i

Crop
Production
Services
March 30, 2010
Via Email or Fax and Certified Mail
Mr, Keith Overcash
NC Department of Environment and Natural Resources
Air Quality Division
1641 Mail Service Center
Raleigh, NC 27699-1641
1
Mr. Ken Pickle
NC Department of Environment.and Natural Resources
Water Quality Division
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Overcash and Mr. Pickle:
Re. Request for Extension
Crop Production Services, Inc,
Princeton, NC, Wayne County
In our Plans for Fugitive Dust Emissions sent on August 28, 2009 and our Conditional No
Exposure Exclusion accepted by the Water Quality Division on October 20, 2009, we
agreed that certain areas of our facility would be graded and replanted with vegetation to
control dust and storm water runoff. These improvements were part of our overall plan to
reduce all fugitive dusts and ensure storm water runoff remained non -impacted from facility
operations.
We have completed the lime containment structure and site grading has been completed
and the planting of grasses and trees were on schedule. As you know, we have
experienced an extremely wet winter and spring. The three (3) inch rain we received
Sunday night and Monday (March 28 and 29) prohibited any further work on this project
until next week or at least April 5. All of the prepared areas are saturated and must be
allowed to dry out before planting. Barring any more drenching rains, we expect to have
phytoremediation areas planted by April 30. We would gladly provide the executed
contract agreements with both the grading firm and the landscape contractor as proof of
our efforts to meet the established deadline.
In consideration of the complexity of this project, our near completion, and the recent
significant rains, we would like to request an extension of project completion to April 30. If
you have additional questions, feel free to contact me or Nancy Vincek [phone].
Your consideration of this request is appreciated

Sincerely,
II-- nn r
Kirk Williams
Environmental Manager
C: Robert Fisher, Washington Regional Office, DENR
Arni Hopkins, Washington Regional Office, DENR
Al Hodge, Washington Regional Office, DENR
Thom Edgerton, Washington Regional Office, DENR
Brandon Brewer, CPS General Manager
Willis Johnson, CPS Princeton
Shannon Peedin, CPS Princeton
Nancy Vincek CPS, Rocky Mount
Environmental Group 7251 W. 4th Street Greeley, CO 80634 PA. Box 1286 Greeley, CO 80632-1286
Phone: [phone] Fax: [phone]

/VewAf&
Crop
Production
Services
1160 Brake Road, Rocky Mount, NC 27801
252-977-0308 Phone
252-973-0761 Fax ri
April 27, 2010
Mr. Keith Overcash
NC Department of Environment and Natural Resources
Air Quality Division
1641 Mail Service Center
Raleigh, NC 27699-1641
Mr. Ken Pickle
NC Department of Environment and Natural Resources
Water Quality Division
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Overcash and Mr. Pickle:
Re. Crop Production Services, Inc.
Princeton, NC, Wayne County
We have completed the projects presented in our Plans for Fugitive Dust Emissions sent
on August 28, 2009 and our Conditional No Exposure Exclusion accepted by the Water
Quality Division on October 20, 2009.
The lime containment structure is currently in use for all lime handling at the Branch. As
of Wednesday, April 21, 2010, the phytoremediation 1 drainage enhancement plan we
proposed has been completed. The one exception is the proposed windbreak planting
on the south boundry. Once we installed the new lime containment, the access drive
was greatly reduced and the plantings would have been too close to the rail road
grass/weed control area to permit planting. The number of trees planned for this area
were incorporated in the plantings on the north boundry.
We thank you for allowing us the extension to April 30 for completing this project. Feel
free to visit any time to see the results.
If you need any further information, please let me know.

Keith Overcash I Ken Pickle
Page 2
April 27, 2010
Sincerely,
Ti[ Q,yt y.�iYt ct
Nancy Vincek
Manager, Operations Compliance
C: Willis Johnson, Princeton
Shannon Peedin, Princeton
Kirk Williams, CPS, Greeley
Robert Fisher, Washington Regional Office, DENR
Arni Hopkins, Washington Regional Office, DENR
Al Hodge, Washington Regional Office, DENR
Thom Edgerton, Washington Regional Office, DENR
Brandon Brewer, General Manager

Pickle, Ken
From: Pickle, Ken
0ent: Wednesday, August 19, 2009 8:13 AM
0: Edgerton, Thom; Hodge, Al
Cc: Bennett, Bradley
Subject: Crop Production Services
Gentlemen,
I got a call late yesterday from a new player for Crop Production Services. Kirk Williams has some corporate
responsibility for —200 facilities across the nation, and he is in their Greely, Colorado office. He reports that there may
be perhaps 25 CPS facilities across North Carolina.
He raised several issues with me, and when he was done I advised him to go ahead and do double duty, and to repeat
them directly to you guys as well. Once you hear from him, let's talk about whether his presentation changes our minds
in any way. I gave him both of your names. His issues:
a) He says the Princeton facility is not PRIMARILY ENGAGED IN the manufacture of blended fertilizers. In support he
relayed that 32% of sales at Princeton are for agricultural chemicals (herbicides, pesticides); 27% of sales are for the
straight fertilizer material, unblended, like straight potash; 22% of sales are for blended fertilizers, the material we have
been at least partially basing our capture of the facility on; and 18% of sales are for seed; his figures total 99% - ok, His
argument is that since the facility is not 'primarily engaged in' (this wording is per the SIC Manual instructions on how to
assign a SIC number, which we typically use to determine if we can capture a facility under NPDES) fertilizer blending, it's
not a SIC 2875 - he says.
Gocountered that regardless of SIC code, DWQ has the authority to bring facilities into the NPDES stormwater program if
we have reason to believe the facility causes, or has the potential to cause either a water quality violation, or the
discharge of pollutants. But I did acknowledge that we would consider this new information, to see if it changed our
approach to Princeton.
I further countered that I had been on the EPA stormwater regulators listserve bulletin board, and received unanimous
agreement from those state regulators responding that this type of activity is regulated under SIC 2875 in several states.
I further countered that when we get a substantive complaint at a facility, we cannot ignore it, and take no action.
b) Second new idea, at least to me. Mr. Williams thinks that CPS offered to make significant physical improvements in
the Princeton facility in the meeting in June in Washington. And, I guess his argument/question is why isn't that
acceptable? He believes their June proposal included a three sided containment for the lime featuring tennis -court type
wind breaks, berming, and vegetative plantings with sheet flow.
I countered that DWQ has no written proposal from CPS in hand, either in my office or in WARO. I noted that the only
thing written out of that meeting was the 1991 EPA/industry trade organization correspondence o his topic. Further, I
countered that I'm not sure why he thinks he made a proposal, when he has no written response that proposai.
advised him to put the proposal in writing, ASAP, and get it to SPU and WARO for our consideration. He acknowleded
that time is running out on his required response, and that he would get us something today.
c) He raised the issue of significance of pollutants from this site, noting that they're in the middle of farming country,
Vnd that runoff from adjacent fields has the potential to contribute more than his site. He has been to the site.
I offered no direct rebuttal on this third issue, but I did note that the receiving wate (Water Supply water, and an NSW
water, and that that makes it more significant to us as to protecting it. /1

RATIONAL METHOD RUNOFF COEFFICIENTS WORKSNEET
%%OUI N H [
Project: Reedy Creek By: CWJ Date: 6/6/2008
Location: DA 2 - Drop Inlet 2 Checked: Date:
Drainage Area 2 - Drop Inlet 2
Runoff Coefficient (Chart E-1)
Slope
Rolling: 2-7%
Cover description
land Use
Coefficient
Area
Product
of
C x area
Mill.
Max
Used
_ 5 f?l=_>._
Acres
Ft^2
Rolling
Rooftops and pavement
0.95
fl.95
0,95
7323,00
6956.850
Rolling
Pastures, grass, & Farmland
0.20
0.25
0.000
Rollina
Woods
0.15
0.20
0.20
0.000
Rolling
Residential
0.40
0.55
U00
Totals =
7323,001
6956.860
Composite C = total product/total area
Drainage Area Info
Area
Tc
•
0.l7 Acres
5 ntin

�That's all on his issues. On the feel -good side, he noted that he graduated from Appalchian State, that he grew up in
Cinston, and spent many years in his home state with Royster-Clark before being transferred around the country. He
noted that CPS has approximately 9 facilities in the planning stages for phyto-treatment of stormwater, and that they
want to stay out of the stormwater permitting arena if possible.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties.
•

�11
0
RATIONAL METHOD RUNOFF COEFFICIENTS WORKSHEET
uror P
Project: Reedy Creek By: CWJ Date: B1612008
Location: DA 3 - Drop Inlet 3 Checked; Date:
Drainage Area 3 - Drop Inlet 3
Runoff Coefficient (Chart E-1)
Slope
Rolling: 2-7%
Cover description
Land Use
Coefficient
Area
Product
of
C x area
Mill.
Max
Used
'`Sq Ft —
Acres
Ft^2
Rolling
Rooftops and Pavement
0-95
0.95
0.95
6600,00
G460.000
Rolling
Pastures, grass, & Fafmland
020
0.25
0.000
Rolling
Woods
0.15
0.20
0.20
0.000
Rolling
Residential
0.40
0.55
0.000
Totals =
6800.00
6460.000
Composite C ; total productltotal area
Drainage Area Info
Area 0.16 Acres
Tc 5 min
C = 0.95

Pale I of")
Nancy Vincek
From: Kirk Williams
Sent: Wednesday, August 19, 2009 618 PM
To: Ken Pickle (ken. pickle@ncdenr,com); Al Hodge ([e-mail]); Thom Edgerton
([e-mail]); Shelton Sullivan ([e-mail])
Cc: Nancy Vincek; Bill Coleman; Shannon Peedin; Jim Cahoon; Kirk Williams
Subject: Crop Production Services- Princeton, NC
Attachments: 20090819 CPS NCDENR Site Refresher.PDF
Greetings to All- I would like to refresh all of you on the subject site. Please excuse my delay in being able to
address some of the site concerns and the volume of this email. I would like to share the below and attached
information, allow for your review, and plan a conference call or "Go To Meeting" for tomorrow where I can
summarize this information for you and we can then discuss and decide how to proceed. Your consideration of
the time constraint is appreciated.
Information Contained in the Attached pdf
�+ Pickle July 21-mern-Ure NOV-2007-DV-0298
✓� CPS Conceptual Plan Narrative and Site Plan (Bay Environmental)
✓+ Sand Creek Consultants peer review of Bay Plan
✓+ Draft August 20 2009 CPS Fugitive Dust Control Plan (details lime storage area and other dust control
efforts)
v+ Storm water Permitting Interpretation packet 1991
1987 Standard Industrial Classification Manual Excerpt "Basis of Code Assignment"
5191 and 2875 SIC Code Descriptions
Bullet Point Discussion
SIC Code Interpretation
+ Most Ag Retail centers are best described as SIC 5191 (now NAICS 424910)
+ 5191 was exempt from the storm water regulations
+ When sites have multiple "activities" the "Basis of Code Assignment in the SIC' (the page 15 referred to
in the Ephraim King, EPA Chief NPDES Program Branch) recommends assigning a code based on the
location's principal product and in this case retail or wholesale, by "Value of Sales."
+ Sales as a percentage at Princeton (2009 to date) are as follows:
32% Packaged Chemical
27% Straight sale fertilizers (fertilizers that are not mixed or blended but received and sold directly "as
is" to the farm customer
22% Blended fertilizers
18% Seed
• CPS will remove all unnecessary equipment from the site
• Only clean pallets are stored outside for reuse
• Dry product field equipment (spreader trucks, Killebrews) contributions are considered de minimis
+ All liquid equipment if field rinsed prior to returning to the site
Proposed Facility Improvements (presented at the June meeting excluding Sand Creek peer review)
8/20/2009

Page 2 of 3
• Phytoremediation and drainage plan -See CPS Conceptual Plan Narrative (original narrative)and Site
Plan by Bay Environmental
• Also see Sand Creek Consultants email comments and mark ups/suggested improvements to the Bay
Conceptual Plan
• Phyto related grading and grassing can begin in the fall of 2009 and spring 2010 tree plantings. The
trees will require 2-3 years for full effect.
• Lime Containment Area (excerpted in part from the attached draft Dust Control Plan dated August 20,
2009):
• The area responsible for most of the airborne dust -the historic lime storage
area on the southeast end - will be excavated back to the natural soil level and
back filled so the area can be seeded with grasses. This will eliminate airborne
dust from this area.
The "active" lime storage area will be contained within a structure constructed
of a 4 to 6-foot high cast wall or equivalent on three sides measuring 36' x 75'.
The open end will face east and will include a ramp to prevent storm water from
flowing out of the storage area (though most likely fully absorbed by the lime).
On the west and south sides, we will add a 6 to 8' high chainlink fence with
appropriate sized mesh screening to buffer wind impact. The north side will not
be screened to allow the clam shell to unload the lime from rail cars directly into
the structure, eliminating the need to move the material twice. The adjacent
building provides a wind buffer on the north side. The lime pile will be shaped
(tabletop like) and will not be stored over the height of the wind break. We
believe these efforts will effectively control any fugitive lime dust while allowing
for operational considerations without the need for a cover and without the
additional carbon footprint from additional handling (canopy system) or the
impractical tarp cover (safety and labor concerns).
We are working with the phyto consultants to plant additional windbreak trees
on the southern, northern, and eastern boundaries to add to and replace the
trees we planted earlier. When these trees are established, they will form an
additional windbreak further minimizing any potential dust emissions leaving
our property.
The timeline for this work is as follows:
• Excavation of historic lime storage area will begin this summer and will be
completed so that the grasses can be planted in the Fall of 2009 or no later than
March 31, 2010. Until the grasses are planted and established in this area, we
will spray with water to suppress the dust.
Lime Containment Area: Containment will be in place prior to December 31,
2009. Until the structure is complete, we will wet the pile to reduce airborne
particles. We do not plan to receive any additional shipments of lime until the
containment structure is complete.
• Windbreak Trees: The trees will be planted Fall 2009 or no later than March
31, 2010 to improve chances of becoming established.
Area 2: Driveway_/ Parking Lot
8/20/2009

Page 3 o f 3
• Some of the areas in the driveway and parking lot will be excavated and
prepped for grasses and low bushes. This will eliminate some of the dry surface
areas around the facility. Refer to the Site Plan attached for proposed planting
areas.
• The areas that cannot be planted will be wetted on a routine basis with water
to suppress the dust. A schedule will be developed and a log kept to document
the spraying.
The timeline for this work is as follows:
• The areas that can be planted will be done no later than March 31, 2010.
• The entire area is currently being sprayed with water on a routine basis. The
log is available for inspection at any time.
Summary
CPS does not believe it is applicable to the storm water regulations based on the SIC code evaluation.
CPS has made significant investments (secondary containment system for liquids, dry product load out pads) and
proposes significant additional investment and effort to manage dusts and storm waters
CPS believes the consolidated lime storage area, even with the open top, will control fugitive dusts, eliminate
lime in solid or dissolved phases in storm waters, yet allow for operational needs with no additional carbon
footprint,
Proposed "Go To" Meet! ng_{only email and web access is necessary)
Thursday 1:30 Mountain, 3:30 Eastern. I will send an invite to your email.
Kirk Williams
Environmental Manager
Crop Production Services, Inc.
7251 W. 4th Street
Greeley, CO 80634
Office: 970-347-1542
Fax: [phone]
Cell: 970-518-7430
Email: [e-mail] (note new email address as of 6/12/09)
8/20/2009

A
ra.en,a�O.errsr�re�
HCDEHR
North'Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Taves Perdue Coleen H. Sullins Dee Freeman
Govemor Director Secretary
July 21, 2009
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ms. Nancy Vincek•
Crop Production Services
1160 Brake Road
Rocky Mount, North Carolina 27801
Subject: NOV-2007-DV-0298
Intent to Assess
Crop Production Services, Princeton
Wayne County
Dear Ms. Vincek:
The Division has considered your No Exposure Certification received November 12, 2008, for your
Princeton facility,, At this time, DWQ cannot grant CPS Princeton the No Exposure,Exclusion from
Permitting. This determination was based on the following two considerations.
• On November 17, 2008, DWQ conducted an Inspection for the specific purpose of
determining whether no exposure conditions had been achieved at the site. We observed -
that the lime pile was not fully covered, i,e, that the tarp covering had not been
succ6ssfully and fully Implemented, as required In our October 14, 2008, letter to you, as a
condition of granting the No Exposure Exclusion from Permitting, .Further, at the time of
the visit, CPS personnel commented that the tarp was extremely difficult to deploy. Along
with our observations that day, this comment calls into question whether the tarp can be
reliably deployed in the future.
• DWQ observed -additional areas of exposure that we had not previously considered, but did
comment on to CPS staff at the time of our inspection. Specifically, stacks of pallets,
outside storage of tires and metal hoppers, and other site business related implements, all
stored outside. When stored outslde, these materials constitute exposure.
DWQ has also reviewed the 1991, correspondence received from CPS In a meeting June 12, 2009,-
at DWQ's Washington Regional Office. CPS provided us with the several pieces of correspondence
between various industry organizations and the EPA concernirig proper SIC classification of farm
supply facilities, and indicated that the correspondence supported the conclusion that CPS
Princeton was not subject to NPDES stormwater regulations,' and that consequently a stormwater,
discharge permit may not be required at CPS Princeton. We disagree that the 1991 summary
letter from EPA supports that conclusion at CPS Princeton, Specifically, we view the mixing and
blending of granular and liquid materials at Princeton as neither Incidental nor small scale with
wetlands and stormwater Branch
1517 Mal Service Center, Raleigh, North Carotin 27699-1617
Location: 512 N. Salisbury SL Ralelgh, North Carolina 27604
Phone: 919-807-M k FAX [phone] Customer Servkm: 1-877-623-6748
Internet www.noNatarquallty.org
An Equal 0pponuni y l AIIImi0ve AcWn Employer
NOne hCaro i a
Naturally

•
•
JUL. 16. 2008 7:16AM CHAR-MECK UTY•41113 W. 1975 P. 6
Applicant: Charlotto-Mecklanburg Utilftics Pile Nfimbez: SAW-2008. bale: May
De l., A(Vii: Dennis Ciwalttfay _ 01353-360
_u
Attached is:
Scc Section below
1NITYAL PROFF l?REM PERMIT (Standard Perinit or Letter of
A
permission) _
P12OFFERLID PERMIT (StantW(t Permit or Letter of permissio_ n}
13
_
PERMIT DENIAL
C
}C
APPROVED JURISDICTIONAL; DETERMINATION
D -
PRELD&MARY ICMSDICTIGNAT. DIi'I kit MMATION
v' L
IQ I.- die i1 0�+4 Xili; idt}tlfi a ,yotit; � '�� raj' 41?L1 ><W zQQtt>114� im On i p VA (i aPdal or the abova
cicCigiiin. tdotlt♦1 infot tRi �rf tiia ifbe food at, ;flWw`'tyg a�.itr _ is I41st1$Cl tiIoonFLsrwfc gfx e�
Col s le$U(tftitjYt4 lit 33 CF1t art:3�7'; ;;
A: INITIAL PROFFERED PERMX•l'; You may accupt or object to the pennit,
• ACCEPT: If YOU received a Standard Pursuit, you may sign the porinii document and retum it to the district engirecr for final
autliotization. If you received a Utref of Perritission (LOP), you may nerept the LOV and your wnrk is authmizeel. Your signature
on the 5landard pernitt or aeceprance of the LOP means that you accept the permit in its entirety, and waive all rights to appeal the
pemtit, including its terms lint] eondilions, and approved jurisdictional detemiimtious assuciated with the permit.
• OBJECT: If you object to the pennit (Standard or LOP) because of cerialn terms and conditions therein, you may re(lacst that the
permit be modified accordingly. You inust conipletc Scction IT of this fnrm anti reniru the fonn to the district engineer. Your
objections must be received by Ilia district engineer within GD dQys of [lie date of this nutico, or you will fortcit your right to appcnl
the permit in the future. Upou receipt of your letters the dietrict engineer will evoluitie your objections and ntay: (a) modify Tile
pemtit to address all of your cnucerns, (h) modify Use pennit to oddress sonic of your objectiuizs, of (c) not modify flits permit
having determined that the per nit should bu issued ns previously wrinem Auer evaluatixig your objections, the district engineer
will Bond you a proffered permit for your reconsldcratioi , as indicated in Section H lselow.
B: PROFFERED PERMIT': You play accept or appoal rife pot -Alit
• ACCFPT: If you -received a Stan&rd Pennir, you -nay sign the pemtit document and return it to the district engineer for Milli
authorization. If you received a Luttvr ofPcrmissiva (LOP), yuu my accept the LOP and your work is nuthorizcd. Your t:ignafurn
on the Standard Permit or accaptancc of the LOP meting that you accopt.tlio permit in its entirety, and waive all rights to appeal iho
pennit, inoluding irn temv; imd rouditions, and nppxovcd imisdiclional dctonWriations ussocinted with the permit.
• A-PPEAL.' Ifyou choose to decline the proffered pennit (Standard or LOP) because cif cedaiu terns and cotuildons therein, you
may appeal the derlined pennit under the Cotps ofingincors Administrative Appeal Process by completing Section II of this form.
anti sending the form to the division engineer. This form must be rcccivert by the division engineer within 60 dayt; of the ilatr. of
Hula notice.
C: PERMIT DENIAL: You nmy appeal the denial of a pemtit under the Corps of l?ngincera Administtative Appeal Process by
cornploing Section 11 of this forin and sending the form to Iltr division ongiueer. This form must be received by the division engb1cor
within GD days of the date of this. notice.
D:.APPROVED JUMSDIM ZONAL DETERMINATION: You may accept or appeal thu approved JD or
providts now information.
• ACCHI''f: You do not need to notify the Corps to accept an approved ID, Failure to nolif� the. {tarps within 60 days of the date of
this ilorice, nieans that you accept ti►e approved Jb in its entirety, and waive all r1p)its to appeal the approved JD.
• A11PKAl",: If you disagree wilh the approved J17, you may appeal the approved Jri under the Corps of Lingincen Adniinistialivo
Appeal Pioem by completing Section 11 offhls forin And sending flit; form to the division enl irtoer. This form roust ho received by
the division engineer within fiD days of the, date of this notice.

•
prop production Services
July 21, 2009
respect to the current operating mode of the facility. 'On, this basis the SIC classification 2875
most closely describes activities at CPS Princeton; and the facility Is captured by the NPDES
stormwater regulations.
Washington Regional office staff and I believe that a No Exposure Exclusion from Permitting may
still be achievable at your site, pending a feasible response to the lime plle exposure and to the
other exposures observed at Princeton. As an alternatiie; we also believe that a stormwater
discharge permit is a feasible option for Princeton. We are requesting that you either take
additional actions to achieve no exposure and subsequ6ntly submit a new No Exposure
application; or, that you submit an individual stormwater permit application.
The Washington Regional office will begin NOV penalty and assessment procedures on
Monday, August 24, 2009, if by that date DWQ has not received either a revised,
completed application for the No Exposure Exclusion from Permitting, including a
narrative description detailing proposed changes to achieve No Exposure, or a
completed application for an Individual storrnviaier discharge permit.
Please contact either Thom Edgerton in Washington at [phone], or'me In the Central
office at [phone] with any comments or questions.
Sincerely; �%
ee�, l�-C'-1
Ken Pickle
DWQ stormwater Permitting Unit
cc, DWQ Washington Regional Office, Al Hodge
DWQ Washington Regional Office, Thom Edgerton -
DWQ NPS Assistance and Compliance, Shelton Sullivan
DWQ SPU, Bradley Bennett

•
s
.311L- 16. 2008 7: 1IM MR -HECK 0TY-•EIIG
V0.1975 F. 7
lr: PRELiMWARY JURISDICTIONAL DETERMINATION: You do not need to respond to the Corps
rogarding tilt: prehiniawy JD. The Preliminary JD is not appealable. If you wish, you may request an approved
JD (which may beappealed), by contacting the Corps district for further instruction. Also you rutty provide new
inforrxration for firrther consideration by the Corps to reevaluate Iho JD,
77,
-29C' f_ON li - 99QM- a4 .(iB3 'tvTx01 •'i't`)`A'i '1 ,:]� t nPEl #�� ItMI'l; •. ; .
REASONS YOR APPEAL OR 07i WrIONS: (Describe your reasons for appealing thn decision or your
objections to art initial proffered Hermit in Clear concise statements. You may attach additional information to
this form to clari fy where your reasons or objections are addressed in the administrative record.)
ADDITIONAL INFORMATION: The appeal is limited to a review of the adntinislratiVC record, the Corps
mcinaraudum for the record of the uppeal conference or ra"ling, and any supplemental information that the
review officer has deterrninud ire needed to dar•i£y the ndtninistrative record. Neither tho appellant nor the Coe lm
may add noxv information or a rinlyses to the record. However, you may provide additional iufomiation to elir'ify
lire location of informalion that is already in the administrative record.
OF
If you have questions regarding this decisiotr and/or the
If you only have questions:regavding tiro appeal process
appeal process you may contact:
you inuy also contact:
Steve Chapin, Project Manager
Mr. Michael P. Bell,
US.AC , Asheville Regulatory Field Office
Administrative Appeal Review Officer
151 Patton Ave, Room 208
CPSAD-ET-CO-R
Asheville, NC 28806 4P
U.S. Army Corps of Engincom, South Atlantic Division
828-971-7980
60 Forsyth Street, Roorn 9M15
.A.tlranta, Georgia 30303-8801
RIGHT OF ENTRY: Your signature below grants the right of oulry to Corps of Lngitwois personnel, and aatty
government consultants, to conduct investigations of the project site during the course of the appeal prc> cmi. You
will be movided a 15 day notice of any site investigation, and will have the opportunity to participate in all silo
invosti rations.
Date:
Tolophonc uurubor:
Signatture of at r ulltrrrt or ngont.
For appeals on initint Proffered Permits and approved Jurisdictional Detertnivatiorns send
this form to:
AisUict lEnghteer, Wilmingtoan Regulatory Division, AttmSteve Chapin, Project Manager,
Aglieville Regulatory Field 4ftit:e,151 Pntton Avenue, Room 208, Asheville, NC 28801.
For Permit denials and Pruffered Permits send tidal form to:
Rivision Engineer, Comninuder, U.S. Army Engineer Division, South Atlantic, Attu: Mr.
Mite Bell, Administrative Appeal Officer, CESAD-IU V-CO-R, 60 Forsyth Street, Room
9MIS; Atlanta, Ceorgia 30303-81301

Crop Production Services
Princeton, North Carolina
Conceptual Environmental Plan Narrative
Crop Production Services operates a facility at 141 Luby Smith Road just east of the town of
Princeton, North Carolina along the western boundary of Wayne County. The facility distributes
bulk and bagged agricultural products Including fertilizers and lime. The site is located in a rural
area of Wayne County and is comprised of approximately 4.6 acres of land. The site is
underlain by poorly drained soils and the topography is generally flat. The site currently has a
vegetative buffer zone along the eastern edge of the property that is approximately 1.3 acres.
The site's stormwater runoff is generally directed towards this buffer area, however, the
operational area of the site experiences flooding during larger storm events, To assist with this
issue and to reduce the potential for windborn dust, Bay Environmental, Inc. has prepared a
conceptual plan that addresses drainage and dust control.
Jim its of the Conceptual Plan
Windbreaks
The site current) has windbreaks planted along the northeastern and eastern property
Y P 9 p P rtY
boundaries. These windbreaks consist of two rows of Leyland cypress planted on five to ten
foot centers staggered between the two rows. The conceptual plan proposes additional
windbreaks with a similar planting scheme along most of the remainder of the northern
property boundary, as well as along the entire southern boundary. The conceptual plan also
proposes to replace any dead, diseased, or dying trees within the existing windbreak. Based on
field reconnaissance, it appears that some of the trees in the extreme northeastem corner of
the site are being flooded, as the Leyland cypress does not tolerate irregular flooding. This
location may require the creation of a one foot berm to divert ponded water away from the
windbreak plantings.
Vegetated Buffers
The conceptual plan proposes vegetated buffers and landscaped beds on all areas of the facility
that are not required for operations or traffic flow. These vegetated buffers will reduce the
amount of runoff directed to the eastern end of the property and will provide soil stabilization to
reduce dust. The larger buffer areas along the northenn boundary and in the southeastern
corner will contain taller plantings (shrubs, small canopy trees) with low ground cover, and the
landscaping beds will contain perennials and grasses. The large vegetated buffer at the eastern
end of the property will have to be excavated slighdy (less than 2 feet) to accommodate the
® drainage from the site and to provide a slight gradient across the site, as currently, some areas

JUL. 16.2008 1:1IAM CHAR -DECK UTY-F11G 00. 1971 P. 8
OA-1710"[DE PERMIT 12
DEPARTMENT OF THE ARMY
CORPS OF FINGINEERS
FINAL NOTICE OF ISSUANCE AND MODIFICATION OF NNFION WIDE PERMITS
I:?LDERAL REGISTER
AUTHORIZED MAkCH 19, 2007
Utility Line Activitieq. Activities required for the construction, maintenance, repair, and
ramovAl of+ctili(y lines and ussooiated facilities in waters of tho United States, provided ilia
activity does not result in the loss of greater throe 112 ucro of waters of the United States,
TV ]l lines: 7'hia NWP authorizes the construction, maintonatree, or ropnir of utility
lines, irirltiditig onlfoll and intake structures, and the associated excavatiotr, backfill, or bedding
for the utility lines, in all waters of the United States, provided there is no change in pre -
construction contours. A "utility line" is dclincd as any pipe or pipehim for the transportation of
any gasrons, liquid, liquescent, or slurry substance, for any purpose, and any cable, lure, or wire
for the transmission for any purpose of electrical energy, telephone, and telegraph messages, and
radio and television communication. `fire terra "utility line" does not include activities that drain
u water. of the United States, such us drainage the or french drains, but it does apply to pipes
conveying drainage from another area.
Material rosolW)g from trench excavation may be temporarily sidcuest into waters of the
United Slates for no more Ihau three months, provided the material is not placed in such a
manner dint it is dispctgcd by currents or other forces. '17xe district ongineer may extend the
period oftemporarySide casting for no snore than a total of 1.80 days, where appropriate. In
wetlands, the top 6 to 12 irwhcs of the trench should normally be backfrlled with topsoil .from the
trench. The trench cannot be con"treated or backfilled in Auch a maruier as to drain waters of the
United States (e.g., back(lli#ztg with extensive gravel layers, creating a freiwh drain effect). Any
exposed slope:r and sircnrn banks must bn stabilized hnniediately upon completion of tiro utility
line crossing of cacti wnterbody.
0jl-lac substatiarrs; This NWP authorizes the construction, maintenance, or
expansion of substation facilities associated with a power line or utility litre in non -tidal waters
of the United States, provided the activity, in combination with all other activities included in
one single and complete pi0ject, does not result in the loss of greater than 1/2 acre ofwators of
the United Slates. This MVP does not authorize discharges into rton-tidal wetlands adjacent to
tidal waters of the United States to construct, maintain, or expand substation foci linos,
I clad s o av a d ut' ' P ole.tand anehn . ; This NWP authorizes
Ilia consunedon or maintenance of foundations for overhead utility line towers, poles, and
anchors in all waters of the United States, provided the foundations are tho, rniulmvni slze
necessary and separate footings for each tower leg (rather 0van a larger single }gad) are used
whero fcnsiblo.
Aaces r+Vtils: Tl1is NWP authorizes Use constntction of Access roads for (lie construction
and maintenance of utility lines, including overhead power lines and utility line substutiUns, iu
s►on-tidui waters of Ili s United Statao, provided tho total discharge from it single and complete
project does not cawo tiie loss of gseatcr than 1/2-acre of non -tidal waters of the United Stntos.
This NVVT does not authorize discharges into non -tidal wetlands adjacent to tidal waters for
access roads. Access roads.must be the m(nimum width necessary (see Note 2, helow), Access
0

r
of the site are lower in elevation than the buffer area. This larger area will be planted with
native grasses and shrubs with a ring of large canopy trees on the northern, eastern and
southern borders of the buffer area. It is anticipated that willow and poplar species will be
utilized for these larger canopy trees.
Infiltration Trench/Pits
Two infiltration areas are proposed in the conceptual plan. The first is a narrow infiltration
trench located along the southeastern corner of the warehouse building. This trench will
intercept runoff from the roof as well as from the concrete slab along most of the southern side
of the building. The infiltration trench will be excavated to a depth of approximately eight feet,
lined with filter fabric, and then backfilled with clean stone. The trench will be dressed with
topsoil, and the topsoil will be graded into a shallow swale before being stabilized with native
grasses. The proposed infiltration pit is a non -linear infiltration feature that will also allow for a
source of water for irrigating the adjacent planting areas if needed. This pit will intercept runoff
from the southern portion of the site between the railroad main line and railroad spur. The pit
will be excavated to a depth of approximately eight feet and will be lined with filter fabric. The
pit will be filled to the surface with stone along the upgradient (west) face, and will be filled to
within one foot of the surface over the remainder of the pit. This area will then be dressed with
topsoil and planted with native grasses.
0 Lime Retaining 5tmct pare
The conceptual plan proposes a retaining structure to contain bulk lime on the site, and to
protect the lime pile from wind. Two structures are under consideration. The first is a concrete
block wall with a chain link fence installed on top of the wall on the western and southern
facing edges of the structure. Wind break fabric similar to the fabric used for enclosed tennis
courts will be installed on the chain link fence to reduce the amount of the bulk lime pile
subjected to winds crossing from west to east. This design allows for loading to and from rail
cars over the northern section of the structure, and direct access with a loader from the eastern
side of the structure. The second design under consideration is a permanent containment tent
or shed. This design will allow for loading from only one side, but may provide more complete
protection of the bulk lime pile from wind and rain.
C

JUL, 16.2006 1: 17AM CHAR-MI:CK UIY-ENG M. 1975 P. 9
roads must be constructed so that tha league of Cho road minimizes any adverse effects on waters
of the United States and must be as near as possible to pre -construction contours and elevations
(e.g., at grade eordwoy roads or geotextile/gravel roads). Access roads constructed above prc-
construction contours and elevations in waters of tile United States must be properly bridged or
oulverted to maWain surface flows.
This NWP may authorize utility lines In or affecting navigable watery of the United
Stmos every if Were is no associated discharge of dredged or till material (See 33 CFR Part 322).
Overhead utility lines cortstrtiotcd over section 10 waters and utility lines that are routed in or
under section 10 waters without a discharge of dredged or fill material requlce a sectinrc 10
pecr.nit.
This NW.P also authurives temporary structures, fills, and work necessary to conduct the
utility line activity. Appropriate measures must be taken to maintain normal downstream flows
and xninimizo flooding to the maximum extent practicable, when temporary structures, work, and
dischurges, including colferdanrs, are necessary far corwirrrction activities, access fills, or
dewatering of construction sites. Temporary tills must consist of materials, and be placed in a
manner, that will not be eroded by exported Irlph flows. Temporary filly nrur,t be trarroved in
their entirety acid the affected areas returned to pro -construction elevations. The tvcav affected by
temporary lilts must bo ravegetated, as appropriate.
-Notlhcation: The permittcc must submit a pre -constructions notification to tha district
engincer prior to eornmencing the activity if any of the following criterin are met: (1) tho activity
involves rneclinnized land clearing in a forested Welland for the utility line right-ol-way; (2) a
section 10 perrnit is regnixed; (3) the utility lino in waters of the United States, excluding
overhead lines, exceeds 500 feet; (4) the utility line is placed within a jurisdictional area (i_e.,
water of tiro United States), and it nuns parallel to a stream bed that is within dust jurisdictional
area; (5) discharges Ihat result in the loss of greater than 1/10»acre of waters of the United States;
(6) permunent access roads are constructed above grade in waters of the United States for a
distance of more than 500 foct; or (7) permanent access roads are constructed in waters of the
United Slates with Impervious materials. (Soo general condition 27,) (Sections 10 and 404)
NQ(q 1: VAtcrc tho proposed utility line is constructed or installed in navigable waters of
the United States (i.e., section 10 waters), copies of the pre -construction notification and N M,
verificatioti will be sent by the Corps to the National Oceanic and Atmospheric Administration
(NOAA), National Ocean Service (NUS), for charting the utility line to protect Navigation.
Noto : Access roads used for both cunstruelion and mninteninice may he authorized,
provided they meet the terms and conditions of this NWP. Access roads used solely for
construction of tine utility line must bo removed upon completion of the work, accord r ce with
the requirements for temporary fills.
_Igtc 3: Pipes or pipelines used to transport gaseous, liquid, liquesccnt, or slurry
substances over navigablo waters of the, United .States are considered to be bridges, not utility
linos, roil may requiro a permit from the U.S. Coast Quard pursuant to Section 9 of the Rivers
and 1-ltirbc�rs Act of 1899. However, any discharges of dredged or fill material into waters of the
United Suites aggoclated with such pipelines will requiro a section 404 permit (see NWP 15),
0
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Wl♦l�l<� ICI
FOR DISCUSSION PURPOSES ONLY
SCALE: APPR. 1" = 60' CONCEPTUAL PLAN
PATE: 5/11M9 PHYTOREMEDIATION/DRAINAGE ENKMCEMENT
BAY i 09-054-01 CROP PRODUCTION SERVICES
NORTH DRAWN BY: CJC PRiNCETON, NORTH CAROLINA cn.orvrr xcws rn{ sm:
P O IK. ib6b _vA 1;517

JUL, 16. 2006 7: 1CA3M CHAR-MICK UTY-EEG No. 1915 P. 10
NATAON WM kip RNU 1Q—Qj=ONN
jh�o wljjg (icnexal Canditipgs must be fpjJowed in ordor for any Autltoximinn by a NWP to
be valid-,
1. Ngjg
yadon. (a) No activity may cause more than a minimal adverse effect on
linvigcition.
(b) Any safety lights and silpials prescribed by die U.S. Coast Guard, through regulations
our otberwlso, must be lustalled and malntalned at the permittces oxponsc on authorized facilities
in navigable waters of the United States.
(c)'Ibe permittee understands and agrees that, if future operations by the United States
rcyuiro the removal, ralocation, or other alteration, of the structure or' work herein authorized, or
If, in the opinion of the Secretary of the Army or his authorized represontative, said stricture or
work shal l cause urueamnable obstruction to the free navigation of the navigable- waters. the
peanittvc will be required, upon duo notice from tite.Corlss of &gim mrs, to rcuiuve, relocate, or
e
r r`

Kirk Williams
From:
Mark Dawson [[e-mail]]
Sent:
Wednesday, August 19, 2009 12:54 PM
To:
Kirk Williams
Subject:
RE: Princeton, NC- Plans by Bay Env
Attachments:
20090819-NC Princeton -SC C-Cents on Bay Draft Concept Phyto Plan.pdf; 20090819-NC
Princeton-SCC-Ian Cnstrctn Details.pdf
Kirk,
Per our discussion this morning, here are our comments and suggestions on Bay Environmental's conceptual stormwater plan
for Princeton. I have attached Bay Environmental's drawing with comments added to the drawing.
In general we very much like the wide use of vegetation and the mix of large canopy trees, wind breaks, and short vegetation.
Excellent and creative use of available space.
We recommend a few alterations that will make the system more efficient. Please note that we have arrived at these
conclusions without know the topography of the site or knowing much of anything else, although we understand that the site
is underlain by clay.
1. North Buffer Area: Manage stormwater flow by constructing a series of shallow pans along the flow path, This will effect
to slow water and ultimately reduce the volume of stormwater discharging to the east portion of the site.
• The bottom of the pans must be perfectly flat to distribute the water uniformly across the pan thereby opVmizfng
the ability for plants to utilize the water and nutrient.
• • The number of pans needed is a function of total slope present and the ability to construct the pans yet allow for
surface flow to enter the pans. We like to not exceed 8 inches of height elevation between pan bottoms, but at
times will have more. Less is preferred and easier to manage.
• 1 have attached some pan construction details from some past projects. Bay might find them useful for their own
design needs.
2. The red hatched Existing Vegetation Buffer Area: Much of the water from the facility could drain into this area.
• Typically we would recommend planting such an area with hybrid willows such as SX-61 or 5V-1. These facultative
plants are very effective at growing in areas subject to repeated flood events and are particularly good at
transpiring water.
• Planting density is a function of how much SW runoff enters the area, etc. During drought periods some of the
willows will die. This is acceptable and some replanting can be conducted if extreme drought conditions are
observed, Surround the willow planting with poplars.
• If water storage capacity is limited, then deepen this area by pushing soil to the east to increase holding capacity.
• If ponded water remains present throughout the year, plant wetland plants such as cattails. Very effective at
nutrient uptake and transpiration.
3. Infiltration Trench
• We normally do not recommend using these structures unless no other option exists. Too easy for nutrient, et al
to bypass the rhizosphere and not be treated. Plus these structures can have a limited life,
• Try to pipe water directly to the east treatment area.
4. Infiltration Sump/Pit
• Similar to above we do not recommend these structures except for short term or "emergency" use.
• We recormend treating the water by establishing a tree -based treatment system in the southeast corner. Again,
use the pan concept with a planting of willows and poplars. A treatment wetland might be considered if excess
water is frequently present.
• Because the site is relatively flat and no surface water bodies are immediately nearby, filter strips are of lower
need for particulate trapping than are phreatophyte trees that can transpire large amounts of water.
Please let me know if you need any additional help on this. We would be happy to assist Bay on construction details.

Jtil.. 16. 2008 7: NAM CHAR-UNK HY-ENG 110. 1975 P. it
alter the structural work or obstructions caused thereby, without expense to the United States. No
claim shall be made against the United States on account of tiny such removol or alteration.
2. Aguatic Li ' vemc ns. No activity may substantially disrupt the necessary life cycle
movements orthosc species of aquatic life indigenous to the waterhody, inrltrding those species
that normally migrate through the area, unless Cite activity's primary purpose is to impound
water. Culverts placers In striates toust be Installed to maintain low flow conditions.
3, a tt'u &qu,,, Activities hi spawning areas du big spawning seasons must be
avoided Eo the ntaxiimurn extent practicable. Activities that result In the physical destruction (e.g.,
through excavation, fill, or downstream smothering by wbOantiaal mrhidity) of an intpurtat►t
spawning area are nut authorized.
4. iv[igrator iird Brccdina Arens, Activities in waters of th'O United States that serve ay
breeding areas for migratory birds must bu avoided to the maximum extent practic;xhle.
S. She ft,'h�. No activity may occur in arcus of concentrated shellfish populations,
unless the activity is directly reloted to a shellfish harvesting :activity authorized by NWPs 4 and
48.
6. Suitable Material.'No activity may use unsuitable material (e.g., trash, debris, car
bodies, asphalt, etc.). Material used for construction or dlscharged inast be frcc from toxic
pollutants in toxic umoutits (see Section :301 of the Clean Water Act).
so7. Water Supply lgto as. No activity may occur iu the proximity of a public water supply
intake, except where the activity is for the repair or Improvement of public water supply intake
strucnares or adjucunt bank stabiliantion.
S. ,adverse Effects FrojiQ jliwowidjnLnhi. if the activity creates tin impoundment of water,
adverse effects to the aquatic system clue to accelerating the pasmgc of water, and/or restricting
its flow must be minimized to the ►naximurrt extent practicable.
9. Mppggemgnt of Wglg[FlQws. To the maximum extent practicable, the pre -construction
comsc, condition, capacity, and locatann of open waters must be maintained for each activity,
including streara cliannelization and storm water management activities, except as provided
below. 'fire activity must be constructed to withstand expected high flows. The activity auust unt
restrict or impede the passage. of normal or high !lows, unless the primary putposa: of the activity
Is to impound water or manage high flows. The activity may alter the pre -construction course,
condition, capacity, aid location of upon waters if it beitef its the aquatic Utivirottment (e.g.,
siteam reStoratiurt or rolocation activities):
10. Filig Within 100-Yqr FloodplAins. The activity must comply with applicable FEMA-
approved state Qr local floodplain nitauagement requirements.
lilt. Pkirkiumont. Heavy equipment working in wetlands or ntudfluts must be placer/ on
mats, or other measures must be taken to itiinimizc soil disturbance.
4.
o

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CfinsiNa 2 to 3 pans
13t1I 1 ¢ I' II across this entire area. with I t
lI IIII �I III � ► illowSlpopiars. I I ?
► a (A�i01ll�ll Il { I ' i f Imul< ul
FOR DISCUSSION PURPOSES ONLY
j/ SCALE: APPR. I- = 60' CONCEPTUAL PLAN
E
PAT5ti/11109 PHYTOREMEOIAT[ON/DRAINAGE ENHANCIEMWT i
BAY 0 09.054-01 MP PRODUCTION SERWCES `I 4
NORTH DRAWN BY: CJC PIUNCETON, NORTH CAROLINA

JUL. 16. 2000 7: 10AM CHAR-5MECK UTY-EfIG NO. 1915 P. 17
12. lei V__rsi gE li _��dimcrit Centrals. Appropriate sell erosion acid sedinicut control6
must be used and rrsintained in effective operatfng condition during construction, and all
exposed soil and other fills, us well as any work below life ordinary bigh wutor mark or high tide
lino, must be permanently atahilized at the earliest practicublo date, Perinittees aio oncouragud to
perform work within.waters of the United States during periods of low -flow or no -flow.
13, Rctnoviil eitipaimly Fills. Temporary fills trust be removed in their entirety and
the affected Areas returned to pre-cynstruclion olevations. The afferled areas must be
revegotated, as appropriate.
14. A.tiy authorized structure or fill shall be properly maintained,
including main€enttnw to ensure public safety.
15. W�_1d nca i S4clti� Rivers. No activity MAY dcolu' fiat a UUMPUlrellt of the Nutional Wild
and Smiic River Systoin, or in a river officially designated by Congress as a "study river" for
possible inclusion hi the system while the river is in wi official study stutw, llnlc5s the
appropriate Federal agency with direct management responsibility for such river, has determined
in writing that the proposed activity will not adversely affect the Wild nittl Scenic ]liver
designation or study status. information on Wild and Scenic Rivers may be obtained from the
appropriate Federal land uintlagomont Agency in the area (e.g., National Park Service, U.S. Porost
Service, Bureau of Land Management, 'U.S. Fish and Wildlife %rviuo).
16. Tribe A_iglyt . No activity or its operation may impair raseirved tribal rights, including,
but not limi€ed ta, reserved Witter rights and treaty fishing and hunting rights.
17, BOAo f;ered_ SpecL. (a) No activity Is authorized under any NWP which I I lkely to
jeopardize the continued existence of'a threatened or endangered speeios or a species proposed
for such designation, as identified under the lFederal T;ndangered Species Act (F-SA), or which
will destroy or adversely modify tho critical habitat of such species. No activity Is authorized
tinder any N WP wlticb "inny affect" a listed species or critical habitat, unless Section 7
consultation addressing the effects of the proposed activity ling been completed.
(b) Federal agencies should follow 11tcir own procedures for complying with Elio
requirementa of the PISA. Federal permiittees niust proviele the district engineer Willi the
appropriate documentation to dctnoristrato oomplianco with those requirements.
(e) Non-federal pormincos shall notary the district engineer if any listed species or
designated czitirol habitat inight he.af ootcd or is in the vicinity of the project, or if tho project is
located in designated critical habitat, and shall not begin work on the activity until notified by Cite
district engineer that the requirements of the ESA have been satisfied and that the activity is
authorized. For Activities that might affect Pedcrally-listed endangered or threatened species or
designmed Critical habitat, Elio pro -construction notification must includo the'ximue(s) of the
etidangored or throatened specios that may be uffectod by the proposed work or that utilize: the
designated critical habitat that Inny be affected by. the proposed work. 'fhe district engineer will
determine whether ttte proposed activlty "may affect" or will have "no efTect' to listed species
and designated critical habitat and will notify the non-Fedeml-applicant of the Corps'
determination within 45 Jnys of receipt of a complete pre-constziirtion notification. ]n cases

0
WATER BAR HEIGNT
TO BE 6' LOWER THAN
E)OSF*rf'.C. WEST BERM
I.WA'r DEPTH 0' FROM
TOP OF RIPRAP. TO
TOP Of WATER BAR
Op
417 WIDE SP&LWAY
WSOIL r
-c �ol
COMPACTED OOMPACTEO
SOIL SOIL
EROSION CONTROL CiEOTEXTILE EXISTING GRKM
(SUPPUFDBYSCr)
WATER BAR LONGITUDINAL CROSS SECTION
DRAW PIPE (24MCH PVC) USED DRAIN
PANSSIZE TOFULLY DRAIN PAN WITHIN
24 HOURS Or PAN MUG FULL INLET
FILLED WITH D" TILE SCREEN TO
REDUCE PLUGGING.
BOTtOW. OF PAN COMPLETELY LEVELJFLAT
TOPSOIL
EXISTING GRACE—Z
TOP OF BERM
Z WIDE
AnR BAR SLOPES NOT
To EXCEED ILI --RIPRAP VTO f,'sTC*,*
r'nJ- LONG TAIL
BELOW KEY
7TE'
TOPSOIL
EROSION CONTROL GE'TEXTILE
KEY
(SL-PPLIED By SCC
FOR SUPPORT
WATER BAR CROSS SECTION
SAND CREEK CONSULTANTS, INC. PAN WATER BAR CONSTRUCTION DETAILS FIGURE 1
OR I6 Rmrwda ftrwo, P.O, Sol 1512 RMmum1w, Vfi 5cm
fi? T.U. 716,M5.18iS PREMIER COOPERATIVE DATE: JULY 18, 2005
IF= W&AMBA73 MOUNT HOREB, WISCONSIN DRAWN BY: MD
41 .

