NCG060047_COMPLETE FILE - HISTORICAL_20190118

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
IV CCU Dv ooy-7
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ Jn6 (:)I)
YYYYMMDD �

Lawyer, Mike
From: Scott Schuelke <[e-mail]>
Sent: Friday, January 18, 2019 8:13 AM
To: Lawyer, Mike
Cc: Terry Crawford; Arun Nagineni
Subject: RE: [External] Cargill Fayetteville - Unanticipated Bypass Potential
Mike,
As a follow -up -to the below, the Sand Filter system for Outfall FV001 was repaired and put back into operation yesterday
afternoon (January 17, 2019). This work was completed prior to any rain event, therefore; no bypass occurred.
Thanks,
Scott Schuelke
Regional EHS Manager - East
CASCNA / GEOSNA
Cargill
Helping the world thrive
direct. 910-223-6623
1754 River Road, Fayetteville, NC 28312
www. Cargill. com
From: Lawyer, Mike <[e-mail]>
Sent: Wednesday, January 16, 2019 10:37 AM
To: Scott Schuelke <[e-mail]>
Cc: Terry Crawford <[e-mail]>; Arun Nagineni <[e-mail]>
Subject: RE: [External] Cargill Fayetteville - Unanticipated Bypass Potential
Scott,
Thank you for the notification. Hope all goes well and the work can be completed in a timely fashion.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
910 433-3394 office
mike.lawyer0)ncdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301

Nothing Compares.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Scott Schuelke <Scott [e-mail]>
Sent: Wednesday, January 16, 2019 10:28 AM
To: Lawyer; Mike <[e-mail]>
Cc: Terry Crawford <Terry [e-mail]>; Arun Nagineni <Arun [e-mail]>
Subject: [External] Cargill Fayetteville - Unanticipated Bypass Potential
Mike,
As discussed this morning on the phone, we could possibly have an unanticipated by-pass of our Stormwater sand filter
at Outfall FV001. FV001 is on a Semi -Annual sampling basis with the last sampling conducted in November or 2018, so
there are no issues from a sampling standpoint.
We have had some recent issues with standing water on the sand filter and were fortunate enough to have the
contractor that installed the sand filter system to come out and assess the issue. Upon evaluation, it was realized that
we could have pluggage at the drain lines under grade which discharge to the outfall.
The contractor is in the process today of removing the materials to access and replace these drain lines. The
unanticipated bypass would occur if he cannot finish the job before an expected rainfall tomorrow. If this would occur,
the stormwater run-off from the 4 inlet drains that would normally be filtered through the sand filter, would overflow
directly into the ditch along River Road. This ditch drains through an unnamed tributary to the Cape Fear River.
As per conversations with the contractor, if the work cannot be finished before tomorrow's rain event, it will be
completed no later than Saturday, January 191h 2018.
Once the work on the sand filter is complete, we will send you a follow-up email. Should you have any questions, please
let me know.
Regards,
Scott Schuelke
Regional EHS Manager - East
CASCNA / GEOSNA
Cargill
Helping the world thrive
direct. 910-223-6623
1754 River Road, Fayetteville, NC 28312
www. Cargill. corn

Lawyer, Mike
From: Scott Schuelke <[e-mail]>
Sent: Wednesday, January 16, 2019 10:28 AM
To: Lawyer, Mike
Cc: Terry Crawford; Arun Nagineni
Subject: [External] Cargill Fayetteville - Unanticipated Bypass Potential
Mike,
As discussed this morning on the phone, we could possibly have an unanticipated by-pass of our Stormwater sand filter
at Outfall FV001. FV001 is on a Semi -Annual sampling basis with the last sampling conducted in November or 2018, so
there are no issues from a sampling standpoint.
We have had some recent issues with standing water on the sand filter and were fortunate enough to have the
contractor that installed the sand filter system to come out and assess the issue. Upon evaluation, it was realized that
we could have pluggage at the drain lines under grade which discharge to the outfall.
The contractor is in the process today of removing the materials to access and replace these drain lines. The
unanticipated bypass would occur if he cannot finish the job before an expected rainfall tomorrow. If this would occur,
the stormwater run-off from the 4 inlet drains that would normally be filtered through the sand filter, would overflow
directly into the ditch along River Road. This ditch drains through an unnamed tributary to the Cape Fear River.
As per conversations with the contractor, if the work cannot be finished before tomorrow's rain event, it will be
completed no later than Saturday, January 191h, 2018.
Once the work on the sand filter is complete, we will send you a follow-up email. Should you have any questions, please
let me know.
Regards,
Scott Schuelke
Regional EHS Manager - East
CASCNA / GEOSNA
Cargill
Helping the world thrive
direct: 910-223-6623
1754 River Road, Fayetteville, NC 28312
www. Cargill. cam

F2D
Ja`S �D S7q TFS
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
' REGION 4
Q ATLANTA FEDERAL CENTER
�� o= 61 FORSYTH STREET,
yTgL PROfGt ATLANTA, GEORGIA 30303-8960
DEC 0 5 2017
CERTIFIED MAIL 7010 1060 0002 1703 8501
RETURN RECEIPT REQUESTED
Mr. Don Camden
Commercial Manager, East
Cargill, Incorporated
105 New Fidelity Court n� a 2017
Garner, North Carolina 27529
Re. Consent Agreement and Final Order No. CWA-04-04-2017-45 I 0(b)
Cargill, Incorporated, Fayetteville, North Carolina
Dear Mr. Camden:
Enclosed is a fully executed copy of the Consent Agreement and Final Order that has been finalized by
the U.S. Environmental Protection Agency Region 4 and the Regional Administrator. Please make note
of the provisions under Paragraph 1V. Payment.
Should you have any questions or concerns, please contact Mr. Kenneth Kwan at [phone] or via
email at [e-mail].
Sincerely,
i
Mary . Walker
Director
Water Protection Division
Enclosure
cc: Mr. Mike Randell
North Carolina Department of Environmental Quality
Mr. Toby Vinson
North Carolina Department of Environmental Quality
Internet Address (URL) • http://www.epa.gov
RecycledlRecyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
IN THE MATTER OF: )
}
CARGILL, INCORPORATED }
FAYETTEVILLE, NORTH CAROLINA, )
RESPONDENT. )
CONSENT AGREEMENT AND r,
FINAL ORDER
'r 4
DOCKET NO. CWA-04-2017-4510(b)
CONSENT AGREEMENT
I. Statutory Authority
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1. This is a civil penalty proceeding pursuant to Section 309(g)(2)(B) of the Clean
Water Act ("CWA"), 33 U.S.C. § 1319(g)(2)(B), and the Consolidated Rules of Practice
Governing the Administrative Assessment of Civil Penalties, Issuance of Compliance or
Corrective Action Orders and the Revocation, Termination or Suspension of Permits, including
Subpart I, published at 64 Fed. Reg. 40,176 (July 23, 1999) and codified at 40 Code of Federal
Regulations ("C.F.R.") Part 22.
2. The authority to take action under Section 309(g)(2)(B) of the CWA, 33 U.S.C.
§ 1319(g)(2)(13), is vested in the Administrator of the United States Environmental Protection
Agency (EPA). The Administrator has delegated this authority to the Regional Administrator of
EPA, Region 4, who in turn has delegated this authority to the Director of the Water Protection
Division, of the EPA, Region 4 ("Complainant").
IL Allegations
3. Cargill, Incorporated, ("Respondent") is a corporation formed under the laws of
the State of Delaware and is therefore a `person" within the meaning of Section 502(5) of the
CWA, 33 U.S.C. § 1362(5).
4. At all times relevant to this action, Respondent owned and/or operated a soybean
and peanut processing facility ("Facility"), as identified by Standard Industrial Classification
("SIC") Code 2075, located at 1579 Underwood Road, Fayetteville, North Carolina 28312.
5. To accomplish the objective of the CWA, defined in Section 101(a) of the CWA,
33 U.S.C. § 1251(a), to restore and maintain the chemical, physical and biological integrity of
the nation's waters, Section 301(a) of the CWA, 33 U.S.C. § 131 ](a), prohibits the discharge of
pollutants by any person into waters of the United States except as in compliance with a National
Pollutant Discharge Elimination System ("NPDES'') permit issued pursuant to Section 402 of the
CWA, 33 U.S.C. § 1342.

6. Section 402 of the CWA, 33 U.S.C. § 1342, establishes a NPDES Permit Program
authorizing the EPA or authorized states to administer the NPDES Permit Program, including the
issuance of NPDES permits allowing for the discharge of pollutants, including stormwater, into
navigable waters subject to specific terms and conditions. The EPA has granted the State of
North Carolina, through the North Carolina Department of Environmental Quality ("NCDEQ"),
approval to issue NPDES permits pursuant to Section 402(b) of the CWA.
7. The NCDEQ issued General Permit to Discharge Storniwater Under the National
Pollutant Discharge Elimination System, Permit No. NCG060000 ("Permit") for establishments
primarily engaged in food and kindred products in accordance with the North Carolina General
Statute 143-215.1 and the CWA. The Permit became effective December 1, 2012, and will expire
on October 31, 2017. Coverage under the Permit is obtained by submitting a Notice of Intent
("NOI") to NCDEQ.
8. The Respondent's permit was renewed on December 4, 2012, and requires
Respondent to comply with all provisions of the Permit.
9. Part I1, Section A, Paragraph 1(a) of the Permit requires that the Stormwater
Pollution Prevention Plan ("SPPP") contain: "A general location 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," and "accurate latitude and longitude of the points of
stormwater discharge associated with industrial activity," as wel I as "identify whether any
receiving waters are impaired or if the site is located in a watershed for which a TMDL has been
established."
10. Part II, Section A, Paragraph l(b) of the Permit requires that the SPPP contain: "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."
11. Part II, Section A, Paragraph 1(c) of the Permit requires that the SPPP contain: "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;
site topography and finished grade; all drainage features and structures; drainage area boundaries
and total contributing areas 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."
12. Part II, Section A, Paragraph 2 of the Permit specifies: "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."
2

13. Part II, Section A, Paragraph 8 of the Permit specifies: "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 pollutants to surface waters. All aspects of the SPPP shall be
reviewed and updated on an annual basis."
14. Part 11, Section B of the Permit specifies that stormwater samples be collected
after a dry weather interval of at least 72 hours from a previous storm event and within the first
30 minutes of discharge (first flush condition).
15. Part 11, Section B of the Permit specifies that semi-annual monitoring is required
for all discharge characteristics at each stormwater discharge outfall.
16. Part 11, Section B, Tier One of the Permit specifies: `'If: The first valid sampling
results are above a benchmark value, or outside of the benchmark range, for any parameter at any
outfall; Then: The permittee shall conduct a stormwater management inspection of the facility
within two weeks of receiving sampling results. Identify and evaluate possible causes of the
benchmark value exceedance. Identify potential and select the specific: source controls,
operational controls, or physical improvements to reduce concentrations of the parameters of
concern, and/or to bring concentrations within the benchmark range. Implement the selected
actions within two months of the inspection. 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."
17. Part III, Section C, Paragraph 1 of the Permit specifies: "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."
18. Part 11I, Section D, Paragraph 2 of the Permit specifies: "For each measurement or
sample taken pursuant to the requirement of this general permit. the permittee shall record ... the
individual who performed the sampling or measurements."
19. Part 1I1, Section D, Paragraph 4 of the Permit requires that test procedures for the
analysis of pollutants conform to 40 C.F.R. Part 136. The approved procedure for analyzing pH
in 40 C.F.R. Part 136 is the electrode method.
20. On February 10, 2016, representatives of the EPA, in conjunction with the
NCDEQ, performed a Compliance Stormwater Evaluation Inspection ("CSWEI") at the Facility
to evaluate the Respondent's compliance with the requirements of Section 301 of the CWA, 33
U.S.C. § 1311; the regulations promulgated thereunder at 40 C.F.R. § 122.26; and the Permit.
21. Based on the EPA's observation during the CS WEI and the review of informatics
provided to the EPA by the Respondent, the EPA has determined that the Respondent has failed
to comply with the CWA, its implementing regulations, and the Permit.

22. Locks Creek (Waterbody ID: NC 18-28) and the Cape Fear River (Waterbody ID:
NC18-(26)a) are two impaired waterbodies that were not discussed in the TMDL provision of the
SPPP (Section 2.1.1) nor were they identified in a general location map in violation of Part I1,
Section A, Paragraph I(a) of the Permit.
23. The "V" area, which contained exposed scrap materials and junk parts, and the
truck parking area across Underwood Road were not identified and evaluated in the SPPP as a
potential pollutant source in violation of Part II, Section A, Paragraph I (b) of the Permit.
24. The catchment basin and the sand filter basin were existing structural stormwater
BMPs that were not depicted on the site map in violation of Part 1I, Section A, Paragraph 1(c) of
the Permit.
25. A stormwater outfall, identified in the updated SPPP as Outfall FV006, was not
identified in the December 20I5 SPPP nor the facility's site map as a permitted outfall in
violation of Part II, Section A, Paragraph 1(c) of the Permit.
26. Section 4 of the SPPP did not include all the BMPs employed onsite. The sand
filter basin for stormwater treatment, the catchment basin installed as a result of benchmark
exceedances, and the mechanical sweeper used for housekeeping were BMPs that were not
summarized in the SPPP as part of the Stormwater Management Strategy in violation of Part II,
Section A, Paragraph 2 of the Permit.
27. Respondent's SPPP violated Part 1I, Section A, Paragraph 8 of the Permit by
failing to amend, update, and modify according to the following site conditions and operations.
a. The 2'x2'x2' catchment basin installed in December 2014 as a result of
benchmark exceedances was not added to the SPPP. The SPPP had no
information on how the design and operation of the catchment basin would reduce
pollutant discharges through outfall FV002.
b. The "V" area with its storage of junk parts and the truck parking area across
Underwood Road were not evaluated in the SPPP as potential sources of exposed
material which may have had a significant effect on the potential for discharge of
pollutants to surface waters.
The BMPs in Section 4 of the SPPP did not identify and discuss the design and
operation of the sand filter basin for stormwater treatment.
The Facility's exposed material list in Table 2-1 of the SPPP did not reflect the
current site conditions. Several locations for these exposed materials had changed.
e. The truck staging and parking area across Underwood Road was not evaluated in
the SPPP for erosion and sediment control.

Locks Creek (Waterbody ID: NC18-28) and Cape Fear River (Waterbody ID:
NC 18-(26)a) have an impaired designated use of fish consumption with a
Mercury TMDL. The TMDL Provision of the SPPP (Section 2.1.1) did not
evaluate whether the discharges from Respondent had any significant effect on
these two impaired waterbodies.
28. A stermwater outfall, identified in the updated SPPP as Outfall FV006, was not
identified in the December 2015 SPPP nor the Facility's site map as a permitted outfall. The
Facility did not have documentation of semi-annual monitoring at this outfall in violation of Part
I1, Section B of the Permit.
29. The sampling log did not record the time when the discharge began. The only
time recorded was the time of grab sample. The Facility did not have documentation of sampling
within the first 30 minutes of flow (first flush condition) in violation of Part II, Section B of the
Permit.
30. Respondent failed to record each instance of a Tier One response in the SPPP.
Also, there were no status reports on the effectiveness of each of the following Tier One
responses in the SPPP and in the routine site inspection reports in violation of Part II, Section B,
Tier One of the Permit:
Exceedances of benchmark values occurred at Outfalls FV002, FV003, and
FV004. The permit requires the permittee to conduct a stormwater management
inspection within two weeks of receiving sampling results, identify and evaluate
possible causes of the benchmark value exceedance, and/or install stormwater
BMPs in a tiered program. Outfall FV003's benchmark exceedances were:
7/21/2013 for Chemical Oxygen Demand ("COD") & Total Suspended Solids
(`'TSS"), and 10/7/2013 for pH. A Tier 1 Checklist was completed only for the pH
exceedance and the date of the inspection was not recorded, yet it is required to
take place within two weeks of the sample date. No specific controls or
improvements were identified to bring the concentrations within the benchmark
range. No possible onsite causes were evaluated and an assumption was made that
acid rainfall was the cause of the exceedance.
b. At outfall FV002, a substantial number of benchmark exceedances.occurred for
COD and TSS. The 10/712013 Tier 1 Checklist for TSS and COD exceedances
lacked necessary information. The checklist said to "Identify and evaluation of
possible causes. Explain." The response was "Post Shutdown Equipment in
Area." This does not evaluate or explain the exceedance of TSS or COD. The
date of the inspection was not recorded, yet it was required to take place within
two weeks of the sample date. Also, in a 2014 feasibility study, a catchment basin
was installed in December 2014. However, this basin had no apparent impact on
reducing the COD and TSS exceedances at outfall FV002.

Outfall FV004's benchmark exceedances were: 5/18/2013 COD, 4/7/2014 COD
& TSS, 7/21/2014 TSS. The Facility conducted monthly benchmark sampling
after the two consecutive TSS exceedances for August 2014-December 2015. The
4/7/14 Tier 1 Checklist that was performed for TSS and COD exceedances lacked
necessary information. The date of the inspection was not recorded, yet it is
required to take place within two weeks of the sample date.
31. Respondent violated Part II1, Section C, Paragraph 1 of the Permit regarding
proper operation and maintenance practices. During the EPA's on -site evaluation of pollutant
sources and SPPP implementation, the following operation and maintenance deficiencies were
observed:
a. The covered loadingfunloading area "B" had a fair amount of spilled materials on
the floor.
b. The material storage area had three uncovered dumpsters; two with organic
materials and one with trash materials.
C. The EPA observed several areas where good housekeeping practices were
deficient:
1. The grain drying area had grain dust and grain materials on the ground.
2. The raw soybean dump area had grain on the ground.
3. Exposed soybean meal storage with soybean meal and grain dust several inches
thick was observed on the ground.
4. The material storage area had various materials on the ground.
Secondary containment for the chemical tote storage was full of liquid. The
lock at the drain pipe was unlocked. This could have potentially caused site
personnel to accidentally release this liquid without properly evaluating the
pollutant level.
e. The EPA observed the following areas where sediment and erosion controls were
lacking:
1. Sediment deposit was observed in the roadway and in the ditch at the River
Road entrance area.
2. Construction activity along Building 1 did not appear to have the necessary
state permit for construction activity due to the Facility having more than 1 acre
cumulatively disturbed. No perimeter BMPs were observed, resulting in
uncontrolled sediment loss outside of the construction area.
3. Extensive sediment accumulation was observed surrounding outfall FV002.
4. Small rills were observed in several areas along the "V" area.
5. The truck staging and parking area across Underwood Road was not evaluated
in the SPPP for erosion and sediment control.

