NCS000539_Fact sheet binder_20230113

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer / Date
Brianna Young 12/7/2022
Permit Number
NCS000539
Owner / Facility Name
Tyton NC Biofuels, LLC / Tyton NC
Biofuels, LLC
SIC Code / Category
2869 / Industrial Organic Chemicals NEC
Fuel Ethanol Production
Basin Name / Sub -basin number
Lumber / 03-07-53
Receiving Stream / I UC
UT to Little Marsh Swam / 030402030603
Stream Classification / Stream Segment
C; Sw / 14-22-1-3
Is the stream impaired [on 303(d) list]?
No
Any TMDLs?
No Statewide Mercury TMDL
Any threatened and/or endangered species?
See Section 2 below
Any compliance concerns?
See Section 2 (below)
Any permit mods since lastpermit?
See Section 2 below
New expiration date
1/31/2028
Comments on Draft Permit?
See Section 6 (below)
Section 1. Facility Activities and Process:
Tyton NC Biofuels, LLC is an ethanol production facility. Fuel ethanol is produced by
fermentation of corn and distillation and dehydration to produce ethanol at a
concentration of greater than 95%. The ethanol is denatured with unleaded gasoline and
sold for fuel blending and a coproduct is distillers dried grains with solubles (animal
food).
All stormwater from the plant discharges through a single stormwater detention pond,
with a controlled outlet to a single outfall. The primary raw materials are corn, enzymes,
yeast, nutrients, and gasoline. The final products are denatured ethanol for fuel and
distillers dried grain with solubles. Minor spills, drips, or leaks from process equipment
may allow contact with stormwater.
Since the permit renewal application has been submitted, production at the facility has
been on and off, and per a letter received by DEQ in October 2020, Tyton ceased
operations in October 2018 and has not operated since. Per the inspection report from
June 2022, the facility plans to resume operations with new processes including:
• Replacing corn with sorghum
• Installing new evaporation, drying, and extraction systems
• New boilers with steam turbines,
• New anaerobic digestor
Per the inspection report from June 2022, there is currently storage of corn in silos leased
by Smithfield, 2-3 totes of chemicals used for the boilers prior to shutdown, enzymes and
emulsifiers for corn, and some gear and hydraulic oils for equipment maintenance.
Ownership will change from Tyton NC Biofuels, LLC to Benchmark Raeford, LLC.
Page 1 of 7

SW001:
The stormwater detention pond receives the rainfall runoff from the entire plant site. The
stormwater detention pond is designed to allow sediment to settle for periodic removal.
The discharge structure is designed to release the inflow at a rate not exceeding the
predevelopment rate. The runoff from the access road is to the stream north of the road
(does not go into the stormwater pond). No industrial activities which have the potential
to expose stormwater to raw materials, finished products, or waste products take place on
or north of the access road.
Outfall 002 (covered by NCG500645):
Boiler Blowdown and Cooling Tower blowdown go to the existing stormwater detention
pond. Discharge from the stormwater detention pond on the southeast side of the facility
and receives all of the rainfall runoff from the manufacturing and material handling areas
as well as utility blowdowns permitted under NCG500645. FRO expressed concern in
July 2010 about boiler blowdown and cooling tower blowdown entering the pond, noting
the facility may need to consider rerouting discharges so as not to impact the stormwater
basin.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES
regulations define stormwater discharge associated with industrial activity in 40 CFR
§122.26 (b)(14) as: "the discharge from any conveyance that is used for collecting and
conveying storm water and that is directly related to manufacturing, processing or raw
materials storage areas at an industrial plant. The term does not include discharges from
facilities or activities excluded from the NPDES program under this part 122. For the
categories of industries identified in this section, the term includes, but is not limited to,
storm water [sic] discharges from industrial plant yards; immediate access roads and rail
lines used or traveled by carriers of raw materials, manufactured products, waste
material, or byproducts used or created by the facility; material handling sites; refuse
sites; sites used for the application or disposal of process waste waters (as defined at part
401 of this chapter); sites used for the storage and maintenance of material handling
equipment; sites used for residual treatment, storage, or disposal; shipping and receiving
areas; manufacturing buildings; storage areas (including tank farms) for raw materials,
and intermediate and final products; and areas where industrial activity has taken place in
the past and significant materials remain and are exposed to storm water. For the
purposes of this paragraph, material handling activities include storage, loading and
unloading, transportation, or conveyance of any raw material, intermediate product, final
product, byproduct or waste product. The term excludes areas located on plant lands
separate from the plant's industrial activities, such as office buildings and accompanying
parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• 2010 to October 2018, benchmarks exceeded for: (NOTE: continuous monitoring
was not performed in this time period)
o Pond water: Arsenic 2x, Zinc 2x, TSS Ix
o Fenn D, E, F: BOD Ix, COD Ix, TSS Ix
Page 2 of 7

o Condensate: BOD 2x, COD 2x, O&G Ix, pH min not reached Ix, Total
Phosphorus Ix, TSS Ix, TKN Ix
o Stillage syrup: BOD Ix, COD Ix, O&G Ix, pH min not reached Ix, Total
Phosphorus Ix, TSS Ix, TKN 1
o Outfall 001: COD Ix
Per the June 2022 inspection report, benchmarks were only exceeded for BOD 2x and
COD Ix.
NOV-2011-PC-0278 was issued in a letter dated April 20, 2011 to the previous owners
for failure to perform analytical monitoring as required by the permit for the previous
monitoring period (only BOD and COD were monitored).
Threatened/Endangered Species:
There are no threatened or endangered species at the facility site, however there are
species located nearby.
• Southern Chorus Frog: NC Status SR
• Ornate Chorus Frog: NC Status Endangered
• Eastern Tiger Salamander: NC Status Threatened
• Cypress Savanna (typic subtype)
• Awned Meadow -Beauty: NC Status SC-V
• Netted Nutrush: NC Status SC-V
• Mabee's Salamnder: NC Status Threatened
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities
and data was submitted for 2010 to October 2018. Quantitative sampling included pH,
BOD, COD, and TSS.
Unlike most stormwater permits in its program, the Division is proposing a permit
structure with outfall-specific monitoring for discharges. Parameters are based on
potential pollutants in the drainage area, sampling results, and in some cases, dependent
upon future activities (e.g., ash removal through the drainage area). Below is a table of
the proposed monitoring for each outfall at the Tyton NC Biofuels, LLC site.
Outfall SW001
Quarterly monitoring
Total Suspended Solids
BASIS: Potential pollutant from drainage area and BMP
(TSS)
effectiveness indicator.
Quarterly monitoring
pH
BASIS: Pollutant indicator.
Quarterly monitoring
Total Rainfall
BASIS: Discharge potential indicator
Page 3 of 7