JUL. 16.2008 7:10AM CHAR -HECK UTY-016 NO, 105 P. 13
•
where the non -Federal applicant hm identifted listud species or critical habitat that might be
atfet:ted or is hi tlic vicinity of the project, and bas so notified tha Coq)s, the applicant shall nut
begin work until the Corps has pruvidcd notification the proposed activities will luive "no effect"
on listed species or critical habitat, or until Section 7 consultation has been completed.
(d) As a result of forhnad or informal consultation with the FWS or NMFS the district
ongineer may add species-speol is regional cndangcred species conditions to the NWPs,
(o) Authorization of an activity by a NWP does not authorize the "take" of A threatened or
endmigered species as defuied under the FSA. In tho absence of seprirate authorization (e.g., an
ESA Sectxoxt 10 Ponnit, a 13iologicnl Opinion with "incidental take" provisions, etc,) frorrx lice
U.S. FWS or the NMFS, bout lethal and noxi-lethal "takes" of protected species are in violation
of the ESA. Inforrivitiou oil 9w Ivcation of threatened and euda igcred species slid their critical
babihut can be obtained direotly fYom tine offices of the U.S. FWS andNMFS or their world wide
Web pages at littih://wmv.fwts.gov/ and htip://www.noan,govljrisherlegLiltInt reslaoctivoly.
I B. Historic Pro glics. (a) fn cases where the district engineer deterniities that the
activity may affect propartles listed, or eligible for listing, in tho National Register of Historic
Pirtoos, the activity is not authorized, until the requirements of Section 106 of the National
Historic, Preservation Act (NIVA) have been satisfied.
(b) Federal perwittees should follow thoix Own procedures for complying with the
requirements of Section 106 ofthe National Historic Preservation Act. Federal permittecs must
provide the district engineer with the appropriate documentation to demonstrate compliance with
those requirements.
(c) Non-federal perniitwes must submit, n prc-construction notification to the district
exit inear if the authorized activity may have the potuntial to cause ullocts to any historic
properties listed, dcta nrincd to be oligiblu for listing on, or potentially eligible for listing on the
National Register of'Historic Places, including previously unidentified propartics. For such
activities, the pre -construction notification inust state which historic propertiCB inay he affected
by the proposed work or include a vicinity map indicating the location of the historic properties
or file potential for the presencc of historic, properties. Assistance regarding information on the
lucntiva of or potontial for the presence of historic resources can be sought froin the State
Historic Preservation Officer or Tribal I•listoric Preservations Officer, as appropriate, and Elie
National Register of Historic Planes (see 33 CFR 330.4(g)). The digtriet engineer shut] make it
reasonable and good faith effort to carry out npproprinto identification olforts, which may include
haftwund research, consultation, oral history interviows, sample field investigation, and field
survey. Based on the irifumintion submitted and these efforts, tho district englAcer shall
determine whethor the proposed activity has the potential to cause an effect on tine historic
properties. Where the non-federal applicant has idontifickl histuric properties which the activity
may have the potential to cause effects and so notified tine Corps, the ikon -Federal applicant shall
1191 bogin (lie, activity witil xxotitied by the district engineer either that the activity has nu potential
to cause effects or that consultation under Section 106 of the NHPA has been completed.
(d) Tbe district cngincer will notify the prospective permittee within 45 days of iecoipt
of a. complete pre-conStxtletioll notification whedierNHPA Section 106 consultation is required.
Section 106 consultation is not required when the Corps detamil ies that tho activity does not
have the potential to cause effects on historic properties (see 36 CFR 800.3(a)), If NHPA section
106 consultation is required and will occur, the district engineer will notify the non -Federal
applicant that he or she cannot begin work until Section 106 consultation is completed.
0

I
• • o
WAYSIZE
C WIDE BY 6 DEPTH
EXISTINGWEST BERLLTOP
M. B INCHES ABOVE
WATEER BAR T RIP RA.P ATER BAR
f Tot, STONE
COV(PACTED SCM
EROSION CONTROL GEOT Ek11L E
-E INCH ELEVATION ATER BAR CONSTRUCTED OF
CHANGE BETwEE.K CO WACTYO LOCAL SO41M7T TOPSOIL)
WATER BAR TOPS YNT1i MAmIUM SIDE SLOPES OF 1 3
I AN AREA AREA CONPEEILLY
r FLAT TL^. SPREAD WATER AHD
MINP.IIZE FLOW VELOCm
1.QH- 6 R�G1E9 TOPSOL
COMPACTED 500. 1O1°�
F�RAP K T -✓
APPROIDMATT LY
to INGiES TOPSOIL
EROSION CONTROL GEOTEXTILE
(SUPPLIED BY SOC)
RW RAP
A'TO STO",--\
NOTES:
1. ELEV AT1ON DROP ACRDSS PNTTO AREA APPRxD ATELY Z Fm I.
2 TREE$ PLANTED ON APPROXWTFLY 9 FOOTCENTERS (BY SCC}
3. ALL DISTURBED SOIL COVERED WITH STRAW EROSION CONTROL.
NOT TO SCALE B7A0(M AND SCEOPO WITi1 GRASS ffxGYPT AREAS COVERED WITH
SFODT WIDE WEED GAMER USED FOR TREE MANT14G (BY S=.
N PIPE RAZH Pvq UFED DRAW
PANS. 6IZED TO FULLY 6ft!(rI PAN wITwN
N IIDUR$ OF PAN B9NG PULL HLET
MLED W"ORAPI TILE SCAEEV TO
REDUCE PLUGG.NG.
FL[AM
1rrlca TOP$OILPRL
SAND CREEK CONSULTANTS, INC. PAN CONSTRUCTION DETAILS FIGURE 2
i .ao.R�.�ITaaew.1
wmn.rFL Yp 1414L
k�rq TM: LARSEN COOPERATIVE DATE: SEPT. zs. 21704
Ft]: �1ld�<K73
RI=ADFIELD. WI oRAvna gv: Mo

JUL. 16. 20OU 7:19AM CHAR-MECK U IY-ENO NO. 1975 P, 14
•
(e) Prospective permittees should be aware that section 1 I Ok of the NHPA (16 U-S.C.
474h-2(k)) prevents the Corps from granting a permit or other assistance to an applicant who,
with Intent to avoid the requirwocuts of Section 106 of the X11PA, has intentionally significantly
adversely affeeivtl a historic property W which the permit would relate, or having legal power to
prevent it, allowed simh significant adverac effoot to occur, unless the Corps, after consultation
with the Advisory Council on Historic Preservation (ACHP), detudnines that circumstances
)ttstifiy granting such nssistancu despite the adverse effect created or ponniltcd by the appiicanI
It circumstances justify granting the assistance, the Corps is retuired to notify the ACI)P and
provide documentation specl.fyinp, the circumstances, explaining the degree of daniago to Iltc
Integrity of any Witork properties affected, and proposed mitigation. "Phis doctitnontation must
include nay views obtained front the applicant, SUI'Cil'fMWO, appropriate Indian tribes if the
undartakiug occurs on or affects historic properties on tribal lands of affects properties of interest
to those tribes, and other parties known to have n legiturralc'inlarest in the impacts to the
permitted activity on historic properticg.
19. Designated Critical Resunrce Wnte . Critical resource waters include, NOAA-
desig;nated ntarint� sanctuaries, National Estuarino Research Reserves, state natural heritage siti:s,
and outstanding xraiioml rnsour o waters or otbur waters officially designated by a state as
having; particular environmental or ecological significance and identi€ted by the district engineer
after notice and opportunity for public comment. The district engineer may also designate
additiolial critical resource waters after notice and opportunity for Comment.
(a) Discharges of dredged or fill material into waters of the united Stales are not
authorized by NWPs 7, 12, 14, 16, 17, 21, 29, 31, 35, 39, 40, 41, 43, 44, 49, and 50 for any
activity within, or directly affecting, critical resource waters, htcluding wetlands adjacent to such
waters.
(b) For NWPs 3, 8, 10, 13, 15, 18, 19, 22, 23, 25, 27, 28, 30, 33, 34, 36, 37, and 38,
notification is required in accordance with gonarol corulition 27, fox any activity proposed in the
designated critical ruswircowoters including wetlands adjacent to lhosc waters. The district
engineer may authorke activities under lhcsc NWPs only after It is detenrilned that the impacts
to the critical resource waters will be no more than minimal.
20, Mitiwt' The district ongineer will consider the following factors whou
dotermining appropriate and practicable mitigation necessary to ensure that adverse effects on
the ngttatic ettvirutuucnt are minintol,
(a) Tito activity must be designed and canstruatcd to avoid and minienizo adverse effects,
both temporary and pertnanent, to waters of the United States to the maxi tnutn extent practicable
at the project site (i.e., on site).
(b) Mitigation in all Its forms (avoiding, minimizing, rectifying, reducing, or
compensating) will be rrquirrd to tho oxtent necessary to ensure that lite adverse offerts to th$
aquatic, environment are minimal.
(c) Curnponsatory mitigation at a minimum one -for -one ratio will be required for all
wetland losses that exceed I A 0 acre and require pro -construction notification, uniess the district
engineer deterntiues in writing that some other form of mitigation would be more
environinentally appropriate and provides a project -specific waiver of this requirement. For
wet;and losses of 1110 acre or loss that rcriniro pic-construction notification, the district engineer
May determine on a case -by -cases basis that compensatory mitigation is required to ensure that
0

A. 16, 2000 7:19AM CHAR—MECK UTY—ENG NO. 1975 P. 15
rr�
the activity results in minimal advcrso effects on the aquatic environment. Since the likelihood of
success is greater and the inapaetr. to potentially valuable uplands are reducod, wetland
reAorntioxi should be the tirst compensatory mitlgatiou option considered.
(d) For losses of streams or other open waters that require pro -construction notificatiurr,
the district engineer nury require compensatory mltigation,, such as stream restoration, to ensure
that the activity rosults in miaintal adverse effects on the aquatic environment.
(c) Compensatory mitigation will not be used to increase lire acrcagc losses allowed by
the acrengo limits of the NWPs. For example, if an NWP has an acreage limit of 1/2 acro, it
annnot he used to autherizo any ,project resulting in tlxu loss of greater than 1/2 acre of waters of
the United States, oven if compensatory mitigation is provident that replaces or restores some of
the lost waters. However, compensatory mitigation can and should be used, as necessary, to
enstrro that a project already nrcetfng the established acreage limits also satisfies the minimal
impact requirement associated with the NWI's.
(t) Compensatory mitigation plans for projects in or near streams or other open waters
will rtorrnaliy inoludc a requirement for the establishment, maintenance, turd legal protection
(e.g., conservation casements) of riparian areas next to open watery. In some cases, riparian urcas
rnny be the only compensatory mitigation required. Riparian areas should consist of'itative
species. Tha width of the required riparian area will address documented water quality or Aquatic
habitat loss concerns. Normally, the riparian area will be 25 to 50 feet widu on curb side of the
stream, but the district engineer may rcquiro slightly wider riparian a rvos. to address documonwd
water quality or habitat loss concerns. Where both wetl8nds and open waters exist on the project
site, the district engineer will determine the appropriate compousatory ntitigatiol► (cr.g., ripariun
areas and/or wetlands compensation) based on what is bent for tho aquatic environment on a
watershed basis. In cases where riparian areas are 4otermined to be the mast AppropriAte form of
compensatory mitigation, the district onginver finny waivn or reduce the re.quirement to provide
wetland comper>Satory mitigation for wetland losses.
(g) persnittecs may propose the use of it itigation hanks, in4ieu fee arrangements or
separate activity -specific compensatory mitigation. In nil cases, the mitigation provisions will
spe0fy tho party responsiblo for accomplishing and/or complying with thernitigation plan.
(h) Where certain (unctions and services of waters ofthe Iltrlted States are permanently
:tdversc ly affected, such as the conversion of a forested or scrub -shrub wetland to a lrerhaccous
wutlaud in it permanently maintained utility line riglit-of-way, rnitigatiora array be required to
reduce the adverse effects of the project to the minimal level.
21. r ttrLliN. Where States and authorized Tribes, or HIIA Where applicable, have
riot previously cc:rtiftcd compliance of an NWP with CiVA Section 401, individual 401 Water
Duality Certification must be obtained or waived (see 33 CPR 330.4(c)), The district engineer or
State or Tribe may require additional water quality management measures to ansure that the
authorized aotivity does not result in more than minimal degradation of water quality.
22. Coastal bane Manarter7rent, irr coastal states where an NWP has not prrsviously
received a state coastal zono management consistency concurrence, an individual state coastal
zone management consistency concurrence must be obtained, or a presumption of concurrence
crust occur (sec: 33 CFR 330.4(d)). The district engineer or a State may require additional
measures to ensure that die authorized activity is consistunt with state coastal zono rnattagernent
rcquirertrerrts.
o

Crop - -
Services(
1160 Brake Road, Rocky Mount, NC 27801
252-977-0308 Phone
252-973-0761 Fax
August 20, 2009 Via Certified Mail
Mr. B. Keith Overcash, P. E.
Ur-
Director
North Carolina Department of Environment and Natural Resources
Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27604
Ref. Crop Production Services
Princeton, North Carolina
Fugitive Dust Emissions Control Plan
Dear Mr. Overcash:
Per your letter of July 8, 2009, Crop Production Services, Princeton, NC submits the following Dust
Management Plan (DMP) in compliance with NCAC 2D.0540,
We have identified two areas at our facility on Luby Smith Road in Princeton, NC that will require dust
control measures:
+ Area 1: The dolomite lime storage pile and historic area of lime storage on the southeast side of
the property, and;
+ Area 2: Driveway / Parking Lot
For Area 1:
+ The area responsible for most of the airborne dust -the historic lime storage area on the southeast
end - will be excavated back to the natural soil level and back filled so the area can be seeded
with grasses. This will eliminate airborne dust from this area.
A The "active" lime storage area will be contained within a structure constructed of a 4 to 6-foot
high cast wall or equivalent on three sides measuring 36' x 75'. The open end will face east and
will include a ramp to prevent stormwater from flowing out of the storage area. On the west and
south sides, we will add a 6 to 8' high chainlink fence with appropriate sized mesh screening to
buffer wind impact. The north side will not be screened to allow the clam shell to unload the
lime from rail cars directly into the structure, eliminating the need to move the material twice.
The adjacent building provides a wind buffer on the north side. The lime pile will be shaped
(tabletop like) and will not be stored over the height of the containment structure. We believe
these efforts will effectively control any fugitive lime dust while allowing for operational
considerations without the need for a cover.

Ell
0
JUL. 16. 2008 7;19AM CHAR -DECK UTY-1116 NO. 1975 P. 16
23. tie i� Hl �snd_Gasc- y-Crtse Coni*jtions. 7fie activity must comply with any regional
conditions that may have been added by the Division Engineer (see 33 Cl<R 330.4(e)) and with
attty Guso specific conditions added by (lie Corps or by the state, IndianTribe, or 11.3. RPA in its
section 401 Water Quality Certification, or by the state] in its Coastal Zone Managemont Act
consistency determination,
24. Use o u i p le allti ttwide_ omits. The use of more thane Otte NW P fvr a single and
complete project is probibited, except when the acreages lass of waters of tiro United Stites
authorized by the NW1's clots not exceed the acreage limit of the NW3' with the highest sp► oitiud
acreage liniat. For example, if a road crossing over tidal waters is constntoted uncic:TNVR 14,
with associated bank stabilization authorized by NWP 1.3, the aniximurn uercagc loss of waters
of the United Statov for tiro totat project cannot exceed 1/3-tacrc.
25. Tra nsfel of _atior�wi a Perr�uit Verification, If the pemittco sells the psvperty
.associated with a nationwide pennit voelfication, the permittee may transfer the nationwide
permit verificatlon to the new owner by subtnitting a letter to the appropriate: Corps district office
to validate the transfer. A copy of tho nationwide permit verification must be attached to the
letter, and the letter must contain the following statemecnt and signature,
"When tic stn:ct► ras or work authorized by this nationwide permit are still in existence at the
ticne the property is traitsfeued, the tattres and conditions of this nationwide pertnit, including any
special Wild itionu, will continue: to he binding on the new owner(s) of the property. TO validate
9
X , ,P

Mr. B. Keith Overcash, P.E.
SPage 2 'OY6,
August 20, 2009 '0
• We are working with a consultant to plant additional windbreak trees on the southern, northern,
and eastern boundaries to add to and replace the tress we planted earlier. When these trees are
established, they will form an additional windbreak further minimizing any potential dust
emissions leaving our property.
The timeline for this work is as follows:
• Excavation of historic lime storage area will begin this summer and will be completed so that the
grasses can be planted in the Pall of 2009 or no later than March 31, 2010. Until the grasses are
planted and established in this area, we will spray with water to suppress the dust. (See Area 2
for implementation schedule.)
• Lime Containment Area: Containment will be in place prior to December 31, 2009. Until the
structure is complete, we will wet the pile to reduce airborne particles. We do not plan to receive
any additional shipments of lime until the containment structure is complete.
• Windbreak Trees. The trees will be planted Fall 2009 or no later than March 31, 2010 to
improve chances of becoming established.
Area 2: Driveway / parking Lot.
• • Some of the areas in the driveway and parking lot will be excavated and prepped for grasses and
low bushes. This will eliminate some of the dry surface areas around the facility. Refer to the
Site Plan attached for proposed planting areas.
The areas that cannot be planted will he sprayed on a routine basis with water to suppress the
dust. A schedule will be developed and a log kept to document the spraying.
The timeline for this work is as follows:
The areas that can be planted will be done no later than March 31, 2010.
The entire area is currently being sprayed with water on a routine basis. The log is available for
inspection at any time.
When this plan is approved, we will document training of all personnel on all aspects of the plan.
Records will be kept of all spraying to suppress dust.
A site plan and a sample of the spray Iog are attached for review. We appreciate the opportunity to
submit the plan and look forward to your comments.
Sincerely,
Shannon Peedin Bill Coleman Nancy Vincek
Branch Manager General Manager Mgr, Operations Compliance
Phone: [phone] Phone. [phone] Phone: [phone]
cc: Kirk Williams, Greeley, CO

JUL. 16.2008 7:20AM CAAfi-MECK UTY-ENG N0. 1975—P. 17
thr, transfer of this nationwide pennit and the associated liabilities ussoclatcd with compliance
with its tens and conditions, have the tninsfereo sign anti date below."
(Transfoiw.)
(hate)
26. G'urnpliang"9):fitica Lion. Each ponnitt a who rcccivcd an N WP verification From the
Corps must submit a signed ccrtiflcation regarding the completed work and any required
mitigation. 'rho certification farm must be forwarded by the Corps with the NWp verification
letter artd will include:
(a) A statornent that the authorized work was done to accordance with the NWk
audierization, including any general or specific condition~,
(b) A, statement that any required witigat.inn was completed in accordance with the permit
conditions; and
(c) Thu signature of the pertnitteo certifying the completion of tbo work and mitigation,
27. &e-Cgils(L%fj-gn Notificatloq, (a) Tin! U. Where required by the towns of the W'WP,
tl►v prospective permitten must notify the district engineer by submitting a pre -construction
notifications (PCN) as early as possible, The district engineer roust determine If tho PCN is
completo within 30 calendar days of the date of receipt and, as a general rule, will request
additional int'orntatiun steceasury to mako the PCN complete only onvo.11owcver, if the
prospective pennitten does not provide all of the requested information, then tlke district engineer
will notify the prospective perrttittec that the PCN is still lncompleto and the PCN review procoss
wil I not coinmeacc until all of the requested information has been received by rite district
engineer. 'I'!te prospective purmittee shall not begirt rite activity until either;
(1) He or sho is notified in writing by the district engineer that tho activity may pmoewl
under the N WP with any special conditinns Imposed by the district or division engineer; or
(2) Forty-five calendar days have passed from the district ongincer's receipt of'die
complete PCN and the prospective permittee king not rcccivcd written xiotice from the district nr
division enginesor. However, if the porroitwo was required to notify tho Corps pursuant to general
condition 17 that listed species or critical habitat Wight affected or in the vicinity of the project,
or to notify tiro Corps pursuant to general condition 18 that the activity may have the potential to
cause offects to historic properties, the permutes cannot begin the activity until receiving written
notification from the Corps that is "no effect" on listed specieg or "no potential to cause effects"
on historic properties, or that any consultation required under Section 7 of the Endiingered
Species Act (see 33 CFR 330.4(f)) and/or Section 106 of the National, Historic Preservation (sec
B CFR 330.4(g)) is compicted. Also, work cannot begin under NWI's 21, 49, or 50 until the
permittee has received written approval fi:om the Corps. If tho proposed activity requires a
written waiver to exceed Specified limits of an NWP, the pennitteo cannot begin the activity until
thu district engineer issues the waiver; If thv district or division engineer notlfles that parmittee in
writing that an individual permit is rcyuired within 45 calendar Clays of receipt of u cumplotc
PCN, the pertnifte. cannot begin fha activity until apt hidividunl pennit has been obtained.
10
•

t8)
LAW OrrICCS
MCKENNA & CUNEO
♦Ol A.IO[L[f
1575 EYE STREET, N.W.
Oirva■
... iou Tr ►LOW[w fr■J1L7
WAS14IN42TO,MI D.C. 90000
wIT[ 000
606 AMO[L916 CALIrQA—A 00071
{IIOl1 78p •7500
'O u[
11121 a0e•IOOO
oarv[w, cOLotACO 00403
iAr s■AI.c10C4
C Afla wOOAi■■{ M,.MarCQrr �6.cc
1]O71 •i0.0700
!r[uw■T ir■iiT 7QW[■
[■W>t[LO
ONC WA■w[T 01,A[A
FAX liot 170 9•7004
Av[.V[ Our■[ Jf7. ■O■ a
4r IIIArCIfCO.CwL17emr1w f.bf
I-SI a.7.0294
Cu t2411 *.a. a.*
RICHARD A. FLYE
oiN[cT awl. IJO[I 749•70a!
March 6, 1991
By Hand
Mr. Frank E. Hall
Deputy Director, Permits Division
Office of Water Enforcement and
Permits
United States Environmental
Protection Agency
401 M Street, SW
Northeast Tower, Room 214
Washington, DC 20460
Re: Stormwateg Permitting
Dear Frank:
Thank you for your offer to assist Karl Johnson of The
Fertilizer Institute and me in our efforts to access the
administrative record of the November.16, 1990 stormwater
permitting regulations in light of the temporary closure of the
EPA library. I enclose copies of the documents I promised.
These documents relate to the potential concerns I outlined in
response to the questions you posed yesterday.
Briefly, our concerns stem from conflicting advice provided
by the new "Stormwater Hotline" on an issue that was resolved six
or seven years ago. We believe the conflicting advice stems from
the Hotline contractor's unfamiliarity with the issue and its
history.
EPA's development of the September 26, 1984 stormwater
regulations, 49 Fed. Reg. 37,998, raised an issue of stormwater
permit coverage that was of great importance to the U.S.
fertilizer industry and American agriculture in general. The
1984 regulations required permits for certain stormwater
discharges at "industrial facilities." The question was whether
or not farm supply outlets that sell fertilizer to farmers were
subject to stormwater permitting because they incidentally mix

0
JUI. 1b.2000 7:70AM CHAR-MECK UTY-EUG
NO.1975 P. 19
(2) For all NW1' 48 activities requiring pre-eonsttuetlon notification find for either NWP
activities requiring pre -construction notifioatlon to rite district engineer that result In tiro loss of
greater than 1/2-acre of waters of the United States, the district engineer will immediately
provide (u.g., via facsimile transmission, overnight rttt;il, or outer expeditious manner) a copy of
the PCN to the appropriate Federal or state offices (U.S. FWS, state natural resuinc or water
quality nj3oncy, EPA, Stale Historic Preservation Officer (MPO) or Tribal Historic Preservation
Oliico(THPO), and. if appropriate, the NMFS).'With the exception of NWP 37, these agencies
will then have 10 calendar days from the date the material is transmitted to telephone or fax ft
district engineer notice that they iuiemd to provide substantive, site -specific comments. If"so
contacted by no agency, the distt•ici engineer will wait rail udditionnf 15 calendar days before
ncnkitrg n decision on the pre -construction notificntion. The district engineer will fully consider
agency comments received within tho spuciftcd time fia ma, but will provide no responso to the
resource agency, except as provided below. The district ongineor will indicate era the
ndministrative record associated with each pre -construction notification that the resource
agencies' concerns wero considered. ForNVP 37, the emergency watershed protection and
rehabilitation notivity may proceed immediately in casos where there is an unacceptable hrtiard
to life or a significant loss of property or economic hardship will occur. The district engineer will
consider ally comtucnts mcrived to decide: whether the NWP 37 anthorirgtion should bo
modified, s►>;spendcd, or revoked iti accordance with the procedures nt 33 CM 3:30.5.
(3) in cases of where the prospective perrttitteo is not a federal agency, the district
cttginccr will provide a response to NMFS within 30 calendar days of receipt of any Essential
Fish Habitat conservation recommendations, as required by Section 305(h)(4)(B) of the
Magnuson -Stevens Fishery Conservation and Management Act.
(4) Applicants are encouraged to provide the Corps multiple copies of pro-coustructiun
notifications to oxpeditu ugenoy uourdination.
(5) For NWP 48 activities that require roportutg, ibo district migirtcer will provide a ropy
of each ,report within 10 calendar days of receipt to the appropriate regional office of thoNMf S,
(e) i t 'ot girtecr' l7c risio�t; Jn reviewing the PCN for the proposed activity, the
disiriet rxtgirtrcx wilt detorrrtino whether the activity authorized by the NWP will result in more
than minimal individual or cumulative advorso cnvironmental (;Meets or pray be cantraty to the
public interest. Jf flin proposed acclivity requires a PCN and will result fn a loss of greater than
1/10 acre of wetlands, the prospective pcmtittee should submit a mitigation proposal with the
PCN. Applicants may also propose compensatory mitigation for projects with smaller impacts.
The district engineer will consider any proposed compensatory mitigation the applicant has
included In the proposal in determining whether the net advorsc CrIVIVOtitttentnl effects to the
aquatic envirotnnont of the proposed work are minimal. The compensatory mitigation proposal
may be either conceptual or detailed. If the, district onglnenr determines that the activity complies
with the terms and conditions of the NWP and that the adverse effects on the aquatic
environment aro minimal, after considering mitigation, the district engineer will notify the
pertnittee and include, any conditions the district engineer dooms necessary. Ilse district erighieer
trust approve any conpensatory mitigation proposal before The parmittee commences work. If
the prospective perrttitteo olocts to submit a compensatory mitigation plan with the VCN, the
district engineer will expeditiously review the proposed compensatory mitigation plan. The
district engineer must review the plat within 45 calendar days of reccivinq a complete PCN and
determine whether the proposed mitigation would ensum no more than minimal adverse cfrcutas
on the aquatic environment. if thc.net adverse effects of the project on the agviatic essvinxretrent
0 12

-Aw ar"Es
MQK£NNA 6. CUNEO
Mr. Frank E. Hall
March 6, 1991
Page 2
different fertilizers together to meet the needs of the farmer
customer. As I outlined to you, these farm supply outlets
generally sell all three of the basic nutrients, nitrogen,
phosphorus and potassium. As part of the services they provide,
the outlet assists farmers in conducting soil testing to
determine how much of each of these nutrients is required. After
this is determined, the farmer has two options. Either he can
make three separate applications of nitrogen, phosphorus and
potassium fertilizer, respectively, or he can mix the three
fertilizers together and make one application. Obviously, the
second option is far less time-consuming and expensive,
Therefore, the fertilizer outlet will mix the three fertilizers
together, in the correct proportions, thus allowing the farmer or
the outlet to make one application. Where necessary and
physically possible, the mix may also contain "micronutrients"
such as zinc and crop protection chemicals.
As TFI pointed out in 1984, this mixing of products at farm
supply outlets can be distinguished from the production of mixed
or blended fertilizer, often by chemical reaction, at large
fertilizer mix and blend plants where the resulting fertilizer
products are sold in bulk to retail suppliers or bagged for sale
to such retail suppliers, including farm supply centers,
supermarkets, drug stores, garden centers, etc. These bulk blend
and mixed fertilizer plants are engaged in "industrial activity,"
farm supply outlets combining fertilizer products incidental to
their sale of those products to a farmer are not.
This issue of stormwater permit coverage of farm supply
outlets potentially affected many thousands (up to 10,000) local
businesses, many of them family run. Consequently, this issue
was thg major issue addressed by TFI during and subsequent to the
development of the 1984 regulations. In this connection, TFI met
with EPA representatives to discuss this issue and also conducted
a workshop, attended by EPA representatives, at which the issue
was discussed extensively. After full consideration, EPA agreed
that farm supply outlets were not subject to stormwater
permitting.
This conclusion was adopted in TFI's voluntary stormwater
discharge data -gathering Program. TFI's March 22, 1985 draft
commitment letter addressing the data -gathering program (copy
enclosed) carefully restated this conclusion (see pages 9-11).
EPA's agreement was again confirmed in conversations with EPA
officials (see enclosed April 9, 1985 memorandum). EPA's
response to TFI's draft commitment letter (copy enclosed)
® outlined changes required in TFI's data -gathering program. No

•
JUL. 16.2068 7:21MA CHAR-MECK UTY-ENG NO. 1975 P. 70
(alter rolrsidnintion of the compensatory niltigntion proposal) aro determined by the district
engineer to be minimal, tho district ouginear will provide a timely written response to [tie
applicant. The response will state that the project can proMt:d utrdcr the terms And conditions of
the NWP.
If the district engineer determines that the adverso effects of the proposed work are more
than minhnul, then the district engineer will notify the applicant either., (1) That the project Blocs
not qna i fy for authorization under the NWP and instruct ilia Applicant on the procedures to seek
authorization under an individual permit; (2) that the project Is authorized under the NWP
subject to the applicanfis submission of a mitigation plan that would reduce the adverse effects
on tho aquatic environment to the minimal level; or (3) that the ptujoct is authorized under the
NWV with specific modifications or conditions. Where the diistricl onginear determines that
mitigation is required to ensure no more than minhnal adverse effects occur to the aquatic
environnient, the activity will be authorized within the 45-dny PCN period. The authorization
will inclodo the neressaiy conceptual or specific mitigation or a requirement that the applicant
submit a mitigation plan that would reduce ilic adverse olfec[s on dic aquatic oriviromnont to tltc
minimal level. When mitigation is required, no work In waters of the United States may Occur
until file district engineer has approved it spocif c. ritigation plan.
29. Sin o a d ui itot . The activity must be a single and complete project. 'file
same NWP cannot be uscd rnoro than oncefor the same single and complete project.
FUR-DEM INFORMATXQl+I
1. District Fnginccrs.bavo authority to determine if an activity complies with tlic terms
and conditions of an NWP.
2. NWPs do not obviate the need to obtain otter federal, state, or local perrrriis,
approvals, otrauthorization,; required by law.
3. NWP.-. do itot: grant nay property rights or exclusive privil4gos.
4. NWPs do not authorize any injury to the property or rights of others.
5. NWPs do not authorize interference with any existing or proposed Federal project.
DIE FINI' QNS
Rest a e l pyaq#gc (B4 s): Policies, practices, procedures, or structures
Implemented to mitigate the adverse environmental ctferts on surface water quality tesulttng
from clevslopment. BMPs are categorized as structural or non-structural.
Caml2ensatory odfigalion: 'rite re4tor4tion, establishment (creation), or
preservation of aquatic resources for ilic purpose of compensating for unavoidable adverse
impacts winch remain alter all appropriatc and practicable avoidattco at►d in'suhniiation has been
achieved.
Cuayntly Igalocable: Useable its is or with some maintonance, but not so 4graded as to
essentially rcquirc reconstruction.
D4,C-bgrze. The Will "discharge" moans nny discharge of dredged or fill material.
tceirir, ram: Tile rrrariipulation of the physical, chemical, or biological eharattei istics of
an aquatic resource to heighten, intensify, or improve a specific aquatic resource f mcdon(s).
Bnhaii cement results in the gain of selected aquatic resoitrcu function(s), but may alio lead of u
13

LAW OMCL$
MsKENNA s CUNEO
Mr. Frank E. Hall
March 6, 1991
Page 3
changes were required insofar as the non -inclusion of farm supply
outlets was concerned.1/
Given the time and effort devoted to this important issue
by both TFI and EPA, TFI considered the issue resolved. TF1
carefully reviewed both the December 7, 1986 proposed stormwater
permitting regulations, 53 Fed. Reg. 49,417, and the November 16,
1990 final regulations, 55 Fed. Reg. 47,990. Neither of these
documents in any way suggested that the issue did not remain
resolved. To the contrary, the proposed and final regulations
confirmed the 1984-1985 resolution. Farm supply outlets are
properly classified in SIC Code 5191 - Farm Supplies. Bulk mix
plants are properly classified in SIC Code 2875 - Fertilizers,
Mixing only. Facilities in SIC Code 2875 are subject to
stormwater permitting, facilities in SIC Code 5191 are not.
Furthermore, the SIC Code Manual description of Wholesale Trade,
of which SIC Code 5191, is a part, makes it clear that:
In addition to selling, functions frequently
performed by wholesale establishments include
maintaining inventories of goods; extending
credit; physically assembling, sorting. and
gradi-ng goods in large lots; Ylreaking Sulk
and redistribution in smaller lots; delivery;
refrigeration; and various types of promotion
such as advertising and label designing.
1987 SIC Manual at 287 (emphasis added). I enclose copies of
relevant pages of the SIC Code Manual. Thus, the SIC Manual
precisely describes the fertilizer mixing activities engaged in
by farm supply centers as part of Wholesale Trade. The preamble
to the November 16, 1990 stormwater regulations makes it clear
that "EPA intends that the list of applicable SICs will define
and identify what industrial facilities are required to apply,"
55 Fed. Reg. 48,011; and that the regulations "exclude from the
definition of industrial activity, at 5 122.26(b)(14) of today's
rule, those facilities that are generally classified under the
office of Management and Budget Standard Industrial
Classifications (SIC) as wholesale, retail, service, or
commercial activities. 55 Fed. Reg. 46,007 (emphasis added).
1� For your information, I also enclose a copy of TFI's April
12, 1985 final commitment letter. The voluntary data
® collection program was discontinued by EPA shortly after
TFI's final commitment letter was submitted.

JUL, 16.2008 7:21AM CIIAR-MICK UTY-ING N. 1975 P. 21
doulinc in other aquatic resource lunction(s). Enhancetima dues notresult in a gain ;n acivatie
resource area,
Egjt_@mernl cum: An ephemeral streani Iias flowing water only during, and fur a short
duration after, prceipitation events in a typical year. Ephemeral stream beds are located above the
water table year-round. Groundwater is not a sauna of water for the strumm Runoff from rainfall
is thu primury source of water fur strctuat flow.
9 k(;dmirrtr (rreutlnri): 1 e manipulation of tht; physical, chemical, or biological
characteristics present to develop wx aquatie resource that did not proviuusly exist at an upland
site. t?stablislunent results in a gain in acluntic resource ama.
roySrU. Any prehistoric or historic district, site (including xrubacological
silo), building, structute, or other object included in, or eligible fbr inclusion In, the Natiorml
Register of Historic Places maintained by the Secretary of the Interior. 7Vs term includes
artifacts, records, and rornains that are related to and located within such properties. 'Chu; femur
includes properties of traditional religions and cultural importance to an Indian tribe or Native
Hawalimi organization and that meet the National Register critarin (36 CFR part 60).
!n endent ttdillty: A test to determitie what constitutes a single and complete project in
the Corps regulatory program. A project is considered to have Independent utility if it would be
constructed absent the construction of other projects in the project area, Portions ofa multi -phase
project that depend upon other phases of the project do not have independent utility. Phases of.`a
proicct That would be constmeted even if the other phases were not built can be considered as
separate single and complete projects with independent utility.
jnh ftrent.slre—aw An intermittent stream has flowing water during certain times of the
year, when groundwater provides water tar stream flow, During dry periods, iunterntiUent streams
may not have flowing lunar. Runoff from rainfall is a supplemental source of water fur .-itmatu
flow.
loss of ate s n};Irs__1nited SU s: Waters of the United States that are pemuancntly
adversely affected by tilling, flooding, excavation, or drainago bemuse of the regulated activity.
Permanent adverse effects include permanent discharges of dredged or fill material that change
an aquatic: area to dry land, Increase dto bottom olovatcun of a waterbody, or change du: use of it
waterbudy. The ncroage of loss of waters of tho United States is a threshold ruousuretrtent of the
impact to.iudsdictional waters for dutcriaUdrtg whether a project may qualify for tin NWP; it is
not n not tltrvshold that is calculated after considering compensatory mitigation fitat Piny he itsed
to offset losses of aquatic functions and scrviccs. Tho loss of strearn bed Includes the linear feet
of stream bed that is filled or excavated. Waters of the Uolted States temporarily filled, flooded,
oxenvated, or drained, but restored to pre -construction contours and elevations aficr Gonstructinn,
are not included In dio measurement of loss of waters, of the I.lnited States. Impacts resulting
from Activities eligible. for exemptions under Saction 404(f) of the Clean Water Act aru not
considered when calculating the toss of waters of the United States.
Nvactf4a byefla A non -tidal wetland is a wetland that Is not subject to the cbb euud
Dow of tidal waters. Ilse definition of A wetland can he found tit 33 CPIs 32$3(b), Non -tidal
wetlands contiguous to tidal waters are located landward of (Ito hieli title line (i.c., spring hich
tide tine).
Oymw water, For purposes of the NWP s, an open water is any area that in a year with
normal patterns of precipitation has water flowing or standing above ground to the extent that ary
ordinary high water mark can be determined, Aquatic vegetation within tiro area of standing or
0 14

LAW arrices
MCKENNA S CUNEO
Mr. Frank E. Hall
March 6, 1991
Page 4
The potential concern has arisen as a result of conflicting
advice on this issue provided by the Stormwater Hotline. In
early February 1991, the National AgriChemical Retailers
Association (NARA), unaware of the history of this issue,
contacted the Hotline for advice on the permit coverage of farm
supply outlets. The advice they received was in full accord with
the conclusions reached by EPA in the mid-1980's. I enclose a
copy of the NARA Washington Update, sent to its members,
reflecting the advice initially received.
In the last week, however, one of TFI's member companies,
and NARA itself, have been informed by the Hotline that farm
supply outlets must apply for Stormwater permits for their
incidental mixing activities. The person to whom TFI's member
company and NARA recently spoke was not the same person to whom 6
NARA spoke earlier.
We believe that this conflicting advice results simply from
the Hotline contractor's unfamiliarity with the long and detailed
history of this issue. Therefore, we would appreciate it if EPA
could inform the Hotline contractor of the long-standing
resolution of this issue so that advice provided in the future by
the contractor will be consistent with that long-standing
resolution.
If, however, the explanation for the conflicting Hotline
advice lies elsewhere, we believe it is essential that we meet in
the immediate future to discuss and resolve the enormous problems
that would be occasioned by a reversal of EPA's earlier
resolution of this issue. Such a reversal of position could
require up to 10,000 facilities to apply for stormwater permits
at a point in time only two weeks away from the deadline for
group applications. Furthermore, such a change of position would
be without notice to the affected regulated community or the
public and without an opportunity for comment or full
consideration of the important issues involved.
Thus, if there is any more to the conflicting Hotline
advice than the contractor's lack of understanding of the history
of this issue, please let me know immediately so that we can
L_J

0
JUL. 16.2000 7:21AM CHAR-MECK 11TY-06 NO. 1975 P. 22
flowing water is cither non -emergent, sparse, or absent. Vegetuted shallows are considered to be
open waters. Examples of "open waters" include rivers, streams, lakes, and ponds.
Ord _bLa!X MgLi Wurer,lL%,_r,�,rk: An ordinary high water mark is a► IIne on the sl=oro
established by the fluctuations of water and indicated by physical characteristics, or by other
appropriate means that consider the characteristics of the surrounding areas (see 33 CI:R
328,3(o)).
Perg 1tt a!_st1'egin: A perconial strove has flowing water year-round during a typical year.
Tbu water table is located above the stream bed for mna of rho your. Groundwater is the primary
source of water for stream flow. Runoff from rainfall is a supplemental snttrce of water for
stream flow.
frarrfcable: Available and capable of being done after taking into cousideration cost,
existing technology, and logistie9 In light of overall project purpoaos.
1 rN`rcre.str_r�.r! an rrestf :rifler: A request submitted by the prq)cct proprinunt to the Corps
for contirmation that a patticular activity Is authorized by nationwide permit. The request may be
a permit application, letter, or similar document that includes information about the proposed
work and its anticipated onvironrncatal cffccts. Pro -construction notification may be required by
the terms and conditions of n nationwide permit, or by regtonnl conditions. A pre -construction
notification Way be VOluuutarily subtrultted iri oases where pre -constriction notification is not
required and the project proponent wants confirmation that the activity is anthadzed by
nationwide permit.
frerervalfotl: The removal of a threat to, or preventing the declino of, aquatic resources
by an action in or near those aquatic resources. This term includes activities commonly
associated with the protection and maitttenatwe of aquatic resources through the implorucntation
of appropriate legal and physical mechanisms, PreservAtion doo not result in a gain of aquatic
resource area or Ainctiony.
Re-eslablfxlemcrar: The manipulatlun of the physical, chemical, or biological
characteristics of a site with tlw goal Of returning naturallitistoric functions to a former aquatic
resource. Re-establishment results in rebuilding a Corner uquatic resourco and results in a Rain in
Aquatic resource area,
Aelrabllfta&n: 'Cho manipulation of tho physical, chemical, or biological characteristics
of a site with the gvul of ropalting natttrallhistoric functions to a degraded aquatic resource.
Rehabilitation insults 1n a gain in aquatic resource ftuiction, but does not result in a gain in
aquatic r000mcc area.
Ractnrnlfn)r: The manipulation of the physical, chemical, or biological c1SArgctaristios of it
site with tlrs goal of returning natturdl/historic firnctlons to a former or dtgruded aquatic resource.
For the purpose of tracking not Unins in aquatic resource area, restoration is divided into two
catogorie6: re-cstabilshment and rehabilitation.
Rlf1Te and vool e: m dex: Riffle and pool complexes are speciul aquatic Sites under flue
404(b)(1) Guidelines. ltifflo and pool complexes sometimes characterize steep gradient sections
of streatacs. Such Stream sections are rcoognimblo by their hydraulic characteristics. 'flta rapid
movement of water over at courso subamte in riffles results in a rough flow, a turbulent surface,
and high dissolved oxygeit lovels in the water. Pools are deeper areas associated with riffles. A
slower Motu velocity, a streaming flow, a smooth surftico, and a finer suhstrato characterize
Pools.
RIMLaLi. OW.W: Riparian areas are lands adjacent to streams, lakcs, and cstuftrine-unarinc
shorelines. Riparian areas fire transitional between termstriul and aquatic ecosystems, through
0 is

LAW orfaC[S
MCKF-NNA & CUNCO
Mr. Frank E. ball
March 6, 1991
Page 5
discuss the resulting issues in greater detail. Also, if you
need any further information, please feel free to contact me at
789-7682.
RAF/ptr
Enc.
Cc: Chris Myrick, NARA
•
40
Sincerely y urs,
01--4
Richard A. Flye
Counsel to The Fertilizer
Institute

n
f�
JUL. 16.2008 7:2A MiAR-MECK UTY-ENG N0, 1975 P. 23
which surface and subsurface hydrology connects watorbodi©s with their Adjacent uplands.
Riparian areas provide a variety of eeologleol funotions and services and help improve or
maintain local water quality. (See general condition 20.)
Shtlllish seeditru.-'Ille placement of shellfish seed and/or suitable substrate to increase
shellfish production. Shellfish seed consists of intntature Individual shellfish or individual
shellfish attached to Hhells or shell fragments (i.e., spat on shell). Suitable substrate may consist
of8101#ish shells, sholi fragments, or other appropriate materials placed into waters for shellfish
habitat.
,Ftjle Mtn 1 c 1Bp to rMjyt: The term "single and complete project" is durtried at 33
CPR 330.2.(1) as the total project proposed or accomplished by o-no uwncrldcveloper or
partnership or other association of owtlers/devetopers. A singdo and complete project roust have
independent utility (see definition). Fnr linear projects, a "single and complete p>ojoct" is all
crossings of a singtowater of the Uxtitcd Status (i.e., a single waterhody) at a specific loomiott.
For linear projects crossing a single waterbody several times ttt soparatc and distant locations,
each crossing is considered a singlo and complete project. However, individual chatmofs ill a
braided strcum or river, or individual arms of a large, irregularly slurped wetland or lake, ate., are
not .ScpArato waterbodios, and crossings of such features cannot be considered'separately.
;5'tnrnft_var. er&err : Stormwater management is the mccbauism for controlling
stormwater runoff for the purposes of reducing dowrratrcam erosion, water quality degradation,
And flooding and mitigating the advertise effects of changes in land use oil the aquatic
environment.
1%tormryat1• itronaggg -nt faces &Ues: Stormwater management facilities are those facilities,
includbig but tint limited to, stormwnter retention and detention ponds and best management
practices, which retain water for a pariod of time to control runoff and/or improvo this quality
(i.c., by reducing the concentration of nutrients, sediments, hazardous subsWnces and other
pollt,tants) of stormwawr nwofil.
&ap r &. The substrate of the straw) channel between the ordinary high water wftr cs.
They substrate may be bedrock or inorganic particles that range in size from clay to boulders.
Wetlands contiguous to the stream bed, but outside of the ordinary high wattsr marks, Are not
considered part of the stream bed.
lSircam chatltt4 znifv_If: The manipulation of a strctun's course, condition, capacity, or
location that causes more than minimal interruption of normal stream processes. A ohannolizod
stream remains a water of the United States.
trut:ture: An object that Is arranged in a delitute pattern of organization. Examples of
stnictures include, without limitation, any pier, boat dock, boat ramp, wharf, dolphin, weir,
boom, breakwater, bulkhead, revetnm:nt, rhprap, jetty, artificial island, artificial reef, permanent
111006118 structure, pnwvcr transmission line. permanently moored floating vessel, piling, aid to
navigation, or any other maamnde. obstuclu or obstruction.
.77& svrtland: A tidal wetland is a wetland (i.e., water of the United States) that Is
Inundated by tidal waters. 'rho doCnitions of a wetland and tidal waters can be found. at 33 CPR
328.3(b) and 33 CPR 328.3(f), respectively. Tidal watots rise atul fall in a predictable and
measurable rhythm or cycle duo to the gravitational pulls of the moon and son. Tidal waters end
where the rise and fall of the water surface can no longer be practically measured in a predictable
rhytiuu due: to wasking by other waters, wlnd, or other effects. Tidal wetlands are located
chnrvielword of the high tide line, which is defined at 33 CFR 32$.3(d).
0 16

L.J
•
Ju.. 31 191 11:38 M&C
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01wtCT a-A441041 1,6e•7,468
LAW OF9,1ces
MCKENNA & CUNEO
%574 LY9 STTatltT, N.w,
%V&G"**AG7Oti. CL C. 80o400
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June 14, 1991
Thomas J. Seaton, Esq.
Attorney Advisor
Office of Wastewater Enforcement
and Compliance (EN-336)
United States Environmental
Protection Agency
401 M. Street, SW
Washington, DC 20460
,OM P. 2J4
Re: T I SjQrMXj&jtr Pgrmit&inq Issues
Dear Mr. Seaton:
Oawwtw
■VITs 000
303 LAM scYtwTUMTM AVtwyr
acwvcr,eauo,rao cocoa
13031 430-WOO
,rn,sat�s
ter.
ArcwVc 1,aUlsc set. so■ T
s-.060 edwas"16 "661U44
Ou t3921 E40•40do
During our recent conversation, you requested that The
Fertilizer Institute prepare a letter, for EPA review and
approval, summarizing TFI`s understanding of the agency's views
on the scope of the Clean Water Act's stormwater permitting
program as it applies to fertilizer outlets. I enclose such a
letter from Gary Myers, President of TFI.
I would appreciate it if you and others involved at EPA
could review this letter and return an executed copy to me at
your earliest convenience. If you have any questions concerning
the enclosed letter, or any other aspect of this matter, please
feel free to contact me at 789-7682.
Sincerely yours,
I
F1ye
The Fertilizer
Richard A.
Counsel to
Institute
RAF/pw
Enc.
is cc: G.D. Myers

JUL ib. 1008 1:22AM CHAR-MECK NTY-ENG N0. 1975 R. 24
•
T!Pg�tuted sf�allotivs: Vegetated shallows are special aquatic sites under the 404(b)(1)
Guidelines. They ura urous that are permunently inundated and lender normal circumstancos have
rootedaquatic vegetation, such as seagrasses in Marino and estuarine systems and a variety of
vasuislar rooted plws in freshwater systems.
WoLerbod: For purposes of the NWPs, a watorbody is a jurisdictional water of the
United States that, during a year with normal patterns of precipitation, has water flowing or
standing above ground to the extent that. an orr inAry Haigh water spark (OHWM) or other
indicators of.jurisdiction con be determined, as well as any wotland area (sen 33 CPR 328.3(b)).
if a jurisdictional wetland is ldjacent--meaning bordering, contiguous, or neighboring --to a
jurisdicti<ourd waterbariy displaying rexs OHWM car other indicators of jurisdiction, that waterbody
and its adjacent wetlands arc considered together as u single aquatic wit (sins 33 CFR
37 9.4(c)(2)). Exarnplos of "waterhodia5" include streams, rivers, lakes, ponds, and wetlands.
1
LJ
0 17

LLIJ LNSTIrIM 501 Second S!roo. N.S.. Washing an. D.C. 20002 (20M 675432W
GARY D. WYEAS
Prot
June 14, 1991
Thomas J. Seaton, Esq.
Attorney Advisor .
Office of Wastewater Enforcement
and Compliance (EN-336)
United States Environmental
Protection Agency
401 M Street, SW
Washington, AC 20460
. Re: 6tormva&1r Permitting
Dear Mr. Seaton:
•
Over the last seven years, The Fertilizer Institute (TFI)
and the United States Environmental Protection Agency (EPA) have
engaged in a series of discussions and correspondence concerning
the scope of the Clean Water Act's stormrater permitting program
as it applies to fertilizer outlets. The correspondence involved
includes an exchange of several letters in 1985 and TFI's letter
to EPA of March 6, 1991.
Based on our correspondence and discussions, TFI
understands that EPA agrees that facilities primarily engaged in
the wholesale or retail distribution of fertilizer to end users
are properly classified in Standard Industrial Classification
(SIC? Code 5191 - Farm Supplies. Therefore, such facilities are
not subject to the storavater permitting program established by
S 402 of the Clean Water Act, 33 U.S.C. S 1342. Furthermore, EPA
agrees that this conclusion is not altered by the fact that such
facilities may mix or blend different fertilizers to meet the
needs of their customers. Finally, we understand that EPA also
agrees that these facilities are properly classified in SIC Code
5191 even though they may in some cases ship to or exchange
fertilizer with other retail or wholesale outlets before shipment
to the ultimate end user.
— - oo -A** . rwy• »n A" "44 s T®lecooior. (2= 54"123

JUL. 16. 2006 7:22ANi CPAR-NECK UTY-ENO N0, 1975 P. 25
O]$AILC ,Y.D— X }CIS EOR_NATIONWYriLI PERM IS IN TH -E WILM1N TON
DININCT
1.0 Excluded Waters
The Corps has identified waters that will be excluded from tho use of all NWP's during certain
tlrve..fimmes. These waters are:
1.1. Anadromons Trish Spimming Areas
Waters of the United Stales identified by either the North Carolina Division of Marine Fisheries
WIL)MID or the North Carolina Wildlife Resources Commission (NCWRC) its anadromous fish
spawning areas arc excluded during the licriod between February 15 and Jirne 30, W itlannt l)Tivr
written approval front NCDMT,or NCWRC And the Corps,
1.2. Trout Waters 1VIorntorium
Waters of the United States in the iwraly-live dcslh►nated tront counties ofNottlt Carolina ern
oxcluded during the period between October 15 and April 15 without prior writtenapproval from
the NCWRC. (see Section I. b. 7. for it list of the twenty-five trout counties).
1.3. Sturgeon Spawning Areas
Wuturs of the Unitcd Slates designated as sturgeon spawning areas are oxclurled during the
period between February 1 and Swle 30, without priur written appovai from the Nationisl Marine
Fisheries Service (NMTS).
2.0 Waters Requiring Additional Notification
'file Corps has identified waters that wilt be subject to addilional nutiFcution requirements for
activities authof mcd by all NWl"s. These watery are:
2.1. Westuru NC Counties that Drain to Designated Critical Habitat
Waters of the U.S. that requires u Pro-Coiistnrction Notificatiou pursuant to Ocneral Condition
27 (PCN) tied located in the sixteen counties listed below, applicaiit9 must provide it copy ofibo
PCN to the US Fish and Wildlife Service; 160 Zillicoa Street, Asheville, North Cuolina 28805.
This PCN must lac sont coucmantly to the US fish and Wildlife Service and the Corks Ashevillo-
Regulatory Hold Office. Please sec General Condition 17 for specific notification requirements
related to Federally fAidatigum-d Specios and the fnlinwing websitc for information on the
location of designated critical habitat.
Counties with tributaries that dmin to designated critical habitat that require notification to the
Asheville US Fish and Wildlife Service: Avery, Clicrokee, Porsylb, Graham, Haywood,
0 18

0
•
Thomas J. Seaton, Esq.
.tune 14, 1991
Page 2
TFI appreciates your acknowledgment of our understandings
and the timely resolution of this most important issue.
Sincerely yours,.
G$ry �D. Myers
President
Reviewed and Approved
United States Environmental
Protection Agency
is By
0

JUL, 16. 2000 7: 220 CHAR-MECK UTY- ENG No. 1975 F. 26
Henderson, Jackson, Macon Mecklenburg, Mitchell, Stokes, Sktrry, Swain, Transylvania, Union
and Yancey.
chvite aq4 office nddresses for f e e s Act 1 f i
Tito 'Wilmington District has developed the following website far applicants which provide
guidelines on how to review linked webiites and maps in order to fulfill NWr general condition
17 requicomeats.
htt }:/ wt�w.fiaw,usace,e�rrri�y.rnillweitlands/1;SA
Applicants who do not have internist access tnay contact ftappropriate US risk and Wildlife
Service; offices or the US Army Corps of Prigincers of ice Iisted below.
US fish anti Wildlife Service
Asheville Field Otlice
160 Zillicoa Strvet
Asheville, NC 28801
Telephone: [phone]
Asheville US fish and Wildlife Sorvice Office counties: All
counties west of and including Anson, Stuuly, l)avldsan, Forsyth and Stokcs Counties
US fish and Wildlife Service
Raleigh Fichd Office
Post Office Box 33726
Rulcigh, NC 27636-3726
Telephone, [phone]
Raleigh US Fish ftud Wildlife Service 001ce counties: all comities east of awl including
Riclunond, Montgomery, Rkindulph, Guilford, and Rockingliara Counties.
2.2. Special basiguation Waters
Prior to the use of any NWP in any of the following North Carolina Identified waters and
contiVions wetlands, applicants must comply with Nationwide Permit General Condition 27
(PCN). The North Carolina water, Lind contiguous wetlands that require additional natitication
requirements are:
"Outstanding Resource Waters" (01tW) and "High Quality Waters" (HQW) (as designated by
the Not1lt Carolina Environmental Martagoutout Commission), or
"lnIand Primary Nursery Arc&' 0PNA) (as designated by the Nurth Carolina Wildlife
Resources Commission), or "Contiguous Wetlands" (as domed by the North Carolina
Environmentai Management Commission), or "Primary Nursery_ Areas" (PNA) (as designated by
the North Carolina Marino Flsheries Commission).
0 19

•
L-1
0
k I Ur rMD STATES ENVIRONMENTAL PROTECTION AGENCY
� WASHINGTON. D.C. 20460
t .mot'
OCT 3 G'5i
Mr. Chris Kyr'_ck
Director
Legislative and Regulatory Affairs
National AgzJChemical RetaiiQrs Asscciatien
1155 15th Street, N.W., 9th Floor
Washington, D.C. 20005
Dear Mr. Myrick:
tiS .A,;
arc€ CP
WAM
Thank you for your latter dated August 13, 1991 and
attachments addresser .o Dr.. Jon Baker, Agricultural Advisor to
the Administrator, U.s. Environmental Protection Agency (EPA).
In your letter, you asic for clarl f i.cation of whether a fertilizer
wholesale or retail distritutcr that performs some mixing or
blending as part of their operation is included in the definition
of a storm water discharge associated with industrial activity at
122.26(b)(14) of the vzom water permit application regulation
(51 FR 47990).
Facilities chat are -primar.ii,y,7engaged. in-,manufacturer::,mixing.,
ing and.,blendof._fart ils•zers �a:_a�aclassif end as Standard:.Irdustr.i•al
CI'sssifiCatian {LLSIC) wctiders.7.5: Major group 29 is included in
citegcry ii of"tha dafini'zon of storm water discharge associated
With industrial activity; tnerol =e, facilities classified as SIC
code 26 are required to submitNational pollutant Discharge
Elimination System (NPCES) storm avatar d{scnargo permit
applications.
EPA agrees that incident&! or small scale mixing and
blending of fertilizers at wholesale or retail facilities does
not constitute manufacturer blendinq and mixing desr..ribed under
SIC coda 2375, and such wholesale or retail facilities would nct
be required to submit ►Pus storm water discharge permit
applications. EPA also agrees that these facilities are properly
elassltled in SIC code 5191 even though they may in some rases
ship to or exchange fertilizer with other retail or wholesale
outlets before shipment to the ultimate end user. However. �h_an
the=tail'ityfs mi°xi:rg:' b Lend ng-`end°rc�di;stributiriq r.t3iese=
materials :on a =anufactLx, ,ng ca.e `=sucC`=that- the..Zzxing_ a►ad,
blendingbeccme� the=-act�rityln _�rh:ch :he-gacZfty= is -primarily
rigaged, that''�ac>Ll:. " ::►au ii` `::ieri- ire=more--appropriately
c�aiss�ifisac3�ilndsr 5TC cac� __6!5- and1t!:Arafore would bq% required to
3ubait a NPVES permit applicat«a:. .,or its star.& .rater discha-rges.