Concrete staining from a past spill draining into a ditch along Underwood Road
was observed.
g. The "V" area had a large amount of unprotected and uncovered used equipment
and parts. Staining on the ground was observed in many spots throughout the
disposal area.
32. Chain of Custody forms did not have signatures of all individuals who handled
the samples in violation of Part III, Section D, Paragraph 2 of the Permit.
33. Laboratory bench data showed that the test procedure for pH was conducted with
a paper pH test strip instead of the approved electrode probe/meter equipment in violation of Part
III, Section D, Paragraph 4 of the Permit.
34. Based on the CSWEI and due to the hydrology of the Facility and historic rainfall
data, the EPA has determined that from September 2012 to March 2016, stormwater associated
with industrial activities discharged to Locks Creek, a tributary of the Cape Fear River. The Cape
Fear River is a traditionally navigable water of the United States as defined by Section 502(7) of
the Act, 33 U.S.C. § 1362(7) and its implementing regulations at 40 C.F.R. § 122.2. This
discharge occurred while the Facility was in violation of the Permit.
1311.
35. Therefore, the Respondent has violated Section 301 of the CWA, 33 U.S.C. §
lll. Stipulations and Findings
36. Complainant and the Respondent have conferred for the purpose of settlement
pursuant to 40 C.F.R. § 22.18 and desire to resolve this matter and settle the allegations
described herein without a formal hearing. Therefore, without the taking of any evidence or
testimony, the making of any argument or the adjudication of any issue in this matter, and in
accordance with 40 C.F.R. § 22.13(b), this Consent Agreement and Final Order ("CA/FO") will
simultaneously commence and conclude this matter.
37. For the purposes of this CA/FO, the Respondent admits the jurisdictional
allegations set out above, but neither admits nor denies the factual allegations set forth above.
38. The Respondent hereby waives its right to contest the allegations set out above
and its right to appeal the Final Order accompanying this Consent Agreement.
39. The Respondent consents to the assessment of and agrees to pay the civil penalty
as set forth in this CA/FO and consents to the other conditions set forth in this CA/FO.
40. By signing this CA/FO, the Respondent certifies that the information it has
supplied concerning this matter was at the time of submission, and is, truthful, accurate, and
complete for each such submission, response and statement. The Respondent realizes that there

are significant penalties for submitting false or misleading information, including the possibility
of fines and/or imprisonment for knowing submission of such information.
41. The EPA reserves the right to assess and collect any and all civil penalties for any
violation described herein to the extent that any information or certification provided by the
Respondent was materially false or inaccurate at the time such information or certification was
provided to the EPA.
42. Complainant and the Respondent agree to settle this matter by their execution of
this CA/FO. The parties agree that the settlement of this matter is in the public interest and that
this CA/FO is consistent with the applicable requirements of the CWA.
IV. Payment
43. Pursuant to Section 309(g)(2)(B) of the CWA, 33 U.S.C. § 1319(g)(2)(B), and
40 C.F.R. Part 19, and considering the nature of the violations and other relevant factors, the
EPA has determined that Seventy-five thousand five hundred dollars ($75,500) is an appropriate
civil penalty to settle this action.
44. The Respondent shall submit payment of the penalty specified in the preceding
paragraph within thirty (30) days of the effective date of this CA/FO via a cashier's or certified
check, payable to the order of "Treasurer, United States of America." The check shall reference
on its face the name of the Respondent and the Docket Number of this CA/FO. Such payment
shall be tendered to:
U.S. Environmental Protection Agency
Fines and Penalties
Cincinnati Finance Center
P.O. Box 979077
St. Louis, Missouri 63197-9000
45. At the time of payment, the Respondent shall send a separate copy of the check,
and a written statement that payment has been made in accordance with this CA/FO, to the
following persons at the following addresses:
Regional Hearing Clerk
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
and

Ms. Mary Mattox
U.S. Environmental Protection Agency, Region 4
Water Protection Division
NPDES Permitting and Enforcement Branch
Municipal and Industrial Enforcement Section
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
46. The penalty amount specified above shall represent civil penalties assessed by the
EPA and shall not be deductible for purposes of federal taxes.
47. Pursuant'to Section 309(g)(9) of the CWA, 33 U.S.C. § 1319(g)(9), failure by the
Respondent to pay the penalty assessed by the CA/FO in full by its due date may subject the
Respondent to a civil action to collect the assessed penalty plus interest (at currently prevailing
rates from the effective date of this CA/FO), attorney's fees, costs for collection proceedings and
a quarterly nonpayment penalty for each quarter during which such failure to pay persists. Such
nonpayment penalty shall be in an amount equal to twenty percent (20%) of the aggregate
amount of such penalty and nonpayment penalty which are unpaid as of the beginning of such
quarter. In any such collection action, the validity, amount and appropriateness of the penalty
and of this CA/FO shall not be subject to review.
V. General Provisions
48. This CA/FO shall not relieve the Respondent of its obligation to comply with all
applicable provisions of federal, state, or local law, nor shall it be construed to be a ruling on, or
determination of, any issue related to any federal, state or local permit. Other than as expressed
herein, compliance with this CA/FO shall not be a defense to any actions subsequently
commenced pursuant to federal laws and regulations administered by the EPA.
49. Issuance of this CA/FO shall not be deemed as prohibiting, altering, or in any way
limiting the ability of the EPA to pursue any other enforcement actions available to it under law.
Such actions may include, without limitation, any administrative, civil, or criminal action to seek
penalties, fines, injunctive, or other appropriate relief, or to initiate an action for imminent and
substantial endangerment, under the CWA or any other federal or state statute, regulation, or
permit.
50. Except as otherwise set forth herein, this CA/FO constitutes a settlement by
Complainant and the Respondent of all claims for civil penalties pursuant to the CWA with
respect to only those violations alleged in this CA/FO. Except as otherwise set forth herein.,
compliance with this CA/FO shall resolve the allegations of violations contained herein.
51. Nothing in this CA/FO is intended to nor shall be construed to operate in any way
to resolve any criminal liability of the Respondent, or other liability resulting from violations that
were not alleged in this CA/FO.

52. Each undersigned representative of the parties to this CA/FO certifies that he or
she is fully authorized to enter into the terms and conditions of this CAIFO and to execute and
legally bind that party to it.
53. This CA/FO applies to and is binding upon the Respondent and its officers,
directors, employees, agents, successors and assigns.
54. Any change in the legal status of the Respondent, including but not limited to any
transfer of assets of real or personal property, shall not alter the Respondent's responsibilities
under this CA/FO.
55. Each party shall bear its own costs and attorney's fees in connection with the
action resolved by this CA/FO.
56. In accordance with 40 C.F.R. § 22.5, the individuals below are authorized to
receive service related to this proceeding:
For Complainant:
Patrick B. Johnson
Associate Regional Counsel
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
[phone]
For Respondent:
Adam G. Sowatzka
Partner
King & Spalding LLP
1180 Peachtree Street, N.E.
Atlanta, Georgia 30309-3521
[phone]
57. The parties acknowledge and agree that this CA/FO is subject to the requirements
of 40 C.F.R. § 22.45(c)(4), which provides a right to petition to set aside a proposed CA/FO
based on comments received during the public comment period.
58. Pursuant to Section 309(g) of the CWA, 33 U.S.C. § 1319(g), and 40 C.F.R.
§ 22.38(b), Complainant represents that the State of North Carolina was provided a prior
opportunity to consult with Complainant regarding this matter.
59. Effective upon signature of this CA/FO by the Respondent, the Respondent agrees
that the time period commencing on the date of its signature and ending on the date the EPA
receives from the Respondent the payment required by this CA/FO shall not be included in
10

computing the running of any statute of limitations potentially applicable to any action brought
by the EPA related to the matters addressed in this CA/FO and that, in any action brought by the
EPA related to the matters addressed, the Respondent will not assert, and may not maintain, any
defense or claim based upon principles of statute of limitations, waiver, laches, estoppel, or other
defense based on the passage of time during such period. If the EPA gives notice to the
Respondent that it will not make this CA/FO effective, the statute of limitations shall begin to
run again commencing ninety days after the date such notice is sent by the EPA.
V1. Effective Date
60. The effective date of this CA/FO shall be the date on which the CA/FO is filed
with the Regional Hearing Clerk.
AGREED AND CONSENTED TO:
BY THE RESPONDENT, CARGILL, INCORPORATED:
Date:�DO
Don Camden
Commercial Manager, East
Cargill, Incorporated
For COMPLAINANT, U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 4:
�i
Mary S.ker `
Director (
Water Protection Division
U.S. EPA, Region 4
N
Date: i v
b�

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
IN THE MATTER OF:
CONSENT AGREEMENT AND
CARGILL, INCORPORATED ) FINAL ORDER
FAYETTEVILLE, NORTH CAROLINA
}
RESPONDENT. } DOCKET NO. CWA-04-2017-4510(b)
FINAL ORDER
In accordance with the Consolidated Rules of Practice Governing the Administrative
Assessment of Civil Penalties, Issuance of Compliance or Corrective Action Orders and the
Revocation, Termination or Suspension or Permits, including Subpart I, 40 C.F.R. Part 22, and
authorities delegated to me, the foregoing Consent Agreement is hereby approved and
incorporated by reference into this Final Order. Pursuant to Section 309(g)(2)(B) of the CWA,
33 U.S.C. § 1319(g)(2)(B), the Respondent is hereby ordered to comply with the terms of the
foregoing Consent Agreement.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Date:
Onis "Tre lenn, III
Regional Administrator

Docket No. CWA 04-2017-4510(b)
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the attached CONSENT
AGREEMENT AND FINAL ORDER in the matter of Cargill Incorporated, Docket No. CWA-
04-2017-4510(b) (filed with the Regional Hearing Clerk on SL , 2017) was served on
l0 2017, in the manner specified to each of the persons listed below.
By hand -delivery: Patrick B. Johnson
Associate Regional Counsel
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
By certified mail,
return receipt requested: Adam G. Sowatzka
Partner
King & Spalding LLP
1180 Peachtree Street, N.E.
Atlanta, Georgia 30309-3521
[phone]
Mike Randell, Stormwater Program Engineer
NC Division of Energy, Mineral and Land Resources
NC Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
Toby Vinson, Chief of Program Operations
NC Division of Energy, Mineral and Land Resources
NC Department of Environmental Quality
1612 M • ice Cen6Bu
Raleigh, NG` 7 ' 6P tricia _
Regional Hearing Clerk
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
[phone]

'.
Division of Energy, Mineral, and Land Resources
Kf 11;
Land Quality Section / Stormwater Program
National Pollutant Discharge Elimination System (NPDES)
Energy, Mineral &
PERMIT OWNER AFFILIATION DESIGNATION FORM
Land Resources
ENVIRONMENTAL QUALITY
(Individual Legally Responsible for Permit)
Use this form if there has been:
FOR AGENCY USE ONLY
Date Received
Year
Month
Day
NO CHANGE in facility ownership or facility name, but the individual
who is legally responsible for the permit has changed.
If the name of the facility has changed, or if the ownership of the facility has changed,
do NOT use this form. Instead, you must fill out a Name -Ownership Change Form
and submit the completed form with all required documentation.
What does "legally responsible individual" mean?
"IThe person is either:
RECEIVED
• the responsible corporate officer (for a corporation); A�
• the principle executive officer or ranking elected official (for a municipality, state; ederal?or other public
agency);
• the general partner or proprietor (for a partnership or sole proprietorship);
• or, the duly authorized representative of one of the above.
1) Enter the permit number for which this change in Legally Responsible Individual ("Owner Affiliation")
applies:
Individual Permit
N I C I S
2) Facility Information:
Facility name:
Company/Owner Organization:
Facility address:
(vr) Certificate of Coverage
N C G 0 6 0 0 4 7
Favetteville Plant
Cargill Incorporated
1579 Underwood Rd
Address
Fayetteville NC 28312
City State Zip
To find the current legally responsible person associated with your permit, go to this website:
http://deq.ne.gov/about/divisions/energy-mineral-land-resources/energy-mineral-land-permits/stormwater-prog am
and run the Permit Contact Summary Report.
3) OLD OWNER AFFILIATION that should be removed:
Previous legally responsible individual: Michael
First M1
4) NEW OWNER AFFILIATION (legally responsible for the permit):
Person legally responsible for this permit:
Johan
First MI
Page 1 of 2
Klauke
bast
Clairet
Last
SWU-OWN ERAF F I L-23NIarch2017

NPDES Stormwater Permit OWNER AFFILATION DESIGNATION Form
(if no Facility Name/Ownership Change)
Facility Leader
Title
1579 Underwood rd.
Mailing Address
Fayetteville NC 28312
City State Zip
[phone] Johan Clairet@Cargillxom
"Telephone E-mail Address -
(952-249-4344)
Fax Number
5) Reason for this change:
® Employee or management change
A result of: ® Inappropriate or incorrect designation before
® Other
New Admin Building and ownership of road resulted in a changed
If other please explain: mailing address for the facility. Also incorrect contacts on entire permit.
E-mail explaining all the changes sent to [e-mail] .
Site was not receivin, information as it was being sent to a sister facilih
The certification below must be completed and signed by the permit holder.
PERMITTEE CERTIFICATION:
1, Johan Clairet, attest that this application for this change in Owner Affiliation (person legally responsible
for the permit) has been reviewed and is accurate and complete to the best of my knowledge. I understand
that if all required parts of this for are not completed, this change may not be processed.
li I
S Date
PLEASE SEND THE COMPLETED FORM TO:
Division of Energy, Mineral, and Land Resources
Stormwater Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
For more information or staff contacts, please call [phone] or visit the website at:
http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
Page 2 of 2
SW U-OWNERAFFiL-23Mar2017

PUBLIC NOTICE
U. S. ENVIRONMENTAL PROTECTION AGENCY, REGION 4
WATER PROTECTION DIVISION
NPDES PERMITTING AND ENFORCEMENT BRANCH
ATLANTA FEDERAL CENTER
61 FORSYTH STREET, S.W.
ATLANTA, GEORGIA 30303
DATE: August 21, 2017 PUBLIC NOTICE No. CWA-04-2017-4510(b)
Notice of Proposed Issuance of
Consent Agreement and Final Order
The U.S. Environmental Protection Agency (EPA), Region 4, proposes to issue a Consent Agreement and Final
Order (CAFO), Docket No. CWA-04-2017-4510(b), that assesses an administrative penalty of $75,500.00 to
Cargill, Incorporated, (Respondent), 1579 Underwood Road, Fayetteville, North Carolina under the authority of
Section 309(g)(2)(B) of the Clean Water Act (CWA) 33 U.S.C. § 1319(g)(2)(13).
The CAFO will settle the EPA allegations that the Respondent violated Section 301 of the CWA, 33 U.S.C.
§ 1311, by discharging stormwater associated with industrial activity into waters of the United States while in
violation of the State of North Carolina's Storm Water Discharges Associated with Industrial Activity, General
Permit No. NCG060000, at its industrial facility known as Cargill, Incorporated, located at 1579 Underwood
Road, Fayetteville, North Carolina.
Any person wishing to comment on any aspect of the proposed CAFO may submit such continents in writing to
the Regional Hearing Clerk at U.S. EPA, Atlanta Federal Center, 61 Forsyth Street, S.W., Atlanta, Georgia,
30303. Comments must be submitted within 30 days of the date of this notice. Please include the Public Notice
Number and the Docket Number with any submitted comments.
Because this matter involves a CWA Section 309(g) proceeding that is proposed to be simultaneously commenced
and settled under 40 C.F.R. § 22.13(b), the EPA cannot resolve or settle this CAFO until ten days after the close
of the public comment period in accordance with 40 C.F.R. § 22.45 (b) and (c).
FOR FURTHER INFORMATION: Persons wishing to receive a copy of the Consolidated Rules of Practice
Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination or Suspension of
Permits, 40 C.F.R. Part 22, which apply to this matter, or comment upon the proposed penalty assessment, should
contact the Regional Hearing Clerk identified above. Unless otherwise noted, the public record for this action is
located in the EPA Regional Office at 61 Forsyth Street, S.W., Atlanta, Georgia, and the file will be open for
public inspection between 9:00 a.m. and 4:00 p.m., Monday through Friday.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
IN THE MATTER OF: }
}
CARGILL, INCORPORATED }
FAYETTEVILLE, NORTH CAROLINA, }
)
RESPONDENT. )
CONSENT AGREEMENT AND
FINAL ORDER
DOCKET NO. CWA-04-20174510(h)
CONSENT AGREEMENT
1. Statuto , Authority
1. This is a civil penalty proceeding pursuant to Section 309(g)(2)(B) of the Clean
Water Act (" Pk A'' , 33' U.S.C. § 1319(b)(2)(B), and the Consolidated Rukv.refPiwelice
Governing the ��[lmiinisirtntit>e.�lssec:�°nic'frF of 001 Penalties, Issuance cif Compliance or
Corrective 1ic•tion Orders rind the. Revocation. Termination or Suspension of Perniits, including
Subpart I, published at 64 Fed. Reg. 40,176 (July 23, 1999).and'codified at 40 Code of Federal
Regulations ("C.F.R.") fart 22.
2. The authority to take action under Section 309(g)(2)(B) of the CWA, 33 U.S.C.
1319(g)(2)(B ), is vested in the Administrator of the United States Environmental Protection
Agency ( EPA). The Administrator has delegated this authority to the Regional Administrator of
EPA, Region 4, who in turn has delegated this authority to the Director of the Water Protection
Division, of the EPA, Region 4 ("Complainant").
11. Allegations
3. Cargill, Incorporated, ('Respondent") is a,corporat'on formed under the laws of
the State of Delaware and is therefore a "person" within the meaning of Section 502(5) of the
CWA, 33 U.S.C: § 1362(5).
4. At all times relevant to this action, Respondent owned and/or operated a soybean
and peanut processing Facility ("Facility' ), as identified by Standard Industrial Classification
("SIC'') Code 2075, located at 1579 Underwood Road, Fayetteville, North Carolina 28312.
5. To accomplish the objective of the CWA, defined in Section 101(a) of the CWA,
33 U.S.C. § 1251(a), to restore and maintain the chemical, physical and biological integrity of
the nation's waters. Section 301(a) at -the CWA. 33 U.S.C. § 131 ](a), prohibits theAischarge of
pollutants by any person into waters of the United States except as in compliance with a National
Pollutant Discharge Elimination System ("NPI)ES-) permit issued pursuant to Section 402 of the
CWA, 33 U.S.C. § 1342,

6. Section 402 of the CWA, 33 U.S.C. §� 1342, establishes a NPDES Permit Program
authorizing the EPA or authorized states to administer the NPDES Permit Program, including the
issuance of NPDES permits allowing for the discharge of pollutants, including stormwater, into
navigable waters subject to specific tennis and conditions. The EPA has granted the State of
North Carolina, through the North Carolina Department ol'Environmental Quality ("NCDEQ"),
approval to issue NPDB permits pursuant to Section 402(b) of the CWA.
7. The NCDEQ issued General Permit to Discharger Stormwater Under the iVational
Pollutant Discharge Elimination Svstenr, Permit Nor iVCGO60000 (`Permit') for establishments
primarily engaged in food and kindred products in accordance with the North Carolina General
Statute 143-215.1 and the CWA. The Permit became effective December 1, 2012, and will expire
on October 31, 2017. Coverage under the Permit is obtained by submitting a Notice of Intent
(-NO[-) to NCDEQ.
$. The Respondent's permit was renewed on December 4. 2012, and requires
Respondent to comply with all provisions of the Pen -nit.
9. Part 11, Section A, Paragraph I(a) of the Permit requires that the Stormwater
Pollution Prevention Plan C-SPPP") contain: "A general location map. showing the facility's
location in relation to transportation routes and surface waters; the name of the receiving waters
to which the stormw'atcr outfalls discharge.'' and "accurate latitude and longitude of the points of'
stormwater discharge associated with industrial activity." as well as "identi k- whether any
receiving waters are impaired or if the site is located in a watershed for which a TMDL has been
established..'
10. Part Il, Section A, Paragraph I(b) of the Permit requires that the SPPP contain: "A
narrative description of storage practices, loading and unloading activities, outdoor process areas,
dust or particulate generating; or control processes, and waste di.spoaal practices. A narrative
description of the potential pollutants that could be expected to he present, in the stormwater
discharge from each outfall."
11. Part 11, Section A, Paragraph 1(c) of the Permit requires that the SPPP contain: "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,
site topography and finished grade; all drainage features and structures; drainage area boundaries
and total contributing areas tar each outfall; direction of flow in each drainage; area; industrial
activities occurring in each drainage area; buildings; stormwater Best Management Practices
(' 13MI's"); 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."
12. Part 11, Section A, Paragraph 2 of the Permit specifies: "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."

,13. Part 11, Section A, Paragraph 8 of the Permit specifies: `'The permittee shall
amend the SPPP whenever there is a change in design; construction, operation, site; drainage,
inaintenance, or configuration ofthe physical features which may have a significant effect on the
potential -for the discharge ofpollutants.to surface waters. All aspects of the SPPP shall be
reviewed and updated on an annual basis:..
14, Part 11, Section B of time Perrnit specifies that stormwater samples be collected
after a dry weather interval of at least 72 hours from a previous storm event and within the first
30 minutes ofdiscltarge (first flush condition).
15. Part 11, Section B of the Permit specifies that semi-annual monitoring is required
for all discharge characteristics at each stormwater discharge outfall.
16. Part 11, Section 13, Tier One of the Permit specifies: "If: The first valid sampling
results are above,a bcnehmark value, or outside of the benchmark range, for any parameter at any
outfall; Then: The permittee shall conduct a'stormwatcr management inspection of the facility
within two weeks of receiving sampling. results. Identify and.evaluate possible causes of the
benchmark value exceedance. Identify potential and select the specific: source controls,
operational controls, or physical improvements to reduce concentrations of the parameters of
concern, and/or to bring concentrations within the benchmark range. implement the selected
actions Within.two months of the inspection. 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 selectedactions, and the date the selected actions were
implemented...
17. Part III, Section C, Paragraph I of the Permit specifies: '`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."
18. Part Ill, Section D, Paragraph 2 of the PermitspLcifies: "For each measurement or
sample taken pursuant to the requirement of this general permit, the pertnince shall record ... the
individual who performed the sampling or measurements."
10. Part 111. Section D,'Paragraph 4 of the Permit requires that test procedures for the
analysis of pollutants conform to 40 C.F.R. Part 136. The approved procedure for analysing pH
in 40 C.F.R. Part 136 is the electrode method.
20. On February 10, 2016, representatives bf the EPA, in conjunction with the
yCDEQ. performed a Compliance Stormwater Evaluation Inspection ("CSWEF'J at the Facility
to evaluate the Respondent's compliance with the requirements of Section 301 of the CWA, 33
U.S.C. §'131 1; the regulations promulgated thereunder at 40 C.F.R. § 122.26; and the Permit.
21. Based on the EPA-s observation during the CSWE1 and the review of information
provided to the EPA by the Respondent, the EPA has determined that the.Respondent has failed
to comply with the CWA, its implementing regulations, and the Permit..