Quarterly monitoring
Non -Polar Oil &Grease
BASIS: Potential pollutant from lubricants; Method 1664
SGT-HEM targets petroleum -based O&G
Quarterly monitoring
Monthly Oil Usage
BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD
BASIS: Discharge potential indicator
Quarterly monitoring
COD
BASIS: Discharge potential indicator
Quarterly monitoring
Ethanol
BASIS: Discharge potential indicator
Stormwater Benchmarks and Tiered Response: Rather than limits, North Carolina
NPDES Stormwater permits contain benchmark concentrations. Stormwater benchmarks
are numerical action levels for stormwater monitoring. Benchmarks are not effluent
limits, and benchmark exceedances are not permit violations. Benchmarks provide
facilities a tool for assessing the significance of pollutants in stormwater discharges and
the effectiveness of best management practices (BMPs). Benchmark concentrations are
intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan (SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase
management actions, increase record keeping, and/or install stormwater BMPs in a tiered
program. The permit establishes a tiered approach to specify actions the permittee must
take in response to analytical results above benchmark concentrations. The tiered
structure of the permit provides the permittee and DEMLR wide flexibility to address
issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the
guidance of DWR. NC DWR follows established federal procedures for calculating acute
standards when developing the benchmarks. Just like the acute standards, metals
benchmarks normally reflect one half of the calculated Final Acute Value (the "1/2
FAV" ). In most cases, translation into total recoverable values is based on an assumed
hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L. Acute
standards protect aquatic life from negative impacts of short-term exposure to higher
levels of chemicals where the discharge enters a waterbody. The Stormwater Permitting
Program applies this approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some
outfalls is adequate to characterize potential pollution or BMP effectiveness. For
example, one or more metals or other parameters may serve as an adequate tracer for the
presence of ash pollution during disturbance or ash removal in specific drainage areas at
this site. For parameters that do not have a stormwater benchmark, the Division may
Page 4 of 7

develop a benchmark value if appropriate toxicity data become available or if rising
trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter
Benchmark
Basis
BOD
30 mg/L
BPJ; Based on Secondary Treatment Regulation
40 CFR 133.03
COD
120 mg/L
BPJ; Generally found at levels 4x BODS in
domestic wastewaters
Ethanol
3,900 m /L
'/2 FAV
Total Suspended
100 mg/L
National Urban Runoff Program (NURP) Study,
Solids (TSS)
1983
H
6 s.u. — 9 s.u.
NC Water Quality Standard (Range)
Non -Polar Oil &
Review of other state's daily maximum
Grease, EPA
15 mg/L
benchmark concentration for this more targeted
Method 1664
O&G; NC WQS that does not allow oil sheen in
SGT-HEM
waters
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the
EPA and NC's pollution prevention approach to stormwater permitting. The Division's
maintains that implementation of Best Management Practices (BMPs) and traditional
stormwater management practices that control the source of pollutants meets the
definition of Best Available Technology (BAT) and Best Conventional Pollutant Control
Technology (BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site -specific plans to minimize and
control pollutants in stormwater discharges associated with the industrial activity. Title
40 Code of Federal Regulations (CFR) § 122.44(k)(2) authorizes the use of BMPs in lieu
of numeric effluent limitations in NPDES permits when the agency finds numeric
effluent limitations to be infeasible. The agency may also impose BMP requirements
which are "reasonably necessary" to carry out the purposes of the Act under the authority
of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included under
the authority of both of these regulatory provisions. In essence, the pollution prevention
and BMP requirements operate as limitations on effluent discharges that reflect the
application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee
to propose an alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive
exceedances, exercise the option of contacting the DEMLR Regional Engineer as
provided below in Tier Three. The Regional Engineer may direct the response
actions on the part of the permittee as provided in Tier Three, including reduced
or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee
may propose an alternative monitoring plan for approval by the Regional
Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring
changes sooner than Tier Three (upon any four benchmark exceedances) and gives
Page 5 of 7

guidance on one option to take. For example, the permittee may request that mercury
only be monitored semi-annually under the tiers, or that only parameters over the
benchmark be monitored more frequently. In this way, changes to the monitoring scheme
for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan (SWPPP) requirements to
include an annual certification that stormwater outfalls have been evaluated for
the presence of non-stormwater discharges, and if any are identified, how those
discharges are permitted or otherwise authorized.
• Requirement to submit a request for permit modification if the facility identifies
or creates any new outfalls, removes outfalls, or alters any drainage area that
changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and
consider the safety of its personnel in fulfilling sampling obligations under the
permit.
• Federal regulations require electronic submittal of all discharge monitoring
reports (DMRs). If a state does not establish a system to receive such submittals,
then permittees must submit DMRs electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls
throughout year.
Section 4. Changes from previous permit to draft:
• Monitoring increased from semi-annually to quarterly for all parameters
(qualitative and quantitative)
• "No discharge" clarifications made
• eDMR requirement added
• Boilerplate language moved into body of the permit; boilerplate no longer
attached
• Benchmarks updated for parameters per guidance from DWR Standards group on
stormwater benchmarks
Section 5. Changes from draft to final:
• Receiving stream name corrected on map legend
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility made: 4/28/2022
• Initial contact with Regional Office: 428/2022
• Draft sent to CO peer review: 6/23/2022 (not completed due to change in review
process)
• Draft sent to Fayetteville Regional Office: 10/24/2022
• Final permit sent for supervisor signature: 12/12/2022
Page 6 of 7