JUL. 16. 2008 7:22AM CHAR-MECK UTY-ENG W. 1975 r', 27
i
2.3. Coastal Area Munugament Act (LAMA) Arens of Environmental Cancer,►
Non -Federal applicanu for any NWP in a designated "Aron of Environmental Concern' (AEC)
In the twenty (20) counties of Eastern N0011 CavolinA covered by the North Carolina Coastal
Area Management Act (LAMA), must also obtain the rewired CAMApennit. Construction
activities for t►on-Fcdorat projects iotuy utot rormrnepice until a copy of the approved LAMA
pormit is furnished to the appropriate Wilmington District Regulatory Field Office (Wilmington
Field Office-- P.O. Box 1890, Wllrnington, NC 28402 or Washington Field Office — P.O. Brix
1000, Washington, NC 27889).
2. 4. barrier Islands
Prior to the mu of orgy NWP on a harrier inland of North Carolina, applicants must comply with
Nationwide Permit General Condition 27 (PCN).
2.5. Mountain or Piedmorut Bogs
Prior to the use of any NWP in a "Moantait) of Picdmoid Bog" of North Carolina, applicants
shall comply with Nationwide Permit General Condition 27 (PCN).
Note: The following wetland community types identified in the N.C. Naturai Huriwgu Programs
document, "Classification of Natural cUnuuuch,hities of North Carolina (Michael P. Sehafale and
Alan S. Weakley, 1990), arc subject to this regional condition.
Mountain Bogs T.._
Piedmont Bogs
Swavap Forest -Bog Complex
Upland depression Swamp
Forest
Swamp Forest -flog Complex
.5 ruco Subtypol_
Southern Appalachian Bog
Northern Sulu o
Southern Appalachian flog
(5puthcrn Subtypo)_
Southern Ap alachiart l�cn
2.6. Animal Waste Facilities
Prior to use of any NWP for constntetion of animal waste facilities in waters of the US, including
wetlands, applicants shall comply with Nationwido Permit General Condition 27 (PCN).
2.7. Trout Waters
Prior to any discharge of dredge or fill material Into strcanw or waterbodiss within the twenty-
five (25) designated trout mantles of North Carolina, the applicatit shall comply with
0 20

•
To determine which activity,a facility is primarily engaged
in vhen multiple activ_itier. occur on 2 given site, the "�lssia�xcsl �
CoQo~AssigruQer,t-;in the 'SIC"= cncie =manual ;(found jon-paqu- ls) -{phottld
bi�carafuYly:-f,ai'lowed ri.'s summary„_ rhe.,prin`cipal yrodubt:orl
group _of pro_ducts-or-sez-71ces.,dr@mevaluated- _for `each'Actsv *
aceardi7 g% to=the data measures, st'eain-the manual, A4valu�
Should :;be calcul atedforQachcti•rztiy. Th"e activity wit$ the
predominant value is the activity which defines the SIC code
class iricatior. for.the facility. i
I would lice to advise you, however, that States with
authorized NPUS permit rrcgraw may have more stringent
reg4i,rements with respect to storm Water discharges. Under these ,F
State programs, some or all of the storm water discharges
identified in yaur letter may be required to submit NPDW Storm
vater discharge permit applications. In addition, when an
operator of an industrial activity determines the applicable SIC
code for the activity, a verification of the chosen code by the
State rag-alatory agency is recommended. This mould be most
important for industrial activities with multiple SIC code
activities occ.xring at one site.
It is also important to note that under the authority of
402(p)(2)(E) of the clean water Act, any point source discharge
of storm water may be dasignatad and required to submit a permit
application if the pe mitti.rg authority determines that the storm
water discharge is contributinc tc a violation of a water quality
standard or is a significant contributor of pollutants to waters
of the United States.
I ?pope that I have clarified this issue satisfactorily. 1:
you have any further quest'-cns you may contact me at (202) 260-
9541 or Willi -am Swietli:c of day staff at [phone].
Sincarely yours,
V
Icing,Chiogram Branch
CC: Gary D. Myers, The Fertilizer Institute
.sir. Richard F ye, xcKcr.na & Cuneo
Jahn Bake{, PhD., U-S, ;.PA
L-1

•
0
JUL. 16. 2008 7:23AM CHAR -HECK UTY-ENG
140.1475
Nationwide Pdrmit (leneral Condition 27 (PCN). The applicant shall also provide a copy of the
notification to the appropriate NCWRC office to fttcilitatc the determination o£atty potential
impacts to designated Trout Waters. Notification to the Corps of Engineers will include a
statement with the name of the NCWRC biologist contacted, the date of the notification, the
location of work, a delineation of wedonds, a discussion of alternatives to working in the
mountain trout waters, why altornatives were not selactod, and a plan to provide compensatory
mitigation for all unavoidable advorse impacts to mountain trout waters.
NCWRC and NC Trout Counties
Mr. Trott Linville
Western Piedmont Region
Coordinator
Allegheny
Caldwell
Watauga
38551dlewlId Roaa
Aahe
Mitchell
Vir'tllces
Kernersv[lle NC 27284-9180
Avery
Stokes
Telr, hone: (i3ti 7G9-90 3
Burke
urry
Mr. Dave McHen
Mountain Region Coordinator
Buncombe
Henderson
Polk�w
20830 Great Sinoky Mtn.
Ex resswa
Cherokee
Jackson
Rutberford
Waynesville, NC 287R6
Cla
Macon
Swain
'f elc hone: 82$ 452 2546
Graham
Madison.
Tran lvank
l ax; $28 452-777'L -
Haywood
McDowell
Youce
3.0 Y..ist of Corps Regional Conditions for All Nationwide Permits
'111e following conditions apply to all'Nationwido Permits in rite Wilmington District:
3.1. Urnitation of Loss of Perennial Stream hied
NWPs may not be used for activities that may result in the loss or degradation of grouter than
300 total linear feet of perennial strcains. "11r N WI's may not be used for activities that trlay
result in the loss or degradation of greater than 300 total linear feet of ephemeral and intermittent
streams that exhibit important aquatic fLnction(s)* L03S of stream Includes the linear feet of
stream bed that is tilled, excavated, or flooded by the proposed activity. The District
Commander can wuivu the 300 linear foot limit for ephemeral and intermittent streams on it case -
by -case basis if lie determines that the proposed activity will molt in miWmal Individual and
cumulative ndvorse impacts to the aquatic onviroiunont. Waivers for the loss ofephenierai'aud
intermittent streams crust bo in writing. TVs waiver only applies to the 300 linear feet threshold
for NWI's. Mitigation may still be-rcquired.for impacts to ephemeral and intcrinitmnuarearns,
on a case -by -case basis, depondhig on the impacts to the aquatic environment of the proposul
prujeut. [*Noto: `1'ho Corps uses the Strratit Quality Assessment Worksheet, located with Permit
htforntation on the Regulatoty Program Web Site, to aid In the determination of aquatic function
.within tlto Intermittent stream channel.]
0 21`

El
0
V.Ifwnl,rf .1s;i14 lirinH31 i{i-I.Oe rk A,.iniltl0d)
fl','� f,y(h +rr,.1�r, tv,W.,'rfli h6nK •1U.rshirti�u,n, h,L, • 1{u}lli
Ily FAX
DATE: October 3, 1991
TO: State Fertilizer led Chemical Associations
FROM. Chris Myrick, NAIL%
RE: EPA Clarification of Storm water Permit Requirements for
AgriChemical Dealers
At long last, the Environmental Protection Agency has responded to NARA's request for
clarification of storm water permit applicability to retail dealers who mix and blend
fertilizers and market pesticides for use on the farm.
With this letter, state associations liuve something in hand to work with State regulatory
officials when they consider permitting; t:tnit agrichemical dealerships.
Key points or letter.
-- "EPA agrees that incidental or small scale mixing and blending of fertilizers at
wholesale or retail facilities does not constitute manufacturer blending and mixing
facilities under SIC code 2375. and such wholesale or retail facilities would not be
required to submit NPI)ES storm ivater discharge permit applications",
-- "EPA also agrees that these facilities are properly classified in SIC code 5191 even
though they may in some eases ship to or exchange rertilizers with other retail or
wholesale outlets before shipment to the ultimate end user".
"i would Iii►e to advise you, however, that States with authorized NPDES permit
programs may have more stringent requirements with respect to storm water discharges".
NARA recommends flint State associations use this letter when dealing with state
regulatory agencies and that they provide information as to where dealers can obtain a
SIC code of $191 for racilities that have been improperly classiRed.
Questions, call NARA at 202.457.0825.

'T A WA
• t NC®ENR
North Carolina Department of Environment and Natural Resources _
Division of Land Resources
James D. Simons, PG, PE Land Quality Secfion Michael F. Easley, Governor
Director and State Geologist 1NJIiam G. Ross Jr., Secretary
a
C,
September 5, 2008
LETTER OF APPROVAL,
Mr. Dennis D. O waitney, Senior Project Manager
/d(?.-80 Brookshire Boulevard ,
' Tharlatte, North Carolina 28216
RE: Project NTarize. Reedy Creek Pump Station (CMUD)
Acres Approved: 2.92
Project ID: CABAR-2009-004
County: Cabanas, Lower Rocky River Road
Rive ,Basiri: Yadkin
Subriiitted By: Dennis D. Gwaltney, Senior Project Manager
Date Received by LQS: August 12, 2008
Plan Type: New ,
Dear Mr. Gwaltney:
This office has reviev�,ed the subject erosion and sedimentation control plan. We find the
plan to.be acceptable and hereby issue this Letter of Approval. The Certificate - of Approval must
be posted at the job site. This plan approval shall' expire three (3).years'fo11owing the date of
approval, if no land -disturbing activity has been undertaken, as is required by Title ISA NTCAC
4B .0129.,
Title 15A NICAC 4B .0118(a) requires that a copy of the approved erosion control plan be
on file at the job site. Also, tlris letter gives the notice required by G.S. 113A-6.1.1(a) of our right
of periodic inspection to insure compliance with the approved plan.
North Carolina's Sedimentation Pollution Contm rol Act is perforance-oriented, requiring
protection of existi-ia natural. reSDUrces and adjoining properties. If, following the
commencement of this project, the erosion and sedimentation control plan is inadequate to meet
the requirements' df the Sedimentation Pollution Control Act of 1973 (North Carolina General
Statute 11 �A-51 through b6), this office may require revisions to the plan and implementation of
the revisions to insure compliance v,:ith the Act.
µ;. Meoresvrlle Regional Office
610 East Center Avenue, Suite�301, Mooresville, I\Qrth Carolina 28115 - Prone: 704-663-16991 FAX: [phone]
11:

Letter of Approval
Dennis D. Gwaltney, .Senior Project Manager
September 5, 2008
Page 2 of 2
Acceptance and approval of this plan is conditioned upon your compliance with Federal
and State water quality laws, regulations, and. rules. In addition, local city or county ordinances
or rules may also apply to this land -disturbing activity. This approval does not supersede any
other permit or approval.
Please be aware that your project will be covered by the enclosed NPDES General
Storrnwate.r Permit NCGO1000 (Construction Activities). You should first become fanuliar with
all of the requirements for compliance with the enclosed general permit.
Please note that this approval is based in part on the accuracy of the information provided
in the Financial Responsibility Form, which you provided. You are requested to file an amended
form if there is any change in the information included on the form. In addition, it would be
helpful if you notify this office of the proposed starting date for this project. Please notify us if
you plan to have a preconstructi o n conference.
•
Your cooperation is appreciated.
Mae
Enclosures: Certificate,of Approval
NPDES Permit
cc: Woolpert
Inspection Department
Surface Water Protection
0
Sincerely,
Tamera Epl n, P.E.
Assistant Regional Engineer
Land Quality Section

15
:22.
perform such activities as general management; accounting; computing,
pment, and Nesting
tabulating, or data processing; purchasing; engineering and systems
and parts, covered
planning; advertising; public relations or lobbying; and legal, financial,
Perating establish-
or related matgerial functions,
1 part of an enter.
(2) Establishments primarily engaged in research, development, and testing
ass establishments
for other establishments of the same enterprise, except establishments
In by funds of the
of aircraft, guided missile, and spacecraft manufacturers as defined in
fy engaged in re-
Exceptions and Borderlines.
vered by industry
(3) Warehouses and storage facilities primarily serving other establish-
hments. FAtablish-
ments of the same enterprise.
ad testing of prod-
(4) Maintenance and repair shops primarily serving other establishments of
re classified as op-
the same enterprise for the maintenance and repair of its own machin-
1.
ery and equipment.
ments in Agricul.
(5) Automotive ro air shop
s ps or storage garages operated by an enterprise
primarily for repair or storage of its own vehicles.
rucking, sievedor-
(6) Establishments primarily engaged in news collection, editorial worm, or
)r other establish-
advertising sales related to publishing activities for other establish-
ig establishments
ments of the same enterprise.
(7) Establishments primarily providing equipment to construction establish-
aent construction
�)
menu of the same enterprise,
ndustries in Divi-
anstrwdon, Divi.
R
($)tabliahments primarily
p y engaged in providing field engineering sup-
services for establishments the
ind maintenance
port other of same enterprise at loca-
ndustrms in Ihvi-
[g
tions other than the parent facility, e.g., at the customer's site.
.vision E. liowev-
(9) Showrooms in Which sales do not take place.
ossified in Indus-
(10) Recreation facilities, such as gymnasiums, golf courses, and swimming
pools, maintained by an enterprise for the benefit of its employees.
-imarily engaged
5;
(11) Milk receiving stations for dairies.
in�yam
Basis of Code Assignment in the SIC
is in Public Ad-
e;
Operating Establishments
ive maintenance
wry establish-
Each operating establishment is assigned an industry code on the basis of its
primary activity, which is determined by its principal product or group of products
pry activities for
produced or distributed, or services rendered. Ideally, the principal product or serv-
3 in the United
ice should be determined by its relative share of value added at the establishment.
basis of the es-
In practice, however, it is rarely possible to obtain this measure for individual prod-
"
ucta or services; typically, it is necessary to adopt some other criterion which may
be expected to give approximately the same results in determining the primary ac-
tivity of an establishment. It is recommended, therefore, that, when available, the
rily engaged in
following data measures be used -for each of the major economic sectors in nssigning
As of the same
industry codes:
2
Division Iota me"Urr
'ring manage-
Agriculture, forestry, and fishing (except Vaiue of production.
tabli$hments of
j
agricultural services).
ive offices may
li��
Mining............................................................. Value of production.

2. If this application is being submitted as the result of a renewal or modification to an existing permit, list the
existing permit numbern/a _ _ T _ and its issue date (if known)rnZa
3. Specify the type of project (check one):
❑Low Density ❑High Density ❑Redevelop ®General Permit ❑Universal SMP ❑Other
4. Additional Project Requirements (check applicable blanks; information on required state permits can be
obtained by contacting the Customer Service Center at 1-877-623-6748):
❑CAMA Major ®Sedimentation/Erosion Control ❑404/401 Permit ❑NPDES Industrial Stormwater
III. PROJECT INFORMATION
1. In the space provided below, summarize how stormwater will be treated. Also attach a detailed narrative
(one to two pages) describing stormwater management for the project.
Stgrmwater for the proposed. im-12rovementswill involve runoff being captured 12y proposed storm drainage pives
and stormwater swales that will route the runoff to a pra.1a__�sed wet detention basin at the eastern portion of the
project. The wet detention basin will then cilpturg and detain the firstflu�h of runoff and release the first flush
volume over a period of 4 days.
2. Stormwater runoff from this project drains to the Cape River basin.
3. Total Property Area: 30.38 acres 4. Total Coastal Wetlands Area:, N/A acres
5. Total Property Area (3) — Total Coastal Wetlands Area (4) = .Total Project Area**:30.38 acres
6. (Total Impervious Area / Total Project Area) X 100 = Project Built Upon Area (BUA):55 %
7. How many drainage areas does the project have?l
8. Complete the following information for each drainage area. If there are more than two drainage areas in the
project, attach an additional sheet with the information for each area provided in the same format as below.
For high density projects, complete the table with one drainage area for each engineered stormwater device.
Basin Information
Drainage Area 1
Drainage' Area 2
Receiving Stream Name
Rocky River
Stream Class & Index No.
C 17--43-(8)
Total Drainage Area (so
169013
On -site Drainage Area (so
169013
Off -site Drainage Area (sf)
0.
Existing Impervious* Area (sf)
0
Proposed Impervious *Area (so
.93218
% Impervious* Area (total)
55
Impervious* SurfacepArea
t „Drainage Area 1- _ . ;•
Drainage Area 2
On site 8WIdings (so
15158
On -site Streets (so
5050
On -site Parking (sf)
72340
On -site Sidewalks (so
670
Other on -site (so
0
Off -site (sf)
0
Total
93218
Form SWU-101 Version 09.25.08 Page 2 of 4

uo• .....�t.e�J- Scales_, nFfl;r•� -
16 STA"ARA INDUSTMAL CLASSMCA1 rON
Mdaiun
Data mcmwm
construction..............r............-.....-.......---.--....
Value of production.
Manufacturing ..............................................
Value of production.
Transportation, communications, elec_
Value of receipts or revenues.
tric, gas, and sanitary services.
Wholesale trader..r...........rr•r..r.r.r•..r....... f Value of snlee. T�
Alb
Retail"trade........•.............................• °�
Valueofle
Finance, insurance, and real estate...........
Value of receipts.
Services (including agricultural services).
Value of receipts or revenues.
Public administration .......................•...........
Employment or payroll.
Occasionally, in establishments with multiple activities, the appropriate Maas-
ure cannot be determined or estimated for each product or service. In some in -
stands, an industry classification based upon the recommended output measure
will not represent adequately the relative economic importance of each of the.
varied activities carried on at such establishments. In such cases, employment or
payroll information should be used to determine the primary activity of the eatab- - -
lishments.
Even though a data collecting organization may have no immediate need to
analyze or publish establishment data at the four -digit industry level of classifica-
tion, it may be useful to assign four -digit codes to each estabhshmeut report where
the information is available and the -incremental cost of such classification is not
excessive. The four -digit code assignment should be made directly on the basis of
the primary products, services, or activities reported by each establishment at the
four -digit industry level of detail.l
Four -digit code assignment is also helpful in determining comparability with
codes previously assigned from earlier editions of the manual. In this revision, for
example, Industry Group 604, Professional and Commercial Equipment and Sup-
plies, was changed by shifting some four -digit industries into this industry group
and others out of it. Therefore, if four -digit industry oodes were assigned previously,
reclassification would not be necessary to provide comparable historical data for
that industry group on the revised basis. Before an agency limits classification to
less than the fonr4igit industry detail, consideration should also be given to possi-
ble.expansion'of the requirements for industry data, as well as for editing and spe-
cial analyses of certain data series for which more detail would be helpful.
Auxiliary Edablbhmenfas
Auxiliary establishments are assigned four -diet industry codes on the basis of
the primary activity of the Operating establishments they serve. In addition, they
are subclassified further through the assignment of a one -digit auxiliary code, out-
r It Ea posathle for the clasMcstion of an eatabliahmcnt, based on ite priumJr activity ai t.tw twvdigft mgpr gip
or thrw4Wt industry gmup laved, to di0br from that and9ned on the basis of its primary activity at the bu digit
indaatry level. Tide can occur whore the prlmaty activity of an ostabliahmant in classified in the foLn-ftit indoatry of
me industry group that is sat an Tarp as tba combined acdvhy of two or morn foBrdwt industrias within anuthnr
industry group. (Tote, boaover. that if vAAndoatrlaa arc uaad, the coda osdgamout should be made on the haste of the
prbUU7 °y within the aaaigned four -digit industry'.)

2. If this application is being submitted as the result of a renewal or modification to an existing permit, list the
existing permit numbern/a_ and its issue date (if known)n a
3. Specify the type of project (check one):
❑Low Density High Density ❑Redevelop SGeneral Permit ❑Universal SMP ❑Other
Y
4. Additional Project Requir men s (check applicable blanks; information on required state permits can be
obtained by contacting the Customer Service Center at 1-877-623-6748):
❑LAMA Major ®Sedimentation/Erosion Control ❑404/401 Permit ❑NPDES Industrial Stormwater
III. PROJECT INFORMATION
1. In the space provided below, summarize how stormwater will be treated. Also attach a detailed narrative
(one to two pages) describing stormwater management for the project.
Stormwater for the pLoposed improvements will involve runoff being captured by-pMosed storm drainage pipes
and stormwater swales that will route the runoff to a proposed wet detention ba5in at the eastern portion of the
project. The wet detention basin, will then capture, and detain the first flush of runoff and release the first flush
volume over a pgrigd of 4 days.
2. Stormwater runoff from this project drains to the Cape Fear . River basin.
3. Total Property Area: 30.38 acres 4. Total Coastal Wetlands Area: N/A acres
5. Total Property Area (3) — Total Coastal Wetlands Area (4) = Total Project Area**:30.38 acres
6. (Total Impervious Area / Total Project Area) X 100 = Project Built Upon Area (BUA)S5 %
7. How many drainage areas does the project have?1
8. Complete the following information for each drainage area. if there are more than two drainage areas in the
project, attach an additional sheet with the information for each area provided in the same format as below.
For hijzh density proiects, complete the table with one drainage area for each engineered stormwater device.
Basin Information
Drainage Area 1
Drainage Area 2
Receiving Stream Name
Rocky River
Stream Class & Index No.
C 17--43-(8)
Total Drainage Area (so
169013
On -site Drainage Area (so
169013
Off -site Drainage Area (sf)
0
Existing Impervious* Area (so
0
Proposed Impervious*Area (so
93218
Impervious* Area (total)
55
Impervious* Surface Area
Drainage -Area 1
Drainage Area 2
On -site Buildings (sf)
15158
On -site Streets (so
5050
On -site Parking (so
72340
On -site Sidewalks (so
670
Other on -site (so
0
Off -site (so
0
Total (so:
93218
Form SWU-101 Version 09.25.08 Page 2 of 4

ata measure
-oduction.
oduction.
ceipts or revenues.
lee.
lea.
)eipts.
vipts or revenues
t or payroll.
e appropriate meas-
iervice, In some in -
led output measure
nee of each of the
des, employment or
edvity of the seta} -
immediate need to
7 level of claesifica-
tment report where
;iassification is not
tly on the basis of
tablishment at the
=parability with
o this revision, for
uipment and Sup`
us industry group
reigned previously,
aistorical data for
is classification to
be given to possi-
r editing and spe-
helpful.
�a on the basis of
In addition, they
udbary code, out -
he tw*446t MO&T 6—P
w3mty at the four awt
be foardfgit mdastry of
ulusuiee within another
nails M the bawls of the
17
lined below, based on the primary activity performed by the auxiliary
establish-ment.
Agencies should provide for the separate presentation of statiaties on an indus-
try basis for operating and aaziliary establishments when data for both types of es-
tablishments are presented.
Industrial Subclassification of Auxiliary )Establishments
Au>3linry
Code Number Mes and Descriptions of Atpoltarles
Centre) Adminletrative Ofliem
Auxiliary establishments primarily engaged in performing management
and other general administrative Ilrnctions centrally for'otber estttbUhments
of the same enterprise.
A000undug offices
Advertising offices
Buying offiow
Central off oes
Computer operatiuns facilities
Corporate d ices
Data promesiag facilities
District administrative offices
F rrecutive offices
F m=cial offices
Head offices
Legal offices
l obbyinj offices
Marketing research of5cea
Public relations offices,
Purchasing offices
Rcoordkeeping offices
Regional administrative offices
Rewarcft. Development, and Testing Labomtorles
Auxiliary establishments primarily engaged in performing laboratory or
other physical or biological research, develnpment, and testing for other eutab-
lishments of the same enterprise.
Biological regeareh faciiitiee Industrial laboratories
Chemical laboratories I,aboratorlse, testing of products
Em&eering laboratories Resoarth laboratories
Food rwwrch/tosting facilities Testing facilities
Warehouses
Auxiliary establishments primarily engaged in storing raw materials, fin-
ished goods, and other products to be used or sold by other establishments of
the same enterprise.
Storage yards Warehouaw
Awdliartee, Not Elsewhere Classified
Auxiliary establishments primarily engaged:in providing support services,
not eiirewhere clasafed, for other establishments, of the same enterprise.
Advertising sales offices Repair shops
Computer maintenance facilities $eourity offlcm
Gwmgaz maintenance, tapair, Showrooms, without sales
.:motor-poola Stamp redemption waters
Milk receiving stations Trading stamp stores
jiecreation centers lrutokiog terminals

CW
STEWART
Water Quality Drawdown Calculation - Pond A
(1st inch of rainfall)
Storage Volume Required (Simple Method)
Basin Characteristics
Total Drainage Area =
3.88 ac
Pond Invert =
560.50 ft
Total Impervious Area =
2.14 ac
Normal Pool Elevation =
569.00 ft
Percent Impervious =
55%
Next available Outlet =
570.30 ft
Storage Depth =
1.30 ft
Rv = 0.05 + 0.009(I)
Average Head =
0.65 ft
I = % impervious =
55%
Ks =
5747
Rv =
0.55 in
b=
1.17
Average Head/3=
0.22 ft
Minimum depth
Runoff Vol. = 7696 cf
_
required for storage =
1.28 ft
Temporary Storage Volume = 7817 cf
Temporary Storage Surface Area = 7050 sf
Find orfice size for 2-day drawdown time
Flow Rate = Volume (cf) / Time (sec)
— 0.0452 cfs
Q=Cp*A*(2*9*h)A(1/2) (Orrice Equation - solve for A (area))
A= 0.01165 ft'
1.67803 in
Orrce Size 2 day) = 1.46 in. dia
Find orfice size for 5-day drawdown time
Flow Rate = Volume (cf) / Time (sec)
— 0.0181 cfs
Q=Cp*A*(2*g*h)^(1/2) (Orrce Equation - solve for A (area))
A= 0.00807 ft'
1.16258 In
Orrce Size 5 day) 1.22 in dia
Select orfice size between 2 and 5 day size I
Size selected = 1.5 " dia
Actual Drawdown Time
Volume =
7817 cf
Pipe Size =
1.5 "dia
Area =
0.012272 ftz
Flow Rate
0.027504 cfs Using a N/3
Drawdown Time =
3.29 days
421 Fayetteville St., Suite 400, Raleigh, NC 27601 Tel 919.380,8750 Fax [phone] www.stewart-eng.com

18 1 STANDARD INAUSTRIAi, CLASSIFICATION
Treatment of Ownership Characteristics
All establisbments primarily engaged in the same kind of economic activity are
classified in. the same .four -digit industry, regardless of their types of ownership;
hence, their owners may -include such diverse legal organizations as corporations,
partnerships, sole proprietorships, government agencies, etc.
Government establishments, therefore, are classified by their primary- economic
activity, rather than by type of owner.
Where applicable, agencies should publish at least summary data separately for
the private and government establishments constituting an industry or industry
group -
if available, these two major ownership sectors may be further subdivided by
the following classification system:
Sector 1. Private
Corporation
Profit
Nonprofit (except cooperatives)
Cooperative or mutual association (incorporated or not)
Profit
Nonprofit
Partnership
,Sole proprietorship
Other —estate, receivership, joint venture, personal trust,
fiduciary trust, etc.
Sector 11. Government
Federal
Regular government
Quasi -government`
State
Regular government
Quasi -government'
Local .
Regular government
County.
City, town, village, or township
School districts
Special districts
Quasi -government'
International government or foreign government
Other —regional commissions, inter -State organizations, etc.
'Quadlo.erumeat mclu" thou establ}dumts wbicb are oontmllod by the gw&nn=t and private sectors
through joint ownership of stoop or joint membership on boards of direatore or other oontrolling bodice.

Central Files: APS SVVP
08/21 /09
Permit Number SW5090701
Permit Tracking Slip
Program Category
Status Project Type
State SW
Active New Project
Permit Type
Version Permit Classification
State Stormwater
1.00 Individual
Primary Reviewer
robe rt. patte rson
Coastal SW Rule
Post Construction - Phase II
Permitted Flow
Facility Name
Chatham Hospital
Location Address
Permit Contact Affiliation
MajortMinor Region
Minor Raleigh
County
Chatham
Facility Contact Affiliation
Owner
Owner Name Owner Type
Town of 5iler City Government - Municipal
Owner Affiliation
Joel J. Brower
PO Box 769
Dates/Events Siler City NC 27344
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
08/21/09 07/01/09 08/21/09 08/21/09 08/21/19
Regulated Activities ectuested/Received Events
State Sturmwater - HD - Detention Pond Deed restriction requested
Deed restriction received
Additional information requested 07/13/09
Additional information received' 08/05/09
Additional information requested 08/06/09
Additional information received 08/20/09
Outfall NULL
Waterbody Name Stream Index Number Current Class Subbasin

Description for 5191: Farm Supplies Page I of 1
OCCUPATIONAL SAF(TY & HLALTH AvmiNts`rjtAT1oN
www.OSHA.gov A-L Xwidox_ A B C 0 E F G F4 S 3 k L M N 0 p Q R 5 T U V W X V Z Search OSHA
�,Tg; �cs�.;rgrytRr+!? frpr �;9 sj'1,
Description for 5191: Farm Supplies
Division F. Wholes Ia_Tra_ctg
Major .Group. 51:.WholesaIc Trade -non -durable Goods
Industry Group 519, Miscellaneous Non -durable Goods
5191 Farm Supplies
Establishments primarily engaged in the wholesale distribution of animal feeds, fertilizers,
agricultural chemicals, pesticides, seeds, and other farm supplies, except grains.
Establishments primarily engaged in the wholesale distribution of pet food are classified in
Industry 5149, and those distributing pet supplies are classified in Industry 5199.
■ Agricultural chemicals -wholesale
■ Agricultural limestone -wholesale
• Alfalfa -wholesale
e Animal feeds, except pet -wholesale
a Beekeeping supplies -wholesale
• Farm supplies -wholesale
a Feed additives, animal -wholesale
o Feed, except unmixed grain -wholesale
e Fertilizer and fertilizer materials -wholesale
r Flower and field bulbs -wholesale
e Harness equlpment-wholesale
o Harness made to individual order -wholesale
• Hay -wholesale
o Insecticides -wholesale
■ Lime, agricultural -wholesale
o Mineral supplements, animal -wholesale
■ Pesticides -wholesale
• Phosphate rock, ground -wholesale
■ Seeds; field, garden, and flower -wholesale
o Straw -wholesale
[ SiC Search I Division Stnicture I hlajcar Group_Structure I OSHA Standards Cited )
(-) Back to Tod www_osha.gov wn�wvdol gav
Contact Us I Freedom of information Act I Customer Survey
Privacy and Securlty_Statemarnt I Dlsclalmers
occupational Safety & Health Administration
200 Constitution Avenue, NW
Washington, DC 20210
hq://www.osha.gov/pis/imis/sic_manual.display?id=9&tab=description 8/19/2009

INSTRUCTIONS:
1. TRAVEL REQUEST COMPLETED BY
AGENCY
2. APPROVED BY DEPT. HEAD
3. TAKEN.TO MOTOR POOL FOR
ASSIGNMENT
G- UPON RETURN OF CAR. FOAM
COMPLETED
DRIVER'S NAME 5 DRIVER'S LICENSE NO.
PURPOSE: OF TRIP
STATE OF NORTH CAROLINA
DEPARTMENT OF ADMINISTRATION
MOTOR FLEET MANAGEMENT DIVISION
RALEIGH-
REQUEST FOR MOTOR POOL VEHICLE
OEPT.IOFFICE NO.:
TELEPHONE NO. TRAVEL TO BEGIN (DATE -TIME)
ITINERARY
TRIP NO.
NV NL.: r16%, NUMI)tli:
TRAVEL TO ENq It)ATE-TIME)
I CERTIFY THAT ALL PERMANENTLY ASSIGNED CARS IN MY AGENCY WILL BE IN USE DURING THE PERIOD OF THIS ASSIGNMENT AND I
HEREBY APPROVE THIS TRIP.
APPROVALOF DEPT, HEAD OR AGENT (SIGNATURE)
SIGNATURE FOR RECEIPT OF CAR
X
DATE AND TIME IN
CREDITCARDS RETURNED
CHECKED IN BY
ODOMETER READING IN
DATE AND TIME OUT
CREDIT CARDS ISSUED
ASSIGNED BY
ODOMETER READING OUT
DRIVER COMMENTS: (PLEASE REPORT SUGGESTIONS AND
M EC HAN fCAL 01 FF ICU EY LTIES IN THIS SPAC
•
,
TOTAL MILES DRIVEN
$ 1
RATE PER MILE
I
I
$ I
1
'
TOTAL AMOUNT
f
SIGNATURE OF DRIVER
X
FORM FM 2
DRIVER MUST PRESENT VALID STATE -ISSUED DRIVER'S LICENSE TO DISPATCHER

Description for 2875: Fertilizers, Mixing Only Page 1 of 1
OCCUPATIONAL SAFETY & HLALTH ADMINISTRATION
www,OSHA.gov r-f A e C LP L r-- h r} =, M R n.f� R�i; d V W Y y Z Search OSHA _ 54
5rC Descriottoo fn: 2197i;
Description for 2875, Fertilizers, Mixing Only
Division D: Manufacturing
htaipr Group- 28: Chemicals And Allied Products
Industry Group 287. Agricultural Chemicals
2875 Fertilizers, Mixing Only
Establishments primarily engaged in mixing fertilizers from purchased fertilizer materials.
a Compost
■ Fertilizers, mixed: made in plants not manufacturing fertilizer
■ Potting soil, mixed
[ 5iC_ search DiviSio�$tni_ ure I Maur M Stru ure I $.tD d r CQ_ J
pi * to Top- www.osha.aoy wwA-dgLgnv_
Contact Us I Freedom of Information Act I Customer Survey
Privacy and Security Statement I Disdalmers
Occupational Safety & Health Administration
200 Constitution Avenue, NW
Washington, DC 20210
http://www.osha.gov/pislimis/sic_manual.display?id=620&tab=description 8/19/2009

Mr. David W. King, Jr.
Shotwell Transfer Station—NCG 130057
July 31, 2009
If you have any questions concerning this permit, please contact Jennifer Jones at
telephone number [phone]
Sincerely,
for Coleen H. Sullins
cc: Raleigh Regional Office, Danny Smith
Central Files
Stormwater Permitting Unit Files

Pickle, Ken
From: Pickle, Ken
*ent: Monday, August 24, 2009 1:05 PM
0: Edgerton, Thom
Subject: FW: No Exposure Certification - CPS Princeton, NC
Attachments: Cert of No Exp August 2009.pdf
Importance: High
Thom,
I'm out of the office this Wednesday and Friday. Could we talk about Crop Production sometime when you and I are
both in at the same time?
From: Nancy Vincek fmailto:[e-mail]]
Sent: Friday, August 21, 2009 4:10 PM
To: Pickle, Ken; bodge, Al; Edgerton, Thom
Cc: Kirk Williams; Bill Coleman; Brandon Brewer; Shannon Peedin; Moore, James
Subject: No Exposure Certification - CPS Princeton, NC
Importance: High
Mr. Pickle
Per your letter or July 21, 2009, attached in pdf format is our signed NPDES No Exposure Certification for Exclusion. This
is being mailed to your Raleigh office today via certified mail.
We appreciate the opportunity to resubmit this proposal, Please contact myself or Kirk Williams at 970-347-1542 or
Shannon Peedin at 919-735-8800 with any questions or concerns.
'hank you,
Nanny Vincek
Manager, Operations Compliance
Crop Produclion Services, Inc.
1160 Brake Road
Rocky Mount, NC 27801
252-977-0308 (office)
252-973-0761 (fax)
618-407-5616 (rnobile)
[e-mail]
J

Safety Factor = (Ta/Te) = (3.25 /1.828) = 1.78
I$
•
•
•

08/21/2009 16:26 2529730761 EHS
PAGE 01/22
Crop Production .Services
1:60 Broke Road, RockyMuunt, NC 27801 crop
[phone] Phone 1
Proauctio � �
(252) 973-0i61 Fax #+ 4li
eivices
Fax
I o: Ae" ! % r Fram .0 /n G —
Fcvc: — A D 7 - fp Y-9 �,G Date: f _ � / -.
Phone: Pages:
Re: CC:
❑ Urgent 0 For Review © Please Comment ❑ Please Reply © Please Recycle
-Comments;
/�J 4
1,0 e)u r e, L�er� i cK � f� �jc 0-/44S; CY?
/% - tl/0 70 e-II'1Gt� !?off e
i

08/21/2009 16:26 2529730761 EHS P4GE 02/22
Crop
Production
Services
1160 Brake Road, Rocky Mount, NC 27801
252-977-0308 Phone
252-973-0761 Fax
August 21, 2009 Via E-Mail and Fax
Mr. Ken Pickle
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re. No Exposure Certification for Crop production Services, Princeton, NC
Dear Mr. Pickle:
Enclosed is the signed NPDES NO EXPOSURE CERTIFICATION for Exclusion for the above -
named facility located at 141 Luby Smith Road, Princeton, NC 27569. Our proposed plan for
achieving No Exposure is detailed below. The attached site map enumerates the Areas of
Concern,
Area 1 Shop. Used oil is in a double -walled containment unit inside the shop. Safety Keen
disposes of the used oil and leaves shipping manifests, which are available in the front office.
Area 2 - Empty Bulk Chemical Shuttle Tank Storage Area. This is a concrete slab next to the
building. Only triple -rinsed, clean shuttles are stored in this area.
Area 3 - Bulk Chemical Storage Tanks. Tanks are in secondary containment. All storm water
from the containment area and the contained load pad is collected and agronomically land
applied through an application rig. A housekeeping decal is posted near the sump to remind
employees that the water must be collected and disposal wires manager approval.
Area 4 - Liquid Nitrogen Storage Tanks. Tanks are in secondary containment. Stdrmwater Is
tested with nitrate strips and if there is any coloration on the strip, the water is collected and land
applied at agronomic rates or used as make up water. A four -inch lip around the nitrogen load
pad ensures storm waters are contained and eliminates water flaw across the pad toward the
east end of the facility. A Housekeeping decal reminds employees of the proper management
for stormwaters from the containment and the load pad,
Area 5 - Railcar Unloading Area. We added metal plates on 3 sides of the load -in to facilitate
sweeping up any spilled product The area is swept after load -in and product placed Inside the
storage bullding.
Area 6 - Blended Fertilizer Discharge. We extended the concrete pad in this area and have
posted Housekeeping Signs to remind employees that the area must be swept daily and the
product placed back inside the building or put on the truck before it leaves the facility.

08/21!2009 16:26 2529730761 EH9 MGM 03/22
Mr. Ken Pickle
Page 2
August 21, 2009
Area 7 — Main Fertilizer Storage Building, The building has been repaired so there is no residual
discharge through the wall to the outside of the building.
Area 8 — Fuel Tank Storage. The tanks are not contained, but fueling takes place over a
concrete pad. Any spillage is cleaned up with oil absorbent and property disposed of in a waste
container_
Area 9 — Outside Bulk, Storage Bins. We installed doors on two of these bins and now use them
for bagged storage only. The third bin is used only for "filler" which is a non -nutrient material. In
addition, a four -inch concrete lip has been added to all three bins to eliminate wash back of any
rainwater that eaters the bin_ The concrete pad in front of the bins is the drive path for the loader
when transporting filler to the blender. This pad will be swept daily, when in use, and all filler
placed back inside the bin.
Area 10 — least Field and Southeast corner of Facility. We are planning excavation of the
southeast comer back to natural soil depth so that the area can be planted to create a vegetative
buffer. The existing field will be further developed by grading and planting of grasses and trees.
Please see the Conceptual Plan and Narrative attached outlining our proposed improvements for
windbreaks, vegetative buffers, and infiltration trenches and pits.
Area 11 -- Lime Pile. We are proposing a containment structure for the active lime storage area.
This structure will consist of 4 to 6' Cast wall or equivalent on three sides measuring 36' x 75'.
The open and will face east and will include a ramp to prevent stormwater from flowing out from
the storage area. On the west and south sides, we will add a 6 to 8' high chain link fence with
appropriate sized mesh screening to buffer wind impact. The north side will not be screened to
allow the clam shell to unload the lime from rail cars directly Into the structure, eliminating the
need to move the materiel twica, as would be required with a covered structure. The adjacent
building provides a wind buffer on the north side. The lime pile will be shaped (tabletop like) and
will not be stored over the height of the windbreak. The loader in the area is dedicated for the
season, and only leaves the area should our other loader break down or if a storm is forecast,
Trucks back beside the pile and pull straight out once loaded. Please see additional information
on this structure In the Conceptual Plan and Narrative.
Additional Areas of Exposure noted in your lefter of July 21, 2009 - Outside storage of pallets,
tires, metal hoppers, and other site business -related implements.
We will remove all unnecessary equipment from the site. Pallets that are stored outside are
clean and are stored for reuse. Any that are retumable, are returned as soon as space on
transport trucks allows. All liquid application equipment is field rinsed prior to returning to the site
and dry product field equipment (spreader trucks, Killebrew trailers) contributions are considered
de minimis.
In addition to these measures, Kirtk Williams presented documentation conceming the SIC Code
designation and its impact on Storm Water Regulations. Princeton is classified as SIC 5191
(now NAILS 424910) which was exempt from storm water regulations_ Based on percentage of
sales, blended fertilizers account for 22% of the sales volume, relative to 32% chemical sates
and 27% straight fertilizer sales. Therefore, this process is not considered the "principal product"
for assigning of the SiC Code. Kirk's Bullet Point Discussion from his e-mail of August 19 is
attached, highlighting the SIC Code Determination area and summary.

03/21/2009 16:28 2529730761 EHS PAGE 04/22
Mr. Ken Pickle
Page 3
August 21, 2009
Employees are trained annually on Stormwater Management, Waste Minimization, and
Housekeeping. Site personnel perform a Site Inspection monthly which includes all areas.
Stormwater that Is collected from the containment areas is documented on the 'Stormwater
Discharge Inspection Report." A copy of the monthly inspection form and the Stormwater
Discharge Inspection Report are enclosed.
We trust this answers any questions that may arise. Please feel free to contact me at the above
number, Shannon Peedin, Manager at Princeton at 919-735-8800, or Klrk Williams at 970-347-
1542.
Sincerely,
Crop Production Services, Inc,
Phillip Shannon Peedin Nsncy Vi�
Branch Manager Manager, Operations Compliance
Enciosures:
• NPDES No Exposure Certification for Exclusion
« Satellite Map
• Site Drawing enumerating Areas of Concern
• Conceptual Plan Narrative and Drawing from Bay Environmental
• SIC Code Discussion from Kirk Williams
• Agnum Monthly Inspection Report Sample
• Agrium Storm Water Discharge Inspection Report Sample
C: Kirk Williams, Environmental Manager, Greeley
Bill Coleman, General Manager
Brandon Brewer, General Manager

08/21/2009 16:26
2529730761
EHS
PAGE 05/22
��
NCDENR
'�.lY7M
Division of Water Quality / Surface Water Protection
National Pollutant Discharge Elimination System
NO EXPOSURE CERTTICATION for Exclusion
NCGNEOOOO
NO EXPOSURE QERTIFICATION
rOR A(3bNCY UM ONLY
Dag Fkuci+en
Ye2f
MpMdh Div
cenilnate orcoyeraz
Please check here if this is a renewal: ❑ RENEWAL
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit
based on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notice that your, facility does not require permit
authorization for its sformwater discharges associated with industrial activity In the State of North
Carolina because It qualifies for a no exposure exclusion. A condition of no exposure at an industrial
facility means all industrial materials and activities are protected by a start resistant shelter (with some
exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste
products. Material handling activities include the storage, loading and unloading, transportation, or
conveyance of any raw material, intermediate product, final product orwaste product. A storm resistant
shelter is not required for the following industrial materials and activities: drums, barrels, ranks, ana
similar containers that are tightly sealed, provided those containers are not deteriorated and do not leek.
"Sealed" means banded or otherwise secured and with locked or non -operational taps or valves;
adequately maintained vehicles used in material handling; and final products, other than products that
would be mobilized In stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion.
In addition, the exclusion from NPOES permitting is available on a facility -wide basis only —not for
individual outfalls. if any industrial activities or materials are, or will be, exposed to precipitation, the
facility Is not eligible far the no exposure exclusion. By signing and submitting this No parposure
Certification form, you certify that a condition of no exposure exists at this faclllty or site and are
obligated to comply with the terms and conditions of 40 CFR 122-Mq).
You must re -apply for the No Exposure Exclusion once every five (5) years.
For questions, please contact the DWQ Regional Office for your area. (See page 5)
(Please print or type)
1) Meiling address of ownerloperator (address to which all certification cQrrem)ondence will be mailed):
Name
Contact
Street Address
City
Telephone No.
Greeley State M ZIP Code 80634
970-347-1542 Fax: --U"- 47-1535
2) Location of facility producing discharge:
Facility Name Crop Production services - Princeton #0242
Facility Contact _ Phillip Slaritlon _pCedin. NW2gager
Street Address 141 Luby�Straith Road
city Princeton _ State _-B.C-_ __ ZIP Cope 2756
County
Telephone No. 919-735--8800 _ Pax: 919-735-8823
Page 1 of 5
SW U-NE•071408 Lact revised 711 4/2008

08/21/2009 16:26 2529730761 EHS PAGE 06/22
NCGNEOOOO No Exposure Certification
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). fits. 70 East- of Princeton._ Jt�st AL you
cross the Wayne_CcuntY_line, turn right onto Luby Smith_Rd.. ti ..,on T f+-
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) IS the facility located on Native American Lands? 0 Yes 7 No
5) Is this a Federal facility? 0 Yes A No
6) Latitude 35.271637 Longitude-78.08122 (deg., thin., seconds)
7) This NPD ES No Exposure Exclusion application applies to which of the following:
13. New or Proposed Facility
CIF Existing
Date operation is to begin
Date operation began 1963
d Renewal of existing No Exposure Certification Certification No.: NCGNE __
8) W3s this facility or situ ever covered under an NiPDES Stormwater Permit? ❑ Yes )b No
if yes, what is the NPDES Permit Number?.
9) Standard Industrial Classification:
Provide the 4 digit Standard industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 5 1 9 1
10) Provide a brief description of the types of industrial activities and products produced at this facility -
Agricultural Prcducts tail n 1
(:hertticals with fertilizer blendina onpratinn-,
11) Uoes this facility have any Non -Discharge permits (ex: recycle permits)?
M No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Exposure Cheakli$xs f 12. - 14j
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible Tor the no exposure exclusion.
❑ Yes AO
a. Using, storing, or cleaning Industrial machinery or equipment, and areas where
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b- Materials or residuals on the ground or in stormwater inlets from spill$Aeaks
c- Materials or products from past industrial activity
d. Material handling equipment (except adequately maintained vehicles)
e- Materials or products during loadinglun loading or transporting activities
f. Materials or products stored outdoors (except final products intended tar outside
use [e.g., new cars] where exposure to stormwater does not result in the dschargo
of pollutants)
0 Yes /NiD Yes I
q Yes I� 7
No
0 Yes V N
❑ Yes ;N0
Page 2 of 5
SWU•NE-071408 Lest revised 7114rMOB

09/ 21 / 2009 16: 26 2529730761 EFTS PACE 07/ 22
NCGNE0000 No Exposure Certification
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks,
0 Yes
afloo
and similar containers
h. Materials or products handled/stored on roads or rallways owned or maintained by
❑ Yes
[ No
the discharger
/No
i. Waste material (except waste in covered, non-IeaMing containers [e.g., dumpsters])
❑ Yes
j. Application or disposal of process wastewater (unless otherwise permitted)
G Yes
Id'No
k. Particulate matter or visible deposit$ of residuals from roof stacks and/or vents not
❑ Yes
E No
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
//
I. Empty containers that previously contained materials that are not properly stored
❑ Yes
2 No
(i.e., not dosed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers
lj Yes
P(No
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or C/ Yes ❑ No
deterioration, or evidence of teaks?
b. Is secondary containment provided for all exterior ASTs? it so, is it free of any i( Yes 0 No
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
14) SeConclary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers 2 Yes ❑ No
(including drums, barrels, etc_) with a capacity of more than 660-gallons?
/Yes
b. Is secondary containment provided for alcove ground storage containers stored
❑ No
in close proximity to each other wlth a combined Capacity of more than 1,320-
gallons?
c, is secondary containment provided for gny amount of Title III Section 313
e Yes 0 No
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals?
d. Is secondary containment provided for any amount of hazardous substances?
Les ❑ No
e. Are release valves on all secondary containment structures locked?
e(es ❑ No
15) hazardous Waste:
Page 3 of 5
SWU-NE-071408 Last revisad 7/14/2008 ,

"s@A•a, D\s"ajLL@L->=DP\rx1EjJ,j LL=v) j4j-L*=Tdj�jlgzei °-,IozraeUu®!®! taJjLb6®k1/-a*$
.t.T. ♦ ] .