22, Lacks Creek (Waterbody ID: NC 18-28) and the Cape Fear River (Waterbody ID:
NC I8426)a) are two impaired waterbodies that were not discussed in the TMDL provision of the
SPPP (Section 2.1.1) nor were they identified in a general location map in violation of Part 11,
Section A, Paragraph I(a) of the Permit.
23. The "V'- area, which contained exposed scrap materials and junk parts, and the
truck parking area across Underwood Road were not identified and evaluated in the SPPP as a
potential pollutant source in violation of Part 11, Section A, Paragraph I(b) of the Permit.
24. The catchment basin and the sand filter basin were existing structural stormwater
BMPs that were not depicted on the site map in violation of Part 11, Section A, Paragraph 1(c) of
the Permit.
25. A stormwater outfall, identified in the updated SPPP as Outfall FV006, was not
identified in the December 20I5 SPPP nor the Facility's site map as a permitted omtali in
violation of Part It, Section A, Paragraph I(c) of the Permit.
26, Section 4 of the SPPP did not include all the BMPs employed onsite. The sand
filter basin for stormwater treatment, the catchment basin installed as a result of benchmark
exccedances, and the mechanical sweeper used for housekeeping were BMPs that were not
summarized in the SPPP as part of the Stormwater Management Strategy in violation of Part 11,
Section A, Paragraph." of the Permit.
27. RespL)ndcnt's'SPI'P violated Part II. Section A, Paragraph 8 ofthc Permit by
failing to amend, update, and modify according to the following site conditions and operations:
a. The 2'x2'x2' catchment basin installed in December 2014 as a result of
benchmark exceedances was not added to the SPPP. The SPPP had no
information on how the design and operation of the catchment basin would reduce
pollutant discharges through outfall FV00-1.
b. The "V" area with its storage of junk parts and the truck parking area across
Underwood Road were not evaluated in the SPPP as potential sources of exposed
material which may have had a significant effect on the potential for discharge of
pollutants to surface waters.
C. The BMPs in SLvtion 4 of the SPPP did not identify and discuss the design and
operation of the sand filter basin for stormwater treatment.
d. The Facility's exposed material list in Table 2-1 ofthe SPPP did not reflect the
current site conditions. Several locations for these exposed materials had changed.
The trtck.staging and parking area across Underwood Road was not evaluated in
the SPPP for erosion and sediment control.

f. Locks Creek (Wat6body I D: NC 18-28) and Cape Fear River (Waterbody I D:
NC18-(26)a) have an impaired designated use of fish consumption with it
,Mercury TMDL. The TMDL Provision of the SPPP (Section 2.1.1) did not
evaluate whether the discharges from Respondent had any significant effect on
these two impaired waterbodies.
28. A stormwater outfall, identified in the updated SPPP as Outfall FV006, was not
identified in the December 2015 SPPP nor the Facility's site map as a permitted otttfall. The
Facility did not have documentation of semi-annual monitoring at this outfall in violation of Part
11, Section B of the Permit.
29. The sampling log did not record the time when the discharge began. The only
time recorded was the time of grab sample. The Facility did not have documentation of sampling
within the first 30 minutes of flow (first flush condition) in violation of Part I1, Section B of the
Permit.
30. Respondent failed to record each instance of a Tier One response in the SPPP.
Also, there were no status reports on the effectiveness of each of the following; Tier One
responses in the SPPP and in the routine site inspection reports in violation of Part II, Section B,
Tier One of the Permit:
Exceedances of benchmark values occurred at Outfulls FV002, FV003, and
FV004. The permit requires the permittee to conduct a stormwater management
inspection within t-wo weeks of receiving sampling results, identify and evaluate
possible causes of the benchmark value exceedance, and/or install stormwater
RMPs in a tiered program. Outfalf FV003's benchmark exceedances were:
7/21/2013 for Chemical Oxygen Demand (--COD") & Total Suspended Solids
("TSS''), and 10/7/2013 for pli. A Tier I Checklist was completed only for the pH
exceedance and the date of the inspection was not recorded, yet it is required to
take place within two weeks of the sample date. No specific controls or
improvements were identified to bring the concentrations within the benchmark
range. No possible onsite causes ;vere evaluated and an assumption was made that
acid rainfall was the cause of the exceedance.
b. At outfall FV002, a substantial number of benchmark exceedances occurred for
COD and TSS. The I O/7t2013 Tier'l Checklist for TSS and COD exceedances
lacked necessary inlormation.'['lie checklist said to "Identify° and evaluation of
passible causes. Explain." The response was "Post Shutdown Equipment in
Area." This does not evaluate or explain the exceedance of TSS or COD. The
date of the inspection was not recorded, yet it was required to take place within
two weeks of the sample date. Also, in a 2014 feasibility study, a catchment basin
was installed in December 2014. However, this basin had no apparent impact on
reducing. the COD and TSS exceedances at outfall FV002.

Outfall FV004's benchmark exceedances were: 5/19/2013 COD. 4i7/3014 COD
TSS, 7/21/2014 TSS, The Facility conducted monthly benchmark sampling;
after the two consecutive TSS exceedances for August 2014-December 2015. The
417/14 Tier I Checklist.that was performed for TSS and COD exceedances lacked
necessary information. The date of the inspection was not recorded, yet it is
required to take place within two weeks of the sample date.
31. Despondent violated Part 11I, Section C, Paragraph 1 of the Permit regarding;
proper operation and maintenance practices. During the I-PA's on -site evaluation of pollutant
sources and SPPP implementation, the following; operation and maintenance deficiencies were
observed:
a. The covered loading/unloading area "B" had a fair amount of spilled materials on
the floor.
b. The material storage area had three uncovered dumpsters; two with organic
materials and one with trash materials.
C. The EPA observed several areas where good housekeeping; practices were
deficient:
1. The gratin drying area had grain dust and grain materials on the ground.
2. The raw soybean dump area had grain on the ground.
3. Exposed soybean meal storage with soybean meal And gratin dust several inches
thick was observed an the ground.
4. The material storage area had various materials on the ground.
d: Secondary containment for the chemical tote storage was'/-, full of liquid. The
lock at the drain pipe was unlocked. This could have potentially caused site
personnel to accidentally release this liquid without properly evaluating the
pollutant level.
e. The EPA observed the following; areas where sediment and erosion controls were
lacking:
1. Sediment deposit was observed in the roadway and in the ditch at the River
Road entrance area.
?. Construction activity along Building; I did not appear to have the necessary
state permit for construction activity due to the Facility having; more than I acre
cumulatively disturbed. No perimeter BIMPs were observed, resulting in
uncontrolled sediment loss outside of the construction area.
3. Extensive sediment accumulation was observed surrounding outfall FV002.
4. Small rills were observed in several areas along the "V" area.
5. The truck staging and parking area across Underwood Road was not evaluated
in the SPPP for erosion and sediment control.

Concrete staining from a past spill draining into a ditch; along Underwood Road
was observed.
g;. The "V".area had a large amount of unprotected and uncovered used equipment
and parts. Staining on the ground was observed in many spots throughout the
disposal area.
32. Chain ot'Custody forms did not have signatures of all individuals who handled
the samples in violation of Part 111, Section D, Paragraph 2 of the Permit.
33. laboratory bench data showed that the test procedure for pH was conducted with
a paper pH test strip instead of the approved electrode probe/meter equipment in violation of Pan
111, Section D, Paragraph 4 of the Permit.
34. Based.on the CSWEI and due to the hydrology of the Facility and historic rainfall
data, the EPA has determined that from September 2012 to March 2016, stormwater associated
with industrial activities discharged to locks Creek, a tributary of the Cape Fear River. The Cape
Fear River is a traditionally navigable water of the United States as defined by Section 502(7) of
the Act. 33 U.S.C..§ 1362(7) and its implementing regulations at 40 C.F.R. 122.2. This
discharge occurred while the Facility was in violation of the Permit.
1311.
35. Therefore, the Respondent has violated Section 301 of the CWA, 33 U.S.C.
Ill. Stipulations and Findings
36. Complainant and the Respondent have conferred for the purpose of settlement
pursuant to 40 C.F.R. § 22.18 and desire to resolve this matter and settle the allegations
described herein without a formal (tearing. Thcrefore, without the; taking of any evidence: or
testimony, the making; of any argument or the adjudication of any issue in this matter, and in
accordance with 40 C.F.R. § 22.13(bj. this Consent Agreement and Final Order ("CA/F0") will
simultaneously commence and conclude this matter.
37. For the purposes of this CA/FO, the Respondent admits the jurisdictional
allegations set out above, but neither admits nor denies the factual allegations set forth above.
A The Respondent hereby waives its right to contest the allegations set out above
and its right to appeal the Final Order accompanying this Consent Agreement.
39. The Respondent consents to the assessment of and agrees to pay the civil penalty
as set forth in this CA/FO and consents to the other conditions sef forth in this CA/FO.
40. By signing this CANO. the Respondent certifies that the information it has
supplied concerning this matter was at the time of submission, and is, truthful, accurate, and
complete for each such submission, response and statement. The Respondent realizes that there

are significant penalties for submitting false or misleading in Formation., including the possibility
of fines and/or imprisonment for knowing submission of such information.
41. "fhe EPA reserves the right to assess and collect any and all civil penalties for any
violation described herein to the.extentthat any information or certi fication provided by the
Respondent was materially false or inaccurate at the time such information or certification was
provided to the EPA.
42. Complainant and the Respondent agree to settle this matter by their execution of
this CA/FO. The parties agree that the settlement of this matter is in the public interest and that
this CA/FO is consistent with the applicable requirements of the CWA.
IV. Pavment
43. Pursuant to Section 309(g)(2)(B) of the CWA, 33 U.S.C. 1319(g)(2)(B), and
40 C.F.R. Part 19, and considering the nature of the violations and other relevant factors, the
EPA has determined that Seventy-five thousand five hundred dollars ($75,500) is an appropriate
civil penalty to settle this action.
44. The Respondent shall submit payment of the penalty specified in the preceding
paragraph within thirty (30) days of the effective date of this CA/FO via a cashier's or certified
check, payable to the order of "Treasurer. United States ofAni rica." The check shall reference
on its face the name of the Respondent and the Docket Number of this CA/FO. Such payment
shall be tendered to:
U.S. Environmental Protection Agency
Fines and Penalties
Cincinnati Finance Center
P.O. Box 979077
St. Louis, Missouri 63197-9000
45. At the time: of payment, the Respondent shall send a separate copy of tine check,
and a written statement that payment has been made in accordance with this CA/FO, to the
following persons at the following addresses:
Regional Hearing Clerk
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
and

Ms. Mary Nlattox
U.S. Environmental Protection Agency, Region 4
Water Protection Division
NPDES Permitting and Enforcement Branch
Municipal and Industrial Enforcement Section
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
46. The penalty amount specified above shall represent civil penalties assessed by the
EPA and shall not be deductible for purposes of federal taxes.
47. Pursuant to Section 309(g)(9) of the CWA, 33 U.S.C. § 1319(g)(9), failure by the
Respondent to pay the penalty assessed by the CA/FO in full by its due' date may subject the
Respondent to a civil action to collect the assessed penalty plus interest (at currently prevailing
rates from the effective date of this CA/FO). attorneys fees, costs for collection proceedings and
a quarterly nonpayment penalty for each quarter during which such failure to pay persists. Such
nonpayment penalty shall be in an amount equal to twenty percent (20%) of the aggregate
amount oFsuch penalty and nonpayment penalty which are unpaid as of the beginning -of such
quarter, In any such collection action, the validity, amount and appropriateness of the penalty
and of this CAVFO shall not be subject to review.
V. General Provisions
48, This CA/FO shall not relieve the Respondent of its obligation to comply with all
applicable provisions of federal, state, or local law, nor shall it be construed to be a ruling on, or
determination of, any issue related to any fs'deral, state or local permit. Other than as expressed
herein, compliance with this CA/FO shall not be a defense to any actions subsequently
commericed pursuant -to federal laws and regulations administered by the EPA.
49. Issuance of this CA/FO shall not be deemed as prohibiting. altering, or in any way
limiting the ability of the EPA to pursue any other enforcement actions available to it under law.
Such actions may include, without limitation, any administrative, civil, or criminal action to seek
penalties, fines, injunctive, or other appropriate relief, or to initiate an action for imminent and
substantial endangerment, under the CWA or any other federal or stale statute, regulation. or
permit.
50. Except as otherwise set forth herein, this CA/FO constitutes a settlement by
Complainant and the Respondent of all claims for civil penalties pursuant to the CWA with
respect to only those violations ,alleged in this CA/FO. Except as otlmvise set forth herein,
compliance with this CAIFO shall resolve the allegations of violations contained herein.
51. Nothing in this CA/FO is intended to nor shall be construed to operate in any way
to resolve any criminal liability of the Respondent, or other liability resulting from violations that
were not alleged in this CA/FO.

52. Each undersigned representative of the parties to this CA/FO certifies that he or
she is fully authorized to enter into the terms and conditions of this CANO and to execute and
legally bind that party to it.
53. This CA/FO applies to and is binding upon the Respondent and its officers,
directors, employees, agents, successors and assigns.
54. Any change in the legal status of the Respondent, including but not limited to any
transfer of assets of real or personal property, shall not alter the Rcspondent's responsibilities
under this CA/FO.
55. Each party shall bear its own costs and atturncy*s fees in connection with the
action resolved by this CANO.
56. In accordance with 40 C.F.R. § 22,51. the: individuals below are authorized to
receive service related to this proceeding:
For Complainant:
Patrick B. Johnson
Associate Regional Counsel
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
[phone]
For Respondent:
Adam G. Sowatzka
Partner
Kind; R Spalding LLP
l l80 Peachtree Street, N.E.
Atlanta, Georgia 30309-3521
[phone]
57. The parties acknowledge and agree that this CA/FO is subject to the requirements
of 40 C.F.R. 23.45(c)(4), which provides a right to petition to set aside a proposed CANO
based on comments received during the public comment period.
58, Pursuant to Section 309(g) of the CWA, 33 U.S.C. § 13 l9(g), and 40 C.F.R.
§ 22.38(b), Complainant represents that the State of North Carolina was provided a prior
opportunity to consult with Complainant regarding this matter.
59. Effwive upon signature of this CA/FO by the Respondent, the Respondent agrees
that the time period commencing on the date of its signature and ending on the date the EPA
receives from the Respondent the payment required by this CA/FO shall not be included in
I ()

computing the ntnning of any statute of limitations potentially applicable to any action brought
by the EPA related to the matters addressed in this CA/FO and that, in any action brought by the
EPA related to the matters addressed, the Respondent will not assert, and may not maintain, any
defense or claim based upon principles of statute of limitations, waiver, lathes, estoppel, or other
defense based on the passage of time during such period. If (lie EPA gives notice to the
Respondent that it will not make this CA/FO effective, the statute of limitations shall begin to
run again commencing ninety days after the date such notice is sent by the EPA.
V1. Effective Date
60. The effective date of this CAJFO shall be the date on which the CA/FO is filed
with the Regional Hearing Clerk.
AGREED AND CONSENTED TO:
BY THE RESPONDENT, CARGILL, INCORPORATED:
4'M Date: `
Don Camden
Commercial \tanager, East
Cargill, Incorporated
For COIMPLAINANT, U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 4:
Date:
Mary S. Walker
Director
Water Protection Division
U.S. EPA, Region 4

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
IN TIIE i19ATTER OF: )
CARGILL, INCORPORATED )
F'AYETTEVILLE, NORTH CAROLINA )
RESPONDENT. )
CONSENT AGREEMENT AND
FINAL ORDER
DOCKET NO. CWA-04-2017 4510(b)
FINAL ORDER
In accordance with the Consolidated Rules of Practice Governing the Administrative
Assessment of Civil Penalties, Issuance vf"Compliance or Corrective Action Orders and the
Revocation, Termination or Suspension of'Perinils, including Subpart 1, 40 C.F.R. Part 22, and
authorities delegated to me, the foregoing Consent Agreement.is hereby approved and
incorporated by reference into this Final Order. Pursuant to Section 309(g)(2)(B) of the CWA,
33 U.S.C. § 1319(g)(2)(B), the Respondent is hereby ordered to comply with the'terms of the
foregoing Consent Agreement.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Date:
V. Anne Heard
Acting Regional Administrator

�1
Docket No. CWA 04-20174510(b)
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the attached CONSENT
AGREEMENT AND FINAL ORDER in the matter of Cargill Incorporated, Docket No. CWA-
04-2017-4510(b) (riled with the. Regional Hearing Clerk on , 20 f 7) was smed on
2017, in the manner specified to each of the persons listed below.
By hand -delivery; Patrick B. Johnson
Associate Regional Counsel
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
By certired mail,
return receipt requested: Adam G. Sowatzka
Partner
King & Spalding LLP
1180 Peachtree Street, N. E.
Atlanta, Georgia 30309-3521
[phone]
Mike Randell, Stormwater Program Engineer
NC Division of Energy, Mineral and Land Resources
NC Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
Taby Vinson, Chief of Program.Operat ions
NC Division of Energy, Mineral and Land Resources
NC Department of Environmental Quality
1612 Mail Service Center
Raleigh, NCC27699-1612
Patricia A. Bullock
Regional Hearing Clerk
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
[phone]

cArfill,
April 10, 2017
Division of Water Quality
Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Delegation of Signatory Authority
Cargill Incorporated — Fayetteville, NC Facility Stormwater
General Permit NCG060000, CoC060047
Cumberland County
To whomever it May Concern:
APR 1) 2017 U
u
0i
0 OURC WATER RSS
4& BUFFER p S
• �RM17TIfV
As the Vice President, Eastern Regional Manager, Cargill Agricultural Supply Chain North America, I
hereby delegate responsibility, and authority, to Mr. Johan Clairet — Fayetteville Facility
Leader, to sign all required documents under the State of North Carolina NPDES Stormwater
Program.
Ifyou have any questions, please contact me at 919-329-5240 or David Helms at 910-223-6671.
Sin rel .
on Camden
Vice President, Eastern Regional Manager
Cargill Agricultural Supply Chain North America
Cargill, Incorporated
cc: Mike Lawyer, NCDENR -Division of Water Quality - Fayetteville Regional Office, 225
Green Street, Suite 714, Fayetteville, NC 28301-5043

April 10, 2017
Division of Water Quality
Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Delegation of Signatory Authority
Cargill Incorporated — Fayetteville, NC Facility Stormwater
General Permit NCG060000, CoC060047
Cumberland County
To whomever it May Concern:
As the Vice President, Eastern Regional Manager, Cargill Agricultural Supply Chain North America, I
hereby delegate responsibility, and authority, to Mr. Johan Clairet — Fayetteville Facility
Leader, to sign all required documents under the State of North Carolina NPDES Stormwater
Program.
Ifyou have any questions, please contact me at 919-329-5240 or David Helms at 910-223-6671.
Sin rel ,
on Camden Ark 2 2017 i
Vice President, Eastern Regional Manager
Cargill Agricultural Supply Chain North America
Cargill, Incorporated
cc: Mike Lawyer, NCDENR -Division of Water Quality - Fayetteville Regional Office, 225
Green Street, Suite 714, Fayetteville, NC 28301-5043

.• J�SEQ STgT�s
A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Tz REGION 4
o c ATLANTA FEDERAL CENTER
61 FORSYTH STREET
�FyrgL PROTEG�`o ATLANTA, GEORGIA 30303-8960
PEAR 2 0 2017
CERTIFIED MAIL 7016 1970 0000 8992 6991
RETURN RECEIPT RE UESTED
Mr. Johan Clairet RECEIVED
Facility Superintendent MAR 23 2011
Cargill Inc.
1759 Underwood Road DEP14i-LAND QUALITY
STORIVI'�1ATEn FR1111"TING
Fayetteville, North Carolina 28312
Re: Notice of Violation and Opportunity to Show Cause Pursuant to Section 309(a) of the Clean Water
Act (CWA), 33 U.S.C. § 1319
Cargill Inc., NPDES No.: NCG060047
Mr. Clairet:
On February 10, 2016, the U.S. Environmental Protection Agency Region 4 conducted a Compliance
Stormwater Evaluation Inspection (CSWEI) at the Cargill Inc. (Cargill) facility, located at 1754 River
Road, Cumberland County, North Carolina, 28312 for which Cargill is the owner and operator. The
purpose of the CSWEI was to evaluate Cargill's compliance with the requirements of Section 301 of the
Clean Water Act (CWA), 33 U.S.C. § 1311; the regulations promulgated thereunder at 40 C.F.R. §
122.26; and the State of North Carolina's General Permit to Discharge Stormwater, issued pursuant to
Section 402(p) of the CWA, 33 U.S.C. § 1342(p) for establishments primarily engaged in Food and
Kindred Activities, Permit No. NCG060000 (Permit).
The CSWEI inspection report was submitted to Cargill on March 23, 2016 for its review. The CSWEI
inspection report; the EPA's review of Cargill's response to the CSWEI inspection report, elated May 5,
2016; and EPA's review of Cargill's Stormwater Pollution Prevention Plan (SPPP), dated December
2015, have revealed that Cargill failed to comply with the requirements of Section 301 of the CWA. 33
U.S.C. §§ 1311; its implementing regulations at 40 C.F.R. § 122.26; and the Permit. Specifically, the
EPA hereby notifies Cargill pursuant to Section 309(a) of the CWA, 33 U.S.C. § 1319(a), of the
following violations:
Part I, Section B of the Permit states that "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."
At the " Environatental Pit No. 2 " area, a pipe from the facility was observed discharging into
an underground flowing stream. Water at the outlet of this pipe was very cloudy and bubbling.
This pipe is not listed in the SPPP or the facility's site ntap as a permitted outfall. Also, it is not
identified or listed in the SPPP as an allowable non-stormwater discharge. It is unclear as to
the drainage area or sources of this non-stormwater discharge observed in dry weather
conditions.
2. Part II, Section A, Paragraph ](a) of the Permit states that the SPPP shall contain: "A
general location map, showing the facility's location in relation to transportation routes and
Internet Address (URL) • http://www,epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer}

