NCS000594_HISTORICAL WITH APPLICATION_20181203

STURMVVATER DIVISION CODING SHEET
PERMIT NO.
Ncl;
1
DOC TYPE
❑FINAL PERMIT
❑ MONITORING INFO
� APPLICATION
0 COMPLIANCE
❑ OTHER
DOC DATE
❑ 201 q
YYYYMMDD

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Bennett, Bradley
From: Bennett, Bradley
Sent: Monday, December 03, 2018 5:08 PM
To: Willis, Ben
Cc: Koschnick, Tyler, Lucas, Annette
Subject: Re: [External] RE: Draft NPDES Stormwater Permit
Attachments: NCS000594 Aerial View of Proposed Monitoring.pdf
Ben,
still have access to email for a while so I'll try and answer these questions. See responses below in Red. If
Annette has any other comments I will let her respond directly to you.
I would like to confirm the outfall locations. From my understanding there are five outfalls, two are
where manufacturing occurs and three near the research ponds. - As noted in the cover letter and
permit attached in the previous email there are five monitoring locations in the areas you noted. I
have also attached a map with the approximate locations we discussed at the site visit.
Does SePRO get a chance to comment on the draft permit? - Yes, as noted in the cover letter, we have
forwarded the draft to allow you the chance to comment on the permit. Please try and get us
comments back within the next 30 days. The public notice will appear in the Rocky Mount paper
tomorrow and run through January 4th.
3. If vehicle maintenance area has less than 55 gallons of oil per month averaged over a year then we do
not need to measure non -polar oil. and grease? - You are correct, if VM over the threshold of 55
gal/month does not occur then you do not have to monitor for this parameter.
4. Do I need to have an outside laboratory measure pH or am I allowed to measure pH myself since I am
familiar with the method? - If you are familiar with the use of a pH meter then you can measure the
pH.
5. Is electronic reporting accepting monitoring data? We are still working to update the electronic
database so that it will accept electronic data for stormwater permits. Once this is available we will let
the permittees know. For the current time you will still have to submit paper copies of the monitoring
reports.
6. For mailed copy of monitoring results, may I sign then scan and email the document to our cooperate
office for the officer signature, or does the mailed copy need original signatures? - We do require a
signed original for the paper submitals. One option allowed for in the permit is for the officer from
your corporate office to designate a "duly authorized representative" which could be someone local to
sign. See Part III Section B. 3. b. for information on the duly authorized representative.
Hope this answers your questions.
Bradley Bennett Note New Office Phone
Stormwater Program Phone: [phone]
NC Division of Energy, Mineral & Land Resources Fax: [phone]
1612 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1612

Email correspondence to and from this address may be subject to public records laws
From: Willis, Ben <[e-mail]>
Sent: Monday, December 3, 2018 2:51 PM
To: Bennett, Bradley; Lucas, Annette
Cc: Koschnick, Tyler
Subject: [External] RE: Draft NPDES Stormwater Permit
Thank you Bradley.
Annette, I have a few questions.
1. 1 would like to confirm the outfall locations. From my understanding there are five outfalls, two are
where manufacturing occurs and three near the research ponds
2. Does SePRO get a chance to comment on the draft permit?
3. if vehicle maintenance area has less than 55 gallons of oil per month averaged over a year then we do
not need to measure non -polar oil and grease?
4. Do I need to have an outside laboratory measure pH or am I allowed to measure pH myself since I am
familiar with the method?
S. Is electronic reporting accepting monitoring data?
6. For mailed copy of monitoring results, may I sign then scan and email the document to our cooperate
office for the officer signature, or does the mailed copy need original signatures?
Feel free to call me if answering these questions is more convenient by phone [phone]).
Thank you,
Ben
From: Bennett, Bradley <[e-mail]>
Sent: Monday, December 03, 2018 8:38 AM
To: Willis, Ben <[e-mail]>
Cc: Lucas, Annette <[e-mail]>
Subject: Draft NPDES Stormwater Permit
Hi Ben,
We have completed our review and now have the draft Stormwater NPDES permit ready for your review. The
draft permit is attached. This was mailed out to the contact in your application, but I wanted to forward the
draft to you as well. My temporary assignment with the Stormwater Program has come to an end so you
should forward any comments or questions you might have to Annette Lucas. Annette is the supervisor of the
stormwater program and can address your questions or get you in touch with another permit writer in
stormwater. I have copied her on this email.

"" W
The draft permit should be publicly noticed in a local paper sometime this week for a 30 day public comment
period. After that time frame we will consider any comments and work to finalize the permit.
Thanks for all your help in the process.
Bradley Bennett
Stormwater Program Note New Phone Number
NC Division of Energy, Mineral & Land Resources Phone: [phone]
512 N. Salisbury Street Fax: [phone]
1612 Mail Service Center Email: brad ley. ben nett(@ncdenr.gov
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws

w�
• Last updated 11/29/18
NC Division of Energy, Mineral and Land Resources
Review of Permit Application-- NCS000594
SePRO Research & Technology Campus - Whitakers
SIC 2879 — Pesticides and Agricultural Chemicals. Facility is a 410 acre site whose main focus is herbicide and
algaecide manufacturing along with scientific studies and lab assays. Facility has land area used for laboratory
activities, manufacturing and packaging of chemicals, research pond system for testing chemicals and row crop
production.
Backgound — SePro Corporation researches, develops, manufactures and packages a variety of aquatic, agricultural,
turf and ornamental herbicides and other chemicals. This facility has a lab area on the eastern portion of the site
where they do the development and testing of specialty chemical products. Near the lab there are also areas where
plants are grown in greenhouses and open containers for testing. This area also has open containers where
developed chemicals are tested on plants and water areas. The eastern part of the site also includes a large pond
system in a grid network where plants are grown and developed products are tested. The pond system is
interconnected with pipes and they can adjust water level within the pond system, etc. Facility says the ponds are
lined and don't discharge? The facility was utilizing the lower ponds in the grid to dump water produced in the
laboratory process from time to time. Water was allowed to set in the ponds for treatment. In 2015/2016 there
were issues at the location due to this unpermitted treatment system and DWR issued NOVs and took enforcement
actions. This led to a settlement agreement that required the facility to obtain coverage under the stormwater
permit. The facility now collects the lab wastewater and periodically pumps and hauls to Rock Mount.
The western portion of the site has a manufacturing/blending and packaging building were the chemicals are
produced and packaged for shipment. The area includes outside tanks with secondary containment for storage of
chemicals. The western area also has a maintenance shop/ warehouse area where bulk chemicals are stored along
with some biproducts and wash water. Some storage is under roof but with open wails for totes that contain wash
water. This building also handles regular maintenance of farm equipment and has outside storage of equipment,
laydown area, used oil in containment area, etc.
(DWR inspection reports that are included in the LF files include a detailed description of the facility activities)
Monitoring —The facility provided data for one sampling event as part of their Form 2F submittal for general
parameters in the form (O&G, BOD, COD, TSS TN, TP, pH). Also provided data for Total Cu. None of the monitoring
results were at levels about the benchmark values. Monitoring conducted by DWR during the 205/2016
investigation showed potential issues with metals values and their investigation has also lead to other potential
pollutants of concern. Working with DWR DEMLR has established monitoring requirements in the permit that will
allow us to collect data that will help characterize the potential impacts from this facility and the chemicals and
processes that they have ongoing at the facility. Parameters that are included in monitoring requirements —
ammonia nitrogen, TKN, nitrate/nitrite nitrogen, Cl, TSS, Al, Ar, Cd, Ca, Cu, Pb, Mn, Mg, Ni, TP, K, Na, Zn, hardness
and pH.
At a site visit on October 23, 2018 staff pointed out monitoring locations for the facility rep onsite (Ben Willis).
There are four outfalls and one in -ditch location that staff requested monitoring for. The first two outfalls (001 and
002) are on the west side of the property near the shop area. Outfall 003 is along the access road leading to the
laboratory area where the lab area drains back into a conveyance. Outfall 004 is the discharge point from the riser
below the pond system. The in -ditch location is below the last outfall from the pond system and will help assess the
overall impacts from the facility for DEMLR and DWR. There may be some groundwater issues that these results
could help to assess. The monitoring locations are roughly shown in the aerial views in this document along with
notes on location of activities and potential pollutant sources from the site visit.
Two parameters did not have benchmarks established. Worked with Chris Ventaloro in DWR on benchmarks for
Potassium and Calcium. For Potasium he looked at the FAV from EPA information and''/: FAV is 17.14 mg/L. For
Calcium he reviewed information in ECOTOX and found a number of old studies but could not find the references.
Found a good reference from 1997 study. Using ceriodaphnia they developed an LCSO of 1,830. For benchmark we
would use h LC50 of 915 mg/L.
• Facility drains to UT to Fishing Creek [28-79-(29)] in the Tar -Pamlico River Basin, a class C; NSW stream. 2016
Assessment Report shows no impairment of concern for this facility in this area.

Last updated 11129118
NC National Heritage review — NHP report shows no aquatic resources in the project area. In the one mile radius
around the facility there are a few species noted, but there is insufficient information to establish the viability and
accuracy of data is not high. No Federally listed species.
RRO — Site visit was conducted on October 23, 2018. Bradley Bennett, Thad Valentine and Danny Smith participated
in the visit and onsite rep was Ben Willis. After a brief overview discussion staff reviewed the outdoor areas of the
site but did not tour any of the indoor activities. Site was found to be generally clean and well maintained. There
were some secondary containment structures that did not have locked valves. One containment area had oil stored
in open buckets and staff noted the need for different handling of used oil. There were empty totes stored onsite
and a dumpster behind the maintenance/warehouse building that looked to have more than just office type trash.
The laboratory area had very little outside material, but there were open containers adjacent to the lab that contain
the chemicals being tested or materials that have been used and are now being held for sunlight treatment prior to
being used for irrigation in the greenhouse. These materials could overflow during rain events.
During the site visit the water level of the pond system was observed to be very low. The facility had indicated there
was no discharge from the ponds and that the ponds were lined. It does not appear that there is the potential for
evapotranspiration that would account for the low water level. Onsite staff offered that there were muskrats that
bored holes that could explain some loss of volume? Need to continue to evaluate this process to determine where
the water volume is going. Could create groundwater issues. Hopefully the monitoring requested and supplemental
monitoring by DWR can assess any impact.
Areal Views with Notes and proposed outfalls from site visit:
Tanks w/TEA (Triethanolamine). Secondary
Western Portion of Site containment but valve not locked
Tote storage- indicated that all where
new totes waiting to be filled

Last updated 11/29/18
Water from tests stored in open containers treated
by sunlight until water is okay to be used for
• Outfoll 003 — drains back from Lab area and discharges into conveyance ditch
along road.
• Outfall 004 — discharge from riser
• 'Outfoll 005 — general location for in -ditch monitoring below riser outfoll
--------------------------------------------------
Ponds on this side were very low.
Unsure whether there was some
leaking or infiltration j
---------------------------------------------------a

ROY COOPER NORTH CAROLINA
Governor Envlronmentof Qua[lty
MICHAEL S. REGAN
Secrrtury
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
DATE: November 28, 2018
TO: [Rocky Mount Telegraph]
EMAIL: [E-MAIL]
FROM: Suzanne McCoy, DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
SUBJECT: PUBLIC NOTICE -
PAGES: 1
Please publish only the information (Public Notice) attached, ONE TIME in the legal section of your paper by iTugsday;
December 3, 21}18. Please fax a copy of the proof to Suzanne McCoy at [phone] for final approval prior to
publication. Within 10 days after publish date, please send the invoice and two copies of the original affidavit to:
Suzanne McCoy
NCDEQ/DEMLR
512 N. Salisbury St
1612 Mail Service Center
Raleigh, NC 27699-1612
NC DIV. OF ENERGY, MINERAL AND LAND RESOURCES' INTENT TO ISSUE A
STORMWATER DISCHARGE PERMIT
Public comment or objection to the draft permit is invited. Submit written comments to DEMLR at the address
below, All comments received through January 3, 2018 will be considered in the final determination regarding
permit issuance and permit provisions,
Application: SePro Development Company III LLC,16013 Watson Seed Rd, Whitakers, NC has applied for an
NPDES permit to discharge stormwater from an industrial facility at this address in Nash County. The facility
discharges to a UT to Fishing Creek in the Tar -Pamlico River Basin. Permit NCS000594,
Stormwater Program Contact: Annette Lucas
[phone]
[e-mail]
A copy of the draft permit is available at: https://bit.ly/2jSf5ls. Additional permit documents are available for the
reproduction cost at:
DEMLR Stormwater Program
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Lund Resources
512 North Salisbury Street 11612 Mail Service Center I Ralrigh, North Carolina 27699-1612
919.707,926o

ROY COOPER
Governor
NORTH CAROLINA
Environmental Quality
MICHAEL S. REGAN
Secretary
WILLIAM F. (TOBY) VINSONJR,
interim. Director
November 28, 2018
Mr. Tyler Koschnick
SePRO Development Company III, LLC
11550 N. Meridian Street; Suite 600
Carmel, In 46032
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000594
SePRO Research and Technology Campus
Nash County
Dear Mr. Koschnick:
Enclosed with this letter is a copy of the draft Stormwater permit for your facility. Please review the draft
carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit includes the following significant items:
You are required to collect analytical and qualitative monitoring samples during "measurable storm
events" as defined in Part II, Section B. Stormwater benchmark values are included in the permit for
most parameters. Stormwater benchmarks are not permit limits, but rather guidelines for
implementing the Stormwater Pollution Prevention Plan (SPPP). A benchmark exceedance is not a
permit violation; however, the permittee must respond to exceedances as directed in the Tiers set
out in the permit. Please become familiar with the tiered process as proper response under the tiers
may be enforceable items under your permit. Response to the tiered process may include review of
onsite conditions, installation of BMPs or requirements for more frequent monitoring.
During our site visit on October 23rd we discussed monitoring locations for your facility. There were
four outfall locations noted and a fifth location in the conveyance ditch below the last outfall. The
first two outfalls (001 and 002) are on the west side of the property near the shop area. Outfall 003
is along the access road leading to the laboratory area where the lab area drains back into a
conveyance. Outfall 004 is the discharge point from the riser below the pond system. The final
location (005) should be selected in the ditch below outfall 004. Please provide our office with the
latitude and longitude for each of these locations. If you have questions about these locations, please
contact Thad Valentine in our Raleigh Regional Office at [phone].
2. You are required to develop and implement a Stormwater Pollution Plan (SPPP). Requirements for
the SPPP have been updated in Part II, Section A.
3. Vehicle maintenance monitoring parameters are included. Non -Polar Oil & Grease [EPA Method
1664 (SGT-HEM)] replaces Oil & Grease/TPH. The benchmark for Non -polar Oil & Grease using this
e:.o5fDFQ
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512.Nonh Salisbury Street 11612 Mail Service Center I Raleigh, North Carolina 27699-1612
919.7079200

Draft Permit NCS000594
Page 2
method is 15 mg/L. This requirement appears in all individual stormwater permits; however, it only
applies to facilities that perform onsite vehicle maintenance activities. If the facility begins vehicle
maintenance during the permit cycle, the requirements shall apply. Also, pH monitoring is no longer
required for discharges only associated with vehicle maintenance activities.
The vehicle maintenance language in the permit clarifies that these activities include not just
vehicles, but also other similar equipment maintenance activities that may be exposed to
stormwater. This has always been the Division's implementation of this requirement, but hopefully
the adjusted language is a little clearer about this process.
4. Language is included under Part lI Section D to address potential responses to qualitative
monitoring issues.
5. A new section on Special Conditions has been added in Part II, Section E to comply with federal
regulations requiring electronic submittal of discharge monitoring reports. Our electronic
submittal process is not available for use at this time, but we will continue to provide feedback on
when this process will be available.
Please review the draft permit and submit any comments to our office no later than 30 days following
your receipt of the draft. Comments maybe emailed to Annette Lucas at annette.lucas@ncdenn gov or
mailed to her attention at NC DEMLR, Stormwater Permitting Program,1612 Mail Service Center, Raleigh,
NC 27699-1612. With this notification the Division will solicit comment on this draft by publishing a
notice in a local newspaper. Fallowing the 30 day public comment period, the Division will review
comments and take appropriate action prior to issuance of the final permit.
If you have any questions, please contact Annette Lucas at [phone].
Sincerely,
Original Signed by Bradley Bennett
Bradley Bennett
Stormwater Permitting Program
Attachment: Draft Permit NCS000594
cc: Bill Denton, DEMLR Raleigh Regional Office -via email
Danny Smith, DWR Raleigh Regional Office - via email
Ben Willis, SePRO Research & Technology Campus
Stormwater Permitting Program Files

NCS000594 D FT XMIT
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINA'�ON SYSTEM
bl >' i
In compliance with the provisions of North Carolina General Statute 143-215.1, other
y
lawful standards and regulations promulgated and;adopted by°the North Carolina
", N"
Environmental Management Commission, and the%Federal Water Pollution Control Act, as
amended, \'!>,
SePRO Development Company III, LLC
is hereby authorized to discharge sto''rmwater from a facility engaged in the research,
development, manufacturing and packaging of herbicides, algaecides and agricultural
chemicals located at:
&PR0 Research & Technology Campus
'_p`_°1'6013 Watson Seed Farm Road
Witakers, NC
Nash County
to receiving waters designated as UT to Fishing Creek, a class QNSW stream in the Tar -
Pamlico River Basin, in accordance with the discharge limitations, monitoring
requirements, and other conditions set forth in Parts I, 11, I11, and IV hereof.
Note: Draft Permit Dates are Approximate
This permit shall become effective [February 1, 2019].
This permit and the authorization to discharge shall expire at midnight on [January 31, 2024].
Signed this day [February 1, 2019].
for E., CPESC, CPM, Interim Director
Division of Energy, Mi ra nd Land Resources
By the Authority of a Envir mental Management Commission

Permit No. NCS000594 DRAFT
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART [I MONITORING, CONTROLS, AND LIMITATIO.NS.FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention 1 lam ,
Section B: Analytical Monitoring Requirements,, -
Section C; Qualitative Monitoring Requir"emehts
Section D: Special Conditions"-.
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
Section A: Compliance and Liability
1. Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
S. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports {
11. Onshore or Offshore Construction
12. Duty to Reapply
9

Permit No. NCS000594 DRAFT
Section B: General Conditions
1. Permit Expiration
2. Transfers
3. Signatory Requirements
4. Permit Modification, Revocation and Reissuance, or Termination
S. Permit Actions
6. Annual Administering and Compliance Monitoring Fee
Requirements
Section C: Operation and Maintenance of Pollution Controls
�iir �§ii@g¢P'y
1. Proper Operation and Maintenanc`6e
2. Need to Halt or Reduce Not adI fense
3. Bypassing of Stormwater Cont4Facilities
Section D: Monitoring and Records
1.
Representative Sa'iipling
2.
Recording Resulfs
3.
Flow Measurements
4.
Test Procedures
S.
Representative Outfall
6.
Reco> ds.Retention
7.
Inspection and Entry
Section E: Reporting Requirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
5.
Planned Changes
6.
Anticipated Noncompliance
7.
Spills
8.
Bypass
9.
Twenty-four Hour Reporting
10.
Other Noncompliance
11.
Other Information
PART IV DEFINITIONS
ii

Permit No. NCSOOOS94 DRAFT
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration,
the permittee is authorized to discharge stormwater associated with industrial activity.
Such discharges shall be controlled, limited and monitored as specified in this permit.
If industrial materials and activities are not exposed to precipitation or runoff as described
in 40 CFR §122.26(g), the facility may qualify for a No;Exposure Exclusion from NPDES
stormwater discharge permit requirements. ;Any owner or operator wishing to obtain a No
Exposure Exclusion must submit a No Exposure Certificatiofi Notice of Intent (NO I) form to
the Division; must receive approval by the(Divzsion; Amust" aintain no exposure conditions
unless authorized to discharge under a valid,NPDES stormwater permit; and must recertify
the No Exposure Exclusion annually.
SECTION B: PERMITTED ACTIVI-TIES"
A
Until this permit expiresaoris modified or revoked, the permittee is authorized to discharge
stormwater to the surface water`s,of North Carolina or separate storm sewer system that
has been adequately trea d``an&managed in accordance with the terms and conditions of
this permit. All stormwater discharges shall be in accordance with the conditions of this
permit. +..£
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization, or
approval. The stormwater discharges allowed by this permit shall not cause or contribute
to violations of Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
Page - 1

SECTION C: LOCATION MAP
Permit No. NCS000594 DRAFT
Page - 2

Permit No. NCS000594 DRAFT
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop and implement a Stormwater Pollution Prevention Plan
(SPPP). The SPPP shall be maintained on site unless exempted from this requirement by
the Division. The SPPP is public information in accordance with Part 111, Standard
Conditions, Section E, paragraph 3 of this permit. The SPPP shall include, at a minimum,
the following items:
1. Site Overview. The Site Overview shall� provide a,descr-iption of the physical facility
and the potential pollutant sources that'.may be expected to contribute to
contamination of stormwater dischargesia`The. Site Overview shall contain the following:
(a) 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; the name of the receiving waters to which the stormwater outfalls
discharge, or if thb 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 th`e:pvints{of stormwater discharge associated with industrial
activity. The general location map (or alternatively the site map) shall identify
whether any/'receiving`waters are impaired (on the state's 303(d) list of impaired
waters) or if the siteli located in a watershed for which a TMDL has been
established; and -what the parameters of concern are.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices. A narrative description of the potential pollutants that
could be expected to be present in the stormwater discharge from each outfall.
(c) A site map drawn at a scale sufficient to clearly depict: the site property boundary;
the stormwater discharge outfalls; all on -site and adjacent surface waters and
wetlands; industrial activity areas (including storage of materials, disposal areas,
process areas, loading and unloading areas, and haul roads); site topography and
finished grade; all drainage features and structures; drainage area boundaries and
total contributing area for each outfall; direction of flow in each drainage area;
industrial activities occurring in each drainage area; buildings; stormwater Best
Management Practices (BMPs); and impervious surfaces. The site map must
indicate the percentage of each drainage area that is impervious, and the site map
must include a graphic scale indication and north arrow.
(d) A list of significant spills or leaks of pollutants during the previous three (3) years
and any corrective actions taken to mitigate spill impacts.
Page - 3

Permit No. NC5000594 DRAFT
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The permittee shall re -certify annually 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 III, Standard Conditions, Section B, Paragraph 3.
2. Stormwater Management Strategy. The Stormwater Management Strategy shall
contain a narrative description of the materials management practices employed which
control or minimize the stormwater exposure of significant materials, including
structural and nonstructural measures. The Stormwater Management Strategy, at a
minimum, shall incorporate the following: 141
(a) Feasibility Study. A review of the teclinical;and economic feasibility of changing
the methods of operations and/or stowage practices to eliminate or reduce exposure
of materials and processes to rainfall Ad run-on flows. Wherever practical, the
permittee shall prevent exposure of alF'storage areas, material handling operations,
and manufacturing or fueling operations.`. In areas where elimination of exposure is
not practical, this review shall �document the feasibility of diverting the stormwater
..NI rf Ir--
run-on away from areas Opotentialcontamination.
(b) Secondary Cont inme fifRequirements and Records. Secondary containment is
required for: buld'Zftguid materials. storage in any amount of Section 313
of Title III of the''Superfund Amendments and Reauthorization Act (SARA) water
priority chemicals; and storage in an amount of hazardous substances in order to
..�
prevent teaks and spills from contaminating stormwater runoff. A table or summary
of all such tan and stored materials and their associated secondary containment
areas shall be maintained. if the secondary containment devices are connected to
stormwater conveyance systems, the connection shall be controlled by manually
activated valves or other similar devices (which shall be secured closed with a .
locking mechanism). Any stormwater that accumulates in the containment area
shall be at a minimum visually observed for color, foam, outfall staining, visible
sheens and dry weather flow, prior to release of the accumulated stormwater.
Accumulated stormwater shall be released if found to be uncontaminated by any
material. 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 (5) years. For facilities subject to a federal oil Spill
Prevention, Control, and Countermeasure Plan (SPCC), any portion of the SPCC Plan
fully compliant with the requirements of this permit may be used to demonstrate
compliance with this permit. The Division may allow exceptions to secondary
containment requirements for mobile refuelers, as with the exemption provided by
amendments to federal SPCC regulations, as long as appropriate spill containment
and/or diversionary structures or equipment is used to prevent discharge to surface
waters. Exceptions do not apply to refuelers or other mobile tannage used primarily
as bulk liquid material storage in a fixed location in place of stationary containers.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMPs) shall be provided. The installation and implementation of BMPs
Page - 4

