NC0003719_Owner (Name Change)_20040715

NPDES DOCUMENT !;CANNINL COVER SHEET
NC0003719
Cedar Creek site WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Monitoring Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
July 15, 2004
This document is printed on reuse paper - ignore any
content on the "ew-erse side

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DAK Americas
FIBERS. MONOMERS & RESINS
July 15, 2004
Mrs. Susan Wilson
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
JUL 2 6 20C4
JUL 2 6 2004
DENR - WATER QUALITY
POINT SOURCE BRANCH
Subject: NPDES Permit Modification Name/Ownership Change
Permit NC0003719
DAK Americas Cedar Creek Site
Dear Mrs. Wilson,
Thank you and the Division for meeting with DAK Americas on July 6, 2004 to discuss your letter
dated June 7, 2004 regarding the Cedar Creek Site NPDES Permit (NC0003719) transfer issues.
In the June 7 permit letter, the state requested DAK to submit a major permit modification and an
Engineering Alternative Analysis (EAA) within 60 days of receipt of the new permit. In the July 6th
meeting, the state agreed that DAK was not to submit a major permit modification at this time.
The state agreed that DAK did not have to complete the land disposal section of the EAA but
would complete the remainder of the analysis. The state agreed that DAK would submit the major
permit modification after the state reviewed the EAA. At the Division's request, DAK Americas
agreed to submit an Engineering Alternative Analysis (EAA). DAK asked for some additional time
to submit the EAA in order to get an external consultant to complete the analysis.
As discussed on the phone this morning, we would like to request a submittal date for the EAA of
August 26, 2004. Once the Division has reviewed the EAA, another meeting will be scheduled to
discuss the next step in the permit modification name/ownership change.
If DAK's understanding of the agreed upon timing and pathforward is incorrect, or if you have any
question or concerns please contact me at 910-371-5082 or 910-262-2288.
Sincerely,
Richardson
Cc: File Room
Paul Rawls, NCDWQ Fayetteville Regional Office
Ms. Penny Mahoney, DAK Americas
www.dakamericas.com
DAK Americas, LLC
3500 Daniels Road, N.E. • Leland, NC 28451
1-877-432-2766

DAK Americas
FIBERS, MONOMERS & RESINS
Cedar Creek NPDES Permit
Meeting

DAK Americas
FIBERS, MONOMERS & RESINS
Agenda
® PWC History/Financials/Summary
• DAK Proposal
• Discussion

DAK Americas
PWC History
FIBERS, MONOMERS & RESINS
uP0 1 r 5 LMrj
Mid 2001 - Monsanto notified DAK and DTF that they were going to shutdown their
manufacturing facilities. Offered utility facilities for purchase to either DTF/DAK. Both
declined. Services to be cut off between 12/03 and 6/04.
- Late 2001 - Monsanto threatened to cut off WWT services prior to contract if buyer for
plant could not be found.
— November, 2001 - DAK/DTF began discussions with PWC on possibility of their
treating DAK/DTF wastewater.
PWC could take wastewater only if it were pre-treated to reduce COD and if site
could minimize flow
- 2002 - Monsanto found a potential buyer but buyer would not take over responsibility
for wastewater treatment.
- PWC received —$800,000 grant to install header out to DAK/DTF complex.
- Late 2002 - Monsanto deal fell through due to concerns over future environmental
liability.
- Early 2003 - DAK/DTF began discussing purchase. DAK agreed to purchase for
betterment of the overall complex.
— December 17, 2003 - Purchase finally completed.
- PWC header well into construction at this point.

DAK Americas
FIBERS, MONOMERS & RESINS
PWC Financials
• Cost to run header to tie-in to PWC - $750,000. Currently
being installed.
• Water must be pre-treated so many of the costs of the
current wastewater plant will continue.
• PWC cost per gallon of water without any surcharges will
exceed $250,000/year.
• Surcharges will occur if excessive flow, COD or TSS.
• Storm water and excess flow will have to be discharged to
the Cape Fear River from DAK facility.

DAK Americas
FIBERS, MONOMERS & RESINS
PWC Summary
O DAK believes that we are obligated to tie-in to the PWC
header in order to repay the county for installing the header
when the facility was in need.
O However, ongoing cost to dual -treat water will be
prohibitive to the current businesses
O Despite the availability of many other services at the site,
additional growth at the site would be precluded due to the
flow limitations of PWC.
® There is no benefit to the river whether the water is
discharged via PWC or through the DAK's facility.

DAK Americas
FIBERS, MONOMERS & RESINS
DAK's Wastewater
Operations Proposal

DAK Americas
FIBERS, MONOMERS & RESINS
Initial Operation
Operate under existing permit with no changes to effluent limitations and
a permitted discharge of 0.5 MGD.
Continue to discharge stormwater from Outfall #002.
PWC Operation (expected 4th Qtr 2004)
Operate under existing permit with no changes to effluent limitations and
a permitted discharge of 0.5 MGD. Permit cooling tower blow -down to
discharge to a stormwater outfall.
Future Operations
Decrease flow to PWC and allow more water to discharge from DAK
facility until all flow to PWC has been stopped.
In all cases, keep 1.25 MGD allocation for future expansion and other
businesses to be located on -site.

DAK Americas
FIBERS, MONOMERS & RESINS
DAK's Proposed Pathforward
• DAK to submit $860 and a permit
modification to allow for cooling tower
blow -down directly to Outfall.
— DAK should not need to resubmit complete permit modification for
current operations because there is no change to what was previously
submitted by Monsanto.
• DAK will submit a complete major permit
modification and an Engineering
Alternative Analysis when requesting to
increase discharge to the 1.25 MM gallons.

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June 7, 2004
Mr. Craig Leite, Site Manager
DAK Resins, LLC
PO Box 1690
Fayetteville, North Carolina 28312
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
L,,)5 <
k)Q'
Subject: NPDES Permit Modification - Name/Ownership Change
Permit NC0003719
DAK Resins - Fayetteville
Cumberland County
Dear Mr. Leite:
In accordance with your original request received December 29, 2003, the Division is
forwarding the subject permit modification. This modification documents the change in
name/ownership at the subject facility. It is the Division's understanding that DAK Resins, LLC is
now the owner of the wastewater treatment plant, and subsequently the NPDES permit (NC0003719).
All other terms and conditions in the original permit remain unchanged and in full effect. This permit
modification is issued under the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U. S. Environmental Protection Agency
dated December 6, 1983.
In anticipation of the sale and removal of Monsanto, the Division of Water Quality initiated
certain conditions that the new permittee is required to perform. Part I, Condition A.(5.) of the permit
requires that:
• the new permittee submit proof of change of ownership along with the change in
name/ownership form (which DAK has submitted),
• the new permittee submit a new application for discharge, along with a major modification fee
of $860 outlining existing plans, future plans, and need for continued NPDES permit,
• the new permittee submit an Engineering Alternative Analysis in conjunction with the permit
application.
The above information should be submitted within 60 days of receipt of this letter. At this
time, DAK Resins should be compliant with Conditions A.(3.) and A.(4.) for Outfall 002 (as well as the
other conditions specific to the other outfalls). The permit was originally structured with the
knowledge that Monsanto would be sold and the existing on -site industries needed an approved permit
to discharge. The Division of Water Quality decided to maintain the Monsanto permit at a reduced
flow after the period of shutdown at Monsanto. The Division of Water Quality was aware that
Monsanto was in contact with PWC Fayetteville and that the discharge may soon be routed to PWC
Fayetteville. In order to continue to maintain an NPDES permit to discharge, DAK Resins must clarify
and justify the need for flow and discharge of process wastewater. If this need cannot be justified to
the satisfaction of the Division, then the permit will not be reissued.
The name/ownership change has been completed. However, Condition A.(5.) has been
continued, as well as No. 4 in the Supplement to the Permit Cover Sheet. A new permit application
along with the Engineering Alternatives Analysis has been included with the permit.
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[phone]
FAX [phone]
On the Internet at http://h2o.enr.state.nc.us/

r '
Permit Number NC0003719
7,
1
Mr. Leite
Page 2
If any parts, measurement frequencies or sampling requirements contained in this permit
modification are unacceptable to you, you have the right to an adjudicatory hearing upon written
request within thirty (30) days following receipt of this letter. This request must be a written petition
conforming to Chapter 150B of the North Carolina General Statutes, filed with the Office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such
demand is made, this decision shall be final and binding.
This permit does not affect the legal requirement to obtain other permits which may be required
by the Division of Water Quality, the Division of Land Resources, Coastal Area Management Act, or any
other Federal or Local government permit that may be required. If you have any questions concerning
this permit, please contact Susan Wilson at (919) 733 - 5083, ext. 510.
Sincerely,
A164.-„,
Alan W. Klimek, P.E.
cc: Central Files
Fayetteville Regional Office, Water Quality Section
NPDES Unit
Ms. Penny Mahoney, DAK Resins, LLC