surface waters; the name of the receiving waters to which the stormwater outfalls discharge,"
and "accurate latitude and longitude of the points of stormwater discharge associated with
industrial activity," as well as "identify whether any receiving waters are impaired or if the
site is located in a watershed for which a TMDL has been established. "
A current review of the Waterbody listing status indicates that both the Locks Creek (Waterbody
ID: NC18-28) and Cape Fear River (Waterbody ID: NC18-(26)a) have on impaired designated
use of fish consumption with a Mercury TMDL. These two impaired waterbodies were not
discussed in the TMDL provision of the SPPP (Section 2.1.1) nor were they identified in a general
location snap.
Part 11, Section A, Paragraph 1(b) of the Permit states that the SPPP shall contain: "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
storm water discharge froin each outfall. "
a. The " V" area which contains exposed scrap materials and junk parts was not identified
and evaluated in the SPPP as a potential pollutant source.
b. The truck staging and parking area across Underwood Road was not identified and
evaluated in the SPPP as a potential pollutant source for sediment runoff.
4. Part 11, Section A, Paragraph I (c) of the Permit states that the SPPP shall contain: "A site
slap 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; site topography and finished grade; all drainage features and structures; drainage
area boundaries and total contributing areas 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. "
Ci. The 4 storm drains at the West side of the facility were not identified tit the SPPP and were
not depicted in the site map cis potential overflow/discharge points. According to the faciliti,
representative, they are designed to overflow during a heavy rain event through a concrete
berin structure into a conveyance that goes off -site.
b. The truck staging and parking circa across Underwood Road was not identified in the site
snap as (tit industrial activity area with a potential pollutant source for sediment runoff.
C. The catchment basin and the sand filter basin were existing stormwater BMPs that were
not depicted on the site snap.
Part 11, Section A, Paragraph 2 of the Permit states: "The Stormwater Management Strategy
shall contain a narrative description of the materials management practices employed which
control or minimize the stormwater Lrposure of significant materials, including structural
and nonstructural measures."
Section 4 of the SPPP did not include all the BMPs employed onsite. The sand filter basin for
stormwater treatment, the catchment basin installed as a result of benchmark exceedances, and
the mechanical sweeper used far housekeeping ivere BMPs that were not summarized in the
SPPP cis part of the Stormwater Management Strategy.
6. Part 11, Section A, Paragraph 8 of the Permit states: "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 pollutants to surface waters. All aspects of the SPPP shall be reviewed and
updated on an annual basis."
a. The 4 storm drains at the West side of the facility were designed to overflow during a
heavy rain event into a conveyance that goes off -site. These 4 storm drains and their
potential overflow points from the concrete berm structures were not listed in the SPPP as
permitted outfalls. It is unclear as to the site drainage area and the design storm event
conditions that would result in a discharge.
b. The 2 'x2'x2' catchment basin installed in December 2014 as a result of benchmark
exceedance was not added to the SPPP. The SPPP has no information on how the design
and operation of the catchment basin would reduce pollutant discharges through ozrtfall
FV002.
C. The "V " area with its storage of junk parts, and the truck staging area across Underwood
Road were not evaluated in the SPPP as potential sources of exposed material which may
have a significant effect on the potential for discharge of pollutants to surface waters.
d. The BMPs in Section 4 of the SPPP did not identify and discuss the design and operation
of the sand filter basin for stormwater treatment.
e. The facility's exposed material list in Table 2-1 of the SPPP does not reflect current site
conditions. Several locations for these exposed materials have changed (e.g., sulfuric acid
and the diesel tank).
f. The truck staging and parking area across Underwood Road was not evaluated in the
SPPP for erosion and sediment control.
g. Locks Creek (Waterbody ID: NC18-28) and Cape Fear River- (Waterbody ID: NCI8-
(26)a) have an impaired designated use offish consumption with a Mercury TMDL. The
TMDL Provision of the SPPP (Section 2.1.1) did not evaluate whether the discharges from
Cargill have any significant effect on these two impaired waterbodies.
Part Il, Section, B of the Permit specifies that stormwater samples shall be collected after a
dry weather interval of at least 72-hours front the previous storm event and within first 30
minutes of discharge first flush condition).
Sampling log does not record the time when discharge began. The only time recorded is the
time of grab sample. The facility did not have documentation of sampling within the first 30
minutes of flow (first flush condition).
8. Part II, Section B, Tier One of the Permit states: "If the first valid sampling results are above
a benchmark value, or outside of the benchmark range, for arty parameter at arty outfall;
Then the permittee shall conduct a stormwater management inspection of the facility, identify
and evaluate possible causes of the benchmark value exceedance, identify potential and select
the specific: source controls, operational controls, or physical improvements to reduce
concentrations of the parameters of concern, and/or to bring concentrations within the
benchmark range, implement the selected actions within two months of the inspection, and
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."
Exceedances of benchmark values occurred at Outfalls FV002, FV003, and FV004. The permit
requires Cargill to conduct a stormwater management inspection within two weeks of receiving
3

sampling results, identify and evaluate possible causes of the benchmark value exceedance,
card/or install stormwater BMPs in a tiered program. 1.
a. Outfall FV003 's benchmark exceedances were: 712112013 for COD & TSS, and
10/712013 for pH. A Tier I Checklist was completed only for the pH exceedance and
the date of the inspection: was not recorded, yet it is required to take place within 2
weeks of the sample date. No specific controls or improvements were identified to
bring the concentrations within the benchmark range. No possible onsite causes were
evaluated; an assumption of rainfall pH was identified as the cause.
b. At outfall FV002, benchmark exceedances occurred 17 times out of 23 sampling
events for COD (73% exceedance rate), and 12 times out of 23 sampling events for
TSS (52% exceedance rate). COD exceedances ranged from 175 to 725 mg1l (tip to
504% over the benchmark value) and TSS exceedances ranged front 104 to 1640 mg1l
(up to 1,540% over the benchmark value). The 101712013 Tier I Checklist for TSS
and COD exceedances lacked necessary information. The checklist said to "Identify
and evaluation of possible causes. Explain. " The response was "Post Shutdown
Equipment in Area. " This does not evaluate or explain the exceedance of TSS or
COD. The date of the inspection is not recorded, yet it is required to take place within
2 weeks of the sample date, Also, in a 2014 feasibility.study, a catchment basin was
installed in December 2014. However, this catch basin has had no apparent impact
on reducing the COD and TSS exceedances at outfall FV002. The current plan is to
eliminate outfall FV002 and route all stormwater runofffrom outfall FV002 to outfall
FV003. It is unclear how outfall FV003 can meet its benchmark value after tying in
with outfall FV002 without additional BAIP practices and/or structural controls for
COD and TSS removal.
c. Out/all FV004's benchmark exceedances were: 511812013 COD, 41712014 COD &
TSS, 712112014 TSS. The facility conducted monthly benchmark sampling after the 2
consecutive TSS exceedances for August 2014-December 2015. The 417114 Tier 1
Checklist that was penforinned fo- TSS and COD exceedances lacked necessary
information. The date of the inspection was not recorded, yet it is required to take
place within 2 weeks of the sample date. The record said the storm water retention
basin was cleaned. This feature was not observed during the inspection, but a sand
filter was observed onsite. The possible cause for the high COD and TSS was
identified as heavy pollen.
9. Part II, Section B, Tier Two condition of the Permit specifies that for any two consecutive
benchmark value exceedances, Cargill should immediately institute monthly monitoring for
all parameters. Monthly monitoring shall continue until three consecutive sample results are
below the benchmark values.
Monthly sampling is required at outfall FV002 clue to chronic exceedance of the benchmark
values for COD and TSS in years 2013 and 2014. Sampling records reviewed during the
inspection were missing monthly sampling data for January, February, March and April, 2014.
4

10. Part III, Section C, Paragraph 1 of the Permit states: "Tile 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. "
During EPA 's on -site evaluation of pollutant sources and SPPP implementation, the following
operation and maintenance deficiencies were observed:
a. The covered loading/unloading area " B" has a fair amount of spilled materials on the
floor. This could result in vehicle tracking ofsolid material off -site and into road side
storm drains.
b. Material storage area has three uncovered dumpsters; two with organic materials and
one with trash materials.
c. EPA obsen�ed several areas where good housekeeping practices were deficient:
1. The grain drying area had grain dust and grain materials on the ground.
2. The raw soybean dump area had grain on the ground.
3. Exposed soybean meal storage with soybean meal and grain dust several inches thick
was observed on the ground.
4. The material storage area had various materials on the ground.
d. Secondary containment for the chemical tote storage was V full of liquid. The lock at the
drain pipe was unlocked. This can potentially cause site personnel to accidentally release
this liquid without properly evaluating the pollutant level.
e. EPA observed several areas where sediment & erosion controls were lacking:
1. EPA observed sediment deposit in the roadway and in the ditch at the River Road
entrance area.
2. Construction activity along Building I does not appear to have the necessary state
permit for construction activity due to the facility having more than 1 acre
cumulatively disturbed. No perimeter BMPs were observed, resulting in uncontrolled
sediment loss outside of the construction area.
3. Extensive sediment accumulation was observed surrounding outfall FV002 which can
contribute to high TSS benchmark levels.
4. Small rills were observed in several areas along the " V " area.
5. The truck staging and parking area across Underwood Road was not evaluated in the
SPPP for erosion and sediment control.
f Concrete staining from past spill draining into a ditch along Underwood Road was
observed.
g. The "V " area has a large amount of unprotected and uncovered used equipment and
parts. Staining on the ground was observed in many spots throughout the disposal area.
11. Part III, Section D, Paragraph 2 of the Permit states: "For each nteasurentent or sample
taken pursuant to the requirement of this general permit, the permittee shall record... the
individual who performed the sampling or measurements. "
Chain of Custody forms do not have signatures of all individuals who handled the samples.
12, Part III, Section D, Paragraph 4 of the Permit requires that test procedures for the analysis
of pollutants conform to 40 C.F.R. 136. The approved procedure for analyzing pH ill 40
C.F. R. 136 is the electrode method.
5

Laboratory bench data showed that the test procedure for pH was conducted with a paper pH
test strip instead of the approved electrode probe/meter equipment.
Until compliance with the CWA is achieved, Cargill is considered to be in violation of the CWA and
may be subject to enforcement action pursuant to Section 309 of the CWA, 33 U.S.C. § 1319. This
Section provides for the issuance of administrative penalty and/or compliance orders and the initiation of
civil and/or criminal actions.
The EPA also requests that representatives of Cargill contact the EPA within seven (7) business days of
receipt of this letter to arrange a meeting in this office to show cause why the EPA should not take
formal civil enforcement action against Cargill for these violations and any other potential violations,
including the assessment of appropriate civil penalties. Also, Cargill should discuss the status of ongoing
SPPP update, sampling monitoring procedures, additional BMP implementation, and outfall evaluations
as detailed in its response to EPA's CSWEI dated May 5, 2016. In lieu of appearing in person, a
telephone conference may be scheduled. Cargill should be prepared to provide all relevant information
with supporting documentation pertaining to the violations, including but not limited to any financial
information which may reflect an inability to pay a penalty. Cargill has the right to be represented by
legal counsel.
All information submitted in response to this letter and/or during the show cause meeting must be
accompanied by the following certification that is signed by a duly authorized official in accordance
with 40 C.F.R. § 122.22:
"I certify tinder penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designcd 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 or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are. significant penalties for
submitting false information, including the possibility of fine and imprisonment for
knowing violations."
Please be aware that the EPA may use information provided during the meeting or telephone conference
in any enforcement proceeding related to this matter. Failure to schedule a show cause meeting may
result in a unilateral enforcement action against Cargill. Notwithstanding the scheduling of a show cause
meeting, the EPA retains the right to bring further enforcement action under Sections 309 of the CWA,
33 U.S.C. § 1319, for the violations cited therein or for any other violation of the CWA.
In addition, the Securities and Exchange Commission (Commission) requires its registrants to
periodically disclose environmental legal proceedings in statements filed with the Commission. To assist
Cargill, the EPA has enclosed a document entitled Notice of Securities and Exchange Commission
Registrants 'Ditty to Disclose Environmental Legal Proceedings.
Please contact Mr. Kenneth Kwan at [phone] or LCDR Tara Houda at [phone] to arrange
a show cause meeting or if you have any questions or concerns.
0

Legal inquiries should be directed to Mr. Patrick B. Johnson, Assistant Regional Counsel, at
[phone].
Sincerely,
Maqyv... " alker
Director
Water Protection Division
Enclosure
cc: Mr. Bradley Bennett
North Carolina Department of Environmental Quality
7

cdN111'"
July 25, 2016
Division of Water Quality
Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699- 1617
Subject: Delegation of Signatory Authority
Cargill Incorporated -Fayetteville, NC Facility Stormwater
General Permit NCG060000, CoC060047
Cumberland County
To Whomever it May Concern:
As the Vice President, Eastern Regional Manager, Cargill Agricultural Supply Chain North America, I hereby
delegate responsibility, and authority, to Mr. Walt Halley -Crush Superintendent, and Mr. Brent
Chinchar, Refinery Superintendent, to sign all required documents under the State of North Carolina
NPDES Stormwater Program.
Ifyou have any questions, please contact me at 919-329-5240 or Scott Schuelke at 910-433-4954.
Sincerely,
4(na den 1JuL2 7 2016
dent. Eastern Regional Manager I0' (�,�,�/LJ
Cargill Agriculturd Supply Chain Nordi America
Cargill, Incorporated
cc: fvtik'e Lawye Environmental Program Consultant, North Carolina Department of Environment & Natural
Resources Division of Energy, Minerals, and Land Resources, Fayetteville Regional Office, 225 Green
Street, Suite 714, Fayetteville, NC 28301-5095

cAr6rill"
July 25, 2016
Division of Water Quality
Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699- 1617
Subject: Delegation of Signatory Authority
Cargill incorporated —Fayetteville, NC Facility Stormwater
General Permit NCG060000, CoC060047
Cumberland County
To Whomever it May Concern:
As the Vice President, Eastern Regional Manager, Cargill Agricultural Supply Chain North America, I hereby
delegate responsibility, and authority, to Mr. Walt Halley —Crush Superintendent, and Mr. Brent
Chinchar, Refinery Superintendent, to sign all required documents under the State of North Carolina
NPDES Stormwater Program.
lfyou have any questions, please contact me at 919-329-5240 or Scott Schuelke at 910-433-4954.
Sincerely,
4�na den
dent, Eastern Regional Manager
Cargill Agricultural Supply Chain North America
Cargill, Incorporated
cc: Mike Lawyer, Environmental Program Consultant, North Carolina Department of Environment & Natural
Resources Division of Energy, Minerals, and Land Resources, Fayetteville Regional Office, 225 Green
Street, Suite 714, Fayetteville, NC 28301-5095
.sla! 2 8 � fl
Zt1,�
srpRlLj Q '3 pQ A, lTy

AWIFA
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Joshua Small
Cargill Incorporated
1754 River Rd
Fayetteville, NC 28302
Dear Permittee:
Division of Water Quality
Charles Wakild, P. E.
Director
December 4, 2012
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Fayetteville plant
CDC Number NCG060047
Cumberland County
In response to your renewal application for continued coverage under stormwater General Permit NCG060000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCG060000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current 5PPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last CDC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://portal.ncderr.org/web/wq/ws/su/npdessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N, Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 91 M07-6492
Internet: www ncwaterguality.org
An Equal Opportunity L Affirmatve Adlion Employer
onr NthCarolina
Nati rally

Joshua Small
December 4, 2012
Page 2 of 2
Some of the changes include:
• Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections 6, C: Failure to perform analytical stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections 8, C: A lower TSS benchmark of 50 mg/I for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections 8, C, The monitoring parameter Oil & Grease (0&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections 8, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections 8, C: The term "Representative Storm Event" has been replaced by "Measurable Storm
Event." A measurable storm event is defined in the permit.
• Section D: If the permittee fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Units website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal request prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,
for Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files
Fayetteville Regional Office

s
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060047
STORMWATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Cargill Incorporated
is hereby authorized to discharge stormwater from a facility located at:
Fayetteville plant
1754 River Rd
Fayetteville
Cumberland County
to receiving waters designated as Cape Fear River and Locks Creek, a class C waterbody in the
Cape Fear River Basin in accordance with the effluent limitations, monitoring requirements,
and other conditions set forth in Parts I, 11, 111, and IV of General Permit No. NCG060000 as
attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 4th day of December, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

08/09/2012 THU 16!12 FA%
s
August 9d', 2012
Mr. Dale Lopez
NCDENR, Division of Water Quality
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
RE: Cargill, Incorporated -- Fayetteville, NC
10 gallons Soap Stock Spill Off -Site /August 2"', 2012 Incident Report # 201201332
To whom it may concern:
Cargill, Incorporated (Cargill) is submitting this written notification as a follow-up to an off -site
soap stock spill that occurred at our Fayetteville, NC facility on the evening of Thursday August
2'd, and was communicated to your office via telephone that following morning.
Process Description
Cargill operates a soybean oil extraction and vegetable oil refining process at 1754 River Road,
Fayetteville, NC 28312_ During the vegetable oil refining process, soap stock is produced as a
byproduct of our refining process, Soap stock is normally stored in process tanks around the
Refinery facility.
Event Description
At 1:00 PM, the Refinery Operator notifies Refinery Supervision that there is an issue with the
Dissolved Air Flotation (DAF) unit, It had become overloaded, and would not separate
efficiently. The plan was to dump the DAF to the mop pit, and clean out the DAF, During this
process, the soap stock that was located in the DAF, was dumped to the mop pit for re-
processing, which is a normal cleaning task for this piece of equipment.
Zp02/i 07
At 3:30 PM (August 2°d),a heavy rain event started, with periods of heavy rain falling for several
minutes, According to Weather Underground, there was a 1.64" rain event duling this time
period, which is not atypical of this area, The heavy rains around the plant caused our mop pit to
overflow.
At 4:41 PM, an employee discovered soap stock on Environmental Pit #i, and immediately
walked over to Environmental Pit #2, where additional soap stock was discovered. The overflow
gate to the Gum Log Creek was closed, and the stoma water pumps that were pumping to the
mop pit were shut off to lower the level. The appropriate personnel were contacted to start the
clean up around the mop pit, Environmental Pit #1, and Environmental Pit 92.

0�/09l2012 THU 16! 12 FAX UOWC07
At 4:47 PM, an employee discovered soap stock on the Gum Log Creels, off Cargill's property
across the railroad main line rail tracks. The water current was very strong, but the soap stock
was not moving down stream, and appeared to be collecting in three clumps around a log.
At 5:02 PM, NRC was contacted of the situation.
At 5:07 PM, our spill response contractor was notified of the situation, and they were deploying
a vehicle to the Cargill site,
At 5:07 PM, two Cargill employees walk downstream from Cargill's property approximately 100
yards, and find notrace of soap stock in the Gum Log Creels at that location, Two additional
employees drive approximately one quarter mile downstream, and walk upstream approximately
two hundred yards, and find no trace of soap stock in the Gum Log Creek at that location. To
clarify, the soap stock did not travel any further downstream the Gum Log Creek than
approximately 50 yards off --site of Cargill's property, and did not reach the Cape Fear River.
At 5:48 PM, the spill response contractor arrives on site to start the cleanup.
At 7:51 PM, 100% of the soap stock that was discovered on the Gwn Log Creek was recovered,
and the spill recovery was completed. .
Notifications
National Response Center — 5:02 PM: Notification of event to NRC (Rpt # 1019814) was
delayed beyond the 15 minute requirement, as location personnel were working to ensure the
spill Was contained as much as possible.
Corrective Actions
Cargill is committed to make sire this type of incident does not happen again. A Root Cause
Analysis was completed on the incident, and the following corrective actions will be completed
by the following dates.
I. By August 31, 2012, develop and implement a Rain Event Standard Operating Procedure
(SOP). This procedure will detail what tasks to complete when a rain event occurs on
this site. As a final stop gap measure, if necessary, Cargill will shut down the entire
process, to ensure we do not negatively impact the environment.
2. By August 24, 2012, install automation to make both the mop pit Hi Level and Hi Hi
Level alarms audible alarms, and make these alarms automatically resetting every five
minutes, to prevent somebody from accidently silencing the alarm.
3, By September 28, 2012, install automation to interlock the mop pit Hi Hi Level alarm
with the different plant areas, so the area pumps will direct rain water to the rain water
storage basin.