Permit No. NCS000594 DRAFT
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and on data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
selected site BMPs. The BMP Summary shall be reviewed and updated annually.
3. Spill Prevention and Response Procedures. The Spill Prevention and Response
Procedures (SPRP) shall incorporate an assessment of potential pollutant sources based
on a materials inventory of the facility. Facility personnel responsible for implementing
the SPRP shall be identified in a written list incorporated into the SPRP and signed and
dated by each individual acknowledging their responsibilities for the plan. A
responsible person shall be on -site at all times during facility operations that have
increased potential to contaminate stormwater, runoff through spills or exposure of
Aw
materials associated with the facility operations'.jheSPRP must be site stormwater
specific. Therefore, an oil Spill Prevention Control and Countermeasure plan (SPCC)
may be a component of the SPRP, but may not`be sufficient to completely address the
stormwater aspects of the SPRP. The common elements of the SPCC with the SPRP may
be incorporated by reference into"the!SP0 /
4. Preventative Maintenance -'and Good'Housekeeping Program. A preventative
maintenance and gbb housekeeping program shall be developed and implemented.
The program shall add ress,all stormwater control systems (if applicable), stormwater
discharge outfalls,.all on=site "and adjacent surface waters and wetlands, industrial
activity areas (including material storage areas, material handling areas, disposal areas,
process areas, loading and unloading areas, and haul roads), all drainage features and
structures, and'existin structural BMPs. The program shall establish schedules of
inspections, maintenance, and housekeeping activities of stormwater control systems,
as well as facility equipment, facility areas, and facility systems that present a potential
for stormwater exposure or stormwater pollution where not already addressed under
another element of the SPPP. Inspection of material handling areas and regular
cleaning schedules of these areas shall be incorporated into the program. Timely
compliance with the established schedules for inspections, maintenance, and
housekeeping shall be recorded and maintained in the SPPP.
S. Facility Inspections. Inspections of the facility and all stormwater systems shall occur
as part of the Preventative Maintenance and Good Housekeeping Program at a
minimum on a semi-annual schedule, once during the first half of the year (January to
June), and once during the second half (July to December), with at least 60 days
separating inspection dates (unless performed more frequently than semi-annually).
These facility inspections are different from, and in addition to,! the stormwater
discharge characteristic monitoring at the outfalls required in Part II B and C of this
permit. {
6. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill
response and cleanup, preventative maintenance activities, and for any of the facility's
operations that have the potential to contaminate stormwater runoff. The facility
Page - 5

Permit No. NCS000594 DRAFT
personnel responsible for implementing the training shall be identified, and their
annual training shall be documented by the signature of each employee trained.
7. Responsible Party. The SPPP shall identify a specific position or positions responsible
for the overall coordination, development, implementation, and revision of the SPPP.
Responsibilities for all components of the SPPP shall be documented and position
assignments provided.
B. SPPP Amendment and Annual Update. The permittee shall amend the SPPP
whenever there is a change in design, construction, operation, site drainage,
maintenance, or configuration of the physical features which may have a significant
effect on the potential for the discharge of pollEutants to surface waters. All aspects of
� f1) � E d9 ITIN
the SPPP shall be reviewed and updated ori!4n)annual basis. The annual update
shall include: i.: `' .Fr:ffo
an updated list of slgnif can
(3) years, or the notation tl
Overview); ,
a written re-certiFcationih
the presence
a documeni
BMPs (BM,
r�
a review. -an,
applicable)
x,
status.1,The
ks of pollutants for the previous three
have occurred (element of the Site
atethe stormwater outfalls have been evaluated for
of nati'stor'inwater discharges {element of the Site Overview);
reevaluation of the effectiveness of the on -site stormwater
mmaryelement of the Stormwater Management Strategy).
tmparison of sample analytical data to benchmark values (if
�r the past year, including a discussion about Tiered Response
.imittee shall use the Division's Annual Summary Data
Monifvring-Report (DMR) form, available from the Stormwater Permitting
Program's website (See: https://deg.tic.gov/about/divisions/energv-mineral-land-
resources/nodes-stormwater-individuall.
The Director may notify the permittee when the SPPP 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 SPPP to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part Ill, Standard Conditions, Section B, Paragraph 3) to the Director that the changes
have been made.
9. SPPP Implementation. The permittee shall implement the Stormwater Pollution
Prevention Plan and all appropriate BMPs consistent with the provisions of this permit,
in order to control contaminants entering surface waters via stormwater.
Implementation of the SPPP shall include documentation of all monitoring,
measurements, inspections, maintenance activities, and training provided to
employees, including the log of the sampling data and of actions taken to implement
BMPs associated with the industrial activities, including vehicle maintenance activities.
Such documentation shall be kept on -site for a period of five (S) years and made
available to the Director or the Director's authorized representative immediately upon
request.
Page - 6

Permit No. NCS000594 DRAFT
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1.
All analytical monitoring shall be performed during a measurable storm event at each
stormwater discharge outfall (SDO). Only SDOs discharging stormwater associated with
industrial activity must be sampled (See Definitions).
A measurable storm event is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72 hours
prior. The 72-hour storm interval does not apply if the permittee is able to document that a shorter
interval is representative for local storm events during the sampling period, and the permittee
obtains a2j2roval from the local DEMLR Regional Engineer, See Definitions.
fi ,. Z,
The permittee shall compare monitoring results,t'o the benchmark values in Table 1.
Exceedances of benchmark values require rtl apermitteerto increase monitoring, increase
management actions, increase record keeping,tand/or install stormwater Best Management
Practices (BMPs) in a tiered program. Seebelowwtl a descriptions of Tier One, Tier Two, and
Tier Three response actions below.,,In the,event that the Division releases the permittee from
ee
continued monthly monitoring and"reprtin`g under Tier Two or Tier Three, the Division's
release letter may remain in effect thr'ough,subsequent reissuance of this permit, unless the
release letter provides f6nother eonditions or duration.
The benchmark values iri Tabhe.1'are not permit limits but should be used as guidelines for
implementation of t,, permittee'ys SPPP. An exceedance of a stormwater benchmark value
is not a permit violation; however, failure to respond to the exceedance as outlined in this
r-i4 "0,
permit is a violationofpermit conditions.
Please note that the parameters in the last two rows in Table 1 (no -polar oil and grease and
new motor oil usage) are only required for outfalls that discharge runoff from vehicle or
equipment maintenance areas in which more than 55 gallons of new motor oil and/or
hydraulic ail per month is used when averaged over the calendar year.
Table 1. Analytical Monitoring Requirements
Parameter
Code
Discharge
Characteristics
Units
Measurement
Frequencyi
Sample
Type2
Sample
Locati6n3
Bench -
mark
C0610
Total Ammonia as Nitrogen TAN
m L
semi-annual
Grab
SDO
7.2
625
Total K'eldahl Nitrogen TKN
m L
semi-annual
Grab
SDO
20
630
Nitrate + Nitrite Nitrogen (NO3 + NO2)
m L
semi-annual
Grab
SDO
10
940
Chloride(Cl)m
L
semi-annual'
Grab
SDO
860
C0530
Total Sus Ended Solids TSS)
m L
semi-annual
Grab
SDO
100
1105
Total Aluminum Al
m L
semi-annual
Grab
SDO
0.75
1002 Y
Total Arsenic Ar
m L
semi-annual
Grab
SD0
0.34
1027
Total Cadmium Cd
m L
semi-annual
Grab
SDO
0.003
916
Total Calcium Ca
m L
semi-annual
Grab
SDO
915
C0042
Total Copper Cu
m L
semi-annual
Grab
SDO
0.01
1051'1
Total Lead Pb
m L
semi-annual
Grab
SDO
0.075
1055
Total Manganese Mn
mgZL
semi-annual
Grab
SDO
n a
Page - 7

Permit No. NCS00O594 DRAFT
Parameter
Discharge'
Measurement
Sample
.,,Sample '
Bench- `
Code ;'
Cha1.racteristics
Uriits'.
Fre ueric 1
T e�
l.ocation3
mark``;'
927 ✓
Total Magnesium M
m L
semi-annual
Grab
SDO
32
1067
'Total Nickle Ni
m L
semi-annual
Grab
SDO
0.335
C0665
Total Phosphorous P
m L
semi-annual
Grab
SDO
2
937 -'
Total Potassium K
m L
semi-annual
Grab
SDO
17.14
929
Total Sodium Na
m L
semi-annual
Grab
SDO
865
1092
Total Zinc Zn
mg/L
semi-annual
Grab
SDO
0.126
900
Hardness
m L
semi-annual
Grab
SDO
-
400
pH
standard
semi-annual
Grab
SDO
6-9
46529
Total Rainfall4
inches
, semi-annual
Rain Gauge
-
Non-Polar-0il & Grease by EPA
Method 1664 (SGT-HEM) for
552
mg/[ '�i
, semis°annual
Grab
SDO
15
outfalls with vehicle/equipment
maintenance activitiess
New Motor Oil Usage
--
for outfalls with vehicle/
Gallons / �
semi-annual
Estimate
--
equipment maintenance
month
activitiessF
Footnotes: V
Measurement Frequency, �Xwice;p4er year unless other provisions of this permit prompt monthly
sampling) during a measureable stio ",:event, until either another permit is issued for this facility or until
this permit is revoked or rescinded. I6 e facility is monitoring monthly because of Tier Two or Three
F. IY ,.,.,,,f N
response actions under the previous -permit, the facility shall continue a monthly monitoring and
reporting schedule in Tier Two o`r Tier Three status until relieved by the provisions of this permit or
the Division.'
2 Grab samples shall be collected within the first 30 minutes of discharge. When physical separation between
outfalls prevents toll ct g all samples within the first 30 minutes, sampling shall begin within the first 30
minutes, and shall continue until completed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless
representative outfall status (ROS) has been granted. A copy of the Division's letter granting ROS shall be
kept on site. Samples shall also be collected at an in -ditch monitoring point downstream of the
discharge from the facility's riser structure below the pond system.
4 For each sampled measureable storm event, the total precipitation must be recorded. An on -site rain gauge
is required. Where isolated sites are unmanned for extended periods of time, a local rain gauge reading
may be substituted for an on -site reading.
5 This parameter is only required for outfalls that discharge runoff from vehicle / equipment maintenance
areas in which more than 55 gallons of new motor oil per month is used when averaged over the
calendar year.
The permittee shall complete the analytical samplings in accordance with the schedule
specified below in Table 2, unless adverse weather conditions prevent sample collection
(see Adverse Weather in Definitions). Sampling is not required outside of the facility's
normal operating hours. A minimum of 60 days must separate Period 1 and Period 2
sample dates, unless monthly monitoring has been instituted under a "Tier Two"
response. Inability to sample because of adverse weather conditions must be documented
in the SPPP and recorded on the DMR. The permittee must report the results from each
sample taken within the monitoring period (see Part I11, Section E). However, for purposes
of benchmark comparison and Tiered response actions, the permittee shall use the
analytical results from the first sample with valid results within the monitoring period.
Page - 8

Permit No. NCS000594 DRAFT
Table 2. Monitoring Schedule
Semi -Annual
Monitoring Events.x `E
Start Date
(All Years)
End Date'
(All Yeairs)3,+
Period 1
December 1
March 31
Period 2
April 1
November 30
Foolotes:
1 Maintain semi-annual monitoring until either another permit is issued for this facility or until this
permit is revoked or rescinded. The permittee must submit an application for renewal of coverage
before the submittal deadline (180 days before expiration) to be considered for renewed coverage
under the permit. The permittee must continue analytical monitoring throughout the permit
renewal process, even if a renewal permit is not issued'until after expiration of this permit.
2 If no discharge occurs during the sampling period; the permittee must submit a monitoring report
indicating "No Flow" or "No Discharge" within-30 days of.the end of the sampling period.
3 Monitoring periods remain consistent through the permit term and through the renewal process.
Failure to monitor semi-annually per permit terms may result in the Division requiring
monthly monitoring for all parameters.for-,a:specified time period. "No discharge" from an
outfall during a monitoring perioddoes"not.'constltute failure to monitor, as long as it is
t
properly recorded and reported.,'
Tier One
If. The first valid samplingiesults a'r'e"above a benchmark value, or outside of the benchmark range, for any
parameter at any outfall; _!
Then: The permittee shall;;,'
1. Conduct a stormwater management inspection of the facility within two weeks of receiving sampling
results.
2. Identify and evaluate possible causes of the benchmark value exceedance.
3. Identify potential, and select the specific feasible: source controls, operational controls, or physical
improvements to reduce concentrations of the parameters of concern, and/or to bring concentrations
within the benchmark range.
4. Implement the selected feasible actions within two months of the inspection.
5. Record each instance of a Tier One response in the SPPP. Include the date and value of the benchmark
exceedance, the inspection date, the personnel conducting the inspection, the selected actions, and the
date the selected actions were implemented.
6. Note: Benchmark exceedances for a different parameter separately trigger a tiered response.
Page - 9

Permit No. NC50o0594 DRAFT
E
-Tier Two
:'
d
If: The first valid sampling results from two consecutive monitoring periods (omitting periods with no
discharge) are above the benchmark values, or outside of the benchmark range, for any specific parameter at
a specific discharge outfall;
Then: The permittee shall:
1. Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring and reporting for all parameters. The permittee shall conduct
monthly monitoring at every outfall where a sampling result exceeded the benchmark value for two
consecutive samples. Monthly (analytical and qualitative) monitoring shall continue until three
consecutive sample results are below the benchmark values or within benchmark range.
3. If no discharge occurs during the sampling period, the permittee is required to submit a monthly
monitoring report indicating "No Flow" to comply with' eporting requirements.
4. 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 prov ded 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.
5. Maintain a record of the Tier Two response.in�t, he SPPP.
6, Continue Tier Two response obligation's throu'ghodt the permit renewal process.
'Ti' Tree
If: The valid sampling results`required for the'permit monitoring periods exceed the benchmark value, or
are outside the benchmark range, fora y,specific parameter at any specific outfall on four occasions, the
,:,. 1. .
permittee shall notify the DEMLR,Regional'Engineer in writing within 30 days of receipt of the fourth
analytical results;
Then: The Division may but is not limited to:
• require that the permittee;revise, increase, or decrease the monitoring and reporting frequency for
some or all of the parameters herein;
• require sampling of additional or substitute parameters;
• require the permittee to install structural stormwater controls;
• require the permittee to implement other stormwater control measures;
• require the permittee to perform upstream and downstream monitoring to characterize impacts on
receiving waters;
• require the permittee implement site modifications to qualify for a No Exposure Exclusion;
• require the permittee to continue Tier Three obligations through the permit renewal process,
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
The purpose of qualitative monitoring is to evaluate the effectiveness of the Stormwater
Pollution Prevention Plan (SPPP) and identify new potential sources of stormwater
pollution. Qualitative monitoring of stormwater outfalls must be performed during a
measurable storm event.
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status. Qualitative monitoring shall be performed semi-annually
during required analytical monitoring events (unless the permittee is required to perform
further qualitative monitoring per the Qualitative Monitoring Response, below). Inability
to monitor because of adverse weather conditions must be documented in the SPPP and
Page - 10

Permit No. NCS000594 DRAFT
recorded on the Qualitative Monitoring Report form (see Adverse Weather in Definitions).
Only SDOs discharging stormwater associated with industrial activity must be monitored
(See Definitions).
In the event an atypical condition is noted at a stormwater discharge outfall, the permittee
shall document the suspected cause of the condition and any actions taken in response to
the discovery. This documentation will be maintained with the SPPP.
Table 6. Qualitative Monitoring Requirements
Discharge Characteristics,;° ,
Frequency?;
Monitoring
r
Location2
Color
semi-annual
SDO
Odor
/_ semi-annual
SDO
Clarity`",semi-annual
SDO
Floating Solids ,•
`''semi-annual
SDO
Suspended Solids '0 ".
­ <semi-annual
i SDO
Foamr , ''i i�
semi-annual
SDO
Oil Sheen'' %`f
semi-annual
SDO
Erosion or deposition aftheoutfall>
semi-annual
SDO
Other obvious indicators " �` , `.
semi-annual
SDO
,>
of stormwater pollution
Footnotes:
1 Monitoring Frequency- Twce per year during a measureable storm event unless other provisions of this
permit prompt monthly monitoring. See Table 2 for schedule of monitoring periods. The permittee must
continue qualitative monitoring throughout the permit renewal process until a new permit is issued.
2 Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall
(SDO) regardless of representative outfall status.
A minimum of 60 days must separate monitoring dates, unless additional sampling has
been instituted as part of other analytical monitoring requirements in this permit.
If the permittee's qualitative monitoring indicates that existing stormwater BMPs are
ineffective, or that significant stormwater contamination is present, the permittee shall
investigate potential causes, evaluate the feasibility of corrective actions, and implement
those corrective actions within 60 days, per the Qualitative Monitoring Response, below.
A written record of the permittee's investigation, evaluation, and response actions shall be
kept in the Stormwater Pollution Prevention Plan.
Page - 11

Permit No. NCS000594 DRAFT
'
3ij`E {e
Qualitative monitoring is for the purposes of evaluating SPPP effectiveness, identifying new
potential sources of stormwater pollution, and prompting the permittee's response to pollution. If
the permittee repeatedly fails to respond effectively to correct problems identified by qualitative
monitoring, or if the discharge causes or contributes to a water quality standard violation, the
Division may but is not limited to:
• require that the permittee revise, increase, or decrease the monitoring frequency for some
or all parameters (analytical or qualitative)
• require the permittee to install structural stormwater controls;
require the permittee to implement other stormwater control measures;
0,
require the permittee to perform upstream and;.downstream monitoring to characterize
impacts on receiving waters; or
require the permittee implement site r dificati ns.to� ualify for a No Exposure Exclusion.
i> , ex %..�.: ; .—I
SECTION D: SPECIAL CONDITIONS, ' "'
ELECTRONIC REPORTING O
REPORTS [G.S.143-21S.1(b)]
Federal regulations requrre1electronic submittal of all discharge monitoring reports
(DMRs) and program reports,-The`.ffinal NPDES Electronic Reporting Rule was adopted and
became effective on December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within
Part III of this permit'•(Sta`ndard Conditions for NPDES Permits):
• Section B. (3.) Signatory Requirements
• Section D. (6.) Records Retention
• Section E. (1.) Discharge Monitoring Reports
• Section E. (2.) Submitting Reports
1. Re op rting Requirements [Supplements Section E. (1.) and Supersedes Section E.
�1
Effective December 21, 2016 or when the agency's electronic reporting system is able
to accept NPDES stormwater permit monitoring data, the permittee shall report
discharge monitoring data electronically using the NC DWR's Electronic Discharge
Monitoring Report (eDMR) internet application. NC DEMLR will notify permittees
when eDMR is ready to accept stormwater monitoring data.
Monitoring results obtained during the previous month(s) shall be summarized for each
month and submitted electronically using eDMR. The eDMR system allows permitted
facilities to enter monitoring data and submit DMRs electronically using the internet.
Until such time that the state's eDMR application is compliant with EPA's Cross -Media
Electronic Reporting Regulation (CROMERR), permittees will be required to submit all
discharge monitoring data to the state electronically using eDMR and also will be
Page - 12

Permit No. NCS000594 DRAFT
required to complete the eDMR submission by printing, signing, and submitting one
signed original and a copy of the computer printed eDMR to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due
to the facility being physically located in an area where less than 10 percent of the
households have broadband access, then a temporary waiver from the NPDES
electronic reporting requirements may be granted'and discharge monitoring data may
be submitted on paper DMR forms or alternativeforms approved by the Director.
Duplicate signed copies shall be submitted tiothe milling address above. See "How to
Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first'DMR is due no later than 30 days from
%T
the date the facility receives the sampling results from the laboratory.
2. flow to Request w, aiver,from Electronic Reportillig,
The permittee may seeka temporary electronic reporting waiver from the Division. To
obtain an electronic reporting waiver, a permittee must first submit an electronic
reporting waiver request;to the Division. Requests for temporary electronic reporting
waivers must be submided in writing to the Division for written approval at least sixty
(60) days prior to -the date the facility would be required under this permit to begin
submitting monitoring data and reports. The duration of a temporary waiver shall not
exceed 5 years and shall thereupon expire. At such time, monitoring data and reports
shall be submitted electronically to the Division unless the permittee re -applies for and
is granted a new temporary electronic reporting waiver by the Division. Approved
electronic reporting waivers are not transferrable. Only permittees with an approved
reporting waiver request may submit monitoring data and reports on paper to the
Division for the period that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver
are found on the following web page:
http,./.Ideq.nc.gov./about/divisionslwater-resources/Qdmr
3. Signatory Requirementse tiSuperNedes Section
B. (3.1 fdll
All eDMRs submitted to the permit issuing authority shall be signed by a person
described in Part III, Section B. (3.) (a) or by a duly authorized representative of that
person as described in Part I1I, Section B. (3.) (b). A person, and not a position, must be
delegated signatory authority for eDMR reporting purposes.
Page - 13

Permit No. NCS000594 DRAFT
For eDMR submissions, the person signing and submitting the DMR must obtain an
eDMR user account and login credentials to access the eDMR system. For more
information on North Carolina's eDMR system, registering for eDMR and obtaining an
eDMR user account, please visit the following web page:
http: ///deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system
shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED:
7 certify, under penalty of law, that this documentJand all attachments were prepared
under my direction or supervision In accordance iniith a system designed to assure that
qualified personnel properly gather andlevaluate they formation submitted. Based on my
inquiry of the person or persons who manage,the system, or those persons directly
responsible forgathering the information, the:lnformation submitted is, to the best of my
n wEI,�.7
knowledge and belief, true, accurateandF complete. I am aware that there are significant
penalties forsubmitting false informattonptncluding the possibility offines and
imprisonment for knowing violations.
4. Records eention fSunblements°Section D, f6,11
N,,,:,,:r,
The permittee shall retain'records of all Discharge Monitoring Reports, including eDMR
submissions. These recorclsor copies shall be maintained for a period of at least 3
years from the date of the�r port. This period may be extended by request of the
Director at any time [40 CFR 122.41].
Page - 14

Permit No. NCS000594 DRAFT
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time: The
Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the
effective date of the initial permit and updated thereafter on an annual basis. Secondary
containment, as specified in Part 1I, Section A, Paragraph *,'2(b) of this permit, shall be accomplished
within 12 months of the effective date of the initial permit issuance.
New Facilities applying for coverage for the first time The Stormwater Pollution Prevention Plan
shall be developed and implemented priorito the beginning of discharges from the operation of the
industrial activity and be updated thereafter bn an annual basis. Secondary containment, as specified
in Part I1, Section A, Paragraph 2(b) of this.perrnit shall be accomplished prior to the beginning of
stormwater discharges from the operation Eofthe fridustrial activity.
Existing facilities previously permitted a" applying for renewal: All requirements, conditions,
limitations, and controls contained in this permit (except new SPPP elements in this permit renewal)
shall become effective`immediately upon issuance of this permit. New elements of the Stormwater
Pollution PreventionaPlan.for thispermit renewal shall be developed and implemented within 6
months of the effective:date of this permit and updated thereafter on an annual basis. Secondary
containment, as specified in Part 11, Section A, Paragraph 2(b) of this permit: shall be accomplished
prior to the beginning of stormwater discharges from the operation of the industrial activity.
r`
2. Duty to Comp)
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes
a violation of the Clean Water Act (CWA) and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal
application [40 CFR 122.41].
a. The permittee shall comply with standards or prohibitions established under section 307(a) of
the CWA for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement [40 CFR 122.41].
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of
the Act, or any permit condition or limitation implementing any such sections in a permit issued
under section 402, or any requirement imposed in a pretreatment program approved under
sections 402(a)(3) or 402(b)(8) of the Act, is subject to a civil penalty not to exceed $51,570 per
day for each violation [33 USC 1319(d) and 40 CFR 122.41(a)(2)).
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308,
318, or 405 of the Act, or any condition or limitation implementing any of such sections in a
permit issued under section 402 of the Act, or any requirement imposed in a pretreatment
program approved under section 402(a)(3) or 402(b)(8) of the Act, is subject to criminal
penalties of $2,500 to $25,000 per day of violation, or imprisonment of not more than 1 year, or
both. In the case of a second or subsequent conviction for a negligent violation, a person shall be
subject to criminal penalties of not more than $50,000 per day of violation, or by imprisonment
of not more than 2 years, or both [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)].
Page - 15