Permit Number NC0003719
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
DAK Resins, LLC
is hereby authorized to discharge wastewater from a facility located at
DAK Resins - Fayetteville
3468 Cedar Creek Road
Fayetteville
Cumberland County
to receiving waters designated as the Cape Fear River in the Cape Fear River Basin
in accordance with effluent limitations, monitoring requirements and other conditions set
forth in Parts I, II, III and IV hereof.
This permit shall become effective June 7, 2004.
This permit and authorization to discharge shall expire at midnight on October 31, 2006.
Signed this day June 7, 2004.
a-1(AL
an W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number NC00037I9
SUPPLEMENT TO PERMIT COVER SHEET
DAK Resins, LLC is hereby authorized to:
1. Continue to operate an existing 1.25 MGD wastewater treatment facility consisting
of flow equalization, spill basin, pH adjustment, oilskimming, comminute, dual
aeration basins, clarifier, parshall flume, sludge pump station, dual aerobic
digesters, aerated biosolids holding basin, biosolids drying beds and other
associated equipment located at DAK Resins, LLC, on NC Highway 53, south of
Fayetteville in Cumberland County.
2. Upon closure and clean-up of the Monsanto RoundUp plant, continue to operate
an existing 1.25 MGD wastewater treatment facility with a permitted discharge of
0.5 MGD consisting of flow equalization, spill basin, pH adjustment, oil skimming,
comminute, dual aeration basins, clarifier, parshall flume, sludge pump station,
dual aerobic digesters, aerated biosolids holding basin, biosolids drying beds and
other associated equipment located at DAK Resins, LLC, Fayetteville Plant, on NC
Highway 53, south of Fayetteville in Cumberland .County.
3. Discharge water from said treatment works at the location specified on the
attached map into the Cape Fear River which is classified C waters in the Cape
Fear River Basin
4. Upon sale of the Monsanto Fayetteville facility, the new owner shall request a
modification to the NPDES permit and complete a new application for discharge in
accordance with special condition A. (5.) for an ultimate permitted flow of 1.25
MGD.
5. Discharge stormwater from the outfall specified on the attached map (and other
outfalls specified in the July 31, 1992 stormwater permit application) into the
Cape Fear River which is classified C waters in the Cape Fear River Basin.
Any other point source discharge to surface waters of the state is prohibited unless covered by another permit,
authorization or approval.
This permit does not relieve the permittee from responsibility for compliance
with any other applicable federal, state, or local law, rule, standard, ordinance,
order, judgement or decree.

Latitude:
Longitude:
Quad #:
Stream Class:
Receiving Stream:
Permitted Flow:
34°58'08" Sub -Basin:
78°46'58"
H23NE/Cedar Creek, NC
C
Cape Fear River
1.25 MGD (002) and no limit (001)
03-06-15
DAK Resins, LLC
DAK Resins- Fayetteville Facility
NC0003719

i.j< A td)-
v04 k-`9c/
Permit NC0003719
A. (1.) EFFLUENT LINIITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date of this permit and lasting unti June 30. 2003, t e Permittee is
authorized to discharge from outfall 002. Such discharges shall be limited and moni
specified below:
Pernttee as
Effluent Characteristics
Limits
Monitoring Requirements
Month Alterage
Daily Maximum
Measurement
Frequency
Sample
Type
Sample Location'
�--_�.
Flow
1.25 MGD
r vlC
Continuous
Recording
Influent or Effluent
Total Suspended Solids (TSS)
457.0 lb./day
914.0 lb./day ,
3/Week
Composite
Effluent
BODs, 20°C (April 1- October 31)
191.0 lb./day
382.0 Ib./Oay"
3lweek
Composite
Effluent
BOD5, 20°C (November 1 - March
31)
Ib./day -•
- ----
--7
—84 O 16/day
-
3/week
Composite
Effluent
-- - -Effluent- ----
COD
. .--erlipasite_
NH3 N (April 1-October 31)
lb./day
70.0 lb./day
3lweek
Composite
Effluent
NH3-N (November 1 - March 31)
70.0 lb./day
140.0 lb./day
3lweek
Composite
Effluent
Fecal Coliform (geometric mean)
3/week
Grab
Effluent
Total Nitrogen (NO2 + NO3 + TKN)
-----
Quarterly
Composite
Effluent
Total Phosphorus
Quarterly
Composite
Effluent
-Glyphosate3—_ -- - ---- - _
_
---2lmonth--
--Gomposite---rEfflu
—
----- - --- --
ent
Total Residual Chlorine
r\-W
t( ett(_ l
3/Week
Grab
Effluent
Acute Toxicity2
Quarterly
Composite
Effluent
pH4
3/week
Grab
Effluent
Dissolved Oxygens
Weekly
Grab
Effluent
Dissolved Oxygens
(June 1- September 30)
3lweek
Grab
Upstream,
Downstream6.7
Temperature (9C)
Weekly
Grab
Effluent
Temperature (9C)
(June 1 - September 30)
3lweek
Grab
Upstream,
Downstream6.7
Conductivity
(June 1 - September 30)
3/Week
Grab
Upstream,
Downstream6.7
Notes:
i Sample locations: Upstream - upstream 2 miles from outfall; Downstream - downstream. 100 yards upstream of Lock and
Dam #3.
2 Whole Effluent Toxicity shall be measured by a P/F at 90% acute toxicity test using Fathead Minnow. Test shall be
conducted in February, May. August and November. See Part A. (5.). Samples for toxicity testing shall be collected at the
combined outfall box located below outfalls 001 and 002-
Once cleanup of glyphosate production area is complete. Monsanto Company shall submit a letter to the Division giving
the shutdown and cleanup dates. After this date, Monsanto shall sample for glyphosate six (6) additional times over the
course of three months. If these samples result in non -detects for glyphosate, glyphosate monitoring may be terminated.
If glyphosate is detected, the source should be identified and cleaned; glyphosate monitoring shall continue until such
point at which it is not detected in six (6) samples.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units-
5 The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L. Effluent samples for dissolved
oxygen testing shall be collected at the combined outfall box located below outfalls 001 and 002.
6 lnstream monitoring shall be conducted as follows: 3/week June 1 - September 30; 1 /week: October 1-May 31.
7 As a participant in the Middle Cape Fear River Basin Association, the instream monitoring requirements as stated above
are waived. Should your membership in the agreement be tenninated. you shall notify the Division immediately and the
instream monitoring requirements specified in your permit shall be reinstated.
There shall be no chromium, zinc, or copper added to the treatment system except as pre -approved
additives to biocide compounds or that which results from the normal degradation of piping and
equipment used in process units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC00037 19
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQIREMENTS - FINAL
During the period beginning on the effective date of the permit and lasting until June 30, 2003, the Permittee is
authorized to discharge from outfall 002. Such discharges shall be limited and monitored by the Permittee as
specified below:
Effluent
Characteristics
Limits
DAILY
UM (lbs. , day)
MONTHLY
AlbsVERAGE
(.
day)
Monitoring
MEASUREMENT
FREQUENCY
Requirements
SAMPLE
SAMPLE
LOCATION'
Acenaphthene
0.1'07
0.40
Annual
Grab
E
Acenaphihylene
0.1�7
0.40
Annual
Grab
E
Acrylonitrile
0.440
0.74
Annual
Grab
E
Anthracene
0.147
0.
40
Annual
Grab
E
Benzene
0.247
0.
67
Annual
Grab
E
Benzo(a)anthracene
0.107
0. 40
Annual
Grab
E
3,4-Benzofluoranthene
0.111
0 042
Annual
Grab
E
Benzo(k)fluoranthene
0.107
0 040
Annual
Grab
E
Benzo(a)pyrene
0.11,1
.042
Annual
Grab
E
Bis(2-ethylhexyl) phthalate
0.507
d.187
Annual
Grab
E
Carbon Tetrachloride
0.069
(1033
Annual
Grab
E
Chlorobenzene
0.051
0t027
Annual
Grab
E
Chloroethane
0.487
01189
Annual
Grab
E
Chloroform
0.084
0,038
Annual
Grab
E
2-Chlorophenol
0.178
056
Annual
Grab
E
Chrysene
0.107
0.040
Annual
Grab
E
Di n butyl phthalate
0.104
0.049
Annual
Grab
E
1,2-Dichlorobenzene
0.29E
0.140
Annual
Grab
E
1,3-Dichlorobenzene
0.080'
0.056
Annual
Grab
E
1,4-Dichlorobenzene
0.051
0.027
Annual
Grab
E
1,1-Dichloroethane
0.107
0.040
Annual
Grab
E
1,2-Dichloroethane
0.383
0.124
Annual
Grab
E
1,1-Dichloroethylene
0.045
0.029
Annual
Grab
E
1,2-trans-Dichloroethylene
0.098
0.038
Annual
Grab
E
2,4-Dichlorophenol
0.204
0.071
Annual
Grab
E
1,2-Dichloropropane
0.418
0.278
Annual
Grab
E
1,3-Dichloropropylene
0.080
0.053
Annual
Grab
E
Diethyl phthalate
0.369
0.147
Annual
Grab
E
2,4-Dimethylphenol
0.065
0.033
Annual
Grab
E
Dimethyl phthalate
0.085
0.035
Annual
Grab
E
4,6-Dinitro-o-cresol
0.503
0.142
Annual
Grab
E
2,4-Dinitrophenol
0.224
0.129
Annual
Grab
E
2,4-Dinitrotoluene
0.518
0.205
Annual
Grab
E
2,6-Dinitrotoluene
1.165
0.463
Annual
Grab
E
Ethylbenzene
0.196
0.058
Annual
Grab
E
Fluoranthene
0.124
0.045
Annual
Grab
E
Fluorene
0.107
0.040
Annual
Grab
E
Hexachlorobenzene
Annual
Grab
E
Hexachlorobutadiene
0.089
0.036
Annual
Grab
E
Hexachloroethane
0.098
0.038
Annual
Grab
E
Y