Section 7. Comments received on draft permit:
• Mike Lawyer (DEMLR FRO; via email 11/1/2022): In the cover letter for the
subject draft permit, it states under the section about significant changes from the
current permit that units of measure for several benchmarks have been changed
from mg/L to ug/L. It also states that changes have been made to several
monitoring parameters. The units of measure in the permit are all mg/L and the
only change in parameters is the non -polar oil & grease with benchmark of 15
mg/L (current/expired permit has the basic oil & grease with benchmark of 30
mg/L).
o DEMLR response: This is standard language held over from the
template.
• Wes Plummer (Tyton NC Biofuels; via email 12/5/2022):
o The legend for the map on page six incorrectly identifies Little Marsh
Swamp as Little March Swamp
■ DEMLR response: The name has been corrected.
o Starting on page five of the draft statements mention "outfalls" yet during
the recent Tyton site visit it was determined that the Tyton site has only
one outfall which is identified as Outfall 2 in the Tyton SPPP.
■ DEMLR response: This is standard language included in all
stormwater permits. This will remain for consistency across the
Stormwater Program.
o Tyton strongly believes the benchmark for Non -Polar Oil and Grease
would be more appropriate at 30mg/L as opposed to the 15mg/L.
■ DEMLR response: The benchmark is used for all stormwater
permits and created by the Standards and Classifications Branch of
the DEQ Division of Water Resources. Therefore the benchmark
will remain as is.
Page 7 of 7

Young, Brianna A
From: Wes Plummer <[e-mail]>
Sent: Friday, January 13, 2023 1:07 PM
To: Young, Brianna A
Cc: Jim Massoni
Subject: Re: [External] Re: Issued NPDES Permit NCS000539
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Yes I have
Thank you
On Fri, Jan 13, 2023 at 11:01 AM Young, Brianna A <[e-mail]> wrote:
Good morning,
I am following up on my previous email. Please confirm that you received the attached document, were able to open
and view the document, and have saved/printed a copy for your records.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604

Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our
offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the
public during this challenging time.
From: Young, Brianna A
Sent: Tuesday, January 10, 2023 8:27 AM
To: Jim Massoni <[e-mail]>
Cc: Wes Plummer <[e-mail]>
Subject: RE: [External] Re: Issued NPDES Permit NCS000539
Good morning,
Attached is the issued NPDES permit for Tyton NC Biofuels, LLC (NCS000539). Please respond to this email confirming
that you received the attached document, were able to open and view the document, and have saved/printed a copy
for your records.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our
offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the
public during this challenging time.
From: Jim Massoni <[e-mail]>
Sent: Monday, January 9, 2023 10:31 PM
To: Young, Brianna A <[e-mail]>
Cc: Wes Plummer <[e-mail]>
Subject: [External] Re: Issued NPDES Permit NCS000539
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Electronic transmission of documents is acceptable.
Jim Massoni
On Jan 9, 2023, at 1:03 PM, Young, Brianna A <[e-mail]> wrote:
Good afternoon,
In order to provide more convenience, control, and security to our permittees and assist them in
processing their transactions, the Division of Energy, Mineral, and Land Resources, is currently
transitioning towards electronic correspondence. This will hopefully provide more efficient service to
our permittees and other partners and will allow us to more effectively process and track documents.

We are writing to ask you for your approval of the transmittal of documents related to your permitting
and related activities with the Division in an electronic format. Documents will be emailed to the
appropriate contact person(s) in your organization in a PDF format.
Please respond to me through email with verification that transmittal of your documents in an
electronic manner is acceptable to you. If you have any questions, please feel free to contact me.
Thank you
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
Brianna.Young6Dncdenr.eov (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
<image001.png>
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate
staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate
your patience as we continue to serve the public during this challenging time.
Wes Plummer

Plant Manager
Tyton NC Biofuels, LLC
800 Pate Road
Raeford, NC 28376
Cell: 401.258.3090
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Nov o 12e77
DENR-LAND QUALITY
STORWNATER PERMiTTRIG
NORTH CAROLINA - HOKE COUNTY
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary Public of said County and
State, duly commissioned, qualified, and authorized by law to
administer oaths, personally appeared Ken MacDonald who
being first duly sworn, deposes and says: that he is Publisher of
BROWN PUBLISHING, LLC, engaged in the publication of a newspa-
per known as THE NEWS -JOURNAL, published, issued, and entered
as second class mail in the City of Raeford, in said County and
State; that he is authorized to make this affidavit and sworn state-
ment; that the notice, legal advertisement or other advertisement,
a true copy of which is attached hereto, was published in THE
NEws-JOURNAL on the following dates:
OCrOBER 26,2022
and that said newspaper in which such notice, paper, document
or legal advertisement was published was, at the time of each
and every such publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597 of the General
Statutes of North Carolina and was a qualified newspaper within
the meaning of Section 1-597 of the General Statutes of North
Carolina.
This day of Q r , 2022
Publisher
Sworn to and subscribed before me, this 2r7 day of
My Commission expires:
3 -Zt - ZozG
CATHARIN SHEPARD
NOTARY PUBLIC
HOKE COUNTY, NC
W Commission Expires 3-21-2026

The North Carolina Environmental Management Commission proposes to issue NPDES
stormwater discharge permits) to the person(s) listed below. Public comment or objec-
tion to the draft permits is invited. Written comments regarding the proposed permit will
be accepted until 30 days after the publish date of this notice and considered in the final
determination regarding permit issuance and permit provisions. The Director of the NC Di-
vision of Energy, Mineral, and Land Resources (DEMLR) may hold a public hearing should
there be a significant degree of public interest, Please mail comments and/or information
requests to DEMLR at 1612 Mail Service Center, Raleigh, NC 27699-1612.
•Tyton NC Biofuels, LLC [PO Box 372098, satellite Beach, FL 32937] has requested re-
newal of permit NCS000539 for the Tyton NC Biofuels, -LLC facility in Hoke County. This fa-
cility discharges to an unnamed tributary to Little Marsh Swamp in the Lumber River Basin.
Interested persons may visit DEMLR at .512 N. Salisbury street, Raleigh, NC 27604 to
review information on file. Additional information on NPDES permits.and this notice may
be found on our website: https://deq.nc.gov/about/divisions/energy-mineral-and-land-
resources/stormwater/stormwater-program/stormwate r- pu blic- notices, or by contacting
Brianna Young at [e-mail] or 919-707-3647.