08/21/2009 16.26 2529730761 EHS PAGE 08/22
NCGNE0000 No Exposure Certification
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? Cl Yes 9/Na
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste ❑ Yes Cd'No
generated per month) of hazardous waste? /
c, Is this facility a Large Quantity Generator (i 000 kg_ or more of hazardous waste 12 Yes f/ No
generated per month) of hazardous waste?
II you answered yes to questions b, or c., please provide the following information:
Types) of waste:
How is material stored: _
Where is material stored_
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
16) Certification:
I certify under penalty of law that I have read and understand the ellgiblllty requirements for claiming a condition of -no
exposure" and obtaining an exclusion born NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial aCtivities
or material from the industrial f8dlity or Site identified in this document (except as allowed under 40 CFR 122,26(g)(2)),
I understand that I am obligated to submit a no e4osure pert fication form QN4g every five _(5 years to the North Carolina
Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into
which lhs facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water
Quality, or MS4 operator where the discharge is into the local M54, to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request.
In the event that the site no longer qualities for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, i certify under penalty
of law that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gathered And evaluated the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted Is to tho best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submming false information, inducting the possibility of fine and imprisonment for
knowing violations_
i certify that f am lamllar 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: _ Philli Shannnn PppdYil
Title: /--N Branch Manaaer
(signature of
--.2-09
(Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCUENR Regional Office prior to issuance_ The Regional oftlea may inspect your facilily for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
Page 4 of 5
SWU-NE-071408 Lamfe0i 7114dnOS

6] -H*v 109 = I I %H69 @ I $ 6 I jH*ee !! *plpx®£

08/21/2009 16:26 2529730761 EMS I PAGE 09/22
NCGNE0000 No Exposure Certification
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowfngly makes any false statement, ropresentallon, or certification in any application, rewrd, 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 fatso
statement of a material fact in a rulemaking proceeding or contested case under this Articla; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated ar maintained under this Article or rules of the
(Environmental Management] Commission Implgmonting this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to excaed ten thousand dollars ($10,0001
There Is currently no fee for a No Fx osure Exclusion.
Final Checklist
This application should Include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
❑ if this is a renewal, indicated current NCGNE number in Question 7.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Noto
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWQ Regional Office for your area.
DWD Re Tonal Office Contact Information:
Asheville Office ......
(828).296-4500
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office,__.
(919) 791-420D
Washington Office ...(252)
946-WI
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 5of5
SWU-NE-071408 Last revised 7/14/2008

zLi

08/21/2009 15:26 2529730761
ENS PAGE 11/22
FertAlzet .
StrJid e
!!quid
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liquid
H'itrogen
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• Chemical
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V Seed
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Shop
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r
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141 LuOy Smith road
19 - a p IV 27869
912/06/06 18920
19-785-8l300

08/21/2009 16.26 2529730761 EHS PAGE 12/22
Crop Prodw*Jon Services
Princeton, North Carolina
Conceptual Environmental Plan Narrative
Crop Production Services operates a facility at 141 Luby Smith Road just east of the town of
Princeton, North Carolina along the western boundary of Wayne County. The facility distributes
bulk and bagged agricultural products including fertilizers and lime. The site is located in a rural
area of Wayne County and is comprised of approximately 4.6 acres of land, The site is
underlain by poorly drained soils and the topography is generally fiat. The site currently has a
vegetative buffer zone along the eastern edge of the property that is approximately 1.3 acres.
The site's stormwater runoff Is generally directed towards this buffer area, however, the
operational area of the site experiences flooding during larger storm events. To assist wide this
issue and to reduce the potential for windbom dust, Bay Environmental, Inc. has prepared a
conceptual plan that addresses drainage and trust control.
The site currently has windbreaks planted along the northeastern and eastern property
boundaries. These windbreaks consist of two rows of Leyland cypress planted on five to ten
foot centers staggered between the two rows. The conceptual plan proposes additional
windbreaks with a similar planting scheme along most of the remainder of the northern
property boundary, as well as along the entire southern boundary. The conceptual plan also
proposes to replace any dead, diseased, or dying braes within the existing windbreak, eased on
field reconnaissance, it appears that some of the trees In the extreme northeastem corner of
the site are being flooded, as the Leyland cypress does not tolerate irregular flooding. This
location may require the creation of a one foot berm to divert ponded water away from the
windbreak plantings.
The primary species that will be utilized for these windbreak plantings is Leyland cypress
(Cuprezocypw7i; leybndr& however, the cypress will have to be planted In higher areas not
subject to significant ponding (on berms for instance)_ As the final grading plans are
completed, the incorporation of other more flood tolerant species may have to be Considered.
August 20, 2009
Page 1 of 3

08/21/2009 16:26 2529730761 EH5 PAGE 13/22
o aj# LrR* JI1-.
The conceptual plan proposes vegetated buffers and landscaped beds on all areas of the facility
tt,at are not required for operations or traffic flow. These vegetated buffers will reduce the
amount of runoff directed to the eastern end of the properly and will provide soil stabill7ation to
reduce dust. The larger buffer areas along the northern boundary and in the southeastern
corner will contain taller- plantings (shrubs, small canopy trees) with low ground cover, and the
landscaping beds will contain perennials and gasses. The large vegetated buffer at the eastem
end of the property will have to be excavated slightly (less than 2 feet) to accommodate the
drainage from the site and to provide a slight gradient across tyre site, as currently, some areas
of the site are lower in elevation than the buffer area. This larger area will be pidnted with
native grasses and shrubs with a ring of large canopy trees an the rrorthem, eastern and
southern borders of the buffer area.
The primary species for these vegetative buffer areas include:
gra§s
Switehgrass (Pankurtm vinWam) plugs and seed
Pink Muhly Grass (Muhlenberoia caplllaris) plugs
Broomsedge (AndxVWons ftinicus) plugs or seed
Fescue and/or annual rye for temporary erosion control
all Cangipy Trees
Wax myrtle (Morella cerife-J)
Ironwood (arpinus cmrliniana)
Dwarf (Cottet) Willow (Salbrx cottetl�
Hybrid willows (Salixspp. 5X-61 or Sil-1)
Tulip poplar (Linbdaodmn tuliplli'ra)
WateLew
Within the northem and southern vegi�tated buffer areas, stormwater will be managed within
flat, vegetated areas referred to as water pans. These structures are flat (0% grade) areas
within the drainage course (vegetated swale) that are widened to provide water storage and to
slow the velocity of water as it proceeds downstream. The attached general cross sections
depict the outlet stnxtures for these water pans. Water parrs will be vegetated with species as
detailed above in the vegetative buffer sect€on,
JW
August 20, 2009`
Page 2 of 3

08/21/2009 16:26 2529730761 r'HS PAGE 14/22
The conceptual plan* proposes a retaining structure to contain bulk lime on the site, and to
protect the lime pile fmm wind. The proposed structure is a concrete block wall with a chain
link fence installed on top of the wall on the western and southern facing edges of the
structure. Wind break fabric similar to the fabric used for enclosed tennis courts will be
installed on the chain link fence to reduce the amount of the bulk lime pile subjected to winds
crossing from west to east. This design allows for loading to and from rail cars over the
nQrthem section of the kructure, and direct access with a loader from the eastern We of the
structure. This design will reduce carbon output by reducing equipment handling during
loading and unloading of railcars compared to other closed storage structures which may
require double handling of the bulk material.
August 20, 2009
■
Page 3 of 3
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08/21/2009 16:26
2529730761
EHS
PAGE 18/22
Page X of 3
Nancy Vincek
From: Kirk Williams
Sent: Wednesday, August 19, 2009 016 PM
To: Ken Pickle (ken,pickle@nedenr,com), Al Hodge ([e-mail]); Thom Edgerton
([e-mail]); Shelton Sullivan (shelton.sullivan@ncdenr.00v)
Cc: Nancy Vincek; Bill Coleman; Shannon Peedin; Jim Cahoon; Kirk Williams
Subject: Crop Production Services- Princeton, NC
Attachments: 20090819 CPS NCDCNR Site Refresher.PDF
Greetings to All- I would like to refresh all of you on the subject site. Please excuse my delay in being able to
address some of the site concerns and the volume of this email. I would like to share the below and attached
information, allow for your review, and plan a conference call or "Go To Meeting" for tomorrow where I can
summarize this information for you and we can then discuss and decide how to proceed. Your consideration of
the time constraint is appreciated.
Information Contained in the Attached pelt
• Pickle July 21 memo re NOV-2007-DV-0298
• CPS Conceptual Plan Narrative and Site Plan (Bay Environmental)
• Sand Creek Consultants peer review of Bay Plan
• Draft August 20 2009 CPS Fugitive Dust Control Plan (details lime storage area and other dust control
efforts)
• Storm water Permitting Interpretation packet 1991
• 1987 Standard Industrial Classification Manual Excerpt "Basis of Code Assignment"
• 5191 and 2875 SIC Code Descriptions
Bullet Point Discussion
SIC Code Interpretation
• Most Ag Retail centers are best described as SIC 5191 (now NAICS 424910)
• 5191 was exempt from the storm water regulations
• When sites have multiple "activities" the "Basis of Code Assignment in the SIC" (the page 15 referred to
in the Ephraim Icing, EPA Chief NPDES Program Branch) recommends assigning a code based on the
location's principal product and in this case retail or wholesale, by "Value of Sales."
• Sales as a percentage at Princeton (2009 to date) are as follows:
32% Packaged Chemical
277, Straight sale fertilizers (fertilizers that are not mixed or blended but received and sold directly "as
is" to the farm customer
22% Blended fertilizers
18% Seed
• CPS will remove all unnecessary equipment from the site
• Only clean pallets are stored outside for reuse
• Dry product field equipment (spreader trucks, Killebrews) contributions are considered de minimis
• All liquid equipment if field rinsed prior to returning to the site
Proposed Facil'rty�royements (presented at the lone meeting excluding Sand Creek peer review
8/20/2009

08/21/2009 16:25 2529730761 EHS PAGE 19/22
Page 2 of 3
• Phytoremediation and drainage plan- See CPS Conceptual Plan Narrative (original narrative)and Site
Plan by Bay Environmental
• Also see Sand Creek Consultants email comments and mark ups/suggested improvements to the gay
Conceptual Plan
• Phyto related grading and grassing can begin in the fall of 2009 and spring Z010 tree plantings. The
trees will require 2-3 years for full effect.
• Lime Containment Area (excerpted in part from the attached draft Dust Control Plan dated August 20,
2009):
The area responsible for most of the airborne dust -the historic lime storage
area on the southeast end - will be excavated back to the natural soil level and
back filled so the area can be seeded with grasses. This will eliminate airborne
dust from this area.
• The "active" lime storage area will be contained within a structure constructed
of a 4 to G-foot high cast wall or equivalent on three sides measuring 36' x 75'.
The open end will -face east and will include a ramp to prevent storm water from
flowing out of the storage area (though most likely fully absorbed by the lime).
On the west and south sides, we will add a 6 to 8' high chainlink fence with
appropriate sized mesh screening to buffer wind impact. The north side will not
be screened to allow the clam shell to unload the lime from rail cars directly into
the structure, eliminating the need to move the material twice. The adjacent
building provides a wind buffer on the north side. The lime pile will be shaped
(tabletop like) and will not be stored over the height of the wind break. We
believe these efforts will effectively control any fugitive lime dust while allowing
for operational considerations without the need for a cover and without the
additional carbon footprint from additional handling (ca nopy system) or the
impractical tarp cover (safety and labor concerns).
We are working with the phyto consultants to plant additional windbreak trees
on the southern, northern, and eastern boundaries to add to and replace the
trees we planted earlier. When these trees are established, they will form an
additional windbreak further minimizing any potential dust emissions leaving
our property_
The timeline for this work is as follows:
• Excavation of historic lime storage area will begin this summer and will be
completed so that the grasses can be planted in the Fall of 2009 or no later than
March 31, 2010_ Until the grasses are planted and established in this area, we
will spray with water to suppress the dust.
Lime Containment Area: containment will be in place prior to December 31.,
2009. Until the structure is complete, we will wet the pile to reduce airborne
particles. We do not plan to receive any additional shipments of lime until the
containment structure is complete.
• Windbreak Trees: The trees will be planted Fall 2009 or no later than March
31, 2010 to improve chances of becoming established.
Area 2: Driveway/, Parma Lot
8/20/2009

08/21/2009 16:26 2529730761 EFTS PAGE 20/22
Page 3 of 3
• Some of the areas in the driveway and parking lot will be excavated and
prepped for grasses and low bushes. This will eliminate some of the dry surface
areas around the facility. Refer to the site Plan attached for proposed planting
areas.
• The areas that cannot be planted will be wetted on a routine basis with water
to suppress the dust. A schedule will be developed and a log kept to document
the spraying.
The timeline for this work is as follows:
• The areas that can be planted will be done no later than March 21, 2010,
• The entire area is currently being sprayed with water on a routine basis. The
log is available for inspection at any time.
Su ma
CPS does not believe it is applicable to the storm water regulations based on the SIC code evaluation.
CPS has made significant investments (secondary containment system for liquids, dry product load out pads) and
proposes significant additional investment and effort to manage dusts and storm waters
CPS believes the consolidated lime storage area, even with the open top, will control fugitive dusts, eliminate
lime in solid or dissolved phases in storm waters, yet allow for operational needs with no additional carbon
footprint.
Proposed "Go To" Meeting (only email and web access is, necessary)
Thursday 1:30 Mountain, 3:30 Eastern. I will send an invite to your email.
Kirk Williams
Environmental Manager
Crop Production Services, Inc.
7251 W. 4th Street
Greeley, CO 80634
Office: 970-347-1542
Fax: [phone] S
Cell• 970-518-7430
Email: klrk.williams@cpsagu..com (note new email address as of 6/12/09)
8/20/2009

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08/21/2009 16:26 2529730761
Azriuni"Retai.
]AN FEB MAR APR
Facility:
EHS
PAGE 21/22
Safety POW
APPENDIX A -
MONTHLY INSPECTION REPORT
MAY JUN IUL AUG SEP OCT NOV DEC YEAR
— Inspector's Signature: - Date: — —
Monthly Inspections Items)
OK
corrective Measures
Required and Comment,
Date Actions
Completed
Emergency Eye WashfSarety Showers (weekty Inspection req.)
Week Y We& 2 Wft7 Week 4
Emergency Respirators/SCBA's
Facility Lighting & Securlty Signs)
Fire Extinguishers (All radlltles & mobile equipment)
First Aid Kits (complete & sanitary)
Guards & Covers (irwplant equipirrient)
Hoist Cable & Chain, Manlift Equipment
Noose Kmping/pverall Facility Appearance ([at graded)
Lockout/T`agout Equipment
PPE (gloves, goggles, respirators)
Spill Kits
Chernicat Warehwse (dean, organized)
Dry Fertilizer Warehouse, Storage Bins, MW61end Areas, Pads
Hazardous Waste Storage Areas (weakly inspection required)
Week I
Week 2 Week 3 Week 4
Liquid Fertilizer Tanks, containment, Mix/Blend Areas, Pads
Liquid Pestldde Tanks, Containment, Mix/Blend Areas, Pads
NK3 Fae llty (pains, plumbing, condition etc)
Use separate form more detailed Mgmctions if re4ulred by
your Aate/local requirements
Seed Warehouse
Used Oil Storoge Area
Scheduled Inspections
Application Equipment
Decontarninatlon Kits
Dry Buggies, !squid Trailers, etc.
Electrical (condition of boxes, wiring and cords)
NH3 Wagons, Nurse Tanks & Mobile Equipment (paint,
condition Btc
Nurse Trucks & Pickups
INSTRUCTIONS,. Complete all applicable sections of the forms and return a copy (both sides) to the Asmark
Institute With your monft/ training. Weekly inslxzdons are to be documented on the original form that is kept on
Me at the facility.
www.agriumtetailehs.com etailehs.com Page: 170 7-4-2008

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08/21/2009 16:26 25297307SI EHS PAGE 22/22
ium
Safety Pays!
STORM WATER DISCHARGE INSPECTION REPORT
Containment Area & Test Results* Method of
Date inspected By Sump Inspected (PPM) Disposal*
*List applicable tested constituents including Nitratetnitrites (test strips), Ammonia (test strips),
Sulfates (test kit), Phosphates (test kit), outside lab (retain results)
** Methods of disposal include on -site (non -detect for all applicable components), off -site
(complete "Notice of Application" }, reuse as make up water, and off -site disposal (requires
supporting documentation)
WWW.agriurnr+etallehs com Page: 7-4-2008

•
DUST SUPPRESSION SPRAY LOG
Date Time Time Weather and Est. Area Sprayed: Signed
Spraying Spraying Wind Speed and Lime Pile
Began Stopped Direction Yard
Both
•
•

•
JUL. 15. NOR 7:20AM CHAR-MECK UTY-ENG W. 1975 P, 18
Suhserinently, rho permittee's right to proceed under the NWP may bo modified, suspended, or
revoked only in accordance with the procedurc set forth in 33 CFR 330.5(d)(2.).
(b) Cottlents,of 1'r-CUnsttug' oti l atio : Tito PCN must be in writing and include
the following information-
(1) Name, address and telephone numbers of the prospective permittee;
(2) Lucation of the proposed project;
(3) A deswiptioa of the proposed'project; tho projec:t's purpose; direct and indirect
adverse environmental effects the project would cause; any otherNWP(s), regional general
permit(s), or individual pennit(s) used or intended to be used to authoriro any part of tlto
proposed lnoject or any routed activity, The doscription should be sutiiciantly detailed to allow
the district engineer to dctcmiina that the adverse effects ofthn projcct will be 6nincal and to
determine the need for compensatory rrritigatioat. Sketches should he provided when necessary
to show that the activity complies.with tlto terms of the NWP. (Sketches usually clarify the
project and when provided result in a quicker decision.);
(4) The, PCN must include a delineation of special uquatic sites and tither waters of the
United States on the project site. Wetland dolincations roust be prepared in accordance wilt the
current method required by the Corps. The permittee may ask the Corps to delineate the special
aquntie sites and other watcrs of the United Stages, but there may be a delay if the Chips does thri
delineation, especially if the project site is large or contains many waters of the United State.s.
Furthermore, the 45 day period will not start until the delineation has been submitted to or
completed by the Corps, where appropriate;
(5) 1f the proposed activity will result in the loss of greater than I A 0 acre of wetlands and
a PCN is required, tho prospective porinittee must submit a statement describing how the
Mitigation requircinwit will by satisfied. As an altomativu, the prospective pwinittco may submit
a conceptual or detailed mitigation plan.
(S) If any listed species or designated critical habitat might be affected or is in (Ito violnity
of Ilie project, or if the project is located In designated critical habitat, for uon-pederal applicants
tliu PCN must include the liamc(a) of those endangered or throatened species that might be
affected by the proposed work or utilize the designated critical habitat that may bu affected by
the proposed work. Federal applicants must provide documentation demonstrating compliance
with the Ridangercd Species Act; and
(7) For an activity that may affect a historic property listed on, detenniued to be eligible
lot listing on, or potentially eligible for listing on, die Nntional Register of Historic, Places, for
non -Federal applicants the 1'CN must state which historic property may be affected by the
proposed *nrlc or include a vicinity map indicating tiro location of the historic property. Federal
applicants must provide documentntioa demonstrating compliance with Section 106 of the
National Historic Preservation Act.
(c) Form of Prue-Constmetion Notification: 'rho standard individual permit application
form (Form LNG 4345) may be used, but the completed application fort imist clearly indivatc
that it Is a PCN and must include all of the Infrinuadon required in paragraphs (b)(1) through (7)
of this general condition. A letter containing the required information rttay also be used.
{d} Agency Cnordi t d: (1) The district engineer will coiwider any comments from
Federal and state agencies concerning the proposed activity's compliance.with the terms and
conditions of the NWI's and the aced'for mitigation to reduce the project's adverse
environmental effects to a minimal level.
0
11

i-�
-; ,
.tiv^�fy
.Jtt4 -,
UNITED STATES ENVIRONMENTAL FROTEC"nON AGENCY
'N,aSHING"CON, D.C. 20460
ACT 3 AS
Mr. Chris Myrick
Director
Legislative and Regulatory Affairs
National Agrichemical Retailers .association
1155 15th Street, N. w., Ith Floor
washingtcn, D.C. 20005
Dear Mr. Myrick:
CFW oP
WER
Thank you for your letmar dated August 17, 1991 and
attacbments addressed to Dr. .horn Baker, kgrieultural Advisor to
the Administrator, U.S. Invironmantal protection Agency (EPA).
In your letter, you ask for cla_i!ication of whether a fertilizer
wholesale or zetall distributor that performs some nixing or
blending as part of their operation is included in the definition
of a storm water discharge associated with industrial activity at
122.26(b)(14) of the storm water permit application regulation
(55 FR 47990).
Facilities that are primarily engaged in manufacturer mixing
and blending of fertilizers art classified as Standard Industrial
Class V i cation (SIC) code 2875. Major group 28 is included in
category ii of the definition of storm water discharge associated
with industrial activity; tnezetoze, facilities classified ass SIC
code 28 are required to :rational Pollutant Discharge
Elimination System (NPCES) storm water discharge permit
applications.
EPA agrees that incidental, or small kale mixing and
blending of fertilizers at wholesale or retail facilities does
not constitute manufact-urer blending and mixini; described under
SIC code Z875, and such w:tielesal= or retail facilities would not
be required to submit NPDES storm water discharge permit
applications. EPA also agrees that these facilities are properly
classified in SIC code 519i even though they may in some cases
ship to or exchange fertilizer with other retail or wholesale
outlets before shipment to the ultimate end user. However, when
the facility is mixing, bicndin;, and redistributing these
material on a tanufactt;ring scale such that the mixing and
blending becomes the activity in vniGh the facility is primar;'�y
engaged, that facility :rculti :men be more appropriately
classi_`iad under SIC and" IS75 and twMrgf0re WeVid bA required to
3UbAit a NPOES permit application :or its storm water discharges.

Grate Inlet: Standard'Drop Inlet
Bioretention Cell Outlet Design Storm: GRATE INLET
Grate area= 3.66 sf per grate
Q= CdA(2gh)^0.5 10 YR Qdesign= 2.99 cfs
Q: 2.99 Design Discharge (cfs)
Single inlet Cd= 0.60
A= 3.66
h= 0.03 ft
Solve for Depth of Flow (ft): h= 0.35 inches
f
Page 1

To determine which activity a facility is primarily engaged
in ,Then multiple activities occur an a given site, the wDasis of
Code Assignment in the SIC" code manual (found on page 13) should
be carefully followed. in summary, the principal product or
group of products or aer•rices are evaluated for aach activity
according to the data measures 'listed in the manual. A value
should be calculated for each activity. The activity with the
predominant value is the activity which defines tho SIC code
Classification, for .the facility.
would like to advise you, however, that States with
authorized NPDES permit prcrrams may have More stringent
requirements with respect tc storm water discharges. Under these
State programs, some or all of t.te star= water discharges
identified in your setter may be required to submit NPDES stor=
water discharge permit applications. In addition, when an
operator o: in industriai activity determines the applicable SIC
code for the activity, a vc-rifi.cation of the chosen Code by the
Stato regulatory agency 4*9 recommended. This would be most
important for industrial activities with multiple SIC code
activities occ:rrinq at one site.
it is also important to note that under the authority of
40,2 (p) (2) (F,) of the Clean water kct, any point source discharge
of star= water may be desi.gnatad and required to submit a permit
application if the pp--zi,ttinq authority determines that the storm
water discharge is contributinq to a violation of a water quality
standard or is a significant contributor of pollutants to waters
of the United States.
I hope that l have ciari,:ied thin :.ssue satisfactorily. 1.0
you have any further questions yap: may contact me at (202) 260--
9541. or William Swietlik of my staf` at [phone].
Sincerely yours,
raim King, Chief
ODES Program Branch
cc: Gary D. Myers, Vae Fert_Iizer institute
:3r. Richard Faye, McKcrna & C%nco
John 'Baker, Prx. , U. s . EPA

curb cut.txt
channel calculator
Given Input Data:
Shape ........................... Rectangular
solving for ..................... Depth of Flow
Flowrate ........................ 1.0000 cfs
slope ........................ 0.0100 ft/ft
Manning's n ..................... 0.0120
Height ..................... 6.0000 in
Bottom width .................... 36.0000 in
computed Results:
Depth ........................... 1.4136 in
Velocity ........................ 2.8296 fps
Full Flowrate ................... 9.6594 cfs
Flow area 0.3534 ft2
Flow perimeter .................. 38.8273 in
Hydraulic radius ................ 1.3107 in
Top width 36.0000 in
Area ............................ 1.5000 ft2
Perimeter .................... 48.0000 in
Percent full .................... 23.5607 %
Page 1

Las ANCCLcs
..a lOUT- ILO -Cm STA[CT
Los .Ncucs, c.L�Fo.N.. 900,.
I2 N) SA4ro00
SAN ,rANCISCO
!1[VAlT STRICT TOwC=
Oti[ MARt.[r .L.ZA
%AN fAANCISCP.CALITORNIA 94103
(a. Y,( pa�020a
S iCHARD A. FLY$
OiRlCT 01a� 4202) 761P•7662
By Hand
LAW orrlcEs
MCK£NNA & CUN£0
1573 EYE STREET. N.W.
WA5MINOTON, D.C. 20003
{202) 789-7500
CALL •UCACSS: NC"[NCON. wASwpC
TCL[R ITw [1 710.022'O�ao
YAa NEW) 709.7JDa
March 6, 1991
Mr. Frank E. Hall
Deputy Director, Permits Division
Office of Water Enforcement and
Permits
United States Environmental
Protection Agency
401 M Street, SW
Northeast Tower, Room 214
Washington, DC 20460
Re: Stormwater Permitting
Dear Frank:
(8)
SUkTc Soo
207 [AST %gyC.Tt[NT.. w[NUL
OLNvp R, COt OPPA00 50203
13011 •30-0700
ORUSS[L9
A.CNUC l*VtSC 267, •Ott 7
0-1060 ARUSS[LS. •ILOIUw
oil (322) 6.0-9.0
Thank you for your offer to assist Karl Johnson of The
Fertilizer Institute and me in our efforts to access the
administrative record.of the November 16, 1990 stormwater
permitting regulations in light of the temporary closure of the
EPA library. I enclose copies of the documents I promised.
These documents relate to the potential concerns I outlined in
response to the questions you posed yesterday.
Briefly, our concerns stem from conflicting advice provided
by the new "Stormwater Hotline" on an issue that was resolved six
or seven years ago. We believe the conflicting advice stems from
the Hotline contractor's unfamiliarity with trhe issue and its
history.
EPA's development of the September 26, 1984 stormwater
regulations, 49 Fed. Reg. 37,998, raised an issue of stormwater
permit coverage that was of great importance to the U.S.
fertilizer industry and American agriculture in general. The
1984 regulations required permits for certain stormwater
discharges at "industrial facilities." The question was whether
or not farm supply outlets that sell fertilizer to farmers were
subject to stormwater permitting because they incidentally mix

9. How was the off -site impervious area listed above derived?
7A
Projects in Union County: Contact the DWQ Central Office staff to check to see if you project is located
within a Threatened c& Endangered Species watershed that may he subject to more stringent storonvater
requirements,
IV. DEED RESTRICTIONS AND PROTECTIVE COVENANTS
One of the following property restrictions and protective covenants are required to be recorded for all
subdivisions, outparcels and future development prior to the sale of any lot. If lot sizes vary significantly, a table
listing each lot number, size and the allowable built -upon area for each lot must be provided as an attachment.
Dorms can be downloaded from http://h2o.enr.state.nc.us/sulbmi? forms.hhn_-.deed restrictions.
Form DRPC-1
High Density Commercial Subdivisions
Form DRPC-2
High Density Developments with Outparcels
Form DRPC-3
High Density Residential Subdivisions
Form DRPC-4
Low Density Commercial Subdivisions
Form DRPC-5
Low Density Residential Subdivisions
Form DRPC-6
Low Density Residential Subdivisions with Curb Outlets
By your signature below, you certify that the recorded property restrictions and protective covenants for this
project shall include all the applicable items required in the above form, that the covenants will be binding
on all parties and persons claiming under them, that they will run with the land, that the required covenants
cannot be changed or deleted without concurrence from the NC DWQ, and that they will be recorded prior to
the sale of any lot.
V. SUPPLEMENT FORMS
The applicable state stormwater management permit supplement form(s) listed below must be submitted for each
BMP specified for this project. Contact the Stormwater Permitting Unit at [phone] for the status and
availability of these forms. Forms can be downloaded from http://h2o.enr.state.nc.us/su/bmp forms.htm.
Form SW401-Low Density
Form SW401-Curb Outlet System
Form SW401-0ff-Site System
Form SW401-Wet Detention Basin
Form SW401-Infiltration Basin
Form SW401-Infiltration Trench
Form SW401-Bioretention Cell
Form SW401-Level Spreader
Form SW401-Wetland
Form SW401-Grassed Swale
Form SW401-Sand Filter
Form SW401-Permeable Pavement
Form SW401 -Cis tern
Low Density Supplement
Curb Outlet System Supplement
Off -Site System Supplement
Wet Detention Basin Supplement
Infiltration Basin Supplement
Underground Infiltration Trench Supplement
Bioretention Cell Supplement
Level Spreader/Filter Strip/Restored Riparian Buffer Supplement
Constructed Wetland Supplement
Grassed Swale Supplement
Sand Filter Supplement
Permeable Pavement Supplement
Cistern Supplement
Form SWU-101 Version 09,25.08
i
Page 3 of 4

L.AW OFFICES
MGKENNA & CUNEO
Mr. Frank E. Hall
March 6, 1991
Page 2
different fertilizers together to meet the needs of the farmer
customer. As I outlined to you, these farm supply outlets
generally sell all three of the basic nutrients, nitrogen,
phosphorus and potassium. As part of the services they provide,
the outlet assists farmers in conducting soil testing to
determine how much of each of these nutrients is required. After
this is determined, the farmer has two options. Either he can
make three separate applications of nitrogen, phosphorus and
potassium fertilizer, respectively, or he can mix the three
fertilizers together and make one application. Obviously, the
second option is far less time-consuming and expensive,
Therefore, the fertilizer outlet will mix the three fertilizers
together, in the correct proportions, thus allowing the farmer or
the outlet to make one application. Where necessary and
physically possible, the mix may also contain "micronutrients"
such as zinc and crop protection chemicals.
As TFI pointed out in 1984, this mixing of products at farm
supply outlets can be distinguished from the production of mixed
or blended fertilizer, often by chemical reaction, at large
fertilizer mix and blend plants where the resulting fertilizer
products are sold in bulk to retail suppliers or bagged for sale
to such retail suppliers, including farm -supply centers,
supermarkets, drug stores, garden centers, etc. These bulk blend
and mixed fertilizer plants are engaged in "industrial activity,"
farm supply outlets combining fertilizer products incidental to
their sale of those products to a farmer are not.
This issue of stormwater permit coverage of farm supply
outlets potentially affected many thousands (up to 10,000) local
businesses, many of them family run. Consequently, this issue
was the major issue addressed by TFI during and subsequent to the
development of the 1984 regulations. In this connection, TFI met
with EPA representatives to discuss this issue and also conducted
a workshop, attended by EPA representatives, at which the issue
was discussed extensively. After full consideration, EPA agreed
that farm supply outlets were not subject to stormwater
permitting.
This conclusion was adopted in TFI's voluntary stormwater
discharge data -gathering program. TFI's March 22, 1985 draft
commitment letter addressing the data -gathering program (copy
enclosed) carefully restated this conclusion (see pages 9-11).
EPA's agreement was again confirmed in conversations with EPA
officials (see enclosed April 9, 1985 memorandum). EPA's
response to TFI's draft commitment letter (copy enclosed)
outlined changes required in TFI's data -gathering program. No

VI. SUBMITTAL REQUIREMENTS
Only complete application packages will be accepted and reviewed by the Division of Water Quality (DWQ).
A complete package includes all of the items listed below. The complete application package should be
submitted to the appropriate DWQ Office. (Appropriate office may be found by -locating project on the
interactive online map athtip://h2o.enr.staic.nc.us/su/rnsi„maps.litii
1. Please indicate that you have provided the following required information by initialing in the space provided
next to each item.
Initials
• Original and one copy of the Stormwater Management Permit Application Form
• Original and one copy of the Deed Restrictions & Protective Covenants Form (if /
required as per Part IV above)
• Original of the applicable Supplement Form(s) and O&M agreement(s) for each BMP T1�
• Permit application processing fee of $505 (Express: $4,000 for HD, $2,000 for LD)
payable to NCDENR 1
• Calculations & detailed narrative description of stormwater treatment/management 1 6
• Copy of any applicable soils report :/
• Two copies of plans and specifications (sealed, signed & dated), including: T13
- Development/Project name
- Engineer and firm
-Legend
- North arrow
- Scale
- Revision number & date
- Mean high water line
- Dimensioned property/project boundary
- Location map with named streets or NCSR numbers
- Original contours, proposed contours, spot elevations, finished floor elevations
- Details of roads, drainage features, collection systems, and stormwater control measures
- Wetlands delineated, or a note on plans that none exist
- Existing drainage (including off -site), drainage easements, pipe sizes, runoff calculations
- Drainage areas delineated
- Vegetated buffers (where required)
Vli. AGENT AUTHORIZATION
If you wish to designate authority to another individual or firm so that they may provide information on your
behalf (such as additional information requests), please complete this section. (ex. designing engineer or firm)
Designated agent (individual or firm): (9 F A
Mailing Address: 1Y30 C,t%Sk St /VW Sy';Pe- 9-a0
City: A4Ian -e, State: 6iX _ Zip:_ 303 G �l
Phone: ( L04 ) (o0I '1000
Email- I OC2Rgfregnber� ' rrouo. Corn
Vlll. APPLICANT'S CERTIFICATION
Fax: ( go �( (0a 1 - 39 fd
I, (print or type name of person listed in General Information, item 2) i Ohr\6-S
certify that the information included on this permit application form is, to the best of my knlfwledge, correct and
that the project will be constructed in conformance with the approved plans, that the required deed restrictions
and protective covenants will be recorded, and that the proposed project complies with the requirements of 15A
NCAC 2H .1000.
Signature:
Date:
Form SWU-101 Version 09,25.08 Page 4 of 4

LAW OFPICES
MQKENNA & CUNEO
Mr. Frank E. Hall
March 6, 1991
Page 3
changes were required insofar as the non -inclusion of farm supply
outlets was concerned.1/
Given the time and effort devoted to this important issue
by both TFI and EPA, TFI considered the issue resolved. TFI
carefully reviewed both the December 7, 1986 proposed stormwater
permitting regulations, 53 Fed. Reg. 49,417, and the November 16,
1990 final regulations, 55 Fed. Reg. 47,990. Neither of these
documents in any way suggested that the issue did not remain
resolved. To the contrary, the proposed and final regulations
confirmed the 1984-1985 resolution. Farm supply outlets are
properly classified in SIC Code 5191 - Farm Supplies. Bulk mix
plants are properly classified in SIC Code 2875 - Fertilizers,
Mixing Only. Facilities in SIC Code 2875 are subject to
stormwater permitting, facilities in SIC Code 5191 are not.
Furthermore, the SIC Code Manual description of Wholesale Trade,
of which SIC Code 5191, is a part, makes it clear that:
In addition to selling, functions frequently
performed by wholesale establishments include
maintaining inventories of goods; extending
credit; physically assembling, sorting, and
grading goods -in large lots; breaking bulk
and redistribution in smaller lots; delivery;
refrigeration; and various types of promotion
such as advertising and label designing.
1987 SIC Manual at 287 (emphasis added). I enclose copies of
relevant pages of the SIC Code Manual. Thus, the SIC Manual
precisely describes the fertilizer mixing activities engaged in
by farm supply centers as part of Wholesale Trade. The preamble
to the November 16, 1990 stormwater regulations makes it clear
that "EPA intends that the list of applicable SICs will define
and identify what industrial facilities are required to apply,"
55 Fed. Reg. 48,011; and that the regulations "exclude from the
definition of industrial activity, at S 122.26(b)(14) of today's
rule, those facilities that are generally classified under the
Office of Management and Budget Standard Industrial
Classifications (SIC) as wholesale retail service or
commercial activities. 55 Fed. Reg. 48,007 (emphasis added).
?� For your information, I also enclose a copy of TFI's April
12, 1985 final commitment letter. The voluntary data
collection program was discontinued by EPA shortly after
TFI's final commitment letter was submitted.

Lawrence Associates, PA
106 W. Jefferson St
Monroe, NC 28112
Storm Drainage Design
for
Piedmont High School
Town of Unionville
Union County, North Carolina
Project No.: 2249
Storm Drainage Calculations
Bioretention Cell Supplement
Bioretention Cell Design
Bioretention Depth Over Outlet
Rip Rap Calculations
BAR "'o
SEAL -
985 -

LAW oi*iCE'S
MCKENNA 5 CuNEO
Mr. Frank E. Hall
March b, 1991
Page 4
The potential concern has arisen as a result of conflicting
advice on this issue provided by the stormwater Hotline. In
early February 1991, the National AgriChemical Retailers
Association (NARA), unaware of the history of this issue,
contacted the Hotline for advice on the permit coverage of farm
supply outlets. The advice they received was in full accord with
the conclusions reached by EPA in the mid-1980's. I enclose a
copy of the NARA Washington Update, sent to its members,
reflecting the advice initially received.
In the last week, however, one of TFI's member companies,
and NARA itself, have been informed by the Hotline that farm
supply outlets must apply for stormwater permits for their
incidental mixing activities. The person to whom TFI's member
company and NARA recently spoke was not the same person to whom
NARA spoke earlier.
We believe that this conflicting advice results simply from
the Hotline contractor's unfamiliarity with the long and detailed
history of this issue. Therefore, we would appreciate it if EPA
could inform the Hotline contractor of the long --standing
resolution of this issue so that advice provided in the future by
the contractor will be consistent with that long-standing
resolution.
If, however, the explanation for the conflicting Hotline
advice lies elsewhere, we believe it is essential that we meet in
the immediate future to discuss and resolve the enormous problems
that would be occasioned by a reversal of EPA's earlier
resolution of this issue. Such a reversal of position could
require up to 10,000 facilities to apply for stormwater permits
at a point in time only two weeks away from the deadline for
group applications. Furthermore, such a change of position would
be without notice to the affected regulated community or the
public and without an opportunity for comment or full
consideration of the important issues involved.
Thus, if there is any more to the conflicting Hotline
advice than the contractor's lack of understanding of the history
of this issue, please let me know immediately so that we can

Q �0.-9t`17 X,; °'jLJ
�cfS r
94
= 2 � sf =I a, ssA,
I- o 6,,,ne 0, 23 xc, 33'
Cw

lI►W pi'i'iC E9
MCKENNA & CUNEO
Mr, Frank E. ball
March 6, 1991
Page 5
discuss the resulting issues in greater detail. Also, if you
need any further information, please feel free to contact me at
789-7682.
Sincerely y urs,
Richard A. Flye
Counsel to The Fertilizer
Institute
RCAF/pw
Enc.
cc: Chris Myrick, NARA

Bioretention Design
Rv = runoff coefficient (Runoff/Rainfall)
Rv = 0.05 * 0.0090 ) Where "I" = % Impervious
("Simple Method" - Schueler, 1987)
NCDENR April 1999
Fill in Values:
"I" _ 1J.W60M Percent Impervious of Site
'A' _ O 68! Acres
Answer:
WQv NOROJ0290JAc. Ft.
A ` MCubic Feet Required
Formula:
Af = (WQv)/(Pd) Where:
Af = Surface area of Rain Garden (S.F.)
WQv = Water Quality Volume to be Captured
Pd = Ponding Depth (Between 9" to 12")
Fill in Values:
Pd = jWjM&q_q-$j inches
Pd = INWA015 Feet
Answer:
Af = &5 Square Feet Required
For Rain Garden
., _jdtlMinimum
r-, ...
Sri hi
Approximate Size

• 111EFER.q.E I*g
ER
INSrrrl= 501 Second Street. N,S., Washington, O.C. 20002 [phone]
GARY D. WYFRS
Pnnidw
June 14, 1991
Thomas J. Seaton, Esq.
Attorney Advisor .
Office of Wastewater Enforcement
and Compliance (EN-336)
united States Environmental
Protection Agency
401 M Street, SW
Washington, DC 20460
Re: Stgrmwater Permitting
Dear Mr. Seaton:
Over the last seven years, The fertilizer Institute (TFI)
and the United States Environmental Protection Agency (EPA) have
engaged in a series of discussions and correspondence concerning
the scope of the Clean Water Act's Stormwater permitting program
as it applies to fertilizer outlets. The correspondence involved
includes an exchange of several letters in 1985 and TFI's letter
to EPA of March 6, 1991. ,
Based on our correspondence and discussions, TF1
understands that EPA agrees that facilities primarily engaged in
the wholesale or retail distribution of fertilizer to end users
are properly classified in Standard Industrial Classification
(SIC) Code 5191 - Farm Supplies. Therefore, such facilities are
not subject to the stormwater permitting program established by
S 402 of the Clean water Act, 33 U.S.C. S 1342. Furthermore, EPA
agrees that this conclusion is not altered by the fact that such
facilities may mix or blend different fertilizers to meet the
needs of their customers. Finally, we understand that EPA also
agrees that these facilities are properly classified in SIC Code
5191 even though they may in some cases ship to or exchange
fertilizer with other retail or wholesale outlets before shipment
to the ultimate end user.
Tl v- on -1cm . TUVY• 74A e99 09riq a TAIecacierl (202) 5"8123

Underdrains
Outlet Invert Height Above Bottom of Gravel
2ft
Thickness of gravel below outlet
�5 ft
Thickness of media below outlet
ft
Rough Max Water Detention in Media
9M cf
Minimum Flow
Darcy's Law
MI -fa
Factor of Safety (range between 2 and 10)
Design Flow
c f s
Manning's Roughness Coefficient
0.011 smooth wall
0.015 corrugated wall
. 4 01,1 n
Internal Slope (recommended minimum 0.5%)
Pipe(s) Diameter(s)
jjjjMgRMjM inches
equation: D = 16 ' (Q ` n ` s^0. 5)^{318)
# of 4" diam. # of 6" diam. calculations assume n=0.011
Underdrains Underdrains
REMOMR
2
Note : A minimum of 2 underdrains recommended

Thomas J. Seaton, Esq.
June 14, 1991
Page 2
TFI appreciates your acknowledgment of our understandings
and the timely resolution of this most important issue.
Sincerely yours,.
Gary D. Myers
President
Reviewed and Approved
United States Environmental
Protection Agency
By

Monroe, NC
Precipitation Data Chart From: http://hdsc.nws.noaa.gov/hdsc/pfds/
Preci
itation Frecql ncv Estimates
inches
ARI'
(years)
5
min
10
min
15
min
1 30
min
60
min
120
min
3
hr
6
hr
1 12
hr
24
hr
48
hr
4
day
7
day
10
day
20
day
30
day
45
day
60
day
1
0.43
0.68
0.851
1.17
1.46
1.69
1.8
2.2
2.5
2.99
3.52
3.94
4.54
5.221
7.02
8.63
10.9
13
2
0.51
0.81
1.02
1.4
1.76
2.04
2.2
2.6
3.1
3.61
4.23
4.72
5.42
6.21
8.29
10.2
12.8
15.2
5
0.59
0.94
1.19
1.69
2.17
2.53
2.7
3.2
3.8
4.54
5.29
5.84
6.61
7.48
9.8
11.8
14.6
17.2
10
0.65
1.03
1.31
1.89
2.46
2.9
3.1
3.7
4.5
5.28
6.13
6.73
7.57
8.49
11
13.1
16
18.7
25
0.71
1.14
1.44
2.13
2.84
3.38
3.7
4.4
5.3
6.32
7.3
7.97
8.89
9.85
12.6
14,8
17.9
20.7
50
0.76
1.21
1.53
2.3
3.12
3.74
4.1
5
6
7.16
8.25
8.97
9.96
10.9
13.9
16.2
19.3
22.3
100
0.8
1.27
1.6
2.46
3.39
4.1
4.6
5.5
6.7
8.04
9.24
10
11.1
12
15.2
17.5
20.7
23.7
200
0.84
1.33
1.67
2.6
3.65
4.45
5
6.1
7.5
8.96
10.3
11.1
12.2
13.2
16.5
18.8
22
25.1
600
0.88
1.39
1.75
2.78
3.99
4.92
5.6
6.9
8.5
10.3
11.8
12.7
13.9
14.7
18.3
20.5
23.8
27
1000
0.91
1.43
1.79
2.91
4.24
5.28
6.1
7.5
9.3
11.3
12.9
13.9
15.2
16
19.7
21.9
2521
28.4
Intensity, Peak 10-yr, 24-hr
d(in)124hr 0.22 in/hr
Depth at 24hr& 10-yr: d= 5.28 in

JUL 31 '91 I2:38 M&C
LAW OorwICE3
MCKENNA 6 CUNEO
,00 ANOt,[r
1576 CYC STRE[T, w w.
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3Q3 LAar 99VLNTLLN7N Ar[wua
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ArLMIL LOLUIYf 1417. SON 7
a+N /Ra NCIrCO. CAL1?* IM.A 04106
a'.oro aRUraLLS. "641UN
14Ar1 94*s 0104
O�1 iaasl *..!•Arlo
R1CHARo A. FLYE
wAaCT aaL 41011 760.7601
June 14, 1991
Thomas J . Seaton, Esc}.
Attorney Advisor
Office of Wastewater Enforcement
and Compliance (EN•-336)
United States Environmental
Protection Agency
401 M Street, SW
Washington, DC 20460
Re: TFI Starmvatjr Permitting Issues
Dear Mr. Seaton:
During our recent conversation, you requested that The
Fertilizer Institute prepare a letter, for EPA review and
approval, summarizing TFI`s understanding of the agency's viers
on the scope of the Clean Water Act's stormwater permitting
program as it applies to fertilizer outlets. I enclose such a
letter from Gary Myers, President of TFI.
I would appreciate it if you and others involved at EPA
could review this letter and return an executed copy to me at
your earliest convenience. If you have any questions concerning
the enclosed letter, or any other aspect of this matter, please
feel free to contact me at 789-7682.
Sincerely yours,
Flye
The Fertilizer
Richard A.
Counsel to
Institute
RAF/per
Enc.
cc: G.D. Myers

Water Draw Through Rate:
Darcy's Equation:
Q = (.0000232)"K`A"('HIL )
Where:
Q = Flow (Rate of Draw) through Bioretentioin Soil (cfs)
K = Hydraulic Conductivity of soil ( Use 1"!Hour)
A = Surface Area of Bio-Retention Area (SF)
H = Height of Water above Drainage ripe (Underdrain)
L = Thickness of Soil Bed
Assume (HIL) — 1
Time to Drawdown water from Inundation to Saturation at Surface:
Volume/Q: 21552 Seconds
Time to lower Water Table to 2.0 feet below surface:
Assume 45% Porosity
Volume = Area x 2' x 0.45
1490.6 Cubic Feet
38793 Seconds
Fill Soil Choice
Nitrogen Removal - Sandy Loam
K= 1 inlhr Soil Type: 12% Fines (Silt+Clay), 82-85% Sand, 3-6% Organic
Other Pollutant Removal - Loamy Sand
K= 2 inlhr Soil Type: 8% Fines (Silt+Clay), 86-90% Sand, 2-4% Organic
Saturated K = 2 inlhr
Fill Soil Thickness = = 2 ft
Fill Soil Eff. Porosity = -1 fraction 0.1-0.45
Stone Envelope Thickness =MR
ft
Stone Envelope Eff. Porosity =, fraction 0.1-0.45

n � �
";,II A' !?1S iwrnic.S1 Ri-Lkifw, A ,iwi•Iion
II',5 [.ill[ tlntia, h,W„ •illl hh�K . tV,�yhinGsr,rti, P)�{;, � jpE1[1.5
i;: ; • FAX 11!(12! -6 -0864
BY FAX
DATE: October 3, 1991
TO: State Fertilizer and Chemical Associations
FROM: Chris Myrick, NAR k
RE: EPA Clarification of Storm water Permit Requirements for
Agr",Chemical Dealers
At long last, the Environmental Protection Agency has responded to NARA's request for
clarification or storm water permit applicability to retail dealers who mix and blend
fertilizers And market pesticides for use on the farm.
With this letter, state associations have something in hand to work with State rm. latory
officials when they consider permitting rct:[il agrichemical dealerships.
Key points of letter-
.. "EPA agrees that incidental or small scale mining and blending or fertilizers at
wholesale or retail facilities does not constitute manufacturer blending and mixing
facilities under SIC code 2875, and such wholesale or retail facilities would not be
required to submit NPDES storm water discharge permit applications".
.- "EPA also agrees that these facilities are properly classified in SIC code 5191 even
though they may in some cases ship to or exchange fertilizers with other retail or
wholesale outlets before shipment to the ultimate end user".
-- "I would lime to advise you, however, that States with authorized NPDES permit
programs may have more stringent requirements with respect to storm water discharges".
NARA recommends that Suite aS 06.1tiOnN use this letter when dealing with state
regulatory agencies and that they provide information as to where deniers can obtain a
SIC code of 5191 for facilities that have been improperly classified.
Questions, call NARA at 202-457-0825.

Riprap Velocity Dissipator Pad
OUTLET A
Piedmont High School
Union County, North Carolina
Design Storm: 10-year
BACKGR( Use the E&S Control Planning & Design Manual, Section 8.06.
REFEREN' (NCDEHNR, 1993)
Step 1. Minimum Tailwater Condition
Step 2. D-o =
15 in.
D-o =
1.25 ft.
Q-10 =
0 cfs
V=
0.00 fps
d-50 =
0.25 ft. Figure 8.06 a
L-a =
8 ft. Figure 8.06 a
Step 3. 3*D-o =
3.75 ft, Use: 5 ft
W =
9.25 ft. Use: 10 ft
Step 4. d-max
0.375 ft. Maximum Stone Diameter (1.5*d-50)
d-max
4.5 in. Class A Rip -Rap
Step 5. Thickness =
0.6 ft. Apron Thickness With Filter Fabric (1.5*d-50)
Thickness =
7 in. Use: 12 in
TERMINO Q25 =
25-Year Design Storm, Peak Discharge, (cfs)
D-o =
Pipe Diameter, (in. & ft.)
d-50 =
Mean Stone Diameter of Rip -Rap, (ft.)
L-a =
Length of Rip -Rap Apron
3*D-o =
Width of Rip -Rap Apron @ Pipe End of Apron, (ft.)
W =
Width of Rip -Rap Apron @ End of Apron, (ft.)
d-max =
Maximum Stone Diameter of Rip -Rap, (ft. & in.)
Thickness =
Thickness of Rip -Rap Apron With Filter Fabric, (ft. &in.)