Permit NC0003719
A.(2.) Continued
Effluent
Characteristics
Limits
Monitoring Requirements
DAILY
MAXIMUM
(lbs./day)
MONTHLY
AVERAGE
(lbs./day)
MEASUREMENT
FREQUENCY
SAMPLE
SAMPLE
LOCATION'
Methyl Chloride
0.345
0.156
Annual
Grab
E
Methylene Chloride
0.162
0.073
Annual
Grab
E
Naphthalene
0.107
0.040
Annual
Grab
E
Nitrobenzene
0.124
0.049
Annual
Grab
E
2-Nitrophenol
0.15
0.075
Annual
Grab
E
4-Nitrophenol
0.225
0.131
Annual
Grab
E
Phenanthrene
0.107
0.040
Annual
Grab
E
Phenol
0.047
0.027
Annual
Grab
E
Pyrene
0.122
0.045
Annual
Grab
E
Tetrachloroethylene
0.i 02
0.040
Annual
Grab
E
Toluene
0.' 45
0.047
Annual
Grab
E
Total Chromium
5.
2.017
Quarterly
Grab
E
Total Copper
6.1 2
2.635
Quarterly
Grab
E
Total Cyanide
2.181
0.763
Quarterly
Grab
E
Total Lead
1.204
0.582
Quarterly
Grab
E
Total Nickel
7.2%13
3.071
Quarterly
Grab
E
Total Zinc
ti'`- 1
It,
1
Quarterly
Grab
E
1,2,4-Trichlorobenzene
0.254
0.124
Annual
Grab
E
1,1,1-Trichloroethane
0.008
0.038
Annual
Grab
E
1,1,2-Trichloroethane
0.0 B
0.038
Annual
Grab
E
Trichloroethylene
0.(49B
0.038
Annual
Grab
E
Vinyl Chloride
0.487
0.189
Annual
Grab
E
Effluent
Characteristics
Limit
Monitoring Requirements
DAILY
MAXIMUM
(µg/L)
MEASUREMENT
FREQUENCY
SAMPLE
SAMPLE
LOCATION'
Total PAHs2
69.70
Quarterly
Composite
E
Hexachlorobenzene
1.73
Quarterly
Composite
E
Notes:
1. Sample Location: E - Effluent, I - Influent
2. Total PAI-Is are comprised of Benzo(a)anthracene; Benzo(a) pyrene; 3,4-Benzofluoranthene;
Benzo(k)fluoranthene: Chrysene: Dibenz(a,h)anthracene and Indeno(1,2,3-ed)pyrnene.
Note: Composite samples must be refrigerated

Permit NC0003719
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
During the period beginning on July 1, 2003 and lasting until expiration, the Permittee is authorized to discharge
from outfall 002. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Limits
Monitoring Requirements
Monthly Average
Daily Maximum
Measurement
Frequency
Sample
Type
Sample Location'
Flow
0.5 MGD
Continuous
Recording
Influent or Effluent
Total Suspended Solids (TSS)
72.5 lb./day
235.7 lb./day
Weekly
Composite
Effluent
B0D5, 20°C
43.4Ib./day
115.7 lb./day
Weekly
Composite
Effluent
COD
W.
-�---,
Weekly
Composite
Effluent
NH3-N (April 1-October 31)
35.0 lb./day
70.0 lb./day \,
Weekly
Composite
Effluent
NH3-N (November 1 - March 31'
70.0 lb./day
140.0 lb./day
Weekly
Composite
Effluent
Fecal Coliform (geometric mean)) -
r
/
Weekly
Grab
Effluent
Total Nitrogen (NO2 + NO3 + TKN)
i
Quarterly
Composite
Effluent
Total Phosphorus
Quarterly
Composite
Effluent
Total Residual Chlorine
Weekly
Grab
Effluent
Acute Toxicity2
\.
Quarterly
Composite
Effluent
pH3
Weekly
Grab
Effluent
Dissolved Oxygen4
l
Weekly
Grab
Effluent
Dissolved Oxygen4
(June 1 - September 30)
- /
. �'
3/week
Grab
Upstream,
Downstream5.6
Temperature (°C)
(�
Weekly
Grab
Effluent
Temperature (°C)
(June 1 - September 30)
J�
/� U ,
3/week
((�
Grab
Upstream,
Downstream5,e
Conductivity
(June 1 - September 30)
- 1 �`i 3/Week
Ct-2 J ?
Grab
Upstream,
Downstream5s
Notes: 2 �5/�(c b. / , /ilk
1 Sample locations: Upstream - upstr am 2 miles from utfall; Downstream - downstream, 100 yards
upstream of Lock and Dam it3.
2 Whole Effluent Toxicity shall be measured by a P/F at 90% acute toxicity test using Fathead Minnow. Test
shall be conducted in February, May, August and November. See Part A. (5.). Samples for toxicity testing
shall be collected at the combined outfall box located below outfalls 001 and 002.
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4 The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L. Effluent samples
for dissolved oxygen testing shall be collected at the combined outfall box located below outfalls 001 and 002.
5 Instream monitoring shall be conducted as follows: 3/week June 1 - September 30
1/week: October 1-May 31.
6 As a participant in the Middle Cape Fear River Basin Association, the instream monitoring requirements as
stated above are waived. Should your membership in the agreement be terminated, you shall notify the
Division immediately and the instream monitoring requirements specified in your permit shall be reinstated.
There shall be no chromium, zinc, or copper added to the treatment system except as pre -
approved additives to biocide compounds or that which results from the normal degradation of
piping and equipment used in process units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC00037 19
A. (4.) EFFLUENT LIMITATIONS AND MONITORING REQIREMENTS - FINAL
During the period beginning on July 1, 2003 and lasting until expiration, the Permittee is authorized to discharge
from outfall 002. Such discharges shall be limited and monitored by me rermittee as s • ecuiea oeim
1` 4x !� a
r J y-ti':,�. 1T = `�i� �Un,
.•J
:`w
:1�." •<. •.�' _ ti '
.i :�.q%.'f."'g"r.'; `sf, s
' '� f .
a'.. , i = . '. . ?,. y .S�R
ei ..l'7 f
x
�;'4
rS
�y
'� { i •
'4� ''/
.
• a/ 6 i E[ q fi '
4 - ^� ('' ,, ( ;Y,.'+x,
'4 .�3 �� v
.^.1'/ "s :.% x :: 6 r,
- :�i
- r
,-
�j L i ,1•4 F'
'+41 r
i-, yyr.��
Grab
.t "xf` i,
''i0, "'= "•ti..
E.4n� _" �+ 0
,
E
fix..
y ,, y"w
y.. ^..., . ''''' '7' ;
.i l •, _ ,4..r
TM
Acenaphthene
0.107
0.040
Annual
Acenaphthylene
0.107
0.040
Annual
Grab
E
Acrylonitrile
0.440
0.174
Annual
Grab
E
Anthracene
0.107
0.040
Annual
Grab
E
Benzene
0.247
0.067
Annual
Grab
E
Benzo(a)anthracene
0.107
0.040
Annual
Grab
E
3,4-Benzofluoranthene
0.111
0.042
Annual
Grab
E
Benzo(k)liuoranthene
0.107
0.040
Annual
Grab
E
Benzo(a)pyrene
0.111
0.042
Annual
Grab
E
Bis(2-ethylhexyl) phthalate
0.507
0.187
Annual
Grab
E
Carbon Tetrachloride
0.069
0.033
Annual.
Grab
E
Chlorobenzene
0.051
0.027
Annual
Grab
E
Chloroethane
0.487
0.189
Annual
Grab
E
Chloroform
0.084
0.038
Annual
Grab
E
2-Chtorophenol
0.178
0.056
Annual
Grab
E
Chrysene
0.107
0.040
Annual
Grab
E
Di-n-butyl phthalate
0.104
0.049
Annual
Grab
E
1,2-Dichlorobenzene
0.296
0.140
Annual
Grab
E
1,3-Dichlorobenzene
0.080
0.056
Annual
Grab
E
1,4-Dichlorobenzene
,
0.051
0.027
Annual
Grab
E
1,1-Dichloroethane
0.107
0.040
Annual
Grab
E
1,2-Dichloroethane
0.383
0.124
Annual
Grab
E
1,1-Dichtoroethylene
0.045
0.029
Annual
Grab
E
1,2-trans-Dichloroethytene
0.098
0.038
Annual
Grab
E
2,4-Dichtorophenol
0.204
0.071
Annual
Grab
E
1,2-Dichloropropane
0.418
0.278
Annual
Grab
E
1,3-Dichloropropylene
0.080
0.053
Annual
Grab
E
Diethyl phthalate
0.369
0.147
Annual
Grab
E
2,4-Dimethylphenol
0.065
.
0.033
Annual
Grab
E
Dirnethyl phthalate
0.085
0.035
Annual
Grab
E
4,6-Dinitro-o-cresol
0.503
0.142
Annual
Grab
E
2,4-Dinitrophenol
0.224
0.129
Annual
Grab
E
2,4-Dinitrotoluene
0.518
0.205
Annual
Grab
E
2,6-Dinitrotoluene
1.165
0.463
Annual
Grab
E
Ethytbenzene
0.196
0.058
Annual
Grab
E
Fluoranthene
0.124
0.045
Annual
Grab
E
Fluorene
0.107
_
0.040
Annual
Grab
_ E
Hexachlorobenzene
Annual
Grab
E
Hexachtorobutadiene
0.089
0.036
Annual
Grab
E
Hexachloroethane
0.098
0.038
Annual
Grab
E