14044i uu'l
Summary
The Cargill Fayetteville facility had an soap stock spill off site on August 2, 2012. The soap
stock is a byproduct of our vegetable oil refining process. once discovered to be off -site, the
source of the spill was safely stopped, and the spill contained. Cargill contracted with a spill
response contractor, and 100°10 of the soap stock that left the site was recovered. There are no
known or anticipated acute or chronic health risks associated with this spill.
Please contact me at [phone] with any questions regarding incident.
Sincerely,
CARGILL, INoRATED
JoshU
Facili

08/09/2012 THU 16:13
08/03/2012 13:04
FAX
9104860707
NC DENR
Z005/007
PAGE 02/04
oi WAT�740
incident Report
a -c
Report hlumbcr: 201201332
Incident Type: Spill (011, Chemical, non -sewage) Gtr-9lte Contsot:
Category: Incldant
FinWMWILest Name:
Incident Started: 08/02/2012
Company Name:
County: Cumberland
Phone;
City:
Pagerkobtle Phone:
1
Farm pt
Reapnrteible Party:
Reported By;
Owner.
FIrstUd/Labt (tome;
Merit Grose
Permli:
R Cempeny Wme:
Fadlity:
Addrese,
Cargilllno
FM Name:
11734 Rlvor Rd
Middle Name;
City/SWer0p:
Fayetteville NC 28312
Last Name:
phone;
(010)d334W
Address
Pager/Mobile Phone.
I
city/Rate/zip:
Phone:
mufarlal Category: Estimated W. UOM
DDAWSS Declrn21
Latitudo:
Longltudet
L.ocatlon of Incldant' CWOIl lira
Address: 1754 Rlyar Rd
Citylsuteop Fayettevillc NC 28312
Chemical Name Reportable ter. Iba. Reportable Uty, "S.-
Position Method:
Potritlon AceLIMOy:
Posttfan Datum:
Report Crested 08/03/12 12:28 PM Page I

05/09/2012 THU 16:13 FAX
i9B%83/.2012 13:04 9104868707 NC DENR
Cause/Observation; plrecttonb;
Heavy rains aeveod 10 gelbna of snap dark {byprowuef} o
leave the mop pil end flaw Into Gurnfog Ganef and ietbr Into the
Ceps Farr River,
U006/007
PAGE 03/04
Aotion Talmn- Commants:
Called In to the National RaspvnSo Center (800) 42+6002 at The wnVany will revlaw and improve the pr*$Ont ayststn, install high
4:04 PM on 08-09.2012. Scooped up the mWdues and plaosd in lava! alarm In the map pit for heevy rain *vent, faroute Mtn flows,
begs and Into a wants bin r*r dlepoul,
Incident Questions:
Did the Meterlal raaoh the Surfeoa Water? Unknown Commyonoe :
Surfnca Water Name? _
Did the Spill result In a Rah kill? Unknown Estimated Number offish?
If the Spill was from a atorege tank Indlwte type.
—_, (Above around of Under Ground)
Containment? Ur}krlawn
Cleanup Complete? Yes _
Water supply Walla within ISOOR : Unknown Groundwater Impacted : Unknmrn
went Type Event Data Blue Date Comment
Requef tad Add1bonel Information Information from Carglil 00ncemin
Report Entered 2012-CM312:16;33
Report Rscnived 2012-08-03 00:24.00
Referred to Reglonal Ot#ias - Primary Contract 2012-08.03 09,24.00
Report Created 08ro3112 12:7.8 PM age 2

09/09/2012 THU 16:13 FAX
Vag 03/2012 13:04 9104860707
2001/007
NC DENR PAGE 00/84
Incident dosed
Inoldent 5tarl
Standard Agancled Notlfledt
agency Name phone
Other Agencies Notified:
Agency Namo Phone
DWQ Information:
2012-06-0312:00:oo
2012-08-02 04:04:00
First Name Mi. Lest Name Contact Date
First Name M.I. Last Noma Contact bate
Report Taken By; Report Entered sy: Regional Contact,
Dale Lopez Dole Lopez dale Lopez
Phone:
DateITirima: 2012-00-03 09:24-00 AM 2012-08,0312:18:33 PM 2012:08-03 00,24:00 AM
Rderred Via:
Did DWQ requaat an additional written report?
It yoe, What additional InMimatlon la needed? Information ftra CRraill cemmming dotal la of the spill onri concerning a pl.
Report Crested 08M3/12 12:37 PM Pegs 3

IPPA
NC®ENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Joshua Small, Facility Superintendent
Fayetteville plant
1754 River Rd
Fayetteville, NC 28302
Dear Permittee:
Division of Water Quality
Charles Wakild, P.E.
Director
March 5, 2012
Subject: NPDES Stormwater Permit Coverage Renewal
Fayetteville plant
COC Number NCG060047
Cumberland County
Dee Freeman
Secretary
Your facility is currently covered for stormwater discharge under General Permit NCG060000. This permit expires on
10/31/2012. The Division staff is currently in the process of renewing this permit. When a draft is available for
notice and public comment, it will be posted on our vrebsite at http://portal.ncdenr.org/web/wq/ws/su/public-notices.
Please continue to check this website to review and comment on proposed changes to the permit. Once the permit
is reissued, your facility would be eligible for continued coverage under the reissued permit.
To assure consideration for continued coverage under the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal of your permit. Enclosed you will find a Permit Coverage Renewal Application Form. The
application must be completed and returned by May 4. 2012, Letters confirming our receipt of the completed
application will not be sent.
Failure to request renewal within the time period specified may result in a civil assessment of at least $250.00.
Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your
facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to $25,000 per day.
"No exposure exclusion" is now available to industrial facilities in any of the categories of "storm water discharges
associated with industrial activity," (except construction activities). If you feel your facility can certify a condition of
"no exposure", i.e. the facility industrial materials and operations are not exposed to stormwater, you can apply for
the no exposure exclusion. For additional information contact the Central Office Stormwater Staff member listed
below or check the Stormwater Permitting Unit Web Site at http://portal.ncdenr.org/web/wq/ws/su/npdessw#tab-5.
If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed
Rescission Request Form. Mailing instructions can be found on the bottom of the form. You will be notified when
the rescission process has been completed.
If you have any questions regarding the permit renewal procedures please contact Bill Diuguid of the Central Office
Stormwater Permitting Unit at [phone].
Sincerely,/
Bradley Bennett
Supervisor, Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone:91MOTE300 L FAX: [phone] Customer Service: l $77-623-6748
Internet: www.ncwaterquality.org
An Equal opportunity 1 Affirmative Action Employer
One
NorthCarolina
naturally

wA T4; G Permit Coverage
y Renewal Application Form
° National Pollutant Discharge Elimination System Certificate of Coverage Number
Stormwater General Permit NCGO60000 NCG060047
The following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/ additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information
Owner / Organization Name:
Owner Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
* Reissued Permit will be mailed to the owner address
Cargill Incorporated
Joshua Small, Facility Superintendent
1754 River Rd
Fayetteville, NC 28302
910-433-4922 Ext.
Facility/Permit Contact Information
Facility Name:
Fayetteville plant
Facility Physical Address:
1754 River Rd
Fayetteville, NC 28312
Facility Contact:
Joshua Small, Facility Superintendent
Mailing Address:
1754 River Rd
Fayetteville,NC 28302
Phone Number:
910-433-4922 Ext.
Fax Number:
E-mail address:
Discharge Information
Receiving Stream:
Stream Class:
Basin:
Sub -Basin:
Number of Outfalls:
CAPE FEAR RIVER
C
Cape Fear River Basin
03-06-15
Impaired Waters/TMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes ❑ No ❑ Don't Know
for information on these waters refer to http.y/hlo.enrstate.nc.us/su/Impaired Waters TMDL,/
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and
belief such information is true, complete and accurate.
Signature
Print or type name of person signing above
Date
Title
Please return this completed renewal application form to: SW General Permit Coverage RenewalStormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
December 4, 2012
Joshua Small
Cargill Incorporated
1754 River Rd
Fayetteville, INC 28302
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Fayetteville plant
COC Number NCG060047
Cumberland County
Dear Permittee:
In response to your renewal application for continued coverage under stormwater General Permit NCG060000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCG060000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new. permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://portal.ncdenr.org/weblwglws/sulnpdessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone [phone] FAX! 919-807-6492
Internet; www.ncwaterguad!1y,ur
Qn.:
Noi-Marolina
;.i Equ_, Oppodumty 1 hff ,,,loll „^. Act, „ Employer

Joshua Small
December 4, 2D12
Page 2 of 2
Some of the changes include:
• Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections B, C: Failure to perform analytical Stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections 8, C: A lower TSS benchmark of SO mg/I for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections 8, C. The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections 6, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections 8, C: The term "Representative Storm Event" has been replaced by "Measurable Storm
Event." A measurable storm event is defined in the permit.
• Section D: If the permittee fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal request prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,
for Charles Wakild, P.E.
cc: DWQCentral Files
Stormwater Permitting Unit Files
Fayetteville Regional Office

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060047
STORMWATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Cargill Incorporated
is hereby authorized to discharge stormwater from a facility located at:
Fayetteville plant
1754 River Rd
Fayetteville
Cumberland County
to receiving waters designated as Cape Fear River and Locks Creek, a class C waterbody in the
Cape Fear River Basin in accordance with the effluent limitations, monitoring requirements,
and other conditions set forth in Parts 1, 11, II1, and 1V of General Permit No. NCGO60000 as
attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 4th day of December, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Southeastern $oil & Environmental Associates, Inc.
P.O. Box 9321
.1�_ NC,28311
Rtmelr-ax C41 6;1 622-4U0
Email rrW&e1agautheastamso. C=
March ZZ_20.1 I (revised)
'Alr. Bi-6d Rude
-Prii i Enpne;-,
;Ca.r
. gitl "Grain & Oi ls=ls
1.7 54. ; River, ad
Fjyeme'yi tfe;. N-.C-. 28312
'Re.- Ntail0wedand investigation and'delineatiol ' k, p6rilon df (Albert. Smilh Prc)*rty
(PIN 0448-6&-04l4-),-. River Road; Cumki-land.Courlty, North, Carolinia
Dcar,Mr. Rude;
A site: investigation, and wetland delineation -has been conducted forthe above:Ircferenced
property. Tb'e purpose.of the. investigation was.to- determine the exi kcnCC-and,cxtcnt-of
Micd&W Wetki6ds kid/6 gmms-under.
zirca.s.. that"exhi bit' r,
ib" n A0 :of:th'c'Cfcan Wa't& Act, neallbas
LW&fe.n-iadoin-a-ccorda'n'ce-witt ihc 1987.1US,Ariny`Cdr 's s p, bff�gii4een
Dclinexion--ManuaL. We1ave received roncnrienci-_kom-te USACOE.(W
sttach�41,
Tha
d'stre. �fi6d`:,o`n,it�prpparty.
:'
of thc .�Ujw- p.rokrty' Areas of wetlands'ms-were i�e�
'rhe bou��ari-e's':W"erie.c eliReated on the- rouiW, by. placilg flagong.oT pin,flaW,(pink-glo)
.alone..Ihe,perimeter. and,.hurnbihrig Lhe'flags Qonxw&ly,as annolaitcd.6n th&.CP map
C rke).
CU
There are two am,-wof wctlands-nolcd on the majy-(B,.Q There is -also one-
-streaWwaters, noted- on -the, ma the
p (A)., The area
�8 we and t h a t p mvi . des a�..y 1`01-09jq
bbtto 111'kda 1n'a'n`nWe .'. ditch.. ("bki fiy4r6tpgj)
ne cuo'" ce"n:wttian"waier�..(o'fi s_-ite),-
.As we previously discussed. niltigatitow(or-&,in itca.of).yy-ould be roquired,tq'i.mpact ;any
Oif thesc-amas. St -ream impaqts.m be as MU _ph.as $339',00p& lii%L-4r-fb't (ihiere s
le area,4 'Wet
:appT ;k p..
pxim�tely. I �300'lidear fee ' t ' �b ' f sti 6mir(' anas mi,!ga lofk,.
'iitiq, tbs&W.000.00/ac�6 (" '1/4' ne
9�1- -�n& in aae i remen Noneof thiw fi it
Sop -MITE FVALUAn6N • SOIL PHYSICAL
AL ANALYSIS - t-AhD USErSUBDIVIMON KMNING
GROUNDWATER DRAINAGENCUNDING SURFACSrSUSSUPFACE WkqTg TRRATMENT SYSTEMS.:EVALUATIOM 1 DEMN

n ,or pc7nit-.ke§. O'uM6uOyJt i�r&ild tktopiopriatc arrodi5sibly
required'(USACOC- or.NC-DWQ) to,av6id'Or-nUMM&7.e-any impacts:to,wctlanr�wateT3,
-is -f nd N C-Di�bion
-A�y.-proposed impar, milt, req�ire:.appropn:a'te,p�irnii�ts. �qni',US�kCOF-'a --.
;SS A►=appn ci�lus the pportututytc):serve-youln�thisniamer. PIcw-ofcd'fre.e(q,c;e.IIwith
qucs6ohs'.
f.f% ..
N ZZI<- Aa m c

cm
e#1aihdJVVWs; Delineation-;Gi1be'rt.,5mith Property (Revised)
Cumberland County;; NC'
1J$ SISLe F'fano f 3 £,.CZ4W ,:d;B00 co/r�l / Ss51
L_..,; _ BPS' Fhi:lrijnae�°:ar::ea
us 8urv'l "PC. '0Trimbk
'SMMTE EV413hF!CN • S4iL E'HYS'61 ANAL YMS LAN' l?{U$15UBiriVISIL,'Ct PLANNING
C,Ad6k,-YvATER 0.14ALVAG&WOU1:M"i • SURF'ACEISUB.%SFACEVASTE TSF-ATM" ENT SYSiFMS. EVALUAiIf:*14 $ DESIGN

Cargill, Inc.
Fayetteville, NC
Elevator Expansion Project — Phase 2B
AMEC Project 168038
May 17, 2011
10:00 AM EDT
AGENDA
1. Cargill Facility Expansion
a. Site Walk
b. Proposed Facility Expansion Footprint
c. Discussion of Build -out Phases
2. Wetland/Stream
a. Impacts — Roadway and Facility
b. Permits
c. Mitigation
d. Timeline
3. Stormwater
a. Preliminary Plan Review
b. Permits
c. Monitoring requirements
d. Timeline
4. Sediment and Erosion Control
a. Permits
b. Monitoring requirements
c. Timeline
5. Other comments/questions
6. Action Items

a
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ROUND STORAGE
PRELIMINARY CONFIDENTIAL
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FAYETiENLLE, NC GOSCNA
SP-RS-DI

4
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ii� +�' ! �'�, �a.�y �'.:_ �� �t -4 r �t4_ s�,�• �1. �� �}, `����{'}.y,�.! fn"r! rt�ri• 'a., tJi�; -
L'
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.. .I r
A
14'`'M..a—r•-> .:.�r Cy"' 7^c'. Y rae _ ,jY rr�, s J
ANION 10"17
VISO
Vr
�, �� _ � ,yiJ a � � t tSr• _�ry� � F„Zn , � r i � � � J ^`�'
�r .�'!:i'if. �, i I � =I"" r� v; a_.�' � "�.� ••t t� «i p r�'�r� ,.I r�
CLIENT: SITE LOCATION:
AMEC Earth 8f Environmental - Figure No.
2200 Gateway Centre Bvd, Stite 205 Cargill Proposed Expansion Facility
Morrisville, NC 27,%0 Cargill River Road and Underwood Road
(P19)447-275C Fayetteville, North Carolina
ATITLE:
t inch = 300 feet DATE: May 16, 2011 PROJECT: S66790000
�Site Layout Map RAWN BY: C. McClelland CHECKED BY. Bennett
P.IProjectFleslCapill%Fayetteville%Permittirg Phase 56579000058_cad and GISlxetlartd sand sNemaps

Cargill, Inc.
Fayetteville, NC
Elevator Expansion Project — Phase 2B
AMEC Project 168038
May 17, 2011
10:00 AM EDT
AGENDA
1. Site Walk
2. Wetland/Stream
a. Impacts — Roadway and Facility
b. Permits
c. Mitigation
d. Timeline
3. Stormwater
a. Preliminary Plan Review
b. Permits
c. Monitoring requirements
d. Timeline
4. Sediment and Erosion Control
a. Permits
b. Monitoring requirements
c. Timeline
5. Other comments/questions

Lawyer, Mike
From: [e-mail]
Sent: Thursday, May 12, 2011 2:48 PM
To: Lawyer, Mike
Cc: Scott [e-mail]; Susanna—[e-mail]
Subject: RE: Cargill Fayetteville Sand Filtration System
The land disturbance is less than 1 acre." We do however have a silt fence around the construction area to retain
sediment onsite.
Kevin
From: [e-mail] [mailto:[e-mail]]
Sent: Thursday, May 12, 2011 2:35 PM
To: Huseby, Kevin T. - Kevin [e-mail]
Cc: Schuelke, Scott - Scott [e-mail]; Tarnowski, Susanna - Susanna Tarnowski(d)cargill.com
Subject: RE: Cargill Fayetteville Sand Filtration System
Thanks for the update. As a reminder of something we spoke about during my site visit, if land
disturbance/construction for the project is greater than 1 acre you must obtain an approved erosion control
plan through the Land Quality Section here in the regional office. Did you guys do that? Or, is the disturbance
less than 1 acre? Please keep in mind that if the project is less than 1 acre, which does not trigger the need for
an approved erosion control plan, you still may need to install erosion control measures to retain sediment
onsite.
Mike
Michael Lawyer, CPSWQ
Environmental Specialist
NCDENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]
e-mail: [e-mail]
*E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: Kevin Husebv(&carciill.com fmailto:Kevin Husebv(&caraill.coml
Sent: Wednesday, May 11, 2011 1:12 PM
To: Lawyer, Mike
Cc: Scott [e-mail]; Susanna Tarn owski(& ca rgi I Lcom
Subject: Cargill Fayetteville Sand Filtration System
Mike,

N
Just thought I would inform you construction has begun on our new stormwater filtration system. We will
continue to collect samples as we can during this period. If you have any questions, feel free to contact me or
Scott Schuelke (910-433-4954)
Kevin Huseby
Engineering CO-OP
Grain and Oilseed Supply Chain North America
Cargill
Direct: 910-221-1271
1754 River Road I Fayetteville, NC 28312
Confidentiality Note: This message is intended only for- the named recipient and may contain confidential, proprietary or legahy privileged
information. Unauthorized individuals or- entities are not permitted access to this information, Any dissemination, distribution or copying of this
information is strictly prohibited, if you have received this message in error, please advise the sender by reply e-mail, and delete this message
and any attachments Thank you.

NCDENR
North Carolina Department of Environment and
Division'of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
June 10, 2009
Mr. Joshua Small
Cargill, Incorporated
1754 River Road
Fayetteville, North Carolina. 1-8312
Natural Resources
Dee Freeman
Secretary
DENR-FRO
J J+ l G ',�,.:1
DWQ
Subject: General Permit No. NCG060000
Cargill, Incorporated — Fayettevide
COC NCG060047
Cumberland County
Dear Mr. Small:
In accordance with your request for a discharge permit correction received on May 28, 2009, we
are forwarding the attached Certificate of Coverage (COC). Your previous COC had indicated an
incorrect receiving water listed as Gum Log Creek. The receiving water has been changed to -Locks
Creek and the Cape Fear River to represent actual conditions.
If you have any questions concerning this revised COC, please contact Cory Larsen at telephone
number [phone] or [e-mail].
Sincerely,
for Coleen H. Sul ins
cc: Fayetteville Regional Office, Mike Lawyer
Central Files
Stormwater Permitting Unit Files
1617 Mail Service Center, Rafei h, North Carolina 27699-1617
location: 512 N. Salisbury St Ralegh, North Carolina 27604 One,1, 1
Phone: 91M07-63001 FAX: 919M7-64921 Customer Service: 1-877-623-6748 NOf l,l lCcarOli ilc`i..
Internet: www.ncwaterquality.org ;Vaturally
An Equal Opportunity 1 Affirmative Action Employer

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF'WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060047
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
in compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Cargill, Incorporated
is hereby authorized to discharge stormwater from a facility located at
Cargill, Incorporated - Fayetteville
1754 River Road
Fayetteville
Cumberland County
to receiving waters designated as Locks Creek and the Cape Fear River, both class C waters in
the Cape Fear River Basin, in accordance with the effluent limitations, monitoring requirements,
and other conditions set forth in Parts I,1I, III, IV, V, and VI of General Pennit No. NCCJ060000
as attached.
This certificate of coverage shall become effective November 1, 2007.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 1" day of November, 2007.
for Coleen H. Sullins., Director
Division of Water Quality
By the Authority of the Environmental Management Commission
®ENR-FInn 0
D WQ

LOCATION MAP:
Ttl
67 r, " TTF'['h
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INCGO60047
S
"P Scale 1.'20,000
Cargill, Incorporated
Cargill, Incorporated - Fayetteville
Lab tude: 350 05' 16" N
Longitude: 780 50' 44" W
Gounty: Cumberland
Receiving Stream: Locks Creek and Cape Fear River
Stream Class: C
Sub -basin: 03-06-15 (Cape Fear River Basin)
Facility Location

A7iA-
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
June 10, 2009
Mr. Joshua Small
Cargill, Incorporated
1754 River Road
Fayetteville, North Carolina 218312
Subject: General Permit No. NCG060000
Cargill, Incorporated — Fayetteville
COC NCG060047
Cumberland County
Dear Mr. Small:
Dee Freeman
Secretary
In accordance with your request for a discharge permit correction received on May 28, 2009, we
are forwarding the attached Certificate of Coverage (COC). Your previous COC had indicated an
incorrect receiving water listed as Gum Log Creek. The receiving water has been changed to Locks
Creek and the Cape Fear River to represent actual conditions.
If you have any questions concerning this revised COC, please contact Cory Larsen at telephone
number [phone] or [e-mail].
Sincerely,
for Coleen H. Sul ins
cc: Fayetteville Regional Office, Mike Lawyer
Central Files
Stormwater Permitting Unit Files
1617 Malt Service Center, Ralsgh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 �TOlng
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 1 � OIffi C ciro fi n a
Internet: vrww.ncwaterquaiiry.org a �}���/N� //� ,
An Equal Oppodunity 1Affrmative Action Employer � �! iL Al

STATE OF NORTH CAROLINA
DEPARTMENT_ OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060047
STORMWATER DISCHARGES
NATIONAL POLLUTANT, DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Cargill, Incorporated
is hereby authorized to discharge stormwater from a facility located at
Cargill, Incorporated - Fayetteville
1754 River Road
Fayetteville
Cumberland County
to receiving waters designated as Locks Creek and the Cape Fear River, both class C waters in
the Cape Fear River Basin, in accordance with the effluent limitations, monitoring requirements,
and other conditions set forth in Parts I, 11, III, IV, V, and VI of General Pen -nit No. NCG060000
as attached.
This certificate of coverage shall become effective November 1, 2007.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this I" day of November, 2007.
for Coleen H. Sullins., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

E
LOCATION MAP:
3_ 1
L„ r `• - y -Jlr 5r -
d'
.` 3R, Y h -1 w w P r� � - • ''S4 NO
tEE' N r�C3�g�J'A.� - e
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ay% i�6 4i g � Ce fil
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1NCG060047
Map 5'cale 1:217,000
Ca rgill, Incorpora ted
Ca rgill, Incorpora ted - Fayetteville
Lab tide: 35° 05' 16" N
Longitude: 781150' 44" W
County: Cumberland
Receiving Stream; Locks Green and Cape Fear River
Stream Class; C
Sub -basin: 03-06-15 (Cape Fear River Bain)
irr1�
Facility Location