Ie: NCS - questions'
Subject: Re: NCS - questions'
From: Bethany Georgoulias<[e-mail]>
Date: Fri, 28 Sep 2007 16:19:37 -0400
To: Ken Pickle <[e-mail]>
Ken -
Save those pictures and this advice. This is the kind of thing we should share at
our RO Training Workshop!
Ken Pickle wrote:
A1,
I spoke with Ed today, and unfortunately, I can't make a site visit next week.
But we have talked about permitting these folks, and whether or not they have in
fact been discharging without a permit.
This part is tricky wrt what the actual industrial activity taking place really
is. There are some cases where similar looking activities might be categorically
required to have a permit, and some where they wouldn't. In 40CFR122.26 the
federal regs outline what types of activities are categorically covered by the
NPDES program. It looks to me like we need to make an on -site call as to
permitting based on whether we think the facility is A) manufacturing agricultural
chemicals, or B) whether they are only wholesaling them without on -site
manufacturing. For Example::::
PERMIT CATEGORICALLY REQUIRED:
SIC 287 - Agricultural Chemicals - including 2873, mixed Fertilizers made in
plants producing nitrogenous fertilizer materials; 2874, establishments primarily
engaged in manufacturing phosphatic fertilizer materials; 2675, Establishments
primarily engaged in mixing fertilizers from purchased fertilizer materials; 2879,
including establishments primarily engaged in manufacturing soil conditioners.
NO PERMIT CATEGORICALLY REQUIRED:
SIC 5191 - Farm Supplies - Wholesaling Agricultural Chemicals, Wholesaling
Agricultural Limestone, Wholesaling Fertilizer and Fertilizer Materials,
Wholesaling Agricultural Lime, Wholesaling ground phosphate Rock.
If the site is mixing, blending, combining, or reacting materials resulting in an
agricultural chemical product, an NPDES permit is categorically required.
Further, if the site is re-packaginq, then I have made the call previously that
they need our permit. I mean, if they receive the material in bulk, but actually
sell it in bags, from a bagging operation on site, then I have called that
"manufacturing from purchased materials" on one or two previous occasions. My
perspective has been that their product is the bagged item itself, and that they
go through a manufacturing process to make their end product.
However, if the site is receiving in bulk, and selling in bulk, and there is no
blending, mixing, etc, nor bagging, nor re -packaging, etc, then strictly speaking
they are not "manufacturing" and they are not categorically required to have our
permit. But, even in this case, there is good news to come.
So......
First step in permitting - Are they "manufacturing" or "wholesaling only"? This
step determines whether they are categorically required to have our permit, and
whether or not they have been discharging w/o a permit.
Second step in permitting - Here's the'good news - - If there's a problem, and it
looks like there is from your photos, then we can still require a permit from them
by "designating" them under our rules at 15A NCAC 2H .0102(4) and other places,
even though they may not be categorically required to have a permit. That may be
our path at this site. (Presuming, of course, that they have a point -source
discharge.)
1 of2 12/28/2007 10:17 AM

Re: NCS - questions'
Third step in permitting - We probably won't want to put them in a General Permit,
so it looks like they need an Individual Permit. No problem. It's actually
better, because we get to format the individual permit for exactly what we want
them to correct and accomplish, both now and in the future.
Ken
Al Hodge wrote;
hi guys
just making sure; we would cover this under an individual fed sw permit.
i've looked in the sic manual and believe that 5191-Farm Supplies: would be the
classification this guy is under.
Crop production Services is the name
Bethany Georgoulias
Environmental Engineer
NC DENR DWQ
Stormwater Permitting Unit
[phone], ext. 529
[e-mail]
2 of 2 12/2$/2007 10: 17 AM I

Crop Production Services
L/ r to 46edtrer4(2m Creek e3-4¢-10L
2,7- SS
Subject: Crop Production Services A/S'it/
From: Ken Pickle <[e-mail]>
Date: 'rue, 02 Oct 2007 15: 54:49 -0400
To: Ed Warren -Jr <Ed. [e-mail]> Gt!Sff Ns` N/ C%�)
CC: Al Hodge <[e-mail]>, Bradley Bennett <[e-mail]>, Bethany
Georgoulias<[e-mail]>
Ed,
Here are my observations after our visit this morning. Almost all of this we
discussed on site, I'm just re -iterating it for my notes, and as an aid in your
follow-up letter with them.
1. This facility must apply for an individual NPDES stormwater permit. There is no
general permit that fits their activity. The basis for this conclusion is provided
below.*
2. There have been discharges of stormwater from the site in the past, and given that
a permit is required for their industrial activities, this facility was discharging
stormwater without a permit. There is certainly a basis for WARO to initiate
enforcement action for discharging without a stormwater permit.
3. The operator seems willing, and able with corporate help and funding, to address
the original issue of dolomitic limestone discharges from his facility. We didn't
discuss much about the nutrient discharges. We probably need to clarify for
ourselves which of those discharges are stormwater (incidental puddles resulting from
spilled materials?), and which are wastewaters (liquids that escape from the main
building floor, where many nitrogenous materials are contained in bins? and/or
washdown water? sprinkler water?)
4. While we have a complaint, and EPA interest, in the discharge of dolomitic
limestone (finely ground limestone of primarily CaCO3 plus varying lesser amounts of
MgCO3) from the site, of more concern to me is the presence of nitrogenous and
phosphatic materials where the receiving water (UT to Little River, Neuse Basin) is a
WS-IV NSW . I'm not sure that the limestone is a significant pH issue - - I'm not
saying it isn't, I'm just saying that this material is not quicklime, Ca(OH)2, and so
I would not automatically presume that pH would be in the 11-12 range - - I would
presume that it would be lower, but still somewhat alkaline. If I understand the
operator, more significant to me is that many of the granular and pelletized
nitrogenous materials deliquesce, resulting in a brownish liquid puddle, even in the
absence of rain or washdown water. So we have a ready source of nutrients at a
couple of on -site locations that can be transported when it does rain. Further, he
has reported to us that he releases collected rainwater from the AST containment
areas when the colorimetric test strips indicate less than 10 ppm nitrogen. Also,
although we didn't observe this during our visit, the operator indicated that the
railcars on his siding typically leak a little granular material that also
subsequently liquifies under the cars.
5. As you pointed out while we were with the operator, this facility has the land
available to implement some vegetated stormwater BMPs. We have considerable freedom
in the drafting of an inividual stormwater permit to address the specific problem
areas on the site. I think it is likely that we will ask them to implement some
vegetated structural BMPs in their individual stormwater permit.
6. You alerted them to the potential that some of their discharges might be
wastewaters, but 1 don't think the operator appreciated that the distinction between
wastewater and stormwater might be significant for him. I'll be glad to work with
1 of 2 10/2/2007 3:55 I'M

Crop Production Scivice5
you on him, once we get it clear in our minds what we want him to do about which
flows. WARD might have a basis for enforcement for discharging without a wastewater
permit, too.
7. Other site circumstances: I judge from the soils that they're in the sandhills or
coastal plain, -and the sandy soils are likely highly permeable, and so the
contaminated runoff volume might be greatly reduced on this flat, porous site,
compared to runoff in the piedmont. And, he is located in an agricultural area, so
that his nutrient contribution might not be the only contribution in his immediate
watershed. Given the materials he handles, I think that they should attempt some /
improvement in housekeeping, but I don't think it is realistic to hope that this ✓
site could ever qualify for the No Exposure Exclusion from permitting.
*NPDES Stormwater permit rationale: By my observation, and by the operators
confirmation that they blend materials, this facility fits SIC 2875 FERTILIZER,
MIXING ONLY, "Fertilizers, mixed: made in plants not manufacturing fertilizer
materials". SIC28 is captured in the federal stormwater regs at
40CFR122.26(b)(14)(ii), which is incorporated by reference as NC rule at 15A NCAC 2H
.0126. This string of citations establishes that a NPDES stormwater permit is
required. Since we don't have a general permit covering SIC28, they must be
permitted with an individual stormwater permit. Thanks for bringing the EPA Form 1
and Form 2F.
Ed, I hope this helps on your follow up letter. Please copy me. I think we have a
willing permittee here, and a manageable problem, so I believe we have a chance to
really accomplish something with Crop Protection Services.
Ken
2 of 2 10/2/2007 3:55 PM

O��F W A T �RpG Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environnicnt and Natural Resources
p Colcen Sullins, Director
Chuck Wakild, P.E., Deputy Director
Division of Water Quality
November 19, 2007 - '�""""�111PUB00
AVM - �JN30
CERTIFIED MAIL 7007 0220 0003 1484 7685 AON
RETURN RECEIPT REQUESTED J
Mr. Billy Pirkle �uutl
Crop Production Services, Inc.
6 Executive Drive
Collinsville, IL 62234
Subject: NOTICE OF VIOLATION -NOTICE OF INTENT TO ENFORCE CIVIL PENALTY
ASSESSMENTS
NOV-2007-DV-0298
Crop Production Services, Inc.
Wayne County
Dear Mr, Pirkle:
A site inspection of the ­Crop Production Services, Inc. facility located at 141 Luby Smith Rd.,
Princeton, Wayne County, NC was performed on October 2, 2007. The inspection was performed by
Ed Warren, NC Division of Water Quality, Surface Water Protection Section, Washington Regional
Office and Ken Pickle, NC Division of Water Quality, Stormwater Permitting Unit, Raleigh, NC.
The inspection revealed the following violations of North Carolina General Statutes (NCGS) and the
North Carolina Administrative Code (NCAC):
(1) Facility is engaged in industrial activities requiring a Federal NPDES Individual Stormwater
Discharge Permif, is discharging stormwater from the site and does not possess the
appropriate permit(s) (15A NCAC 2H .0126).
(2) Facility is generating process wastewater from product storage areas on site, which is
discharged directly or commingled with the stormwater discharge and does not possess the
appropriate permit(s) (NCGS 143-215.1).
These violations are subject to a maximum civil penalty assessment of $10000 per day per violation.
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue
enforcement action for this and any additional violations of State law.
Nt ilhCarolina
North Carolina Division of Water Quality Washington Regional Office Phone [phone] Customer Service
Internet: www.ncwaterqualily.org 943 Washington Square Mall, Washington, NC 27889 FAX [phone]
An Equal opportunity/Affirmalive Action Empbyer— 50% RecycJedl14% Post Consumer Paper

To prevent further action, carefully review these violations and deficiencies and respond in writing to
this office within 10 days of receipt of this letter. You should address the causes of noncompliance
and all actions taken to prevent the recurrence of similar situations. if you have any questions,
please contact Ed Warren at [phone] or Ken Pickle at [phone] (Ext. 584) or myself.
Sin erely,
4V—Hodge, Regional Su ervikr' : k'
p -�
Surface Water Protection Section
Washington Regional Office
Division of Water Quality
Cc: WQ Central Files
Ken Pickle-Stormwater Permitting Unit
Shelton Sullivan-Nondischarge Enforcement
WaRO Enforcement Files

From: "Bill Coleman" <[e-mail]>
Date: Tue, I I Dec 2007 08.41:28 -0800
To: <[e-mail]>, <[e-mail]>, <ed.warren [e-mail]>
CC: "Anderson, Thomas C - Hartsville, SC" <[e-mail]>, "James Pirkle"
<jbpi rkIe a roysterclark.corn>, "Randy Springs" <[e-mail]>, "Tevebaugh, Beverly J -
Collinsville IL" <BJTevebaugh @roystercl ark. com>, "I 110 Princeton Farmarket"
<1110 a roystercIark.com>
Mr. Hodge,
As a follow up to our discussion this morning concerning the permit application for the Crap Production
Services facility located in Princeton IdC, Tom Anderson and I will be available any time the weeks of January 7th
and 21st. We will let you pick the date that best fits your schedule. If these dates will not work,'let me know and we
will change our plans to suit your schedule. Also I want to thank you for allowing us an extension on the storm
water permit process until we have an opportunity to meet on site to come up with the best possible solution to
correct our runoff problem_ If you need to reach me by phone my office number is 800 628 2507 and cell is 434
917 3804.
Thanks,
Bill Coleman
I of 1 12/27/2007 1 1:25 AM

48
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Crop Production Services
Subject: Crop Production Services
From: Ken Pickle <[e-mail]>
Date: Wed, 20 Feb 2008 09:01:38 -0500
To: Bradley Bennett <[e-mail]>
CC: Al Hodge <[e-mail]>, Thom.edgerton@ncmail_net
Bradley,
The outcomes from yesterday's meeting at WARO are as follows:
a) Al will not yet initiate penalty assessments against the CPS, Wayne County site
for discharging stormwater without a permit. The issue of discharging wastewater
without a permit was tacitly dropped from discussion.
b) Discussions during the meeting indicated that CPS wanted to pursue no exposure.*
CPS committed to the schedule of NLT Friday 3/7/08, CPS will submit to SPU a No 0
Exposure Certification package (3 copies - SPU, WARD, return to CPS). The package
will include the 5 page NCGNE form**, a site map, and a narrative description of the
measures to be taken to achieve no exposure. Al was emphatic that CPS not miss the
deadline, since they had been granted an extension on the first deadline, and not
made sufficient response to the second deadline.
CZD
c) SPU and WARO will review the proposal and either accept it or request additional
measures. WARO and/or SPU may be requested to visit the site to specifically
identify all areas of exposure, to be sure that CPS does not overlook any in the
preparation of their submittal.
d) Upon DWQ acceptance of the eventual final proposal, CPS will construct and
implement the physical improvements necessary to achieve no exposure. Our acceptance
(^ of the elements of the final proposal will be documented by returning the third copy
of the submittal package to CPS with some sort of stamp or approval notation by SPU.
Upon confirmation by WARO and/or SPU that the site has indeed achieved no exposure,
SPU will issue the no exposure exclusion from permitting.
*This appeared to be the outcome that most suited CPS, and WARD. I concur that this
is the best outcome. - - However, I noted in the meeting that we will have sharp eyes
in evaluating whether or not no --exposure conditions are actually achieved. An
individual permit seemed immediately problematic to both CPS and WARO, and I concur
(achieving no exposure may also be problematic, but that is the course they have
chosen, apparently as the less difficult one.)
** Al, as I think about it now, I think that we should instruct CPS to submit the
first No Exposure Certification filled out, but unsigned in the first submittal.
They really can't "certify no exposure" until they complete the proposed measures.
But I think it will be instructive for them to fill out the form at the earliest
possible time, so that they can better understand what we will consider as
constituting no exposure. So, I imagine it happens like this: they fill it out
unsigned, submit it with the site drawing and narrative, after some number of
iterations we eventually receive and accept a final proposal, they implement the
physical changes, then they resubmit the NCGNE form with signature, and then we grant
the no exposure exclusion from permitting.
Refresher: in terms of the typical SPU formal procedure on no exposure:
- Typically, first the industrial site 'certifies' to DWQ that there is no exposure
to stormwater on the site. This is called the "Certification of No Exposure."
- Then typically, if DWQ RO concurs that no exposure conditions exist at the site,
SPU issues the no exposure "Exclusion from Permitting." with the result that the
facility does not have to get our stormwater permit _ but they have to maintain no
I of 2 2/20/2008 9:11 AM

Crop Production Scrvices
exposure conditions at the facility.
- In the present case of CPS we have stretched the normal sequence to include a
preliminary submittal for our review, since we have an NOV history, and potential for
assessment, and since we are uncertain that these guys will get it right on the first
try.
Ken
2 of 2 2/20/2008 9:1 1 AM

March 5, 2008
201 Society Ave.
Hartsville, Sc 29550
Mr. Al Hodge
NCDENR
Division of Water Quality
943 Washington Square Mall
Washington, NC 27889
Dear Mr. Hodge:
This letter is in response to the Notice of Violation letter that I received on November 19,
2007 in regards to the inspection that was conducted at the Princeton, NC facility located
in Wayne County. On October 2, 2007 Mr. Warren and Mr. Pickle visited the site and
noticed some violations in regards to NC General Statutes and the NC Administrative
Codes, these were discharging storm water from the site without a permit and generating
process wastewater from product storage areas on site.
On February 19, 2008 we met with you, Ken Pickle, and Thom Edgerton at the NCDENR
Washington Regional office to discuss these violations and the minimal response from
Crop Production Services in regards to these violations. During the discussion it was
determined that the Crop Production Services facility located in Princeton, NC is going to
pursue a No Exposure Certification from the state of North Carolina through the
Department Water Quality office in Raleigh, NC.
1 was given a No Exposure Certification application while at your office as well as the
direction from you and Mr. Pickle on what is needed for submittal from the facility along
with the application. The attached document describes in detail how and what the facility
is going to do in order to obtain a No Exposure Certification.
If you should have any questions in regards to our approach, please do not hesitate to
give me a call and I will be glad to discuss or modify the plan to obtain No Exposure for
any rainfall at the facility.
Thanks in advance, .
Thomas C. Anderson
Compliance Manager
Crop Production Services

crop
Production
Services
March 5, 2008
Crop Production Services
201 Society Ave.
Hartsville, SC 29550
Ken Pickle
NCDENR
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Ken Pickle:
I appreciate the opportunity that your office gave us to state our case in regards to the
storm water violations at the Crop Production Services facility located in Princeton, NC.
I also had a clear understanding after the meeting at the NCDENR regional office in
Washington, NC on February 19, 2008 of what I needed to submit to your office in order
to obtain a No Exposure Certification for storm water discharge at the Princeton location.
The following report indicates the areas at the facility that have potential storm water
impact and how the facility is currently handling or plans to have no exposure in regards
to processes or materials stored at the facility during a rainfall event.
I have identified eleven areas, see attached map, around the facility that have potential
impact to storm water discharge during a rainfall event. I will explain what takes place in
each of these areas and how the areas are protected against rainfall or what is done or is
going to be done to eliminate storm water runoff.
Area 1 : This is a shop area located in the southwest corner of the main building. Only
'K minor maintenance on the vehicles takes place in this area. Prior to any oil changes
taking place on the vehicles they are pulled completely into the chemical building on the
concrete floor. The used oil is stored in a double walled containment unit placed in the
center of the shop away from the door opening. The used oil is transported by Safety
Kleen and taken to an EPA approved recycler. The shipping manifests are available in the
manager's office.
or Area 2: This is the empty bulk chemical shuttle tank storage area. The shuttle tanks are
scaled, and inspected for leaks, cracks, and any defects prior to storage in this area. Any
visible residue apparent on the tanks is washed off in the bulk chemical load out area and
• C�n'� dr n
kt�� agronomically land applied.

4
a Area 3: This is the bulk chemical storage tanks. The tanks are located within secondary
containment. Any rain fall that collects in the containment area is inspected for sheen,
odor, and any visible spillage that may have occurred from the pump. The storm water
that is collected from this area along with the load out pad adjacent to the secondary
containment is collected and agronomically land applied through an applicator rig.
Area 4: This is the liquid nitrogen containment area. There are presently four storage
tanks within the containment area that store 24S, 28 %, and 10-34-0. Any rain water that
is collected in the containment area is inspected for sheen and odor and tested with nitrate
test strips. The test strips are obtained from a third party supplier and stored in the
refrigerator as indicated on the test strip bottle. The containment water is checked with a
test strip for any nitrate levels. if there is any indication on the test strip due to a color
change, this indicates that nitrates are present in the storm water and the water is pumped
to a temporary storage tank to be agronomically land applied. Should there be no
indication of nitrates present in the rain water; the rain water is pumped out of the
�2 containment area onto the surface soil. The same process is completed for the load out
st 4j pad area adjacent to the nitrogen tank containment area. The load out pad is also used as a
'�° wash off site for the trucks.
n� U Sub note: Any water collected in area 3 or 4 is documented on a company form. See
attachment A. Also, all employees at this faculty are required to attend annual safety
training in regards to Storm Water Discharge.
Area 5: This is the railcar unloading area. This area is used to unload various nutrient
' containing materials used in the blending process and conveyed into the main dry storage
building. There is one employee at the facility assigned to unload rail cars. The bottom
hopper doors are opened and the material flows onto a covered rail conveyor which feeds
into an elevator. At one time there was a concrete slap in this area but the railroad made
the facility tear it up. The plan is to place a steel plate on each side of the conveyor feed
in point so that any residue can be swept up. Residual product will be taken and placed in
the bulk fertilizer storage bins inside the main dry storage building. Projected time frame
for completion: April 2, 2008
Area 6: This is the blended fertilizer discharge. 1n this area trucks pull under a load out
conveyor and any material or fertilizer that was blended inside the bulk fertilizer storage
►P building is discharged through this covered incline conveyor. There is also a bulk blender
located on the outside of the building that is used minimally when the facility is in the
busiest time of the year or the inside blender would be in need of repair.
Any spillage that would take place around the blender and the discharge points is swept
up and best management practices are followed.
The trucks are parked on a concrete slab and any residual product that may fall off the
conveyor is swept up at the end of each days use and placed back into the dry fertilizer
storage building.
*Sub note: Areas 5 & 6, all employees at the facility are required to complete
housekeeping training and are instructed on best management practices for any residual
spillage in or around the facility.

��. Area 7: This is the northeast corner of the main fertilizer storage building. This part of
the building is in need of repair due to the fact that the metal siding the building is
constructed of has deteriorated over time and is currently in the process of being torn
down and replaced with siding that will not allow residual discharge through the wall to
the outside of the building. Projected completion date of this project is June 30, 2008.
Area 8: This is the fuel tank storage area. There is currently a 480 gallon gasoline tank
and a 250 gallon off road diesel tank located in this area. The tanks are not located within
secondary containment but any refueling of mobile equipment is conducted over a
concrete pad. Any residual spillage that may occur on the pad is cleaned up with oil
absorbent material and is properly disposed of in a waste container. The tanks are
inspected oil a monthly basis per CPS monthly checklist and placed in a file in the facility
manager's office. Please see attachment B.
y Area 9: This is the outside bulk storage bins. The materials that were noted on a previous
inspection, such as ammonit1111 sulfate and tailings, are no longer stored in these outside
bins. Tile material has been moved inside into the main bulk fertilizer storage building.
The only products that will be stored in these outside bins are non nutrient producing
products, such as granular limestone or filler. The limestone filler does not produce any
hydroscopic elements that can discharge to the concrete pad located in front of the
storage bins for release into the storm water run off. On the east end of the pad in front of
the bays, there is a door leaving the main bulk storage building. Any residual material
from the loader tires that gets on the pad in this area is scooped and swept up and placed
back in the main dry building.
Area 10: This area is located on the east end of the facility between the end of the
buildings and the property line, which is a ditch that runs from north to south. The ditch
currently collects the rain water discharge from this end of the facility. This area is
currently over seeded with oats, which is not adequate for soil retention. The plan is to
bring in some fill dirt, level the area, and over seed with fescue grass. This grass is a good
source for nutrient uptake from the soil and will also aid in minimizing soil erosion. The
grass area will be maintained and cut and then will be considered as a sheet run off area
at this end of the facility. Projected completion date is April 2, 2008 dependant on the
weather.
J Area 11: This is the dolomite lime storage area. The facility currently receives the
majority of its lime in during the months of August and September by rail cars. This is
due to the shortage of material during peak season. The material they use for the peak
season must be received and stored ahead of time due to lack of available rail cars. Tile
pile during the peak season is approximately 200 feet long, 60 feet wide, and 12 feet
high. In order to achieve a No Exposure from rain fall to the lime pile it will be covered
with a 200 lb / in. poly cover (see attached sheets) that will be secured around the entire
perimeter of the pile and along the top. Only the areas of the pile that will be in current
use for shipments will be uncovered during the day it is being used. At the end of each
day, the tarp will be inspected for securemcnt to prevent any rain fall from contacting the
lime. The projected date for completion of obtaining the cover and securement equipment
will be dependant on completion of the order since the cover will have to be special
ordered due to the size that is needed. The plan is to order the covers in 50' x 100' sizes
and enough of them to cover the entire pile during the peak season.

I feel that I have adequately covered ali storm water exposure areas throughout the
facility and have listed any plans that we may have for preventative measures to be taken
for no exposure. If you should have any other areas of concern about the facility or need
any additional information in regards to these areas, please do not hesitate to contact nie
via phone or email.
In closing I Would like to thank you for your assistance and your direction in how we
may be able to obtain a No Exposure Certification for the Princeton, NC facility.
Slncerely,
G,
Thomas C. Anderson
Compliance Manager
Crop Production Services
Enclosed Attachments:
No Exposure Certification
Maps — Google Aerial and facility
Attachment A — CI'S Storm water Discharge Inspection Form
Attachment B — CPS Monthly Checklist Inspection
Attachment C — Lime pile Cover spec sheets
cc: Collinsville Office
Al Hodge

AIN1.1MA
it,Division of Water Quality / Surface Water Protection
NCDENRNational Pollutant Discharge Elimination System
MORN G�U_DC%' -EME NO EXPOSURE CERTIFICATION for Exclusion
�YInp1MEM .wo N.uunK Rcso�ncce
NCGNE0000
NO EXPOSURE CERTIFICATION
FOR AGENCY USE ONLY
Dale Received
Year
Month
Da
Certificate of Coverage
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit
based on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notice that your facility does not require permit
authorization for its stormwater discharges associated with industrial activity in the State of North
Carolina because it qualifies for a no exposure exclusion. A condition of no exposure at an industrial
facility means all industrial materials and activities are protected by a storm resistant shelter (with some
exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff.
industrial materials or activities include, but are not limited to: material handling equipment or activities,
Industrial machinery, raw materials, intermediate products, by-products, final products, or waste
products. Material handling activities include the storage, loading and unloading, transportation, or
conveyance of any raw material, intermediate product, final product or waste product. A storm resistant
shelter is not required for the following industrial materials and activities: drums, barrels, tanks, and
similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak.
"Sealed" means banded or otherwise secured and with locked or non -operational taps or valves;
adequately maintained vehicles used in material handling; and final products, other than products that
would be mobilized in stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion.
in addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for
individual outfalls. if any industrial activities or materials are, or will be, exposed to precipitation, the
facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure
Certification form, you certify that a condition of no exposure exists at this facility or site and are
obligated to comply with the terms and conditions of 40 CFR 122.26(g).
You are required to reapply for the No Exposure Exclusion once every five (5) years.
For questions, please contact the DWO Regional Office for your area. (See page 5)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed}:
Name er,,ti,d IrOelue_14 04 5eryfc.15S
Street Address _ /, Fxezu air- Dcfyr-
City Csr. /,&25t/i%k-. State ; L ZIP Code g:z.'r i
Telephone No. __b/a _ 3Y,, Fax: fa/9 3Y6 •- 7VS/
2) Location of facility producing discharge:
Facility Name L�-�3_ 6,2d e i vet se-tL,rcEs rincef/art Z4 2
Facility Contact 06I) i C Wi sgs , �A��ge,-
__.
Street Address /5i/ 1,io /&a/
City Pr4cAfvV7 State, J�C ^_ZIP Code 275-69
CountyG(,/,9T�
Telephone No. D9 _ `%3r ?OD Fax: 7i17 9� 5�� 23
Page 1 of 5
SWU-NE-110607 Last revised 11/06/07

NCGNE0000 No Exposure Certification
3) Physical location information:
Please provide a narrative description of how to get.to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). _,64-vsr 7O E,ns� oG �rintc%�s/- 'uses
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes X No
5) Is this a Federal facility? ❑ Yes X No
6) Latitude �s. Longitude (deg, min, sec)
7) This NPDES Permit Application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
X Existing Date operation began I qeo 3
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes JKNo
If yes, what is the NPDES Permit Number?,
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: !� / V /
10) Provide a brief description of the types 1of industrial activities and products produced at this facility:
I�etr b7aiL bleriI )nq ope_y-a- or
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
}-No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
c. Materials or products from past industrial activity
d. Material handling equipment (except adequately maintained vehicles)
e. Materials or products during loading/unloading or transporting activities
I. Materials or products stored outdoors (except final products intended for outside
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
❑ Yes XNo
0 Yes 4 No
❑ Yes ;; No
Cl Yes )K No
❑ Yes KNo
❑ Yes X No
Page 2 of 5
SWU-NE-110607 Last revised 11/06/07

NCGNE0000 No Exposure Certification
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes kNo
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes kNo
the discharger
i. Waste material (except waste in covered, non -leaking containers (e.g., dumpsters]) ❑ Yes kNo
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes )(No
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes kNo
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored ❑ Yes )(No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes No
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not .
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or 9Yes 0 No
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any 19 Yes ❑ No
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers I Yes ❑ No
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for 2ny amount of Title III Section 313
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals?
d. Is secondary containment provided for �!ny amount of hazardous substances?
e. Are release valves on all secondary containment structures locked?
Z Yes ❑ No
X Yes ❑ No
g Yes ❑ No
Xl Yes ❑ No
Page 3 of 5
SWU-NE-110607 Last revised 11/06/07

NCGNEOOOO No Exposure Certification
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes . KNo
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste ❑ Yes ANo
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes 0 No
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport I disposal vendor:
Vendor address:
16) Certification:
I certify under penalty of law that I have read and understand the eligibility,requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to submit a no exposure certification form once every five (5) years to the North Carolina
Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into
which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water
Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request -
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty
of law that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
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.
Name of Person Signing: r '
ture of Applicant)
-,-,2 %d F
(Date Signed)
Page 4 of 5
SWU-NE-t 10607 Last revised 11/06/07

NCGNE0000 No Exposure Certification
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
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).
There is currently no fee for a No Exposure Exclusion.
Final Checklist
This application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWO Regional Office for your area.
DWQ Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
733-5083
Page 5 of 5
SWU-NE-110607 Last revised 11/06/07

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Bulk 7
Fertilizer
!Squid
Nitrogen
•Y
tlquld
Nitrogen
3
Bulk
Chemi�l
buby Smith Road
Crop Production Services 242 Reri,ad: code:
141 L.uby Srmittl Road
Princeton, NC 27569 12/06/06 18920
919-735-8600

STORM WATER DISCHARGE INSPECTION REPORT
Date Inspected Containment Area & Sump Nitrate Test Results Method of Disposal
B Inspected PPM
F.

,4 A
Appendix A
'tJJ� E R rl /���
AGRIUM RETAIL V
MONTHLY INSPECTION REPORT P►SerVi eS
Services
FARM SERVICE
JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC YEAR
Facility
Inspector's Signature:
Date:
Monthtynspections Itemfsl
0",Corrective Measures Required and Cornments
Date Actions Completed
Emergency Eye Wash/Safety Showers
(weekly inspection req.)
Week 1
Week 2 Week 3 Week a
Emergency Respirators/SCBA's
Facility Lighting & Security Signs)
Fire Extinguishers (All locations & mobile
equipment)
First Aid Kits (complete & sanitary)
Guards & Covers (in -plant equipment)
Hoist Cable & Chain, ManliR Equipment
House Keeping/Overall Facility
Appearance (lot graded)
Lockout(Tagout Equipment
PPE (gloves, goggles, respirators)
Spill Kits
Chemical Warehouse (clean, organized)
DryFertilizer Warehouse, Storage Bins,
MixiBlend Areas, Pads
Hazardous Waste Storage Areas (weekly
inspection required)
week f
week z
T_
weeks
week 3
Liquid Fertilizer Tanks, Containment,
Mix/Blend Areas, Pads
Liquid Pesticide Tanks, Containment,
Mix/Blend Areas, Pads
NH3 Facility (paint, plumbing, condition etc.)
Use separate form more detailed inspections if required by
your staleRocal requirements
Seed Warehouse
Used Oil Storage Area
(Scheduled Inspections
Application Equipment
Decontamination Kits
Dry Buggies, Liquid Trailers, etc.
Electrical (condition of boxes, wiring and
cords)
NH3 Wagons, Nurse Tanks & Mobile
Equipment (paint, condition, etc)
Nurse Trucks & Pickups
INSTRUCTIONS: Complete all applicable sections of the forms and return a copy (both sides) to Asmark with your monthly training. weekly inspections
are to be documented on the original form that is kept on file at the facility.
136

Appendix B
MONTHLY INSPECTION
A walk around of facility to determine status of monthly inspection items_ Walk -around to take inspection team through the following areas:
(1) Office, (2)Shop, (3) Chemical Warehouse, (4) Dry Fertilizer Storage, (5) Liquid Fertilizer Tank Farm(s), (6) Pesticide Tank Farm(s), (7) Seed
Warehouse and (8) Yard.
MONTHLY ROUTINE INSPECTION ITEMS
EMERGENCY EYE WASHES & SHOWERS - Suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the
work area for immediate emergency use, where the eyes or body of any person may be exposed to injurious corrosive material. Such situations
include using or handling in open containers corrosive liquids in quantities of one gallon or more, filling or withdrawing a corrosive liquid from a
container of 5 gallons or more in size or loading and unloading corrosive liquid from tank cars or tank truck
EMERGENCY RESPIRATORS & EQUIPMENT - Stationa[y NH3 Stgraae shouldhave: Two NH3 gas masks w/spare canisters, NH3 gloves, gog-
gles, face shield, rubber boots, one protective sticker or protective pants and jacket, fire extinguisher 40 BC rated, working shower and eye wash.
Mobile NH3 Storage should have: One NH3 gas mask with spare canister, goggles, face shield, NH3 gloves, fire extinguisher 20 BC rated, 50 gal-
lons fresh water. yehicle TranAportino NH3 should have, Goggles, face shield, NH3 gloves, fire extinguisher rated 20 BC, 5 gallons fresh water, if
transporting over 1200 gal. must have NH 3 gas mask: Emergency respirators shall be stored in a clean, dry and sanitary location and thoroughly
inspected at least once a month and after each use; a record of inspection dates and findings shall be maintained with the emergency respirators.
FACILITY LIGHTING & SECURITY SIGNS -Emergency notification signs are current, condition of fences & gates
FIRE EXTINGUISHERS - Unit tops not over 5 ft. from floor, if over 40 lbs. 3-1I2 ft. from floor, free access to units, unit locations marked, annual
maintenance performed and tag on unit, fire extinguishers in their proper place and have not been actuated or tampered with, extinguishers free of
obvious damage, corrosion or other impairment.
FIRST AID KITS- complete and in proper place, first aid cabinets properly labeled
GUARDS & COVERS (In Plant Equipment)- PTO guards in place; motor coupling guards in place; screw conveyor covers in place; rotating shafts
ends and collars guarded. Grinder work rests adjustable and within 118" of wheel; bench and floor grinding wheel exposure should not exceed 90"
or 1/4 the periphery and shall not begin more than 65' above the horizontal; safety guards on "side arm" portable grinders shall not expose more
than 180* of the wheel; flywheels, clutches, V-belts, pulleys, sprockets, chains, etc. which are 7 feet or less above floor or other working level shall
by guarded; shaft ends within 7 feet of working level shall be smooth and rounded and, if projecting more than 1-112 times the shaft diameter
beyond end of bearing, shall be guarded. During repair, equipment shall be effectively blocked or otherwise secured to prevent inadvertent move-
ments that could cause injury
HOIST CABLE & CHAIN, MANLIFT EQUIPMENT - Load capacity signs in place; cable, rope and chain free of weak spats; three U-bolts on cable
ends; safety latch type hooks used; hydraulic lines and hose free of damaged or warn spots.
HOUSEKEEPINGIOVERALL FACILITY APPEARANCE - Restroom and shower facilities clean and equipped: areas free of trash, shop areas
clean, floors free of oil and grease. Tools not in use are properly placed. Tank equipment in good condition. All areas free of weeds, waste and fire
hazards. Emptied containers, pallets in designated areas. Containers labeled. Perimeter berms, curbs and controlled release points well main-
tained; Yard surfaces free of spill and waste material contamination.
LOCKOUT/TAGOUT EQUIPMENT - Individual locks and tags are available and readily accessible in designated area.
PERSONAL PROTECTIVE EQUIPMENT -(gloves, goggles, respirators etc.) During walk around check to see that employees are wearing
required ppe; safety goggles available at grinders and used; hard hats in use where required; hearing protection provided and used; NH3 face
shields and goggles available and used; protective clothing properly stored, respirators cleaned and disinfected regularly and properly stored;
assigned respirators should be cleaned after each day's use, those used by more than one worker shall be thoroughly cleaned and disinfected
after each use.
SPILL KITS - Are accessible and contents are clean and accessible, review checklist
CHEMICAL WAREHOUSE -Clean, organized, materials stacked straight; warning signs posted; No Smoking signs in place; all exits accessible
and marked; Flammable liquid storage main aisles 8 feet wide and side aisles 4 feet; approved containers used for Flammable and combustible liq-
uids; permanent aisles and passageways appropriately marked; aisles and passageways clear, clean and in good repair; truck and rail wheel
blocks and chocks available and used; forklift trucks have working horns and brakes, and have load capacity marked, and operated by trained
drivers; unattended forklift trucks shall have forks lowered, controls in neutral, power off, brakes set. Toxic material spills cleaned up and area
decontaminated, Spill clean up and decontamination supplies available.
DRY FERTILIZER WAREHOUSE, STORAGE BINS, MIXIBLEND AREAS, PADS - Mixing area is clean and swept daily, load out pad is clean and
swept daily; shafts, gears and belts guarded.
HAZARDOUS WASTE STORAGE AREAS - Containers labeled. Logs maintained to identify Contents accumulated in bulk hazardous waste stor-
age facilities.
LIQUID FERTILIZER TANKS, CONTAINMENT, MIXIBLEND AREAS, PADS - Walls and floor are properly maintained (cracks repaired). Liners
(when present) are properly maintained. Piping and valves are free of leaks. Tanks labeled. Loading pads and sumps are properly maintained.
Transfer equipment in good condition. No spillage of product to unpaved areas, shafts, gears and belts guarded.
LIQUID PESTICIDE TANKS, CONTAINMENT, MIXIBLEND AREAS, PADS - Walls and floor are properly maintained (cracks repaired), Piping and
valves are free of leaks. Tanks Labeled. Loading pads and sumps are properly maintained. Transfer equipment in good condition, no spillage of
product to unpaved areas of facility. Wash, recycle, and holding tank equipment in good condition.
NH3 FACILITY - Replace 6 year old high pressure hose; Inspect all other hose and connections; NH3 liquid pumps and compressors should have
working suction and discharge pressure gauges; NH3 tank valves not damaged; NH3 pressure gauges and liquid level gauges in working order;
Tank shell free of dents, gouges, bulges or bad corrosion; Relief valves replaced every 5 years; Tanks properly marked and placarded and paint-
ed. Valves and pipelines color coded; Tank car connected signs available and used.
SEED WAREHOUSE - clean, organized, materials stacked straight, all exits accessible and marked
USED OIL STORAGE AREA - container in good condition and not leaking, labeled "Used Oil", no evidence of spills, area housekeeping good.
SCHEDULED INSPECTIONS -
APPLICATION EQUIPMENT - no Guttered floors, trash, seat and dash dean, exterior clean, no excess greaseloil, no spillage to soil, name & logo
DECONTAMINATION KITS - clean, gloves, goggles, soap, change of clothing
DRY BUGGIES, LIQUID TRAILERS ETC - Clean, SMV signs if applicable, shaft, gears, belts guarded, tanklbox good condition,
ELECTRICAL Panel controls labeled; Covers on all boxes and knockouts plugged; Equipment lockouts available and used. All motors connected
with fixed wiring; Panels have 30" clear space; Automatic start equipment warning sign in place; Extension cords free of splices and grounded;
Portable tools grounded; Conduit in good condition and properly supported. Lock, block, and tag out procedures established and enforced.
NH3 WAGONS, NURSE TANKS and mobile equipment - wheels, tires, hitch condition, safety chains, required markings, tank condition, SMV if
applicable, guarding
NURSE TRUCKS & PICKUPS - Exteriors clean, washed, interiors clean, no trash, required documents, logo when required, equipment safety
check, no fluid leaks
137

Inland Plastics Inc.
- ..
Page 1 of 2
W %� e,
PRODUCTS a FARM TARPS s MAY TARPS
Heavy Duty Hay Covers for Round
and Square Bales
Rawntaa _Irto_�L qt_ l�QJ
$liver on the outside to reflect light, black on the inside to
prevent greenhousing. Super tough 6.1 ot/sq, yd, UVI treated
coated fabric gives 3-5 years of use. Eyelets and webbing set into
five layers of Fabric, giving about 500 lbs. of pull strength.
Specifications;
Heavy reinforced super tough poly fabric has 200 lb./In, tensile
strength. Speclal treatment for outdoor life, Beware of Inferior
fabrics.
Rope Is encased In the hem and a spur eyelet Is set Into No
layers of material to glve 500 Ibs. of pull per eyelet. Webbing
gives 535 Ibs. per loop strength.
Silver/Grey on outside to reflect Ihght and Black on the Inside to
preventgreenhousing.
Versatile hem is designed for both pipe insertion and other
conventional systems like rope, spiral, pins, etc. See
"Suggested Tie Down Methods"
7 P r
Ws" DKI.r usr- ff"CK Twos -An
FOR o rrrr-P UVr 9r1.;tSTANCr?
iDOp Ie/
Loop Systemf
Large IT
comior Gussef
OVER I= fbs
OF Pu tl
Horne I News I About us I Por Retailers I Contact
"Save the cost of the cover
in the first year..."
-George McBain, Cremona
AB
RCLATiED PRODUCTS
Hay Tarps
Temporary Harvest
Farm Truck Tarp
Inners
Misc. Farm Tarps
bttp://www.iiila-ndt)lasfies.coj*famtart)s/hav/ 1,+,z 11 nnsz

Wand Plastics Inc,
Page 2 of 2
Standard Sizes
12x60
15x54
18x48
20 x 48
25 x 33
23 x 48
25 x 48
28 x 48
33 x 48
30 x 54
Hay tarp accessories
Spiral Anchor Pins are ideal For attaching the cover firmly to the
hay stack.
Custom
COPYF19ht 11'11and VI�yStics, 2006. Webslte ny BC DesfgnWOcitU
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Grog
Production
Services
March 5, 2008
Crop Production Services
201 Society Ave.
Hartsville, SC 29550
Ken Pickle
Z
NCDENR
-a
1617 Mail Service Center
a`
Raleigh, NC 27699-1617g
�
o°
Dear Ken Pickle:
I appreciate the opportunity that your office gave us to state our case in regards to the
storm water violations at the Crop Production Services facility located in Princeton, NC.
I also had a clear understanding after the meeting at the NCDENR regional office in
Washington, NC on February 19, 2008 of what I needed to submit to your office in order
to obtain a No Exposure Certification for storm water discharge at the Princeton location.
The following report indicates the areas at the facility that have potential storm water
impact and how the facility is currently handling or plans to have no exposure in regards
to processes or materials stored at the facility during a rainfall event.
I have identified eleven areas, see attached map, around the facility that have potential
impact to storm water discharge during a rainfall event. I will explain what takes place in
each of these areas and how the areas are protected against rainfall or what is done or is
going to be done to eliminate storm water runoff.
Area 1: This is a shop area located in the southwest corner of the main building. Only
minor maintenance on the vehicles takes place in this area. Prior to any oil changes
taking place on the vehicles they are pulled completely into the chemical building oil the
concrete floor. The used oil is stored in a double walled containment unit placed in the
center of the shop away from the door opening. The used oil is transported by Safety
Kleen and taken to an EPA approved recycler. The shipping manifests are available in the
manager's office.
Area 2: This is tale empty bulk chemical shuttle tank storage area. The shuttle tanks are
scaled, and inspected for leaks, cracks, and any defects prior to storage in this area. Any
visible residue apparent on the tanks is washed off in the bulk chemical load out area and
agronomically land applied.

Area 3: This is the bulk chemical storage tanks. The tanks are located within secondary
containment. Any rain fall that collects in the containment area is inspected -for sheen,
odor, and any visible spillage that may have occurred from the pump. The storm water
that is collected from this area along with the load out pad adjacent to the secondary
containment is collected and agronomically land applied through an applicator rig.
Area 4: This is the liquid nitrogen containment area. There are presently four storage
tanks within the containment area that store 24S, 28 %, and 10-34-0. Any rain water that
is collected in the containment area is inspected for sheen and odor and tested with nitrate
test strips. The test strips are obtained from a third party supplier and stored in the
refrigerator as indicated on the test strip bottle. The containment water is checked with a
test strip for any nitrate levels. If there is any indication on the test strip due to a color
change, this indicates that nitrates are present in the storm water and the water is pumped
to a temporary storage tank to be agronomically land applied. Should there be no
indication of nitrates present in the rain water; the rain water is pumped out of the
containment area onto the surface soil. The same process is completed for the load out
pad area adjacent to the nitrogen tank containment area. The load out pad is also used as a
wash off site for the trucks.
*Sub note: Any water collected in area 3 or 4 is documented on a company form. See
attachment A. Also, all employees at this faculty are required to attend annual safety
training in regards to Storm Water Discharge.
Area S: This is the railcar unloading area. This area is used to unload various nutrient
containing materials used in the blending process and conveyed into the main dry storage
building. There is one employee at the facility assigned to unload rail cars. The bottom
hopper doors are opened and the material flows'onto a covered rail conveyor which feeds
into an elevator. At one there was a concrete slap in this area but the railroad made
the facility tear it up. The plan is to place a steel plate on each side of the conveyor feed
in point so that any residue can be swept up. Residual product will be taken and placed in
the bulk fertilizer storage bins inside the main dry storage building. Projected time frame
for completion: April 2, 2008
Area G: This is the'blended fertiiizer discharge. In this area trucks pull under a load out
conveyor- and any material or fertilizer that was blended inside the bulk fertilizer storage
building i.s discharged through this covered incline conveyor. There is also a bulk blender
located on the outside of the building that is used minimally when the facility is in the
busiest time of the year, or the'inside blender would be in need of repair.
Ariy spillage that would take place around the blender and the discharge points -is swept
up and best management -practices are followed:
The tilicks are parked on a concrete slab and any residual product that may fall' off the
conveyor is swept up at the end of each days use and placed back into the dry fertilizer
storage building.
*Sub note: Areas 5 & &, all employees at the facility are required to complete .
hbusekeeping training and are instructed on best management practices fof any residual
spillage in or around the facility.

Area 7: This is .the northeast corner of -the main fertilizer storage building. This part of
the building is in need of repair due to the fact that the metal siding the building is
constructed of has deteriorated over time and is currently in the process of being torn
down and replaced with siding that will not allow residual discharge through, the wall to
the outside of the building. Projected completion date of this project is June 30, 2008.
Area 8: This is the fuel tank storage -area. There is currently a 480 gallon gasoline tank
and a 250 gallon off road diesel tank located in this area. The tanks are not located within
secondary containment but any refueling of mobile equipment is conducted over a
concrete pad. Any residual spillage that may occur on the pad is cleaned up with oil
absorbent material and is properly disposed of in a waste container. The tanks are
inspected on a monthly basis per CPS monthly checklist and placed in a file in the facility
manager's office. Please see attachment B.
Area 9: This is the outside bulk storage bins. The materials that were noted on a previous
inspection, such as ammonium sulfate and tailings, are no longer stored in these outside
bins. The material has been moved inside into the main bulk fertilizer storage building.
The only products that will be stored in these outside bins are non nutrient producing
products, such as granular limestone'or filler. The limestone filler does not produce any
hydroscopic elements that can discharge to the concrete pad located in front of the
storage bins for release into the storm water run off. On the east end of the pad in front of
the bays, there is a door leaving the main bulk storage building. Any residual material
from the loader tires that gets on the pad in this area is scooped and swept up and placed
back in the main dry building.
Area 10: This area is located on the east end of the facility between the end of the
buildings and the property line, which is a ditch that runs from north to south. The ditch
currently collects the rain water discharge from this end of the facility. This area is
currently over seeded with oats, which is not adequate for soil retention_ The plan is to
bring in some fill dirt, level the area, and over seed with fescue grass. This grass is a good
source for nutrient uptake from the soil and will also aid in minimizing soil erosion. The
grass area will be maintained and cut and then will be considered as a sheet run off area
.at this end of the facility. Projected completion date is April 2, 2008 dependant on the
weather.
Area 11: This is the dolomite lime storage area. The facility currently receives the
majority of its lime in during the months of August and September by rail cars. This is
due to -the 'shortage of material during peak season. The material they use for the peak
season must be received and stored ahead of time due to lack of available rail cars. The
pile during the peak season is approximately 200 feet long, 60 feet wide, and 12 feet
high. In order'to achieve a No Exposure from rain fall to the lime pile it will be covered
with a 200 lb J in. poly cover (see attached sheets) that will be secured around the entire
perimeter of the pile and along the top. Only the areas of the pile that will be in current
use for shipments will be uncovered during the day it is being used. At the end of each
day, the tarp will be inspected for seeurement to prevent any rain fall from contacting the
lime. The projected'date for completion of obtaining the cover and securement equipment
will be dependant on completion of the order since the cover will have to be special
ordered due to the size that is needed. The plan is to order the covers in 50' x 100' sizes
and enough of there to cover the entire pile during the peak season.