Permit NC0003719
A.(4.) Continued
EIXii*Iii _ -,
Limits
` L a� Re
.
i• z
i -3 _
,.z..
:'•C=y_a-s
'
r t_
."Pv� r ,fg ��a
rar
e+.
.-�Iti :�-.
!' .+: A"
�..:.Q�
• .
��77r `•., • %=Cl' -..
. F
r • ^ .y
,�'� �t� '
Methyl Chloride
0.345
0.156
Annual
Grab
E
Methylene Chloride
0.162
0.073
Annual
Grab
E
Naphthalene
0.107
0.040
Annual
Grab
E
Nitrobenzene
0.124
0.049
Annual
Grab
E
2-Nitrophenol
0.125
0.075
Annual
Grab
E
4-Nitrophenol
0.225
0.131
Annual
Grab
E
Phenanthrene
0.107
0.040
Annual
Grab
E
Phenol
0.047
0.027
Annual
Grab
E
Pyrene
0.122
0.045
Annual
Grab
E
Tetrachloroethylene
0.102
0.040
Annual
Grab
E
Toluene
0.145
0.047
Annual
Grab
E
Total Chromium
5.034
2.017
Quarterly
Grab
E
Total Copper
6.142
2.635
Quarterly
Grab
E
Total Cyanide
2.181
0.763
Quarterly
Grab
E
Total Lead
1.254
0.582
Quarterly
Grab
E
Total Nickel
7.233
3.071
Quarterly
Grab
E
Total Zinc
Quarterly
Grab
E
1,2,4-Trichlorobenzene
0.254
0.124
Annual
Grab
E
1,1,1-Trichloroethane
0.098
0.038
Annual
Grab
E
1,1,2-Trichloroethane
0.098
0.038
Annual
Grab
E
Trichloroethylene
0.098
0.038
Annual
Grab
E
Vinyl Chloride
0.487
0.189
Annual
Grab
E
Notes:
1. Sample Location: E - Effluent, I - Influent
Note: Composite samples must be refrigerated

Permit NC0003719
A. (5.) SPECIAL CONDITION FOR TERMINATION OF MONSANTO DISCHARGE
The Monsanto Roundup plant portion of this discharge is expected to terminate within the
first half of 2002. The Monsanto Company will retain control over the utilities until such
time as the facility and utilities are purchased.
The allocation for this permitted discharge remains at 1.25 MGD. However, a new permit for
the discharge will be issued when all of the following take place:
• Proof of change of ownership from Monsanto Company has been furnished. The
resulting name/ownership change form shall be submitted to the Division of
Water Quality.
▪ A new application for a discharge has been completed and submitted by the new
owner of the facility with a request for a major modification of the NPDES permit.
• The request for a major modification to NPDES Permit NC0003719 should
include the appropriate fee for such an action.
• Completion of the application shall include a complete flow justification for the
proposed discharge and an Engineering Alternatives Analysis (EAA).
When all of the above actions are complete, the Division shall furnish new effluent limits
pages that are appropriate for the proposed discharge or set of discharges.
A. (6.) BIOCIDE CONDITION •
The permittee shall not use any biocides except those approved in conjunction with the
permit application. The permittee shall notify the Director in writing not later than ninety
(90) days prior to instituting use of any additional biocide used in cooling systems which
may be toxic to aquatic life other than those previously reported to the Division of Water
Quality. Such notification shall include completion of Biocide Worksheet Form 101 and a
map locating the discharge point and receiving stream.
A. (7.) DETECTION LEVELS FOR COMPLIANCE
If the discharge limitation of a given parameter is below quantitation limits, the measured
quantity for the purposes of a compliance evaluation is considered to be zero. Values that
report below quantitation level shall be deemed to be in compliance.

Permit NC0003719
A. (8.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The Permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the North Carolina
Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent
Concentration" (Revised -July, 1992 or subsequent versions). The monitoring shall be performed as a Fathead
Minnow (Pimephales prometas) 24 hour static test. The effluent concentration at which there may be at no
time significant acute mortality is 90% (defined as treatment two in the procedure document). Effluent samples
for self -monitoring purposes must be obtained during representative effluent discharge below all waste treatment.
The tests will be performed during the months of February, May, August, and November.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE6C. Additionally,
DWQ Form AT-2 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of Water Quality
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed
in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent
toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
Permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at
the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will
revert to quarterly in the months specified above.
Should the Permittee fail to monitor during a month in which toxicity monitoring is required, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to quarterly in the months specified above.
Should any test data from either these monitoring requirements or tests performed by the North Carolina Division
of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
follow-up testing to be completed no later than the last day of the month following the month of the initial
monitoring.
NOTE: Failure to achieve test conditions as specified in the cited document. such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
follow-up testing to be completed no later than the last day of the month following the month of the initial
monitoring.