Young, Brianna A
From: Lawyer, Mike
Sent: Tuesday, November 1, 2022 12:45 PM
To: Young, Brianna A
Subject: RE: Draft permit NCS000539 for public notice
Brianna,
In the cover letter for the subject draft permit, it states under the section about significant changes from the current
permit that units of measure for several benchmarks have been changed from mg/L to ug/L. It also states that changes
have been made to several monitoring parameters. The units of measure in the permit are all mg/L and the only change
in parameters is the non -polar oil & grease with benchmark of 15 mg/L (current/expired permit has the basic oil &
grease with benchmark of 30 mg/L).
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Office: 910-433-3300 1 Direct: 910-433-3394
mike. lawyer(cDncdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301
,:��-D E
NA q7t
may-+orE IouWrrr
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From: Young, Brianna A <[e-mail]>
Sent: Monday, October 24, 2022 12:08 PM
To: Lawyer, Mike <[e-mail]>
Subject: Draft permit NCS000539 for public notice
Hello Mike,
The draft permit for Tyton Biofuels (NCS000539) is going out to public notice. Please provide any comments by
November 30, 2022.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
D 0
, t �: � ��� - E-
ti;
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public
during this challenging time.

Young, Brianna A
From: Young, Brianna A
Sent: Monday, December 5, 2022 3:45 PM
To: Wes Plummer
Subject: RE: [External] Fwd: Message from "dhcppc0"
Good afternoon Wes,
Thank you for submitting comments on the draft permit. Please see below for responses to the submitted comments.
The legend for the map on page six incorrectly identifies Little Marsh Swamp as Little March Swamp
The name has been corrected.
Starting on page five of the draft statements mention "outfalls" yet during the recent Tyton site visit it was
determined that the Tyton site has only one outfall which is identified as Outfall 2 in the Tyton SPPP.
This is standard language included in all stormwater permits. This will remain for consistency across the Stormwater
Program.
Tyton strongly believes the benchmark for Non -Polar Oil and Grease would be more appropriate at 30mg/L as
opposed to the 15mg/L.
The benchmark is used for all stormwater permits and created by the Standards and Classifications Branch of the DEQ
Division of Water Resources. Therefore the benchmark will remain as is.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public
during this challenging time.
From: Wes Plummer <[e-mail]>
Sent: Monday, December 5, 2022 12:59 PM
To: Young, Brianna A <[e-mail]>
Subject: [External] Fwd: Message from "dhcppc0"

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Brianna;
Please see attached letter regarding responding to Stormwater permit no. NCS000539.
Thank you
---------- Forwarded message ---------
From: <[e-mail]>
Date: Mon, Dec 5, 2022 at 12:52 PM
Subject: Message from "dhcppc0"
To: Wes P <[e-mail]>, Richard Brehm <[e-mail]>
This E-mail was sent from "dhcppc0" (Aficio MP C2051).
Scan Date: 12.05.2022 12:33:23 (-0500)
Queries to: [e-mail]
Wes Plummer
Plant Manager
Tyton NC Biofuels, LLC
800 Pate Road
Raeford, NC 28376
Cell: 401.258.3090

�,,, TYTO N
Brianna Young
Environmental Program Consultant
DEMLR Stormwater Program
1612 Mail Service Center
Raleigh, NC 27699
December 5, 2022
Subject: Draft NPDES Stormwater Permit NCS000539
Dear Brianna,
Tyton NC Biofuels has reviewed the draft permit sent October 31, 2022 and offers the following
comments.
• The legend for the map on page six incorrectly identifies Little Marsh Swamp as Little
March Swamp
• Starting on page five of the draft statements mention " outfalls " yet during the recent
Tyton site visit it was determined that the Tyton site has only one outfall which is
identified as " Outfall 2 " in the Tyton SPPP.
• Tyton strongly believes the benchmark for Non -Polar Oil and Grease would be more
appropriate at 30mg/L as opposed to the 15mg/L.
Please review our requested changes and contact us with your comments.
Re
Wes Plummer
Plant Manager
Tyton NC Biofuels
800 Pate Road • Raeford, NC 28376 • Ph: 910.878.7820
www.tytonbiofuels.com

4/27/22, 4:31 PM
North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre -Populated Annual Report form • Print
an Amended a Annual Report form
Limited Liability Company
Legal Name
Tyton NC Biofuels LLC
Information
Sosld: 1387011
Status: Current -Active O
Date Formed: 6/26/2014
Citizenship: Foreign
State of Incorporation: DE
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: CT Corporation System
Addresses
Reg Office
160 Mine Lake Ct Ste 200
Raleigh, NC 27615-6417
Mailing
PO Box 4913
Stateline, NV 89449
Company Officials
Reg Mailing Principal Office
160 Mine Lake Ct Ste 200 800 Pate Road
Raleigh, NC 27615-6417 Raeford, NC 28376
All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20.
Manager Manager Manager
Barbara B Carlisle escottventures, inc Adam Waldman
PO Box 4913 PO Box 372516 5163 Tilden Street NW
Stateline NV 89449 Satellite Beach FL 32937 Washington DC 20016
https://www.sosnc.gov/oniine_services/search/Business_Registration_ResuIts 1 /2

4/27/22, 4:31 PM
North Carolina Secretary of State Search Results
https://www.sosnc.gov/oniine_services/search/Business_Registration_ResuIts 2/2

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
Tyton NC Biofuels, LLC
Attn: James Massoni, Manager
PO Box 372098
Satellite Beach, FL 32937
NORTH CAROLINA
Environmental Quality
June 8, 2022
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater Permit NCS000639
Tyton NC Biofuels, LLC
Hoke County
Dear Mr. Massoni:
On June 2, 2022, a site inspection was conducted for the Tyton NC Biofuels, LLC facility located at 800 Pate Road, Raeford,
Hoke County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Wes Plummer,
Plant Manager, was also present during the inspection and his time and assistance is greatly appreciated. The site visit and
file review revealed that the subject facility is covered by NPDES Stormwater Permit NCS000539. Permit coverage
authorizes the discharge of stormwater from the facility to receiving waters designated as a UT of Little Marsh Swamp, a
class C;Sw stream in the Lumber River Basin.
As a result of the inspection, the facility was found to be compliant with the conditions of NPDES Stormwater Permit
NCS000539 permit. Please refer to the enclosed Compliance Inspection Report for additional comments and observations
made during the inspection.
Please be advised that violations of the NPDES Stormwater Permit are subject to a civil penalty assessment of up
to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with
understanding any aspect of your permit, please contact me at [phone] or via e-mail at [e-mail].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
Enclosure: Compliance Inspection Report
ec: Richard Brehm, General Manager — Tyton NC Biofuels, LLC
Wes Plummer, Plant Manager — Tyton NC Biofuels, LLC
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO — DEMLR, Stormwater Files
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green .Street, Suite 714 1 Fayetteville, North Carolina 28301.
DnpaMieatotEmtrmmmtat 4u�711y 910.433.3300