Larsen, Co
From: Lawyer, Mika
Sent: Friday, June 05, 2009 12:56 PM -
To: Larsen, Cory
Subject: Rll: Cargill, Inc - ✓:ayettavk e
Cory,
I'm OK with designating their receiving stream as a UT to Locks Creek, a Class C water. However, the other stream is
actually called Gum Log Canal (not Gum Log Creek) and the stream classified as SC and HQW is Gum Log Branch in
Brunswick County. So either Gum Log Canal or Locks Creek, whichever we decide (its not really all that clear.based on
the topo), they're both Class C waters.
Mike
Michael Lawyer
Environmental Specialist
NCDENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]
e-mail: rnike.latiy er ncdenr. ov (please note that my e-mail address has changed)
*E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Larsen, Cory
Sent: Tuesday, June 02, 2009 3:58 PM
To: Lawyer, Mike
Subject: Cargill, Inc - Fayetteville
Mike,
Cargill in Fayetteville sent us a letter regarding their outfalls (see attached letter). They feel their receiving water is
incorrect on their NCG06 COC. After looking at the layout and to,po myself (attached), I agree with them. I'm not sure if
FRO wants to verify this physically orjust review and if satisfied, I'll make the revision, and send out a new COC as
appropriate.
Let me know how I should handle this issue. Thanks.
Co ry
Cory Larsen
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit ,
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N, Salisbury St, Raleigh, NC 27604 `
Phone: [phone]
Fax: [phone] '
i

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STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060047
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215. I, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
CARGILL INC'
is hereby authorized to discharge stormwater from a facilily located at
CARGILL INCORPORATED
RIVER RD
FAYETTEVILLE
CUM BERLAND COUNTY
to receiving waters designated as Gum Log Creek, a class SC SW HQW stream, in the Cape Fear River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, 1I, III,
IV, V, and VI of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective September 1, 2002.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day August 23, 2002.
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

IA%
cAlfill
May 22, 2009
Mr. Gil Vinzani
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Request for a Permit Modification
Dear Mr. Vinzani,
r
M AY 2 9 2009
DENR - WATER OUAMY
POINT SOURCE BRANCH
On March 11, 2009 Cargill, Incorporated, (Cargill) conducted a site inspection of its Fayetteville, NC facility
located at 1754 River Road. This facility is a soybean processing operation with a soybean oil refinery and
is permitted to discharge stormwater to Gum Log Creek under National Pollutant Discharge Elimination
System (NPDES) general permit number NCG060047. According to the latest permit issuance (November
2007), Gum Log Creek, located in the Cape Fear River Basin, is considered Class SC Waters with both
swamp water (SW) and high quality water (HQW) designations.
During the inspection it was discovered that 3 out of the 5 outfalls located on -site actually discharge to an
unnamed tributary (UT) to Locks Creek, while the other 2 outfalls release into an UT to the Cape Fear River.
Gum Log Creek runs parallel to Locks Creek, and while close in proximity, is not actually the receiving
waterbody. According to the latest classifications posting on the North Carolina Division of Water Quality
(DWQ) website, both of these waterbodies are considered Class C waters without any special designations
(Gum Log Creek is also likewise considered Class C).
Cargill requests that our stormwater permit certificate of coverage be modified to reflect the correct
waterbodies and their associated classifications. The purpose of this letter is to ensure that all efforts are
made to remedy this situation to help protect North Carolina's surface waters from potential pollution.
Should you have any questions, please do not hesitate to contact me at [phone].
Sinceely,
Jos a mall
Facility uperintend nt
Cargill, Incorporated
Joshua—[e-mail]

e-% F
bo1141 ton xFkw , eo46, I
DEV,,Li .A
7N
LO

COPY
May 22, 2009
Mr. Gil Vinzani
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Request for a Permit Modification
Dear Mr. Vinzani,
On March 11, 2009 Cargill, Incorporated, (Cargill) conducted a site inspection of its Fayetteville, NC facility
located at 1754 River Road. This facility is a soybean processing operation with a soybean oil refinery and
is permitted to discharge stormwater to Gum Log Creek under National Pollutant Discharge Elimination
System (NPDES) general permit number NCG060047. According to the latest permit issuance (November
2007), Gum Log Creek, located in the Cape Fear River Basin, is considered Class SC Waters with both
swamp water (SW) and high quality water (HQW) designations.
During the inspection it was discovered that 3 out of the 5 outfalls located on -site actually discharge to an
unnamed tributary (UT) to Locks Creek, while the other 2 outfalls release into an UT to the Cape Fear River.
Gum Log Creek runs parallel to Locks Creek, and while close in proximity, is not actually the receiving
waterbody. According to the latest classifications posting on the North Carolina Division of Water Quality
(DWQ) website, both of these waterbodies are considered Class C waters without any special designations
(Gum Log Creek is also likewise considered Class C).
Cargill requests that our stormwater permit certificate of coverage be modified to reflect the correct
waterbodies and their associated classifications. The purpose of this letter is to ensure that all efforts are
made to remedy this situation to help protect North Carolina's surface waters from potential pollution.
Should you have any questions, please do not hesitate to contact me at [phone].
Since ely,
Jos a mall
Facility uperintend nt
Cargill, Incorporated
Joshua—[e-mail]

search
Page I of 2
Incident Incident Material
DetaiilsI Dctails2 Agencies Categories Events
* Incident Type: IsPill (Oil, Chemical, non -sews
* Started Date/Time : 0211002009 10:50 zirl
* County : Cumberland ;
Decimal DD:MM:SS
Latitude:
Longitude:
Reporting Person : Anonymous
First Name: Liz
Middle Name:
Last Name: Ivy
Related Inc
Incident Number : 200.!
Position Accuracy: ;---Seieclt Value ---
Position Method: select Value ---
Position Datum: ' ---Select train -
Phone : [phone]
Location of the Incident : Cargill Inc.
Address: 1754 River Rd
City/State/Zip: Fayetteville
Cause/Observation of the incident
.,
Action Taken
I- j .. f,1 :-i-TL
,
Address : ;175'
City Fay,
State/Zip : ; NC
Cell/Pager : i
NG ; 9°999
Directions
Comments/Findings
Water Supply Wells within 1500ft : (". '
Surface Water Impacted : *Yes No C Unknown Groundwater Impacted:
Waterbody : Cum Lat; CarEai - 13 2-1
Waterbody (Other) : Conveyance :---s
Report Received By : Lewis, Steven C. RO Contact : I Lop
Phone : Phone : (91c
0211
Date/Time : 0200/2000 11:20 ani Date/Time
http://binis.enr. state. ne. us: 7001/seleetOnelncident.do?id=3M05FMYGOO S TSDT4CEXXGI ... 3/5/2009

C44rdi'll",
Grain & Oilseed Supply Chain
North America
Fayetteville, NC
To: Dale Lopez
North Carolina Department of Environment and Natural Resources
225 Green Street, Suit 714
Fayetteville, NC 28301
From: Joshua Small, Cargill Inc.
Facility Superintendent
1754 River Rd.
Fayetteville, NC 28312
Date: 02/10/09
Re: Response to Mineral Oil Sheen on February 10, 2009
Thank you for your quick response to the event that occurred at our site on February 10, 2009.
On this day a small release of mineral oil was discovered and reported to your department. We
appreciate the cordial response and sit down discussion to describe the incident and our
corresponding response measures taken. Below is the additional information that you have
requested.
List of agencies to which spill was reported including contact information
NRC
Time:
10:00 am
Contact:
Unknown male
Phone #:
1-800-424-8802
Report #:
897085
Narrative of the sequence of specific information
A sheen was discovered on Gumlog Canal at 9:55 on February 10, 2009,by a pair of Cargill
employees while performing a plant inspection. The employees notified operators and
supervisors of the oil sheen. The sheen was tracked back to locate the source. It was discovered
that the extraction plant cooling towers were overflowing non contact water due to a routine
plant shutdown. The sheen was due to a small residual amount of food grade mineral oil in the
cooling tower basin from a prior equipment leak that had been previously corrected.
Containment system gates at the extraction environmental pits and refinery pits were closed to
contain the sheen. At this point in time, the leak was stopped. The refinery supervisor was
instructed to notify the NRC and other appropriate government agencies in accordance with the
facility FRP procedures. The spill quantity at the time was estimated at 200 gallons. After
further investigation, it was updated to 2 gallons. The facility contractor, Haz-Mat Response,
was called to respond to the spill. The NRC was notified within the required 15 minutes. Oil
absorbent pigs were placed in Gumlog Canal, in multiple locations, where the sheen was
discovered. This contained the off site spill. As previously indicated, the -spill at the extraction

Car`g'�ll
Grain & Oilseed Supply Chain
North America
Fayetteville, NC
cooling towers was investigated and found to have a residual amount of food grade mineral oil in
the basin due to a past equipment leak. Two months earlier, an equipment leak had sent mineral
oil to the cooling tower. The leak was detected and the piece of equipment repaired. The
mineral oil in the cooling tower was reclaimed by pumping and skimming off the top of the
water in the basin. On the day of the release, the cooling tower system was shutdown for the
routine maintenance, which caused the basin to overflow. This overflow is not uncommon, but
the residual amount of oil combined with water overflow was enough to pass through and create
a sheen. The basin water level was pumped down to prevent the water from overflowing. The
containment system gates were kept closed and oil absorbent materials were used to prevent
further communication of the oil sheen. Water in the containment areas was skimmed and
redirected to our wastewater system, which is capable of processing this oil. After this
investigation, it was determined that the size of the spill was no greater than 2 gallons. The
emergency spill contractor was cancelled after the oil was determined to be contained and in a
small quantity. Cargill continued and completed all necessary clean up. All containment areas
were cleaned to remove oil before being returned to service. The oil in Gumlog Canal was
removed using oil absorbent materials and straw. An oil absorbent pig will be kept in place and
checked periodically for the next couple of weeks as a precaution.
Preventative and improvement measures
1.. Cooling towers will be skimmed to remove any remaining residual mineral oil.
2. Plant equipment will be rechecked to ensure that there is not an active leak. This is to ensure
no mineral oil is currently leaking into the cooling tower water.
3. Operators will frequently monitor the containment system pits and take appropriate actions if
necessary. This will include closing the containment gate if necessary.
4. Cooling tower basin will be emptied and refilled at the next feasible opportunity.
5. Cooling tower blow down will be redirected until Cargill is comfortable that no adverse
effects will result from cooling tower blow down.
Copy of the schematic of flow patterns in SPPP and MSDS for Mineral Oil
A copy of the following has been faxed to your office:
1. Schematic of flow patterns for the cooling tower, boiler blow down, and storm water
2. MSDS for Mineral Oil
Again, thank you for your cordial and quick response to this situation. 1 look forward to working
with you in the future.
Sincerely,
.loAh`Small
Facility Superintendent

RE: Request for additional information
Subject: RE, Request for additional information
Prom: [e-mail]
Date: Thu, 12 Fels 2009 96:16:14 -0600
To: Dale. [e-mail], [e-mail], Mike. [e-mail]
CC: [e-mail], [e-mail], [e-mail]
cargill.com
Dale,
I was out of town yesterday and got your voicemail late. I will get with
the appropriate people today to answer the below questions and get that
information to you as soon as possible.
Sincerely,
Scott 5chuelke
ENS Coordinator
Cargill, Incorporated
1754 River Rd.
Fayetteville, NC 28312
[phone] Office
[phone] Fax
The information transmitted is intended only for the person or entity to
which it is addressed and may contain confidential and/or privileged
material. Any review, retransmission, dissemination or other use of, or
taking of any action in reliance upon, this information by persons or
entities other than the intended recipient is prohibited. if you
received this in error, please contact the sender and delete the
material from any computer.
-----Original Message -----
From: [e-mail] [mailto:Dale.Looezoncmail.net]
Sent: Wednesday, February 11, 2009 4:27 PM
To: unknowny argill com
Cc: unknown9car ill.cam; Clapper, Jocelyn - Jocelyn Clapperucargill.corn;
9elinda.Hensononcmail.net; Mike.Lawveroncmail.net
Subject: Request for additional information
Once again, thank you.for your time and courtesy yesterday with my
investigation of the mineral oil spill. My understanding is that
approximately two gallons of mineral oil left the Cargill site via
Gumlog Canal, that flows into Cape Fear River. The cause was related
to a leak of mineral oil (two months ago) into a cooling tower. The
mineral oil leak was repaired. After speaking with Belinda Henson
(Regional Supervisor, Surface water Protection Section), I need
additional information concerning the mineral oil spill. Please email.
me the following as soon as you can: 1) the list of agencies to which
the spill was reported, including contact information (times, persons,
and phone numbers), 2) a Narrative of the sequence of specific
information (including times and quantities) involving the spill (it's
cause, repair, and it's clean-up), please include a schematic of flow
concerning the spill, 3) the preventative and improvement measures that
will be taken to avoid a future occurrence, 4) a copy of the schematic
of flow patterns already required by SPPP (site map) for the cooling
tower, boiler blowdown, and storm water. Please fax me the MSDS for
the mineral oil. Fax number: 910-486-0707.
*Dale Lopez*
1 of 2 2/13/2009 4:12 PN4

RE-: Regi,cst for additioim) inFornrttion
i' . 0
*Environmental Specialist*
*NCDENR *
*225 Green Street, Suite 714*
*Fayetteville, NC 28301*
*910-423-3312*
*910-486-0707*
* *
*E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third
parties.*
2 of 2 2/13/2009 4:12 PM

91114334920 Carqill loc
05 27 48 p it 02-20-2000
1 !8
cArfill,
facsimile transmittal
To: Dale Lopez- Fax: [phone]
NCDENR-DWQ
From: Scott Schuelke, Date: 2/20/09
Cargill, Incorporated
Re: Request for Pages:
additional information
CC:
1754 River Road
Fayetteville NC 28312
910-433-4901
910-433-4929-Fax
❑ Urgent 0 For Review 0 Please Comment ❑ Please Reply ❑ Please Recycle
. . . . . . . . . .
Dale,
Please note. We are in the process of updating/revising our SWPPP
to meet the requirements outlined in our new stormwater permit. We
adjusted our outfalls for stormwater and our non -contact wastewaters
this last fail as a result of: an inspection and discussions with Mike
Lawyer and Huey White, both with NCDENR. We will be updating our
facility layout to incorporate the new outfall locations with our
updated/revised SWPPP.
Please let me know if you have any other questions,
Scott Schuelke
FPS Coordinator
Cargill, Incorporated
[phone]
Y

J1U4"4JLJ l,argw Inc vu.to.uu
Material Safety Data Sheet
Material Safety Data Sheet
SEGTiON 1 PRODUCT AND. COMPANY IDENTIFICATION
Chevron Superla@ White Oil
Product Use: White oil
Product Number(s): CPS231004, CPS231005, CPS231006, CPS231007, CPS231008, CPS231009, CPS231010, CPS231011, CPS231013,
CPS231067, CPS231075, CPS231081
Synonyms: Chevron Superla@ White OF 10, Chevron Superla@ White Oil 13, Chevron Superla@ White Oil 18, Chevron Superla@) White Oil 21,
Chevron Superla@ White Oil 22, Chevron Superla@) White Oil 31, Chevron Superla@ White Oil 35, Chevron Superia@ Whlte Oil 5, Chevron
Superia@ White Oil 50, Chevron Superia@ White Oil 7, Chevron Superla® White Oil 81 Chevron Superla® White Oil 9
Company identification
Chevron Products Company
a division of Chevron U.S.A. Inc,
6001 Bollinger Canyon Road
San Ramon, CA 94583
United States of America
www,chevronlubricants.com
Transportation Emergency Response
CHEMTREC: [phone] or [phone]
Health Emergency
Chevron Emergency Information Center: Located in the USA. International collect calls accepted. [phone] or [phone]
Product Information
email : [e-mail]
Product Information: (800) LURE TEK
MSS Requests: [phone]
SECTION 2 COMPOSITION/ INFORMATION ON INGREDIENTS
COMPONENTS
CAS NUMBER iAMOUNT
White mineral oil ) 8042-47-5 1 100 %weight
This material'complies with Food And Drug Administration Regulation 178.3570 code of Federal Regulations, Title 21.
SECTION 3 HAZARDS IDENTIFICATION
IMMEDIATE HEALTH EFFECTS
Eye: Not expected to cause prolonged or signiftcanl eye irritation.
Skin: Contact with the skin is not expected to cause prolonged or signifcant irritation. Contact with the skin is not expected to cause an allergic
skin response. Not expected to be harmful to internal organs if absorbed through the skin.
Ingestion: Not expected to be harmful if swallowed.
Inhalation: Not expected to be harmful if inhaled. Contains a petroleum -based mineral oil. May cause respiratory irritation or other pulmonary
effects following prolonged or repeated inhalation of oil mist at airborne levels above the recommended mineral oil mist exposure limit. Symptoms
of respiratory irritation may include coughing and difficulty breathing.
h,1tps:/Iwww.cbest chevron.com/rrsdsServer/cont...990&docFormat=HTML&isLoginPage=true&region=NA (1 of 6) [10/16/2008 1:38M PM]