Permit NC00037 19
A. (9.) STORMWATER MONITORING REQUIREMENTS/Analytical Monitoring
FINAL
During the period beginning on the effective date of the permit and lasting until June 30, 2003, the Permittee is
authorized to discharge from outfall(s) serial number 001 (Stormwater). Such discharges shall be limited and
monitored by the permittee as specified below:
... ,. r
++ Y 7 r v
• V i i [ F
s.,,, � ins
.:::.3.r._ ..eL:} 1 �....__-.-a x.� � .y�li
�i
L l�k l
..-,.»i ?-•:....
VaN r.re., Ix �u - i
sty . ,. h . 0 ,
•• ✓ i�D ,i� i'
Q���t.
Measts
Frequ •
"'�
_ .._-.... .•4m
g
'a1
_ ra_�"T
a.., °�... SL
3;"•J-4 t i
-.......*.o_ n,�r
•
sL r� i
;
a �: _
"' r -...'`i .�i.;
- ...�.-L St,... - ,w.-.. _
Total Flow4
MG
Annual
SW-1
Total Rainfall4
Inches
Annual
SW-1
Event Duration'
Minutes
Annual
SW-1
Total Suspended
Solids
mg/L
_
100.00
Annual
Grab
SW-1
Nickel
µg/L
789.00
Annual
Grab
SW-1
Lead
µg/L
33.78
Annual
Grab
SW-1
Di-n-butyl phthalate
mg/L
Annual
Grab
SW-1
Glyphosate
mg/L
Annual
Grab
SW-1
lsopropylamine
mg/L
Annual
Grab
SW-1
Surfactants (MBAS)
, mg/1
100.0
Annual
Grab
SW-1'
Notes:
1. Cutoff Concentration. For each parameter, the arithmetic mean of all analytical sampling results
collected during the first year of the permit shall be calculated for each individual outfall and
compared to the cut-off concentrations listed. If the arithmetic mean is below the specified cut-off
concentration for a given parameter, then the facility is not required to continue annual analytical
monitoring for that parameter at the outfall during the term of the permit unless a significant
change in facility operations or configuration occurs. If cut-off concentration results in
discontinued analytical monitoring at an individual discharge outfall, the permittee is required to
maintain facility operations that ensure the continuation of stormwater runoff quality.
2. Measurement frequency. Once per year. The facility must perform analytical sampling during the
first full year and last year of the permit term regardless of cut-off concentration conditions.
Analytical results from sampling during the final year of the permit term must be submitted with
the permit renewal application. Failure to monitor storm events in accordance with the specified
frequency shall constitute a violation of this permit.
3. Sample Location. Samples to be collected at eactistormwater discharge outfall (SW-1) located
north of the river water intake pump overflow and south of the sludge drying beds.
4. For each sampled representative storm event the total precipitation, storm duration, and total flow
must be monitored. Total flow shall be either: (a) measured continuously, (b) calculated based on
the amount of area draining to the outfall, the amount of build -upon (impervious) area, and the
total amount of rainfall, or (c) estimated by the measurement of flow at 20 minute intervals during
the rainfall event (not to exceed three hours).
For purposes of the stormwater sampling required in this permit, all samples shall be collected from a
discharge resulting from a representative storm event (See Parts A. (13) and A. (14.)).

Permit NC0003719
A. (1O.)STORMWATER MONITORING REQUIREMENTS/Analytical Monitoring
FINAL
During the period beginning on July 1, 2003 and lasting until permit expiration or expansion, the Permittee is
authorized to discharge from outfall(s) serial number 001 (Stormwater). Such discharges shall be limited and
monitored by the permittee as specified below:
r
A - - '•
JL kr-
�
4t'-`i'v..
�
•.. r-
_ .
,
y. �ir,
.c, ;
ti k
y
- ,
`
�
t%sEvtY
i.ro
•
- _�
Mea�
Fre u
f
_
j
•y�J
:
..
, C
.
'',,
.
¢y`Yr
'aStgl3
4r.
3.R
r�-...434N•
`..
v..3:.'.` (. :
Total Flow4
MG
Annual
.:-A.
SW-1
Total Rainfall4
Inches
Annual
SW-1
Event Duration'
Minutes
Annual
SW-1
Total Suspended
Solids
mg/L
100.00
Annual
Grab
SW-1
Nickel
µg/L
789.00
Annual
Grab
SW-1
Lead
µg/L
33.78
Annual
Grab
SW-1
Di-n-butyl phthalate
mg/L
Annual
Grab
SW-1
Notes:
11. Cutoff Concentration. For each parameter, the arithmetic mean of all analytical sampling results
collected during the first year of the permit shall be calculated for each individual outfall and
compared to the cut-off concentrations listed. If the arithmetic mean is below the specified cut-off
concentration for a given parameter, then the facility is not required to continue annual analytical
monitoring for that parameter at the outfall during the term of the permit unless a significant
change in facility operations or configuration occurs. If cut-off concentration results in
discontinued analytical monitoring at an individual discharge outfall, the permittee is required to
maintain facility operations that ensure the continuation of stormwater runoff quality.
2. Measurement frequency. Once per year. The facility must perform analytical sampling during the
first full year and last year of the permit term regardless of cut-off concentration conditions.
Analytical results from sampling during the final year of the permit term must be submitted with
the permit renewal application. Failure to monitor storm events in accordance with the specified
frequency shall constitute a violation of this permit.
3. Sample Location. Samples to be collected at each stormwater discharge outfall (SW-1) located
north of the river water intake pump overflow and south of the sludge drying beds.
4. For each sampled representative storm event the total precipitation, storm duration, and total flow
must be monitored. Total flow shall be either: (a) measured continuously, (b) calculated based on
the amount of area draining to the outfall, the amount of build -upon (impervious) area, and the
total amount of rainfall, or (c) estimated by the measurement of flow at 20 minute intervals during
the rainfall event (not to exceed three hours).
For purposes of the stormwater sampling required in this permit, all samples shall be collected from a
discharge resulting from a representative storm event (See Parts A. (13) and A. (14.)).

Permit NC0003719
A (11). STORMWATER MONITORING REQUIREMENTS/ Qualitative Monitoring
Qualitative monitoring requires a qualitative inspection of each stormwater outfall, regardless of •
representative outfall status, for the purpose of evaluating the effectiveness of the Stormwater
Pollution Prevention Plan and assessing new sources of stormwater pollution. No analytical tests are
required. Qualitative monitoring of stormwater outfall does not need to be performed during a
representative storm event.
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Clarity
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SW-1
Floating Solids
Semi -Annual
SW-1
Suspended Solids
Semi -Annual
SW-1
Foam
Semi -Annual
SW-1
Oil Sheen
Semi -Annual
SW-1
Other obvious indicators of stormwater pollution
Semi -Annual
SW-1
Notes: .
1. Measurement Frequency. The first qualitative monitoring event during the term of the permit must
be performed during the initial analytical monitoring event. All subsequent qualitative monitoring
will be performed twice per year, once in the spring (April - June) and once in the fall (September -
November).
Sample Location: SW-1 Visual monitoring may be performed just inside the perimeter fence at a point
where no additional significant materials could reasonably enter the system as a result of facility
operations.

Permit NC00037 19
A. (12). STORMWATER SPECIAL CONDITION - OUTFALL
Representative outfall status has been granted to allow representative stormwater monitoring to be performed
at the manhole located north of the river water intake pump overflow and south of the sludge drying beds.
Should the facility configuration, drainage areas and activities, and/or stormwater outfalls on -site be
significantly altered, the permittee shall notify the Division in writing prior to implementation of said changes.
A. (13.) STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as the
Plan. The Plan shall be considered public information in accordance with Part II, Section E.10. of this
permit. The Plan shall be updated on an annual basis. The Plan shall include, at a minimum, the
following items:
a. Site Plan: The site plan shall provide a description of the physical facility and the potential
pollutant sources which may be expected to contribute to contamination of regulated
stormwater discharges. The site plan shall contain the following:
(1) A general location map (USGS quadrangle map, or appropriately drafted equivalent
map), showing the facility's location in relation to transportation routes and surface
waters, and the name of the receiving water(s) to which the stormwater outfall(s)
discharges. If the discharge is to a municipal separate storm sewer system, the name of
the municipality and the ultimate receiving waters, and accurate latitude and longitude
of the 'point(s) of discharge must be shown.
(2) A narrative description of storage practices, loading and unloading activities, outdoor
process areas, dust or particulate generating or control processes, and waste disposal
practices.
(3) A site map (or series of maps) drawn to scale with the distance legend indicating
location of industrial activities (including storage of materials, disposal areas, process
areas, and loading and unloading areas), drainage structures, drainage areas for each
outfall and activities occurring in the drainage area, building locations and impervious
surfaces, the percentage of each drainage area that is impervious. For each outfall, a
narrative description of the potential pollutants which could be expected to be present
in the regulated stormwater discharge.
(4) A list of significant spills or leaks of pollutants that have occurred at the facility during
the 3 previous years and any corrective actions taken to mitigate spill impacts.
(5) Certification that the stormwater outfalls have been evaluated for the presence of non-
stormwater discharges. The certification statement will be signed in accordance with
the requirements found in Part II, Section B.11.
b. Stormwater Management Plan: The stormwater management plan shall contain a narrative
description of the materials management practices employed which control or minimize the
exposure of significant materials to stormwater, including structural and non-structural
measures. The stormwater management plan, at a minimum, shall incorporate the following:
(1) A study addressing the technical and economic feasibility of changing the methods of
operations and/or storage practices to eliminate or reduce exposure of materials and
processes to stormwater. Wherever practicable the permittee should consider covering
storage areas, material handling operations, manufacturing or fueling operations to
prevent materials exposure to stormwater. In areas where elimination of exposure is
not practicable, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.