Compliance Inspection Report
Permit: NCS000539 Effective: 10/01/10 Expiration: 09/30/15 Owner: Tyton NC Biofuels LLC
SOC: Effective: Expiration: Facility: Tyton NC Biofuels, LLC
County: Hoke 800 Pate Rd
Region: Fayetteville
Raeford NC 28376
Contact Person: Richard Brehm Title: General Manager Phone: [phone]
Directions to Facility:
The facility is located on the east side of Pate Road approximately 1.25 miles north of the intersection of Pate Road (SR1431) with
NC Highway 20 in Hoke County
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Wes Plummer
Related Permits:
Inspection Date: 06/02/2022 Entry Time 10:OOAM
Primary Inspector: Mike Lawyer
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: 0 Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
910-248-6709
Exit Time: 12:05PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 3

Permit: NCS000539 Owner - Facility: Tyton NC Biofuels LLC
Inspection Date: 06/02/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary
Permit expired on September 30, 2015. A permit renewal application was received by the Division on August 18, 2015 and
the permit has been administratively extended with the same conditions until a new permit is issued. Per documentation
received from facility personnel in 2019 and 2020, facility operations ceased in late 2018 and have not resumed. Inspection
conducted as part of the permit renewal process. Met with Wes Plummer, Plant Manager, to discuss schedule for plant
operations, review the facility's Stormwater Pollution Prevention Plan (SPPP) and historical monitoring records.
According to Mr. Plummer, there are plans to resume operations with new processes to include: replacing corn with
sorghum; installing new evaporation, drying and extraction systems; new boilers with steam turbines; and a new anaerobic
digestor. Ownership of the facility will change from Tyton NC Biofuels, LLC to Benchmark Raeford, LLC within approximately
two months. Presently, there is some storage of corn in silos leased by Smithfield, 2-3 totes of chemicals that were used for
the boilers prior to shutdown, enzymes and emulsifiers for corn, and some gear & hydraulic oils for equipment maintenance,
all stored indoors.
Facility's SPPP appeared to contain all required components and was updated through 2018 when the plant ceased
operations. Monitoring records from 2015 through 2018 when the plant was operational show an exceedance of the
benchmark value for BOD in September 2016 and exceedances for BOD and COD in October 2018. All other monitoring
results were below benchmarks. After the records review, observations were made of the internal drainage ditches leading to
a retention pond, secondary containment for ASTs, retention pond, and stormwater discharge outfall.
Page 2 of 3

Permit: NCS000539 Owner- Facility:Tyton NC Biofuels LLC
Inspection Date: 06/02/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
N El ❑ ❑
# Does the Plan include a General Location (LISGS) map?
0 ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
N ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
E ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0 ❑
# Has the facility evaluated feasible alternatives to current practices?
❑
# Does the facility provide all necessary secondary containment?
0 El 0 ❑
# Does the Plan include a BMP summary?
N El ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
N El ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑ El 0
# Does the facility provide and document Employee Training?
0 ❑ ❑ EJ
# Does the Plan include a list of Responsible Party(s)?
0❑ El ❑
# Is the Plan reviewed and updated annually?
0❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 EJ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑
Comment
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0❑ El ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 M❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? El ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑
# Were all outfalls observed during the inspection? E ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ El R
Comment:
Page 3 of 3

Young, Brianna A
From: Young, Brianna A
Sent: Thursday, June 2, 2022 4:23 PM
To: Wes Plummer
Subject: RE: [External] Stormwater permit NCS000539
Good afternoon Wes,
I cannot find where I responded to your question. I apologize for the delay if that is the case. Please see below:
The main thing I'm not clear on is what would the electronic spreadsheet summarizing monitoring data look like. All
of the past contacts for that info are no longer here so I must search for this past data. As I stated this plant is not
operational. We only have one outfall from the site and the water level to get to that outfall is well below any flow
since we have not operated.
The electronic spreadsheet would be a compilation of past monitoring results. This would consist of past lab data
available either electronically or in paper form depending on how records were kept at the facility. I am requesting that
monitoring results (that are available for discharges that occurred) since the last permit issuance be submitted. Please
let me know if you have any other questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail] (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolin-
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We
appreciate your patience as we continue to serve the public during this challenging time.
From: Young, Brianna A
Sent: Thursday, May 5, 2022 1:35 PM
To: Wes Plummer <[e-mail]>
Subject: RE: [External] Stormwater permit NCS000539
Hello Wes,
I will review your questions and get back to you next week.

Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
Brianna.Young6Dncdenr.eov (e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We
appreciate your patience as we continue to serve the public during this challenging time.
From: Wes Plummer <[e-mail]>
Sent: Thursday, May 5, 2022 9:11 AM
To: Young, Brianna A <[e-mail]>
Cc: Wes Plummer <[e-mail]>
Subject: [External] Stormwater permit NCS000539
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Good morning;
I have started looking into the info needed for our renewal of our stormwater permit. I have a few questions since we
are not in a standard operating condition. If you would help me with them it will help me complete the process more
efficiently. Please not our issues below:
1. Tyton has been in an idle condition for a little more than (4) years. This could change at any time. We have
been waiting for financing to re -tool the facility to make it more financially viable.
2. THe facility has been empty with no discharges for this period of time. Basically rainwater in and rainwater
out.
3. We have had a change in management that will require DOSA updating that looks pretty simple. Also some of
the contact phones have changed which are also simple.
4. The main thing I'm not clear on is what would the electronic spreadsheet summarizing monitoring data look
like. All of the past contacts for that info are no longer here so I must search for this past data. As I stated this
plant is not operational. We only have one outfall from the site and the water level to get to that outfall is well
below any flow since we have not operated.
It may be easier to call me if you like to discuss. I don't mean to make you do a bunch of extra work. I have my cell
phone with me all the time so please feel free to call anytime.
Thank You

Wes Plummer
Plant Manager
Tyton NC Biofuels, LLC
800 Pate Road
Raeford, NC 28376
Cell: 401.258.3090

