NCG060126_COMPLETE FILE - HISTORICAL_20180313

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V�
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ �oj � 6 3 13
YYYYMMDD

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060126
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,
Smithfield Fresh Meats Corporation
is hereby authorized to discharge stormwater from a facility located at:
Smithfield Fresh Meats Corporation
15855 Hwy 87 W
Tar Heel
Bladen County
to receiving waters designated as Goodman Swamp, a Class C, SW waterbody in. the Lumber
River Basin; in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, H, III, and IV of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective March 13, 2018.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day March 13, 2018.
Original Signed by Robert D. Patterson, P.E.
for William E. Vinson, Jr., P.E., Interim Director
Division of Energy, Mineral, and Land Resources
By the Authority of the Environmental Management Commission

Division of Energy, Mineral & Land Resources
Land Quality SectionlStormwater Permitting
NCDENR+�= National Pollutant Discharge Elimination System
Dm�, �M0Ne, W� PERMIT NAME/OWNERSHIP CHANGE FORM
FOR AGENCY 115E ONLY
Date Received
Year
Month
I Day
I. Please enter the permit number for which the change is requested.
NPDES Permit (or) Certificate of Coverage
1911111JUI6101 II=I ' a110 19
II. Permit status prior to requested change. ,� / I
a. Permit issued to (company name): Sry �y''3-P;d l F1h1b,11-J -TM.Lf au �Sie
b. Person legally responsible for permit: cr-40-, 11
First n MI Last
RECEIVE® Title
191-5 SL, Y, F 7 Gt1 es
MAR Ap 07
2010 p Permit ]der Mailing Address q
T A) C_
DENR-LAND QUALITY City 6 I state 1ZIP
STORMWATER PERMITTING (91y) Ld- 74 7 S 010 , j $ `7
�ieZ
oFax
c. Facility name (discharge):
t - (crl U(hjo 1veQi�a
d. Facility address: (_A ':,J'Z LA-)
Address
-'A-YL eelf A) C _ 2
City State �
e. Facility contact person: R--0P6"if rr}'? (mil U ),;l-
7
First 1 MI / Last Phone
III. Please provide the following for the requested Range (revised permit).
a- Request for change is a result of: ange in ownership of the facility
[v� Name change of the facility or owner
If other please explain: _ }
b. Permit issued to (company name): , ru r�S ea 5 C 0 - JR�[Ile-
c. Person legally responsible for permit: )vubo - �,I%
First MI Last
Title
Permit Holder Mailing Address
City State ZIP
(910) 6'LL 70 Ae *`R, a0,c,u�
Phony� E-mail Address
d. Facility name (discharge): �'M s �"! �2 kr -Frelk A1 g -� Cn 2 y - f��>1
e. Facility address: R �IzLt w G _, t`0
Addre s
P_tk�I G
ity tate Zip 1
f. Facility contact person: RIO E ck ms
First MI � Last
(q57) & 1 l r l a rr, 5(? Swf 1 �il'� 1 jd •ta,
Phone E-mail Address _
IV. Permit contact information (if different from the person legally responsible for the permit)
Revised Jan 27, 2014

NPDES PERMIT NAME/OWNERSHtP CHANGE FORM
Page 2 of 2
Permit contact: Ro L P 44M '
First MI Last
�j Title
rer�Mailing Address
N A) c�-
City State Zip
(-7s7) 613 i33� �i1�rr�5
Phone E-mail Address
V. Will the permitted facility continue to conduct the same industrial activities conducted prior
tot ownership or name change?
Yes
❑ No (please explain)
VI. Require Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS
ARE COMPLETE OR MISSING:
This completed application is required for both name change and/or ownership change
equests.
Legal documentation of the transfer of ownership (such as relevant pages of a contract deed,
or a bill of sale) is required for an ownership change request. Articles of incorporation are
not sufficient for an ownership change.
............................................................................................................I.........
The certifications below must be completed and signed by both the permit holder prior to the change, and
the new applicant in the case of an ownership change request. For a name change request, the signed
Applicant's Certification is sufficient.
PER IT CERTIFICATION (Permit holder prior to ownership change):
1, efIAA t that this application for a name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not
completed and that if all req 'red supporting information is not included, this application package will be
returned -as incomplete. - - - - -- - - -- - -- -..
Signature Date
ALDCANCLERTICATION 11
attes that Nis application for a name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not
completed and that if all required supporting information is not included, this application package will be
returned as incomplete. '
Signature Date
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Energy, Mineral and Land Resources
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
RevisM Jan. 27, 2014