I feel that I have adequately covered all storm water exposure areas throughout the
facility and have listed any plans that we may have for preventative measurds t© be taken
for no exposure. If you should have any other areas of concern about the facility or need
any additional information in regards to these areas, please do not hesitate to contact me
via phone or email.
In closing I would like to thank you for your assistance and your direction in how we
may be able to obtain a No Exposure Certification for the Princeton, NC facility.
Sincerely,
Thomas C. Anderson
Compliance Manager
Crop Production Services
Enclosed Attachments:
No Exposure Certification
Maps — Google Aerial and facility
Attachment A -- CPS Storin water Discharge Inspection Form
Attachment B — CPS Monthly Checklist Inspection
Attachment C — Lime pile Cover spec sheets
cc: Collinsville Office
Al Hodge

Division of Water Quality 1 Surface Water Protection
,w. r
National Pollutant Discharge Elimination System
NCDENR
N„ C Aw- t>�.,9� a NO EXPOSURE CERTIFIC, ITION for Exclusion
t .,m ..rHr —0 N� ft3oU4cE3 .
NCGNE0000
NO EXPOSURE CERTIFICATION
FOP AGENCY USE ONLY
Date Received
Year Month
Da
Certificate of Coverage
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit
based on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notice that your facility does not require permit
authorization for its stormwater discharges associated with industrial activity in the State of North
Carolina because it qualifies for a no exposure exclusion. A condition of no exposure at an industrial
facility means all industrial materials and activities are protected by a storm resistant shelter (with some
exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste
products. Material handling activities include the storage, loading and unloading, transportation, or
conveyance of any raw material, Intermediate product, finalproduct or waste product. A storm resistant
shelter is not required for the following industrial materials and activities. drums, barrels, tanks, and
similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak.
"Sealed" means banded or otherwise secured and with locked or non -operational taps or valves;
adequately maintained vehicles used in material handling; and final products, other than products that
would be mobilized in stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion.
In addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for
Individual outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the
facility is not eligible for the'no exposure exclusion. By signing and submitting this No Exposure
Certification form, you certify that a condition of no exposure exists at this facility or site and are
obligated to comply with the terms and conditions of 40 CFR 122.26(g).
You are re uired to reapply for the No Exposure Exclusion once evety five 5 ears.
For questions, please contact the DWO Regional Office for your area. (See page 5)
(Please print or type)
1) Mailing address of ownerloperator (address to which all certification correspondence will be mailed):
Name
Street Address
City
Telephone No.
err
611c2srt & _ State ;Cl- ZIP Code (v223y
1, 3Y6 ,7Yg5 _ Fax: &;,5-
2) Location of facility producing discharge:
Facility Name ell'° ► ,� 6� e-fiaie-5�rvfG—o-s ee-A> ► ZLf 2-
Facility Contact
Street Address
City
County
Telephone No.
PtlnfA_ fair State AIC ZIP Code 275;- T
Fax:
Page 1 of 5
SWU-NE-110607 Last revised 11/ SW

NCGNE0000 No Exposure Certification
3) Physical location information:
Please provide a narrative description of how to get.to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). 7 E�rt v rr_ �'�1,�t oN us A as
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes ,� No
5) Is this a Federal facility? ❑ Yes XNo
6) Latitude 557.�A7.3� Longitude — 79. 08122 (deg, min, sec)
7) This NPDES Permit Application applies to which of the following;
❑ New or Proposed Facility Date operation is to begin
X Existing Date operation began 1363
8) Was this facility or site ever Covered under an NPDES Stormwater Permit? El Yes JXNo
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification -
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: %
10) Provide a brief description of the types of industrial activities and products produced at this facility:
Fri n o arm -t?-
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
KN o
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
c. Materials or products from past industrial activity
d. Material handling equipment (except adequately maintained vehicles)
e. Materials or products during loading/unloading or transporting activities
f. Materials or products stored outdoors (except final products intended for outside
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
C Yes $,No
❑ Yes 4 No
❑ Yes No
C] Yes No
❑ Yes X No
❑ Yes X No
Page 2 of 5
SWU-NE-110607 Last revised 11/06/07

NCGNE0000 No Exposure Certification'.'
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks', ❑ Yes .(No
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes *No
the discharger
I. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) D Yes kNo
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes XNo
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not I❑ Yes kNo
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored' ❑ Yes *No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes VNo
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not .
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or Af Yes it No
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any 19 Yes © No
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers
J� Yes ElNo
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. is secondary containment provided for above ground storage containers stored
Yes ❑ No
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. is secondary containment provided for any amount of Title III Section 313
X Yes ❑ No
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals?
d. Is secondary containment provided for any amount of hazardous substances?
g Yes ❑ No
e. Are release valves on all secondary containment structures locked? 54 Yes ❑ No
Page 3 of 5
SWU-NE-110607 Last revised 11/06/07

NCGNE0000 No Exposure Certification
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑-Yes ,KNo
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste ❑ Yes KNo
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes k( No
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored: _
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
16) Certification:
I certify under penalty of law that I have read and understand the eligibility.requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to submit a no exposure certification form once every five (5) years to the North Carolina
Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into
which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water
Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty
of law that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
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.
0
Page 4 of 5
SWU•NE-110607 Last revised 11/06/07

NCGNE0000 No Exposure Certification
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to .Issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
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 flied or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material tact in a rulemaking proceeding or contested casa 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).
There is currently no fee for a No Exposure Exclusion.
Final Checklist
This application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWQ Regional Office for your area.
DWO Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...[phone]
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
733-5083
Page 5 of 5
SWU-NE-110607 Last revised 11/06/07

Bulk
Fertflizer
Uquld
Nitrogen
11clull
Nitrogen
Bulk
Chen-Licall
Crop Production Services 242 Revised: cc6e.'
141 Luby Smith Road
Princeton, NC 27569 12/06/06 �1� 18920
919-735-8800
71-

STORM WATER DISCHARGE INSPECTION REPORT
Date Inspected Containment Area & Sump Nitrate Test Results Method f Disposal
inspected PPM

Appendix A .
P "-H AGRIUM RETAIL
PMduction
MONTHLY INSPECTION REPORT Services
FARM SERVICE
JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV. DEC YEAR
Facility: _ Inspector's Signature:
Date:
Monthly I s ections Items
OK Corrective Measures Required and Comments
Date Actions Corn leted
Emergency Eye Wash/Safety Showers
(weekly inspection req.)
week 1 Week 2
Week 3 Week 4
Emergency Respirators/SCBA's
Facility Lighting & Security Signs)
Fire Extinguishers (All locations & mobile
equipment)
First Aid Kits (complete & sanitary)
Guards & Covers (in -plant equipment)
Hoist Cable & Chain, Marilift Equipment
House Keeping/Overall Facility
Appearance (lot graded)
Lockout/Fagout Equipment
PPE (gloves, goggles, respirators)
Spill Kits
Chemical Warehouse (clean, organized)
Dry Fertilizer Warehouse, Storage Bins,
Mix/Blend Areas, Pads
Hazardous Waste Storage Areas {weekly
inspection required)
week 1
Week 2 Week 3
Week 3
Liquid Fertilizer Tanks, Containment,
Mix/Blend Areas, Pads
Liquid Pesticide Tanks, Containment,
Mix/Blend Areas, Pads
NH3 Facility (paint, plumbing, condition etc.)
Use separate form more detailed Irupoctions if regLrmd by
your slateftca! requlrernenis
Seed Warehouse
Used Oil Storage Area
(Scheduled Inspections
Application Equipment
Decontamination Kits
Dry Buggies, Liquid Trailers, etc.
Electrical (condition of Saxes, wiring and
cords)
NH3 Wagons, Nurse Tanks & Mobile
Equipment (paint, condition, etc)
Nurse Trucks & Pickups
NaTRUCTioNS: Complete ail applicable sections of the forms and return a copy (both sides) to Asmark with your monthly training. Weekly inspections
ire to be documented on the original form that is kept on file at the facility.
I 136

Appendix B
MONTHLY INSPECTION
A walk around of facility to determine status of monthly inspection items. Walk -around to take inspection team through the following areas:
(1) Office, (2)Shop, (3) Chemical Warehouse, (4) Dry Fertilizer Storage; (5) Liquid Fertilizer Tank Farm(s), (6) Pesticide Tank Farm(s), (7) Seed
rr— Warehouse and (8) Yard_
MONTHLY ROUTINE INSPECTION ITEMS
EMERGENCY EYE WASHES & SHOWERS - Suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the
work area for immediate emergency use, where the eyes or body of any person may be exposed to injurious corrosive material. Such situations
include using or handling in open containers corrosive liquids in quantities of one gallon or more, filling or withdrawing a corrosive liquid from a
container of 5 gallons or more in size or loading and unloading corrosive liquid from tank cars or tank truck
EMERGENCY RESPIRATORS & EQUIPMENT - Stationary NH3 Storage should havg: Two NH3 gas masks w/spare canisters, NH3 gloves, gog-
gles, face shield, rubber boots, one protective slicker or protective pants and jacket, fire extinguisher 40 BC rated, working shower and eye wash.
Mobile NH3 Storage should have: One NH3 gas mask with spare canister, goggles, face shield, NH3 gloves, fire extinguisher 20 BC rated, 50 gal-
lons fresh water. Vehicle s in H3 s ouldhave: Goggles, face shield, NH3 gloves, fire extinguisher rated 20 BC, 5 gallons fresh water, if
transporting over 1200 gal. must have NH 3 gas mask: Emergency respirators shall be stored in a clean, dry and sanitary location and thoroughly
inspected at least once a month and after each use; a record of inspection dates and findings shall be maintained with the emergency respirators.
FACILITY LIGHTING & SECURITY SIGNS -Emergency notification signs are current,- condition of fences & gates
FIRE EXTINGUISHERS - Unit tops not over 5 ft. from floor, if over 40 lbs. 3-112 ft, from floor, free access to units, unit locations marked, annual
maintenance performed and tag on unit, fire extinguishers in their proper place and have not been actuated or tampered with, extinguishers free of
obvious damage, corrosion or other impairment.
FIRST AID KITS- complete and in proper place, first aid cabinets properly labeled
GUARDS & COVERS (In Plant Equipment)- PTO guards in place; motor coupling guards in place; screw conveyor covers in place; rotating shafts
ends and collars guarded. Grinder work rests adjustable and within 1/8" of wheel; bench and floor grinding wheel exposure should not exceed 90'
or 1/4 the periphery and shall not begin more than 65' above the horizontal; safety guards on "side arm" portable grinders shall not expose more
than 180' of the wheel; flywheels, clutches, V-beits, pulleys, sprockets, chains, etc. which are 7 feet or -less above floor or other working level shall
by guarded; shaft ends within 7 feet of working level shall be smooth and rounded and, if projecting more than 1-112 times the shaft diameter
beyond end of bearing, shall be guarded. During repair, equipment shall be effectively blocked or otherwise secured to prevent inadvertent move-
ments that could cause injury
HOIST CABLE & CHAIN, MANLIFT EQUIPMENT - Load capacity signs In place; cable, rope and chain free of weak spots; three U-bolts on cable
ends; safety latch type hooks used; hydraulic lines and hose free of damaged or warn spots.
HOUSEKEEPING/OVERALL FACILITY APPEARANCE: - Restroom and shower facilities clean and equipped; areas free of trash, shop areas
clean, floors free of oil and grease. Tools not in use are properly placed. Tank equipment in good condition. All areas free of weeds, waste and fire
hazards. Emptied containers, pallets in designated areas. Containers labeled. Perimeter berms, curbs and controlled release points well main-
tained; Yard surfaces free of spill and 'waste material contamination.
LOCKOUTffAGOUT EQUIPMENT - Individual locks and tags are available and readily accessible in designated area.
PERSONAL PROTECTIVE EQUIPMENT -(gloves, goggles, respirators etc.) During walk around check to see that employees are wearing
required ppe; safety goggles available at grinders and used; hard hats in use where required; hearing protection provided and used; NH3 face
shields and goggles available and used; protective clothing properly stored, respirators cleaned and disinfected regularly and properly stored;
assigned respirators should be cleaned after each days use, those. used by more than one worker shall be thoroughly cleaned and disinfected
after each use.
SPILL KITS - Are accessible and contents are clean and accessible, review checklist
CHEMICAL WAREHOUSE -Clean, organized, materials stacked straight; warning signs posted; No Si"noking signs in place; all exits accessible
and marked; Flammable liquid storage main aisles 8 feet wide and side aisles 4 feet; approved containers used for flammable and combustible liq-
uids; permanent aisles and passageways appropriately marked; aisles and passageways clear, clean and in good repair; truck and rail wheel
blocks and chocks available and used; forklift trucks have working horns and brakes, and have load capacity marked, and operated by trained
drivers; unattended forklift trucks shall have forks lowered, controls in neutral, power off, brakes set. Toxic material spills cleaned tip and area
decontaminated. Spill clean up and decontamination supplies available.
DRY FERTILIZER WAREHOUSE, STORAGE BINS, MIXIBLEND AREAS, PADS - Mixing area is clean and swept daily, load out pad is clean and
swept daily; shafts, gears and belts guarded.
HAZARDOUS WASTE STORAGEAREAS - Containers labeled. Logs maintained to identify contents accumulated in bulk hazardous waste stor-
age facilities.
LIQUID FEIRTILITER TANKS, CONTAINMENT MIXBLEND AREAS, PADS -Walls and floor are properly maintained (cracks repaired). Liners
(when present) are properly maintained. Piping and valves are free of leaks. Tanks labeled. Loading pads and sumps are properly maintained.
Transfer equipment in good condition. No spillage of product to unpaved areas, shafts, gears and belts guarded.
LIQUID PESTICIDE TANKS, CONTAINMENT MIX/BLEND AREAS, PADS - Walls and floor are properly maintained (cracks repaired). Piping and
valves are free of leaks. Tanks Labeled_ Loading pads and sumps are properly maintained. Transfer equipment in good condition, no spillage of
product to unpaved areas of facility. Wash, recycle, and holding tank equipment in good condition.
NH3 FACILITY - Replace 6 year old high pressure hose; Inspect all other hose and connections; NH3 liquid pumps and compressors should have
working suction and discharge pressure gauges; NH3 tank valves not damaged; NH3 pressure gauges and liquid level gauges in working order;
Tank shell free of dents, gouges, bulges or bad corrosion; Relief valves replaced every 5 years; Tanks properly marked and placarded and paint-
ed..Vaives and pipelines color coded; Tank car connected signs available and used,
SEED WAREHOUSE - clean, organized, materials stacked straight, all exits accessible and marked
USED OIL STORAGE AREA- container in good condition and not leaking, labeled "Used Oil", no evidence of spills, area housekeeping good.
SCHEDULED INSPECTIONS -
APPLICATION EQUIPMENT - no cluttered floors, trash, seat and dash clean, exterior clean, no excess greasetoil, no spillage to soil, name & logo
DECONTAMINATION KITS - clean, gloves, goggles, soap, change of clothing
DRY BUGGIES, LIOUb TRAILERS ETC - Clean; SMV signs if applicable, shaft, gears, belts guarded, tanklbox good condition,
ELECTRICAL Panel controls labeled; Covers on all boxes and knockouts plugged; Equipment lockouts available and used. All motors connected
with fixed wiring; Panels have 30" clear space; Automatic start equipment warning sign in place; Extension cords free of splices and grounded;
Portable tools grounded; Conduit in good condition and properly supported. Lock, block, and tag out procedures established and enforced.
NH3 WAGONS, NURSE TANKS and mobile equipment 'wheals, tires, hitch condition, safety chains, required markings, tank condition, SMV if
applicable, guarding
NURSE TRUCKS & PICKUPS - Exteriors clean, washed, interiors clean, no trash, required documents, logo when required, equipment safety
check, no fluid leaks
137

Inland Plastics Inc.
Page 1 of 2
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t II

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
FAX [phone]
Facsimile transmittal
To: Al Hodge, DWQ WARO Fax: [phone]
From: Ken Pickle, Stormwater Permitting Unit, Date: July 9, 2008
Division of Water Quality
Phone: [phone] ext. 584 Pages: 12
E-mail: [e-mail]
Urgent For review Please comment Per your request FYI, no action Please recycle
Subject: Partial Submittal of Crop Protection Services No Exposure
proposal
Hi AI,
a) I've not attempted to fax several attached pages from their submittal -
two pages are poor printouts of a Google aerial photo of their site, and
several pages are vendor information on the tarps for the limestone pile.
The whole submittal is in the overnight for you.
b) email me as to a time for us to talk on this. I'm out of the office
tomorrow morning, but available the rest of the week.
Ken /!��

CI'S review
Subject: CPS review
From: Ken Pickle <ken.pickle a ncmail,net>
Date: Wed, 09 Jul 2008 12:06:59 -0400
To:.AI Hodge <A1.Hodge@ncmail,net>, Thom Edgerton <[e-mail]>
CC: Bradley Bennett <Bradley.Bennett a ncmail.nct>, Bethany Georgoulias
<bethany.georgoulias cr ncmail.net>
Gentlemen,
1. Our expectation from the February meeting was that CPS would submit a package for
our review, consisting of an unsigned No Exposure Certification (unsigned because
until they truly have no exposure conditions, they can't submit a signed certification
that there is no exposure), a site plan, and a narrative description of the proposed
measures and practices to achieve no exposure. CPS did that on March 6, 2008.
(Except that they signed the no exposure form, which they shouldn't have done. Not a
significant issue, but we need to explain it to them.) Your copy is in the overnight
today, and I will fax you a copy around lunch time.
2. CPS identified 11 areas with exposure or potential exposure and proposed measures
and practices to eliminate the exposure. I judge that they HAVE NOT proposed complete
no exposure, but WARO and SPU should discuss before we respond to them. CPS proposed
the following measures and practices for achieving no exposure in the II areas:
a) Area 1, Maintenance shop bay. CPS reports that all activity takes place within the
bay, under roof. No exposure achieved...... OK
b) Area 2, Empty shuttle tank storage area. Per no exposure regulations, empty
container storage areas may be considered no exposure as long as there are no leaks
and as long as the containers are not in use - i.e. no filling or drawing, and no
operative taps or valves. CPS reports that any visible residue on the tanks is washed
off in another area before empty storage in this area. Clarification: We should
explain to CPS that once the containers are in this area, there may not be any filling
or drawing from the tanks. I think this is what they meant, but we should just
clarify for them. No exposure achieved....... OK (DWQ to clarify for CPS no fills or
draws are allowed.)
c) Area 3, Bulk chemical storage tanks, and adjacent truck load out pad. Secondary
containment is provided for the tanks. CPS reports that all fluids are contained and
are applied agronomically, and not released as stormwater. Outside ASTs with
secondary.containment qualify as no exposure, provided there is no release of
contaminated stormwater. No exposure achieved for the ASTs. However, the truck load
out area may still constitute exposure. We need clarification of the physical
configuration of the load out pad drainage. If it drains into the AST containment
area, we're good, no exposure has been achieved, If if just remains on the pad,
maybe in a little sump that they pump out periodically, that is NOT no
exposure...... OK for ASTs no exposure; need clarification on load out pad actual
configuration.'
d) Area 4, Liquid nitrogen fertilizer materials ASTs, and adjacent load out pad.
Secondary containment is provided for the tanks. Contained fluids are tested for
nitrates, and if below test strip sensitivy the fluid is released. If.above, fluid is
reclaimed and agronomically applied. This pretty good, we just need to get them to
confirm the sensitivity of the test strips. I mean, a test strip that detects down to
1% nitrates would be allowing 10,000 ppm NO3 - - not good in our world. Same comments
as above for the load out pad - we need to understand exactly what the physical
configuration is. If it drains into the AST secondary containment, good. If it
doesn't, then we still have exposure. No exposure not established by the submitted
write up....... NOT OK, yet, on two counts (test strip sensitivity and load out pad
configuration.)
e) Area 5, Railcar unloading for dry materials. This activity takes place outside.
CPS proposes to add steel plates under the car at the unloading point to retain any
spillage, and then to sweep up the materials. This arrangement does NOT meet the
of 3 7/9/2008 12: ! 5 1'M

CI'S review
intent of no exposure.
exposure...... NOT OK.
It may be good housekeeping, but it is not no
f) Area 6, Product load out area and pad, and bulk blender. CPS proposes that any
spillage would be swept up. This arrangement may be good housekeeping, but it is not
no exposure ........ NCT OK.
g) Area 7, deteriorated building siding allowing fertilizer materials to escape the
building. CPS reports that replacing the siding will effectively contain the
materials inside the building. No exposure achieved ....... OK.
h) Area 8, Fuel tank storage area and pad. Two tanks, 480 g and 250 g, fall below the
bulk storage threshhold (660 g individual container or 1320 g aggregate). Secondary
containment not required. CPS proposal of good housekeeping measures is not no
exposure, but the issue is moot due to the tanks small size ..... OK.
i) Area 9, Outside storage bins. CPS reports a change in storage practices so that
deliquescing materials are no longer stored ouside, and will no longer generate a flow
from spilled materials. CPS reports nutrient containing materials are no longer
stored here. CPS proposes that spilled material will be swept up and transferred
inside the main building. This arrangement may be good housekeeping, but it is NOT no
exposure...... NOT OK.
j) Area 10, site yard to be re -vegetated with fescue instead of oats. unclear whether
the proposed fill dirt will be used just to level the area, or to also acutally fill
in the drainage ditch along the eastern property boundary. Either way, there are no
industrial materials stored or present at this location. They do note that the fescue
will do a better job of controlling erosion on this sandy very flat parcel. I think
that's good site management and good housekeeping, but as far as I know, it's not
pertinent to a no exposure determination. However, no exposure is
achieved ........ OK. Their write up mentions that with this re -grading, sheet flow is
produced. It is unclear if they intend that achieving sheet flow carries some other
significance.
k) Area 11, Dolomite lime storage area. CPS proposes.a number of tarps (approx
50'xI00' each) to cover the working pile. Maximum pile size is reported during peak
season (August and September) as 200'x60'xl2'. There is no mention of controlling
run-on under the covers and onto the pile. I think this is a workable solution with
just a little bit of additional controls. No exposure not achieved, yet ........ NOT
OK, but could be easily modified to be ok.
3. Summary:
CPS proposals OK or moot for: Areas 1, 2, 7, 8, 10.
CPS proposals OK with minor modifications: 11
CPS proposals not OK for: Areas 5, 6, 9
Require more information on unloading pad drainage configuration: Areas 3, 4.
4. The next steps
a) As their current submittal stands now, I can't issue a No Exposure exemption from
permitting.
b) Issues that I see for WARO and SPU discussion include, Do we want to issue the No
Exposure, even though we don't think they have really proposed adequate measures to
achieve No Exposure? (I really don't like it.) Do we think that they will ever be
able to get to No Exposure? Do we agree as to the site circumstances and applicable
rules, and are the above evaluations appropriate? Do we arrive at the endpoint that
suits us?
c) After we discuss internally, I'll return their No Exposure application with the
above list of'deficiencies. It seems to me that they can then come back to us to
propose awnings or shed roofs and containment curbs for the several areas that still
constitute exposure. Or they can apply for an individual permit. -I'd prefer to
communicate with them in writing, rather than over the phone, since ultimately they're
going to have to respond to the deficiencies in writing, anyway. We probably want to
encourage them to begin the construction that we are in agreement with, too.
2 of') 719I2008 12:15 PM

CI'S review
Let's discuss.
Bethany, or Bradley - - Would you mind providing a quick review and any comments?
Ken
3 of 3 7/90-008 12:15 1'M

[Fwd: CPS review]
Sub .jecl: [F%W' CPS review]
From: 'thorn Edgerton <Chom.lidgerton a ncmaihict>
Dale; Tuc, 15 Jul 2008 17:49:25 -0400
To. Ken Pickle <Ken.Pickle a nemail.net>
CC: AI Hodge <Al.l lodge n nemail.net>
Please see Wands responses in blue after your responses.
------- Original Message
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Dale -.Wed, 09 Jul 2008 12:06:59-0400
From.Ken Pickle <ken -pickle a nemail.net>
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To:A1 Ilodge <AI.I lodgeCuinemaii.net >, Thorn Edgerton <1fhum.l:dhertc>nr?ncrosil.net>
CC:Bradley Bennell <}3rn(ilcv`li_enneti_n.ncni iil,nel>, Bethany Gcorgoulias<hcihan};gcorgnuhasLhncmnil,net>
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Gentlemen,
1. our expectation from the February meeting was that CPS would submit a
package for our review, consisting of an unsigned No Exposure
Certification (unsigned because until they truly have no exposure
conditions, they can't submit a siened certification that there is no
exposure}, a site plan, and a narrative description of the proposed
measures and practices to achieve no exposure. CPS did that on March 6,
2008. {Except that they signed the no exposure form, which they
shouldn't have done. Not a significant issue, but we aGs;:i LO oxyiiain tit
:o th,:1-1 Your copy is in the overnight today, and I will fax you a
1 Copy around lunCh time.
ry- Napo „rrrels.
2. CPS identified 11 areas with exposure or potential exposure and
proposed measures and practices to eliminate the exposure. I }udge that
they HkV' NOT proposed complo!,q ito eRpcs-v:e, but WARC and SPU should
discuss before we respond to them. CPS proposed the fallowing measures
and practices for achieving no exposure in the 11 areas:
-� WaFC 7.greos and expects issues to be addressed very quickly to prevent additional onforeemont action.
-
ta) Atea 1, Maintenance shop bay. CPS reports that all activity takes
place-within..the-bay,_under-r6cf.--N6-exposure-achieved,.T"""O):�"�
7)7Area-21 Empty shuttle tank storage area. Per no exposure
regulations, empty container storage areas may be considered no exposure
as long as there are no leaks and as long as the containers are not in
use - i.e. no filling or drawing, and no operative taps or valves. CPS
reports that any visible residue on the tanks is washed off in another
area before empty storage in this area. Clarification: We should
explain to f.P3 U'lat the container:: are in this arr.a, thole rlay ncc
t.r; an' tillinq rn: ,wWina f.r:,'t thr. t.aols. I think this is what they
meant, but we should }ast Clarify for them. No exposure
achieved...,.,, OK (CWQ ,., ol,ar'i1, ft.>i: CFG no !ills of d.vd,WS krr° allo:.,x,.l•1
c) Area 3, Bulk chemical storage tanks, and adjacent truck load nut
paA_5eobndary containment is provided for the tanks. CPS reports that
all fluids are contained and are applied agronomically, and not released
as stormwater, Outside ASTs with secondary Containment qualify as no
exposure, provided there is no release of contaminated stormwater. No
exposure achieved for the ASTs. However, the truck load out area may
still constitute exposure. 'Wt., neett ctari,icntiars of the, phystnal
rgcrntio:l of the loa,i out pad drain•-,qe. If it drains into the AST
containment area, we're good, no exposure has been achieved. It if
just remains on the pad, maybe in a little sump that they pump out
periodically, that is NOT no exposure.-. _ OX for ASTs no exposure; need
clarici;:atlo�7 on ICA.1 or,t rail rr,aual :anfinu::a::.tea.
`dl Area_,43 Liquid nitrogen fertilizer materials AS7s, and adjacent load
out pad. Secondary containment is provided for the tanks. Contained
fluids are tested for nitrates, and if below test strip sensitivy the
fluid is released. If above, fluid is reclaimed and agronomically
applied. This pretty good, we just nA,:d '.? gar, tp,n:n t,, confirm the
fgnsieivity cf the t^st etci.ps, i mean, a test strip that detects down
to 16 nitrates would be allowing 10,000 ppm NO3 - - not good in our
world. Sala, sro:r,-:rare ❑s ah,?ut: for thr. ir,;,d our. (tart - we n,a trd t0
'11uJ•:,1::I1'„hd nxEnttly other. the physical, conf Lguret..i Sin i:a. If it drains
l of 7/25/2008 7:36 AM

[Fwd; Ci'S review]
into the AST secondary containment, good. If it doesn't, then we still
hav4 exposure. No exposure not established by the submitted write
up... NOT OF. yet, on two counts 1te.=,L strip senslti:'_ty and load
uUt a ct r;ofi(o4z"tion, 1
Wnkt;; agrBeS. Col
Ce) Area 5, Railcar unloading for dry materials. Thi's activity takes
(place outside. CPS proposes to add steel plates udder the car at the
unloading point to retain any spillage, and then to sweep up the
materials. This arrangement does NOT meet the intent of no exposure.
It may be good housekeeping, but it is not no exposure.....rOT 6'.
( '-•) kaFO ay•eer, althou,p we will allcro with prot:ur ritrbnnp. Larger ticker iL(,M-; 0lt are in t•x addressed will m:i t,imize i!tpa4ts
f) AreAre P6. �oduct load out area and pad, and bulk blender. CPS
proposes Lbat any spillage would he swept up. This arrangement may be
good housekeeping, but it is not no exposure........ VOT oK.
( `) 54,71',11CLpugh we Will nllr:w With pt:Ixl' lecmuF. L.:rg,:r Cic4nt it..mti L';,a1; =+_i! 1-% Y,,m PifldzoS,,m:d will rni ni:ni �e lrrip;x:a:rl
g) Area,7, Deteriorated building siding allowing fertilizer materials to
escape the building. CPS reports that replacing the aiding will
effectively contain the materials inside the building. No exposure
achieved....... OF. .
C} f'.:ter repair. C9
Sfi)"Acea S, Fuel tank storage area and pad. Two tanks, 480 g and 250 g,
fal'l'hclow the bulk storage threshhold {660 g individual container or
1320 g aggregate). Secondary containment not required. CPS proposal of
good housekeeping measures is not no exposure, but the issue is moot due
to the tanks small 91re.....C•{.
�•�� WARO sgrees.
CV) -Area 9-0U[side storage bins- CPS reports a change in storage
practices-sa'that deliquescing materials are no longer stored ouside,
and will no longer generate a flow from spilled materials. CPS reports
nutrient containing materials are no longer stored here. CPS proposes
that spilled material will be swept up and transferred inside the main
building. This arrangement tray be good housekeeping, but it is NOT no
exposure...... NOT OK.
M
M
�...� '4dku - Wit.l. >_a•.! 9s:liauvs:;i.nu u:at•:lr..i.-.,1 p..rmhnint.ly r,_loclat•:::1 r.o rh„ ln.5.i.dc of 010 rr,in huildi,r1q, tile, ,7a,•>:7 clea;tnt:iJ up wr41.1,, l
a lip added to contain the filler material, otnps. BHP': user: to pran:nt tracacing an,l Isaterihl leAvitvy tarn site, w= will Allow. v/J
tjl�Area-'10 —sML.te yard to be re -vegetated with fescue instead of oats.
Un'dlaas wwhether the proposed fill dirt will be used just to level the
area, or to also aeutally fill in the drainage ditch along the eastern
property boundary. Either way, there are no industrial materials stored
or present at this location, They do note that the fescue will do a
better job of controlling erosion on this sandy very flat parcel. 1
think that's good site management and'good housekeeping, but as far as I
know, it's not pertinent to a no exposure dete rteination. However, no
exposure is achieved ........ OK. Their write up mentions that with this
re -grading, sheet flow is produced. It is unclear if they intend that
achieving sheet flow carries some other significance.
NIV athe Wirh ith herd Aifi'usutglectiisl:.=c.emplished'�talall0`- utatilr„ititss and eostnc:ntr,.tiansl. Area, must. bn , rade:i so !:hat wutet
tre[ttme11t,
k) Area 11, 'Dolomite lime storage area. CPS proposes a number of tarps
f (approx 50'x100' each) to cever the working pile. Maximum pile size is
reported during peak season (August and September) as 200'x60'x12'.
There is nc, ment.i.an of contrc-lliry run-ot, unu rx the covers and onto the
pile. 1 think this is a workable solution with just a little bit of
additional controls. No exposure not achieved, yet ........ NOT OK, but
could be easily modified to be ok.
W: ARQ - Pila must ir.r :•;,•:n 1;ad, with a 17orm-.tsund it ar,d all, sum-unc(iu,s ,,real gra:iod so that
wAtur i_ not allow.!d to t.14st4porL the mater'41. Also, a plan of action for Grp use must be presented.
3, Summary: WaF0. - I'.ra I And 2..11 heeds ;.Ie,nat.isn7s,
CPS proposals ON or moot for: Areas 1, 2, 7, A10. W;1FC• - AcLic:7, expl.arv,tabn ;-ndiz tion.
CPS proposals ON with minor modifications: 11, WARO - notion -.nd explanation.
CPS proposals not OR for: Areas 5, 6, 5 WsRO - Why
Require more information on unloading pad drainage configuration: Areas
4. SaFO agrees an, Tes^ strip cr�nfizmiLinn on Area -.
4. The next steps
a) As their current submittal stands now, I can't issue a No Exposure
exemption from permitting.
b) Issues that 1 see for WARO and SPD discussion include, Do we want to
issue the No Expasure, even though we don't think they have really
proposed adequate measures to achieve No Exposure? )I really don't like
it.] D,: we thin". tt,nt, they willever he, abl,M t•,, qAe t', 110 Exr,o .ure? Do
we agree as to the site circumstances and applicable rules, and are the
above evaluations appropriate? Do we arrive at the endpoint that suits us?
e) After we discuss internally, F'll return ;.hair .Dry Erposu_e
application with the atxve list of deficie7:cie:'. it seems to me that
they car, then Goad luck to us tc• propose axe, i:r_s or shed r_ at and
rr.ittai m.cnt •7uni:s f•?t th-a several are,.s thnc :..li, :7on,titu L-a a:posutc:.
i•r they can apply for art individual per-mit. I'd prefer to commmunicate
with them in writing, rather than over the phone, since ultimately
they're going to have to respond to the deficiencies in writing,
anyway. We probably want to encourage them to begin the construction
that we are in agreement with, too.
ci;s,:s r.o
ag,cs, o
Y►%z+efi`a L
s aFO - That is rap t, the=.(, '--e kttow they Are not there.
NaRO ar1rees,
Let's discuss.
2 oi'3 7/25/2008 7: 36 AM

[Fwd: CPS rcviml
Bethany, or Bradley - - would you mind providing a quick raview and any
comlen L 91
Hen
We need m very quick deadline met for compliance, please notify we promptly upon receiving any response.
to nf8.
Thcu"
Thom EdgerLon
Environmental Engineer
North Carolina Department of Environment & Natural Resources
Division of Water Quality
sur_ace water Protection Section
[phone] - Office
(252) 998-S215 - Fax
3 of 3 7/250-008 736 AM

OF W A �F9
r
Thomas C. Anderson
Crop Production Services
201 Society Avenue
Hartsville, South Carolina 29550
Dear Mr. Anderson:
Michael F. Easley, Governor
William G. Ross ]r., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
Subject: Crop Production Services Princeton facility
No Exposure improvements proposal
NOV-2007-DV-0298
Wayne County
The Division received your proposal for improvements at the Princeton facility in partial response to
our Notice of Violation dated -November 19, 2007, and in response to subsequent discussions in our
meeting at DWQ's Washington Regional Office of February 19, 2008. Many of the items you
proposed are acceptable to DWQ, but clarifications and additional actions are required before we
can agree that your proposal is fully responsive to all our concerns at this site.
Your letter of March 5, 2008 identified eleven areas of potential exposure and proposed the
following actions to eliminate exposure and to qualify the site for the No Exposure Exclusion from
permitting.
Area 1, Maintenance Shop area. You reported that vehicle maintenance activities already
take place in the shop bay. We concur that as long as all maintenance activities are under
roof, and as long as CPS continues this practice, no exposure conditions exist for this area.
These circumstances as described meet the intent of no exposure, and your proposal for
this area is acceptable.
f2. Area 2, empty.shuttle tank storage area. You reported that the empty tanks are sealed,
and that any residuals are washed off before: storage in this area. Please be advised per
federal regulations that no exposure conditions can only be attributed to this area as long as
the containers are sealed, not leaking, there are no operative taps or valves, and there is no
filling or drawing from them. Under these constraints the shuttle tank area can meet the
intent of no exposure, and your proposal for this area is acceptable.
h
V3. Area 3, bulk chemical storage tanks and load out pad. The bulk chemical tanks are within
secondary containment, which meets the intent of no exposure conditions as long as
contaminated stormwater is not released, and as long as any drainage from.the
containment area is via a normally locked closed valve. However, unless the load out pad
drains into the containment area, it does not meet the intent of no exposure, and some
additional management measures are required. Please either propose additional
management measures for the load out pad, or clarify for us that the load out pad drains
/into the containment area. Ids 1
4Area 4, liquid nitrogen tanks and load out pad. Again, the tanks and the containment area
itself meet the intent of no exposure as long as contaminated stormwater is not released,
and as long as any drainage from the containment area is via a normally locked closed
valve. - However, unless the load out pad drains into the containment,, it does not meet the
NorthCarolina
Alalmrally
North Carolina Division of Water Qualily 1617 Mail Service Center Raleigh, NC 27699.1617 Phone [phone] Customer Service
fntemec �+'�terqu:rlitv.orL Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

Mr. 'Thomas Anderson
Page 2 of 3
August 15, 2008
intent of no exposure. Please either propose additional management measures, or clarify
for us that the load out pad drains into the containment area. Further at this location,
please provide manufacturer's specification data that confirms for us the sensitivity of the
nitrogen test strips used to qualify the release of the liquid within the containment area.
This issue is significant for us in that test strips that measure in the percent of nitrates or
nitrogen would typically indicate a highly polluted (from a stormwater sense) discharge, and
would disqualify the area from no exposure,
/5. Area 5, railcar unloading area. As we understand it, you have proposed installation of metal
containment plates and sweeping of this area as a part of the routine unloading operation,
and our expectation is that any spillage would be accidental and minimal. DWQ will
consider the exposure at this location de minimis, and will accept your proposed
management measures as meeting the intent of no exposure.
✓6. Area 6, bulk blending, product load out area, and pad. As we understand it, you have
proposed sweeping, and our expectation is that any spillage would be accidental and
minimal. Further, you have reported that the bulk blender is operated infrequently. DWQ
will consider the exposure at this location. de minimis, and will accept your proposed
management measures as meeting the intent of no exposure.
Area 7, storage building opening through deteriorated siding. Your proposal to repair the
siding with new siding, and so to contain materials within the building meets the intent of no .
exposure, and is acceptable.
V8. Area 8, fuel tank storage area. Your proposal to clean up any spillage on the concrete pad
due to refueling from these two small tanks is acceptable. `
✓9. Area 9, outside storage bins. You have proposed to transfer all nutrient -containing
materials inside the main building, and to store only filler materials in these bins. 'The bins
are already roofed and enclosed on three sides. Please provide a management measure
(such as a shallow lip at the front of the bins) to contain any windblown rain within the bins;
please propose to clean up the concrete apron in front of the bins in order to remove past
depositions -of nutrient materials; please propose a management measure to eliminate
tracking of material from the bins. DWQ concludes that with these revisions to operating'
practices and with minor modifications to the area, the outside storage bins area can meet
the intent of no exposure.
V10. Area 10, the east yard currently in oats. Your proposal for minor filling with imported soil,
and for leveling of the area, and for re -vegetation in fescue is acceptable. The design
objective in the filling, grading, and re -vegetation of the area should be to achieve diffuse
flow across the area ('sheet flow'), and to prevent the transport of any materials off of the
site.
11. Area 11, dolomite lime pile. Your proposal to provide tarps over the area appears to be a
workable solution. The end result must be that the material is not exposed to incident
rainfall or run-on from adjacent areas. In addition to the tarps, please provide the
following: a run-on diversion berm around the pile to prevent contact between the material
and run-on from immediately adjacent areas; any and all related incidental grading to
insure that material is not transported away from the pile; a plan of action for utilization of
the tarps, including listing the deployment trigger and deployment_ actions to be

Mr. Thomas Anderson
r ne ..,of 3
Augu-. t 15, 2008
implemented in the event that sudden rain approaches while the working face of the pile is
uncovered.
Please revise your proposal, or provide other written response, to address the comments above
within two weeks of receipt of this letter.
Also, you may if you wish, include a filled out copy of our No Exposure Certification form,
NCGNE0000 in your response to this letter. However, it is not appropriate for you to submit it
with signatures until you have actually achieved no exposure conditions on your site. (Signing
the form constitutes representing to DWQ that no exposure conditions already exist at the time
of the signatures, which is not the case in Princeton.)
Please contact me with any questions or comments.
Sincerely,
X . 7fd-G--
Ken Pickle
DWQ Stormwater Permitting Unit
[phone]
[e-mail]
cc: Al Hodge, WARO
Shelton Sullivan, DWQ NPSACO
Bradley Bennett, DWQ SPU

O�O� W A �F�QG
o �c
Thomas C. Anderson
Crop Production Services
201 Society Avenue
Hartsville, South Carolina 29550
Dear Mr. Anderson:
:5)110oy
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Suflins, Director
Division of Water Quality
Subject: Crop Production Services Princeton facility
No Exposure improvements proposal
NOV-2007-DV-0298
Wayne County
The Division received your proposal for improvements at the Princeton facility in partial response to
our Notice of Violation dated•November 19, 2007, and in response to subsequent discussions in our
meeting at DWQ's Washington Regional Office of February 19, 2008. Many of the items you
proposed are acceptable to DWQ, but clarifications and additional actions are required before we
can agree that your proposal is fully responsive to all our concerns at this site.
Your letter of March 5, 2008 identified eleven areas of potential exposure and proposed the
following actions to eliminate exposure and to qualify the site for the No Exposure Exclusion from
permitting.
1. Area 1, Maintenance Shop area. You reported that vehicle maintenance activities already
take place in the shop bay. We concur that as long as all maintenance activities are under
roof, and as long as CPS continues this practice, no exposure conditions exist for this area.
These circumstances as described meet the intent of no exposure, and your proposal for
this area is acceptable.
2. Area 2, empty shuttle tank storage area. You reported that the empty tanks are sealed,
and that any residuals are washed off before storage in this area. Please be advised per
federal regulations that no exposure conditions can only be attributed to this area as long as
the containers are sealed, not leaking, there are no operative taps or valves, and there is no
filling or drawing from them. Under these constraints the shuttle tank area can meet the
intent of no exposure, and your proposal for this area is acceptable.
3. Area 3, bulk chemical storage tanks and load out pad. The bulk chemical tanks are within
secondary containment, which meets the intent of no exposure conditions as long as
contaminated stormwater is not released, and as long as any drainage from -the
containment area is via a normally locked closed valve. However, unless the load out pad
drains into the containment area, it does not meet the intent of no exposure, and some
additional management measures are required. Please either propose additional
management measures for the load out pad, or clarify for us that the load out pad drains
into the containment area.
4. Area 4, liquid nitrogen tanks and load out pad. Again, the tanks and the containment area
itself meet the intent of no exposure as long as contaminated stormwater is not released,
and as long as any drainage from the containment area is via a normally locked closed
valve. However, unless the load out pad drains into the containment, it does not meet the
NOne
ol-thCarolina
�Vat!/rallfy
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Custontcr Service
Internet: %v"VW.ncWaicrgualitv.ore Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/l0% Post Consumer Paper

Mr. Thomas Anderson
Page 2 of 3
August 15, 2008
intent of no exposure. Please either propose additional management measures, or clarify
for us that the load out pad drains into the containment area. Further at this location,
please provide manufacturer's specification data that confirms for us the sensitivity of the
nitrogen test strips used to qualify the release of the liquid within the containment area.
This issue is significant for us in that test strips that measure in the percent of nitrates or
nitrogen would typically indicate a highly polluted (from a stormwater sense) discharge, and
would disqualify the area from no exposure.
S. Area 5, railcar unloading area. As we understand it, you have proposed installation of metal
containment plates and sweeping of this area as a part of the routine unloading operation,
and our expectation is that any spillage would be accidental and minimal. DWQ will
consider the exposure at this location de minimis, and will accept your proposed
management measures as meeting the intent of no exposure.
6. Area 6, bulk blending, product load out area, and pad. As we understand it, you have
proposed sweeping, and our expectation is that any spillage would be accidental and
minimal. Further, you have reported that the bulk blender is operated infrequently. DWQ
will consider the exposure at this location de minimis, and will accept your proposed
management measures as meeting the intent of no exposure.
7. Area 7, storage building opening through deteriorated siding. Your proposal to repair the
siding with new siding, and so to contain materials within the building meets the intent of no
exposure, and is acceptable.
8. Area 8, fuel tank storage area. Your proposal to clean up any spillage on the concrete pad
due to refueling from these two small tanks is acceptable.
9. Area 9, outside storage bins. You have proposed to transfer all nutrient -containing
materials inside the main building, and to store only filler materials in these bins. 'The bins
are already roofed and enclosed on three sides. Please provide a management measure
(such as a shallow lip at the front of the bins) to contain any windblown rain within the bins;
please propose to clean up the concrete apron in front of the bins in order to.remove past
depositions of nutrient materials; please propose a management measure to eliminate
tracking of material from the bins. DWQ concludes that with these revisions to operating'
practices and with minor modifications to the area, the outside storage bins area can meet
the intent of no exposure.
10. Area 10, the east yard currently in oats. Your proposal for minor filling with imported soil,
and for leveling of the area, and for re -vegetation in fescue is acceptable. The design
objective in the filling, grading, and re -vegetation of the area should be to achieve diffuse
flow across the area ('sheet flow'), and to prevent the transport of any materials off of the
site.
11. Area 11, dolomite lime pile. Your proposal to provide tarps over the area appears to be a
workable solution. The end result must be that the material is not exposed to incident
rainfall or run-on from adjacent areas. In addition to the tarps, please provide the
following: a run-on diversion berm around the pile to prevent contact between the material
and run-on from immediately adjacent areas; any and all related incidental grading to
insure that material is not transported away from the pile; a plan of action for utilization of
the tarps, including listing the deployment trigger and deployment actions to be

Mr. Thomas Anderson
Page 3 of 3
August 15, 2008
implemented in the event that sudden rain approaches while the working face of the pile is
uncovered.
Please revise your proposal, or provide other written response, to address the comments above
within two weeks of receipt of this letter.
Also, you may if you wish, include a filled out copy of our No Exposure Certification form,
NCGNE0000 in your response to this letter. However, it is not appropriate for you to submit it
with signatures until you have actually achieved no exposure conditions on your site. (Signing
the form constitutes representing to DWQ that no exposure conditions already exist at the time
of the signatures, which is not the case in Princeton.)
Please contact me with any questions or comments.
Sincerely,
Ken Pickle
DWQ Stormwater Permitting Unit
[phone]
[e-mail]
cc: Al Hodge, WARO
Shelton Sullivan, DWQ NPSACO
Bradley Bennett, DWQ SPU

TRANSMISSION VERIFICATION REPORT
TIME 09/25/2008 18:05
NAME WET AND SH2O BRANCH
FAX [phone]
TEL [phone]
SER,# 000E6J796376
DATE,TIME 09/25 10:21
FAX NO./NAME 912529469215
DURATION 00:01:17
RESULT OK
MOD fiRD
ECM
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
FAX [phone]
Frd ir"i1 trii �i �.
To: Thom Edgerton, WARD
Fax: [phone]
From: Ken Pickle, Stormwater Permitting Unit, Date: September 25, 200
Dlvislon of Water Quality C
Phone: [phone]
E-mail: Ken. [e-mail]
Urgent For review Please comment / Per
Subject. Fax copy of Crop
Thom,
Pages: 4
Please see the attached threeages.
page of the letter, but that tL1eca d
date of the letter aS-Aug stst 1.5, 2008.
letter nit two weeks�af tl5eir+ receipt
have you?
Ken
FYI, no action Please recycle
Services letter
Note that I forgot to date the first
and third page headers establish the
CPS was required to respond to the
I have not yet heard from them,

'g. -
Crop
Production
ServicesCrop Production Services
1160 Brake Road
Rocky Mount, NC 27801
Phone [phone]
FAX [phone]
October 9, 2008
D
Ken Pickle
DWQ Stormwater Permitting Unit m 4 0
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617 `� t
1 �
Subject. Crop Production Services Princeton Facility
No Exposure Improvements Proposal i)!'
NOV-2007-DV-0298
Wayne County
Dear Mr. Pickle:
This is in response to your letter of August 15, 2008, to Mr, Tom Anderson. Please note that Mr. Anderson is no
longer with Crop Production Services and that any future correspondence should be addressed to me at the above
address. I became aware of your August 15, 2009, letter on September 30 when Mr. Thom Edgerton was kind
enough to fax it to me.
We offer the following additional comments or management measures for the areas of concern:
Area 3, Bulk Chemical Storage Tanks and Load -out Pad. You requested additional management measures for the
load out pad.
• This pad does not drain into the containment area. The pad measures 22' x 17' and has a 4' lip on all 4 sides
with a 2' x 2' x 2' sump in the center. The pad is sloped to the center so that all liquid flows to the sump
area. With these measurements, the load pad will contain approximately 980 gallons of liquid. The largest
container we fill is a 250 gallon shuttle, so should a shuttle fail, the entire contents would be contained on
the pad. In the case of a product spill, the material is pumped out and used per the label. For a rain event,
any water accumulated is pumped into a holding tank as soon as practical and is then land applied at
agronomic rates.
Area 4: Liquid Nitrogen Containment Area and Load Pad. You requested additional management measures for the
load pad and information on the nitrate/nitrite testing strips.
■ This pad also does not drain into the containment area. The current pad measures 45' x 15.5' and has a I .5'
x 1.5' x 1.5' sump in the center. The pad slopes to the center so that liquid flows into the sump area. At
present, this pad does not have a lip around the outer two edges. We are proposing to add a 4" lip to the two
exposed edges which would then allow the pad to contain as much as 1747 gallons. The largest tank filled
on this pad is a 1500 gallon tank. Any spills or accumulated rainfall will be lumped into a holding tank and
land -applied at agronomic rates. Records are kept of all water that is pumped from the containment or the
load -pad to show final disposition.
a ■ The nitratelnitrite testing strips we use are manufactured by Hach AquaCheck. They measure nitrate from
0-50 mg/1 and nitrite from 0-3 mg/l. The gradation scale for nitrate is 0, 1,2,5,10,20,50 and for nitrite it is 0,
0.15, 0.3, 1, 1.5, 3. The strips have a 24-month shelf life and are kept out of direct sunlight. CPS policy is
that any indication of nitrate/nitrite evident on the strip requires that the water be disposed of either through
the manufacturing process or by land application at agronomic rates.

Ken Pickle, DWQ-NCDENR
Page 2
October 9, 2008
Area 9: Outside Storage Bins. You asked for management measures to contain windblown rain within the bins,
clean up of the concrete apron, and measures to eliminate tracking from the bins.
■ There are three bins in the building. We are discontinuing bulk product storage in the two bins closest to the
enclosed bulk storage building (west end of this area). We will install a door on each of these two bins so
they can be used for bagged palletized storage. The third bin (farthest east) will be used for storage of bulk
filler only. We will add a concrete lip in front of all three bins to control windblown rain within the bins.
• The concrete apron has been thoroughly swept and was clean prior to loading the filler in the third bin.
Doors are being installed now on the two bins to be used for bagged storage.
■ Filler is a non -nutrient producing product. In fact, it is crushed stone and is used in -blended fertilizers to
make the desired weight so that the other nutrients are at the proper proportion for land application. A
MSDS is attached for the filler used at Princeton. From the NCSU Cooperative Extension Service website
for "Master Gardener Decision Support Guide: Lime Questions and Answers": Will the limestone rock used
as filler in fertilizer act as lime? Answer: The large size of these particles prevent any meaningful soil
reaction. The link to that website is(httpah►i%v.ces,ncsu.cdu/cabarrus/staff/dgofort)Vlimcfaq.html#L14).
Our loader rides on concrete while transporting filler from the bin to the blending area bin and any product
tracked is swept up and placed back into the storage bin.
Area 11: Dolomite Lime Pile. You asked for a run-on diversion berm, incidental grading so material is not
transported away from pile, and deployment trigger for the tarps.
■ The adjacent area is the bulk liquid containment area and a drive path. Materials from the pesticide
containment area cannot flow toward the lime pile due to the lip on the load pad. Our proposal to install a
lip on the liquid nitrogen load pad will eliminate any possible flow from this area. The only flow would be
from the drive area. The lime pile itself is, in effect, bermed on three sides; by railroad tracks and spur on
the north and south and by a grasslearthern berm on the east end of the property. Also, the tarp used to
cover the pile overlaps onto the ground so that water flow would be on the tarp and not on the lime itself.
■ Trucks back into the area between the railroad bed and the pile so we can load them, then drive straight out.
The loader that is used is usually left in the area once we begin lime season unless there is inclement
weather forecast or our other loader breaks down.
■ The most important measure we have taken is to receive about 1/3 of the amount of lime that we usually
receive. This makes covering the pile more manageable. The pile will be kept covered once all is received
with only the east end being uncovered during working hours. The working portion will be covered should
rain become imminent and before personnel leave for the day.
I trust this answers your concerns. Again, I am sorry, for the delay in getting this response to you, but if future
correspondence is addressed to the above address, you can be sure of a timely response.
Sincerely,
Nancy Vincek
Manager, Operations Compliance
Enc,
C: Kirk Williams
Bill Coleman
Donnie Wiggs

[Fwd: Timeline for Princeton Improvements]
Subject: [Fwd: Timeline for Princeton Improvements]
From: Al Hodge <[e-mail]>
Date: Mon, 13 Oct 2008 17.30:57 -0400
To: Ken Pickle <ken.pickle@ncmaiI net>
as i recall you are to prepare a letter documenting the date and dwq waro's intent to
enforce if the date is not met
same page?
thanks
bodge
Subject: Timeline for Princeton Improvements
From: "Nancy Vincek" <[e-mail]>
Date: Mon, 13 Oct 2008 14:32:45 -0500
To: <ken.pickle cr ncmail.net>, <al.trodge it ncmail.net>
CC: "Donnie C. Wiggs" <dwiggs cr agriumretail.com>, "Bill Coleman" <bcoleirtai1 rr agriun;retail.cotn>,
"Kirk Williams" <kwilliarns@ agriuniretail.com>
Mr. Pickle and Mr. Hodge,
This confirms my conversation with Mr. Hodge this afternoon. Crop Production Services — Princeton, NC will
complete the improvements listed in our letter of Oct. 9 by November 15, 2008. Upon completion, we will file a
signed NPDES NO EXPOSURE CERTIFICATION.
Please let me know if you have any other concerns or questions,
Nancy Vincek
Manager, Operations Compliance
Crop Production Services, Inc.
1160 Brake Road
Rocky Mount, NC 27801
252-977-0308 (office)
252-973-0761(fax)
618-407-5616 (mobile)
[e-mail]
Al Hodge
Regional Supervisor, Division of Water Qualit)'
Surface Water Section
Washington Regional Office
Timeline for Princeton Improvements.emi Content -Type: message/rfc822
Content -Encoding: 7bit
I of l 10/14/2008 10:20 AM

A r�RQ�
7
� r
a �
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
October 14, 2008
CERTIFIED MAIL 7003 2260 0005 5380 6951
RETURN RECEIPT REQUESTED
Ms. Nancy Vincek
Crop Production Services
1160 Brake Road
Rocky Mount, North Carolina 27801
Dear Ms. Vincek:
Coleen H. Sullins, Director
Division of Water Quality
Subject: NOV-2007-DV-0298
Crop Production Services
Wayne County
The Division received your October 9, 2008, letter in partial response to the original Notice of Violation
noted above, and to the Division's subsequent letter of August 15, 2008. Your proposals identified in
your two letters of March 5, 2008, and October 9, 2008, for eliminating exposure to incident rainfall
and stormwater run on are acceptable, and if successfully implemented will be'sufficient for DWQ to
grant the No Exposure Exclusion from permitting that you seek.
As per the agreement reached yesterday in your conversation with Mr. Al Hodge, Washington Regional
Office Supervisor, Crop Production Services is required to fully implement the measures identified in
your two letters, and to submit a No Exposure Certification form to DWQ's Stormwater Permitting
Unit. Both the full implementation of the identified measures, and the submittal of the signed form
must be completed on or before November 15, 2008.
Please be advised that it is DWQ's intent to begin enforcement and penalty assessment
procedures on Monday, November 17, 2008, if the proposed measures are not fully
implemented and the signed No Exposure Certification form is not submitted by Saturday,
November 15, 2008, as per your proposal and our agreement.
The Washington Regional Office will schedule a site inspection a short time before November 15,
2008, to check on your progress on the installation of the no exposure measures.
The No Exposure Certification form is available on our website at this address:
http:/1h2o.enr.state. nc.uslsuldocuments/No Exposure Application rev071408.pdf
Sincerely,
4 P,�J&
Ken Pickle
DWQ Stormwater Permitting Unit
[phone]
cc:
DWQ Washington Regional Office, AI Hodge
DWQ Washington Regional Office, Thom Edgerton
DWQ Central Files
DWQ NPS Assistance and Compliance, Shelton Sullivan
Mailing Address Phone [phone] Location NOne
or hCarolina
1617 Mail Service Center Fax [phone] N. Salisbury St. Naturally
Raleigh, NC 27699-1617 Raleigh,.NC 27604
Internet: www.ncwaterauality.orq . Customer Service 1-877-623-6748
An Equal OpportunitylAf6rmadve Action Employer - 50% Recycle lil0% Post Consumer Paper

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Crop w
Produc6on
Services
Crop Production Services
1160 Brake Road
Rocky Mount, NC 27801
Phone [phone]
FAX [phone]
November 10, 2008
Mr. Ken Pickle ��' _:..
Stormwater Permitting Unit IVO V Z 2 �. ���
Division of Water Quality LWe
���1617 Mail Service Center Raleigh, NC 27699-1617 ° SAt�,
Re. No Exposure Certification for Crop Production Services, Princeton, NC
Enclosed is the signed NPDES NO EXPOSURE CERTIFICATION for Exclusion for the above -
named facility located at 141 Luby Smith Road, Princeton, NC 27569.
A satellite map showing the location and a site drawing are also enclosed. The Site Drawing
refers to the original areas of concern for the facility -
Area 1 — Shop. Used oil is in a double -walled containment unit inside the shop. Safety Kleen
disposes of the used oil and leaves shipping manifests, which are available in the front of%ce.
Area 2 — Empty Sulk Chemical Shuttle Tank Storage Area. This is a concrete slab next to the
building. Only triple -rinsed, clean shuttles are stored in this area.
Area 3 — Bulk Chemical Storage Tanks. Tanks are in secondary containment. All storm water
from the containment area and the contained load pad is collected and agronomically land
applied through an application rig. A housekeeping decal is posted near the sump to remind
employees that the water must be collected and disposal requires manager approval.
Area 4 — Liquid Nitrogen Storage Tanks. Tanks are in secondary containment. Stormwater is
tested with nitrate strips and if there is any coloration on the strip, the water is collected and land
applied at agronomical rates or used as make up water. We added a four -inch lip all the way
around the nitrogen load pad to ensure storm waters are contained and to eliminate water flow
across the pad toward the east end of the facility. A Housekeeping decal reminds employees of
the proper management for stormwaters from the containment and the load pad.
Area 5 - Railcar Unloading Area. We added the metal plates on 3 sides of the load -in to
facilitate sweeping up any spilled product. Product is swept daily and placed inside the storage
building.
Area 6 — Blended Fertilizer Discharge. We extended the concrete pad in this area and have
posted Housekeeping Signs to remind employees that the area must be swept daily and the
product placed back inside the building or put on the truck before it leaves the facility.