Young, Brianna A
From: Wes Plummer <[e-mail]>
Sent: Thursday, May 5, 2022 9:11 AM
To: Young, Brianna A
Cc: Wes Plummer
Subject: [External] Stormwater permit NCS000539
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Good morning;
I have started looking into the info needed for our renewal of our stormwater permit. I have a few questions since we
are not in a standard operating condition. If you would help me with them it will help me complete the process more
efficiently. Please not our issues below:
1. Tyton has been in an idle condition for a little more than (4) years. This could change at any time. We have
been waiting for financing to re -tool the facility to make it more financially viable.
2. THe facility has been empty with no discharges for this period of time. Basically rainwater in and rainwater
out.
3. We have had a change in management that will require DOSA updating that looks pretty simple. Also some of
the contact phones have changed which are also simple.
4. The main thing I'm not clear on is what would the electronic spreadsheet summarizing monitoring data look
like. All of the past contacts for that info are no longer here so I must search for this past data. As I stated this
plant is not operational. We only have one outfall from the site and the water level to get to that outfall is well
below any flow since we have not operated.
It may be easier to call me if you like to discuss. I don't mean to make you do a bunch of extra work. I have my cell
phone with me all the time so please feel free to call anytime.
Thank You
Wes Plummer
Plant Manager
Tyton NC Biofuels, LLC
800 Pate Road
Raeford, NC 28376
Cell: 401.258.3090
ff

Permit Coverage
Aa Renewal Application Form NPDES Permit Number
NCDENR National Pollutant Discharge Elimination System
Stormwater Individual Permit NCSO 0 0 5 3 9
Please provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information
* Address to which permit correspondence will be mailed
Owner / Organization Name:
Tyton NC Biofuels, LLC
Owner Contact:
Richard Brehm, General Manager
Mailing Address:
800 Pate Road
Raeford NC 28376
Phone Number:
910-878-7820
Fax Number:
E-mail address:
[e-mail]
Facility Information
Facility Name:
Tyton NC Biofuels, LLC
Facility Physical Address:
800 Pate Road
Raeford NC 28376
Facility Contact:
Royce Todd, Plant Manager
Mailing Address:
800 Pate Road
Raeford NC 28376
Phone Number:
910-878-7820
Fax Number:
_
E-mail address:
[e-mail]
Permit Information
Permit Contact:
Denise DePolis, EHS Manager
Mailing Address:
800 Pate Road
Raeford NC 28376
Phone Number:
910-878-7820
Fax Number:
E-mail address:
[e-mail]
Discharge Information
Receiving Stream: UT to Little Marsh Swam
Stream Class: C-Sw
Basin: Lumber
Sub -Basin: 03-07-53
Number of Outfalls: 1
0MR-LAND QUALITY
a MWA4 ER PERMITTING
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
The manufacturing facility was restarted in August 2015 under the ownership of Tyton NC Biofuels, LLC. There were no substantive
changes to the facility that would impact Stormwater quality since the original permit was issued.
CERTIFICATION
I certify that I am fami
such information is tru+
Signature
Wth the information contained in the application and that to the best of my knowledge and belief
mpIRQ anclAccurate.
Print or type name of person signing above
Date e AQ ­_
General Manager
Title
SW Individual Permit Coverage Renewal
Please return this completed application form Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

Draft ot text 1-oi-vansmiital letter should go on Tyton letterhead
kl13radi,,w Bennett. Supervisor
Storn1l"x-a-ler Permitting Program
Mait Service. 'enter
SuL)ie(�-k Application tor Renawai of Permit NCS000539
De-, 1, INIt- "nennert,
Attached are the foliowing dc-icunients,
lei Re-neycjl Appiication Forrn for NPDES Permit Number NCS000539
n. he , uppieniental Iniorniation Required checklist
3, -7 vvo copies of Si,,- Mao taken from the Storrnwater Pollution Prevention
Man (SPPTI) Thts :s been -1 an the Checklist.
`NO 01' �! SUMrTlary of the Best Management Practices utilized at the
facility, taken t`on i the SPPP This is Iterri, 4 on the checklist.
T-vvo copses of the Storrnwater Pollution Prevention Plan Development and
G-,ertifticafion forn-,, This, is item 0- on the checklist,
ee har pies o,ai-ntnary oAnalytical Monitoring or Visual Monitoring
being prol;ide-cl oecause no analytical or visual monitoring has been done.
I he 'o e I n 1! lk V" a -,i e, i s s u e a vn Nm oC Biofuels in December cif 2014 to reflect a change
� I
in ')k�vtlersillro However, "'he faciiitv has not yei been placed into operation by Tyton.
CIUIJ'Elrlt sci)edule if for ��roduction to begin in August of 2015. Analytical and visual
n
initi
ated
'o
orijt.)-jr g e-,vfll be in_,te as required by the permit when that occurs. These are Items
-hecklist,
2 and 3 on 'he c
Aisc please note is no Cotoies of a short narrative describing changes is being provided
oecause thfe tacility has not yet beep{ placed in operation and no changes that could
impact th,--i starrnwater discharge have occurred since the permit was issued in
0114-
Dec niber
mica advise 'if vou have axl[V questions or need additional information,
ncereiv
Tyton NO Bi0fuels-z- LL(D
G&nerai Niariager

INFORMATIONSUPPLEMENTAL REQUIRED INDIVIDUAL
NPDES STORMWATER
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
Attached 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
NA_ 2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
NA 3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
Attached 4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
NA 5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
Attached 6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)
Note: The plant is now restarting under current ownership and analytical and visual monitoring
will begin in August 2015. The BMP's in place are taken from the facility SPPP plan.