Permit No. NCS000594 DRAFT
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to
criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3
years, or both. In the case of a second or subsequent conviction for a knowing violation, a person
shall be subject to criminal penalties of not more than $100,000 per day of violation, or
imprisonment of not more than 6 years, or both [33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)].
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act,
or any permit condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, and who knows at that time that he thereby places another person in
imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of
not more than $250,000 or imprisonment of not more than 15 years, or both. In the case of a
second or subsequent conviction for a knowing endangerment violation, a person shall be
subject to a fine of not more than $500,000 or b�Jffiprisonment of not more than 30 years, or
a, �_,�.,.: E,f.,
both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction
of violating the imminent danger provision, bOnT 'e sublect,to;a fine of not more than $1,000,000 and
Jkqi
can be fined up to $2,000,000 for second or subsequent convictions [40 CFR 122.41(a)(2)].
f. Under state law, a civil penalty of not.more tha&$25,000 per violation may be assessed against
./- :� � . e
any person who violates or fails to,actin accordance with the terms, conditions, or requirements
«k:
of a permit [North Carolina Ge� eras tdtutesl§ 143-215.6A].
g. Any person may be assessed an administrative penalty by the Administrator for violating section
301, 302, 306„ 307, 308 318 or�405r,,°of this Act, or any permit condition or limitation
8
implementing any of, such sections in a permit issued under section 402 of this Act.
Administrative penalties for Glass I violations are not to exceed $20,628 per violation, with the
maximum amount of'any Class I penalty assessed not to exceed $51,570. Penalties for Class 11
violations are not to exceed $20,628 per day for each day during which the violation continues,
with the maximum amount of any Class II penalty not to exceed $257,848 [33 USC 1319(g)(2)
and 40 CFR_12;2.,4,1(a)(3)].
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
permit which has a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
4. Civil and Criminal Liability
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater control
facilities, nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3,143-215.6, or Section 309 of the
Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages,
such as fish kills, even though the responsibility for effective compliance may be temporarily
suspended.
Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the
permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be
subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property,
or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of federal, state or local laws or regulations [40 CFR 122.41(g)].
Page - 16

Permit No. NCS000594 DRAFT
Severabilitx
The provisions of this permit are severable, and if any provision of this permit, or the application of
any provision of this permit to any circumstances, is held invalid, the application of such provision to
other circumstances, and the remainder of this permit, shall not be affected thereby [NCGS 15013-23].
B. DAY to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating the permit issued pursuant to this permit or to
determine compliance with this permit. The permittee shall also furnish to the Permit Issuing
Authority upon request, copies of records required to be kept by this permit [40 CFR 122.41(h)].
9. Penalties for Tampering /,>
The Clean Water Act provides that any person who'falsifies, tampers with, or knowingly renders
inaccurate, any monitoring device or method equired`to be maintained under this permit shall, upon
conviction, be punished by a fine of not more than $iiT000'per violation, or by imprisonment for not
more than two years per violation, or by both`: if a conviction of a person is for a violation committed
after a first conviction of such person under this paragraph, punishment is a fine of not more than
$20,000 per day of violation, or by imprisonment of not more than 4 years, or both [40 CFR 122.411.
10. Penalties for Falsification of Reports
The Clean Water Act provides that anylperson who knowingly makes any false statement,
representation, or certifications anyreco'rd or other document submitted or required to be
maintained under this,permit, includi ng,fn on ito ring reports or reports of compliance or
noncompliance shall; upon conviction, be punished by a fine of not more than $10,000 per violation,
or by imprisonment for not`more than two years per violation, or by both (40 CFR 122.41].
11.
This permit does,,not authorize or approve the construction of any onshore or offshore physical
structures or facilitiesor"the undertaking of any work in any navigable waters.
12. Duly to Reannly
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
SECTION B: GENERAL CONDITIONS
1. Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as
are required by the agency authorized to issue permits no later than 180 days prior to the
expiration date, unless permission for a later date has been granted by the Director. (The Director
shall not grant permission for applications to be submitted later than the expiration date of the
existing permit) [40 CFR 122.21(d)]. Any permittee that has not requested renewal at least 180 days
prior to expiration, or any permittee that does not have a permit after the expiration and has not
requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures
as provided in NCGS §143-215.36 and 33 USC 1251 et. seq.
Page - 17

Permit No. NCS000594 DRAFT
Transfers
This permit is not transferable to any person without prior written notice to and approval from the
Director in accordance with 40 CFR 122.61. The Director may condition approval in accordance with
NCGS 143-2.15.1, in particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation
and reissuance of the permit, or a minor modification, to identify the new permittee and incorporate
such other requirements as may be necessary under the CWA [40 CFR 122.41(I)(3), 122.61] or state
statute. The Permittee is required to notify the Division in writing in the event the permitted
facility is sold or closed.
Signatory Requirements
All applications, reports, or information submitted to the Permitting Issuing Authority shall be signed
and certified [40 CFR 122.41(k)].
a. All permit applications shall be signed as
For a
te'bfficer..For the
(1) responsible corporate officeromeansco a ares dent secrets purposet easurrer or vice president
p p •, � .) p .� ,. �. rY,
of the corporation in charge of a principal business function, or any other person who
performs similar policy or decisioninaking functions for the corporation, or (b) the manager
of one or more manufacturing, production,,or operating facilities, provided, the manager is
authorized to make man]age�mentFdec l I;sions which govern the operation of the regulated
facility including having the explicitor implicit duty of making major capital investment
recommendations, and initiating and directing other comprehensive measures to assure
1>:< Or ��
longterm environmental compliance with environmental laws and regulations; the manager
can ensure'that the.necessar!,:systems are established or actions taken to gather complete
and accurate informatiornfor permit application requirements; and where authority to sign
documents has, een assigned or delegated to the manager in accordance with corporate
procedures
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively; or ,�
(3) For a inuniai ality, state, federal, or other public agency: by either a principal executive
officer or ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described in paragraph a. above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant manager,
operator of a well or well field, superintendent, a position of equivalent responsibility, or an
individual or position having overall responsibility for environmental matters for the company.
(A duly authorized representative may thus be either a named individual or any individual
occupying a named position.); and
(3) The written authorization is submitted to the Permit issuing Authority [40 CFR 122.22].
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer
accurate because a different individual or position has responsibility for the overall operation of
the facility, a new authorization satisfying the requirements of paragraph (b) of this section must
be submitted to the Director prior to or together with any reports, information, or applications to
be signed by an authorized representative [40 CFR 122.22].
Page - 18

Permit No. NCS000594 DRAFT
d. Certification. Any person signing a document under paragraphs a. or b. of this section, or
submitting an electronic report (e.g., eDMR), shall make the following certification [40 CFR
122.22] NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction orsupervision in accordance with a system designed to assure that qualified personnel
properlygather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible forgathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility offnes and imprisonment for knowing violations. "
4. Permit Modification. Revocation and Reissuance. or, Termination
The issuance of this permit does not prohibit the Permitl'ssuing Authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed by the
laws, rules, and regulations contained in Title 40,.Code of Fede al Regulations, Parts 122 and 123;
Title 15A of the North Carolina Administratilve.Code, Subchapter 2H .0100; and North Carolina
General Statute 143-215.1 et al. .�
5. Permit Actions
The permit may be modified, revoke4-and,reissu6d, or terminated for cause. The notification of
planned changes or anticipated noncompliance does not stay any permit condition [40 CFR
122.41(f)].
�-R �.:, f
6. Annual Administering_ and ComW" ianee'Moniloring Fee Requirements
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days
after being billed by,the`Division�-"Failure to pay the fee in timely manner in accordance with 15A
NCAC 2H .0105(b)(2) may cause the Division to initiate action to revoke the permit.
SECTION C: OPERATION AND'MAINTENANCE OF POLLUTION CONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by the permittee to achieve
compliance with the conditions of this permit. Proper operation and maintenance also includes
adequate laboratory controls and appropriate quality assurance procedures. This provision requires
the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee
only when the operation is necessary to achieve compliance with the conditions of this permit [40
CFR 122.41(e)].
Need ti2 t e
It shall not be a defense for a permittee in an enforcement action that it would have been necessary
to halt or reduce the permitted activity in order to maintain compliance with the condition of this
permit [40 CFR 122.41(c)].
3. BynasMng of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass
unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater, or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
the exercise of reasonable engineering judgment to prevent a bypass which occurred during
normal periods of equipment downtime or preventive maintenance; and
Page - 19

Permit No. NCS000594 DRAFT
c. The permittee submitted notices as required under, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may
approve an anticipated bypass after'considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume
and nature of the permitted discharge. Analytical sampling shall be performed during a measureable
storm event. Samples shall be taken on a day and time that is characteristic of the discharge. All
samples shall be taken before the discharge joins or is diluted by any other waste stream, body of
water, or substance. Monitoring points as specified?iEn't}'is permit shall not be changed without
notification to and approval of the Permit Issumg Authority [4Q,CFR 122.41(j)].
W
2. Recording Rgsults�;?
For each measurement or sample taken purrsuant to the requirements of this permit, the permittee
shall record the following information [40:. PR 122.41]!
a. The date, exact place, and time of sampling o measurements;
b. The individual(s) who performed the sampling or measurements;
If,+/
c. The date(s) analyses were -performed-,
d. The individuals) ) who,pe formed -the analyses;
e. The analytical techniques\or methods used; and
iI.
E The results of such analyses.
3. Flow Measurements Ia
Where requiredappropriate flow measurement devices and methods consistent with accepted
scientific practices'sh'aill be selected and used to ensure the accuracy and reliability of measurements
of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations
published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the
minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge
requirements, then the most sensitive (method with the lowest possible detection and reporting
level) approved method must be used.
5.
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.
Page - 20

Permit No. NCS000594 DRAFT
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the
Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be
maintained on -site. The permittee shall retain records of all monitoring information, including
o all calibration and maintenance records,
o all original strip chart recordings for continuous monitoring instrumentation,
o copies of all reports required by this permit, including Discharge Monitoring Reports
(DMRs),
o copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 5 years from the date of the
sample, measurement, report or application. This period;may be extended by request of the Director
at anytime [40 CFR 122.411.
Inspection and Entry "; r� r
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the -Director), or in the case of a facility which discharges
through a municipal separate storm sewer -system, an authorized representative of a municipal
operator or the separate storm sewer' system receiving the discharge, upon the presentation of
credentials and other documents as maybe required by law, to:
19
a. Enter upon the pe mittee's.p emises..where a regulated facility or activity is located or conducted,
or where records must be kept u'nder'the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions
of this permit;
C. Inspect at reasonable times'any facilities, equipment (including monitoring and control
equipment)„practices, oi'dperations regulated or required under this permit; and
d. Sample or monitor at�Ceasonable times, for the purposes of assuring permit compliance or as
otherwise auttiorize'd by the Clean Water Act, any substances or parameters at any location [40
CFR 122.41(i)]_•
SECTION E: REPORTING REQUIREMENTS
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report (DMR) forms provided by the Director or submitted electronically to
the appropriate authority using an approved electronic DMR reporting system (e.g., eDMR). DMR
forms are available on the Division's website (httys:Hdeg.iic.gov/about/divisions/enerizy-
mineral -1 and -resource s/nNes-stormwater- individual). Regardless of the submission method
(paper or electronic), submittals shall be delivered to the Division or appropriate authority no later
than 30 days from the date the facility receives the sampling results from the laboratory.
When no discharge has occurred from the facility during the report period, the permittee is required
to submit a discharge monitoring report, within 30 days of the end of the specified sampling period,
giving all required information and indicating "NO FLOW" as per NCAC T15A 0213.0506.
If the permittee monitors any pollutant more frequently than required by this permit using test
procedures approved under 40 CFR Part 136 and at a sampling location specified in this permit or
other appropriate instrument governing the discharge, the results of such monitoring shall be
included in the data submitted on the DMR [40 CFR §122.41(1)).
Page - 21

Permit No. NCS000594 DRAFT
3.
4.
S.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division and shall retain the completed forms on site.
Qualitative monitoring results should not be submitted to the Division, except upon the Division's
specific requirement to do so. Qualitative Monitoring Report forms are available at the website
above.
Submitting Reports
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central Files
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
r.r
�9 Spf.i
Availability of Reports y" r
Except for data determined to be confidential der NCGS -143-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared,in accordance with the terms of this permit shall be
available for public inspection at the ofFcesrof the�Division. As required by the Act, analytical data
shall not be considered confidential. Kno.wingly4dking any false statement on any such report may
result in the imposition of criminal penalties Sas provided for in NCGS 143-215.613 or in Section 309 of
the Federal Act.°...
If the storm event monitored€ Waccardaffce with this permit coincides with a non-stormwater
aJe €`, " s ,,,"
discharge, the permittee's,halllsek tely monitor all parameters as required under all other
applicable discharge, permits and provide this information with the stormwater discharge
monitoring report:''
The permittee'shal,zivenotice to the Director as soon as possible of any planned changes at the
permitted facility,which could significantly alter the nature or quantity of pollutants discharged [40
CFR 122.41(1)]. This notification requirement includes pollutants which are not specifically listed in
the permit or subject to notification requirements under 40 CFR Part 122.42 (a).
6. Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes at the permitted
facility which may result in noncompliance with the permit [40 CFR 122.41(1) (2)].
7. Snips
The permittee shall report to the local DEMLR Regional Office, within 24 hours, all significant spills
as defined in Part IV of this permit. Additionally, the permittee shall report spills including: any oil
spill of 25 gallons or more, any spill regardless of amount that causes a sheen on surface waters, any
oil spill regardless of amount occurring within 100 feet of surface waters, and any oil spill less than
25 gallons that cannot be cleaned up within 24 hours.
8. Bypass
Notice [40 CFR 122.41(m)(3)]:
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and effect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of
an unanticipated bypass.
Page - 22

Permit No. NC5000594 DRAFT
9. Twe -four Hour
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the circumstances.
A written submission shall also be provided within 5 days of the time the permittee becomes
aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes; the
period of noncompliance, including exact dates and times, and if the noncompliance has not
been corrected, the anticipated time compliance is expected to continue; and steps taken or
planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40 CFR
122.41(I)(6)].
a,
b. The Director may waive the written report on,a'ca a -by -case basis for reports under this section
if the oral report has been received within 24'''hour`s.�
c. Occurrences outside normal business ho s may also be reported to the Division's Emergency
Response personnel at [phone],-(B00) 858-0368 or [phone].
10. Other Noncompliance !
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at
the time monitoring reports are"submitted-[40 CFR 122.41(l)(7)].
11. Other Informations
Where the Perm ute--'becomesaware that it failed to submit any relevant facts in a permit
application, or submitted.in`correct information in a permit application or in any report to the
y submit such facts or information [40 CFR 122.41(1]{8)]. Director, it shall promptl
Page - 23

NCS000594 DRAFT PERMIT
PART IV DEFINITIONS
1. Act
See Clean Water Act.
Adverse Weather
Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local
flooding, high winds, or electrical storms, or situations that otherwise make sampling impractical.
When adverse weather conditions prevent the collection of samples during the sample period, the
permittee must take a substitute sample or perform a visual assessment during the next qualifying
storm event. Documentation of an adverse event (with date, time and written narrative) and the
rationale must be included with SPPP records. Adverse wea�thergdoes not exempt the permittee from
having to file a monitoring report in accordance with the sampling schedule. Adverse events and
failures to monitor must also be explained and reported on the,relevant,-DMR.
3. Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. However, non-stormwater discharges which shall be
allowed in the stormwater conveyance system include
a. All other discharges that are authorized by a"non-stormwater NPDES permit.
b. Uncontaminated groundwater, foundation drains; air conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains,flows�•from riparian habitats and wetlands.
c. Discharges resulting from fire -fighting or -fire -fighting training, or emergency shower or eye
wash as a result of use in the event o�fan emergency.
4. Best Manaeement PracticesIBMPsl ' �>
Measures or practices used to reduce'the amount of pollution entering surface waters. BMPs may
take the form of a process, activiV; or physical structure. More information on BMPs can be found at:
S. $voass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility
including the collection system, which is not a designed or established operating mode for the facility.
6. BulkStorage_ofLiquid Products
Liquid raw materials, intermediate products, 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 having a total combined storage capacity of greater
than 1,320 gallons.
7. Certificate of Coverage
The Certificate of Coverage (COC) is the cover sheet which accompanies a General Permit upon
issuance and lists the facility name, location, receiving stream, river basin, effective date of coverage
under any General Permit and is signed by the Director.
8. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
9. Division or DEMLR
The Division of Energy, Mineral, and Land Resources, Department of Environmental Quality.
10. Director
The Director of the Division of Energy, Mineral, and Land Resources, the permit issuing authority.

Permit No. NCS000594 DRAFT
11. EMC
The North Carolina Environmental Management Commission.
12. grab 5ampjg
An individual sample collected instantaneously. Grab samples that will be analyzed (quantitatively
or qualitatively) must be taken within the first 30 minutes of discharge.
13. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
14. Landfill
A disposal facility or part of a disposal facility where waste is placed in or an land and which is not a
y .
land treatment facility, a surface impoundment, an,inlection well, a hazardous waste long-term
storage facility or a surface storage facility.r,,
Xf
15. Measureable Storm Event
A storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must have been at.least.72 hours prior. The 72-hour storm interval may not
apply if the permittee is able to document tliat a shorter interval is representative for local storm
events during the sampling period; and Aiains'aapproval from the local DEMLR Regional Office. Two
copies of this information and a written request letter shall be sent to the local DEMLR Regional
Office. After authorization by the DEMLR Regional Office, a written approval letter must be kept on
site in the permittee s-SPPP: r"
16. Municival Separate Storm Sewer Svstem_fM-541
A stormwater collection system within an incorporated area of local self-government such as a city or
town. Y 41%"'
17. No Exl2osure :_;.• ,F.,aR:
A condition of rioexposure means that all industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or
runoff. Industrial materials or activities include, but are not limited to, material handling equipment
or activities, industrial machinery, raw materials, intermediate products, by-products, final products,
or waste products [40 CFR 122.26 (b)(14)]. DEMLR may grant a No Exposure Exclusion from NPDES
Stormwater Permitting requirements only if a facility complies with the terms and conditions
described in 40 CFR §122.26(g).
18. Notice of Intent
The state application form which, when submitted to the Division, officially indicates the facility's
notice of intent to seek coverage under a General Permit.
19. Permit Issuing Authority
The Director of the Division of Energy, Mineral, and Land Resources (see "Director" above).
20. Permittee
The owner or operator issued this permit.
21. Point Source Discharge of Stgrmwater
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.
Page - 25

Permit No. NCS000594 DRAFT
22. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the Division may grant representative outfall status. Representative outfall
status allows the permittee to perform analytical monitoring at a reduced number of outfalls.
23. Secondaa Containment
Spill containment for the contents of the single largest tank within the containment structure plus
sufficient freeboard to contain the 25-year, 24-hour storm event.
24. 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 11I, Section 313 reporting
requirements; and
c. Meets at least one of the following crite:"""}
�ria.,.
1. Is listed in appendix D of 40 CFR ;part „12r2 on Table 11 (organic priority pollutants), Table
III (certain metals, cyanides, and phenols) -or Table IV (certain toxic pollutants and
hazardous substances),
40
ii. Is listed as a hazardous sub tan' cIe pursuant to section 311(b)(2) (A) of the CWA at 40 CFR
116.4; or
ill. Is a pollutant for which EPA,has,published acute or chronic water quality criteria.
25. Severe Property Damaee
Substantial physical 4'n age,to property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occurin the able ce of a bypass. Severe property damage does not mean economic loss
caused by delays,in producation.
26. Significant Materials���33ftC�°
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.
27. 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 110.3and 40 CFR 117.3) or section
102 of CERCLA (Ref: 40 CFR 302.4).
28. Stormwater Discharge Outfall (SDO)
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including
but not limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection
areas, from which stormwater flows directly or indirectly into waters of the State of North Carolina.
29, Stormwater Runoff
The Flow of water which results from precipitation and which occurs immediately following rainfall
or as a result of snowmelt.
Page - 26

Permit No. NCS000594 DRAFT
30. 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.
31. 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.
32. Total Maximum -Daily Load (TMDLI
TMDLs are written plans for attaining and maintaining water quality standards, in all seasons, for a
specific water body and pollutant. A list of approved,TMDLs for the state of North Carolina can be
found athttps:/1deg.nc.gov/about/divisions/water-resources[planning/modeling:
assessment/tmdIs/draft-and-approved-trills. // -
33. Toxic Pollutant
Any pollutant listed as toxic under Sectiom.307(a)(1)bf the Clean Water Act.
34, Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical.repairs, painting, fueling, lubrication, vehicle cleaning operations,
or airport deicing operations. For the purposes of this permit, vehicle maintenance activity includes
equipment maintenance that uses hydraulic oil and that is stored or used outside, or otherwise
exposed to stormwater.�
35. Visible Sedimentation
Solid particulatematter, boih'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.
36. 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.
Page - 27

OWN NC DEPARTMENT OF
' 'r3N''• Susi Hamilton. Secretary .
�r�i NATURAL AND CULTURAL RESOURCES
Walter Clark, Director, Land and Water Stewardship
NCNHDE-7590
November 27, 2018
Bradley Bennett
NCDEQ
512 N. Salisbury Street
Raleigh, NC 27604
RE; SePRO Corporation - Research and Technology Campus; NCS000594
Dear Bradley Bennett:
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
Based on the project area mapped with your request, a query of the NCNHP database, indicates
that there are no records for rare species, important natural communities, natural areas, and/or
conservation/managed areas within the proposed project boundary. Please note that although there
may be no documentation of natural heritage elements within the project boundary, it does not
imply or confirm their absence; the area may not have been surveyed. The results of this query
should not be substituted for field surveys where suitable habitat exists. In the event that rare
species are found within the project area, please contact the NCNHP so that we may update our
records.
The attached 'Potential Occurrences' table summarizes rare species and natural communities that
have been documented within a one -mile radius of the property boundary, The proximity of these
records suggests that these natural heritage elements may potentially be present in the project area
if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one -mile
radius of the project area, if any, are also included in this report.
If a Federally -listed species is found within the project area or is indicated within a one -mile radius of
the project area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS) for
guidance. Contact information for USFWS offices in North Carolina is found here:
httos://www.fws.gov/offices/Di rectory/ListOffices.cfm?statecode=37.
Please note that natural heritage element data are maintained for the purposes of conservation
planning, project review, and scientific research, and are not intended for use as the primary criteria
for regulatory decisions, Information provided by the NCNHP database may not be published
without prior written notification to the NCNHP, and the NCNHP must be credited as an information
source in these publications. Maps of NCNHP data may not be redistributed without permission.
The NC Natural Heritage Program may follow this letter with additional correspondence if a
Dedicated Nature Preserve, Registered Heritage Area, Clean Water Management Trust Fund
easement, or Federally -listed species are documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance,
please contact Rodney A. Butler at rodney.butlerencdci;,g,ov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPARTMENT OF NATURAL AND CULTURAL RESOURCES
121 W. ,IUNL'•S STREET. RALEIGH. NC 27603 • 1651 MAIL SERVICE CENTER, RALEIGH. hlc 27699
.1 ..ram n.n v.', n.n.� r e ,. n.n -rn. n. n•