Permit NC0003719
(2) A schedule to provide secondary containment for bulk storage of liquid materials,
storage of Section 313 of Title III of the Superfund Amendments and Reauthorization
Act (SARA) water priority chemicals, or storage of hazardous materials to prevent leaks
and spills from contaminating stormwater runoff. If the secondary containment devices
are connected directly to stormwater conveyance systems, the connection shall be
controlled by manually activated valves or other similar devices [which shall be secured
with a locking mechanism) and any stormwater that accumulates in the containment
area shall be at a minimum visually observed prior to release of the accumulated
stormwater. Accumulated stormwater shall be released if found to be uncontaminated.
Records documenting the individual making the observation, the description of the
accumulated stormwater and the date and time of the release shall be kept for a period
of five years.
(3) A narrative description of Best Management Practices (BMPs) to be considered such as,
but not limited to, oil and grease separation, debris control, vegetative filter strips,
infiltration and stormwater detention or retention, where necessary. The need for
structural BMPs shall be based on the assessment of potential of sources contributing
significant quantities of pollutants to stormwater discharges and data collected through
monitoring of stormwater discharges.
(4) Inspection schedules of stormwater conveyances and controls and measures to be taken
to limit or prevent erosion associated with the stormwater systems.
c. Spill Prevention and Response Plan: The Spill Prevention and Response Plan shall incorporate
a risk assessment of potential pollutant sources based on a materials inventory of the facility.
Facility personnel (or team) responsible for implementing the plan shall be identified in the
plan. A responsible person shall be on -site at all times during facility operations that have the
potential to contaminate stormwater runoff through spills or exposure of materials associated
with the facility operations.
d. Preventative Maintenance and Good Housekeeping Program: A preventative maintenance
program shall be developed. The program shall document schedules of inspections and
maintenance activities of stormwater control systems, plant equipment and systems.
Inspection of material handling areas and regular cleaning schedules of these areas shall be
incorporated into the program.
e. Training schedules shall be developed and training provided at a minimum on an annual basis
on proper spill response and cleanup procedures and preventative maintenance activities for all
personnel involved in any of the facility's operations that have the potential to contaminate
stormwater runoff. Facility personnel (or team) responsible for implementing the training shall
be identified in the plan.
f. The Stormwater Pollution Prevention Plan shall identify a specific position(s) responsible for the
overall coordination, development, implementation, and revision to the Plan. Responsibilities
for all components of the Plan shall be documented and position(s) assignments provided.
Plan Amendment: The permittee shall amend the Plan whenever there is a change in design,
construction, operation, or maintenance which has a significant effect on the potential for the
discharge of pollutants via a point source to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis.
The director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum requirements.
The permittee shall provide certification in writing (in accordance with Part III, Standard
Conditions, Section B.11.) to the Director that the changes have been made.
g.

Permit NC0003719
h. Facility Inspections: Inspections of the facility and all stormwater systems shall occur at a
minimum on a semiannual schedule, once in the fall (September - November) and once during
the spring (April - June). The inspection and any subsequent maintenance activities performed
shall be documented, recording date and time of inspection, individual(s) making the inspection
and a narrative description of the facility's stormwater control systems, plant equipment and
systems. Records of these inspections shall be incorporated into the Stormwater Pollution
Prevention Plan.
Visual monitoring as required in A (4) Stormwater Monitoring Requirements/Qualitative
Monitoring shall be performed in addition to facility inspections.
Implementation: Implementation of the Plan shall include documentation of all monitoring,
measurements, inspections, maintenance activities and training provided to employees,
including the log of the sampling data. Activities taken to implement BMPs associated with the
industrial activities, including vehicle maintenance activities must also be recorded. All
required documentation shall be kept on -site for a period of five years and made available to
the Director or his authorized representative immediately upon request.
A. (14) STORMWATER MINIMUM MONITORING AND REPORTING
REQUIREMENTS
Minimum monitoring and reporting requirements are as follows unless otherwise approved in writing
by the Director of the Division of Water quality:
a. If a facility has multiple discharge locations with substantially identical stormwater discharges
that are required to be sampled, the permittee may petition the Director for representative
outfall status. If it is established that the stormwater discharges are substantially identical
and the permittee is granted representative outfall status, then sampling requirements may be
performed at a reduced number of outfalls.
b. Visual monitoring for color, odor, solids, foam, outfall staining, visible sheens and dry weather
flow shall be performed at all stormwater discharge outfall locations. All visual monitoring
shall be documented and records maintained with the Stormwater Pollution Prevention Plan.
The initial visual monitoring event shall be performed simultaneously with the first analytical
monitoring event and documentation of only this initial visual monitoring event shall be
submitted along with the required analytical monitoring submittal.
c. For purposes of the stormwater sampling required in this permit, all samples shall be collected
from a discharge resulting from a representative storm event (See definitions in Part II, Section
A). Failure to monitor storm events in accordance with the specified frequency shall constitute
a violation of this permit. If the stormwater runoff is controlled by a detention pond, the
following sampling requirements shall apply:
(1) If the detention pond detains the runoff generated by one inch of rainfall for 24 hours,
visual observations for color, foam, outfall staining, visible sheens and dry weather flow
are required, but analytical sampling shall not be required.
(2) If the detention pond discharges only in response to a storm event exceeding a 25-year,
24-hour storm, the pond shall be considered a non -discharging stormwater control
system and not subject to NPDES requirements, unless the discharge causes a violation
of water quality standards.
d. Samples analyzed in accordance with the terms of this permit shall be submitted on forms
approved by the Director no later than January 31 for the previous year in which sampling was
required to be performed.

Permit NC0003719
11. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following
rainfall or as a result of snowmelt.
12. Grab Sample
An individual sample collected instantaneously. Grab samples that will be directly analyzed or
qualitatively monitored must be taken within the first 30 minutes of discharge.
13. Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported by
water, air, gravity, or ice from its site of origin which can be seen with the unaided eye.
14. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such as a
city or town.
15. Rinse Water Discharge
The discharge of rinse water from equipment cleaning areas associated with industrial activity.
Rinse waters from vehicle and equipment cleaning areas are process wastewaters and do not include
washwaters utilizing any type of detergent or cleaning agent.
16. Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce stormwater
pollution and is based on an evaluation of the pollution potential of the site.
17. Ten Year Design Storm
The maximum 24 hour precipitation event expected to be equaled or exceeded on the average
once in ten years. Design storm information can be found in the State of North Carolina Erosion and
Sediment Control Planning and Design Manual.
18. Total Flow
The flow corresponding to the time period over which the entire storm event occurs. Total flow
shall be either; (a) measured continuously, (b) calculated based on the amount of area draining to the
outfall, the amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated
by the measurement of flow at 20 minute intervals during the rainfall event.
19. 25-year, 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average,
once in 25 years.

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Permit NC0003719
6. Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure
plus sufficient freeboard to allow for the 25-year, 24-hour storm event.
7. Section 313 Water Priority Chemical
A chemical or chemical category which:
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund
Amendments and Reauthorization Act (SARA) of 1986, also titled the Emergency
Planning and Community Right -to -Know Act of 1986;
b. Is present at or above threshold levels at a facility subject to SARA title III, Section 313
reporting requirements; and
c. That meet at least one of the following criteria:
(1) Is listed in Appendix D of 40 CFR part 122 on either Table II (organic priority
pollutants), Table III (certain metals, cyanides, and phenols) or Table IV (certain
toxic pollutants and hazardous substances);
(2) Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the CWA
at 40 CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality criteria.
8. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and
plastic pellets; finished materials such as metallic products; raw materials used in food processing or
production; hazardous substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and
waste products such as ashes, slag and sludge that have the potential to be released with stormwater
discharges.
9. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable
quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and CFR 117.21) or section
102 of CERCLA (Ref: 40 CFR 302.4).
10. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and
which is directly related to manufacturing, processing or raw material storage areas at an industrial
site. Facilities considered to be engaged in "industrial activities" include those activities defined in 40
CFR 122.26(b)(14). The term does not include discharges from facilities or activities excluded from the
NPDES program.

Permit NC0003719
e. Analytical results from sampling during the final year of the permit term shall be submitted
with the permit renewal application.
f. This permit regulates stormwater discharges associated with industrial activity. Non-
stormwater discharges which shall be allowed in the stormwater conveyance system are:
(1) All other discharges that are authorized by an NPDES permit.
(2) Foundation drains, air -conditioner condensate without added chemicals, springs,
waterline and fire hydrant, water from footing drains, flows from riparian habits and
wetlands, fire -fighting training and fire system testing.
(3) Discharges resulting from fire -fighting.
If the storm event monitored and reported in accordance with this permit coincides with a non-
stormwater discharge, the permittee shall separately monitor and report all parameters as
required under the non-stormwater portion of this permit and provide this information with the
stormwater discharge monitoring report.
g.
A. (15.) STORMWATER DEFINITIONS
1. Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs
may take the form of a process, activity, or physical structure.
2. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single
above ground storage container having a capacity of greater than 660 gallons or with multiple above
ground storage containers located in close proximity to each other having a total combined storage
capacity of greater than 1,320 gallons.
3. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is
not a land treatment facility, a surface impoundment, an injection well, a hazardous waste long-term
storage facility or a surface storage facility.
4. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any
pipe, ditch, channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be
discharged to waters of the state.
5. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least
72 hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm
event may contain up to 10 consecutive hours of no precipitation. For example, if it rains for 2 hours
without producing any collectable discharge, and then stops, a sample may be collected if a rain
producing a discharge begins again within the next 10 hours.