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The purpose of the Storm Water Management Plan is to identify site -specific sources of
storm water pollution based on the field assessment and to develop best management
practices to decrease and/or eliminate potential pollutant sources. The preferred
hierarchy of Best Management Practices (BMPs) is:
1 ) Source Reduction: includes preventive maintenance, spill prevention, chernical
substitution, housekeeping, and training.
2) Containment/Diversion: includes segregating activities of concern, cove, ringthe
activity, berming the activity, and diverting flow to a grassed area,
3) Recycling
4) Storm Water Treatment
These practices are applied in each area where there is a potential for storrnwater to
become contaminated by the industrial activity as described below-
7.1.1 Area 300
This is the cook area. This area is completely enclosed and not subject toweather
conditions. The BMPs applied are Source Reduction (preventive maintenance and
housekeeping), Containment, and Recycling. The area is permanently diked to capture
any spills or drips and a SUMP Pump discharges any leaks or spills back into the
process. Routine (weekly) inspection of the diked area insures that the systerns are
functioning properly. An inspection log is maintained for the area, and the mechanical
equipment is on a routine maintenance schedule maintained by the plant maintenance
supervisor.
7.1.2 Area 400
This area includes seven large fermenters that are designed to Lie operated outdoors
and subject to rainfall. In normal operation, there is no exposure Of Pollutants to rainfall,
but there is potential for any leaks, spills, or drips from the rnechanical eqUipn lent 10
become contaminated by runoff. The PIMP applied in this area is Source Reduction,
consisting of preventive maintenance, housekeeping, and weekly inspection, Anyspills,
leaks, or drips noted during inspection will be addressed promptly. An inspection loci is
maintained for the area. and the mechanical equipment is on a routine- maintenance
schedule maintained by the plant maintenance Supervisor
7.1.3 Area 600
This area contains the distillation equipment for the operation The BMPs applied in this
area include Source Reduction consisting of ii ispectioi i, preventive maintenance. a, nd
good housekeeping: Containment: and kelcyclin-c, This area is contained and has sump
pumps for evacuating the water from the containment area, Vvater from this area r-.an lie
e
sent back into the process eliminating the possibility for release. We also have theoptiorl
to discharge the water from the containment area to the, plant stormwater dra-Inage,
system by manually pumping the captured stormwater to the ad) a cent storniwater

drainage ditch. Prior to any such discharge the stormwater is visually nispectedand
tested in the plant laboratory for COD and TISS to verify that it is notcon"Laminated
fiffz�-TWMWM
This area has tanks, pumps, and piping which are designed to be operated outdoors
exposed to the weather, The BMPs used to reduce the potential for the discharge of
pollutants in stormwater are good maintenance practices and routine weekly inspection,
of the area. The plant maintenance program has a schedule for preventive maintenance
of the equipment that meets manufacturers recommendations,
7.1.5 Area 800
This area contains the ethanol tanks and the storage tank for natural gasolinethe
denaturant. These tanks are inside a large containment area designed to provide the
proper containment volume for the tanks and a 1 00-year storm, These tanks are outside
and exposed to the weather, the product cannot corne into contact with thestormwater.
The drain valve to this area is always closed and locked. As the conta! n me tit becomes
filled with rainwater the water is sampled and analyzed, and is released if it if found to be
uncontaminated. After the water is released, the valve is again closed and locked. This
activity is documented on the inspection log form, This area is visually inspected
weekly. Adjacent to the storage area is a truck loading/Unloading area wheredenaturant
is unloaded to the storage tanks and product is loaded to trucks for shipment. Thisarea
can handle, two trucks at once. The floor is of the area is conorpte. and slopes to astimp
This sump is sealed and would be pumped out by a portable pump in the event of a -spill,
The BMPs used for this area are good housekeeping and operational controls toprovent
spills or discharges. The standard operating procedure for truck loading or unloading is
attached for reference. The area is inspected weekly.
7.1.6 Area 900
Area 900 is the DDGS drying and storage area. The BMPs Used in this area are
containment, recycling, and good housekeeping. In normal operation, there is no
potential for exposure of any product or raw material to stormwater, in the event of S-
process upset, the partially finished product, DDGS, is stored oil a pad that is exposed
to rainfall. The material is contained by the construction of the pad and all oroduetplus,
any rainfall that may accumulate on the pad is returned to the process with no discharge
to the stormwater system.
7.1.7 Area 1000
This is the chemical storage area for the process. The chemicals are stored inside, Out
of the weather with the exception of some tank storage The HMP's chosen for this area
are Source Reduction through containment around the tanks and Good HOUseke eplog.
This area is inspected weekly.
7.2.1 Sediment and Erosion Control
I he topography of the facility and surrounding land Includes Rtle relief, f esUltmp III
relatively sluggish water movement in most areas. No significant erosion or
sedimentation problem areas have been identified at the facility. The enbro. proces-sing
area drains to the existing stormwater detention porid. The existing storrilwate r
detention pond is adequately sized to contain a 10 year and 25 year storm and release
the water at the required rates.

ST R WATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy Mineral, and Land Resources — Stormwater Permitting
Facility Name Eton NC Biofuels, LLC�
Permit Number NCSOoo539
Location Address 800 Pate Road
Raeford, NC 28376
county Hoke,.__�..._,__�._._v_.—____.
I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the Information required by the SPPP. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the information gathered is, to the
best of my knowledge and belief, true, accurate and complete..
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully
implemented at this: facility location in accordance with the terms and conditions of the startrlwater disullarye petit.°
And
I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for
knowing violations "
Sign (:according to permit signatory requirements) and return this Certification. DO NOT
SEND STORRINNIkTLR POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature
III
Date 8 /0
General Manager
Print Afi type name of person signing above Title
SPPP Certification 10/13

SUPPLEMENTAL 11-NFOICNIA,rION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STD RNIINN ATER PERN41T
[,wo Come', ofcach of the i-Ottowia(l shall accouipati\ this submittal in order for the application
Z71
to he �oasidcred coniplete:
Do not submit tile site Storni\vater Pollution Prevention Plan.)
tilitial"
VtaohQd I current Site fl
ap 1'roni the Storillwater Pollution Prevention Plan. The location of
indli-sirl'it acli\ Ines (ilicillding storage of materials, disposal areas, process areas and
Z71
loadiii- and utl[oadin- areash drainage structures, drainage areas for each outfall,
building, locations i,lidimpervious surfaces should be clearty noted.
1 A summary ofAtialytical Monitoring results durinc, the term of the existing permit
(il'N'011r permit required analytical sampling). Do not submit individual lab reports.
'I-hQ SUITHIIIII'V can consist of a table including,) such items as 01.11ftill number.
parmlieters Sampled. lab result,,, date sampled, and storm event data.
Asilriunar\ ofthe Visual Monitoring results. Do not Submit individual monitoring
reports. sul
tana inary can consist of a table including such items as outfall number.
parameters sur\ eyed, observations. and date monitoring conducted.
Attachod4, A -iIiiiiniar\ of thy: Bost Management Practices utilized at the permitted facility.
sulniliar\ should consist ofashort narrative description of each BMP's in place at
the . It"the implementation of any BMP's is planned, please include
in f0ralation oil these BMP's.
A short narrative describing any° significant changes in industrial activities at the
permitted facilit,,, Significant changes could include the addition or deletion of
work processes, changes in material handling practices. changes in material storage
pf"Ictices, and"'or challges in the raw materials used by the facility.
Atiachcd6. Certl t icatio a of the d e-velopment and implementation of a Storniwater Pollution
lljvvenLiori Plart for the permitted facility (Sign and return attached form).
ti'ttAQ final voanr analytical monitoring ofthe existing _,., permit term has not been completed
prior to titilw' tile retlowal submittal, then the last nears rnonitorim,, results should be submitted
withlil 30 dziN s of're, oipt ot'th-e taboratory reports. (i.e. do not withhold, renewal submittal
wanill"', oil tat) results)
Note: The plant i,; ilow restarting under current wvvnersship and analytical and visual monitoring
VVill be to in 20 1 i. Thy 13NMP's in place are taken from the f-acility SPPP plan.