Zf
Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mile Radius of the Project Area
SePRO Corporation - Research and Technology Campus
Project No. NCS000594
November 27, 2018
NCNHDE-7590
ement Occurrences Documented Within a One -mile Radius of the Project Area
mphibian 8794 Necturus lewisi
Neuse River Waterdog 2014-02-19
B
3-Medium ---
Special
G2
S2
Concern
-eshwater 29515 Alasmidonta undulata
Triangle Floater 2010-07-28
E
3-Medium ---
Threatened
G4
S3
ivalve
-eshwater 36793 Elliptio roanokensis
Roanoke Slabshell 2015-06-03
NR
3-Medium ---
Special
G3
S3
ivalve
Concern
-eshwater 10134 Lampsilis cariosa
Yellow Lampmussel 2015-09-16
E
3-Medium ---
Endangered
G3G4
S3
ivalve
-eshwater 4173 Lampsilis radiata
Eastern Lampmussel 2011-06-22
E
3-Medium ---
Threatened
G5
S3
ivalve
-eshwater Fish11720 Noturus furiosus
Carolina Madtom 2010-07-25
E
3-Medium ---
Threatened
G2
S2
ammal 24389 Corynorhinus
Eastern Big -eared Bat 2006-Pre
E
5-Very ---
Special
G3G4T
S3
rafinesquii macrotis
Low
Concern
3
atural Areas Documented Within a One -mile Radius of the Project Area
�e Name , �
Representational•Rating:-Collective
Rating
4R/Fishing Creek Aquatic Habitat
Rl (Exceptional)
C1 (Exceptional)
anaged Areas Documented Within a One -mile Radius of the Project Area
anaged �1rea.Name ,
O.wnerY_
Ow.ner^TyPe
1022: Mail
onservation Reserve Enhancement Program
NC Department of Agriculture, Division of
State
3sement
Soil and Water Conservation
�finitions and an explanation of status designations and codes can be found at httos://ncnhde.natureserye-or.cL/content/hein. Data query generated on November 27, 2018: source: NCNHP. Q4 Oct
)18. Please resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 2 of 3

i
4
NCNHDE-7590: SePRO Corporation - Research and Technology Campus

3 of 3

Analytes:
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Multi -Sector General Permit (MSGP)
Table B.C-1.
Subsector
(You may be subject to requirements for
more than one sector/subsector)
Parameter
Benchmark Monitoring
Concentration
Subsector C1. Agricultural Chemicals
Nitrate plus Nitrite f
0.68 mg/L
(SIC 2873-2879)
Nitrogen
Total Lead (freshwater)2
Dependent
V11Hardness
Total Lead (saltwater)'
0.21 m /L
Total Iron O
1.0 m /L
Total Zinc (freshwater)2
Hardness Dependent
Total Zinc (saltwater))
0.09 m /L
Phosphorus
2.0 m /L
Subsector C2. Industrial Inorganic Chemicals
Total Aluminum
0.75 m /L
Total Iron
1.0 m /L
(SIC 2812-2819)
Nitrate plus Nitrite
0.68 mg/L
Nitrogen
Subsector C3. Soaps, Detergents, Cosmetics,
Nitrate plus Nitrite
0.68 mg/L
and Perfumes (SIC 2841-2844)
Nitrogen
Total Zinc (freshwater)2
Hardness Dependent
Total Zinc (saltwater)'
0.09 m /L
Subsector C4. Plastics, Synthetics, and Resins
Total Zinc (freshwater)2
Hardness Dependent
SIC 2821-2824
Total Zinc saltwater'
0.09 m /L
'Saltwater benchmark values apply to siormwater discharges into saline waters where indicated.
2The freshwater benchmark values of some metals are dependent on water hardness, For these parameters, permittees
must determine the hardness of the receiving water (see Appendix J, "Calculating Hardness in Receiving Waters for
Hardness Dependent Metals," for methodologyl, in accordance with Part 6.2.1.1, to identify the applicable 'hardness
range' for determining their benchmark value applicable to their facility. Hardness Dependent Benchmarks follow in the
table below!
Freshwater Hardness
Range
Lead
m /L
Zinc
m /L
0-24.99 mg/L
0.014
0.04
25-49.99 mg/L
0.023
0.05
50-74.99 mg/L
0.045
0.08
75.99.99 mg/L
0.069
0.11
100-124.99 mg/L
0.095
0.13
125-149.99 mg/.L
0.122 '
0.16 .
150-174.99 mg/L
0.151
0.18
175-199.99 mg/L
0.182
0.20
200-224.99 mg/L
0.213
0.23
225-249.99 mg/L
0,246
0.25
250+ mg/L
0.262
0.26
B.C.4 Effluent Limitations Based on Effluent Limitations Guidelines. (See also Part 6.2.2.1)
Table 8.C-2 identifies effluent limits that apply to the industrial activities described below.
Compliance with these effluent limits is to be determined based on discharges from these
industrial activities independent of commingling with any other waste streams that may be
covered under this permit.
Page 59

i,
3 ,
FACT SHEET SERIES
.. Ne or rrM ` emtCat hd At en
�Stio srpT aIEd`RRf}I¢ 8d ail &
U.S. EPA Office of Water - -
o EPA833+-06018
December 2006
What is the NPDES stormwater permitting program for industrial
activity?
Activities, such as material handling and storage, equipment maintenance and cleaning, industrial
processing or other operations that occur at industrial facilities are often exposed to stormwater. The
runoff from these areas may discharge pollutants directly into nearby waterbodies or indirectly via
storm sewer systems, thereby degrading water quality.
In 1990, the U.S. Environmental Protection Agency (EPA) developed permitting regulations under the
National Pollutant Discharge Elimination System (NPDES) to control stormwater discharges associated
with eleven categories of industrial activity. As a result, NPDES permitting authorities, which may be
either EPA or a state environmental agency, issue stormwater permits to control runoff from these
industrial facilities.
What types of industrial facilities are required to obtain permit
coverage?
This fact sheet specifically discusses stormwater discharges from chemical and allied products
manufacturing facilities as described by Standard Industrial Classification (SIC) Major Group 28.
Facilities and products in this group fall under the following categories, all of which require coverage
under an industrial stormwater permit:
♦ Industrial inorganic chemicals (SIC 2812-2819)
♦ Plastics, synthetics, and resins (SIC 2821-2824)
♦ Medicinal chemicals and botanical products; pharmaceutical preparations in virto and in vivo
diagnostic substances; biological products, except diagnostic substances (SIC 2833-2836)
♦ Soaps, detergents, cosmetics, and perfumes (SIC 2841-2844)
♦ Paints, varnishes, lacquers, enamels, and allied products (SIC 2851)
♦ Industrial organic chemicals (SIC 2861-2869)
♦ Agricultural chemicals (SIC 2873-2879)
♦ Miscellaneous chemical products (SIC 2891-2899)
♦ Inks and paints, including china painting enamels, India ink, drawing ink, platinum paints for
burnt wood or leather work, paints for china painting, artist's paints, and artist's watercolors
(SIC 3952)
♦ Petroleum refining (SIC 2911)
What does an industrial stormwater permit require?
Common requirements for coverage under an industrial stormwater permit include development of a
written stormwater pollution prevention plan (SWPPP), implementation of control measures, and sub-
mittal of a request for permit coverage, usually referred to as the Notice of Intent or NOI. The SWPPP
i

/ - r
INDUS"I-RIAI.. STORMWATF..R FACT Si-IEFT SIERIES
Sector C. Chemical and Allied Products Manufacturing and Ruining
is a written assessment of potential sources of pollutants in stormwater runoff and control measures
that will be implemented at your facility'to minimize the discharge of these pollutants in runoff from
the site. These control measures include site -specific best management practices (BMPs), maintenance
plans, inspections, employee training, and reporting. The procedures detailed in the SWPPP must be
implemented by the facility and updated as necessary, with a copy of the SWPPP kept on -site. The in-
dustrial stormwater permit also requires collection of visual, analytical, and/or compliance monitoring
data to determine the effectiveness of implemented BMPs. For more information on EP,As industrial
stormwater permit and links to State stormwater permits, go to www.epa.gov/npdes/stormwater
and click on "Industrial Activity."
What pollutants are associated with my facilities activities?
Pollutants conveyed in stormwater discharges from facilities involved with the manufacturing of
chemical and allied products will vary. There are a number of factors that influence to what extent
industrial activities and significant materials can affect water quality.
♦ Geographic location
♦ Topography
♦ Hydrogeology
♦ Extent of impervious surfaces (e.g., concrete or asphalt)
♦ Type of ground cover (e.g., vegetation, crushed stone, or dirt)
♦ Outdoor activities (e.g., material storage, loading/unloading, vehicle maintenance)
♦ Size of the operation
♦ Type, duration, and intensity of precipitation events
The activities, pollutant sources, and pollutants detailed in Table 1 are commonly found at chemical
and allied products manufacturing facilities.
Table f. Common Activities, Pollutants Sources, and Associated Pollutants at Chemical and Allied
Products Manufacturing and Refining Facilities
",ActivityPollutant
'_
Source ».
Pnlluta.rt.
Material Handling
and Storage
Equipment storage
Pollutant dependant
upon those at particular
facility
Storage of materials in tanks, either below nr above ground
Storage of cylinders Wised to contain industrial gases
Storage of empty or full drums
Material handling and warehousing
Loading/unloading
Bagging of materials/products
Blending and rnixing of chemicals
Packaging of chericals
Crushing, milling, shredding, granulation, and grinding of materials
Distribution of products
Vehicle Fueling and
Maintenance
Vehicle fueling
TSS, TDS, oil and grease,
gasoline, diesel, acid,
coolant
Vehicle maintenance
EPA-833-F-06-018 2

r - L
[�[.ztA><- i�n�vv Srort Ft r��c:T slIEL7 SL}zlrs
>vu..t --E ' EE,�,€iE 1tr# �'� I����
Sector C. Chemical iral anc! Allied Products Manulfactt€ring and Refining n t .ukk,4
Table 1. Common Activities, Pollutants Sources, and Associated Pollutants at Chemical and Allied
Products Manufacturing and Refining Facilities (continued)
Actrvity
Pollutant'Source
Pollutant
Waste Treatment,
Disposal, and
Cleanup
Washing of drums
Pollutant dependant
upon those at particular
facility
Waste rlurnpstcr or c:ornpactor
Hazardous waste temporary storage or operation of RCRA treatment,
storage, or disposal facility
Landfills or temporary refuse site
Wastewater treatment
Manufacturing
Process Components
Thermal oxidation
Pollutant dependant
upon those at particular
facility
Cooling towers
Steam boilers
Hot oil system for cooling/heat exchangeM
Use of machinery to process materials
Miscellaneous
Activities
Plant yard and areas of past industrial activity
Tss
Access roads and rail tracks
What BMPs can be used to minimize contact between stormwater
and potential pollutants at my facility?
A variety of BMP options may be applicable to eliminate or minimize the presence of pollutants
in stormwater discharges from chemical and allied product manufacturing facilities. You will likely
need to implement a combination or suite of BMPs to address stormwater runoff at your facility.
Your first consideration should be for pollution prevention BMPs, which are designed to prevent
or minimize pollutants from entering stormwater runoff and/or reduce the volume of stormwater
requiring management. Prevention BMPs can include regular cleanup, collection and containment of
debris in storage areas, and other housekeeping practices, spill control, and employee training. It may
also be necessary to implement treatment BMPs, which are engineered structures intended to treat
stormwater runoff and/or mitigate the effects of increased stormwater runoff peak rate, volume, and
velocity. Treatment BMPs are generally more expensive to install and maintain and include oil -water
separators, wet ponds, and proprietary filter devices.
BMPs must be selected and implemented to address the following:
Good Housekeeping Practices
Good housekeeping is a practical, cost-effective way to maintain a clean and orderly facility to
prevent potential pollution sources from coming into contact with stormwater. It includes establishing
protocols to reduce the possibility of mishandling materials or equipment and training employees
in good housekeeping techniques. Common areas where good housekeeping practices should be
followed include trash containers and adjacent areas, material storage areas, vehicle and equipment
maintenance areas, and loading docks. Good housekeeping practices must include a schedule for
regular pickup and disposal of garbage and waste materials and routine inspections of drums, tanks,
and containers for leaks and structural conditions. Practices also include containing and covering
garbage, waste materials, and debris. Involving employees in routine monitoring of housekeeping
practices has proven to be an effective means of ensuring the continued implementation of these
measures.
Minimizing Exposure
Where feasible, minimizing exposure of potential pollutant sources to precipitation is an important
control option. Minimizing exposure prevents pollutants, including debris, from coming into contact
FPA-8.33-F-06-018 3

J
INDUSTRIAL S-FORMWNrER FACT SHEET SPRirs
Sector C: Chemical and Allied Products Manufacturing and Refining
with precipitation and can reduce the need for BMPs to treat contaminated stormwater runoff. It can
also prevent debris from being picked up by stormwater and carried into drains and surface waters.
Examples of BMPs for exposure minimization include covering materials or activities with temporary
structures (e.g., tarps) when wet weather is expected or moving materials or activities to existing
or new permanent structures (e.g., buildings, silos, sheds). Even the simple practice of keeping a
dumpster lid closed can be a very effective pollution prevention measure.
Erosion and Sediment Control
BMPs must be selected and implemented to limit erosion on areas of your site that, due to
topography, activities, soils, cover, materials, or other factors are likely to experience erosion. Erosion
control BMPs such as seeding, mulching, and sodding prevent soil from becoming dislodged and
should be considered first. Sediment control BMPs such as silt fences, sediment ponds, and stabilized
entrances trap sediment after it has eroded. Sediment control BMPs should be used to back-up
erosion control BMPs.
Management of Runoff
Your SWPPP must contain a narrative evaluation of the appropriateness of stormwater management
practices that divert, infiltrate, reuse, or otherwise manage stormwater runoff so as to reduce the
discharge of pollutants. Appropriate measures are highly site -specific, but may include, among others,
vegetative swales, collection and reuse of stormwater, inlet controls, snow management, infiltration
devices, and wet retention measures.
A combination of preventive and treatment BMPs will yield the most effective stormwater
management for minimizing the offsite discharge of pollutants via stormwater runoff. Though not
specifically outlined in this fact sheet, BMPs must also address preventive maintenance records or
logbooks, regular facility inspections, spill prevention and response, and employee training.
All BMPs require regular maintenance to function as intended. Some management measures have
simple maintenance requirements, others are quite involved. You must regularly inspect all BMPs to
ensure they are operating properly, including during runoff events. As soon as a problem is found,
action to resolve it should be initiated immediately.
Implement BMPs, such as those listed below in Table 2 for the control of pollutants at chemical and
allied products manufacturing facilities, to minimize and prevent the discharge of pollutants in
stormwater. Identifying weaknesses in current facility practices will aid the permittee in determining
appropriate BMPs that will achieve a reduction in pollutant loadings. BMPs listed in Table 2 are
broadly applicable to chemical and allied product manufacturing facilities; however, this is not
a complete list and you are recommended to consult with regulatory agencies or a stormwater
engineer/consultant to identify appropriate BMPs for your facility.
Table 2. BMPS for Potential Pollutant Sources at Chemical and Allied Products Manufacturing and
Refining Facilities
Pollutant Source
BNtps ..
Material Dandling
❑
Cover handling and storage areas with roofs, covers, or other appropriate forms of protection.
and storage
Cl
Confine storage to designated and labeled areas outside of drainage pathways and away from
surface waters.
«s "i
❑
Divert stormwater around storage areas with vegetated swales, and/or berms.
❑
Store materials on concrete pads to allow for cleanup of spills or leaks.
❑
Provide secondary containment for storage tanks and drum storage.
❑
If containment structures have drains, ensure that the drains have valves, and that valves
are maintained in the closed position. Institute protocols for checking/testing stormwater in
containment areas prior to discharge.
FPA-833-F 06-018

i
[ N D Lf S_.ZIA I"I-O RM WA i R F�aCr S t I t T S t t ES �u F.0 ,�r' y, rv,. ,,=>=..r 1 I _
,v, ;, ,
Sector C. Chemical and Allied Products Manufacturing and Refining
Table 2. BMPS for Potential Pollutant Sources at Chemical and Allied Products Manufacturing and
Refining Facilities (continued)
Pollutant Saurce
'BMPs,
Material handirng ii'
❑
Use double -walled tanks.
and'storage
high
'(c'6666.ied):'
❑
Locate storage areas away f:rarn traffic areas and surface waters.
h
❑
Inspect storage tanks and piping systems (pipes, pumps, flanges, couplings, hoses, and valves)
for failures or leaks and perform preventive maintenance.
,E 13 .
❑
Maintain an inventory of fluids to identify leakage.
j`•i i � E' � 1t,31� � €E
❑
Provide fluid level indicators.
❑
Properly dispose of chemicals that are no longer in use.
❑
Store and handle reactive, ignitable, or ffammable liquids in compliance with applicable local
,{r3f;,"€1 If;,E';fliip3)ra?:,Ef-
fire codes, local zoning codes, and the National Electric Code.
❑
Provide drip pads/pans where chemicals are transferred from one container to another to
all'g''r,r�fi rE'3i",l
allow for recycling of spills and Icaks.
❑
Develop and implement spill plans or spill prevention, containment, and countermeasure
(SPCC) plans, if required for your facility.
4 ,
Portable containers/drums
❑
Develop and implement spill plans or spill prevention, containment, and countermeasure
i1.E.
fI f4rr
(SPCA plans, if required for your facility.
1,16 3P3 i
i is v
Store drurns indoors when possible.
U
Store drurns, including empty or used drums, in secondary containment with a roof or cover
(including temporary cover such as a tarp that prevents contact with ,precipitation).
❑
Provide secc�rulary containment, such as dikes or portable. conlc�'u•iers, with a helgt-rt sufficiEnt
to contain a spill (the greater of 10 percent of the total enclosed tank volume or 110 percent
r1€
fi'r i �i ij34 itg3i f 9 1,`
of the volume contained in the largest tank).
1 E
Ep€
'
❑
Clearly label drum with its contents.
❑
Train employees in spill prevention and control And proper materials manaoerrient.
❑
Empty containment units with manually operated pumps or ejectors.
PIC
©
If facility drainage is not engineered as listed above, equip the final discharge point of all
3
ii 7i r f1r.;.ri i,r i Y. s,.f fit
facility g p sewers to prevent discharge in the event of an uncontrolled spill.
Loading/.unloading , '
❑
Confine loading/unloading activities to designated areas outside drainage pathways and away
areas '. ,,,€j;tt
r
from surface waters.
irliil3,�d iE (E4k la'. � i4�f,t' E I €:r F�k
❑
Inspect containers for leaks or damage prior to loading/unloading.
" Er(s<; I E�i'W
ro'docks.
❑
Avoid loading/unloading materials in they rain or provide cover or other pr'ote(ttion for loading
aria€3 °i �
❑
Provide diversion berms, dikes or grassed swales around the perinleter of the area to
limit run-on.
t
❑
Cover loading and unloading areas and perform these activities on an Impervious pad to
enable easy collection of spilled materials.
❑
Slope the impervious concrete floor or pad to collect spills and leaks and convey therm to
"
proper containment and treatment.
❑
Provide overhangs or door skirts to enclose trailer ends at truck loading/unloading docks.
x r
U
For rail transfer, a drip pan shall be instalted within the rails to collect spillage from the tank.
EPA-833-F 06-018 5

•
INDUSTRIAL. STORMWATER I'AC.T SFIEFT SERIES
Sector C: Chemical and Allied Products Manufacturing and Refining
Fable 2. BMPS for Potential Pollutant Sources at Chemical and Allied Products Manufacturing and
Refining Facilities (continued)
*61lutant Source
BMP5
Loading/unloading
❑
Where liquid or powdered materials are transferred in bulk from truck or rail cars:
,rareas (cQntinued)
Hose connection points at storage containers to be inside containment areas.
Drip pans used in areas which are not in containrnen3 area where spillage may occur'.
❑
Enclose material handling systems.
U
Cover materials entering and leaving areas.
❑
Regularly sweep area to minimize debris on the ground.
❑
Provide dust control if necessary. When controlling dust, sweep and/or apply water or
;i
materials that will not impact surface or ground water.
U
Develop and implement spill prevention, containment, and countermeasure (SPCC) plans,
❑
Train employees in spill prevention, control, cleanup and proper materials management
techniques.
Manufacturing
U
Use curbing, dikes and gutters to contain and collect spills.
Process Components
Keep spill cleanup materials readily available.
❑
Clean up spills and leaks immediately,
❑
Use dry cleanup methods where appropriate, Sweep up absorbents as soon as spilled
substances have been absorbed,
Lj
Develop and implement spill prevention, containment, and countermeasure (SPCC) plans.
❑
Train employees in spill prevention, control, and cleanup,
vehicle maintenance
Good Housekeeping
❑
Eliminate floor drains that are connected to the storm or sanitary sewer; if necessary, install a
sump that is pumped regularly. Collected wastes should be properly treated or disposed of by
a licensed waste hauler.
❑
Use drip pans, drain boards, and drying racks to direct drips back into a fluid holding tank for
reuse.
❑
Drain all parts of fluids prior to disposal. Oil filters can be crushed and recycled.
C]
Promptly transfer used fluids to the proper container; do not leave full drip pans or other open
containers around the shop. Empty and clean drip pans and containers.
❑
Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers in
compliance with RCRA regulations.
LJ
Store batteries and other significant materials inside.
❑
Label and track the recycling of waste material (e.g., used oil, spent solvents, batteries).
❑
Maintain: an organized inventory of materials.
❑
Eliminate or reduce the number and amount of hazardous materials and waste by substituting
nonhazardous or less hazardous materials.
❑
Clean up leaks, drips, and other spills without using large amounts of water, Use absorbents
for dry cleanup whenever possible.
❑
Prohibit the practice of hosing down an area where the practice would result in the discharge
of pollutants to a stormwater system.
LI
Clean without using #iguid cleaners whenever possible.
FPA-833-F-06-078 6

INDUSTRIAI,STORMWATFR TACT.SF-IrFTSrR.lES
Sector C. Chemical and Allied Products Manufacturing and Refining
Table 2. BMPS for Potential Pollutant Sources at Chemical and Allied Products Manufacturing and
Refining Facilities (continued)
Poll utant .S66rt&`" k S,
is�IYEr 51 € , N. i13. ! f R:EE€ €4, t, F r z i i ! I i� r s E r'.i .... b — x 'Elk.x t
...E ..
1. .. .> ..
Vehicle maintenance,,'.
Good
Housekeeping (continued)
ii.,<Ef.EE . _f LlikEr_
(continued)- I
❑
Do all cleaning at a centralized station so the solvents stay in one area.
-..
U
If parts are dipped in liquid, remove there slowly to avoid spills.
❑
Do not pour liquid waste into floor drains, sinks, outdoor storm drain inlets, or other storm
drains or sewer connections.
Minirrrizing
Exposure
Fk�1.1
❑
Perform all cleanfnq operations indoors or under covering when possible. Conduct the
cleaning operations in an area with i concrete floor with no floor drainage other than to
sanitary sewers or treatment facilities.
❑
If operations are uncovered, perform them on concrete pad that is impervious and contained
a r gr
oilr�p,a!, rzl'r 3.11''.I afla� Irp111!
❑
Park vehicles and Nquiprnenl indoors or under a roof whenever passible and maintain proper
control of oil leakstspills.
❑
Check vehicles closely for leaks and use pans to collect fluid when leaks occur.
!
J
Management of Runoff
❑
Use berms, curbs, grassed swales, or other diversion measures to ensure that stormwater
runoff from other park of the facility does not flaw over the maintenance area.
❑
Collect the stormwater runoff from the cleaning area and provide treatment or recycling.
Discharge vehicle wash or rinse water to the sanitary sewer (if allowed by sevverauthority),
,
wastewater treatment, a land application site, or recycle on -site. DO NOT discharge
`s93 �,.! c PEA, 3•i �. i:,
washwater to a storm drain or to surface water.
r ;
tryf
Inspections
and Training
E € ti p �ildi3t3,9 � �i� € Il,flj
I5 r
❑
Inspect the maintenance area regularly to ensure BMPS are implemented and maintained.
(l
Train employees on waste control disposal procedures.
Vehicle anGf:
❑
Conduct fueling operations (including the transfer of fuel from tank trucks) on an impervious
�equipmertf of fing`r3rlr�
or contained pad and under a roof or canopy vvhere possible. Covering Should extend beyond
spill containment pad to prevent rain from entering.
`
f_f'�i) it i �3f fiiii i=
,, E E ,o
❑
when fueling in an uncovered area, conduct fueling operations on a concrete pad (asphalt is
not chemically resistant to the fuels being handled).
Use drip pans where leaks or spills of fuel can occur and where making and breaking hose
„ !
connections.
❑
Use fueling hoses with check valves to prevent hose drainage after filling.
9 E1 3
lEr 'i f i 3 f E =tt�E, € E�E,I s
, f
❑
Keep spill cleanup materials readily available.
❑
Clean a ills and leaks immediate) P spills Y•
❑
Use dry cleanup methods for fuel area rather than hosing down the fuel area. Sweep up
absorbents as soon as spilled substances have been absorbed.
r
❑
Do not "top off" fuel tanks.
p
M
L1
Minimize/eliminate ern -on into fueling areas with diversion dikes, berms, curbing, surface
3 r ; ` +
grading or other equivalent measures.
,
N?
❑
Collect stormwater runoff and provide treatment or recycling.
�'ll3 �r313 1 +�EE { 3'lll i i �,3I �E3 dry 1fr €,'
❑
Provide cubing or posts around fuel pumps to prevent collisions from vehicles.
tPA-833-F-06-018 7

q
1fNDt1STR.1A1. ST0R: MW T'FR FACT SHEET SFRIFS
Sector C. Chemical and Allied Products Manufacturing and Refining
Table 2. BMPS for Potential Pollutant Sources at Chemical and Allied Products Manufacturing and
Refining Facilities (continued)
Pollutant Source
BMPS
Vehicle and
rJ" Regularly inspect and perform preventive rnalntenance on fuel storage tanks to detect
equipment fueling
potential leaks before they occur.
,(continued"
D Inspect the fueling area for leaks and spills.
J Train personnel on vehicle fueling SIVIPs.
What if activities and materials at my facility are not exposed to
precipitation?
The industrial stormwater program requires permit coverage for a number of specified types of
industrial activities. However, when a facility is able to prevent the exposure of ALL relevant activities
and materials to precipitation, it may be eligible to claim no exposure and qualify for a waiver from
permit coverage.
If you are regulated under the industrial permitting program, you must either obtain permit coverage
or submit a no exposure certification form, if available. Check with your permitting authority for
additional information as not every permitting authority program provides no exposure exemptions.
Where do I get more information?
For additional information on the industrial stormwater program see
www.epa.gov/npdes/stormwater/msgp.
A list of names and telephone numbers for each EPA Region or state NPDES permitting authority can
be found at www.epa.gov/npdes/stormwatercontacts.
References
Information contained in this Fact Sheet was compiled from EPA's past and current Multi -Sector
General Permits and from the following sources:
♦ City of Phoenix, Street Transportation Department, Storm Water Management Section. 2004.
Prevent Stormwater Contamination Best Management Practices Section C - Chemical and Allied
Products Manufacturing. SIC Codes 2812-99, 3952.
http://phoenix.gov/STREETS/chemprod.pdf
♦ U.S. EPA. Office of Science and Technology. 1999. Preliminary Data Summary of Urban
Stormwater Best Management Practices. EPA-821-R-99-012
www.epa.goviOST/stormwater/
♦ U.S. EPA, Office of Wastewater Management. NPDES Stormwater Multi -Sector General Permit
for Industrial Activities (MSGP).
www.epa.gov/npdes/stormwater/msgp
EPA-833-F-06-0 7 8