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ECEtIVE
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POINT SOURCE t3RANCt
WATER QUALITY SECTION
PERMIT NAME/OWNERSHIP CHANGE FORM
Michael F. Easley
Govemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E.
Director, Division of Water Quality
CURRENT PERMIT INFORMATION:
Permit Number: N/C/ 0 / 0 / 0 / 3 / 7 / 1 / 9 / or
Certificate of Coverage Number: N/C/G/ / / / / / /
1. Permit holder's name: Monsanto Company
2. Permit's signing official's name and title: Deborah R. Small
(Person legally responsible for permit)
Director of Manufacturing Animal Ae
(Title)
3. Mailing address: 800 North Lindbergh Blvd City: St. Louis
State: MO Zip Code: 63167 Phone: (314 ) 694-8008
IL NEW OWNER/NAME INFORMATION:
1. This request for change is a result of:
_ Change in ownership of company _ Name change for company
X Change in ownership of property/facility _ Name change for property/facility
— Other (please explain):
2. Owner Information
Company or Owner Name: DAK Resins. L.L.C.
(name to be put on permit / certificate of coverage)
Owner's/operator's or signing official's name: Craig Leite Title: Site Manager
Company Contact: Craig Leite
Owner Mailing address: P.O. Box 1690
State: NC Zip Code: 28312
E-mail address: [e-mail]
3. Facility Information
Facility Name: DAK Resins
Title: Site Manager
City: Fayetteville
Phone: ( 910 ) 433-8254
Facility Contact: Craig Leite Title: Site Manager
Facility Mailing address: P.O. Box 1690
State: NC Zip Code: 28312
E-mail address: [e-mail]
City: Fayetteville
Phone: (910 ) 433-8254
SWU-239-102501

PERMIT NAME / OWNERSHIP CHANGE FORM
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION OF WATER QUALITY UNLESS
ALL OF THE APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
1. This completed application
2. Legal documentation of the transfer of ownership (such as a contract, deed, articles of incorporation)
Certification must be completed and signed by both the current permit holder and the new applicant in the case of change of
ownership. For name change only, complete and sign the application certification.
Current Permittee's Certification:
I, Deborah R. Small , attest that this application for name/ownership
change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are no •mpleted and that if all re supporting information and attachments are not included, this application
package will b - r ed as income+. 1
Signature:
Applicant's Certification:
P", „
Date: M —/M3
I, Craig Leite , attest that this application for a name/ownership change
has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are not completed and that if all required supporting information and attachments are not included, this application
package will be returned as incompl#te.
Signature:
Date: 12 - l et -03
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION & MATERIALS,
SHOULD BE SENT TO THE FOLLOWING ADDDRESS:
NC DENR / DWQ / Point Source Branch
Attn: Valery Stephens
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
SWU-239-102501

BK6379PG812
7 1 5. 8 2
CLIHBERLAND COUNTY RC 12/19/2003
_9
ET4rrp�N
Rau�
$60.00.00
Real Estate
Excise Tax
RECEIVED
1E-19•-2003 Furl 4:1 r : 33
J. LEE WARREN JR.
REGISTER OF DEEDS
CUMBERLAND CO., N.C.
Excise Tax $ C.«, D O. 0 0
Recording Time, Book and Page
Tax Lot No.: 0 4(Co 1 " 14P' ? C ? S
Verified by
Parcel Identifier No.
County on the day of
December, 2003 by
Mail after recording to:
401 South Tryon Street, Suite 3000 Fayetteville, NC .28305
Charlotte, NC 28202
Reaves & Reaves
Parker, Poe, Adams & Bernstein L.L.P. (CBL) Attorneys at Law
Three First Union Center PO Box 53555
This instrument was prepared by: Charles B. Lee, Jr., Esq. (PPAB File #CH192/74089)
Brief Description For The Index:
/ i/. Pi 4cnt C,.1' Cr
NORTH CAROLINA SPECIAL WARRANTY DEED
THIS DEED made this / ,S� + day of December, 2003, by and between
• GRANTOR v
GRANTEE
MONSANTO COMPANY, a Delaware corporation
DAK RESINS, LLC, a Delaware limited liability
company
•
Address:
800 North Lindbergh Boulevard
St. Louis, Missouri 63167
Attn: Dana L. Wesley
Address:
:Post Office Box 2042
Wilmington, North Carolina
Attn: Ocsar Montemayor
•
Enter in $ppropriatz block for each party: name, address. and, if appropriate, character of entity, e.g. corporation or partnership.
2'd ibfr99S8i7.0 T 6 d011E! 2lC `Wd 111I D 3Ndf1Q r L T :9 T 6002 6 T °aQ

81(6379PG813.
The designation Grantor and Grantee as used herein shall include said parties, their heirs, successors and assigns,
• and shall include singular, plural, masculine, feminine or neuter as required by context.
WITNESSETH, that Grantor, for a valuable consideration paid by Grantee, the receipt of which is hereby
aclmcwledged, has and by these presents does grant, bargain, sell and convey unto Grantee in fee simple, all that
certain lot or parcel of land situated in Cumberland County, North Carolina and more particularly described as
follows:
See EXHIBIT A. attached hereto and incorporated herein by this reference.
The property hereinabove described was acquired by Grantor by instrument recorded in Book . Pages
TO HAVE AND .TO HOLD the aforesaid lot or parcel of land and all privileges and appurtenances thereto
belonging to the Grantee in fee simple.
And Grantor covenants with the Grantee, that Grantor has done nothing to impair such title as Grantor received, and
Grantor will warrant and defend the title against the lawful claims of all persons claiming by, under or through
Grantor, except for the exceptions hereinafter stated.
Title to the property is subject to all easements, restrictions, covenants and other matters of record or which would
be revealed by an accurate physical survey as well as taxes for the year 2003 due and payable, but not yet
delinquent, and subsequent years, which Grantee hereby assumes and agrees to pay.
IN WITNESS WHEREOF, the Grantor has caused this instrument to be duly executed under seal, the day and year
first above written.
s ew
COUNTY OF`�
GRANTOR:
MONSANTO COMPANY, a Delaware corporation
By:
Name: Dana L. Wesley
Title: Director, Mergers • . • sitions
fez= A-r7 A ro A- C <A.J o w G 7.
I, , a Notary Public of County, State of
certify that , personally came before me this day and
acknowledged that he is o , and that, he, as
, being authorized to do so, executed the for _ •'ng on behalf of the Monsanto Company, a
Delaware corporation..
Witness my hand and official stamp or seal this day of December, 20
Notary Public
Print Name:
My Commission Expires:
6 ' d t•t,99S8170 16 ZI01113 ZIC `WEJ 111I 9 3Ndf1Q C L I :9I CO0E 6 T oaa

BK6379PG814
CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT
\' a`�:ti. c!s�' \c•' \�.'«.'', ' y� sis\\Ys\�%' ��:`.y�\��: �!. . s-'--� vim; ' / C' :! �/i r:�Yii �' -•r-, , Crti•i �, -ice\d..!- \ti's-�
State of California •
County of e. oA 772.44 C'o STr
personally appeared
}
•
before me, L7v.7/ goLZj A/eV/
Nam aid 7111a of Moir (a.g.;Iwo Doe, notary Public"
HOLZWARTH
• Cornmiteion # 2293523 1'
ieCorrr ?mks_ _Nov!..___ ?mod
Nams(s) of Signals)
0 personally known to me
Moved to me on the basis of satisfactory
evidence
to be the person( whose name(e) is/aw
subscribed to the within instrument and
acknowledged to me that he/she:they. executed
the same in him authorized
capacitypes), and that by hisllectiffieic
signaturefe) on the instrument the person(e).,or
the entity upon behalf of which the person(e)
acted, executed the instrument.
WITNESS my hand and official seat.
-1f,
OPTIONAL
Spatial, of Votary Public
Though the information below is not required by law, it may prove valuable to persons relying on the document and could prevent
fraudulent removal and. reattachment of this form to another documenL
Description of Attached Document
Title or Type of Document N 7// O I Al .0Er-/ A4_ o .) i
Document Date: Number of Pages:
Signer(s) Other Than Named Above:
Capacity(ies) Claimed by Signer
Signer's Name:
O Individual
O Corporate Officer — Title(s):
O Partner — 0 Limited .0 General
O Attomey-in-Fad
O Trustee
r l ^.,wwiiww w� /1nr►wl�nig4Al
Foregoing Certificate(s)"of
at: tio-e3,4id----z-
FltaiT THUW..EPR{M'
a SlGNER
Top o1 thumb here
certified to be correct. This instrument and. this certificate are duly registered at the date and time and in the Book and Page shown on the first page .
of./%
I
LEE W , TR.
REGISTER OF DEEDS FOR CUMBERLAND
Deputy/A.; is - Register of Deeds
COUNTY,
•d
.17..179996f7016 i'I011d dr `WdI11ID 3wuna C LI :9T 6002 6T oaa