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7A Development of Best Management Practices
The purpose of the Storm Water Management Plan is to identify site -specific sources of
,itorni water pollution based on the field assessment and to develop best management
praQtlo,(­,; to dc-Grease andlor eliminate potential pollutant sources. Tho preforred
nierarchy of Best Management Practices (BMPs) is
Sour
ce Reduction: includes preventive maintenance, spill prevention, chemical
$uostitution, housekeeping, and training
o nta I n mei it/ Diversion: includes segregating activities of concern, coveringthe
activity, berming The activity, and diverting flow to a grassed area.
I �3) Reevolilip
4) �torni VVater'lk reatment
These practices are applied in each area where there is a potential for stormwater to
become contaminated by the industrial activity as described below.
i'l Area 300
his es ,,he cook area This area is completely enclosed and not subject to weather
conditions. The BMPs applied are Source,, Reduction (preventive maintenance and
housekeeping), Containment, and Recycling. The area is permanently diked to capture
any spills or drips and a sump pump discharges any leaks or spills back into the
process, Routine (weekly) inspection of the diked area insures that the systems are
functioning properly, An inspection log is maintained for the area, and the mechanical
equipment is on a routine maintenance schedule maintained by the Plant maintenance
supervisor
A. Area 400
'D')!S area
Includes seven large fermenters that are designed to be operated outdoors
-
and subject to rainfall. In normal operation, there is no exposure of pollutants to rainfall,
but there is potential for any leaks, spills, or drips from the mechanical equipment to
oeconie contaminated by runoff, The BIVIP applied in this area is Source Reduction,
consisting of preventive maintenance. housekeeping, and weekly inspection. Any spills,
!eaks, or drips rioted during inspection will be addressed promptly. An inspection log is
maintained for the area. and the mechanical equipment is on a routine maintenance
schedule rnaintained by the plant rnainteriancesupervisor.
7,,L3 Area 500
This area contains the distillation equipment for the operation. The BMPS applied in this
area include Source Reduction consisting of inspection, preventive maintenance, and
good housekeeping,, Containment: and Recycling. This area is contained and has sump
PUMPS for evacuating the water from the containment area. Water from this area can be
sent back Into the process eliminating the possibility for release. We also have theoption
to discharge line water from the containment area to the plant stormwater drainage
­vstem Ov manually pumping the captured stormwater to the adjacent stormwater
s

drainage ditch, Prior to any such discharge the stormwater is visually inspected and
jested in the plant laboratory for COD and TSS to verify that it is notcontaminated.
11,4 Area 700
This, area has [at iks-, purtips, and piping which are designed to be operated outdoors,
exposed to the weather. The BMPs used to reduce the potential for the discharge of
pollutants in stormwater are good maintenance practices and routine weekly inspection
of the area, Fhe plant maintenance program has a schedule for preventive maintenance
of the equipment that meets manufacturers recommendations.
7-1,5 Area 800
This area contains the ethanol tanks and the storage tank for natural gasoline, the
denaturant, These tares are inside a large containment area designed to provide the
proper containment volume for the tanks and a I 00-year storm. These tanks are outside
and exposed to the weather, the product cannot come into contact with thestormwater.
The drain valve to this area is always closed and locked. As the containment becomes
filled with rainwater the water is sampled and analyzed, and is released if it if found to be
uncontaminated, After the water is released, the valve is again closed and locked. This
activity is documented on the inspection log form. This area is visually inspected
weekly, Ad ' iacent to the storage area is a truck loading/unloading area wheredenaturant
is unloaded to the storage tanks and product is loaded to trucks for shipment. This area
can
n handle two trucks at once. The floor is of the area is concrete and slopes to a sump
This surrip is sealed and would be pumped out by a portable pump in the event of a spill.
The WvWs used for this area are good housekeeping and operational controls to prevent
spills or discharges. The standard operating procedure for truck loading or unloading is
attached for reference. The area is inspected weekly,
7.�I.6 AreaW
Area 900 is the DDGS drying and storage area, The BMPs used in this area are
oontainnient. recycling , , and good housekeeping. In normal operation, there is no
potential for exposure of any product or raw material to stormwater. In the event of a
process up -set, the partially finished product, DDGS , is stored on a pad that is exposed
to rainfall. The material is contained by the construction of the pad and all productplus
any rainfall that may accumulate on the pad is returned to the process with no discharge
to the storrnwater system,
'7 ; 1,7 Area 1000
This is the chemical storage area for the process. The chemicals are stored inside, out
or the weather with the exception of some tank storage. The BMP's chosen for this area
are Source Reduction through containment around the tanks and Good Housekeeping.
This area is inspected weekly,
72 SITE -SPECIFIC CONTROLS
7.2. 1 Sediment and Erosion ontrol
T I he topography of the facility and surrounding land includes little relief, resulting in
relatively sluggish water nnovement in most areas. No significant erosion or
sedimentation problem areas have been identified at the facility. The entire processing
area C4rains to the existing stormwater detention pond. The existing stormwater
detention pond is adequately sized to contain a 10 year and 25 year storm and release
the water at the required rates.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and L and Resources — Stormwater Permitting
Facility Name.
Permit Number.
Location Address
County
Tyton NC Biofuels, LLC
NCS000539
800 Paite Road
Raeford, NC 28376
l4oke
I certify, tinder penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the information gathered is, to the
best of my knowledge and belief, true, accurate and complete."
And
I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully
irriplomentod at thic facility location in accordance with the terms and conditions of the stormwater discharge permit."
And
I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for
knowing violations "
,Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORNMAJER. POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature
Richard
Print or t*e name of person -signing above
Date A
General Manager
Title
SPPP Certification loll 3