Please print or tvDe in the unshaded areas only.
Form ADDroved. OMB No. 2040-0086.
FORM
U.S. ENVIRONMENTAL PROTECTION AGENCY
1. EPA I.D. NUMBER
1
11180EPA GENERAL INFORMATION
s
riA c
Consolidated Permits Program
F
2789WSPRRS1613W p
GENERAL
{Read the "General Instructions" before starting.)
t
] 13 1/ 16
IABEL ITEMS
GENERA]_ INSTRUCTIONS
- - ..
if a preprinted label has been provided, affix II in the
_ designated space. Review the Information carefully, If any of h
°
L. EPA LD �' - l,+ -�
NUMBER
- l,4 il' 1,
is Incomoct, cross through it and enter the correct data in the
, .. '- ° r•'- - - -
_
1 - appropriate RII-In area below. Also, If any oithe PreprinSed data
. - -
- is absent (the area to Me left of the label space fists the
III, FACILITY NAME PLEASE PLACE LABEL IN THIS SPACE information (hat should appear), please provide it In She proper
fill-in area(s) below. It the label is pomplate and correct, you
V. FACILITY _MAILING ''' -
- .` need not complete Items I, III, V. and VI (except VI-B which
_
ADDRESS - -
must be completed regardless). Complete all items If no labal
• -
- has been provided. Refer to the mstructlons for detailed hem
- .
VI'. FACILITY iOCATION ,f °
descriptions and for the legal authodxations under which this
,
_
data Is collected.
it. POLLUTANT CHARACTERISTICS
INSTRUCTIONS: Complete A through J to determine whether you need to submit any
permit application forms to the EPA. If you answer 'yes' to any questions, you must
submit this form and the supplemental form listed in the parenthesis following the question. Mark "X' in the box In the third column If the supplemental form Is attached. If
you answer "no' to each question, you need not submit any of these forms. You may
answer 'no" if your activity is excluded from permit requirements; see Section C of the
instructions. See also, Section D of the instructions for definitions of bold-faced terms.
Mark
'X'
Mark
W
YES
NO
ATTACHED
res
No
ATTACHED_
SPECIFIC QUESTIONS
SPECIFIC QUESTIONS
A. Is this facility a publicly owned treatment works which
results in a discharge to waters of the U.S.? (FORM 2A)
X
B• Does or will this facility (either existing or proposed)
include a concentrated animal feeding operation or
X
aquatic animal production facility which results in a
+a
+T
is
+r
xo
r+
discharge to waters of the U.S.? (FORM 2B)
C. Is this a facility which currently results in discharges to
waters of the U.S. other than those described In A or B
�/
X
D. Is this a proposed facility (other then those described In A
or B above) which will result in a dischargd to waters of
X
above? (FORM 2C)
a
93
N
the U.S.? (FORM 2D)
25
m
3T
E. Does or will this facility treat, store, or dispose of
F. Do you or WIII you inject at this facility industrial or
hazardous wastes? (FORM 3)
X
municipal effluent below the lowermost stratum
X
containing, wilhin one quarter mile of the well bore,
„
n
n
underground sources of drinking water? (FORM 4)
„
sT
35
G. De you or will you inject at this facility any produced water
H. Do you or will you inject at this facility fluids for special
or other fluids which are brought to the surface in
processes such as mining of sulfur by the Frasch process,
connection with conventional oil or natural gas production,
X
solution mining of minerals, In situ combustion of fossil
X
Inject fluids used for enhanced recovery of oil or natural
fuel, or recovery ofgeothermal energy? (FORM 4)
gas, or Inject fluids for storage of liquid hydrocarbons?
(FORM 4)
I. Is this facility a proposed stationary source which is one
J. Is this facility a proposed stationary source which is
of the 28 Industrial categories listed In the instructions and
X
X
NOT one of the 28 Industrial categories listed In the
X
which will potentially emit 100 tans per year of any air
instructions and which will potentially emit 250 tons per
pollutant regulated under the Clean Air Act and may affect
year of any air pollutant regulated under the Clean Air Act
'^
n
u
or be located in an attainment area? (FORM 5)
and may affect or be located in an attainment area?
-
(FORM 5)
III, NAME OF FACILITY
C
1 SKIP SePRO Research & echno ogy Campus
N. FACILITY CONTACT
A. NAME & TITLE (iasr, first, & title)
B. PHONE (area code & no.) :i x,' •" e '
2
Wl] is, Aquatic.Deye.3opment,ScienL
1 (_5 ) 3 �-7 9 ;
.Ben,
�.
-
V. FACILTY MAILING ADDRESS' '
A. STREET OR P.O. BOX
3 1 0 3 Watson Seed arm Roa
B. CITY OR TOWN
C. STATE D. ZIP CODE
c
4 Whitakers
Is in
C 2 8 1
a n a
Vt. FACILITY LOCATION
A- STREET, ROUTE NO. OR OTHER SPECIFIC IDENTIFIER
c
5 16131 Watson See arm Roa
15 n
•
.5
B. COUNTY NAME
Nash
C. CITY OR TOWN
D. STATE
E. ZIP CODE
I F. COUNTY CODE (ifknoww)
6
W i a e s
C I
2 8 1
/5
�0
�1 �2
•/ 61
51 b
EPA Form 3510-1 (8-90)
70Rid y'WA41402
JUN 2 6 2018
DENR-LAND QUALITY
STOPWAIATCD ❑Cotisirrlr+n

CONTINUED FROM THE FRONT
VII.SIC CODES 4-dfitinordorof odt
A- FIRST B. SECOND
1(rpeclfy
pesticides and Agricultural Chemicals. Not Elsewhere (specify) Tenting Laboratories
2879 .Maas lied 718734
7
C. THIRD D. FOURTH
7
8731 (spec) Commercial physical and Biological Research 7
1
0131 (specify)
6 ,4
Agricultural Production crops
Vltl. OPERATOR INFORMATION
A. NAME
B. is the name listed in Item
VItI-Aalso the ownen
® YES ❑ NO
8
Mle
SePRO Development Company III, LLC
C. STATUS OF OPERATOR (Enter the appim riate Jester into the answer box: if"Ocher,"specify.) D.
PHONE (ana code & no.)
F = FEDERAL M = PUBLIC (other than federal orstate)
S c STATE M=
p
(sPeC1fy)
A
(317) 216 - 8 2 8 0
OTHER (specify)
P =PRIVATE
u
JW
>r
u ro ]I rx 7e
E. STREET OR P,O. BOX
1 5 D J eri ion S reet Suite 66
F. CITY OR TOWN
G. STATE
H. ZIP CODE
IX. INDIAN LAND
Is the facility looted on Indian lands?
Carmel
IS
IN
46032
❑ YES ® NO
u
X. EXISTING ENVIRONMENTAL PERMITS
A NPDES Discha s to Su ace Water
D. PSD Air Emissions m Pro SrdSaurces
1
19P INA
15 A 1T n 90
C T
9 N
General permit NCG560000
15 le
1r n ]0
B. UIC undo round In' .[ion o Fluids
E. OTHER cI
t
9
i
U
t
NpI
c r
9
l
A N S P 2 P-14-023 3
.-ov
e. ederal permit to mpve live noxious
weds by Interstate
le
1e
11
1e �
IS n
I1
n 3e
C. RCRA Hazardous Wosres
E, OTHER s et
c
9
T
R
1
NCA986189074
c T /��� �y
g NCDA&CS O41713001 M. Cfi)carolina Department of Agriculture
permit to ,rove noxiuea weeds
IS
n
17
1 n b
n a Ir is Xr
XI. MAP
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must show the outline of the facility, the
location of each of its ezisdng and proposed intake and discharge structures, each of Its hazardous waste treatment, storage, or disposal facilities, and each wall where it
injects fluids underground. include all springs, rivers, and *that surface water bodies In the map area. See Instructions for precise requirements.
XII. NATURE OF BUSINESS(provide a brlofdescrr tion
The 410 acre SePRO Research and Technology Campus (SRTC) produces soybeans and cotton, laboratory assays,
herbicide and algaecide manufacturing, and scientific studies. The campus grows 201.5 acres of soybeans and
cotton commercially, which is the main land use (50.88%). Laboratory assays support scientific studies,
manufacturing, and critical technical data for the proper use of SePRO aquatic herbicide products (product
stewardship). M nuffaactur�in consists of the production of US EPA and North Carolina registered aquatic use
herbicides and a gaeT odes, and agricultural use herbicides. Research at the SRTC is for the development and
stewardship of specialty environmental products in aquatics (surface waters), turf, ornamental, and agricultural
industries. a"a,,) 6 A*r fi)& dj Pe.3arr� e� prto�w riTw f %ltdwv�Nw - sac -70 rT q
R .)I� })�J 3'53-20 WLA
Tn T t frpvjj
[Ng�cs)
XIII. CERTIFICATION (see instructions)
I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that, based on my
inquiry of those persons immediately responsible for obtaining the information contained in the application, l believe that the information ls'true, accurate, and complete. I
am aware that there are significant penalties for submiffing false information, including the possibility of fine and imprisonment.
A. NAME & OFFICIAL TITLE (rvpe or print)
B. SIGNATURE
C. DATE SIGNED
Dr.Tyler Koschnick, Vice President
14 Tu N 6 2Q!'�
COMMENTS FOR OFFICIAL USE ONLY
c
C
Is le ss
EPA Form 3510.1 (8.90)

EPA ID Number (copy from llem 1 of Form 1) Form Approved, OMB No. 2040.0086
Please Print or type in the unshaded areas only. 2769WSPRRS1613W Approval expires 5-31-92
FORM
2F
NPOES
U.S. Environmental Protection Agency
A Washington, DC 20460
EPA. Application for Permit to Discharge Storm Water
Discharges Associated with Industrial Activity
Paperwork Reduction Act Notice
Public reporting burden for this application Is estimated to average 28.6 hours per application, including time for reviewing Instructions, searching existing data sources,
gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate, any other aspect
of this collection of information, or suggestions for improving this form, Including suggestions which may increase or reduce this burden to: Chief, Information Policy
Branch, PM-223, U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, NW, Washington, DC 20460. or Director, Office of Information and Regulatory
Affairs, Office of Management and Budget, Washington, DC 20503.
I. Outfali Location
For each outfall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
A Outfall Number
(list)
B- Latitude
C. Longitude
D, Receiving Water
(name)
1
36.00
7.00
26.42
77.001
43.00
37.69
Piehing Creek
ll. Improvements
A Are you now required by any Federal. State, or local authority to meet any implementation schedule for the construction, upgrading or operation of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited
to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and grant or loan conditions.
1. Identification of Conditions,
Agreements, Etc.
2. Affected Outfalls
3. Brief Description of Project
4. Final
Compliance Date
number
source of discharge
a. req.
b. proj.
NA
r
B: You may attach additional sheets describing any additional water pollution (or other environmental projects which may affect your discharges) you now have under
way or which you plan, Indicate whether each program Is now under way or planned, and indicate your actual or planned schedules for construction.
III. Site Drainage Map
Attach a site map showing topography (or indicating the outline of drainage areas served by the outfalls(s) covered In the application if a topographic map is unavailable)
depicting the facility including: each of its Intake and discharge structures; the drainage area of each storm water outfall; paved areas and buildings within the drainage
area of each storm water outfall, each known past or present areas used for outdoor storage of disposal of significant materials, each existing structural control measure
to reduce pollutants in storm water runoff, materials loading and access areas, areas where pesticides. herbicides, soil conditioners and fertilizers are applied; each of
its hazardous waste treatment, storage or disposal units (including each area not required to have a RCRA permit which is used for accumulating hazardous waste
under 40 CFR 262.34); each well where fluids from the facility are Injected underground; springs, and other surface water bodies which received storm water discharges
from the facility.
EPA Form 3510-2F (1-92)
Page 1 of 3
Continue on Page 2

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Scale:1:25,209 b 12p = �t $ .Whly��nf ''''' Flow Direction
USGS Map W hitakers; NC `SRTC Pro Bound
my
Location Map o h:
b 125. f ., o x` � • . •
SePRO Corperation
Whitakers NorthCarolina ^� �� Agriculture; Residential, and Industrial
' .' o /30 land use wiNn'map area
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966996 967846 968696 969546 970396 971246 972096
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Continued from the Front
IV. Narrative Description of Pollutant Sources
A. For each moral, provide an estimate of the area (inctude units) of imperious surfaces (Including paved areas and building roofs) drained to the outrall, and an estimate of the total surface area
drained by the oulfail.
Outran
Area or Impervious Surface
Total Area Drained
Outtall
Area of Impervious Surface
Total Area Drained
Number
remyrde urdts)
fpmvkb unit)
Number
(pr)vide units)
(P-A* unffs)
1
1.04 acres
401.6 acres
B. Provide a narrative descripflon of significant materials that are currently or In the past three years have been treated, stored or disposed In a manner to allow exposure
to storm water, method of treatment, storage, or disposal; past and present materials management practices employed to minimize contact by these materials with
storm water runoff; materials loading and access areas, and the location, manner, and frequency in which pesticides, herbicides, soil conditioners, and fertilizers are
applied.
See next page 7
tdn yntrv+ � � . ?� � f a no dui to � �r � �ir►,�. �► nu�r� b
C. For each outtall, provide the location and a description of existing structural and nonstructural control measures to reduce pollutants in stone water runoff; and a
description of the treatment the storm water receives, including the schedule and type of maintenance for control and treatment measures and the ultimate disposal
of any solid or fktid wastes other than by discharge.
Outrall
List Codes from
Number
Treatment
Table 2F-1
1 Copper, sulfate,and surfactants are housed in a roofed manufacturing facility.
1 Above ground diesel tank, used oil tank, ethylene diamine, and ethanol amine have secondary
containment outside.
V. Nonstormwater Discharges
A I car* under penalty of law hat the oudall(s) covered by this application have been tested or evaluated for the presence of nonstormwater discharges, and that all
nonstornw Ater discharged from these outfall(a) are identified in either an accompanying Form 2C or From 2E application for the outrall.
Name and Official Title (type or print)
Signature
date Signed
Or. Tyler Koachnick, Vice President
`) 5'►-r'r-- 20 t`Ir
B. Provide a description of the method used, the date of any testing, and the onslte drainage points that were directly observed during a test.
Uh
o�j dilc e dN;I at s�., � as f."; �O awed cu�c�' adz
MI1 t- Flirts ► a t pp Pj "a
. Significant Leaks or Spills
Provide existing information regarding the history or significant leaks or spills of toxic or hazardous pollutants at the facility in the tast three years, including the
approximate date and location of the spill or leak, and the type and amount of material released.
A
t'
EPA Form 3510-2F (1-92) Page 2 of 3 Continue on Page 3
KId

968216
968716,- - 9692W 969716
970216
Ii
0
n
kn
L96
o ' tic),
�30 {
�ks; EDA and TEA a�tii Outtall l
with secondaryContaitt ent`
H azardocs
atcrials Waste . � � •, , .,�
Accumulation S'te Loading Area -
Oil StotagC" ith --Diesel tank with:
l 3 secondary containment secondary containmerit,-
•� O
130 -
0 355 710 1,420 Feet "
Scale.1:9,120 _
USGS Map Whitalters, NC Legend
Location Map Irripervious Area {3 04 acres)
SePRO Corperation o r
Whitakers,.Notth Carolina ^' Q Property Boundry {401.6,acres)
-10
U16
968716
969216
969716
970216
i
�i
m
w

Continued from Pane 2 1
EPA ID Number (copy from item 1 of Form 1)
1. Discharge Information
A. B, C, & D: See instructions before proceeding. Complete one set of tables for each outfall. Annotate the outfall number in the space provided.
Table VII-A, VII-B, VII-C are included on separate sheets numbers VII-1 and VII-2.
E. Potential discharges not covered by analysis — Is any toxic pollutant listed in table 217-2, 2F-3, or 217-4, a substance or a component of a substance which you
currently use or manufacture as an intermediate or final product or byproduct?
© Yes (list all such pollutants below) ❑ No (go to Section W
', j /y r
Sulfate 11 Q tr&&w� j 1 44 s rMN+"Sr � lid M bs � O-
Surfactants �,/�M!
Ethylene diamine t' Q
fltrt�ffiRV kkr� ?
4
II. Biological Toxicity Testing Data
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water In
relation to your discharge within the last 3 years?
❑ Yes (list all such pollutants below) No (go to Section DQ
? pwR 11V%V4 g4hQA
IX. Contract Analysis Information
Were any of the analyses reported in Item VII performed by a contract laboratory or consulting firm?
Yes (&I the name, address, and telephone number of, and pollutants
❑ No (go to Section?()
analyzedby, each such taborato or firm bek)
A. Name
B. Address
C. Area Code & Phone No.
D. Pollutants Analyzed
Meritech, Inc.
642 Tamco Road, Reidsville, North
336.342.4748
UOD,5 day
Carolina 27320
COD
Total Suspended Solids
TKN
Nitrate/Nitrite, Nitrogen
Nitrogen, total
Copper, total
Phosphorus, total
Oil 8 Grease (HEM)
X. Certification
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in eccordance with a system designed to assure
that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system orthose persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. 1 am aware that
there are significant penalties for submitting false Information, Including the possibility of fine and Imprisonment for knowing violations.
A. Name & Official Title (Type Or Prfno
B. Area Code and Phone No.
Dr. Tyler Koschnick, Vice President
[phone]
C. Signature ��
D. Date Signed
rc� su.�c zo Ig
EPA Form 3510-2F (1.92) Page 3 of 3

CtDVB.
Pesticides and fertilizers are applied to the row crop fields for production of cotton and
soybeans as needed. Some gravel lots, gravel roads, fence lines, building perimeters,
and drainage canals are treated with US EPA and North Carolina approved herbicides
applied according to the label at a frequency ofIapproximately once or twice per year
depending on the regrowth and label instrdctio6. Similarly, herbicides are applied to
�11 small portions of the irrigation reservoir approximately twice per year using a spot
`S � treatment foliar manner to control nuisance plants. Algaecides are applied to the
J r �`S l ` - irrigation reservoir approximately two to four times per year depending on degree of
infestation and regrowth, treating a fraction of the water body at a time. Herbicide
treatments are applied to the research ponds approximately four times per year. Foliar
broadcast herbicide treatments are applied to the research pond banks approximately
once a year. Herbicides or algaecides under development are applied infrequently to
research ponds. These aquatic applications are conducted in accordance with FIFRA.
Turf research plots are managed with up to four applications per year with herbicides
and fertilizer by broadcast, and treated with fungicides up to seven times per year.
Ornamental research plots are treated approximately once per year with pre -emergent
herbicide and as needed with spot post emergent herbicide.
On September 27, 2017, DEQ issued Findings and Decision and Assessment of Civil
Penalties (the "Civil Penalty Assessment") to SePRO. In the Civil Penalty Assessment,
DEQ alleged that SePRO violated NCGS 143-215(a)(2) by the construction and operation
1 of a sewer.system, treatment works; or disposal system within the State without a
�1 permit and assessed a penalty. Specifically, among other things, DEQ alleged that
SePRO unlawfully disposed of laboratory waste containing pesticides, copper and
1 solvents to the holding ponds. In response, SePRO took corrective action. Waters from
these holding ponds were discharged to the City of Rocky Mount in accordance with a
Pump and Haul Authorization, and sediment and water from these holding ponds were
stabilized and transported by Republic Waste and landfilled in Aulander, North Carolina.
On October 30, 2017, SePRO filed a Petition for Contested Case Hearing (17 EHR 07350)
with the North Carolina Office of Administrative Hearings disputing several findings of
fact contained in the Civil Penalty Assessment.
On April 16, 2018, SePRO and DEQ executed a settlement agreement (without making
any admissions of liability or violations) resolving all alleged violations. )
LJ Hour ; AW v, 4- aX u" ' V #w Su? jy,� IV ftJ! "

EPA Ill Number (copy from Item f or Form 1) Form Approved. OMB No. 2040-0080
2789WSPRRS1613W I Aooroval exoiras 5-31-92
VII. Discharge Information (Continued from page 3 of Form 2F)
Part A — You must provide the results of at least one analysis for every pollutant in this table. Com late, one table for each outrall. See Instructions for additional details.
Pollutant
and
CAS Number
(Havailable)
Maximum Values
(include units)
Average Values
include units
Number
of
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flaw -Weighted
Composite
011andGrease r '
'�sTg/L
NIA
1.00
Outfall #1
Etiological Oxygen,
Demand'(BODS
5.3mg/L
6.lmg/L 9. 91be
1.00
Dutfall #1
Dema_Fhemnd(CODal en
Demand (COD)
56mg/L
106mg/L 171.91be
1.00
outfall #1
ole) Solids
S(TSSS
24.Omg/L
26.6mg/L 38.91be
1.00
Outfall #1
Total Nitrogen
2.6mg/L
2.02mg/L 4.22bs
2.00
outfall #1
Total Phosphorus
0.134mg/L
0.135mg/LO.2191ba
1.0o
outfall #1
pH
Minimum 6.54
Maximum 6.7g
Minimum
Maximum
Part B— List each pollutant that is limited in an effluent guideline which the facility is subject to or any pollutant listed in the facility's NPDES permit for Its process
wastewater (If the facility is operating under an existing NPDES permit). Complete one table for each outfall. See the Instnuctions for additional details and
requi
Pollutant
and
CAS Number
(i1 availab)e)
Maximum Values
(Include units)
Average Values
include units
Number
of
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
EPA Form 3510.2F (1-92) Page VII.1 Continue on Reverse

EPA ID Number (copy hom Item f of Form f) Form Approved. OMB No. 2040-0086
2769WSPRRS1613W I Approval expires 5.31-92
1/II. Discharge information (Candnued from page 3 of Form 2F9
Part A — You must provide the results of at least one analysis forevery pollutant in this table. Complete one table for each outfall. See instructions for additional datalls.
Pollutant
and
CAS Number
ffevallable)
Maximum Values
include unds)
Average Values
(include units
Number
a1
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
oil and Grease
c 5 mg/L
N/A
1.00
Reservoir
Biological oxygen
Demand BO05)
9.8 mg/L
1.00
Reservoir or Au"I,�
Chemical Oxygen
Demand (GOD)
108 mg/L
2.00
Reservoir
Total )
Suspended (TSS
Solids (rss
12 mg/L
1.00
Reservoir
Total Nitrogen
1.6 mg/L
1.00
Reservoir
Total phosphorus
o.109 mg/L
1.00
Reservoir
ptt
Minimum 8.70
Maximum B.70
Minimum
I Maximum
1.00
Reservoir
Part B — List each pollutant that is limited in an effluent guideline which the facility is subject to or any pollutant listed in the faidlity's NPDES permit for its process
wastewater (if the facility is operating under an existing NPDES permit). Complete one table for each outfall. See the Instructions for additional details and
requirements.
Pollutant
and
CAS Number
(Navallable)
Maximum Values
(include units)
Average Values
(include units
Number
o1
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Fknv-Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
i
;
EPA Form 3510-2F (1-92) Page VII-1 Continue on Reverse

Continued from the Front
Part C - List each pollutant shown in Table 2F-2, 2F-3, and 2154 that you know or have reason to believe is present. See the Instructions for odd lional details and
requirements. Complete one table for each outiall.
Maximum Values
Average Values
(include units)
(include units)
Number
Pollutant
of
Grab Sample
Grab Sample
and
Taken During
Taken During
Storm
CAS Number
First 20
Flow -Weighted
First 20
Flow -Weighted
Events
(ifovallable)
Minutes
Composite
Minutes
Composite
Sampled
Sources of Pollutants
Total, Cu
3 ug/L
9ug/L 0.01461bs
1.00
Outfall #I
Total, Cu
17 ug/l,
lug/L 0.01141bill
12,00
lReservoir
Part D — Provide data for the storm event(s) which resulted In the maximum values far the flow weighted composite sample
4.
S.
1.
2.
3.
Number of hours between
Maximum flow rate during
6.
Date of
Duration
Total rainfall
beginning of storm measured
- rain event
Total flow from
Storm
of Storm Event
during storm event
and and of previous
(gallons/minute or
rain event
Event
(in minutes)
(in Inches)
measurable rain event
specify units)
(gallons or specify units)
5/16/18
195
1.9
120 hours
4.2 CFS
280B4 cubic feet:
7. Provide a description of the method of flow measurement or estimate.
Flow was assessed by multipling the canal velocity (measured using a MFP51 Stream Flowmeter) by the canal cross sectional
area (depth measured by portable sonar device). A water staff was placed where the cross sectional area was measured to
adjust for changes in water height.
EPA Form 3510-2F (1-92) Page VII-2