0104334020 Cargill Inc 05, 29:18 p.m. 02-20-2009 4 18
Material Safety Data Sheet
SECTION 4 FIRST AID MEASURES
Eye: No specific first aid measures are required. As a precaution, remove contact lenses, if worn, and flush eyes with water.
Skin: No specific first aid measures are required. As a precaution, remove clothing and shoes if contaminated, To remove the material from skin,
use soap and water. Discard contaminated clothing and shoes or thoroughly clean before feuse,
Ingestion: No specific first aid measures are required. Do not induce vomiting. As a precaution, get medical advice.
Inhalation: No specific first aid measures are required. If exposed to excessive levels of material in the air, move the exposed person to fresh
air. Get medical attention if coughing or respiratory discomfort occurs.
SECTION 5 FIRE FIGHTING MEASURES
FIRE CLASSIFICATION:
OSHA Classification (29 CFR 1910.1200): Not classified by OSHA as flammable or combustible
NFPA RATINGS: Health: 0 Flammability: 1 Reactivity: 0
FLAMMABLE PROPERTIES:
Flashpoint: (Cleveland Open Cup)129 °C (265 °F) (Min)
Autoignition: No Data Available
Flammability (Explosive) Limits (% by volume in air): Lower: Not Applicable Upper: Not Applicable
EXTINGUISHING MEDIA: Use water fog, foam, dry chemical or carbon dioxide (CO2) to extinguish flames.
PROTECTION OF FIRE FIGHTERS:
Fire Fighting Instructions: This material will burn although it is not easily ignited. For fires involving this material, do not enter any enclosed
or confined fire space without proper protective equipment, including self-contained breathing apparatus.
Combustion Products: Highly dependent on combustion conditions. A complex mixture of airborne solids, liquids, and gases including
carbon monoxide, carbon dioxide, and unidentified organic compounds will be evolved when this material undergoes combustion.
SECTION 6 ACCIDENTAL RELEASE MEASURES
Protective Measures: Eliminate all sources of ignition in vicinity of spilled material.
Spill Management. Stop the source of the release if you can do it without risk. Contain release to prevent further contamination of soil, surface
water or groundwater. Clean up spill as soon as possible, observing precautions in Exposure Controls/Personal Protection. Use appropriate
techniques such as applying non-combustible absorbent materials or pumping. Where feasible and appropriate, remove contaminated so;', Place
contaminated materials in disposable containers and dispose of in a manner consistent with applicable regulations.
Reporting: Report spiils to local authorities and/or the U.S. Coast Guard's National Response Center at [phone] as appropriate of
required.
SECTION 7 HANDLING AND STORAGE
General Handling Information: Avoid contaminating soil or releasing this material into sewage and drainage systems and bodies of water.
Static Hazard: Electrostatic charge may accumulate and create a hazardous condition when handling this material. 7o minimize this hazard,
bonding and grounding may be necessary but may not, by themselves, be sufficient. Review all operations which have the potential of generating
and accumulating an electrostalic charge and/or a Flammable atmosphere (including tank and container filling, splash filling, tank cleaning,
sampling, gauging, switch loading, filtering, mixing, agitation, and vacuum truck operations) and use appropriate mitigating procedures. For more
information, refer to OSHA Standard 29 CFR 1910.106, 'Flammable and Combustible Liquids', National Fire Protection Association (NFPA 77,
'Recommended Practice on Static Electricity', and/or the American Petroleum Institute (API) Recommended Practice 2003, 'Protection Against
Ignitions Arising Out of Static, Lightning, and Stray Currents'.
Container Warnings: Container is not designed to contain pressure. Do not use pressure to empty container or it may rupture with explosive
force. Empty containers retain product residue (solid, liquid, and/or vapor) and can be dangerous. Do not pressurize, cut, weld, braze, solder, drill,
grind, or expose such containers to heat, flame, sparks, static electricity, or other sources of ignition. They may explode and cause injury or death.
Empty containers should be completely drained, properly closed, and promptly returned to a drum reconditioner or disposed of properly.
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9104J:$4P29 Uargill Inc UL�:su:uu p.,n uZ-ZV-'�uua 1) rn
Material Safety pata Sheet
SECTION 8 EXPOSURE CONTROLSlPERSONAL PROTECTION
GENERAL CONSIDERATIONS:
Consider the potential hazards of this material (see Section 3), applicable exposure limits, job activities, and other substances in the work place
when designing engineering controls and selecting personal protective equipment. If engineering controls or work practices are not adequate to
prevent exposure to harmful levels of this material, the personal protective equipment fisted below is recommended. The user should read and
understand all instructions and limitations supplied with the equipment since protection is usually provided for a limited time or under certain
circumstances.
ENGINEERING CONTROLS:
Use fin a well -ventilated area.
PERSONAL PROTECTIVE EQUIPMENT
Eye/Face Protection: No special eye protection is normally required. Where splashing is possible, wear safety glasses with side shields as a
good safety practice.
Skin Protection: No special protective clothing is normally required. Where splashing is possible, select protective clothing depending on
operations conducted, physical requirements and other substances in the workplace. Suggested materials for protective gloves include: Nitrite
Rubber, Silver Shield, Viton.
Respiratory Protection: No respiratory protection is normally required.
If user operations generate an eil mist, determine if airborne concentrations are below the occupational exposure limit for mineral oil mist. If not,
wear an approved respirator that provides adequate protection from the measured concentrations of this material. For air -purifying respirators use a
particulate cartridge.
Use a positive pressure air -supplying respirator in circumstances where air -purifying respirators may not provide adequate protection,
Occupational Exposure Limits:
Component Agency TWA STEL Ceiling Notation
While mineral oil ACGIH 15 mglm3 10 m91m3
White mineral oil OSHA Z-t 15 mg1m3 1- F— F
SECTION 9 PHYSICAL AND CHEMICAL PROPERTIES
Attention: the data below are typical values and do not constitute a specification.
Color: Colorless
Physical State: Liquid
Odor: Petroleum odor
pH: Not Applicable
Vapor Pressure: <0.01 mmHg @ 37.8 °C (100 °F)
Vapor Density (Air = 1): >1
Boiling Point: >260°C (5007)
Solubility: Soluble in hydrocarbons; insoluble in water
Freezing Point: Not Applicable
Melting Point: Not Applicable
Specific Gravity: 0.82 - 0.86 @ 15.6°C (60.1'F) / 15.6°C (60.1 °F)
Viscosity: T5 cSt - 90 cSt @ 40°C (104°F) (Min)
SECTION 10 STABILITY AND REACTIVITY
Chemical Stability: This material is considered stable under normal ambient and anticipated storage and handling conditions of temperature
and pressure.
Incompatibility With Other Materials: May react with strong acids or strong oxldizing agents, such as chlorates, nitrates, peroxides, etc.
Hazardous Decomposition Products: None known (None expected)
Hazardous Polymerization: Hazardous polymerization will not occur,
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Material Safety Data Sheet
SECTION 11 TOXICOLOGICAL INFORMATION
IMMEDIATE HEALTH EFFECTS
Eye Irritation: The eye irritation hazard is based on evaluation of data for similar materials or product components.
Skin Irritation: The skin irritation hazard is based on evaluation of data for similar materials or product components.
Skin Sensitization: The skin sensitization hazard is based on evaluation of data for similar materials or product components.
Acute Dermal Toxicity: The acute dermal toxicity hazard is based on evaluation of data for similar materials or product components.
Acute Oral Toxicity: The acute oral toxicity hazard is based on evaluation of data for similar materials or product components.
Acute Inhalation Toxicity: The acute inhalation toxicity hazard is based on evaluation of data for similar materials or product components,
SECTION 12 ECOLOGICAL INFORMATION
ECOTOXICITY
The toxicity of this material to aquatic organisms has not been evaluated. Consequently, this material should be kept out of sewage and drainage
systems and all bodies of water.
ENVIRONMENTAL FATE
This material is not expected to be readily biodegradable. This material is considered inherently biodegradable. This material is not expected to
present any environmentai problems other than those associated with oil spills. See Section 6 for Accidental Release Measures.
SECTION 13 DISPOSAL CONSIDERATIONS
Use material for its intended purpose or recycle if possible. Oil collection services are available for used oil recycling or disposal, Place
contaminated materials in containers and dispose of in a manner consistent with applicable regulations. Contact your sales representative or local
environmental or health authorities for approved disposal or recycling methods.
SECTION 14 TRANSPORT INFORMATION
The description shown may not apply to all shipping situations. Consult 49CFR, or appropriate Dangerous Goods Regufations, for additional
description requirements (e.g,, technical name) and mode -specific or quantity -specific shipping requirements.
DOT Shipping Description: PETROLEUM OIL, N,O.I.B.N.; NOT REGULATED AS A HAZARDOUS MATERIAL FOR TRANSPORTATION
UNDER 49CFR
IMO/IMDG Shipping Description: NOT REGULATED AS DANGEROUS GOODS FOR TRANSPORTATION UNDER THE IMDG CODE
ICAO/IATA Shipping Description: NOT REGULATED AS DANGEROUS GOODS FOR TRANSPORTATION UNDER ICAO
5ECTI _I
ON 15 REGULATORY INFORMATION
EPCRA 311/312 CATEGORIES: I. immediate (Acute) Health Effects: NO
2. Delayed (Chronic) Health Effects: NO
3. Fire Hazard: NO
4 Sudden Release of Pressure Hazard: NO
5 Reactivity Hazard: NO
REGULATORY LISTS SEARCHED:
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,'I-.i J-r JLJ l01u­ 111l
Material Safety Data Sheet
01-1=IARC Group 1
01-2A=IARC Group 2A
01-26=IARC Group 26
02=NTP Carcinogen
03=EPCRA313
04=CA Proposition 65
05=MA RTK
46=NJ RTK
07=PA RTK
No components of this material were found on the regulatory lists above.
CHEMICAL INVENTORIES:
All components comply with the following chemical inventory requirements: AICS (Australia), DSL (Canada), EfNECS (European Union), KECI
(Korea), PICCS (Philippines), TSCA (United States).
NEW JERSEY RTK CLASSIFICATION:
Under the New Jersey Right -to -Know Act L. 1983 Chapter 315 N.J.S.A. 34:5A-1 et. seq., the product is to be identified as follows: PETROLEUM
OlL
WHMIS CLASSIFICATION:
This product is not considered a contro€led product according to the criteria of the Canadian Controlled Products Regulations.
SECTION 16 OTHER INFORMATION
NFPA RATINGS: Health:0 Flammability: 1 Reactivity: 0
HMIS RATINGS: Health 0 Flammability: 1 Reactivity: 0
(0-Least, 1-Slight, 2-Moderate, 3-1­1igh, 4-Extreme, PPE:- Personal Protection Equipment Index recommendation, `- Chronic Effect Indicator).
These values are obtained using the guidelines or published evaluations prepared by the National Fire Protection Association (NFPA) or the
National Paint and Coating Association (for HMIS ratings).
LABEL RECOMMENDATION:
Label Category: BASE OIL 1
REVISION STATEMENT: This revision updates the following sections of this Material Safety Data Sheet,- 2
Revision Date: 03/01/2006 ,
ABBREVIATIONS THAT MAY HAVE BEEN USED IN THIS DOCUMENT:
TLV Threshold Limit Value
JTWA - Time Weighted Average
STEL - Short-term Exposure Limit
PEL - Permissible Exposure Limit
CAS - Chemical Abstract Service Number
ACGIH - American Conference of Government Industrial Hygienists
APi - American Petroleum Institute
IMO/IMDG - International Maritime Dangerous Goods Code
MSDS - Material Safety Data Sheet
CVX - Chevron
NFPA - National Fire Protection Association (USA)
DOT - Department of Transportation (USA)
NTP - National Toxicology Program (USA)
ARC - International Agency for Research on Cancer
OSHA Occupational Safety and Health Administration
Prepared according to the OSHA Hazard Communication Standard (29 CFR 1910.1200) and the AN61 W306 Standard (L400.1) by the
Chevron Energy Research & Technology Company, 100 Chevron Way, Richmond, California 94802.
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91C4334020 r-afqOl 111C 05:31:31 p.m. 02-20-2009 .13 1.9
Material Safety Data Sheet
The above information is based on the data of which we are aware and is believed to be correct as of the
date hereof. Since this information may be applied under conditions beyond our control and with which
we may be unfamiliar and since data made available subsequent to the date hereof may suggest
modifications of the information, we do not assume any responsibility for the results of its use. This
information is furnished upon condition that the person receiving it shall make his own determination of
the suitability of the material for his particular purpose.
h tt[)s://www. cbest.bevron. com/mOsServer/cont... 99()&dOcForma t = HTM L&jsLOgj n Page =,rue& reg on = N A (6 of 6) [10/1612008 1:38M PM)

RE: inspection report
Subject: RE: inspection report
From: <[e-mail]>
Date: Tue, 19 Feb 2008 13:17:29 -0600
To: "Mike Lawyer" <[e-mail]>
Yes, I got it on February 12th.
Thanks,
Scott
-----Original Message -----
From: Mike Lawyer [mailto:[e-mail]]
Sent: Monday, February 11, 2008 9:58 AM
To: Schuelke, Scott - [e-mail]
Subject: inspection report
Hey Scott. Hope your weekend went well. Have you received the inspection
report? It was generated on February 5th and probably mailed out on the
6th. If you have and you can remember, I need to know the date you
received it. The response deadline is 30 calendar days from receipt of
the report. I don't want to assume that you received it a day or two
after we mailed it out. Although that might be the case, I want to be
sure you get a full 30 days to respond.
Thanks,
Mike
Michael Lawyer
Environmental Specialist
NCDENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]
1 of 1 2/19/2008 5:35 PM

o��F w A rE9p�
7
Michael f . Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Eorvironment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
Scott Schuelke, EHS Coordinator
Cargill Incorporated - Fayetteville
1754 River Road
Fayetteville, NC 28302
February 5, 2008
Subject: COMPLIANCE EVALUATION INSPECTION
Cargill Incorporated
Cargill Incorporated - Fayetteville
NPDES Stormwater General Permit-NCG060047
Cumberland County
Dear Mr. Schuelke:
On January 22, 2008, I, Michael Lawyer from the Fayetteville Regional Office of the Division of
Water Quality, conducted a site inspection at the Cargill Incorporated - Fayetteville facility located at
1754 River Road in Cumberland County, North Carolina. A copy of the Compliance Inspection Report
is attached for your review. Mr. Joshua Small, Facility Superintendent, was also present during the
inspection and both his and your time and assistance is greatly appreciated. Stormwater from this facility
drains to Gum Log Canal, a Class C water located in the Cape Fear River Basin. The site visit and file
review revealed that the subject facility is covered by NPDES Stormwater General Pennit-NCG060047.
Accordingly, the following observations were noted during the Division of Water Quality
inspection (please see the attached addendum for information about your permit):
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
im 1ernented.
Yes ■ No ❑
2) Qualitative Monitoring
ualitative monitoring has been conducted and recorded in accordance with permit requirements.
[Yes ■ No❑
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Yes ■ No ❑
None
fhcarolina
Naturn!!y
North Carolina Division of Water Quality 225 Green Strect, Suite 714 Fayetteville, NC 28301-5043 Phone [phone] ' Customer Service
Internet: www.newatM1Aali1Y.0rg Fax [phone]
An Equal OpporlunitylAflirmaNe Action Employer — 50% Recycled/1 0% Post Consumer Paper

Page 2
Mr. Schuelke
February 5, 2008
Other Observations:
As discussed during; the compliance evaluation inspection as well as the subsequent visit on February 4,
2008, the previously identified outfalls and sampling locations should be re-evaluated to comply with
the perniit condition found in Part III, Section D, Item 1, which states in part; "Ail samples shall be
taken before the discharge joins or is diluted by any other waste stream, body of water, or
substance." Also, the environmental pits located adjacent to River Road that receive stonnwater runoff
from that end of the facility should be monitored separately and prior to the road side ditch so as to
capture a more accurate representation of stonnwater runoff From the facility grounds only. Please refer
to the enclosed Compliance Inspection Report for additional observations and comments.
Requested Response
You are asked to respond to this office, in writing, within 30 calendar days from receipt of this letter.
Your response should include a detailed plan of action concerning the identification of appropriate
outfalls at your facility concerning stonnwater only and general wastewater discharges.
Please be advised that violations of the NPDES General Permit are subject to a civil
penalty assessment of up to $25,000 per day for each violation. If you or your staff has any questions,
comments, or needs assistance with understanding any aspect of your permit, please do not hesitate to
contact me at [phone].
Sincerely,
Michael Lawyer
Environmental Specialist
Attachments (2)
cc: Hughic White, Environmental Specialist- DWQ-Fayettevilie Regional Office
FRO -Surface Water Protection Section StomiNvater Files
NPS-Assistance & Compliance Oversight Unit

ADDENDUM
The National Pollutant Discharge Elimination System (NPDES) program was established under the
federal Clean Water Act and then delegated to the Division of Water Quality for implementation in
North Carolina. The NPDES permitting program for stormwater discharges was established in 1990.
Phase I focuses on site and operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten
categories are required to obtain permit coverage under a general permit or an individual permit,
depending upon the facilities SIC code and the industrial activity occurring at the facility. There are
currently 19 active general stonnwater pen -nits in North Carolina. One condition that is applicable to
both the general permits and individual stormwater permits is the requirement to develop and implement
site -specific comprehensive stormwater pollution prevention plans (SPPP). These plans are required to
include a comprehensive evaluation of the site and operations to reduce pollutant sources and prevent
pollutant discharge.
Copies of the general permits and accompanying documents can be accessed from the following
webpage: http://h2o.enr.state.nc.us/su/Forms_Documents.htm Permit text, technical bulletins, discharge
monitoring fonns, and a Notice of Intent [which is the application of for coverage under a NPDES
General Stonnwater Permit] can be found at this web site.
The following items are a subset of pen -nit requirements and are listed to assist you and help bring your
attention to certain penmitting issues, process and condition requirements of your permit. That said;
please see the above -mentioned web site in order to obtain a copy of the permit such that you may fully
comply with all the conditions therein. Failure to properly comply with conditions of the permit, like
those bulleted below, constitutes violations and is subject civil penalty assessment of up to
$25,000.00 per day.
• Industrial facilities that fall into one of the subject ten categories are required to obtain permit
coverage under a general NPDES stonnwater pen -nit or an individual NPDES stormwater pen -nit
• All persons desiring to have facilities covered by a General Permit must register with the
Division of Water Quality (DWQ) by the filing of a Notice of Intent (NOI) and Applicable Fees.
• This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any
discharge of stormwater associated with the industrial activity, process wastewater, and/or mine
dewatering.
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of
Coverage (COC) may be issued. if this Certificate of Coverage is issued the facility is covered
by the General Permit. That is, the pennittee is authorized to discharge stormwater, process
wastewater, and/or mine dewatering pursuant to the type of General Permit until the pen -nit
expires or is modified or revoked.
• Any other point source discharge to surface water of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization or approval.
• There are currently 19 active general permits. Permit conditions vary accordingly; however, most
of the permits have following condition requirements (you must read your entire permit to ensure
full compliance):
o Development and compliance with the Stormwater Pollution Prevention Plan
o Collection, reporting, and recording of Analytical Monitoring

o Collection, reporting and recording of Qualitative Monitoring
o Collection, reporting and recording of Vehicle Maintenance Monitoring
o Records — Visual monitoring shall be documented and records maintained at the facility
along with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring
results shall also be maintained on -site. The Permittee shall retain records of all
monitoring information, including all calibration and maintenance records and all original
strip chart recordings for continuous monitoring instrumentation, and copies of all reports
required by this general permit for a period of least 5 years for the date of the sample
measurement, report or application.
o Expiration — The permittee is not authorized to discharge after the expiration date of the
general permit. 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 expiration date. 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 subject to enforcement_ Failure to renew your permit is
a violation,
o Transfer — The Certificate of Coverage (COC) issued pursuant to this general permit is
not transferable to any person expect after notice to and approval by the Director. The
Director may require modification or revocation and reissuance of the Certificate of
Coverage to change the name and incorporate such other requirements as may be
necessary under the Clean Water Act, The Permit is NOT transferable.
o Name Change, Closure or Facility Ownership change — Pennittee is required to notify the
Division in writing in the event the permitted facility is sold or closed. The Division of
Water Quality views changes of name or ownership as a modification that requires the
Director's approval and reissuance of the permit. Name and ownership changes required
you to complete a Name/ownership Change Fonn from the Division and mail it back to
the Division of Water Quality along with all appropriate information.
o Proper Operation and Maintenance is a requirement of the permit.
0

Compliance Inspection Report
Permit: NCG060047 Effective: 11/01/07 Expiration: 10/31/12 Owner: Cargill Incorporated
SOC: Effective: Expiration: Facility: Cargill Incorporated -Fayetteville
County: Cumberland
1754 River Rd
Region: Fayetteville
Fayetteville NC 28312
Contact Person: Scott Schuelke Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Scott Schuelke Phone: [phone]
On -site representative Joshua Small Phone: [phone]
Related Permits:
Inspection Date: 0112212008 Entry Time: 09:3 AM Exit Time: 01:35 PM
Primary Inspector: Mike Lawyer Phone: [phone]
Ext121
s }72T
f" .4 Belinda S Henson Phone: [phone] Ext,721�'
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
33z6
Permit Inspection Type: FoodfTobacco/SoapslCosmetics/Public Warehousing
Stormwater Discharge COC
Facility Status. ■ Compliant Q Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page: 1

Permit: NCGO60047 Owner - Facility: Cargill Incorporated
Inspection Date: 01122/2008 Inspection Type: Compliance Evaluation Reason for Visit: Reutine
Inspection Summary:
Met with Mr. Scott Schuelke, EHS Coordinator, and Mr. Joshua Small, Facility Superintendent. A review of the facility's
Stormwater Pollution Prevention Plan (SPPP) was conducted. The SPPP was developed in 2002 and is quite detailed,
however it is missing the required component of a documented feasibility study and has not been reviewed and updated
on an annual basis as required by the permit. Facility is required to conduct both visual and analytical monitoring and
records of such were available and presented during the inspection. As a result of the inspection, it has been determined
that the outfall locations and subsequently the sampling points that have been identified should be re-evaluated based on
the permit requirement that "Ali samples shall be taken before the discharge joins or is diluted by any other waste stream,
body of water, or substance." This is based on the fact that the facility's receiving stream (Gum Log Canal) actually travels
via a pipe underneath the rear portion of the facility and previous sampling events for both the facility's stormwater permit
and general wastewater permit have been conducted at an open access pit to the stream itself where stormwater, cooling
tower water and boiler blowdown water commingle. A subsequent visit was made on February 4, 2008 by Mike Lawyer
and Hughie White of the Fayetteville Regional Office to discuss and make recommendations concerning future sampling
events with Mr. Schuelke in order to comply with the aforementioned permit requirement.
Page: 2

Permit: NCGO60047 Owner - Fatuity: Cargill Incorporated
Inspection Date: 01122/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■
0
❑
❑
# Does the Plan include a General Location (USGS) map?
■
Cl
0
Q
# Does the Plan include a "Narrative Description of Practices"?
■
n
n
0
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
rl
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
0
❑
# Has the facility evaluated feasible alternatives to current practices?
❑
■
# Does the facility provide all necessary secondary containment?
■
n
n
n
# Does the Plan include a BMP summary?
■
rl
0
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
❑
Q
# Does the facility provide and document Employee Training?
■
❑
❑
❑
# Does the Plan include a list of Responsible Party(s)?
■
n
n
# Is the Plan reviewed and updated annually?
n
■
❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
Q
Has the Stormwater Poliution Prevention Plan been implemented?
■
U
0
Comment: Facility's current SPPP does not include documentation of a feasibility
study and the SPPP has not been reviewed and updated since its development in 2002.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
U
❑
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
■
❑
Q
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
Cl
■
Comment:
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■ ❑
Q
Cl
# Were all outfalls observed during the inspection?
■ n
n
Q
# If the facility has representative outfall status, is it properly documented by the Division?
n n
■
Q
# Has the facility evaluated all illicit (non stormwater) discharges?
■ 0
D
Q
Page: 3

Permit: NCG060047 Owner - Facility: Cargill Incorporated
Inspection Date: 01/22/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Facility has identified two outfalls, but after walking the property it appears
that there may be additional outfalls to be monitored. Also, one of the two identified
outfalls is actually part of the stream that is piped underneath a portion of the site.
Page: 4

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Visit to C -gill -Summary
-ft. .
Subject: Visit to Cargill - Summary
From: <Scott_Schuelke c@r cargill.com>
Date: Mon, 4 Feb 2008 16:51:57 -0600
To: "Mike Lawyer" <[e-mail]>, <[e-mail]>
Mike/Hughie,
Thanks again for coming out today. I summarized what we discussed today
and just want to make sure I didn't omit anything and that I'm on the
right track. Obviously, I like to double check, and ... double check. This
is not meant to be any response of any type, just further communication
from our meeting today. Mike you'll notice on the attached document,
that there are some items bolded, italicized and underlined. These are
different than what we discussed. Notably, I was thinking about the
representative outfall status from the Environmental Pits near River Rd.
We discussed sampling all three, but one actually discharges into the
other, so wouldn't it suffice to just ample from the two larger ones
near the road and contemplate the representative status from there?
Also, the pit closest to the train tracks DOES have it's own pipe that
goes across River Rd. It also goes under our entrance there to the ditch
that "connect" the two pits.
Additionally, if you remember when you were here for your inspection and
we looked down into the blocked wall casement of the large retention
basin? There was a pipe that was discharging to Gum Log at that point
and we found that it was coming from over by our coal tunnel, where
there was a small pit. Well, I completely forgot to show that to you
this morning, but am quite sure it would qualify as an outfall. It
receives stormwater from the surrounding area. Only question there is,
we pump rainwater from the coal tunnel. Since it is still rainwater, I
would think that it shouldn't have any effect on the'outfall
determination. Your thoughts?
Review the attachment, and let me know if you guys see anything that
jumps out at you.
Appreciate it,
Scott
Content -Description: STRM-NCWW SAMPLING
02-04-08.pdf
STRM-NCWW SAMPLING 02-04-08.pdf
Content -Type: application/octet-stream
I Content -Encoding: base64
i of 1 2/5/2008 9:30 AM