Stormwater Permitting Unit
Page 2
November 10, 2008
Area 7 — Main Fertilizer Storage Building. The building has been patched for now so there is no
residual discharge through the wall to the outside of the building.
Area 8 — Fuel Tank Storage. The tanks are not contained, but fueling takes place over a
concrete pad. Any spillage is cleaned up with oil absorbent and properly disposed of in a waste
container.
Area 9 — Outside Bulk Storage Bins. We have installed doors on two of these bins and now use
them for bagged storage only. The third bin is used only for "filler" which is a non -nutrient
material. In addition, a four -inch concrete lip has been added to all three bins to eliminate wash
back of any rainwater that enters the bin. The concrete pad in front of the bins is the drive path
for the loader when transporting filler to the blender. This pad will be swept daily, when in use,
and all filler placed back inside the bin.
Area 10 — Field, East End of Facility. We brought in fill dirt, leveled the area and planted fescue
to create a sheet run off area at this end of the facility. We also planted cedars on two sides of
this area.
Area 11 — Lime Pile. We have ordered and are using a tarp to cover the lime pile, which goes to
the ground. Only the end being used is uncovered for the day and the tarp in put back into place
at the end of the day or if rain is imminent. The loader in the area is dedicated for the season,
and only leaves the area should our other loader break down or if a storm is forecast. Trucks
back beside the pile and pull straight out once loaded. (A spec sheet for the tarp is enclosed.)
Employees are trained annually on Stormwater Management, Waste Minimization, and
Housekeeping. Site personnel perform a Site Inspection monthly which includes all areas.
Stormwater that is collected from the containment areas is documented on the "Stormwater
Discharge Inspection Report." A copy of the monthly inspection form and the Stormwater
Discharge Inspection Report are enclosed.
I trust this answers any questions that may arise. Please feel free to contact me at the above
number or Donnie Wiggs, Manager at Princeton at 919-735-8800.
Sincerely,
Nancy Vincek
Manager, Operations Compliance
Enclosures
C: Kirk Williams, Greeley
Bill Coleman, General Manager
Donnie Wiggs, Manager
Faxed Copy: Al Hodge, Washington Office -- 252-946-9215

ALTI�`�YA`A
��
N,CPE,t_NR
F��!•Rl�trr,.T R+1N0.Tlnxi Rr1fi.'i^,Ff.
Division ofWater Quality / Surface Water Protection
National P0111a1ant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
CG N EOOOO
NO EXPOSURE CERTIFICATION
FOR AC.F.NCY 0.,1i ONLY
D:nc Rccehvd
Year
1 Month
[hi
cer,iticatc urcovem e
NI-CIGINIF1
Please check here if this is a renewal: ❑ RENEWAL
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit
based on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notice that your facility does not require permit
authorization for its stormwater discharges associated with industrial activity in the State of North
Carolina because it qualifies for a no exposure exclusion. A condition of no exposure at an industrial
facility means all industrial materials and activities are protected by a storm resistant shelter (with some
exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste
products. Material handling activities include the storage, loading and unloading, transportation, or
conveyance of any raw material, intermediate product, final product or waste product. A storm resistant
shelter is not required for the following industrial materials and activities: drums, barrels, tanks, and
similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak.
"Sealed" means banded or otherwise secured and with locked or non -operational taps or valves;
adequately maintained vehicles used in material handling; and final products, other than products that
would be mobilized in stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion.
In addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for
individual outfalls. if any industrial activities or materials are, or will be, exposed to precipitation, the
facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure
Certification form, you certify that a condition of no exposure exists at this facility or site and are
obligated to comply with the terms and conditions of 40 CFR 122.26(g).
You must re -apply for the No Exposure Exclusion once every five (5) years.
For questions, please contact the DWO Regional Office for your area. (See page 5)
(Please print or type)
1) Mailing address of ownerloperator (address to which all certification correspondence will be mailed):
Name Crop Production Services, Inc.
Contact Kirk Williams, Environments Manager
Street Address
City
Telephone No,
7251 W. 4th Street
-Greeley— State m ZIP Code _806�
_�T9'�7--n---zz34.7- 542 _ Fax: —970- _
2) Location of facility producing discharge:
Facility Name Crop Production Services - Princeton #0242
Facility Contact Donnie_Wiggs, Manager
Street Address _ 141, ­1-y-smi-t}_4Zead
City —tr ri: State NC ZIP Code 27569
County e
Telephone No, -9-19---35-gg00 Fax: 19-735-$$2-3
Page 1 of 5
SWU-NE-071408 Last revised 711412008

NCGNE0000 No Exposure Certification
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersectior)) jjW70 _Fa$t $ri n tnn- JriGt as--YQu
ye f—
rm s t-he-Wayne cainty 1 i new tin RR_� nni n T_ r by —Smith Ed- _ lnratiQn--onleft.
(A copy of a wrap with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? © Yes Jl No
5) Is this a Federal facility? ❑ Yes r# No
6) Latitude 35.271 637 Longitude—78.08122 (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
XX Existing Date operation began 1963
0 Renewal of existing No Exposure Certification Certification No.: NCGNE_
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes ANo
It yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 5� 1_ —9_ 1.
10) Provide a brief description of the types of industrial activities and products produced at this facility:
Eertilizex a1 Pnrii ng_0perati on
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
X1 No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") It you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
c. Materials or products from past industrial activity
d. Material handling equipment (except adequately maintained vehicles)
e. Materials or products during'loading/unloading or transporting activities
f. Materials or products stored outdoors (except final products intended for outside
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
0 Yes A No
0 Yes X Na
1:3 Yes XNo
❑ Yes V(No
❑ Yes
❑ Yes ANo
Page 2 of 5
SWU-NE-071408 Last revived VW2008

NCGNEOOOO No Exposure Certification
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes XNo
and similar containers
h. Materials or products handled/stored on roads or railways owned or mai6tained by ❑ Yes XNo
the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes XNo
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes XN0
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not
❑ Yes No
otherwise regulated (Le., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored
❑ Yes l(N0
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers
❑ Yes �11(No
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or IXYes ❑ No
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any Yes ❑ No
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers Yes ❑ No
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored
in close proximity to each other with a combined capacity of more than 1,326-
gallons?
c. Is secondary containment provided for any amount of Title III Section 313
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals?
d. Is secondary containment provided for any amount of hazardous substances?
e. Are release valves on all secondary containment structures locked?
15) Hazardous Waste:
Ayes ❑ No
`,Yes ❑ No
i Yes ❑ No
Yes ❑ No
Page 3 of 5
SWU-NE-071408 Last revised 7/14/2008

NCGNE0000 No Exposure Certification
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? © Yes` ANo
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste ❑ Yes N0
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes O�No
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport 1 disposal vendor:
Vendor address:
16) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to submit a no exposure certification form once every five (5) years to the North Carolina
Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into
which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water
Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NP❑ES permit prior to any point source discharge of stormwater from the facility. Additionally, l certify under penalty
of law that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of tine and imprisonment for
knowing violations.
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.
PrintecjAIA.me of Person Signing:
(Signature of applicant)
(Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCOENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
Page 4 of 5
SWU•NE-071408 Last revised 7/14/2008

NCGNEOOOO No Exposure 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).
There is currently no tee for a No Exposure Exclusion.
Final Checklist
This application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
❑ If this is a renewal, indicated current NCGNE number in Question 7.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWQ Regional Office for your area.
DWG Regional Office Contact Information:
Asheville Office
Fayetteville Office
Mooresville Office
Raleigh Office....,
Washington Office
Wilmington Office
Winston-Salem --..
Central Office .....
[phone]
[phone]
[phone]
[phone]
...[phone]
[phone]
[phone]
..-[phone]
Page 5 of 5
SWU-NE-071408 Last revised 7/14/2008

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141 Luby Smith Rd, Princeton, Wayne, North Carolina 27569 - Google Maps Page 1 of I
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liquid
Nitrogen
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Chemical
(ruby Smith Road
Crop Production Services 242 Code: .
141 Luby Smith Road
Princeton, NC 27569 12/06/06 18920
919-735-8800

STORM WATER DISCHARGE INSPECTION REPORT
Date Inspected Containment Area & Sump Nitrate Test Results Method of Disposal
Inspected PPM

Appendix A
C' ERn-
►°"� � AGR[UM RETAIL Crop • :�
MONTHLY INSPECTION REPORT Production
Services
FARM SERVICE
JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC YEAR
Facility: Inspector's Signature: Date:
Monthly Inspections Ite (sl
QK
Corf•ective-Measures Required and Comments
Date Actions Complet2dd
Emergency Eye Wash/Safety Showers
(weekly inspection req.)
Week t
Week 2 Week 3 Week 4
Emergency Respirators/SCBA's
Facility Lighting & Security Signs)
Fire Extinguishers (All locations & mobile
equipment)
First Aid Kits (complete & sanitary) ,
Guards & Covers (in -plant equipment)
Hoist Cable & Chain, Marilift Equipment
House Keeping/Overall Facility
Appearance (lot graded)
Lockout/Tagout Equipment
PPE (gloves, goggles, respirators)
Spill Kits
Chemical Warehouse (clean, organized)
Dry Fertilizer Warehouse, Storage Bins,
Mix/Blend Areas, Pads
Hazardous Waste Storage Areas (weekly
inspection required)
Week t
Week 2
Week 3
Week 3
Liquid Fertilizer Tanks, Containment,
MWBlend Areas, Pads
Liquid Pesticide Tanks, Containment,
MixlBlend Areas, Pads
NH3 Facility (paint, plumbing, condition etc,)
Use separate form more detailed Inspeettons "required by
your stataAomi requirements
Seed Warehouse
Used Oil Storage Area
Scheduled Inspections
Application Equipment
Decontamination Kits
Dry Buggies, Liquid Trailers, etc.
Electrical (condition of boxes, wiring and
cords)
NH3 Wagons, Nurse Tanks & Mobile
Equipment (paint, condition, etc)
Nurse Tricks & Pickups
INSTRUCTIONS,. Complete all applicable sections of the forms and return a 012y (both sides) to Asmark with your monthly training. Weekly inspections
are to be documented on the original form that is kept on'file at the facility,
136

MONTHLY INSPECTION Appendix B
A walk around of facility to determine status of monthly inspection items. Walk -around to take inspection team through the following areas:
(1) Office, (2)Shop, (3) Chemical Warehouse, (4) Dry Fertilizer Storage-, (5) Liquid Fertilizer Tank Farm(s), (6) Pesticide Tank Farm(s), (7) Seed
Warehouse and (8) Yard.
MONTHLY ROUTINE INSPECTION ITEMS
EMERGENCY EYE WASHES & SHOWERS - Suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the
work area for immediate emergency use, where the eyes or body of any person may be exposed to -injurious corrosive material. Such situations
Include using or handling in open containers corrosive liquids in quantities of one gallon or more, filling or withdrawing a corrosive liquid from a
container of 5 gallons or more in size or loading and unloading corrosive liquid from tank cars or tank truck
EMERGENCY RESPIRATORS & EQUIPMENT - StatiQnaryNH3 Storanp should have: Two NH3 gas masks wlspare canisters, NH3 gloves, gog-
gles, face shield, rubber boots, one protective slicker or protective pants and jacket, fire extinguisher 40 13C rated, working shower and eye wash.
Mobile NH3 Storage should havg: One NH3 gas mask with spare canister, goggles, face shield, NH3 gloves, lire extinguisher 20 BC rated, 50 gal-
lons fresh water. Vehicle Transporting NH3 should have: Goggles, face shield, NH3 gloves, fire extinguisher rated 20 BC, 5 gallons fresh water, if
transporting over 1200 gal. must have NH 3 gas mask: Emergency respirators shall be stored in a clean, dry and sanitary location and thoroughly
inspected at least once a month and -after each use; a record of inspection dates and findings shall be maintained with the emergency respirators.
FACILITY LIGHTING & SECURITY SIGNS -Emergency notification signs are current, -condition of fences & gates
FIRE EXTINGUISHERS - Unit tops not over 5 ft. from floor, if over 40 lbs. 3-112 ft. from floor, free access to units, unit locations marked, annual
maintenance performed and tag on unit, fire extinguishers in their proper place and have not been actuated or tampered with, extinguishers free of
obvious damage, corrosion or other impairment
FIRST AID KITS- complete and in proper place, first aid cabinets properly labeled
GUARDS & COVERS (In Plant Equipment)- PTO guards in place; motor coupling guards in place; screw conveyor covers In place; rotating shads
ends and collars guarded. Grinder work rests adjustable and within 118" of wheel; bench and floor grinding wheel exposure should not exceed 90°
or 114 the periphery and shall not begin more than 65' above the horizontal; safety guards on "side arm" portable grinders shall not expose more
than 180" of the wheel; flywheels, clutches, V belts, pulleys, sprockets, chains, etc. which are 7 feet or4ess above floor or other working level shall
by guarded; shaft ends within 7 feet of working level shall be smooth and rounded and, if projecting more than 1-112 times the shaft diameter
beyond end of bearing, shall be guarded. During repair, equipment shall be effectively blocked or otherwise secured to prevent inadvertent move-
ments that could cause injury
HOIST CABLE & CHAIN, MANLIFT EQUIPMENT - Load capacity signs in place; cable, rope and chain free of weak spots; three U-bolts on cable
ends; safety latch type hooks used; hydraulic lines and hose free of damaged or warn spots.
HOUSEKEEPING/OVERALL FACILITY APPEARANCE - Restroom and shower facilities clean and equipped; areas free of trash, shop areas
clean, floors free of oil and grease. Tools not in use are properly placed..Tank equipment in good condition. All areas free of weeds, waste and fire
hazards. Emptied containers, pallets in designated areas. Containers labeled. Perimeter berms, Curbs and controlled release points well main-
tained; Yard surfaces free of spill and waste material contamination.
LOCKOUTlTAGOUT EQUIPMENT - Individual locks and tags are available and readily accessible in designated area.
PERSONAL PROTECTIVE EQUIPMENT -(gloves, goggles, respirators etc.) During walk around check to see that employees are wearing
required ppe; safety goggles available at grinders and used; hard hats in use where required; hearing protection provided and used; NH3 face
shields and goggles available and used; protective clothing properly stored, respirators cleaned and disinfected regularly and properly stored;
assigned respirators should be cleaned after each day's use, those -used by more than one'worker shall be thoroughly cleaned and disinfected
after each use.
SPILL KITS -Are accessible and contents are clean and accessible, review checklist
CHEMICAL WAREHOUSE -Clean, organized, materials stacked straight-, warning signs posted; No Smoking signs in place; all exits accessible
and marked; Flammable liquid storage main aisles 8 feet wide and side aisles 4 feet; approved containers used for flammable and combustible liq-
uids; permanent aisles and passageways appropriately marked; aisles and passageways clear, clean and in good repair; truck and rail wheel
blocks and chocks available and used; forklift trucks have working horns and brakes, and have load capacity marked, and operated by trained
drivers; unattended forklift trucks shall have forks lowered, controls in neutral, power off, brakes set. Toxic material spills cleaned up and area
decontaminated. Spill dean up and decontamination supplies available.
DRY FERTILIZER WAREHOUSE, STORAGE BINS, MIX/BLEND AREAS, PADS - Mixing area Is clean and swept daily, load out pad is clean and
swept daily; shafts, gears and belts guarded.
HAZARDOUS WASTE STORAGE AREAS - Containers labeled, Logs maintained to identify contents accumulated in bulk hazardous waste stor-
age facilities.
LIQUID FERTILIZER TANKS, CONTAINMENT, MWBLEND AREAS, PADS - Walls and floor are properly maintained (cracks repaired). Liners
(when present) are properly maintained. Piping and valves are free of leaks. Tanks labeled. Loading pads and sumps are properly maintained.
Transfer equipment in good condition. No spillage of product to unpaved areas, shafts, gears and belts guarded.
LIQUID PESTICIDE TANKS, CONTAINMENT, MIX/BLEND AREAS, PADS - Walls and floor are properly maintained (cracks repaired). Piping and
valves are free of leaks. Tanks Labeled. Loading pads and sumps are properly maintained. Transfer equipment in good condition, no spiltage of
product to unpaved areas of facility. Wash, recycle, and holding tank equipment in good condition.
NH3 FACILITY - Replace 6 year old high pressure hose; Inspect all other hose and connections; NH3 liquid pumps and compressors should have
working suction and discharge pressure gauges; NH3 tank valves not damaged; NH3 pressure gauges and liquid level gauges in working order;
Tank shell free of dents, gouges, bulges or bad corrosion; Relief valves replaced every 5 years; Tanks properly marked and placarded and paint-
ed. Valves and pipelines color coded; Tank car connected signs available and used
SEED WAREHOUSE - clean, organized, materials stacked straight, all exits accessible and marked
USED OIL STORAGE AREA - container in good condition and not leaking, labeled "Used Oil", no evidence of spills, area housekeeping good.
SCHEDULED INSPECTIONS -
APPLICATION EQUIPMENT- no cluttered floors, trash, seat and dash clean, exterior clean, no excess greaseloil, no spillage to soil, name & logo
DECONTAMINATION KITS - clean, gloves, goggles, soap, change of clothing
DRY BUGGIES, LIQUID TRAILERS ETC - Clean; SMV signs if applicable, shaft, gears, belts guarded, tank/box good condition,
ELECTRICAL Panel controls labeled; Covers on all boxes and knockouts plugged; Equipment lockouts available and used. All motors connected
!� with fixed wiring; Panels have 30" clear space; Automatic start equipment warning sign in place; Extension cords free of splices and grounded;
Portable tools grounded; Conduit in good condition and properly supported. Lock, block, and tag out procedures established and enforced.
NH3 WAGONS, NURSE TANKS and mobile equipment -wheels, tires, hitch condition, safety chains, required markings, tank condition, SMV if
applicable, guarding
NURSE TRUCKS & PICKUPS - Exteriors clean, washed, interiors clean, no trash, required documents, logo when required, equipment safety
check, no fluid leaks
137

Inland Plastics Inc.
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CPS submittal received
Subject: CPS submittal received
From: Ken Pickle <ken.pickle a nemail.not>
Date: Thu, 13 Nov 2008 07:44:53 -0500
To: Thom Edgerton <[e-mail]>, Al Hodge <[e-mail]>
CC: Bradley Bennett <BradIey.Ben [e-mail]>, Mike Randall <mike.randall a ncmail.net>,
Bethany Georgoulias <bethany.georgouIias c?ncmaii.net>, Bill Diuguid <[e-mail]>,
"[e-mail]" <[e-mail]>, Jennifer Jones <jennifer [e-mail]>,
Cory Larsen <Cory.Larsen @ncrnai1,net>, Boyd Devanc<Boyd. Devane@ncmai ].net>, 'Robert Patterson'
<robert.Patterson @ncmai I.net>
Two guys,
a) I received yesterday afternoon the signed No Exposure form from Crop Protection
Services, Princeton, along with a letter summarizing how they addressed each of eleven
points required for no exposure. My first review indicates the submittal is
acceptable, and is in accordance with the conditions we identified for granting the No
Exposure exclusion from permitting. Thom, I'll fax you a copy of their submittal this
morning.
b) So, they have met our deadline on the submittal of paperwork. By submitting the
signed No Exposure Certification they are telling us that as'of the day of the s.igning
there was no exposure to rainfall or run on at this site, and that.1hey promise to
maintain no exposure conditions at this site. I see our visit on Monday as our visual
confirmation that the signed submittal accurately reflects site conditions, and that
indeed they have achieved no exposure. If we confirm no exposure conditions on
Monday, then I'll issue the No Exposure Exclusion from permitting that they have
requested next week. If we don't confirm no exposure conditions, we have told them we
will begin penalty enforcement actions on Monday (the day of our visit.)
c) I'll see if any of our group wants to tag along on our visit Monday. SPU and WARO
together have made a couple of judgment calls on this no exposure, and those can be
instructive. (SPU - I'll leave around 8:30 Monday, 11/17. Expect to be on site .
lhr+, and to return to Raleigh sometime - 12:00 - 1:00. Let me know if your schedule
and interest will allow you to attend.)
d) Thom, will you call and set it up for 10:00, please? Future follow up at this site
will probably be through WARO, and it seems slightly preferable to me to reinforce in
their minds that their primary contact w/ OWQ is through WARO.
Ken
lofl
11/13P-008 7.5

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
FAX[phone]
Facsimile transmittal
To: Thom Edgerton, WARO Fax: [phone]
From: Ken Pickle, Stormwater Permitting Unit, Date: November13, 2008
Division of Water Quality
Phone: [phone] Pages: 17
E-mail: [e-mail]
Urgent For review Please comment Per your request FYI, no action Please recycle
Subject: Crop Protection Services, Princeton, No Exposure Certification
Thom,
See attached November 10, 2008 letter from CPS, DWQ's 5 page No
Exposure Certification form, and supporting materials from CPS.
Ken

Pickle, Ken
From:
Pickle, Ken
Sent:
Monday, June 15, 2009 6:20 PM
To:
'[e-mail]'
Cc:
Bennett, Bradley; Hodge, Al; Edgerton, Thom
Subject:
Crop Protection Services
Hi Mike,
This is a follow up of a voice message I left earlier today. I'm seeking your guidance or direction to other guidance on
proper SIC code classification, that might pertain to these circumstances in NC:
Our Washington Regional Office responded to a neighbor's complaint about wind-blown lime from a large agricultural
lime pile located at the Crop Protection Services (CPS) facility in Princeton, NC. We visited the site, and saw some
deposition of the lime materials in a roadside ditch, but also noted that the facility did not have an NPDES sw permit.
This facility is called a fertilizer and agricultural chemical supply facility. They receive bulk shipments of granular
nitrates, phosphates, and potash (K) materials, as well as some liquid materials and pesticides. They then make up
standard granular blends, and/or farmer -specified blends of the three nutrient ingredients, and then deliver to, or hold
for pickup by, the farmer. There are no chemical reaction vessels that would constitute what you might think of as
'manufacturing', in the sense of making or refining raw materials into the individual N, P, and K ingredients, But there
absolutely is some significant amount of blending of these bulk ingredients (N, P, K) to produce final products for sale to
the farmer.
This facility serves farmers in and around Johnston and Wayne County, NC - - generally a non -urban and predominantly
agricultural area of the state.
We began with these folks by noting that by virtue of the mixing and blending operation they were SIC 2875, and they
needed a NPDES sw permit, as per the identification of SIC 28 in 40CFR122,26(b)(14)(ii). Subsequently, they argued that
with a few site improvements they could qualify for the No Exposure Exclusion from Permitting. As time passed, they
applied for No Exposure, and we subsequently had problems with site conditions that don't really meet the full intent of
No Exposure. Some additional time has passed, and in a recent status meeting their position has changed, and
corporate staff for the company have produced several pieces of 1991 correspondence exchanged between several folks
at EPA Washington (Frank Hall, Deputy Dir. Permits Division Office of Water Enforcement and Permits; and Ephraim
King, Chief NPDES Program Branch) and representatives of the trade organizations (Richard Flye, Counsel to The
Fertilizer Institute; Gary Myers, President TPI; and Chris Myrick, Director Legislative and Regulatory Affairs National
AgriChemical Retailers Association). The upshot of the correspondence exchanged in 1991 appeared to be as stated by
Mr. King for EPA (bold text added below to emphasize the points of my confusion). If we had ever been aware of this
correspondence from 1991, we are only now re -acquainted with it:
a) per Mr King's letter of October 3, 1991, "EPA agrees that incidental or small scale mixing and blending of fertilizers at
wholesale or retail facilities does not constitute manufacurer blending and mixing described under SIC code 2875, and
such wholesale or retail facilities would not be required to submit NPDES storm water discharge permit applications."
And, continuing uninterrupted in the same paragraph,
b) "EPA also agrees that these facilities are properly classified in SIC code 5191 even though they may in some cases ship
to or exchange fertilizer with other retail or wholesale outlets before shipment to the ultimate end user." And,
continuing uninterrupted in the same paragraph,
c) "However, when the facility is mixing, blending, and redistributing these materials on a manufacturing scale such that
the mixing and blending becomes the activity in which the facility is primarily engaged, that facility would then be more

Meridian Voice Mail Messaging Directions
DISTRIBUTION LISTS
A distribution list saves you time when you are sending a message to a group of mailboxes. You can
create up to nine personal distribution lists, each containing up to 99 entries.
1) Login to the voice mail system.
2) Press 85 for Distribution Lists.
3) Enter a number from 1 to 9 to identify this list, then press #.
4) Press 5 to create the list.
5) Enter the.first mailbox number then press #.
6) To delete a mailbox after you enter it, press 0 then #.
7) Enter the remaining mailboxes, each followed by a #.
8) End the list with an extra #.
COMPOSING MESSAGES
The express messaging feature allows you to call someone within the voice mail system without
dialing directly to his or her extension. This is useful if you know the person is not at their desk.
1) Login to the voice mail system.
2) Press 75 to compose a message.
3) Enter the first address (mailbox number or distribution list number) then press #.
4) Continue to enter numbers followed by # until you have finished.
5) End the list with an extra #.
6) Press 5 to record. Press # to end recording.
7) Press 79 to send the message.
EXPRESS MESSAGING
The express messaging feature allows you to call someone within the voice mail system without
dialing directly to his or her extension. This is useful if you know the person is not at their desk.
1) Dial the Express Messaging extension — 770b1 or if from a remote location - 807-7001.
2) When prompted enter the appropriate mailbox number (5-digit extension) followed by the # sign.
3) Speak your message and hang up.
DIAL BY NAME
The Dial by Name feature allows you to call someone within the voice mail system by their name.
This is helpful if you do not know their extension.
1) Dial the Dial by Name extension — 77004 or if from a remote location - 807-7004.
2) When prompted, begin entering the last name of the person you want to call.
3) When the voice mail system finds an enough of a match, it will dial the extension. If the system
finds multiple matches, it will play the personal verification of each and will allow you to select the
one to dial.
04/14/09 3 of 3

appropriately classified under SIC code 2875 and therefore would be required to submit a NPOES permit application for
its storm water discharges."
SUMMARY
:::So, our questions are, does Mr. King's 1991 letter represent EPA's current thinking on the topic? And if so, which SIC
code pertains to the circumstances at CPS, Princeton, NC? is there any updated information on this topic?
:::According the Mr. Kings 1991 letter, CPS would be SIC 5191 (and not be captured by 40CFR122.26(b)(14)) if the mixing
and blending are "incidental or small scale" and so their operations do not constitute "manufacturer blending and
mixing". But, is there guidance on "incidental" or "small scale"? Similarly, is there guidance or further example of
"manufacturer" blending and mixing?
:::On the other hand, as I read Mr. King's 1991 letter, CPS would be SIC 2875 (and required to have a permit) if their
operation is on a "manufacturing scale" - - Again, is there guidance on what that means, as to what scale constitutes
"manufacturing scale" and what size falls below that threshold?
Thanks, Mike, for any Region IV or Washington guidance you can provide on this topic.
Ken
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties.

Meridian Voice Mail Messaginq Directions
r,
LOGGING IN FOR THE FIRST TIME
1) Lift handset or touch speaker and get dial tone.
2) Press Message key or dial 77000 if you do not have a Message key.
3) When prompted for a Mailbox number, enter your 5-digit extension followed by the # sign.
4) When prompted for a Password, enter your 5-digit extension followed by the # sign.
5) The system will now say your password has expired. Dial 84 from your dial pad (this is for the
Password change routine).
6) When prompted, enter a new password followed by the # sign (use at least 4 digits).
7) When prompted, re-enter the new password again followed by the # sign.
8) To confirm the new password you must enter your old password followed by the # sign. Your old
password is the default password of your 5-digit extension followed by the # sign.
LOGIN AT WORK
1) Lift handset or touch speaker and get dial tone.
2) Press the Message key or dial 77000 if you do not have a Message key.
3) When prompted for a Mailbox number, enter your 5-digit extension followed by the # sign.
Tip: When at your desk and you are prompted for the Mailbox number you only need to touch
the # key.
4) When prompted for a Password, enter the password you selected followed by the # sign.
LOGIN FROM HOME OR A REMOTE LOCATION
1) Lift handset and dial 807-7000 to access the Meridian Mail voice mail system.
2) When prompted for a Mailbox number, enter your 5-digit extension followed by the # sign.
3) When prompted for a Password, enter the password you selected followed by the # sign.
4) After successfully logging on with a correct password you can use the features of the Voice mail
system.
CHANGING YOUR PASSWORD
1) Login to the voice mail system.
2) Press 84 for the Password Change routine.
3) When prompted, enter a new password followed by the # sign (use at least 4 digits).
4) When prompted, re-enter the new password again followed by the # sign.
6) To confirm the new password you must enter your old password followed by the # sign.
RECORD YOUR NAME (PERSONAL VERIFICATION)
1) . Login to the voice mail system.
2)' Press 89 for Personal Verification.
3) Press 5 - Speak your name.
4) Press # - To stop recording and save your name.
5) Press 2 - To listen/check your recording.
6) Press 5 - To re-record (if not satisfied).
7) Press # - To stop and save recording.
04/14/09 1 of 3

Pickle,"ken
�s
From: Parker, Michael
Sent: Tuesday, June 16, 2009 8:12 AM
To: Pickle, Ken
Subject: RE: Agricultural chemicals supply store
Ken,
We really don't have very many of these type facilities in our region, but we do have a few and to my knowledge we
haven't experienced any significant problems with them (outside of some GW contamination incidents), but we haven't
exactly gone over them with a "fine tooth comb" either. Most of the plants we have are built far enough away from
surface waters that we don't necessarily see direct impacts, however, I am sure there are some locations where SW is
being impacted from current and past storage and mfg practices. I cannot see, however, how these facilities could make
the case that they are above the NPDES program given the potential for WQ impacts that exist.
Michael Parker
From: Allocco, Marcia[mailto:[e-mail]
Sent: Monday, June 15, 2009 4:15 PM
To: denr.dwq;swpmro .
Subject: FW: Agricultural chemicals supply store
All,
If you have any insight. please forward to Ken. I mentioned our one wastewater permit for the Southern States
Manufacturing plant in iredeli but do not know of any issues with these facilities in- MRQ.
Marcia
From: Pickle, Ken
Sent: Monday, June 15, 2009 4:03 PM
To: Linda Willis; Lawyer, Mike; Allocco, Marcia; Smith, Danny; Edwards, Roger; Basinger, Corey
Cc: Hodge, Ai; Edgerton, Thom; Bennett, Bradley
Subject: Agricultural chemicals supply store
Friends, /0,10c/uG r/gor?
I'm seeking information on agricultural chemicals supply facilities (Royster Clark, Southern States, Crop Pfeteet0a
Services, etc.). These folks receive bulk ingredients (N, P, and K) and pesticides and sell to farmers. Often their facilities
have a rail spur or siding for receipt of bulk ingredients, along with silos, bins, or tanks for storage.
Has your region seen surface water issues with sites that: receive fertilizer materials in bulk; blend it into standard
blends; and/or blend it into farmer -specified blends; and the final product is either delivered to, or picked up by, the
farmer? They don't 'manufacture' the fertilizer ingredients via'chemical reaction or from the original raw materials,
typically their process is limited to blending the several granular N, P, or K materials received from suppliers or from off -
site parent company manufacturing facilities.
'The stormwater permitting unit has only about 4 of these facilities under an NPDES Stormwater permit at the present.
We are guessing there may be over 200 of such sites in the state, more concentrated in heavily agricultural areas.

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coieen H. Sullins Dee Freeman
Governor Director Secretary
May 20, 2009
Mr. Jim Gregson Subject: Coastal Resources Advisory Council
Director, Division of Coastal Management
400 Commerce Avenue
Morehead City, NC 28557
Mr. Gregson,
1 hereby appoint Cyndi Ka ly, 401/Express Permitting Unit Supervisor, as the Division of
Water Quality's representati e on the Coastal Resources Advisory Council (CRAC). She will be
occupying the seat previously eld by Al Hodge.
Ms. Karoly's contact informatio is as follows:
Mailing Address
1650 Mail Service Center
Raleigh, NC 27699-1650
Telephone: [phone]
Fax: [phone]
Email: Cyndi.Karoly cr,ncdenr.gov
If you require further information, please contact Matt Matthews at 919-807-6384.
Sincerely,
Coleen H. Sullins
cc: Cyndi Karoly
Matt Matthews
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Ralegh, North Carolina 27604
Phone: 91M07-63001 FAX: [phone] Customer Service: 1-877-623-6748
Internet: www,ncwaterquality.org
One
NorthCarolina
;VaturW1Y
An Equal Opportunity 1 Affirmative Action Employer

WaRO has a facility that is diputing our original determination that a NPQE5 SW permit is required, and they -have
pr,duced some 1991. correspondence between EPA HdQtrs and the trade associations that indicate indeed some of
these facilities might be outside the NPDES program under certain conditions.
Again, are these sites on your radar? Have you seen problems with them? Have you any experience with the
stormwater discharges from these sites? Have you had success cleaning up the spilled granular and liquid N,P, K
materials from such sites? How?
Thanks for any responses,
Ken
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties,
f. _..�.
Eir. iR cares s t^'en. to aril ::m ihis _�ra_r is s.ro;ent :r the N r'u k, __ �s ! art and !r.ay bn a �?a �d :W I:�. ?=�=ies.
2

Meridian Voice Mail Messaging Directions
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11
04/14/09 2 of 3

Pickle, Ken
From: Pickle, Ken
Sent: Wednesday, June 17, 2009 9:54 AM
To: Pickle, Ken; Hodge, AI; Edgerton, Thom
Cc: Bennett, Bradley
Subject: RE: Progress report on Crop Production Services
One other aspect that hasn't yet been brought up in our discussion this week - this is a WS-IV, NSW receiving water.
Here in CPS, Princeton is an absolute nutrient risk wrt stormwater runoff. Recall that from Ed Warren's first visit, we
observed exposure of nutrient materials originating from incidental losses in the receiving, load out, and other material
handling areas. It seems we should have some heightened interest in addressing a potential nutrient hot spot in an
NSW basin.
Ken
From: Pickle, Ken
Sent: Wednesday, June 17, 2009 9:38 AM
To: Pickle, Ken; Hodge, Al; Edgerton, Thom
Cc: Bennett, Bradley
Subject: RE: Progress report on Crop Production Services
One additional comment this morning from South Carolina: Arturo offers flour points:
a) He says it's 2875, (not a new idea for us, but it is further corroboration that we would be consistent with other states)
b) He reminds us that we can use the federal rule provisions to capture this type of facility if we can determine that
there is a violation of wqs, or if the facility is a 'significant contributor of pollutants' to waters of the US; (not a new idea,
but further corroboration. Also, we recognize this as a comparatively labor intensive effortfor the RO, and perhaps an
unsuccessful endeavor.)
c) He offers that there may be a path through 40CFR122.26(b)(i) since these facilities are subject to process wastewater
effluent limitation guidelines in 40CFR418.70ff. (A new idea in this discussion, in that he identifies a new path to capture
these folks, but it still doesn't speak to the core issue of, 'Is CPS, Princeton manufacturing or wholesale?')
d) He notes in the federal rule that industrial facilities owned by governmental divisions (local, state, federal) are
captured if they 'meet the description' t hat follows in the rest of the list of captured commercial industrial facilities. He
effectively suggests that this should also be our criterion on the normal commercial industrial facilities (ie, do they
`meet the description'), regardless of which SIC code they may self -assign. (This seems to me a minor point - we already
have the straight up listing of the captured SIC codes. But it may help, if we understand that even for publicly owned
industrial facilities, the key issue in determining whether a stormwater permit is required is, "What's the nature of the on
site activity, and does it match a captured SIC code?")
My opinion - - - We in SPU have now recently had a couple of instances in the NPDES industrial stormwater program
where we are inclined to give some problems/issues a secondary priority. I think that CPS, Princeton must be dealt with
via a stormwater permit - it should be a priority for us now; but, I think programmatically we should not mount an
initiative to capture other similar sites, but rather should deal with other similar sites on a complaint basis. Our interest
in this is to recognize the limitations of our resources, but also to deal with problem sites when we identify them.
Contrary opinions? Overlooked aspects?
Ken
From: Pickle, Ken
Sent: Tuesday, June 16, 2009 6:42 PM

To: Hodge,'Al, Edgerton, Thom
Cc: Bennett, Bradley
Subject: Progress report on Crop Production Services
Folks,
SUMMARY of PROGRESS
a) I've heard back from three other states, two other ROs, and EPA -Washington. Still haven't heard from our state
contact in Region IV.
b) I'm persuaded now that we made the correct initial call with CPS, that the facility is captured by the federal NPDES
stormwater rules, and that consequently DWQ has the authority to require a stormwater permit, or to grant a No
Exposure Exclusion from Permitting. A closer reading of the EPA letter and the SIC codes fed me to this conclusion. It
also helped that other states are in the same place, and the one of the few states that reported back to me indicated
that this small industrial sector has not made a flap about it.
c) Once I believe we have the authority, the questions for me become, Do we want to engage in a dispute with these
folks if we have to? and, Are we at risk if we conclude that the potential for impacts is slight, and that we could spend
our resources better in other areas, and so let's let this fight pass, and move on to more productive issues? And do we
really want to take on the pemitting of potentially another —200 sites (?? you know, hearing from other states, and
some other ROs, I wonder if this number is too high?)
DISCUSSION - Input from others
Here's what I've heard from others:
a) MRO - Marcia Allocco and Mike Parker - not much happening with this type of facility in MRO. Southern States in
Iredell County has a groundwater remediation project due to discharges into an unlined pond. MRO has not mounted
an initiative with these facilities. Opinion - given the types of materials on site, and potential for surface water impacts,
it's hard to see how they could avoid regulation under NPDES stormwater.
WIRO - Linda Willis reports, again, not much familiarity with these sites. Opinion - Feed mills are particularly sloppy at
the receiving and load -out stations, and Linda would expect our type of facility to be as bad, or worse.
b) South Dakota - SIC 2875 applies for blenders/mixers of fertilizers. SIC 5191 applies to folks selling pre -mixed fertilizer
blends. Facilities that do both get a permit as a SIC 2875 facility. Not been brought up as an issue in SD.
- Maine - Two facilities in Maine. Fish kill due to lack of proper clean up after unloading. Those that sell pre -mixed
fertilizer are 5191, but "any which mix on site and then distribue to the wholesale facilty are under 2875."
- Florida -17 blending facilities covered under the Multi Sector General Permit, plus 3 facilities qualified for No
Exposure. Worked with the FDept of Agri. and Consumer Services, and the FFertilizer and Agrichemical Association to
educate and ultimately permit these facilities in 2004-2006. Noted that EPA's 1991 letter does defer to a state's
prerogative to be more stringent. Florida approaches the SIC 5191 argument by saying, in effect, "Well, in Florida you
must have permit coverage, either via the MSGP, or via a Florida Individual Stormwater Permit." This typically ends the
argument, and facilities get a permit under the MSGP.
c) Bryan Rittenhouse, EPA Washington, Water Permits Division - SIC 2875 fits perfectly what they do. SIC 287S was
created specifically for the blending/mixing'facilities. He thinks EPA's 1991 letter talks about minor mixing and blending
at a wholesale or retail operation. The NC facility as described to him is not a wholesale operation lie they're not
breaking down large lots, repackaging, and reselling.)
DISCUSSION - Looking closer at SIC and the 1991 letter from EPA
a) Consider the SIC Manual text related to SIC 2875: Storting with Division D Manufacturing The Division as o Whole:
"The manufacturing division includes establishments engaged in the mechanical... transformation of materials or
substances into new products...characteristically use power driven machines and materials handling equipment... also
included is the blending of materials" Sure sounds like CPS, Princeton, in the brood scope. CPS's contention that the site
is a wholesaler, is spoken to as well in this first part, by the notation, "The breaking of bulk, and redistribution of smaller

lots is —classified as Wholesale or Retail Trade." I would interpret CPS Princeton as not engaged primarily in the
breaking of bulk and redistribution, but rather the receiving of bulk ingredients, and the mixing and blending of them.
To my understanding this goes to the very essence of Wholesale activities, and CPS does not pass this test.
Continuing on with SIC 2875: Major Group 28 -Chemicals and Allied Products, The Major Group as a Whole:
"Establishments classified in this major group manufacture three general classes of products... used as materials or
supplies in other industries, such as ... fertilizers" Sounds like CPS, Princeton.
Continuing on with SIC 2875. lndustry group 287 -Agricultural Chemicals: "establishments primarily engaged in
manufacturing...mixed fertilizers" Sounds like CPS, to me.
Continuing on with SIC 2875: Industry code 287.5 - Fertilizers, Mixing Only: "Establishments primarily engaged in
mixing fertilizers from purchased fertilizer materials." And at the same place, further subcategorization indicating
inclusion under the same heading: "Fertilizers, mixed: made in plants not manufacturing fertilizer materials". Sounds
like CPS, Princeton.
Just by itself, this string of citations seems to present a solid logic path that identifies CPS, Princeton as a 2875 facility.
But, let's compare the facility to the other candidate industry code, SIC 5191.
b) Consider the SIC Manual text related to SIC 5191: Starting with Division F- Wholesale Trade,
The Division as a Whole:
" establishments ... primarily engaged in selling merchandise to...farm... users; or to other wholesalers... The chief functions
of establishments in Wholesale Trade are selling goods to...farm...users... In addition to selling, functions frequently
performed ...include maintaining inventories of goods;... physically assembling, sorting, and grading goods in large lots;
breaking bulk and redistribution in smaller lots; delivery" Well, Division Fdoes indicate that the establishments covered
here sell to farm users. But, somehow it doesn't seem to fit as well as SIC 2875 above. Maybe it's the absence of any
reference -to on -site manufacturing, as per CPS's circumstance. Let's keep going.
Continuing on with SIC 5191: Major Group 51 - Wholesale Trade - Non --Durable Goods, The Major Group as a
Whole: "This major group includes establishments primarily engaged in the wholesale distribution of nondurable
goods." Well, again, maybe,,,, but it feels like a stretch to conclude that selling fertilizer blended on -site is 'wholesale
distribution.'
Continuing on with SIC 5191: Industry Grouo 519 Miscellaneous Nondurable Goods - no explantory commentary
for this industry group in the Manual. Note that the Manual's classification system uses the "9" digit in the third or
fourth place to indicate a sort of miscellaneous catch all categorization for industries not elsewhere classified.
Continuing on with SIC 5191: Industrycode 5191 Farm Supplies: "Establishments primarily engaged in the
wholesale distribution of...fertilizers, agricultural chemicals, pesticides... and other farm supplies" And at the same place,
further subcategorization indicating inclusion under the same heading: "Fertilizer and fertilizer materials -wholesale". I
could buy this description for CPS, if there weren't mixing and blending at the site. But there is no description of
manufacturing activities in 5191. indeed, in the approximately 1100 four -digit industry codes in the Wholesale Trade
Division, every one carries the suffix, "-wholesale", That tells me that manufacturing is categorized back in
Division D, to the exclusion of any manufacturing in Division F. itseems tome that we have to prefer the SIC
categorization that takes into account the manufacturing blending and mixing at CPS. i feel that 2875 offers the more
specific description of what goes on at CPS, Princeton.
c) Consider three points in the 1991 EPA letter. Interestingly, CPS offers this letter as evidence that they should not be
categorized as SIC 2875, but rather 5191. That's not what the letter says, to my reading. Note:
"EPA agrees that incidental or small scale mixing and blending of fertilizers at wholesale or retail facilities
does not constitute manufacturer blending and mixing described under SiC code 2875...However, when the facility is
mixing, blending, and redistributing these materials on a manufacturing scale such that the mixing and blending
becomes the activity in which the facility is primarily engaged, that facility would then be more appropriately classified
under SIC code 2875..."
First discussion point - - Is the blending of ingredients "incidental" to their business? Absolutely not. It is the
specific purpose of their business to deliver standard blends, and customer -specified blends, blended on site. That's not
incidental, it is essential to their current mode of operation. Is the blending of ingredients, "small scale"? Well, I had
some difficulty with this one. "Small" is relative, of course. But, relative to what? The blending isn't small-scale in
relation to the other on -site activities. Indeed, we might argue that the storage bins and auger equipment provided
3

deliberately to facilitate the blending occupy by far the greatest portion of the building footprint. Since small is relative,
and since no definition is forthcoming, this point is arguable ad infinitum. It is not a fruitful discussion point. I presume
in your meeting that the facility advanced the "small scale" argument in one form or another - - ie, insignificant
environmental impact in this agricultural drainage area? or, small scale compared to a 'real' fertilizer manufacturing
facility shipping all over the southeastern US. My conception of 'small' is as good as theirs; and, it's not fruitful to
debate it without a definition. And further, recall that this is just an EPA letter, not rule.
Second discussion point - - Is this a wholesale operation or a manufacturing operation? Well, this second point
is not so important if we accept the first point. I mean, if we conclude that the blending is essential, not 'incidental', and
if we refuse to debate whether it's a 'small' operation, or if we maintain the comparison to other on -site activies that 1
suggest, then the result of this point is moot - - they don't meet the letter's exclusion criteria of BOTH having blending
that is incidental/small AND being a wholesale facitlity. But, anyway: EPA's letter implies that when the blending and
mixing become the activity in which the facility is primarily engaged, they are a SIC 2875 facilty. Again, this facility exists
in its current operating mode in order to deliver blended materials. Do you think if they stopped offering blended
materials they could stay in business? We don't really know, but I conclude that they wouldn't be blending if they could
sell unblended product without that headache and equipment cost and labor cost, of if they could sell pre -blended
product. '
Third discussion point - - Consider, "States with authorized NPDES permit programs may have more stringent
requirements with respect to storm water discharges. Under these State programs, some or all of the storm water
discharges identified in your letter may be required to submit NPDES storm water discharge permit applications." EPA
has put the industry on notice, in 1991, that they will defer to the states on this call, on the basis of our ability to be
more stringent than EPA regulations. As I understand it, this is the basis for how Florida finessed the 2875 vs 5191
argument. They essentially said, "Yeah, well maybe, but if you want a permit in Florida, here's how we do it in our state."
I'll let you know if other comments from other ROs or states come in. As of now, my conclusion is that we have the
authority to act as we have. We need to discuss project specific needs for WARO, and programmatic needs for all the
ROs and SPU.
Contrary opinions? Overlooked aspects?
Ken
E-mail correspondence to and from this address maybe subject to the North Carolina Public Records Low, and maybe disclosed to third parties.