SePRO CORPORATION
r� BUSEY BANK
} 11554 N. MERIDIAN ST.
S�� v SUITE 600'
CARMEL, INDIANA 46032.4666
PHONE: [phone]/0711 {
E
PAY "Pay eight hundred sixty dollars and 001100" ,
i
06/21 /2018 $860.00
NC Division of Energy, Mineral, and Land Resources DATE AMOUNT !
TO THE Attn: Laura Alexander
ORDER 1612 Mail Service Center
OF Rale h, NC 27699 0ShieW
i , 4 AUTHORI= SIGNATURE

Please print or type in the unshaded areas only.
Form Approved. OMB No. 2040.0086.
FORM
U.S. ENVIRONMENTAL PROTECTION AGENCY
I. EPA L0. NUMBER
-.EPA GENERAL INFORMATION
S
TrA
F
Consolidated Permits Progmm
2789WSPRRS1613W p
GENERAL
(Read the "General Instructions" beforr starting.)
1
12
LABEL ITEMS
_
•+ { I is
GENERAL INSTRUCTIONS
If a preprinted label has been provided, affix It in the
designated space. Re+Aew the Information carefully; If any of it
I h EPA`I:D NUMBER
Is Incorrect, cross through it and enter the correct data in the
'•i PLEASE PLACE LABEON THIS SPACE ;
appropriate fill -In area below. Aso, If any of the preprinted data
Is absent (the area to the lell of the labor space Acts the
ln4brmaGbn that should appear), please provide h in the proper
III FACILITY -NAME
''
-• - I _ _
-.l r -
i j„ �,,
fill -In areas} below. If the label is complete and correct, you
need not complete hems t, III, V. and VI (except 0-0 whip]
must be cornoeled regardless), Complete all items if no label
,V. iFACILITY-MAILING
ADDRESS
` ;
� If { ;-
ll {,I?;+j „
has been provided. Rater to the instructions for detailed hem
descriptions and for the legal authorizations under which this
data is collected.
..
VI' FACILITY LOCATION h"'
11. POLLUTANT CHARACTERISTICS
INSTRUCTIONS: Complete A through J to determine whether you need to submit any permit application forms to the EPA. If you answer ryes' to any questions, you must
submit this form and the supplemental form listed in the parenthesis following the question. Mark "X' in the box in the third column if the supplemental form is attached. If
you answer'no" to each question, you need not submit any of these forms. You may answer "no" if your activity is excluded from permit requirements; see Section C of the
instructions. See also, Section D of the instructions for definitions of bold-faced terms.
Mark
"x'
Mark
res
No
ATTAC9ACNEn
rEs
No
FORM
ATfACHACHEO
SPECIFIC QUESTIONS
SPECIFIC QUESTIONS
A Is this facility a publicly owned treatment works which
results in a discharge to waters of the U.S.? (FORM 2A)
X
B, Does or will this facility (either existing or proposed)
include a concentrated animal feeding operation or
X
aquatic animal production facility which results in a
+9
]9
2+
discharge to waters of the U.S.? (FORM 2B)
C. Is this a faciiity which currently results in discharges to
X
D, Is this a proposed facility (other than those described in A
waters of the U.S. other than those described in A or B
or 8 above) which will result in a discharge to waters of
above? (FORM 2C)
n
the U.S.? (FORM 2D)
z5
z5
n
E. Does or wA this facility treat, store, or dispose of
F. Do you or will you inject at this faclllty industrial or
hazardous wastes? (FORM 3)
X
municipal effluent below the lowermost stratum
X
containing, within one quarter mile of the well bore,
2e
s
n
underground sources of drinking water? (FORM 4)
]I
32
M
G. Do you or will you inject at this facility any produced water
H. Do you or will you Inject at this facility fluids for special
or other fluids which are brought to the surface in
connection with conventiorlat oil or natural gas production,
X
processes such as mining of sulfur by the Fraseh process,
solution mining of minerals, in situ combustion of fossil
X
inject fluids used for enhanced recovery of all or natural
fuel, or recovery of geothermal energy? (FORM 4)
gas, or inject fluids for storage of liquid hydrocarbons?
(FORM 4)
N
35
]8
37
38
39
I, Is this facility a proposed stationary source which is one
J. Is this facility a proposed stationary source which is
of the 28 Industrial categories listed in the instructions and
�/
X
NOT one of the 28 industrial categories listed In the
X
which will potentially emit 100 tons per year of any air
instructions and which will potentially emit 250 tons per
pollutant regulated under the Clean Air Act and may affect
year of any air pollutant regulated under the Clean Air Act
0
41
u
43
«
45
or be located In an attainment area? (FORM 5)
and may affect or be located In an attainment area?
(FORM 5)
Ill. NAME OF FACILITY
c
1 sklP SePRO Research & Techno ogy Campus{,,• `-�,, `
15
18 . 29
30 e]
IV. FACILITY CONTACT
A. NAME 8 TITLE (last, first, & title) B. PHONE (area code & no.)
c
2
Wit is, Ben, Aquatic Development Scientist ( 5 ) 3 1-7 9j{,i,r.,,<<r; tl
15
18 -! 48 `4-9 51 W. ]3
V.FACILTY MAILING ADDRESS
A. STREET OR P.O. BOX
3 16131 Watson Seed axis Roa
15 18 a4 i31 { I.,II
B. CITY OR TOWN C. STATE D. ZIP CODE n
4 whitakers C 11 24841
VI. FACILITY LOCATION
A STREET, ROUTE NO. OR OTHER SPECIFIC IDENTIFIER
5 1 0 3 Watson See arm Roa j'' . l: ,'. i•
15 18. l5 t, 'rle1.> I
B. COUNTY NAME
-
Nash
b 19
C. CITY OR TOWN
D. STATE
I E. ZIP CODE
F. COUNTY CODE (ifknown)
c
5
W i a e s 1
4C I
1248J3.
f8 11
4, 47
41 51
57 3-
EPA Foam 3510-1 (8-90)
y to-�'�3 a� _r1?. ? 3570
&G MIUNE SE
JUN 26 2018
DENR-LAND QUALITY
S70RMWATER PERMITTING

t
CONTINUED FROM THE FRONT
VI I. SIC CODES 4-di it, in order of ' rit
A FIRST
B.SECOND
1'eetieides and Agricultural Chemicals, Not Rlsewhere
(specify)
Testing Laboratories
7
jspecify
2879class
16
Eied
7 6734
%
C. THIRD
D. FOURTH
(specify) commercial Physical and Biological Research
(specify)
Agricultural Production Crops
7
15 1M15
8731
19
7 0131
Vill. OPERATOR INFORMATION
A, NAME B. Is the name listed In Item
g SePRO Development Company III, LLC 0 YESS0 NOwneri
1,
C. STATUS OF OPERATOR (Enter the appropriate fetter into the anslwr box: if "Other," specify.)
D. PHONE (area code & no.)
F = FEDERAL M m PUBLIC (other than federal arstate)
S=STATE
W-P
(slxctfy)
[phone]
O= OTHER (specifv)
P = PRIVATE
is 16 u w 71 u m
E. STREET OR P.O. BOX
1 5 0 eri ion S rest Suite 600
F. CITY OR TOWN
G. STATE
H. ZIP CODE
X. INDIAN LAND
Is the facility located on Indian lands?
B
Carmel
IN
46032
13 YES ® NO
5]
1
18
e0 eM1 l2
{1 51
X. EXISTING ENVIRONMENTAL PERMITS
A NPDES Discha es to Su ace t3'It-
D. PSD Air Emissions rrun Peal sed Sources
c T i
g P NA
c
s
T
N
l
General permit NCGS60000
B. UIC Unde mundfn'ectiona Fluids
E, OTHER c ci
c
9
T
U
l
NA
c
s
T
i
A H S P 2 P-14-023 3
s aecifV
s. aderal permit to move live noxious
reads by Interstate
is
C. RCRA Nazardnns Wasles
E. OTHER .1 eci y
e
T�
c e l fi
`ort8 )cnrolina
9
R
NCD986169074
g NCDA&CS O41713001 Department of Agriculture
permit to move nmduos weeds
Is
la li
la M is % lr % 30
XI. MAP
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must show the outline of the facility, the
location of each of its existing and proposed intake and discharge structures, each of its hazardous waste treatment, storage, or disposal facilities, and each well where it
injects fluids underground. Include all springs, rivers, and other surface water bodies in the map area. See instructions for precise requirements.
XII. NATURE OF BUSINESS ovide a brief description)
The 410 acre ScFRO Research and Technology Campus (SRTC) produces soybeans and cotton, laboratory assays,
herbice and algaecide manufacturing, and scientific studies. The campus grows 201.5 acres of soybeans and
id
cotton commercially, which is the main land use (50.88k). Laboratory assays support scientific studies,
manufacturing, and critical technical data for the proper use of SePRO aquatic herbicide products (product
stewardship). Manufacturing consists of the production of US EPA and North Carolina registered aquatic use
herbicides and algaecides, and agricultural use herbicides. Research at the SRTC is for the development and
stewardship of specialty environmental products in aquatics (surface waters), turf, ornamental, and agricultural
industries.
XIII. CERTIFICATION (see instructions)
l certify under penalty of law that 7 have personaNy examined and am familiar with the information submitted in this application and all atfachmonts and that, based on my
inquiry of those persons immediately responsible for obtaining the information contained in the application, I believe that the information is true, accurate, and complete. f
am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment.
A NAME & OFFICIAL TITLE (type urprim)
B. SIGNATURE
C. DATE SIGNED
Dr.Tyler Koschnick, Vice President
COMMENTS FOR OFFICIAL USE ONLY
c
C
EPA Form 3510-1(8-90)

EPA ID Number (copy from Item f of Form 1) Form Approved. OMB No. 2040-0086
Please print or type In the unshaded areas only. 2 7B9WSPRRS1613W Approval expires 5-31.92
FORM
ZF
Nli
U.S. Environmental Protection Agency
o E PA Washington, DC 20460
Application for Permit to Discharge Storm Water
Discharges Associated with Industrial Activity
Paperwork Reduction Act Notice
Public reporting burden for this application is estimated to average 28.6 hours per application, including time for reviewing instructions, searching existing data sources.
gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate, any other aspect
of this collection of Information, or suggestions for Improving this form, including suggestions which may increase or reduce this burden to: Chief, Information Policy
Branch, PM-223, U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, NW, Washington, DC 20460, or Director, Office of Information and Regulatory
Affairs, Office of Management and Budget, Washington, DC 20503.
I. Outfall Location
For each outfall, list the latitude and longitude of Its location to the nearest 15 seconds and the name of the receiving water.
A- Outfall Number
(list)
B, Latitude
C. Longitude
D. Receiving Water
(name)
1
345,001
7.00
26.42
77.00
43.00
37.69
Fishing Creek
11. improvements
A- Are you now required by any Federal, State, or local authority to meet any implementation schedule for the construction, upgrading or operation of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited
to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and grant or loan conditions.
1. Identification of Conditions,
Agreements, Etc.
2. Affected Outfalls
3. Brief Description of Project
4, Final
Compliance Date
number
source of discharge
a. req.
b. proj.
NA
8: You may attach additional sheets describing any additional wafer pollution (or other environmental projects which may affect your discharges) you now have under
way or which you plan, Indicate whether each program is now under way or planned, and indicate your actual or planned schedules for construction.
III. Site Drainage Map
Attach a site map showing topography (or indicating the outline of drainage areas served by the outfalis(s) covered in the application if a topographic map is unavailable)
depicting the facility including; each of its intake and discharge structures; the drainage area of each storm water outfall; paved areas and buildings within the drainage
area of each storm water outfall, each known past or present areas used for outdoor storage of disposal of significant materials, each existing structural control measure
to reduce pollutants in storm water runoff, materiels loading and access areas, areas where pesticides, herbicides, soil conditioners and fertilizers are applied; each of
its hazardous waste treatment, storage or disposal units (including each area not required to have a RCRA permit which is used for accumulating hazardous waste
under 40 CFR 21 each well where fluids from the facility are injected underground; springs, and other surface water bodies which received storm water discharges
from the facility.
EPA Form 3510.21" (1-92) Page 1 of 3 Continue on Page 2

Continued from the Front
IV. Narrative Description of Pollutant Sources
A For each ousall, provide an estimate of the was (include units) of Imperious surfaces (hdudmg paved areas and building roofs) drained to the ounall, and an estimate of the total surface was
drained by the outfain.
Outfall
Area of Impervious Surface
Total Area Drained
Dum
Area of Impervious Surface
Total Area Drained
Number
(provide units)
(provide unNs)
Number
(pmvlda units)
(provide units}
1
3.04 acres
401.6 acres
B. Provide a narrative description of significant materials that are currently or in the past three years have been treated, stored or disposed In a manner to allow exposure
to storm water; method of treatment, storage, or disposal; past and present materials management practices employed to minimize contact by these materials with
storm water runoff; materials loading and access areas, and the location, manner, and frequency in which pesticides, herbicides, soil conditioners, and fertilizers; are
applied.
See next page
C. For each outfatl, provide the location and a description of existing structural and nonstructural control measures to reduce pollutants in storm water runoff; and a
description of the treatment the storm water receives, including the schedule and type of maintenance for control and treatment measures and the ultimate disposal
of any solid or fluid wastes other than by discharge.
Outfall
List Codes from
Number
Treatment
Table 2F-1
1 Copper, sulfate,and surfactants are housed in a roofed manufacturing facility.
1 Above ground diesel tank, used oil tank, ethylene diamine, and ethanol amine have secondary
containment outside.
V. Nonstormwater Discharges
A. I certify under penalty of law hat the outfall(s) covered by this application have been tested or evaluated for the presence of nonstormwater discharges, and that all
nonstormwater discharged from those outfall{s) are identified in either an accompanying Form 2C or From 2E application for the outfall.
Name and Official Title (type or print)
Signature
Date Signed
Dr. Tyler Aoschnick, Vice President
B. Provide a description of the method used, the date of any testing, and the onslte drainage points that were directly observed during a test.
NA
Significant leaks or Spills
Provide existing information regarding the history of significant leaks or spills of toxic or hazardous pollutants at the facility in the last three years, including the
approximate data and location of the split or leak, and the type and amount of material released.
UA
EPA Form 3510-2F (1-92) Page 2 of 3 Continue on Page 3

968216-- ..--968716 — 969216, 969716-970216
F4
0
00
in
tn
n
Ln
M
/-?0 '
1rDA and TEA tanks ��, _ Outfall 1
1€f!r
= with secondary# onta'nment
Hazardous Wast-- IMat erials ?
Accumu ation Site Loading` a
Oil Storag�ewith (Diesel tans with �15
d%y secondary containment secondary containment?
ii+
Ln
of
00
en
M
Fi
96'
i216
968716
969216
969716
970216

Continued from Page 2 1
EPA ID Number (copy from Item i of Form 1)
1. Discharge Information
A, B, C, & D: See Instructions before proceeding. Complete one set of tables for each outfall. Annotate the outfall number in the space provided.
Table VII-A, VII-B, VII-C are Included on separate sheets numbers MI-1 and VII-2.
E. Potential discharges not covered by analysis — is any toxic pollutant fisted in table 2F-2, 217-3, or 2F4, a substance or a component of a substance which you
currently use or manufacture as an Intermediate or final product or byproduct?
© Yes (list all such pollutants below) ❑ No (go to Section N
sulfate
Surfactants
Ethylene diamine
ll. Biological Toxicity Testing Data
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water In
relation to your discharge within the last 3 years?
❑ Yes (list all such pollutants below) ✓❑ No (go to Section N
IX. Contract Analysis Information
Were any of the analyses reported in Item VI performed by a contract laboratory or consulting firm?
© Yes (list the name, address, and telephone number of, and pollutants
❑ No (go to Section X)
analyzed by, each such boratory or firm below)
A. Name
B. Address
C. Area Code & Phone No.
D. Pollutants Analyzed
Meritech, Inc.
642 Tamco Road, Reidsville, North
336.342.4746
ROD day
Carolina 27320
COD
Total Suspended Solids '
TKN
Nitrate/Nitrite, Nitrogen
Nitrogen, total
Copper, total
Phosphorus, total ,
Oil & Grease (HEM)
X. Certification
I ceKNy under penally of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure
that qualifled personnel property gather and evaluate the Information submitted. Based on my inquiry of the person orpersons who manage the system or those persons
directly responsible for gathering the Information, the Information submitted Is, to the best of my knowledge and belief, true, accurate, and complete. 1 am aware that
there are significant penalties for submitting false Information, Including the possibility of rrne and Imprisonment for knowing violations.
A. Name & Official Titte (Type Or Print)
S. Area Code and Phone No.
Dr. Tyler Koschnick, Vice President
[phone]
C. Signature
D. Date Signed
EPA Form 3510-2F (1-02) Page 3 of 3

Item IV B.
Pesticides and fertilizers are applied to the row crop fields for production of cotton and
soybeans as needed. Some gravel lots, gravel roads, fence lines, building perimeters,
and drainage canals are treated with US EPA and North Carolina approved herbicides
applied according to the label at a frequency of approximately once or twice per year
depending on the regrowth and label instructions. Similarly, herbicides are applied to
small portions of the irrigation reservoir approximately twice per year using a spot
treatment foliar manner to control nuisance plants. Algaecides are applied to the
irrigation reservoir approximately two to four times per year depending on degree of
infestation and regrowth, treating a fraction of the water body at a time. Herbicide
treatments are applied to the research ponds approximately four times per year. Foliar
broadcast herbicide treatments are applied to the research pond banks approximately
once a year. Herbicides or algaecides under development are applied infrequently to
research ponds. These aquatic applications are conducted in accordance with FIFRA.
Turf research plots are managed with up to four applications per year with herbicides
and fertilizer by broadcast, and treated with fungicides up to seven times per year.
Ornamental research piots are treated approximately once per year with pre -emergent
herbicide and as needed with spot post emergent herbicide.
On September 27, 2017, DEQ issued Findings and Decision and Assessment of Civil
Penalties (the "Civil Penalty Assessment") to SePRO. In the Civil Penalty Assessment,
DEQ alleged that SePRO violated NCGS 143-215(a)(2) by the construction and operation
of a sewer system, treatment works, or disposal system within the State without a
permit and assessed a penalty. Specifically, among other things, DEQ alleged that
SePRO unlawfully disposed of laboratory waste containing pesticides, copper and
solvents to the holding ponds. In response, SePRO took corrective action. Waters from
these holding ponds were discharged to the City of Rocky Mount in accordance with a
Pump and Haul Authorization, and sediment and water from these holding ponds were
stabilized and transported by Republic Waste and landfilled in Aulander, North Carolina.
On October 30, 2017, SePRO filed a Petition for Contested Case Hearing (17 EHR 07350)
with the North Carolina Office of Administrative Hearings disputing several findings of
fact contained in the Civil Penalty Assessment.
On April 16, 2018, SePRO and DEQ executed a settlement agreement (without making
any admissions of liability or violations) resolving all alleged violations.

EPA ID Number (copy from Item f ofForm f) Form Approved. OMB No. 2040-0086
2789wsPRRS1613w I Approval expires 5-31-92
V11. Discharge Information (Continued from page 3 of Form 2F9
Part A— You must provide the resutts of at least one analysis for every pollutant in this table. Complete one table for each outfall See instructions for additional details.
Pollutant
and
CAS Number
(if available)
Maximum Values
(include units)
Average Values
(include units)
Number
of
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Oil and Grease
a5mg/L
NIA
1.00
Outfall #1
bemand BgD5
D2ma cal d(BO 5)
5 3m9/L
6.lmg/L 9.91be
1.00
Outfall #1
Chemical Oxygen
Demand COD
56mg/L
106mg/L 171.91be
1.00
Outfall 11
Total Suspended
Solids SS
24 Omg/L
26.6mg/L 30,91bo
1.00
Outfall #1
Total Nitrogen
2.6mg/L
2.02mg/L 4.21be
I.Co
Outfall #1
Total Phosphorus
0.134mg/L
0,135mg/LD.2191ba
1,00
Outfall #1
pN
Minimum 6,54
Maximum 6.79
1 Minimum
IMaXIMUM
Part B — list each pollutant that is limited In an effluent guideline which the facility Is subject to or any pollutant listed in the facility's NPDES permit for Its process
wastewater (if the facility is operating under an existing NPDES permit). Complete one table for each outfall. See the instructions for additional details and
requirements.
Pollutant
and
CAS Number
(if available)
Maximum Values
(include units)
Average Values
(include units)
Number
of
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
EPA Form 3510-21F (1.92) Page VII-1 Continue on Reverse

EPA ID Number (copy from Item 1 ofAomr 1) Form Approved. OMB No. 2040-0086
2789WSPRRS1613W I Approval expires 5-31-92
VII. Discharge information (Continued from page 3 of Form 219
Part A —You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.
Pollutant
and
CAS Number
(if available)
Maximum Values
(includo units)
Average Values
(include units)
Number
of
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Fkrw-Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flow Welghted
Composite
Oil and Grease
a 5 mg/L
N/A
1.00
Reservoir
Biological Oxygen
Demand (BODS)
9 • B mg/L
1.00
Reservoir
Chemical Oxygen
Demand (COD)
108 mg/L
1.00
Reservoir
Total Suspended
Solids (fSS)
12 mg/L
1,00
Reservoir
Total Nitrogen
1.8 mg/L
1.00
Reservoir
Total Phosphorus
0.109 mg/L
1.00
Reservoir
pH
Minimum e.7c
Maximum 0.70
Minimum
IMiArnum
11.00
lReservoir
Part B — List each pollutant that is limited in an effluent guldellne which the facility is subject to or any pollutant listed in the facility's NPDES permit for Its process
wastewater (if the facility is operating under an existing NPDES permit). Complete one table for each outfall. See the instructions for additional details and
requirements.
Pollutant
and
CAS Number
(1f available)
Maximum Values
(include units)
Average Values
(include units)
Number
of
Storm
Events
Sampled
Sources or Pollutants
Grab Sample
Taken During
First 20
Minutes
Flov Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
EPA Form 3510-2F (1-92) Page VI 1-1 Continue on Reverse

Continued from the Front
Part C - List each pollutant shown in Table 2F-2, 2F-3, and 2F-4 that you know or have reason to believe is present. See the instructions for additional details and
requirements. Complete one table for each outfall.
Maximum Values I Average Values
(include units)
(include units)
Number
Pollutant
Grab Sample
Grab Sample
of
and
Taken During
Taken During
Storm
CAS Number
First 20
Flow -Weighted
First 20
Flow -Weighted
Events
(ifavallobfe)
Minutes
Composite
Minutes
Composite
Sampled
Sources of Pollutants
Total, Cu
3 ug/L
9ug/L 0.0146lbs
1100
Cutfall ill
Total, Cu
7 ug/L
7ug/L 0.01141ba
1.00
Reservoir
Part D — Provide data for the storm event(s) which resulted in the maximum values for the flow weighted composite sample
4.
5,
1.
2.
3.
Number of hours between
Maximum flow rate during
6.
Date of
Duration
Total rainfall
beginning of storm measured
rain event
Total flow from
Storrs
of Storm Event
during storm event
and end of previous
(gaffons/minute or
rain event
Event
(in minutes)
(in Inches)
measurable rain event
specify units)
(gallons or specify units)
5116118
1295
1.9
120 hours
4.2 US
28080 cubic feet
7. Provide a description of the method of flow measurement or estimate.
Flow was assessed by multipling the canal velocity (measured using a MFP51 Stream Flowmeter) by the canal cross sectional
area (depth measured by portable sonar device). A water staff was placed where the cross sectional area was measured to
adjust for changes in water height.
EPA Form 3510-2F (1.92) Page VII.2

1 SePRO CORPORATION r b `� a b
BUSEY BANK
SOOPRO 11550,N. MERIDIAN 5T.
surrE soD
CARMEL, INDIANA 460324666 70-58ID711 q '
PHONE: [phone]
PAY **Pay eight hundred sixty dollars and 001100**
r ` 06/21/2018 $860.00 m jI
i d
NC Division of Energy, Mineral, and Land Resources DATE AMOUNT y
TO THE Attn: Laura Alexander
ORDER 1612 Mail Service CenterZO
OF - RaleJoh�,, NC 27699 ®q ,I t- •, }.
AUTHORIZEO81GNATURE,+
°n°