. I , 47
February 4, 2008
Mike Lawyer, NCDNE..R-DWQ, Stormwater section and Hughic White, NCDENTR-
DWQ, Non -Contact (NI'DES) section visited the facility today in response to my request.
The purpose of the visit was to evaluate the current outfalls, discharges to those outfalls
and proper monitoring associated with each.
]`TOTE: Gum Log Canal runs under our property through a corrugated steel pipe.
Stormwater and Nan -Contact Cooling water both enter the Canal at various locations
within the plant boundaries. The main objectives of our meeting were to ensure that
monitoring points were so that the particular 'water' being sampled was not mixed with
any other and that our monitoring locations were adequate for the facility dischargers.
Currently, the way discharge and sampling is understood, the following apply:
FV101, is the upstream monitoring point (influent) for Non -Contact Cooling Water. This
sample point is located across Underwood Road at Gum Log Canal.
FV001, is the discharge from the: facility into Gum Log Canal on the opposite side of the
facility, It is located across the railroad tracks, near the Refinery.
FV002, is the discharge from the facility on the River Road side of the plant.
Mike Lawyer conducted a Stromwater inspection on January 22"', and there were some
notable things that had changed over the years however, discharge -sampling points
remained the same. This is why I asked Mike and Hughie to come to the facility. I
wanted to make sure that any changes identified, were in line with permit requiremctits.
Items discussed and changes to be made on behalf of the facility are as follows:
STORMWATFR
For FV002 — There are actually 3 Environmental 'Pits' on this side of the facility (River
Road). # 3 is between the Steel Bean `Ranks and is the first point to screen out solids
(beans mainly). Environmental pit # 3 overflows across a gravel truck parking area via a
cement trough to Environmental pit # 4. Environmental Pit # 4 discharges to a ditch on
the Cargill side of River Road which runs to an underground pipe that noes under River
Road to the other side where there is another ditch. This pipe discharges to the ditch
across the road under water. Another Environmental pit # 5, also on the Cargill side of
Diver Road discharges to the same ditch as Environmental pit # 4, however, has it's own
underground pipe that goes under River Road to the other side where there it too,
discharges to the ditch on the other side of River Road. See Figure 1.
Cargill will sample the discharze from # 4 and # 5 Environmental Pits, just as the
dischar e leaves the pits. The reason for itot sash ling# 3 is because the dis bar ^e
from it goes directly to Environmental Pit # 4 before �oirrt} offtlrc facility,trrounds. If
the lab results differ only slightly, Cargill will request that the discharge from # 4

Environmental Pit only be sampled in the future as a representative sample of both
discharges. If approved, Cargill will label this monitoring point as SWO1.
New Outfall
A concrete pipe had been installed at some point just under the paved drive beside the
maintenance shop. It appears that the reason for this was due to the buildup of stormwater
in front of the shop. A drain was included in the installation at the inlet side of the pipe.
The outlet, discharges to the ditch that runs along Underwood Rd., outside of the Cargill
fence. Cargill will label this monitoring point as SW02.
FVOO1 — Stormwater discharge to the current FVOOI cannot be sampled at that location
without being mixed with the Non -Contact wastewaters. Therefore, Stormwater
monitoring will be conducted at the first catchment basin just inside the gate at the Boiler
entrance. Cargill will label this as SW03.
New Outfall — There is a small Environmental pit near the coal tunnel. This
Environmental pit receives free fall storiwater and stormwater that is pumped front
the coal tunnel. This pit dischaEges into the Retention Basin blocked wall to Guilt L
�' � ill will label this as .. SW04�
Canal. Car _ ,,.. _
.
NON -CONTACT WASTEWATER
Current monitoring points were, I01 for upstream at Gun-► Log Canal before it enters
facility, at the outfall to Gumlog Canal, across railroad tracks, for effluent and the final
monitoring point would be upstream in Gum Log Canal. Walking through the discharges,
it was noted that the Extraction Cooling Tower Blowdown was mixing with Stormwater
or any other water that may be running through the same path, i.e., wash -down water.
Cargill will install a composite pipe to capture discharge from the three pipes coming
from the cooling tower prior to it mixing with any other discharges. Cargill will label this
monitoring point as NCWW02.
For Boiler Blow -Down and Similar Wastewaters from the Boiler area, the discharges go
to the ground from multiple pipes, follow a cement trough to a catchment area and flow
through a a" pipe to another catchment that discharges directly to Gum Log Canal. These
catchments are open to stormwater flows, therefore any samples will be subject to mixing
with stormwater. Cargill will install a composite pipe to capture discharge from the
various pipes coming from the Boiler Blow-Dow-n and Similar Wastewaters prior to it
mixing with any outer discharges. Cargill will label this monitoring point as NCWW03.
Cargill will sample from Gum Log Canal prior to it entering the facility for influent
monitoring. Cargill will label this monitoring point as NCWWOI
Cargill will sample from Gum Log Canal as it leaves the facility. Cargill will label this
monitoring point as NCWW04.

RIVER RD
EP # 4
?P(4CiH
EP # 3
-u
00
-L
y 5rg6 c- s oy 9LA0
Feliloti.'d pi pf-s
UNDERWOOD RD
f—
i

Michael F. Easley, Governor
William G. Ross Jr., Secretary
[North Carolina Department of Environment and Natural Resources
August 23, 2002
PLANT SUPERINTENDANT
CARGILL INCORPORATED
1754 RIVER ROAD
FAYETTEVILLE, NC 28301
Alan W. Klimek, P.E., Director
_ Division of Water Quality
AUG 2 9 2002
Subject: NPDES Stormwater Permit Renewal
Cargill Incorporated
COC Number NCG060047
Cumberland County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG060000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983.
The following information is included with your permit package:
A new Certificate of Coverage
A copy of General Stormwater Permit NCG060000
A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater
and General Permits Unit at [phone], ext. 578
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Fayetteville Regional Office
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
emA
NCDENR
Customer Service
1- 800-623-7748

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
August 23, 2002
PLANT SUPERINTENDANT
CARGILL INCORPORATED
1754 RIVER ROAD
FAYETTEVILLE, NC 28301
Subject: NPDES Stormwater Permit Renewal
Cargill Incorporated
COC Number NCG060047
Cumberland County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG060000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued Stormwater general permit. This permit is reissued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983.
The following information is included with your permit package:
A new Certificate of Coverage
A copy of General Stormwater Permit NCG060000
A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reisshance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater
and General Permits Unit at [phone], ext. 578
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Fayetteville Regional Office
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
TA
NCDENR
Customer Service
1- 800-623-7748

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Departmert of Environment and Natural Resources
_ Gregory J. Thorpe, Ph.D.
,....Acting Director
Diyisiah of 4 hr Quality
f AApn
Dcccnthcr 27.21}I}I
PLANT SUPERINTE-NDANT
CARGILL 1NC(.)RPORA` 131)
1754 RIVER RD
FAYl7-7 E-Vll_Ll . INC 28301
Subject: NPDES Stlar'nlwalCt' Permit RCIIOVad
CARGILL INCORPORATED
COC Number rNCG060047
Cumhcrlautd COUrlty
Dear Pcrrnitlee:
Your facility is currently Coycrcd For storrn%yater dischal'gc under General hermit NCG060000. This permit expires
on Aiwust 31. 2002. The Division staIT is currently in the process ol, rewriting this permit and is sclied uled to have
the permit reissued by hale SO Ill of2002. Once the perrnil is reissued, your Iacihty would he Clil'ible for
continued CUVCIat11C undcr the reissued permit.
In order to assure your continued cover.wo undcr the genes! permit. you must apply (o the Division of' Watcr
QualiIV (DWQ) le)r renewal of your permit coverage. To make this rcncwal process casicr, we are inl01-min" you in
advance that your perillt( will he expiring. l nclosCd You Will find a General Permit Coverage Renewal
Application Form. The application must he cornplCted and rcturnCd by March 4, 2002 in order to assure continued
covC1,lgU undcr the ,Cncral permit.
FailurC to request rcncwal within this (]tile period may result in a civil assessntent o1 at Icast $250.00, Lar'gcr
penalties may he assessed depending on the clClirtquency of the rcquust. Discharge of storrnwatcr from your facility
Without coycragc undcr a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments oaf civil penalties of up to $10.000 per. day.
PlUasc OOIC that r'cccr3l fCLIUral lCgislalion has Cxtcndcd the "nil e.rposurc cxelusion" to,tll opertors of industrial
facilities in ,toy ot, the I I categories o1 "st{rrnl water dischar��cS associated with industrial activity," (except
conSu-uction activities), If you feel your- fatality can ccr il'y a Condition of "nil exposure", i.e. the tWilty industrial
matcrial,s and operations arc not cxpused to stornlwatcr, you cash apply 101- the no uxposure exclusion, hot additional
information contact the Central {.)lficc Slornlwaler Slaafl' inenibcr listed hclow or check the Stornlwater & Gcncral
Permits Unit Weh Site at hltpa/h2o.car,Slalc.nC.uslsulslnrmwalcr.hlnll
11' (tic subject slorrllwatcr dischar-e to walers of the state hags hcen lcrmiirucd, please complete the enclosed
Rescission Request Form. Mailing, instructions arc lislcd on the honour ohthC f01111. You will he nntilicd when (he
rescission process has heen completed.
if yoxr IMVC any yLICS601Is rCgardin4 the permit rcncwatl hroccdurcs plCasC contact Ricky Revels ol'thc Fayctleville
Regional Office al 910-486-1541 or Aisha Lma of the C.Cntlal ( )17ice Stornlwaler Unit at (919) 7_3 3-5083, cm. 578
Sincerely.
BNOIC' BC1111ctt. Superyisor-
Slormwater and General Permits Unit
cc: Central Files
Fayeltevillc Rc+,ional (.)IficC
�► IV 1
NCDENR
N, C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
w a r�RQ�
co r
PLANT SUPF RINTENDANT
CARGILL INCORPORA'I'l D
1754 RIVER RD
fAYL'I"f'LVI!_LI NC 28301
Dear PCI.11141UC:
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
Dccenlher 27. 2001
Subject: NPI)f S Storinwatcr Permit Renewal
CARGILL INCORPORATED
COC Nnmhcr NCG060047
CL1rtlherlall(.I COunly
YOur facilily is currently c0vcr'Cd ]Or SIOrnlwatcr discharte under General Permit NCG060000. This permit expires
ern August 31. 2(X)2. The Division staff is currently in the I)rocesS 01'rewriIin" this i)cl-miI and is scheduled 10 11,1 Ve
the Pcrnlit reiSSucd by tale Sunurter Oh 2002. Orice the permit is rcissucd, y0ur faciIily wotdd he cliI'ihlc for
continued coverage under the r'cissued permit.
In order to assure your continUed coveragC UndCI' II1C gCner,l pernlil, y0u must apply to the Division of Watcr
QUIdity (Dy' Q) Ior renewal ol- your permit coverage. To slake this rcncwal 111-0cCss Cosier, wC arc inl'Orinin") YOU in
advancC that your permit will he expiring. r'11Chl5ed YOU will hind a General Pcrmit Coverage Renewal
Application Fornl. The applicolion must he Completed and returned by March 4. 2002 in order to ussurC cuntinucd
COVU Mge under the general hermit.
Fmluru to request renc%val within this tinie period may result in ,t civil assessntull of at least $250.00. Larger
penalties non' be assessed dcpcnding 0n the dclinquCney of- tlic request. Discharge of stnrmwatcr hrnm }'our facility
with0u1 cnvcr110C undcr,I valid stormwalcr NPDES pa-rnit would contili.tutC <1 violalinn nl- NCGS 143-2I5.1 and
Could 1-csult in assessmults 0f'civil penalties 0t' up to $10,000 pCr day.
Plulse note that recent federal IC0islali0n has CxtcndCd the "no Cxp0surc exclusion" 10 all 01101a101-s 01' industrial
Facilities in any of the I I cate«0rics oh "storm water dischar"es associated with industrial activity", (except
Construction acsivilicS). If you I'M your facility can cCrtif'y a condition of "rui CxposurC", i.e. the facilly induslriu]
materials and operations are not exposed to stnrmwatCr, you can apply For the no Cxp0surC c.Xclusi0n. F'Or additional
irilortmttioll contact Ole Central Off ice Stormwaler Staff member listed below or check the Storniwater & General
Permits Unit WCh Site ,it httpa/h2o.enr.stutC.nC.uslsu/slormwalCr.html
If the '4ihjcc1 stornlwatcl- dischar-c t0 waters (if' tile stale has hccn terntimUMd, please coinplcte the enclosed
Rescission Request Form. Mailing inst-uc1i0ns are listed on the holloni of the form. You will he notified when the
rescission process has been completed,
11 you have any questions regarding the permit rcnCwal prOCCxlures please contact Ricky Revcls of the Faycttcvillc
Rcgional 011-icc at 910-486-1541 or Aisha Lan nh tlsc Central Office Slornnvatcr Unit at (919) 733-50,53. exi. 578
slticCCcly,
Bradley Bennett, Supci-vis0r
S10rmw;nCr,ind General PCrnlits Unit
cc: cclllral Files
Fayeltcvillc Rc',i0nal OlTice
©0A
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699.1617 [phone] Customer Service
1- 800-623-7748

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
TOM RICHARDSON
CARGILL INCORPORATED
PO BOX 2309 RIVER ROAD
FAYETTEVILLE, NC 28302
XT11-1AA
J �
�YT
IDEHNF1
September 11, 1997
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCGO60047
Cumberland County
Dear Permittee:
In response to your renewal application for continued coverage under the subject permit, the Division
of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit
is reissued pursuant to the requirements of North Carolina General Statute 143-215 .l and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency
dated December 6, 1983.
The fallowing information is included with your permit package:
w A copy of the stormwater general permit.
■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit. This form must be completed and returned to the Division within 30 days of receipt of
this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
■ Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program with outlines program components
and addresses frequently asked questions.
■ A corrected Certificate of Coverage if you indicated a name or address change on the Renewal
Form returned to the Division.
Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water
Quality may require modification or revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater Group at telephone number [phone]
Sincerely,
for . Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

COMP LA = NT
ED
�- DIVISION OF-ENVIRONMENTAL,.MANAGEMENT
s
Water Quality Section
M E M O R A N D U
DATE April 6, 1995
TO FRO Complaint Files
Cumberland County
THROUGH : Michael Wicker, P.E.
Water Quality Regional Supervisor
FROM : Paul E. Rawls
Fayetteville Regional Office
SUBJECT : Discharge of Soy Bean Oil and Soy Beans
Cargill
River Road
Cumberland County
Mr. Trent Rainey,
Enforcement Officer
Regional IV EPA
345 Courtland Street
Atlanta GA 30365
[phone]
Mr. Trent relayed a complaint from
Mr. James Cooper
[phone] (work)

The complaint is that of soy,oil and beans leaving the
Cargill site
and entering,;z'a`;ditch'ad�jacent to River Road. After each
rainfall
event
The a_l•ieged_..dischcirge;,f3ows::from 'a sediment basin into
the ditch to
the CapeFear
•tt,•
5- 'w1 .J .'Ci . }.• .:I
.rLY!'= •art 1
•for
- ,
It has,,last
.;years`,,
Fi'�ow..in••'ditch -is- green -with odor
The discharge-is-killing-25-year old pine trees.
Mr. Cooper has reported the incident in the past
(no date(s)
given) to .the 'Arm.�'Corps o.f, Engi'neers .- - .-- Scott Clinton
Wilmington office
and to
DEHNR ----- Ken Averitte (not date(s) given,)
<,
I told Mr. Rainey that complaints of this nature are follow-up on
and that we would contact Mr::lCooper.by.telephone today.
Mr. Rainey asked that we furnish his office a memo on our findings.
t

The complaint is that of soy oil and beans leaving the Cargill site
and entering a ditch adjacent to River Road. After each rainfall
event.
The alleged discharge flows from a sediment basin into the ditch to
the Cape Fear River.
It has last for years .
Flow in ditch is green with odor
The discharge is killing 25 year old pine trees.
Mr. Cooper has reported the incident in the past (no date(s)
given) to the Arm Corps of Engineers ----- Scott Clinton
Wilmington office
and to
DEHNR ----- Ken Averitte (not date(s) given)
I told Mr. Rainey that complaints of this nature are follow-up on
and that we would contact Mr. Cooper by telephone today.
Mr. Rainey asked that we furnish his office a memo on our findings.

Image Undo ValCheck DO -IT! Cancel
Standard Form =01=0
Er -comp # 491 •
ACTIVITY: COMPLAINT-CARGILL ODOR AND RUNOFF
DATE/TIME RECEIVED: 3/27/95
LOCATION: CUMBERLAND/RIVER RD
ASSIGNED TO: KA
DATE ASSIGNED: 3/27/95
DATE COMPLETED:
COMMENTS. PARKING RUNOFF INTO PINES/MR COOPER 486-
491 of 491:Prev
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From:
°.± North Carolina Department of Environment,
Health and Natural Resources 7��L�
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C OMPLA = NT
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DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section
X E X 0 R A N D U N
DATE : April 6, 1995
TO : FRO Complaint Files
Cumberland County
THROUGH : Michael Wicker, P.E.
Water Quality Regional Supervisor
FROM : Paul E. Rawls
Fayetteville Regional Office
SUBJECT Discharge of Soy Bean Oil and Soy Beans
Cargill
River Road
Cumberland County
Mr. Trent Rainey,
Enforcement Officer
Regional IV EPA
345 Courtland Street
Atlanta GA 30365
[phone]
Mr. Trent relayed a complaint from
Mr. James Cooper
[phone] (work)

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Tom Richardson
Cargill Incorporated
P O Box 2309
Fayetteville, NC 28302
Dear Mr. Richardson:
maim
�EHNF�
June 25, 1993 1�
JUN 29 1993 � J
ENV. MANAGEMENT
FAYETTEVILLE REG. OFFICE
Subject: General Permit No. NCG060000
Cargill Incorporated
COC NCG060047
Cumberland County
In accordance with your application for discharge permit received on October 1, 1992, we are
forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1981
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Environmental Management. The Division of Environmental Management may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. Steve Ulmer at telephone number 919n33-
5083.
cc:
Sincerely, Signed BY
Original S{ g,ulCms
Goleen K
A. Preston Howard, Jr., P. E.
Fayetteville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
STORMWATER DISCHARGES
In compliance with the provision of North Carolina General Statute 143-215.I, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Cargill Incorporated
is hereby authorized to discharge stormwater from a facility located at
Cargill Incorporated
River Road
Fayetteville
Cumberland County
to receiving waters designated as Gum Log Creek Creek in the Cape Fear River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, II, III
and IV of General Permit No. NCGO60000 as attached.
This Certificate of Coverage shall become effective June 25, 1993.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day June 25, 1993.
Original Signed BY
Coleen H. Sullins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

GEOLOGICAL SURVEY
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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
June 25, 1993
Tom Richardson
Cargill Incorporated
P O Box 2309
Fayetteville, NC 28302
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IDEHNR
Subject: General Permit No. NCG060000
Cargill Incorporated
COC NCG060047
Cumberland County
Dear Mr. Richardson:
In accordance with your application for discharge permit received on October 1, 1992, we are
forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Environmental Management. The Division of Environmental Management may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. Steve Ulmer at telephone number 919/733-
5083.
cc:
Sincerely
ariginal Signed By
Coleen H. Sullins
A. Preston Howard, Jr., P. E.
Fayetteville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
STORMWATER DISCHARGES
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Cargill Incorporated
is hereby authorized to discharge stormwater from a facility located at
Cargill Incorporated
River Road
Fayetteville
Cumberland County
to receiving waters designated as Gum Log Creek Creek in the Cape Fear River Basin
in accordance with the effluent Limitations, monitoring requirements, and other conditions set forth in Parts I, II, III
and IV of General Permit No. NCG000000 as attached.
This Certificate of Coverage shall become effective June 25, 1993,
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day June 25, 1993.
Original Signedt
Coleen H. Sullins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

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CARGIL
DOMESTIC SOYBEAN
PROCESSING
Box 2S09
Fayetteville, NC 28302
919/48S-4631
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ENV, MM,, A'�'-L.ME
MYETTEVILLE W FY I
February 1, 1990
U. S. Environmental Protection Agency
345 Courtland Street N.E.
Atlanta, Georgia 30365
Re: Stormwater Permitting Request for
Application: Cargill, Inc. Fayetteville, NC
Dear Sirs:
Pursuant to the Clean Water Act Amendments of 1987 (Section 402 P)
requiring certain industrial discharge to apply for NPDES or
Publicly Owned Storm Sewers permits by February 4, 1990 Cargill,
Inc. would like to respectfully request application with this
correspondence.
Our desire is to be complete and timely with this submission. We
appreciate your attention to this request at this time or when
the Agency has finalized the application and permitting mechanism
in the near future.
Thank you for your assistance regarding this matter.
Sincerely,
Mike Michalski, Assistant Plant Superintendent
cc: Don Safrit
Mi Noland

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