Pickle, Ken
From: Edgerton, Thom
Sent: Wednesday, July 01, 2009 11:44 AM
To: Pickle, Ken
Cc: Moore, Bill; Hodge, AI
Subject: RE: Compost site visit in WARO region
Hello,
Thanks for taking the time, to aid in my development. i appreciate the effort and look forward to the site visits.
A conference call at 3:30 PM on July 7"' is good for Mr. Al and myself, regarding CPS -Princeton.
Thanks,
Thom
Thom Edgerton
Environmental Engineer
NCDENR - DWQ - Surface Water Protection Section
Washington Regional Office
[phone] Phone
[phone] Fax
E-mail correspondence to and from this address may be subject.to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Wednesday, July 01, 2009,9:36 AM
To: Edgerton, Thom
Cc: Hodge, Al; Risgaard, Jon; Bennett, Bradley
Subject: RE: Compost site visit in WARO region
Hi Thom, see my comments inserted in your message below.
I(en
From: Edgerton, Thom
Sent: Tuesday, June 30, 2009 3:42 PM
To: Pickle, Ken
Subject: FW: Compost site visit in WARO region
Hello,
Do you have any more information of the intent of the site visits that are to be rescheduled in E. City and Edenton?
- - Our brothers in Div of Waste Management who are responsible for permitting composting facilities have those two
locations coming up for permit renewal. DWM rules require DWQ to 'ok' each composting site before DWM can
proceed with finalizing the permit renewal. Previously this sort of 'ok' from DWQ has been more or less perfunctory, at
least on the surface water side. We are devoting more energy and a closer look at these facilities now than we have
before.
These two visits are intended to:
3) provide the basis for DWQ to assess whether the facilities have wastewater discharges, or stormwater discharges,
that should be permitted.(Many of DWM's'permitted facilities don't have DWQ permits -'- although, a good number of
those rcaily don't need DWQ permits); and,

2050) planning Grant Home Page
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Navigation, Links 205(j) Water Quality Management Planning Grant
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The 205(j) Grant Program is a federally funded program administered In North Carolina by the state
Department of Environment and Natural Resources Division of Water Quality. Limited competitive
funding is available to regional Councils of Government (COGS) for water quality management
planning efforts.
Fiscal Year 07 funds are allotted by the state in accordance with section 205(j) 'of the federal Clean
Water Act. The act states that the grants are to be used for:
Water quality management and planning, Including, but not limited to:
(A) Identifying most cost effective and locally acceptable facility and non -point source measures to
meet and maintain water quality standards;
(B) Developing an Implementation plan to obtaln state and focal Financial and regulatory
committments to implement measures developed under subparagraph A;
(C) Determining the nature, extent, and cause of water quality problems in various areas of the state.
QUO-.-t.�smaT.-�,4rr-�s.�.....-.��. �..,w'�u�'•,...rw.3.y�.��Flm* a.r�,Y'.uFa'7�k,'?'..�+�isn= (5rtw;'�r. r^;o+et8h
Staiesiare;encouragedtito:give.pnonty,to.watershed restoration:�planning.1I h I s Is a competitive grant
application process that usually occurs In or around May of each year. No match Is required but is .
preferred.
For additional information, contact Sandi Brown with the N.C. Division of Water Quality at: (919) 733- .
5083 ext. 542 or sandi,[e-mail].
FY07 Request for Proposals
FY07 205(j) Awarded Proposals
More information about the federal program is available at:
The Catalog of Federal Domestic Assistance
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512 N, Salisbury St. Raleigh; NC 27604 , (91,9)733-7015
DWQ - DENR - NCGOV
http://h2o.enr.state,ne.us/pb/205jPtanningGrantHomePage.htm 2/15/2008

2) educate us in the DWQ Central Office permitting units about the physical site conditions at typical composting
facilities. (Since our previous involvement was somewhat perfunctory, we don't have much first hand background as to
what impact these facilities might have on receiving waters, or ground waters.)
- - Background items:
I)Part of the background here is that we have been stow to respond to DWM recently, and they are impatient with our
delay causing their delay in their permitting process. We're trying to visit most sites so that we can improve our inter-
agency response time for our brothers in DWM;
2) our increased interest in composting began — 4 years ago when two very large composters came to SPU for
stormwater permits for the discharge of the runoff from their windrows. We looked at some literature data on windrow
leachate, and runoff, as well as some stormwater DMR data from a couple of sites that did have stormwater permits,
and we told those two sites, "That's not stormwater, that's wastewater, and we're not going to give you a stormwater
permit for that wastewater discharge." That threw the industry and our brothers in DWM into a tizzy, with some amount
of heated commentary back and forth. We're still working on bringing the industry around, and we're still working on
better cooperation at our end with DWM. i must say that after the initial emotional reaction from DWM, they have
been beyond professional and cooperative at their end. Really, we're the ones that need to improve on our permitting
processes, now.
3) And of course, the industryis impatient with the DWM/DWQ delay in renewing permits, and with the uncertainty of
what we might require of them as to stormwater discharges and wastewater (discharges and non -discharges). It
appears that this is a big change in expectations for their operations. Portions of the industry also still dispute our
determination that it is appropriate to require them to treat the runoff from windrows and finished compost piles as a
wastewater, not a stormwater. And of course, being responsible for their discharges is going to cost them money, and
in these very difficult economic times extra costs take on an impact and importance that is greater than it might be at
other times. Additionally, we have indications from the industry and from DWM that some of these operations are
financially fragile - - I mean, that for some of these folks, extra costs, extra delays in starting up operations can be
darnaging/fatal to the viability - - I'm riot sure to what extent this is true across the industry, but the idea that a small
operation with heavy investment in land and wheeled equipment might be vulnerable seems at least possible to me.
I was doing some preliminary preparation for the visit, mostly on the Federal SW Permitting side and was hoping with a
little more time, that I would be able to research more specific information regarding the intent of the meetings.
See above for our intent in the site visits_ A key issue in our current strategy is the distinction between stormwater and
wastewater at these facilities_ Here's the perspective we hold now, and that we are trying to get the industry to
acknowledge, across the whole industry.
- - As far as sw permitting, right now we think that this industry:
is captured for stormwater runoff,
but only from the non -processing areas,
on the basis of 40CFRI22.26(b)(14)(ii) which captures SIC 28,
and the entry in the SIC Manual for SIC 2875 Fertilizers, Mixing Only - - and the sub entry under that heading,
"Compost",
as well as SIC 2879 Pesticides and Agricultural Chemicals, Not Elsewhere Classified - - and the sub -entry under that
heading, "Soil conditioners".
=> SPU can, and has, issued sw permits for the non -processing areas of composting facilities.
- - As far as the call that the runoff from the receiving areas, the windrows, and the finished compost piles are
wastewaters, we rely on:
- Limited sw DMR data from the couple of sites that we (mistakenly?) have issued sw permits for, and that show very
high values for TSS, and BOD, and N;
- and limited data in the literature that shows that stormwater runoff from windrows has pollutant loads comparable
to, or in excess of, raw sewage (except for bacterial concentrations, which are a couple of orders of magnitude greater in
raw sewage - but even then, the runoff is orders of magnitude greater than our sw benchmarks and greater than suface
wqs);
01

Stormwater Permitting Unit
Administers the Federal NPDES and State
Stormwater Management Programs
o Stormwater Management Programs:
• Federal NPDES (National Poltatant Discharge
ltimination System)
o Industrial Achi lies
o Coralmotteh Achvitls.
o Municipal Separate Storm Bawer Sysleme (MS41)
• State
o Session Law 3t168-246
o Nutrient Sensitive Waters
o High Quality Waters, Outstanding Resource Waten,
Coastal Rules
0 NC Stormwater BMP Manual
lff a . a sl•. —w s..asu h•.m— P.-s aeag Vas
Federal NPDES Stormwater
Program: Construction Activities
o Activities that disturb
one acre or greater of
land are required to
obtain a NPDES general
stormwater permit
• Autornatically istrued and
distributed by Division of
Land Resources
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Federal NPDES Stormwater
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salvage, mines, marinas...) are required to
obtain a NPDES stormwater permit
SOWziiter PerstdlS3n4 Unit
�a
o r vtaws rtvrmx:fer psrtsvt appheadoea and 1e.uea permits
o devalapa general atormw ter permits (currentlytu actives .
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w.uaal. a st..m..+•r s.�a ss•rmwaNr P..e.fa�y tied
3. Federal NPDES Stormwater
Program: MS4s
o Two Phases of Implementation:
• Phase 1: MS4s •*suing populations of 100,000 or more
• Phase II: M54s serving populations loss than I00,000
o Each subject local government 't ;
is required to develop and
implement a stormwater t .
management program
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- and wastewater definitions in both federal NPDES rules and NC General Statutes that effectively establish that liquids
generated from a manufacturing process (like the manufacturing process going on in a windrow) are wastewaters.
>the Aquifer Protection Section can, and has, permitted land application systems and recycle systems for
runoff/leachate. (Jon, have I got that right?)
=> But, as far as I know, NPDES wastewater does not have any permits for treatment plants for wastewater discharges
from composting operations.
I hope that you had a great vacation. I expect that my time away will be very limited, but I'm looking forward to this
Holiday weekend and any time away.
At what point are we with CPS -Princeton? I was expecting mention of a conference call to initiate direction, but I have not
heard anything. Have you heard anything or received any other comments?
- - Let's set up a call next week. I'm pretty much booked for today, and Bradley's not available after today until next
week. i think one of the last things I did before a week's vacation was to summarize via email that we have the authority
to regulate CPS, ie, that we think the Princeton facility is a manufacturing facility, not a wholesale distribution facility.
However I'm suggesting that we NOT mount an industry -wide initiative, but that we deal with the facilities as they come
to our attention via substantive complaints. Are they regulated? - Yes. Are they a recognized problem industry?.- Not
according to feedback we get from the ROs. Could we spend our time more effectively with more serious stormwater
problems? - I think so, but that's a call that we need Bradley and Al to either support or correct me on. Have we set up
an inequity in the industry if we only effectively regulate CPS Princeton, but not their other operations or competitors?
Truly, I think the burden that a sw permit imposes has been deliberately minimized in our program, and that I'm not
much sympathetic with the argument that it's unfair for us for require a permit for folks that we determine to be a
water quality risk, or that present significant potential to contribute to water pollution.
=> I think what all this leads to is for us to go back to CPS Princeton and tell them that we still can't call their site, 'No
Exposure`, in its current condition, and that they have to pony up $860 to apply for an individual stormwater discharge
permit. Seems pretty non -burdensome to me.
- - How about a conference call for Thom, Al, Bradley, and me on Tuesday, July 7, and 3:30? Between Bradley and me,
that's a good time for our schedules.
Ken
Please respond with more information or call if you would like to discuss.
Thanks,
Thom
Thom Edgerton
Environmental Engineer
NCDENR - DWQ - Surface Water Protection Section
Washington Regional Office
[phone] Phone
{252} 946-9215 Fax
E-mai! correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Hodge, Al
Sent: Monday, June 29, 2009 10:10 AM
To: Edgerton, Thom; Vinson, Scott; Dumpor, Samir; May, David; Moore, Bill
Subject: FW: Compost site visit in WARO region
fyi

Federal NPDES Stormwater
Program: Post -construction
oPhase I and Phase II communities
• Must develop and
implement a
post -construction
stormwater runoff
program for new
development and
redevelopment
areas
W W r i Nxrw , 4ud
purw•ru P•rrlW VWI
15 State Stormwater Programs:
I Post -construction
o Nutrient Sensitive Watersheds
• Neuse River Basin
o Targeta nitrogen runoff from urban areas
o Stormwater management program rules affects 15
most populous communities in the Basin
• Tar -Pamlico River Basin
o Targets both nitrogen and phosphorous pollution in
siormwaler runoff
a Program affect.
11 most o Moue r �f
P P
communities in
the Garin a �....
orwa...r.. i..l
W.Nulr a Nrrw•rr 4arvi N..mwvty. P..—iwva VWt
State Stormwater Programs:
Post -construction
o Universal Stormwater Management Program
• a voluntary program that will allow
local government's to satisfy most
existing atormwaler requirements
with a single program (does not
establish now requirement.
o Threatened and Endangered Species Program
• New development activities in s
certain watersheds may be
subject to more stringent
requirements because of
threatened or endangered
species issues ..
Waeavaa ■ aarrawarr iru.i Nvrrwat.r Rrvrlttl.P eatl
�} Federal and State Stormwater
l Programs: Post -construction
oSession Law 2006-246
to Expands post -construction coverage
beyond the incorporated limits
• Requires stormwater controls for
projects that disturb one acre or greater
• Phase 1 and H communities can adopt
more stringent t• -
ordinances
1d.4aw•r F Narw.lir Huai 6larswalu Pra11WP V W
State Stormwater Programs:
i
Post -construction
o High Quality Waters, Outstanding
Resource Waters, Coastal Stormwater
• Protect sensitive waters from the non -point
source impacts of new development &
redevelopment by:
o Trying to minimize impervious cover
c Using passive stormwater management where
possible, engineered controls where necessary
• The Coastal Rules
were recently
w
revised to provide � c , ,r � _-;z y
more protection ' : ` .1
C3
W rtl.n�r a arrmw.lrr arurei Nnrw•Irr P.rrlllly. V W I
NC Stormwater BMP Manual
North Carcli—
o Last Updated in 2007 elA•l,'. wrt•r pvaley
• Individual chapters Stormwater
are periodically Was
updated ;?' Best Management
o Can be found online: `mow t Practices
httaJlh3 fa�a hum. i Manual
c Jug,
W.au�r ! Naraw.W arrsi abrr,rWa Arrlttly VW I
2

From: Pickle, Ken
Sent: Monday, June 29, 2009 9:54 AM
To: Hodge, Al
Subject: Compost site visit in WARO region
Al,
We've had to postpone tomorrow's visit to the composting facilities in the Elizabeth City area. We will reschedule
toward the end of July. Sorry for any inconvenience this may have caused.
Ken
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties.

R• . is ,. .. ,. .... .
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Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, July 14, 2009 9:54 AM
To: Hodge, Al; Edgerton, Thom
Cc: Bennett, Bradley
Subject: CPS letter
Attachments: CPS Princeton intent to assess.doc
Guys,
Please review, comment. Thanks,
Ken
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties,
/� •/.� _ _/v // ru u_p Got �o � o .ri -10 YP a �l r:
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Culvert Calculator Report
CULVERT C
Solve For: Headwater Elevation
Culvert Summary
Allowable HW Elevation
581,00 ft
Headwater Depth/Height
0.54
Computed Headwater Elevation
580,48 ft
Discharge
1.40 cfs
Inlet Control HW Elev.
580,43 ft
Tailwater Elevation
0.00 It
Outlet Control HW Elov.
580.48 ft
Control Type
Entrance Control
Grades
Upstream Invert 579.80 ft . Downstream Invert 579.10 ft
Length 39,00 ft Constructed Slope 1.7949 %
Hydraulic Profile
Profile
Slope Type
Flow Regime
Velocity Downstream
$2
Steep
Supercritical
5.18 fus
Depth, Downstream
Normal Depth
Critical Depth
Critical Slope
0.34 ft
0.34 ft
0.47 ft
0.5285 %
Section
Section Shape
Section Material
Section Size
Number Sections
Circular
Concrete
15 inch
1
Mannings Coefficient
Span
Rise
0.013
1.25 ft
1.25 ft
Outlet Control Properties
Outlet Control HW Elev.
Ke
560.48 It
0.20
Upstream Velocity Head
Entrance Loss
0,17 ft
0.03 ft
Inlet Control Properties
Inlet Control HW Elev.
580,43 ft
Flow Control
N/A
Inlet Type
Groove end w/headwall
Area Full
1.2 ft'
K
0.00180
HDS. 5 Chart
1
M
2.00000
HDS 5 Scale
2
C
0,02920
Equation Form
1
Y
0.74000
Title: White Deer Park Project Engineer. Islate
q:1... lstormwaterloulvert masterlchatham moq.cvm Stewart Engineering CulvertMaster v3.2 [03.02.00.01)
06/24/09 10:56:06 AMC) Bentley Systems. Inc. Haestad Methods Solution Center r Watertown; CT 06795 USA [phone] Page 3

A
i
y W
NCDENR
North Carolina Department of Environment and Natural RPsoUrces
Division of Water Quality
Beverly Eaves Perdue Qoieen H. Sullins Dee Freeman
Governor Director Secretary
July 14, 2009 1
Ms. Nancy Vincek
Crop Production Services
1160 Brake Road
Rocky Mount, North Carolina 27801
Subject: NOV-2007-DV-0298
Intent to assess
Crop Production Services, Princeton
Wayne County
Dear Ms. Vincek:
The Division has considered your No Exposure Certification received November 12, 2008, for your
Princeton facility. At this time, DWQ cannot grant CPS Princeton the No Exposure Exclusion from
Permitting. This determination was based on the following two considerations.
On November 17, 2008, DWQ conducted an inspection for the specific purpose of
determining whether no exposure conditions had been achieved at the site. We observed
that the lime pile was not fully covered, i.e. that the tarp covering had not been
successfully and fully implemented, as required in our October 14, 2008, letter to you, as a
condition of granting the No Exposure Exclusion from Permitting. Further, at the time of
the visit, CPS personnel commented that the tarp was extremely difficult to deploy. Along
with our observations that day, this comment calls into question whether the tarp can be
reliably deployed in the future.
DWQ observed additional areas of exposure that we had not previously considered, but did
comment on to CPS staff at the time of our inspection. Specifically, stacks of pallets,
outside storage of tires and metal hoppers, and other site business related implements, all
stored outside. When stored outside, these materials constitute exposure.
DWQ has also reviewed the 1991 correspondence received from CPS in our meeting June 12,
2009, at DWQ's Washington Regional Office. CPS provided us with the several pieces of
correspondence between various industry organizations and the EPA concerning proper SIC
classification of farm supply facilities, and indicated that the correspondence supported the
conclusion that CPS Princeton was not subject to NPDES stormwater regulations, and that
consequently a stormwater discharge permit may not be required at CPS Princeton. We disagree
that the 1991 summary letter from EPA supports that conclusion at CPS Princeton. Specifically,
we view the mixing and blending of granular and liquid materials at Princeton as neither incidental
nor small scale with respect to the current operating mode of the facility. On this basis the SIC
classification 2875 most closely describes activities at CPS Princeton, and the facility is captured
by the NPDES stormwater regulations.
Wellands and Stormwater Branch One
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 North C`lro l l m
Location 512 N. Salisbury St. Raleigh, Nor117 Carolina 2760.1
Phone. [phone] FAX: [phone] Customer Service: 1-877-623-6748 /�atulall ff
Inlernet: wwvr ncwaterquafity.crg N iJ
An Faual OnnortimiPJ 1 Vrmaliw An inn Fmnlnv-r

Table of Contents
Hydraflow Hydrographs by Intelisolve
C9006.gpw
Wednesday, Jun 24 2009, 1:33 PM
Hydrograph Return Period Recap............................................................................ 1
1 -Year
SummaryReport....................................................................................................................... 2
HydrographReports................................................................................................................. 3
Hydrograph No. 3, Reservoir, D Area to Pond A ...................... 3
PondReport....................................................................................................................... 4
10 - Year
SummaryReport..................................................................................................................... 5
HydrographReports................................................................................................................. 6
Hydrograph No. 3, Reservoir, D Area to Pond A................................................................... 6
PondReport ....................................................................................................................... 7
100 - Year
SummaryReport ................ ....................................................................................................... 8
HydrographReports................................................................................................................. 9
Hydrograph No. 3, Reservoir, D Area to Pond A .............. .................... 9
PondReport..................................................................................................................... 10

Ms, Nancy Vincek
•1 Crop Production Services
July 14, 2009
Washington Regional Office staff and I believe that a No Exposure Exclusion from Permitting may
still be achievable at your site, pending a feasible response to the lime pile exposure and to the
other exposures observed at Princeton. We also believe that a stormwater discharge permit is a
feasible option for Princeton. We are requesting that you either take additional actions to achieve
no exposure and subsequently submit a new No Exposure application; or, that you submit an
individual stormwater permit application.
The Washington Regional Office will begin NOV penalty and assessment procedures on
Monday, August 17, 2009, if DWQ has not received either a revised, completed
application for the No Exposure Exclusion from Permitting, or a completed application
for an individual stormwater discharge permit.
Please contact either Thom Edgerton in Washington, or me in the Central Office with any
comments or questions.
Sincerely,
Ken Pickle
DWQ Stormwater Permitting Unit
cc: DWQ Washington Regional Office, Al Hodge
DWQ Washington Regional Office, Thom Edgerton
DWQ NPS Assistance and Compliance, Shelton Sullivan
DWQ SPU, Bradley Bennett

Hydrograph Return Period Recap
Hyd.
Hydrograph
Inflow
Peak Outflow (cis}
Hydrograph
No.
type
Hyd(s)
description
(origin)
1-Yr
2-Yr
3-Yr
5-Yr
10-Yr
25-Yr
50-Yr
100-Yr
2 5CS Runoff
------- 7.99
10.97
19.33
24.43
28.44
32.61
Drainage Area to Pond A
3 Reservoir
2 1.17
6.32
i
- ----
14.03
19.13
24.26
29.01
D Area to Pond A
Proj. file: C9006.gpw
Wednesday, Jun 24 2009, 1:33 PM
It ---]
Hydra(low Hydrographs by Intelisolve

p �®
NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly. Eaves Perdue
Governor
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ms. Nancy Vincek
Crop Production Services
1160 Brake Road
Rocky Mount, North Carolina 27801
Coleen H. Sullins
Director
July 21, 2009
Natural Resources
Dee Freeman
Secretary
/ 0A v* N �n�asu re,
Subject: NOV-2007-DV-0298
Intent to Assess
Crop Production Services, Princeton
Wayne County
Dear Ms. Vincek:
The Division has considered your No Exposure Certification received November 12, 2008, for your
Princeton facility. At this time, DWQ cannot grant CPS Princeton the No Exposure Exclusion from
Permitting. This determination was based on the following two considerations.
• On November 17, 2008, DWQ conducted an inspection for the specific purpose of
determining whether no exposure conditions had been achieved at the site. We observed
that the time pile was not fully covered, i.e. that the tarp covering had not been
successfully and fully implemented, as required in our October 14, 2008, letter to you, as a
condition of granting the No Exposure Exclusion from Permitting. Further, at the time of
the visit, CPS personnel commented that the tarp was extremely difficult to deploy. Along
with our observations that day, this comment calls into question whether the tarp can be
reliably deployed in the future.
• DWQ observed additional areas of exposure that we had not previously considered, but did
comment on to CPS staff at the time of our inspection. Specifically, stacks of pallets,
outside storage of tires and metal hoppers, and other site business related implements, all
stored outside. When stored outside, these materials constitute exposure.
DWQ has also reviewed the 1991- correspondence received from CPS in a meeting June 12, 2009,
at DWQ's Washington Regional Office. CPS provided us with the several pieces of correspondence
between various industry organizations and the. EPA concerning proper SIC classification of farm
supply facilities, and indicated that the correspondence supported the conclusion that CPS
Princeton was not subject to NPDES stormwater regulations, and that consequently a stormwater
discharge permit may not be required at CPS Princeton. We disagree that the 1991 summary
letter from EPA supports that conclusion at CPS Princeton. Specifically, we view the mixing and
blending of granular and liquid materials at Princeton as neither incidental nor small scale with
Wetlands and Stonmwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St, Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Cusfarrier Service:1-877-623-6748
Internet: www nmaterquality.org
An Equal Opportunily 4 Affirmative Action Employer
olte
NoI-thCarolina
Naturally

Ms. Nancy Vincek
Crop Production Services
July 21, 2009
respect to the current operating mode of the facility. On..ttiis basis the SIC classification 2875
most closely describes activities at CPS Princeton, and the facility is captured by the NPDES
stormwater regulations.
Washington Regional Office staff and I believe that a No Exposure Exclusion from Permitting may
still be achievable at your site, pending a feasible response to the lime pile exposure and to th'e
other exposures observed at Princeton. As an alternative; we also believe that a stormwater
discharge permit is a feasible option for Princeton. We are requesting that you either take
additional actions to achieve no exposure and subsequently submit a new No Exposure
application; or, that you submit an individual stormwater permit application.
The Washington Regional Office will begin NOV penalty and assessment procedures on
Monday, August 24, 2009, if by that date DWQ has not received either a revised,
completed application for the No Exposure Exclusion from Permitting, including a
narrative description detailing proposed changes to achieve No Exposure, or a
completed application for an individual stormwater discharge permit.
Please contact either Thom Edgerton in Washington at [phone], or me in. the Central
Office at [phone] with any comments or questions.
Sincerely;
Ken Pickle
DWQ Stormwater Permitting Unit.
cc: DWQ Washington Regional Office, Al Hodge
DWQ Washington Regional Office, Thom Edgerton' .
DWQ NPS Assistance and Compliance, Shelton Sullivan
DWQ SPU, Bradley Bennett
6

Pickle, Ken
From: Pickle, Ken
0ent: Friday, August 14, 2009 2:50 PM
0: Pickle, Ken; Edgerton, Thom; Hodge, Al
Cc: Bennett, Bradley
Subject: RE: Crop Production Services green card status
Update: August 14, 2009 - still no communication from CPS; 23 days past delivery of letter, and 10 days remaining for
submittal of application or certification of no exposure
Ken.
From: Pickle, Ken
Sent: Monday, July 27, 2009 9:19 AM
To: Edgerton, Thom; Hodge, Al
Cc: Bennett, Bradley
Subject: Crop Production Services green card status
DWQ's Certified Mail green card was signed by Donna Taylor at CPS's Rocky Mount address. The return card was post
marked Wednesday, 7/22/09, from the Rocky Mount post office. Our deadline for submittal of an individual stormwater
permit application, or another No Exposure submittal, was stated in our 7/21/09 letter as August 24, 2009. With
delivery of our letter accomplished on July 22, 2009, that gives CPS 33 calendar days from receipt to provide one
submittal or another. I've had no additional communication from Ms. Vincek and CPS as of this morning.
Ken
-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties.

E
E
Jul., 16. 20H 1:21AM CHAIi-:14EC1i uTY-[Ri NO, 1975 K 22
flowing water is either lion-emorgerit, sparse, or absent. Vegetated shallows are considered to ba
open waiters. Examples of `open waters" include rivers, streams, lakes, and ponds.
Ordinnry ftiz Water uik: An ordinary high watermark is a line onthe alcrrre
established by the fluctuations of water and indicated by physical rhttracteristies, or by other
appropriate means fha.t consider the ehurincteriatics c&the ; urrounding areas (,see .13 t. R
32.8,3(e)).
Perennial stream: A pertnaial streAxn has flowing water year- otuid during a typical year.
Tbc w otcr table is located above the stream bed for most ofthe yeftr. Groundwater is the primary
source of water ror stream flow. Runoff from rainfall is a Supplemental snurce of water for
strcnin (]ow.
Prgy"C able: Available and capable of being done after taking into cousideratiott cost,
existing tealmo logy, and logistics in light of overall projea purpoaes.
f'rr:-run.Strur.linn nr�ti ufio�; A request submitted by flee pmject proporlurst In the Corps
for confirination that u paiticular activity is authorized lay nationwide permit. Tho request may be
a pcimit appilcation, lettoc, or similar document that includes informntion about the proposed
work raid its antiaipatcd euviroxmwcnwl cFlccts. {'rc-cunslrtictian notification may br. required by
the wrens and conditionit of it nationwide permit, or by regional conditions. A pffl-construction
notification way be voltui0trily sobinittcd in rases wbere pro-constn►ction notification is not
required and the project proponent wants confirmation that the activity is authorized by
nationwide permit. .
PreServalron: 'file removal of a threat to, or preventing file decline of, aquatic resources
by an action in or near those aquatic resources. ,mis tofu, hiciudGs aetivjties coioroonly
associated with the protection and =interimiec of aquatic resources through tho irnplonientatiori
of uppropriato legal and physical mechanisms, Preservation does not reslklt in a gain of stgllaft
resourea area or functions.
Re-establiA)i=: The manipulation of the physical, chornical, or biological
characteristics of a Site with the goal of tenirning nntural/liktWiC f metlons to a former aquatic,
resome.c. Re-establishment results in rebuilding a former uiluatie resource; and results in a gain in
aquatic resource aicn,
Reiiatiliftatroll: The manipulation of the physical, cheinic al, or biological rlvararterlstles
of a site with iltc goul ol'rcpnixirag nattiralthistoric functions to a degraded aquatic resource.
Rehribifittition ro-sults in a gain in aquatic resaurCe fiusrtion, but does not result in at gain in
aquatic, rescurne, area.
Be. li rarr�t�: The manipulation of the physical, chemical, or biological characteristics of it
situ with kilo goal ofreturning naturttllhistorir, finictions to a former or degraded nquatic resource.
For tilepurposu ofiracking riot sgrtins in aquatle resaurce area, restoration is divided into two
rst0porle5: re-estabiishinent and reilabilitatioit.
Iffie arrrysl nnc rl�lx: Rifflr, and pool coni7}�lcxes are special ayuatiu sites uncles floe
404(b)(1) Guidelines. piffle and pool Complexes somalimes characterir.0 zteep gradient sections
of stre-Ams. S+sch stream sections are reoogni7.ablo by their hydraulic char:u:teristics. The rapid
movement ofwater over a course 5ubsimle in riffle, results in a rough flow, a turbident surface,
and high dissolved oxygen levels in the water. Pools are deeper areas associated tv'ith riffles. A
Mower stt'eain velocity, a streaming f1mv, a:iniooth surface, and a finer substrate characterize
pools.
Rl Jnrlrr rirrns: Riparian areas are lairds adjacent to streams, lakes, and eshnarine-aurine,
shorelines. Ripnriun areas are transitional between tCr74:5tTial and aqundo ecosystems, through
15
� �4

Central Files: APS_ SWP_
10121 /09
Permit Number NCGNE0656 Permit Tracking Slip
Program Category Status Project Type
NPDES SW A1,9 ee4l x l J ,�Ac�tive New Project
Permit Type Files `&If rP 111 , Version Permit Classification
Stormwater Discharge, No Exposure Certificate 1.00 Individual
Primary Reviewer �I'd'" Permit Contact Affiliation
ken.pickle
Coastal SW Rule
Permitted Flow
Facility Name
Crop Production Services - Princeton #0242
Location Address
141 Luby Smith Rd
Princeton NC 27569
Major/Minor Region
Minor Washington
County
Wayne
Facility Contact Affiliation
Donnie C. Wiggs
701 Ebenezer Church Rd
Goldsboro . NC 27530
Owner Name Owner Type
Crop Production Services Inc Non -Government
Owner Affiliation
Kirk Williams
7251 W 4th St
Greeley CO 80634
Dates/Events
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
10/20/09 08/25/09 10/20/09 10/20/09 10/20/09 10/19/14
Regulated Activities
Stormwater (activities not covered)
Outfall NULL
Re uested/Received Events
Region comments on draft requested 10/20/09
Region comments on draft received 10/20/09
Waterbody Name Stream index Number Current Class Subbasin
ur A dean--4," 0vw4 zz- ss wsu- msA-) v3-o4-12.
27 _ (.Js S.5) a.ol A/Lrk/ 'OS-1ii Cie waA')

Last Accessed 7130120 8 9:09AM
1) Permits with wastewater: Mining (NCG 020000) and Ready Mix (NCG 140000) permits
ma,v have wastewater components (but not necessarily, see; the technical requirements
section for each pen -nit).
2) SA and WS Waters:
a. Notify the following people at the same time; as contacting; the region,
is SA (shellfish) Waters; Shellfish Sanitation (See Table 6 for a list of
contacts)
ii. WS (water supply) Waters: DEH (See "fable 5 for a list of contacts.)
b, Receive permission from them before scald out the COC if have a wastewater
component and drains to either SA or WS waters, (sec contacts in this document
and example memos in shared f-older, Shared/Gui(tance/Permit_Apprc>val_DEI-I
and I'ermit_Approval_Shcllf'isli Sanitation)
3) ORW and 14WQ Waters:
a. ORW (Outstanding Resource Wa(ers):
i. See guidance document stored under Shared/Guidance/ORW Policy
ii. Lockwood Folly: No new or expanding wastewater discharges in Lockwood
Folly (Lumber River Basin): "... area extending north from the intracoastal
waterway to a line extended from Genoes Point to Mullet Creek." See
guidance document stored under Shared/Guidance/I'crmits_ORW Policy
b. HQW (High Quality Waters):
i. Lockwood Folly: No new or expanding; wastewater discharges in Lockwood
Folly (Lumber River Basin): "... area extending north from the intracoastal
waterway to a line extended fi-om Genoes Point to Mullet Creek," See
guidance document stored under Shared/Guidance/Permits—ORW Policy
H Some HQWs are also Primary Nursery Areas (PNAs). This classification is
done by Fish and Wildlife, and does not show up in RIMS. Maps are
available for these areas http://www.ncdmf.net/maps/FNA_maps/. Unlike
trout waters, which are also often classified as HQW and have specific TSS
limits in the mining permit, PNA is not adequately protected in the current
permit text for mining. (Ready mix does not have specific "1 SS limits for
trout or PNA waters). (Sets 15A NCAC 02B .0224 }-High Quality Waters
(1)(b)(11)), Ultimately, the permit will need to be revised to protect PNA
waters (anti the ready mix permit will also necd-to protect trout). The
cun-cnt process is to attach a supplement sheet for these waters to the
permit.
iii. See Appendix J for the PNA supplement sheet and Appendix C for cover
letter language.
iv. The supplement references the 7Q10 flow. 7Q10 can not be calculated for
tidal waters. There is not a GIS layer for tidally influenced areas. This
information is determined frown local knowledge. Contact the Region to .
determine if this is a tidally -influenced area.
1. Not tidally influenced, Contact USGS (J. "Curtis" Weaver,
[e-mail] usgs.gov or 571.4043) to detennine what this flow is.
Be SLtre to provide -him with a map of where.(he discharge will enter
the surface water. Reference this flow in the cover letter of the
permit: An example cover letter is included in "Guidance" folder on
the share drive,

Ai
CDENR
North Carolina Department of Environment and Natural
• Division of Water Quality
Beverly Eaves Perdue_ Coleen H. Sullins
Governor Director
October 20, 2009
Ms. Nancy Vincek
Crop Production Services
1160 Brake Road
Rocky Mount, North Carolina.27801
Resources
Dee Freeman
Secretary
Subject: Conditional No Exposure Exclusion NCG.NE0656
NOV-2007-DV-0298
Crop Production Services, Princeton
Wayne County
Dear Ms. Vincek:
The Division has considered your second No Exposure Certification received August 25, 2009, for
your Princeton facility. Your submittal included a three -page transmittal letter, a completed five -
page DWQ No Exposure Certification form, -a three -page Conceptual Environmental Plan Narrative
by Bay Environmental with appended figures showing the layout and construction details of your
proposed site modifications for no exposure. (There is no permitting fee for the No Exposure -
Exclusion from permitting, and appropriately none was included in your submittal.) As I conveyed
to you by phone last month,'DWQ has determined -to gfantyour second request for the
Conditional No Exposure Exclusion from Permitting. I apologize for my delay in following up with
this written notification. Our determination was based on the following considerations.
---:--Recall-that-in-response to DWQ'S November 171 2008 inspection for the specific purpose of�
determining whether no exposure conditions had been achieved at the site, DWQ denied
your previous first request, based in part on the reported and observed problems with
deploying a tarp over the large lime pile on your site. We feel that your more recent
submittal provides a more reliable stormwater control approach.. We commend your
.resourcefulness in subsequently responding to what we all should have recognized at the
time as an inadequate initial approach.
We believe that your proposal to install stormwater'treatment and control measures as
described in the transmittal letter and in the Conceptual Environmental Plan' Narrative, and
generally consisting of re -grading specific site areas, planting grassed and otherwise
vegetated areas, windbreaks, and infiltration areas, represents an innovative and effective
approach to stormwater and nutrient discharge control given the site circumstances at
Princeton. Some, aspects also represent a -new approach for North Carolina's NPDES
stormwater permitting program.
Your transmittal letter reported site modifications already achieved to reduce exposure in
response to our discussions about your first request for No Exposure. And, this second
submittal also included additional minor modifications and improvements on.several other.
of the potential exposure areas as identified in subsequent correspondence with DWQ.
Wetlands and Stonnwater Branch
1617 flail Service Center, Raleigh, North Carolina 27699.1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 919-807-M 1 FAX: S19-807-64941 Customer Service: 1-877-623.6748
Internet www.nCwalerqualily.org
An Equal opportunity 1 Affirmative Action Employer
One
NorthCarolina
Naturally

Ms. [Nancy Vincek
Crop Production Services
octoUer 20, 2009
Page 2 bf 2
We considered both the sensitivity of the receiving water, and the realistic constraints at
the Princeton site. The receiving water is classified as WS-IV (Water Supply Watershed IV)
and NSW (Nutrient Sensitive Water). North Carolina has stormwater control programs
especially crafted to protect selected sensitive waters in both of these classifications.
Generally we try to pay special attention to these waters. ,We believe your proposals will
proveto provide exemplary protection for.this sensitive receiving water.
As far as our. consideration of realistic site constraints,. our perspective is that it is not
realistic to expect that no exposure conditions could be fully achieved and perfectly
maintained in the long run without considerable expense, given the site configuration and
site activities at Princeton. Our granting of the Conditional No Exposure Exclusion from
Permitting for Princeton is somewhat experimental for us in that while the site may not
fully meet our previous and conventional concept of no exposure, we believe your
proposals provide a degree of protection that might not be so readily achievable under the
conventional elements of a stormwater permit. Consequently, for the moment we consider
our agreement to grant the requested exclusion from permitting for Princeton as a one
time regulatory arrangement that we intend to track to see if it will prove as protective_ as,
we hope. Thanks for working with us in this regard.
Please note that by our acceptance of your No Exposure Certification you are obligated to maintain
the. conditions, features, and improvements identified in your submittal package included with
your signed No Exposure Certification received August 25, 2009. Your Conditional No Exposure
Exclusion from Permitting expires in five years (October 19, 2014). At that time you must re-
certify with the Division, or obtain NPDES discharge permit coverage for any stormwater
discharges -from the Princeton site.
Your conditional exclusion from permitting does not affect your facility's legal requirements to
obtain environmental permits that may be required under other federal, state, or local regulations
or ordinances.
- If -you- have- a ny-q uest io ns,-p lea se -con tact either—Thorn-Edgerton_in-Washington-at-(.252)_946-
6481, or me. in the Raleigh central office at [phone].
Sincerely,
Ken Pickle
DWQ Stormwater Permitting Unit
cc: DWQ Washington Regional Office, Al Hodge
DWQ Washington Regional Office, Thom Edgerton
DWQ NPS Assistance 'and Compliance, Shelton Sullivan
DWQ SPU, Bradley. Bennett
2

NCDENR
•4,—,. C _ �ti �r. 0.
FHvr•,»ur.r.:nn Nmllw N�a..-r_�s
Division of Water Quality / Surface Water Protection
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
NCGNE0000
NO EXPOSURE CERTIFICATION
FOR AGENCY USE ONLY
Date Received
Year
Mo h lla
0
Z
Certificate of Coves
Please check here if this is a renewal: ❑ RENEWAL
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit
based on NO EXPOSURE: z
Submission of this No Exposure Certification constitutes notice that your facility does not require permit
authorization for its storm water discharges associated with industrial activity in the State of North
Carolina because it qualifies for a no exposure exclusion_ A condition of no exposure at an industrial
facility means all industrial materials and activities are protected by a storm resistant shelter (with some
exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste
products. Material handling activities include the storage, loading and unloading, transportation, or
conveyance of any raw material, intermediate product, final product or waste product. A storm resistant
shelter is not required for the following industrial materials and activities: drums,, barrels, tanks, and
similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak.
"Sealed" means banded or otherwise secured and with locked or non -operational laps or valves;
adequately maintained vehicles used in material handling; and final products, other than products that
would be mobilized in stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion.
in addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for
individual oulfalls. It any industrial activities or materials are, or wilt be, exposed to precipitation, the
facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure
Certification form, you certify that a condition of no exposure exists at this facility or site and are
obligated to comply with the terms and conditions of 40 CFR 122.26(g).
You must re -apply for the No Exposure Exclusion once every five (5) years.
For questions, please contact the DWO Regional Office for your area. (See page 5)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspiondence will be mailed):
Name ___CroT) pjoduction ,Services Inc _ -
Contact Kirk Williams, fnvirornnental Manager
Street Address 7251 W. 4th Street
City Greeley State 00 ZIP Code 80634
Telephone No. 970-347-1542 Fax_ — 970-347-1535
2) Location of facility producing discharge:
Facility Name Crop Production Services - Princeton #0242
Facility Contact Phillip Shannon Peedin, Manager
Street Address 141 Luby ,Smith Goad
City Princeton State NC_ ZIP Code 27569
County Wayne
Telephone No. 919-735-8800 Fax: [phone]
Page 1 of 5
SWU-NE-071408 Last revised 7/14/2008

NCGNEOOOO No Exposure Certification
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). Hwy. 70 East of _Princeton. Just as you
cross the Wayne County line, turn right onto Luby Smith Rd. Location on Left
(A copy of a map with the facility clearly located on it should be included with the certification application,)
4) Is the facility located on Native American Lands? ❑ Yes] No
5) Is this a Federal facility? ❑ Yes N No
6) Latitude 35.271637 Longitude-78.08122 (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
ff Existing Date operation began 1963
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Wes this facility or site ever covered under an NPDES Stormwater Permit? © Yes )I No
If yes, what is the NPDES Permit Number?.
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 5 1 9 1
10) Provide a brief description of the types of industrial activities and products produced at this facility:
Agricultural products retailer, including fertilizer~, r_rnn me Pc-t ; nn
chemicals with fertilizer blending ations
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
IM No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion. /
�1 [�o
a. Using, storing, or cleaning industrial machinery or equipment, and areas where
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
c. Materials or products from past industrial activity
d. Material handling equipment (except adequately maintained vehicles)
e. Materials or products during loading/unloading or transporting activities
f. Materials or products stored outdoors (except final products intended for outside
use [e.g., new cars) where exposure to stormwater does not result in the discharge
of pollutants)
❑ Yes
❑ Yes
❑ Yes
© Yes
❑ Yes
❑ Yes
Page 2of5
5WU-NE-071408 Last revised 7/14/2008

NCGNEOOOO No Exposure Certification
VNo
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks,
© Yes
and similar containers
/
h. Materials or products handled/stored on roads or railways owned or maintained by
❑ Yes
U1 No
the discharger
%
i_ Waste material (except waste in covered, non -leaking containers [e.g., dumpsters])
❑ Yes
2No
j. Application or disposal of process wastewater (unless otherwise permitted)
❑ Yes
izJ No
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not
❑ Yes
l/No
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
/
1. Empty containers that previously contained materials that are not property stored
❑ Yes
Cf No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers
❑ Yes
o
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs). If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or i/Yes ❑ No
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? if so, is it free of any 21 Yes ❑ No
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers © Yes ❑ No
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored d Yes ❑ No
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for any amount of Title III Section 313 /yes © No
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals?
d. is secondary containment provided for any amount of hazardous substances? [/Yes ❑ No
e. Are release valves on all secondary containment structures locked? r Yes ❑ No
15) Hazardous Waste:
Page 3 of 5
SWU-NE-071408 last revised 7/14/2008

NCGNE0000 No Exposure Certification
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes MNo
b. Is this facility a Small Quantity Generator (less than 1000 kg, of hazardous waste ❑ Yes C6/No
generated per month) of hazardous waste? /
c. Is this facility a Large Quantity Generator (1000 kg_ or more of hazardous waste ❑ Yes �d No
generated per month) of hazardous waste?
If you answered yes to questions b, or c., please provide the following information:
Type(s) of waste:
How is material stored: _
Where is material stored:
Flow many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
16) Certification:
I certify under penalty of taw that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.25(g)(2)).
understand that I am obligated to submit a no exposure certification form once gym five (5)years to the North Carolina
Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into
which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water
Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request -
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty
of law that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete- I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
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; Phi-Uip_ShapI1 n pjL e 3i n
Title: /—"� Branch Manac
(Signature of
-6J �=1
(bate Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCOENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also j
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
Page 4 of 5
SWU-NE-071408 Last revised 7/14/2008

NCGNE4000 No Exposure 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).
There is currently no fee for a No Exposure Exclusion.
Final Checklist
This application should include the following items:
This completed application and all supporting documentation.
© A map with the location of the facility clearly marked.
Cl li this is a renewal, indicated current NCGNE number in Question 7.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water.Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWO Regional Office for your area.
DWO Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 5 of 5
SWU-NE-071408 Last revised 7/14/2008

euk 9
Fertilizer
Bulk
Ferfillzer
St4ra e
6�
Liquid
Nitrogen
Uquid
lVitrBgen .
Bulk
• �Chemical ,
3
Seed
lw"
Chemical
Storage water
Shop
Office
—. Luby Smith Road
Crop Production Services 242 code
141 Luby Smith Road
919-735- 00 27569 12/06/06 18920
919-735-8800

Crop Production Services
Princeton, North Carolina
Conceptual Environmental Plan Narrative
Crop Production Services operates a facility at 141 Ruby Smith Road just east of the town of
Princeton, North Carolina along the western boundary of Wayne County. The facility distributes
bulk and bagged agricultural products including fertilizers and lime. The site is located in a rural
area of Wayne County and is comprised of approximately 4.6 acres of land. The site is
underlain by poorly drained soils and the topography is generally flat. The site currently has a
vegetative buffer zone along the eastem edge of the property that is approximately 1.3 acres.
The site's stormwater runoff is generally directed towards this buffer area, however, the
operational area of the site experiences flooding during larger storm events. To assist with this
issue and to reduce the potential for windborn dust, Bay Environmental, Inc. has prepared a
conceptual plan that addresses drainage and dust control.
The site currently has windbreaks planted along the northeastern and eastern property
boundaries. These windbreaks consist of two rows of Leyland cypress planted on five to ten
foot centers staggered between the two rows. The conceptual plan proposes additional
windbreaks with a similar planting scheme along most of the remainder of the northern
property boundary, as well as along the entire southern boundary. The conceptual plan also
proposes to replace any dead, diseased, or dying trees within the existing windbreak. Based on
field reconnaissance, it appears that some of the trees in the extreme northeastern comer of
the site are being flooded, as the Leyland cypress does not tolerate irregular flooding. This
location may require the creation of a one foot berm to divert ponded water away from the
windbreak plantings,
The primary species that will be utilized for these windbreak plantings is Leyland cypress
(Cupressocyparrs leylandl�, however, the cypress will have to be planted in higher areas not
subject to significant ponding (on berms for instance). As the final grading plans are
completed, the incorporation of other more flood tolerant species may have to be considered.
August 20, 20d9 j n
Page Iof3 '

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The conceptual plan proposes vegetated buffers and landscaped beds on all areas of the facility
that are not required for operations or traffic flow. These vegetated buffers will reduce the
amount of runoff directed to the eastern end of the property and will provide soil stabilization to
reduce dust. The larger buffer areas along the northern boundary and in the southeastern
corner will contain taller plantings (shrubs, small canopy trees) with low ground cover, and the
landscaping beds will contain perennials and grasses. The large vegetated buffer at the eastern
end of the property will have to be excavated slightly (less than 2 feet) to accommodate the
drainage from the site and to provide a slight gradient across the site, as currently, some areas
of the site are lower in elevation than the buffer area. This larger area will be planted with
native grasses and shrubs with a ring of large canopy trees on the northern, eastern and
southern borders of the buffer area.
The primary species for these vegetative buffer areas include:
Grasses
Switchgrass (Panrcum virgatum) plugs and seed
Pink Muhly Grass (MuhlenGergia capillaris) plugs
Broomsedge (Andropogons virginicus) plugs or seed
Fescue and/or annual rye for temporary erosion control
Shrubs/Small Canopy Trees
Wax myrtle (Morella cerifera)
Ironwood (Carpinus carolinrana)
Dwarf (Cottet) Willow (Salix x cottetli)
Lme Canopy Trees
Hybrid Willows (Salix spp. SX-61 or 5V-1)
Tulip poplar (Liriodendron tulipifera)
Water Pans
Within the northern and southern vegetated buffer areas, stormwater will be managed within
flat, vegetated areas referred to as water pans. These structures are flat (0% grade) areas
within the drainage course (vegetated swale) that are widened to provide water storage and to
slow the velocity of water as it proceeds downstream. The attached general cross sections
depict the outlet structures for these water pans. Water pans will be vegetated with species as
detailed above in the vegetative buffer section.
August 20, 2009 0
Page 2 of 3
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The conceptual plan proposes a retaining structure to contain bulk lime on the site, and to
protect the lime pile from wind. The proposed structure is a concrete block wall with a chain
link fence installed on top of the wall on the westem and southern facing edges of the
structure. Wind break fabric similar to the fabric used for enclosed tennis courts will be
installed on the chain link fence to reduce the amount of the bulk lime pile subjected to winds
crossing from west to east. This design allows for loading to and from rail cars over the
northem section of the structure, and direct access with a loader from the eastern side of the
structure. This design will reduce carbon output by reducing equipment handling during
loading and unloading of railcars compared to other closed storage structures which may
require double handling of the bulk material.
if
August 20, 2009 j Q
Page 3 of 3 FM+mnmi WC—Awy Lni[.. ,

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ium Retail
]AN FEB MAR APR
Facility:
Safety Pays!
APPENDIX A
MONTHLY INSPECTION REPORT
MAY JUN JUL AUG SEP OCT NOV DEC YEAR
Inspector's Signature:
Date:
Monthly Inspections Item(s)
OK
Corrective Measures
Required and Comments
Date Actions
Com leted
Emergency Eye Wash/5afety Showers (weekly inspection req.)
Week 1
Week 2
Week 3
Week 4
Emergency Respirators/SCBA's
Facility Lighting & Security Signs)
Fire Extinguishers (All facilities & mobile equipment)
First Aid Kits (complete & sanitary)
Guards & Covers (in -plant equipment)
Hoist Cable & Chain, Manlift Equipment
House Keeping/Overall Facility Appearance (lot graded)
Loekout/Tagout Equipment
PPE (gloves, goggles, respirators)
Spill Kits
Chemical Warehouse (dean, organized)
Dry Fertilizer Warehouse, Storage Bins, Mix/Blend Areas, Pads
Hazardous Waste Storage Areas (weekly inspection required)
week 1
Week 2
Week 3
week 4
Liquid Fertilizer Tanks, Containment, Mix/Blend Areas, Pads
Liquid Pesticide Tanks, Containment, Mix/Blend Areas, Pads
NH3 Facility (paint, plumbing, condition etc.)
Use separate form more detailed inspections if required by
your state/local requirements
Seed Warehouse
Used Ail Storage Area
Scheduled Inspections
Application Equipment
Decontamination Kits
Dry Buggies, Liquid Trailers, etc.
Electrical (condition of boxes, wiring and cords)
NH3 Wagons, Nurse Tanks & Mobile Equipment (paint,
condition etc
Nurse Trucks & Pickups
INSTRUCTIONS: Complete all applicable sections of the forms and return a copy (both sides) to the Asmark
Institute with your monthly training. Weekly inspections are to be documented on the original form that is kept on
file at the facility.
www.agriamretailehs.com Page: 170 7-4-2008

11
Cerium Retail
Safety Pays!
STORM WATER DISCHARGE INSPECTION REPORT
Containment Area & Test Results* Method of
Date Inspected By Sump Inspected PPM Disposal**
*List applicable tested constituents including Nitrate/nitrites (test strips), Ammonia (test strips),
Sulfates (test kit), Phosphates (test kit), outside lab (retain results)
** Methods of disposal include on -site (non -detect for all applicable components), off -site
(complete "Notice of Application"), reuse as make up water, and off -site disposal (requires
supporting documentation)
www.agriumretailehs.com Page: 7-4-2408

Crop
Production
Services
1160 Brake Road, Rocky Mount, NC 27801
252-977-0308 Phone
252-973-0761 Fax
August 21, 2009 Via E-Mail and Fax
Mr. Ken Pickle
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re. No Exposure Certification for Crop Production Services, Princeton, NC
Dear Mr. Pickle:
Enclosed is the signed NPDES NO EXPOSURE CERTIFICATION for Exclusion for the above -
named facility located at 141 Luby Smith Road, Princeton, NC 27569. Our proposed plan for
achieving No Exposure is detailed below. The attached site map enumerates the Areas of
Concern.
Area 1 _ Shop. Used oil is in a double -walled containment unit inside the shop. Safety Kleen
disposes of the used oil and leaves shipping manifests, which are available in the front office.
Area 2 — Empty Bulk Chemical Shuttle Tank Storage Area. This is a concrete slab next to the
building. Only triple -rinsed, clean shuffles are stored in this area.
Area 3 — Bulk Chemical Storage Tanks. Tanks are in secondary containment. All storm water
from the containment area and the contained load pad is collected and agronomically land
applied through an application rig. A housekeeping decal is posted near the sump to remind
employees that the water must be collected and disposal requires manager approval.
Area 4 — Liquid Nitrogen Storage Tanks. Tanks are in secondary containment. Stormwater is
tested with nitrate strips and if there is any coloration on the strip, the water is collected and land
applied at agronomic rates or used as make up water. A four -inch lip around the nitrogen load
pad ensures storm waters are contained and eliminates water flow across the pad toward the
east end of the facility. A Housekeeping decal reminds employees of the proper management
for stormwaters from the containment and the load pad.
Area 5 - Railcar Unloading Area. We added metal plates on 3 sides of the load -in to facilitate
sweeping up any spilled product. The area is swept after load -in and product placed inside the
storage building.
Area 6 — Blended Fertilizer Discharge. We extended the concrete pad in this area and have
posted Housekeeping Signs to remind employees that the area must be swept daily and the
product placed back inside the building or put on the truck before it leaves the facility.

Mr. Ken Pickle
Page 2
August 21, 2009
Area 7 — Main Fertilizer Storage Building. The building has been repaired so there is no residual
discharge through the wall to the outside of the building.
Area 8 -- Fuel Tank Storage. The tanks are not contained, but fueling takes place over a
concrete pad. Any spillage is cleaned up with oil absorbent and properly disposed of in a waste
container.
Area 9 — Outside Bulk Storage Bins_ We installed doors on two of these bins and now use them
for bagged storage only. The third bin is used only for "filler" which is a non -nutrient material. In
addition, a four -inch concrete lip has been added to all three bins to eliminate wash back of any
rainwater that enters the bin. The concrete pad in front of the bins is the drive path for the loader
when transporting filler to the blender. This pad will be swept daily, when in use, and all filler
placed bark inside the bin.
Area 10 — East Field and Southeast comer of Facility. We are planning excavation of the
southeast comer back to natural soil depth so that the area can be planted to create a vegetative
buffer. The existing field will be further developed by grading and planting of grasses and trees.
Please see the Conceptual Plan and Narrative attached outlining our proposed improvements for
windbreaks, vegetative buffers, and infiltration trenches and pits.
Area 11 -- Lime Pile. We are proposing a containment structure for the active lime storage area.
This structure will consist of 4 to 6' cast wall or equivalent on three sides measuring 36' x 75'.
The open end will face east and will include a ramp to prevent stormwater from flowing out from
the storage area On the west and south sides, we will add a 6 to 8' high chain link fence with
appropriate sized mesh screening to buffer wind impact. The north side will not be screened to
allow the clam shell to unload the lime from rail cars directly into the structure, eliminating the
need to move the material twice, as would be required with a covered structure. The adjacent
building provides a wind buffer on the north side. The lime pile will be shaped (tabletop like) and
will not be stored over the height of the windbreak. The loader in the area is dedicated for the
season, and only leaves the area should our other loader break down or if a storm is forecast.
Trucks back beside the pile and pull straight out once loaded. Please see additional information
on this structure in the Conceptual Plan and Narrative.
Additional Areas of Exposure noted in your letter of July 21, 2009 - Outside storage of pallets,
tires, metal hoppers, and other site business -related implements,
We will remove all unnecessary equipment from the site. Pallets that are stored outside are
clean and are stored for reuse. Any that are returnable, are returned as soon as space on
transport trucks allows. All liquid application equipment is field rinsed prior to returning to the site
and dry product field equipment (spreader trucks, Killebrew trailers) contributions are considered
de minimis.
In addition to these measures, Kirik Williams presented documentation concerning the SIC Code
designation and its impact on Storm Water Regulations. Princeton is classified as SIC 5191
(now NAICS 424910) which was exempt from storm water regulations. Based on percentage of
sales, blended fertilizers account for 22% of the sales volume, relative to 32% chemical sales
and 27% straight fertilizer sales. Therefore, this process is not considered the principal product°
for assigning of the SIC Code. Kirk's Bullet Point Discussion from his e-mail of August 19 is
attached, highlighting the SIC Code Determination area and summary.

Mr. Ken Pickle
Page 3
August 21, 2009
Employees are trained annually on Stormwater Management, Waste Minimization, and
Housekeeping. Site personnel perform a Site Inspection monthly which includes all areas.
Stormwater that is collected from the containment areas is documented on the "Stormwater
Discharge Inspection Report." A copy of the monthly inspection form and the Stormwater
Discharge Inspection Report are enclosed_
We trust this answers any questions that may arise. Please feel free to contact me at the above
number, Shannon Peedin, Manager at Princeton at 919-735-8800, or Kirk Williams at 970-347-
1542.
Sincerely,
Crop Production Services, Inc.
Phillip Shannon Peedin Nancy Vi�
Branch Manager Manager, Operations Compliance
Enclosures:
• NPDES No Exposure Certification for Exclusion
• Satellite Map
• Site Drawing enumerating Areas of Concern
• Conceptual Plan Narrative and Drawing from Bay Environmental
• SIC Code Discussion from Kirk Williams
• Agrium Monthly Inspection Report Sample
• Agrium Storm Water Discharge Inspection Report Sample
C. Kirk Williams, Environmental Manager, Greeley
Bill Coleman, General Manager
Brandon Brewer, General Manager

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