Wafer Resources
ENVIRONMENTAL OUALOY
April 26, 2016
Certified Mail # 7014 3490 000188213010
Return Receipt Requested:
Bill Whitford
Director of Manufacturing & Logistics
SePRO Research & Technology Campus
16013 Watson Seed Farm Road
Whitakers, NC 27991-9114
Dear Mr. Whitford:
+s r
PAT MCCRORY
f i,urnw
R. VAN DER VAART
16'lYllory•
S. !AY ZIMMERMAN
1jpWL1.r
Notice of Violation and Notice of Intent to Enforce
Case No.: NOV-2015-DV-0265
Illegal Discharge/Operating a Treatment unit without a Permit
16013 Watson Seed Farm Road
Nash County
The Division of Water Resources (DWR) investigated an anonymous, possible RCRA
complaint, made to the EPA in 2015. The site inspections and data collected by DWR staff in
October 2015 and January 2016, as well as documents provided by SePRO revealed the
following:
Wastewater from the formulation and analytical laboratories are captured in external holding
tanks [one above -ground storage tank (AST) and one underground storage tank (UST)] that are
pumped out on site when they approach capacity. Specifically, rinsate water, bleached water
used to clean herbicide application equipment, rinsate and/or bleached water used to clean
equipment used to apply and mix experimental products, and some charcoal -filtered wastewater
are captured in holding tanks. This water is given several days for the chlorine to degas in the
AST or UST before the wastewater is delivered to Ponds D1 and D2. The intended design and
the function of the 5 "D" ponds is for storage and to allow pesticide degradation. The
polyethylene -lined holding ponds (D1, D2, D3, D4, and D5) are used for final deposition of
bleached or filtered water from aquatic studies via AST or UST storage.
DWR has determined that (1) high levels of metals and herbicides exist in the holding ponds, (2)
there is no current permitted disposal method, and (3) waste is allowed to discharge into Waters
State or Noah Carolina ( £nvh==nW Quality I Waler Resoumes
1628 Mai! Smite Ccoler I Raleigh, North Carnlinr 27699.1628
919 791 420U
L�

WS
Bill Whitford
NOV-2015-DV-0265
Page 2 of 5
of the State by pond overflow along with stormwater .runoff. Discharges have been routinely
occurring for years without a permit. The test pond grid is shown below, as well as evidence of
overflow to the drain (at the bottom of the photo, south of pond D1). This drain inlet and its
associated piping deliver all runoff water directly into the perennial stream south of the berm.
Figure 1. Aerial photograph of the test pond grid from Google Earth. Imagery dated May 19, 2015.
Pond designations D I-D5 are according to SePRO's response letter and diagram.
i
Analyte
Date
POND D1
POND D2
fit.
(MOIL)
(mglL)
#�}
Copper (Div. Water Resources)
10121/2016
32
S
MOM
Copper (CityoiRocky Maunt)
2/2912016
322
NA
ria
Not",
Prior b SePRO'5 March 2016 response, DWR had caged Pond 01 'Pond A' and Pond 02'Pond 8'
Grab samples were collecled from the surface parson of the pond Indicated.
Standards and Criteria may be found hero_
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F �
r

W,
Bill Whitford
NOV-2015-DV-0265
Page 3of5
DWR has determined that the SePRO Research & Technology Campus facility in Whitakers, NC
is in violation of the following North Carolina General Statutes 143-215.1. (a) (1) and (2), which
state following:
NCGS 143-215.1 (a) (1)
"Activities for Which Permits Required. — No person shall do any of the following things
or carry out any of the following activities unless that person has received a permit from
the Commission and has complied with all conditions set forth in that permit.
(1) Make any outlet into the Waters of the State.
(2) Construct or operate any sewer system, treatment works or disposal system within the
State."
The illegal discharge of wastewater must be immediately eliminated. These violations and any
future violations are subject to a civil penalty assessment of up to a maximum of $25,000.00
per day for each violation. This Office requests that you respond in writing to the seven items
Iisted below within 30 days of receipt of this Notice. Your response should address the
following Items:
Elimination of Wastewater and Waste Treatment Systems
1) Unpermitted waste discharges are not allowed to continue. The unpennitted treatment
systems (Ponds D1, D2, D3, D4, and D5) are NOT allowed to be used to treat and/or
discharge wastewater to surface waters. These treatment systems must be immediately
eliminated. Explain in your written response how this will be accomplished; include a
time line.
Wastewater Treatment and Holding Ponds D1 and D2
2) Waste treatment and holding ponds DI and D2 have no freeboard based on May 10, 2016
photos, and can easily over top. (During efforts to close these basins, a freeboard of
at least 24 inches must be maintained from the top of each pond's liner edge
temporarily until the ponds are emptied.)
Initially, DWR requires that the two wastewater treatment and holding ponds (D1-D2) be
properly dewatered and closed. DWR requires that you provide the following information
regarding the closure of these ponds:
a. Document when and where the wastewater and solids within the DI-D2 ponds
will be temporarily held; e.g. a frac tank, tanker, etc.
b. Document how the water and solids will be pumped into the holding location.
[Include dates, times, and verbal (48-hour) notification to DWR staff of when
activities will take place. Please contact Laura Robertson at [phone].]

w
Bill Whitford
NOV-20I 5-DV-0265
Page 4 of 5
Wastewater Treatment and Holding Ponds D1, D2. D3, D4, and D5
3) The polyethylene -lined holding ponds (Dl, D2, D3, D4, and 135) are used for final deposition of
bleached or filtered water from aquatic herbicide studies, product mixing, and lab cleaning
wastes. These ponds contain wastewater and cannot be allowed over flow/discharge to surface
waters. i
You are requested! to sample Dl, D2, D3, D4, and DS for the following parameters:
metals, herbicides, and pesticides. These samples must be collected at surface and bottom
levels of each basin, totaling a minimum of 10 samples. The results of this sampling
information must be provided to this office within 45 days.
These treatment systems must be immediately eliminated. Explain in your written
response how this will be accomplished for each pond (Di, D2, D3, D4, and 135).
4) Provide this office a detailed document including a pump and haul or treatment schedule,
including dates, for how the waste products will be permanently removed from the site
and properly disposed of by a licensed hauler, facility, or agency.
All Waste Presently On Site
5) A waste disposal plan must be developed to address all waste (solid and liquid) presently
onsite, including all material in underground storage tanks, above ground storage tanks,
and all remaining test/research/wastewater/holding ponds. A waste disposal plan must
also be developed for any new or future waste that may be generated on site. These plans
may be separately contracted.
6) A completed (dated, signed, and stamped) pump and maul permit application should be
submitted to this office within 30 days receipt of this letter. (Your previous application is
incomplete.) The permit application requires the following items:
a. Two sets of detailed plans/specifications signed and sealed by a North Carolina
Professional, Engineer mast be provided, showing the components associated with
the pump and haul activity (drains, piping, tanks, etc.), a general location map, a
plan view of the storage facility and its relationship to property lines, structures,
etc. The tank detail should indicate the high water alarm (either audible and
visual or an auto dialer). Each sheet of the plans and the first page of the
specifications must be signed/sealed by the Professional Engineer.
b. A letter must be provided from the owner/authority of the receiving wastewater
treatment facility stating that the pumped and hauled wastewater will be
accepted and specify the volume of wastewater that will be accepted.
c. A letter or contract from the hauler stating his capability and willingness to
perform the pumping and hauling,

W.
a,
Bill Whitford
NOV-2015-DV-0265
Page 5 of 5
Industrial Pretreatment Permit - City of Rocky Mount
7) You provide a copy of a pretreatment application that you submitted to the nearest
municipality, the City of Rocky Mount, for permission to convey onsite wastewater to the
City to be treated. However, the data sent to the City is incorrect. SePRO submitted data
collected by DWR in the stream sampling locations in January 2016 as if they were
samples from the two holding ponds that were collected in October 2015.
This is incorrect, and must be addressed with the City along with the pretreatment
application, as well as the pump and haul permit application. Alert DWR when this has
been corrected and submitted to the City of Rocky Mount.
Thank you for your attention to this matter. This office requires that the violations, as
detailed above, be abated immediately and properly resolved. Environmental damage and/or
failures to properly manage process wastewater have been documented for the subject site as
stated above. Your efforts to undertake activities to bring the subject site back into compliance
is not an admission, rather it is an action that must be taken in order to begin to resolve ongoing
environmental issues. Please understand, periodic or routine occurrences of the discharge of
unpermitted waste (overflows) must be eliminated. This cannot continue to occur.
Your response to this correspondence will be considered in any civil penalty assessment
process that may occur. Should you have any questions regarding these matters, please contact
Laura Robertson or Cheng Zhang at (919) 7914200.
Sincerely
12 / 2'�
Danny Smith, Supervisor
Water Quality Regiorial Operations
Surface Water Protection Section
cc: RRO DWR Files
Harvi Cooper, NCDEQ DWM, PO Box 1848 Pittsboro, NC 27312
William Bone, City of Rocky Mount, PO Box 1180 Rocky Mount, NC 27801
Kevin LaPointe, EPA CID, Sam Nunn Atlanta Federal Center, .
61 Forsyth Street, Ste. 16T90, Atlanta, GA 30303
Attachments
DWR Wastewater Sampling Results (Wastewater Ponds D1 & D2)
City of Rocky Mount Sampling Data (Wastewater Pond DI)

W.
�w

4
I . J %:
WarerResources
GNVIRQNHUNTAL QUALITY
February 8, 2016
Certified Mail # 7014 3490 000188213003
Return Receipt Re„ nested:
Bill Whitford
Director of Manufacturing & Logistics
Sepro Research & Technology Campus
16013 Watson Seed Farm Road
Whitakers, NC 27891-9114
Dear Mr. Whitford:
PAT MCCRORY
Gowefrw
DONALD R. VAN DER VAART
'-erV&wV
S, JAY ZIMMERMAN
irfm for
Notice of Violation and Notice of Intent to Enforce
Case No.: NOV-2015-DV-0265
Illegal Discharge/Stream Standard Violations/Removal of Use
16013 Watson Seed Farm Road
Nash County
The North Carolina Department of Environmental Quality received an anonymous complaint
that waste chemicals (herbicides) were being, improperly managed or disposed (discharged) at
the Sepro Research and Technology Campus (Sepro) in Whitakers, NC. This complaint was
forwarded to us from US Environmental Protection Agency (EPA). Accordingly, on October 21,
2015, Laura Robertson and Cheng Zhang with the Raleigh Regional Office (RRO) of the
Division of Water Resources (DWR) and representatives of the Division of Waste Management
(DWM) responded to the complaint. ,
On January 4, 2016, Laura Robertson and Cheng Zhang with the RRO conducted a follow-up
site visit.
During the site visits, it was explained that Whitakers Sepro Research & Technology Campus in
Whitakers, NC, conducts research and development of Sepro products containing aquatic
herbicides. The respective waste process water from research facilities at the field station are
stored in two tanks; one above ground tank (AST) and one underground storage tank (UST),
which are then pumped when full and emptied into constructed lagoons on site. A review of the
Nash County GIS tax database revealed that Whitakers Sepro Research & Technology owns
subject site.
Stale of North Cmlina I Envimftraeatal QualityJ Waler Rewu re5
1629 ]Nail Suvice Center I Raleigh, Noah Caen 27699.1629
919 7014200

Bill Whitford
NOV-2015-DV-0265
Page 2 of 10
The DWR site inspections revealed the following:
• The site is not served by or connected to a sewer collection system.
• It was explained during the site visits that there are two septic systems on site; one near
the office buildingtresearch facility and one near the field laboratory. The septic systems
only service the bathroom and kitchen sink areas of both buildings.
• The waste process water used in part of the research facilities is initially contained in the
field lab area in a UST with a level alarms, while the waste process water used in the
main building area is initially pumped to an AST. When the UST or AST reach holding
capacity, the waste water is then pumped into the lined test ponds.
• Waste water in the AST was sampled by DWM on October 21, 2015 for TCLP.
• It was explained during the site visits that the constructed lagoons which hold the waste
water are primarily the 5 southern -most Iagoons within the 32-test-pond. grid. The two
lowest in elevation are Pond A and Pond B.
• According to Sepro personnel, the 5 constructed lagoons at the south end of the test pond
grid (at the lowest elevations) are lined. Pond A and Pond B appear to have plastic liners.
Pond B has been emptied once in the past for maintenance, and there was no sludge
observed by Sepro personnel.
• It was explained that waste process water from the field lab involving plants is bleached
before being pumped into the UST or ponds.
• The waste water generated in the manufacture and testing of Sepro products on this site
in any other capacity is not treated in any manner on site, nor is there a disposal plan in
place.
Figure 1. Parcel map of the Sepro property in Whitakers, NC.
Map source: bitim/sis&o.nasb.nc.usfconnectQWnash!

Bill Whitford
NOV-2015-DV-0265
Page 3 of 10
Figure 2. The 32-pond grid, field station, and October 2015 sampling locations. Ground elevation decreases
to the south and west. A constructed drain is visible in the lighter area to the south of points C and D. This
is the conduit for pond discharge and stormwater runoff.
Figure 3: This photo depicts Pond A with zero freeboard and evidence of surface overflows and piping
conduit:

Bill Whitford
NOV-2015-DV-0265
Page 4 of 10
Figure 4: Facing downslope from Pond A toward an outlet structure, the grass -covered soil berm can be
seen in the background. Dark blue -colored water in puddles is evidence of recent overland flow. Gravel has
been applied since October 21, 2015, and depicts the preferential overland flow pathway from Pond A and
Pond B wastewater overflows. The riser for inlet pipe is Visible at the end of the recently -applied gravel.
Figure 5: Outlet pipe discharging from risbrAnlet pipe within bermed area. The pipe is approximately 20
feet in length from inlet to outlet. Water was visible in the riser and the outlet was discharging.

J
Bill Whitford
NOV-2015-Dv-0265
Page 5of10
October 2015 Surface Water and Soil Sam fin
On October 21, 2015, wastewater samples from the surface of the southwestern -most two ponds
(See Figures 2 and 6, Pond A and Pond B) were collected for laboratory analysis of acid
herbicides and metals. The wastewater in both ponds was dark blue to black, turbid, but did not
have a noticeable odor. Pond A is the lowest in elevation of the 32 ponds, and had approximately
1-2 feet of freeboard. Sampling results are included in Table 1 in attachments.
Surface soils were collected via decontaminated stainless steel hand auger into laboratory -
prepared soil jars. The soils contained elevated levels of aluminum, calcium, potassium,
magnesium, and iron. One acid herbicide was detected at concentrations below NC and EPA soil
remediation goals. See Table 2 in attachments.
October 21, 2015 water parameter readings collected from a YSI Pro Plus Meter revealed the
following:
Parameters measured in Samale Location Pond A:
PH = 7.2
Water Temperature = 18.1 deg C
Conductivity = 506 uS/cm
Parameters measured in Sample Location Pond B:
PH = 7.4
Water Temperature = 18.1 deg C
Conductivity =194 uS/cm

Bill Whitford
NOV-2015-DV-0265
Page 6 of 10
figure 6. Surface water and soils sampling locations on October 21, 2015.
January 2016 Surface Water Sampling
On January 4, 2016, Ponds A and B had no freeboard. DWR staff observed that gravel had been
placed along the edges of the pond berms. Pond overflow and other surface runoff was observed
to have discharged through a PVC pipe located at the top of the berm, poolingjuncontained on
the apex of the hill slope (Figures 3 and 4).
Upon inspection on October 21, 2015, wastewater runoff had noticeably stained the soils where
the flow pathway was void of vegetation and the hillside was rilled/ Bullied due to these
discharges. On January 4, 2016, DWR staff observed that gravel had been added to the ground
surface where the stained soils were previously observed, as shown in Figures 3 and 4.
Overland runoff from the lagoons flows down -slope to an inlet pipe that has been constructed to
transport overland flows to the south side of the constructed berm. This pipe structure discharges
wastewater that overtops the ponds to an Unnamed Tributary to Fishing Creek, Class C, and
Nutrient Sensitive Waters (NSW) in the Tar -Pamlico River Basin.
On January 4, 2016, surface water flows in the vicinity of the lagoons were investigated, as well
as the locations of the UST and septic areas. An upstream and downstream surface water sample
was collected at the locations designated in the following figure. The results of this sampling
event are presented in Table 3. The surface waters in both sampling locations appeared to be
clear, and flows were constant. Copper and zinc were present in the downstream sample at much

4
Bill Whitford
NOV-2015-DV-0265
Page 7 of 10
higher concentrations than in the upstream sample, and one herbicide was present only in the
downstream sample. Copper and zinc exceeded the 15A NCAC 2B Standard in the downstream
sample, and aluminum exceeded the EPA National Criteria in the upstream and downstream
samples collected on January 4, 2016.
January 4, 2016 water parameter readings collected from a YSI Pro Plus Meter revealed the
following:
Parameters .measured in Upstream Sample Location:
pH = 5.47
Water Temperature = 10.5 deg C
Conductivity = 182.9 uS/cm
Parameters measured in Downstream Sample Location:
pH = 5.75
Water Temperature = 7.2 deg C
Conductivity = 124.0 uS/cm
Figure 7, Site infortnation gathered on January 4, 2016, including surface water sampling locations.
Blue arrows represent surf cial water flow pathways relevant to sampling on January 4, 2016.

Hill Whitford
NOV-201 S-DV-0265
Page 8 of 14
The October 21, 2015 site inspection and the January 4, 2016 follow-up revealed the following
violations of North Carolina General Statutes 143-215.1. (a) (1) and (2), which state following:
NCGS 143-215.1 (a) (1)
"Activities for Which Permits Required. — No person shall do any of the following things
or carry out any of the following activities unless that person has received a permit from
the Commission and has complied with all conditions set forth in that permit.
(1) Make any outlet into the Waters of the State.
(2) Construct or operate any sewer system, treatment works or disposal system within the
State."
The illegal discharge of wastewater must be immediately eliminated. These violations and any
future violations are subject to a civil penalty assessment of up to a maximum of $25,000.00
per day for each violation. This Office requests that you respond to this letter in writing within
30 days of receipt of this Notice. Your response should be sent to both this office at the
letterhead address. Your response should address the following items:
1. Please explain clearly explain how waste/residual pesticides and/or herbicides, test
batch pesticides and/or herbicides mixtures, lab cleaning products and solvents are
disposed of on the site. Specifically, explain how the materials are conveyed, stored
and delivered to the test ponds.
2. Clearly explain how each of test ponds are/have been used, how they are maintained
and if they are lined. If the pond(s) is/are lined, please include the liner materials and
documentation. (Please clearly number/identify each pond so that it is clear which
pond you are addressing in your response)
3. Explain what wastes are generated from on -site sinks, wash -down activities, cleaning,
and housekeeping efforts and where/how this waste is disposed.
4. Detail in writing if water is ever pumped between ponds or out of ponds, where it is
pumped, how the ponds are dewatered, or if they are allowed to overflow.
5. If the ponds have ever been drained (naturally or by mechanical means), has the
sludge at the base of each pond been tested -for metals, herbicides, or other
constituents?'
Unpermitted waste discharges is not allowed to continue and must be immediately eliminated.
Accordingly, please develop a waste disposal plan that addresses waste presently onsite
(contained in septic tanks, above ground storage tanks, and ponds), and any future or new waste
that niay be generated. The current waste and any new and future waste must be properly
managed. As a part of this plan you will need to secure a pump and haul approval from the
DWR. A pump and haul permit application is attached to this letter with instructions.

,'t
Bill Whitford
NOV-2015-DV-0265
Page 9 of 10
As a part of your response to this letter, please provide a completed pump and haul permit
application to this office with within 30 days of receipt of this letter. The attached application
includes instructions. These instruction require the following information to be include with
your application;
• Provide this completed and signed form (application).
• Two sets of detailed plans/specifications signed and sealed by a North Carolina
Professional Engineer must be provided; showing the components associated with the
pump and haul activity (drains, piping, tanks, etc.), a general location map, a plan
view of the storage facility and its relationship to property lines, structures, etc. The
tank detail should indicate the high water alarm (either audible and visual or an auto
dialer). Each sheet of the plans and the first page of the specifications must be
signed/sealed by the Professional Engineer.
• A letter must be provided from the owner/authority of the receiving wastewater
treatment facility stating that the pumped and hauled wastewater will be accepted and
specifying the volume of wastewater that will be accepted.
• A letter or contract from the hauler stating his capability and willingness to perform
the pumping and hauling.
Please provide a cover letter explaining the circumstances associated with this pump
and haul request.
Thank you for your attention to this matter. This office requires that the violations, as
detailed„above, be abated immediately and properly resolved. Environmental damage and/or
failures to properly manage process wastewater have been documented for the subject site as
stated above. Your efforts to undertake activities to bring the subject site back into compliance
is not an admission, rather it is an action that must be taken in order to begin to resolve ongoing
environmental issues. Please understand, periodic or routine occurrences of the discharge of
unpermitted waste (overflows) must be eliminated. This cannot continue to occur.
Your response to this correspondence will be considered in any civil penalty assessment
process that may occur. Should you have any questions regarding these matters, please contact
Laura Robertson or Cheng Zhang at [phone].
Si erel ,
Danny Smith, Supervisor
Water Quality Regional Operations
Surface Water Protection Section

Bill Whitford
NOV-2015-DV-0265
Page 10 of 10
cc: RRO DWR Files
Harvi Cooper, NCDEQ DWM, PO Box 1848 Pittsboro, NC 27312
Attachments:
Table 1: Waste Water Sampling Analytical Results on 10-21.-2015
Table 2: Soil Sampling Analytical Results on 10-21-2015
Table 3: Surface Water Sampling Analytical Results on 01-04-2016
Pump and Haul of Industrial Wastewater Permit Application

Table 1
Waste Water Sampling Conducted at Sepro
Whitakers, Nash County, NC
10.21.2015
Analyte
POND A
POND B
MBI 15ANCAC 2B
°�` .;`
., ras6wat
° W p
R SAkNC 0,213
o� rkE�
Hu an"n,,Health
(UgIL)
(ug/L)
ON,
lU9 1IM3
METALS
!t,
AgSilver
-
A! Aluminum:`E
Sb Antimony
As Arsenic
2.0
2,0
Be Barium
10
11
Be Beryllium
510
5.0
" E
Ca Calcium
8,200
12,000
.'> E_fa�
Cd Cadmium
0.50
0.50
E RIM9 ' _
Co Cobalt
50
50
NNO
Cr Chromium
5.0
5.0
?
.� 1
Cu Copper
[" 320001i iGSi
7 800�:
Fe Iron
360
310
LIT �` � NE'►M�
Hg Mercury�
KPotassium
14,000
8,700
U Lithium
25
25
tt t .
Mg Magnesium
1,800
1,700
RUN,98
Mn Manganese
41
^;iiliif260�";� is r
°!"°
�'
Mo Molybdenum
10
10
OR KM
Na Sodium
24,000
Ni Nickel
11
7.1
"FJE
Pb Lead
4.3
2.0
"K
Se Selenium
1,0
1.9
EMNE
ERR
Sn Tin
10
10
Sr Strontium
18
31„��iE`�
k��-jg40;000
TlThallmm
, �1 201, ` u_
F �.,2.O t �'
(g�14`040'
NE I i�O
v l ?r� • �,
Ti Titanium
10
10
E ,
� N
V Vanadium
10
10
1N..��3NE�>
Zn Zinc
45
46
Notes:
Standards and Ulada may be round here:
http:llportel.nrdgnr,t+rglclQooet�t_libr8rylget�F187uuIdx83a9C5!•t�Od•4gBb-Sdcl-81b6dh�}592a6prrwpld•38354

. f%
Table 1(Continued)
Waste Water Sampling Conducted at Sepro
Whitakers, Nash County, NC
10.21.2015
1 NCAC 2B
'
.F i.
1;%A NC�AC-f 15A CAC.2B
Analyte
POND A
POND B.
a Ep
F. �L
ork
a $ piy umaItft
Ac�att
,
(ug&)
NOW
V 11"RM MUM
04 u�x f99� M
ACID HERBICIDES
3. ,
riHITAs ' .: 7.34.
Acifluoden (blazer)
2.10
0.75
MR, W
, s N' '-� ENE ,
Benlazon
<2.1
<2.10
2,4-0
20.6
8.43
1.59
<6.75
b +�27,ti LA
2,44M
Dicamba
<0.75
<0.75
�lE3" `,000�
2M1�E+`l
3,5-Dichlorobenzoic acid
0.90
0.64
=,; M,'1
NE , g�,� tiEf'al
Dichloroprop
<2.7
<2.70
Dinmb
<3.15
<3.15
z0g;1PNIOM
, 9901
4-Nlitrophenol (pest)
<5.20
<1.20
f 7SQ
2 T�fir
Pentachiorophenol (PCP)
<0.45
40.45
,. RE4
2,4,5-T
<0.90
<0.90
1 <{ _.T`,._
2,4,5-TP (Siivex)
<D.90
<0.90
EPA NpUaW C tdlq a e1e,hkh4bW M
Standards and C+it fla maybe fund harp
hOpllportal.ncdenr.cAgfG =menUbrm4ErLma7uuld=cM* t i-mw4ab.8dcl-8lbW7c6592a8prouplda38364