BDf 6379PG8 15
EXHIBIT A
LEGAL DESCRIPTION
Beginning at a point in the southern right-of-way margin of North Carolina Highway 53,
said highway having a right-of-way of 120 feet; said beginning point being marked by a concrete
monument and being the northeast comer of the property of Maurice Suggs and the northwest
comer of' land shown as Parcel 1 on a Plat of Subdivision recorded in Plat Book 110, Page 09 in
the Cumberland County Registry; thence with the southern right-of-way of Highway 53 S. 68°
44' 35" E. 529.02 feet to an existing concrete monument, the northwest corner of parcel A as
shown on said Plat of Subdivision; thence leaving said right -of way and with the western line of
parcel A S. 12° 44' 07" W. 319.88 feet to an existing iron stake, the southwest corner of parcel
A; thence with the southern line of parcel A S. 76° 23' 29" E. 173.47 feet to an existing iron pipe
the southeast corner of parcel A; thence with the eastern line of said parcel A N. 15° 37' 31" E.
294.56 feet to an existing iron stake in the southern right-of-way for Highway 53; thence with
the southern right-of-way of Highway 53 S. 68° 39' 50" E. 418.29 feet to an existing concrete
monument, the northwest corner of parcel B as shown on said Plat of Subdivision; thence leaving
said right -of way and with the west line of parcel B S. 21° 21' 27" W. 169.83 feet to an existing
iron pipe; thence S. 68° 41' 37" E. 120.99 feet to an existing iron rod with an aluminum Rose
Group Disk cap; thence S. 68° 31' 46" E. 79.48 feet to an existing iron pipe; thence S. 21° 59'
24" W. 42.43 feet to an existing iron pipe, the southwest corner of parcel D; thence S. 68° 55'
41" E. 527.41 feet to ari existing iron pipe, the southeast corner of parcel G as shown on said Plat
of Subdivision; thence with the east line of parcel G N. 21° 23' 00" E. 210.66 feet to an existing
iron stake in the southern right-of-way for Highway 53; thence with the southern right-of-way of
Highway 53 S. 68° 45' 05" E. 1,899.85 feet to an existing concrete monument, the northwest
corner of the E.M. Starling property recorded in Deed Book 983, Page 123 in the Cumberland
County Registry; thence leaving said right -of way and with .said E.M. Starling's west line S. 21°
29' 17" W. 550.89 feet to an existing concrete monument E.M. Starling's westernmost comer,
thence with E.M. Starling's south line S. 68° 46' 32" E. 717.28 feet to an existing iron pipe and a
corner in E.M. Starling's -south line; thence continuing S. 50° 19' 34" E. 307.42 feet to an
existing iron pipe, E.M. Starling's south most corner and a corner along the westerly line of
Falling Run Missionary property line recorded in Deed Book 3576, Page 159 in the Cumberland
County Registry;; thence with the westerly line of Falling Run Missionary property S. 10° 56'
30" W. 107.31 feet to an existing iron pipe; thence continuing along the. westerly line of Falling
Run Missionary property S. 17° 51' 10" W. 183.93 feet to an existing iron pipe; thence
continuing along the westerly line of Falling Run Missionary property S. 08° 20' 31" W. 240.15
feet to an existing concrete monument; thence continuing along the westerly line of Falling Run
Missionary property S. 56° 36' 28" E. 76.97 feet to an existing concrete monument the south,
most corner of Falling Run Missionary property and a point in the NC Products Company's
northerly tine recorded in Deed Book 3237, Page 818 in the Cumberland County Registry;
thence with said NC Products Company's northerly line S. 58° 56' 47" W. 89.95 feet to an
existin.g concrete monument; thence continuing with NC Products Company line S. 60° 51' 00"
W. 2,063.64 feet to an existing concrete monument on the high bank of the Cape Fear. river;
thence continuing S. 60° 51' 00" W. 35.49 feet to a point on the Cape Fear River; thence with the
Cape Fear River along a meander line N. 69° 23' 00" W. 500.00 feet to a point on the Cape Fear.
S •d
1,'99S8.b0 T 6 ZI0111=1 ar `Wd I11 I J 3Ndf1Q r L T :9 T 6002 S T O2 j

•
BK6379PG816
River; thence continuing with the Cape Fear River N. 78° 36' 49" W. 622.90 feet to a point on
the Cape Fear River; thence a line leaving said meander line of the Cape Fear River, and
separating Parcel 1 from Parcel 2 as shown on a Plat of Subdivision recorded in Plat Book 110,
Page 09 in the Cumberland County Registry N. 34° 39' 19" E. 29.84 feet to an existing iron rod
with an aluminum Rose Group Disk cap on the high bank* of the 'Cape Fear River; thence
continuing N. 34° 39' 19" E. 580.54 feet to an existing iron rod with an aluminum Rose Group
Disk cap; thence a new line N. 69° 50' 15" W. 262.48 feet to an existing iron rod with an
aluminum Rose Group Disk cap; thence a line N. 20° 09' 37" E. 229.91 feet to an existing iron
rod with an aluminum Rose Group Disk cap; thence a line N. 68° 46' 33" W. 211.33 feet to an
existing iron rod with an aluminum Rose Group Disk cap, said Rose Group Disk being in the
easterly property line of E.I. Dupont De Nemours and Company recorded in Deed Book 4787,
Page 536 as shown on a Plat of Subdivision recorded in Plat Book 110, Page 09 in the
Cumberland County Registry; thence with said easterly line of E.L Dupont De Nemours and
Company N. 21° 06' 13" E. 222.49 feet to an existing concrete monument; thence continuing
with the easterly line of E.I. Dupont De Nemours and Company N. 45° 03' 29" E. 125.70 feet to
an existing cotton spindle; thence N. 21° 11' 55" E. . 598.25 feet to an existing concrete
monument, the northeast corner of said E.I. Dupont De Nemours and Company; thence with the
north line of E.I. Dupont De Nemours and Company N. 68° 32' 16" W. 247.73 feet to an existing
concrete monument, the southeast comer of the Fayetteville Fiber, Inc. property recorded in
Deed Book 5772, Page 600 in the Cumberland County Registry; thence with said Fayetteville
Fiber Inc.'s easterly line N. 21° 08' 53" E. 850.96 feet to an existing concrete monument; thence
continuing with Fayetteville Fiber Inc.'s easterly line N. 11° 19' 50" W. 71.60 feet to an existing
concrete monument a point in Fayetteville Fiber Inc.'s northerly line; thence N. 68° 47' 1T' W.
589.60 feet to an existing iron rod with an aluminum Rose . Group Disk cap, a point in
Fayetteville Fiber Inc.'s northerly line; thence continuing N. 68° 47' 17" W. 241.48 feet to an
existing concrete monument, Fayetteville Fiber Inc.'s northwest comer, thence with Fayetteville
Fiber Inc.'s westerly line S. 21° 16' 37" W. 907.18 feet to an existing iron stake, Fayetteville
Fiber Inc.'s southwest corner, said stake also being in E.I. Dupont De Nemours and Company's
north line; thence with E.I. Dupont De Nemours and Company's north line N. 68° 32' 27" W.
52.56 feet to an existing concrete monument; thence continuing with E.I. Dupont De Nemours
and Company's north line N. 68° 32' 24" W. 783.31 feet to an existing concrete monument, said
concrete monument also being in Maurice Suggs' western line; thence with Maurice Suggs'
western line N. 12° 49' 20" E. 1,240.75 feet to the Beginning and containing 171.82 acres and
being subject to all legal highways and easements of record.
9 ' d 99S8�0 T 6 21011E dr `WEB I11I 9 3wuna C L T :9 T E0026I pea

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