Table 2
Soil Sampling Conducted at Sepro
Whitakers, Nash County, NC
10.21-2015
Analyte
Soil C
Soil D
� � •
R !
PS .G
� �.�.�
InustriaT I
' Protscsion�
P.
mSfk9
mglkg
jg._b_,j
' M :.
METALS
i, r y'3� -i.
'��.�A i��
-7A.
�. $e-LIST.
Ag Silver
0.2
0.2
N MME 0
r �. 3MM
Al Aluminum
14,000
6,300a
As Arsenic
1.2
0.4
Q E ,
1-279N.M,M
1
Ca Calcium
600
220
1�20
�k�;
Cd Cadmium
0.2
0.2
r1w0Fs� E.
all 2
Cr Chromium
10
5.4
Cu Copper
610
330
,•
4,0+' <
w
Fe Iron
IL;r�11;000�`,;
`7;400d"K{NKOMO
Hg Mercury
0.03
0.02
K Potassium
750
300I
?H
,
E?METE
Mg Magnesium
MOO
340:g�
Mn Manganese
61
16f�'
Na Sodium
43
27
4M
Ni Bickel
3.9
1.7
Pb Lead
Se Selenium
9.6
0.2
6.0
0.2�!
Y ►
-1.
Zn Zlnc
25
9.64680��
:T001]0_
�
EllACIDHERBICIDE5 � pia€
Acl6uorfen (blazer)
0.0488
0,0375
;E5 60 i;
Benlazon
<0,052
<0.052
-38C?
2,4•1)
<0.0268
<0.0268N
2,4-DB
<0.108
<0.108
j 100M'-`
f-MI';a.
l;. NME
Dlcamba
<0.0132
<Ull32
MIMI. �380 :l
a 1 9 0,,m-
3,5-Dichiorobenzoic acid
<0.0132
<0.0132
Zll.aiCN
1;: ' - NJ
ARM
Dichloroprop
<0.080
<0.080
,may, l �: � .'_g
WfiIVEM
J� r NE B
Dinoseb
<0.0268
<0.0268a1
4-Nitrophenol (pest)
<0.052 '
<0,052
Pentachlorophenal (PCP)
<0.0132
<0.0132
s g 1 06„
0
n b 0 0 ,
2,4,5-T
2,4,5-TP (Silvex)
<0.0132
<0.0132
<0.0132
<0.0132
I �, '� i102�F
�n Ir 1840n*,-vJ
F,1;320
Ngp
WacM Hazardous Sties Branch (IH5e) Pmk*a[y Soil Remediakn Goafs (PSRGs), Updated Seplember2015
htm:l/aortal.ncdenr.orA/c document library/get file3uuld=�160 Ma•�7Ad-dA79•bbbA-253aFO6fi5615&arauo1da399G1
NE - No Standard FstabLshed

Table 3
Surface Water Sampling Conducted at Sepro
Whitakers, Nash County, NC
01.04-2016
Upstream
Downstream
..'Ie '(NCAC 2fsC.
;ra.^A'Eum
a �
B G�r28Analyte
A Water Su fialth
(u911.)
(u9n-)�?(uf)I"S(Pf3��i
METALS
- k
Et ' 1 M
Al Aluminum
'690g �
�; '200 "
Ca Calcium
16,000
11,000
iceR *714
PON9M.NRI, , to
Cu Copper
2.0
'u:F t�r110a
-14"2
45NE;N'",
MI Mv w I a 01�124.
Fe Iran
310
530
K Potassium
4,800
2,800
Mg Magnesium
5,400
2,000
1N ., ;.,.
,,
Mn Manganese
49
2.0
;
s tE a j
Na Sodium
6,000
10,000
tQf?,NElE'
Ni Nickel
2.0
2.0
2.0
.
Pb Lead
2.0
Zn Zinc
11
130�
ACID HERBICIDES
�Q
ITM
Acifluorfen (blazer)
<0.33
0.22
.._
,
Untazon
<0.42
<0.42
';CNN*
v
M�� f xs -
2,4-D
<0.45
<0.45
jP2-500M
D€camba
<0.15
<0.15
10 Pi k_ I
"1, . M
a W.1� e
3,5-Dlchlombenzole acid
<0.18
<0.18
,' ` l Yr `t
CAM
Dichloropmp
<0,54
<0.54
N
Dinoseb
<3
0.6
<0.63
�. � 1 g
r N
E "ff
4-Nitrophenol (pest)
<0.24
<0.24
�27�
Pentachloraphenol (PCP)
<0,09
<0,09
�� vs
(iT Ua3 '55
2,4, 5-T
<0;18
<0.18
'�1'�.
2,4,5-TP (Silvex)
<0.18
<0,18
T '� ,7-NM: ,� -0;
Natal:
EpA' Netlanal CrHerla dru'f>lgABphted in Biay, ;�.��,r=t;;.. ���.n;��';:�;:� ��` ,� • �; ��E,
rdards and Colefia may be round here:
:llp(utal.ncdsar.agkldorLmanU�braYlpeLJfCa?uuld�cAa3a9c51-aaAd�s8b8dC161 b6d1c17�92adAroUP�dz3BS84

HAZARDOUS WASTE SECTION - COMPLIANCE BRANCH
FILE TRANSMITTAL & DATA ENTRY FORM
Your Name: WILLIAM HUNNEKE
Facility ID Number: NCD986189074
Facility Name: SEPRO CORPORATION RESEARCH CAMPUS
Document Group: Inspection/Investigation (1)
Document Type: I - Compliance Evaluation Inspection (CEI)
File Description/Comments: Laboratory Focused follow-up to 10/15/15 Inspection. No violations.
Date of Document: 1/12/2016
Author(s) of Document: William Hunneke
Inspector ID #: NC060
Suborganization: Eastern Region
County (if not on report): NASH

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WASTE MANACEMENT
HAZARDOUS WASTE SECTION
FOCUSED COMPLIANCE EVALUATION INSPECTION REPORT
FACILITY INFORMATION:
Facility Name: SEPRO CORPORATION RESEARCH CAMPUS
EPA ID Number: NCD986189074
Type of Facility: Conditionally Exempt Small Quantity Generator (CESQG)
Facility Location/ 16013 Watson Seed Road, Whitakers, NC 27891
Mailing Address: Nash County
Telephone Number: 252-391-8373
Property Owner: Sepro Development Company, LLC
Property Owner Address: 11550 North Meridian Street, Carmel, IN 46032
Legal Owner of Business: Sepro Corporation
FACILITY CONTACT: Bill Whitford, Director of Manufacturing & Logistics
Phone Number: 252-391-8373
Email Address: [e-mail]
PARTICIPANTS:
Representing facility: Bill Whitford, Hamid Ullah, Sophia Ullah (chemistry area),
Ben Willis (plant culture area)
Representing NCDEQ: William Hunneke & Harvi Cooper
DATE OF SITE VISIT: January 12, 2016 onsite: 1000 hrs. offsite: 1145 hrs.
PURPOSE OF SITE VISIT:
Initially response to an anonymous complaint posted on the Environmental Protection Agency's website
alleging improper disposal of pesticide herbicide laboratory waste coupled with an unannounced
Compliance Evaluation Inspection to determine compliance with 40 CFR 261, 262, 265 273, 279 and
268. A compliance evaluation inspection was performed at the site on October l5, 2015 however field
laboratory personnel were not available that day. Consequently, the focus of this investigation is
exclusively on the field laboratory.
FACILITY DESCRIPTION:
The Field Laboratory/Formulations Laboratory sits adjacent to the company's aquatic test impoundments
and is used to grow out customer aquatic plant sample species in preparation for planting in the test
impoundments. Additionally, the wet chemistry section of the field lab performs side by side testing of
competitor products against company formulations to gather efficacy and concentration data. Very small
amounts of waste are generated which are customarily placed down a sink that drains to a six -hundred -
gallon underground tank that is pumped out several times per year and according to Mr. Whitford,
currently managed as hazardous waste. Small amounts of acetone used to final wash the cleaned
glassware go down the sink. Larger, but still relatively small amounts (several gallons at most) of wet

SePro Corporation Research Campus NCD986189074
Focused Compliance Evaluation Inspection Report Page 2 of 2
January 12, 2016
chemistry waste are brought back to the facility's manufacturing/blending building for reuse in
manufacturing and are not considered hazardous waste.
AREAS OF REVIEW AND INSPECTION:
Emergency preparedness, manifests, and inspection records were all covered in the previous CEI report of
October 15, 2015 and are not discussed in this report. On the day of the inspection, interviews with
laboratory personnel were conducted in the field lab to ascertain common practice and expressly identify
any hazardous wastes generated. The aquaculture and plant testing (referred to as the cylinder) rooms do
not typically generate hazardous waste as most everything is either decontaminated in an autoclave or
moved outside to the test impoundments. As mentioned above, the wet chemistry lab generates acetone
in minute amounts which is then managed as hazardous waste.
CONCLUSIONS:
There do not appear to be any hazardous waste violations at the field/formulations lab. The facility must
ensure any hazardous waste is containerized and that the contents of the underground collection tank is
managed appropriately. Additionally, a waste determination must be completed on any sludge dredged
from the ponds or wastewater removed from the ponds. The facility may not transfer waste water of any
kind into surface impoundments without a discharge permit.
William Hunncke
Environmental Senior Specialist, NCDEQ
Copy of report provided to facility contact
February 5, 2016
Date

r
HAZARDOUS WASTE SECTION - COMPLIANCE BRANCH
FILE TRANSMITTAL & DATA ENTRY FORM
Your Name:
Facility ID Number:
Facility Name:
Document Group:
Document Type:
Description for File (for CARA):
Date of Document:
Author(s) of Document:
Inspector ID #:
Comments for RCRAInfo:
William Hunneke
NCD986189074
SEPRO CORPORATION RESEARCH CAMPUS
Inspection/Investigation (I)
I - Compliance Evaluation Inspection (CEI)
CEI as a result of a complaint call. Referred to DWR after reviewing sample results.
10/15/2015
William Hunneke
NC060 Suborganization: Eastern Region
CEI as a result of a complaint call. Referred to DWR after reviewing sample results.
County (if not on report): NASH

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION
COMPLAINT & COMPLIANCE EVALUATION INSPECTION REPORT
FACILITY INFORMATION:
{
Facility Name:
EPA ID Number:
Type of Facility:
Facility Location/
Mailing Address:
Telephone Number:
Property Owner:
Property Owner Address:
Legal Owner of Business:
FACILITY CONTACT:
Phone Number:
Email Address:
PARTICIPANTS:
Representing facility:
Representing NCDEQ:
DATE OF SITE VISIT:
SEPRO CORPORATION RESEARCH CAMPUS
NCD986189074
Conditionally Exempt Small Quantity Generator (CESQG)
16013 Watson Seed Road, Whitakers, NC 27891
Nash County
252-391-8373
Sepro Development Company, LLC
11550 North Meridian Street, Carmel, IN 46032
Sepro Corporation
Bill Whitford, Director of Manufacturing & Logistics
252-391-8373
[e-mail]
Bill Whitford & Sam Mason
William Hunneke & Harvi Cooper
October 15, 2015 onsite: 1040 hrs. offsite: 1420 hrs.
PURPOSE OF SITE VISIT:
Response to an anonymous complaint posted on the Environmental Protection Agency's website alleging
improper disposal of pesticide/herbicide laboratory waste coupled with an unannounced Compliance
Evaluation Inspection to determine compliance with 40 CFR 261, 262, 265 273, 279 and 268. There is no
record that the facility has had a previous hazardous waste compliance evaluation inspection.
FACILITY DESCRIPTION:
Sepro Corporation (SePro) is a manufacturer of specialty blended aquatic herbicidal products for the
treatment of ponds and other small to mid -sized water impoundments. At the Whitakers research campus,
the company develops and blends customer specific aquatic herbicidal treatment compounds and tests
them in a series of aquatic impoundments located in the north quadrant of the property. Formerly owned
and operated by Syngenta Crop Protection, Inc., the 402 acre site was purchased by SePro in October
2004 from Mr. James Shearin, a farmer who bought the site from Syngenta approximately one year prior
to that. Approximately 90 acres of the property is wooded (southeastern section), the remaining acreage
is in crop production with an approximately ten acre pond created by a dammed creek that feeds Fishing
Creek in the middle of the site.

r
SePro Corporation Research Campus
Complaint & Compliance Evaluation Inspection Report
October 15, 2015
NCD986189074
Page 2 of9
Five buildings populate the site, four of which are clustered toward the western side of the property and
the last, the Field Lab/Formulations Lab which sits adjacent to the aquatic test impoundments. The main
office building is approximately 8,000 square feet and houses all administrative offices plus several small,
one room laboratories each specific in nature. The facility's Main Laboratory Building (Lab) is
approximately 4,600 square feet and is where the company does its qualitative testing, and initial grow
out of customer's samples. The Lab also houses the facility's waste storage in the form of a hazardous
waste accumulation area and a 2,000 gallon tank which accepts all of the Lab and Manufacturing area's
wastewater. A more complete discussion of the facility's waste disposal system is included later in this
report. The facility's Manufacturing and Packaging building is located immediately adjacent and to the
west of the Lab. Approximately 9,300 square feet in area, the Manufacturing/Packaging Building is
where bulk chemical formulations are blended and packaged into saleable units, primarily 5 and 2.5
gallon containers. The blending plant mixes copper and various other products dissolved in water to
produce concentrated aquatic herbicide suspensions which are placed into 250-gallon totes used to feed
the facility's consumer packaging line. Drains in the floor of the manufacturing area lead to a sump
which is pumped into the 2,000 gallon tank located next door in the Lab building. A 4,600 square foot
Maintenance Shop/Warehouse completes the cluster of buildings on the west side of the property. The
Maintenance Shop/Warehouse is used to store universal waste used lamps and a covered area adjacent to
the Warehouse stores bulk process chemicals; (RCRA) empty drums; cardboard for recycle, and assorted
used machine parts and farm equipment. The Field Lab/Formulation Lab houses numerous tubs and open
top tanks used to grow a variety of aquatic plants for the company's research. A small lab also occupies
part of the area and is utilized for testing and formulation of materials destined for the aquatic test
impoundments. The aquatic test impoundments are 32 in number arranged in a grid occupying an
approximately eight to nine acre area. Each of the impoundments are approximately 50 x 60 foot sized
rectangles on the average of six feet deep. According to Mr. Whitford, the impoundments are supposedly
plumbed together allowing for water from one to be pumped or diverted to adjacent ponds but to his
knowledge, SePro has never utilized those conduits. There are five "lower" impoundments located at the
bottom of an approximately 20 foot embankment apparently used as overflow areas if needed. The
remaining ponds sit atop the embankment and are on relatively level grade. According to Mr. Whitford,
the five "lower" ponds are lined with bentonite. There is one gentleman working at the facility, Mr. Barry
Hendrix who worked at the site when the impoundments were constructed and has knowledge of some of
the engineering parameters of the impoundments. The company is going to try to locate any "as -built"
drawings for those impoundments. Mr. Whitford indicated that waste from the 2,000 gallon tank at the
Main Laboratory is periodically pumped into one of two impoundments next to the westernmost lower
impoundment. He said that approximately six years ago, the company had the contents of the tank tested.
The company has not been able to locate those test results.
The company employs twenty-six individuals in North Carolina, twenty of whom work regularly at the
subject site, the remainder working at a warehouse in Rocky Mount where the company has plans to
establish another laboratory. Compliance assistance was offered for the Rocky Mount facility once its lab
comes online. Employees at the Whitakers facility generally work one shift. Buildings at the cite are on
municipal water with the exception of the Field Lab/Formulation Lab which accesses water from one of
the two wells on the property. All buildings are on septic systems for sanitary sewer. Hazardous waste
from the lab's high pressure liquid chromatography (HPLC) machines is collected in satellite
accumulation containers and emptied into a 55-gallon drum for storage until it is removed by a hazardous
waste transporter. The Main Laboratory and Manufacturing/Packaging building sinks and drains are both
plumbed to a system of pipes that lead to sumps which are then pumped into the 2,000 gallon tank in the
Lab Building. Water from the invasive species grow tanks is delivered after it has been bleached to the
2,000 gallon tank mentioned above. According to Mr. Whitford, the 2,000 gallon tank is periodically
pumped into a mobile tank, and driven by tractor to the aquatic test impoundment area where its contents
are pumped into one of the two impoundments next to the westernmost lower impoundment. The facility
has an invasive weed permit but no storm water or other discharge permits. The property is

SePro Corporation Research Campus NCD9861 M74
Complaint & Compliance Evaluation Inspection Report Page 3 of 9
October 15, 2015
approximately one third of a mile from Fishing Creek, a tributary of the Tar River. The distance to the
nearest offsite well is unknown and the nearest residence is across Watson Seed Road, approximately one
tenth of a mile from the sites' main cluster of buildings.
The facility is operating as. a conditionally exempt small quantity generator (CESQG) of hazardous waste,
shipping approximately 300 pounds of hazardous waste on the average of two times per, year. The facility
was inspected as a CESQG with guidance provided regarding the small quantity generator (SQG) rules,
many of which the company was following as best practices.
WASTE STREAMS INCLUDE:
Hazardous Waste Streams and Waste Codes:
• Waste acetonitrile solution DOOI
• Petroleum Distillates (Ligoine) D001
• Assorted lab solvents and lab pack wastes DOO1/D002
Other Waste Streams:
• Acteo Diquat Dibromide (RCRA empty drums)
• Used Oil, recycled
• Universal Waste
• Cardboard, recycled
AREAS OF REVIEW AND INSPECTION:
Emergency Preparedness/Arrangements with Local Authorities:
The manufacturing/blending/packaging building is completely covered by a wet fire suppression system
which is tested annually. The Whitakers Volunteer Fire Department visits the facility annually, the
facility has an emergency action plan which describes the actions personnel will take in a fire or other
emergency (not reviewed as part of the inspection). The facility is documenting weekly inspections of its
hazardous waste storage area. Every employee is provided general hazard communication awareness
training at the time of hire, and those individuals whose job duties include the management of hazardous
waste are given hazardous waste training. The main lab is an ISO accredited laboratory.
Manifests 1 LDR:
Hazardous waste manifests were reviewed from August 2011 through the present (last shipment July 28,
2015) and found to be in compliance (with SQG rules) and were complete with land disposal restriction
documents.
Transporters:
• A&D Environmental
• Eastern Environmental Management (for universal waste)
TSDs:
• EcoFlo, Inc.
NCD986232221
NCR000146456
NCTFO0000060 (Transfer Facility #)
NCD980842132
Inspection Records (storage):
The facility is documenting weekly inspections of its hazardous waste storage area. Complete log of
inspection records was not reviewed as part of the inspection.
Accumulation Areas:
The facility has satellite accumulation areas for hazardous waste generated from HPLC machines in the
main laboratory. On the ,day of the inspection, two HPLC machines were observed with satellite
accumulation containers (amber 1.5 liter jugs) properly closed and labeled per SQG rules. Several amber

' SePro Corporation Research Campus
Complaint & Compliance Evaluation Inspection Report
October 15, 2015
NCD986189074
Page 4 of 9
jugs of waste acetonitrile solution were also observed properly labeled and closed, Additional waste
solvents stored under the lab hood in Building 2 were observed properly labeled and closed. One of the
amber jugs was labeled as containing waste methylene chloride, When methylene chloride is used for its
solvent properties in laboratory applications, waste methylene chloride would likely be characterized as
an F002 listed waste. The EPA Environmental Management Guide for Small Laboratories was emailed to
Bill Whitford on October 19, 2015. Please review sections 3.2 and 3.3 and contact Harvi Cooper with
any questions on waste coding of F listed solvents.
Storage Areas:
The facility has one area for the storage of hazardous waste located immediately adjacent to the Lab in the
same building. One the day of the inspection, two 55-gallon drums containing waste petroleum distillates
and waste acetonitrile solution respectively were observed properly closed, labeled and dated (per SQG
rules) sitting on secondary containment pallets. Though not required under CESQG rules, recommend a
fire extinguisher and spill kit in the area. The storage area is also where the 2,000 gallon tank is located
which is plumbed to the Lab and Manufacturing/Packaging Building drains. The tank sits inside of a
secondary containment area. The tank was sampled on October 21, 2015 to determine if any TCLP
parameters exceeded action limits. Split samples were collected by Brian Polk for NCDEQ and by Sam
Mason for SePro. Analytical results for TCLP metals, volatiles, semi-volatiles, pesticides and herbicide
parameters did not exceed TCLP action limits (see attached results, Appendix B, Shealy Environmental
Services, Inc. Report of Analysis). According to a conversation between Ms. Harvi Cooper and Mr.
Whitford on November 19, 2015, SePro did not have their splits of the samples taken that day analyzed.
Other Areas Visited:
Main Administrative Building;
Three small labs are located in this building: Genetics Lab; Biologic Lab and a Grow Lab. Currently,
only the grow lab is staffed. On the day of the inspection, no hazardous waste was observed or reported
to be generated at any of these three labs.
Manufacturing/Packaging Building
Copper based products are dissolved to produce concentrated aquatic herbicidal solutions in the
Manufacturing Building. A chelated copper blending plant contains seven large above ground storage
tanks (ASTs) between 6,000 and 10,000 gallons in size all located within a secondary containment area
capable of holding approximately 10,000 gallons. This operation feeds 250 and 300 gallon totes which
support the consumer bottling line, filling 5 and 2.5 gallon plastic bottles. Floor drains in the
Manufacturing Building are plumbed to a sump which pumps into the 2,000 gallon tank next door in the
Lab's storage area. No hazardous waste was observed in the Manufacturing/Packaging Building on the
day of the inspection and according to Mr. Whitford, none is customarily generated.
Maintenance Shop/Warehouse/Covered Storage
The Maintenance Shop/Warehouse consists of a light machine shop, enclosed storage area and covered
storage area. On the day of the inspection, used lamps were observed in containers that were closed and
labeled. Bills of lading from Eastern Environmental Management documented shipping of universal
waste on a less than annual basis were reviewed. No hazardous waste was observed at the enclosed and
covered storage areas,
Field Lab/Formulation Lab
On the day of the inspection, a wide variety of chemicals were observed in the Field/Formulation Lab but
no hazardous waste was observed stored. Numerous tubs and large containers were being utilized to
grow aquatic plants. Field lab staff was not present at the time of the inspection and additional
information on the types of waste generated and how it is stored and disposed of will require another site
visit.

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Complaint & Compliance Evaluation Inspection Report
October 15, 2015
NCD986189074
Page 5 of 9
Aquatic Test Impoundments
The test impoundments described earlier were observed to be approximately four to six feet deep with
plenty of freeboard remaining to prevent overflow and a piping system connected to overflow ponds on
the lower level. The five overflow ponds were in similar condition as far as current water levels, however
an aerial photo showed brown vegetation from the lower edge of the northern overflow pond trailing
toward a drainage ditch downgradient. A sampling event for two of the lower ponds and downgradient
soils was conducted by NC Division of Water Resources personnel Cheng Zhang and Laura Robertson on
October 21, 2015. Additional testing of any sludge and wastewater removed from the lower ponds will
be required prior to disposal or treatment to determine if either wastes are characteristic hazardous wastes.
Prior to removal of sludge or wastewater, contact the selected treatment storage and disposal facilities to
ensure any additional analytical tests that they may require are conducted.
CONCLUSIONS:
There do not appear to be any hazardous waste violations at this facility. The facility must ensure all
hazardous waste is contained and no hazardous waste is released to the collection tank or surface
impoundment system. Additionally, a waste determination must be completed on any sludge dredged
from the ponds or wastewater removed from the ponds. The facility may not transfer waste water of any
kind into surface impoundments without a discharge permit. The complaint was assigned a Tips &
Complaint System ID# FY15-134603-3709 by EPA and has been referred to the NC Department of
Environmental Quality Division of Water Resources Raleigh Regional Office.
➢ Please review sections 3.2 and 3.3 of The EPA Environmental Management Guide for Small
Laboratories and contact Harvi Cooper with any questions on waste coding ofF listed solvents.
William Hunneke
Environmental Senior Specialist, NCDEQ
Copy of report provided to facility contact
November 9, 2015
Date
Guidance documents provided with report:
EPA Environmental Management Guide for Small Laboratories
CESQG checklist including used oil and universal waste rules.
Small quantity generator checklist

SePro Corporation Research Campus
Complaint & Compliance Evaluation Inspection Report
October 15, 2015
Appendices
Aerial Photos of SePro Campus including detail of Aquatic Test Impoundments.
Report of Analysis, Shealy Environmental Services, Inc.
2,000 Gallon Tank sampled on October 21, 2015
NCD986189074
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SePro Corporation Research Campus NCD986189074
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pctober 15, 2015
Appendix A
Aerial View of SePro Research Campus
16013 Watson Seed Road, Whitakers, NC 27891