Delaware Page 1
The First State
I, JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF
DELAWARE, DO HEREBY CERTIFY THE ATTACHED IS A TRUE AND CORRECT
COPY OF THE CERTIFICATE OF INCORPORATION OF "SMITHFIELD FRESH
MEATS CORP.", FILED IN THIS OFFICE ON THE SIXTH DAY OF
NOVEMBER, A.D. 2017, AT 2:27 O'CLOCK P.M.
AND I DO HEREBY FURTHER CERTIFY THAT THE EFFECTIVE DATE OF
THE AFORESAID CERTIFICATE OF INCORPORATION IS THE EIGHTH DAY OF
NOVEMBER, A. D. 2017 AT 12: 01 O'CLOCK A.M.
A FILED COPY OF THIS CERTIFICATE HAS BEEN FORWARDED TO THE
NEW CASTLE COUNTY RECORDER OF DEEDS.
6605607 8100
SR## 20176947282 z ""`"Pm'
You may verify thiscertificate online at corp.delaware.gov/authver.shtml
. \1-n� I-e",
Vnmy M. UQIIxb. stmury oT SW.
Authentication: 203529372
Date: 11-07-17

State- of Hamm
Secretsrr of State
Division of Corporation
Deftered 02:27 PA111106l2017
FILED- 02:21 PAf 1110612017 CERTIFICATE OF INCORPORATION
SR 20176447282 - HeNamber 6605607
OF
SNIITHFIELD FRESH MEATS CORP.
ARTICLE FIRST
The name of the corporation is Smithfield Fresh Meats Corp. (the "Corporation"j.
ARTICLE SECOND
The address of the Corporation's Registered Office in the State ofDelaware is 1209 Orange -
Street, Corporation Trust Center, in the City of Wilmington, County of Now Castle, State of
Delaware, 19901. The name of the Registered Agent at such address is The Corporation Trust
Company,
ARTICLE THIRD
The purpose of the Corporation is to engage in any lawful act or activity for which
corporations may be organized under the General Corporation Law of Delaware, but the
Corporation is not formed to engage in any act or activity requiring the consent or approval of any
state or federal official, department, board, agency or other body without such consent or approval
first being obtained. ,
ARTICLE FOURTH
The total number of shares of capital stock of the Corporation which the Corporation small
have authority to issue is 1,000 shares, with no par value.
ARTICLE FIFTH
A. The business and affairs of the Corporation shall be managed by or under the
direction of a board of directors (the "Board"), except as may be otherwise provided in the
Delaware General Corporation Law or in this Certificate of fire poration. If any such provision
is made in this Certificate of Incorporation, the powers and duties conferred or imposed upon the
Board by the Delaware Geneml Corporation law shall be exercised or performed to such extent
and by such person or persons as shah be provided for in this Certificate of incorporation.
B. Unless and except to the extent that the Bylaws of the Corporation shall be so
required, the election of directors of the Corporation need not be by written ballot,

ARTICLE SIXTH
The name and mailing address of the incorporator is:
Michael H. Cole
c/o Smithfield Foods, Inc.
200 Commerce Street
Smithfield, Virginia 23430
ARTICLE SEVENTH
The Board is expressly authorized to snake, alter or repeal Bylaws of the Corporation but
the stockholders may make additional Bylaws and may alter or repeal any Bylaw whether adopted
by them or otherwise.
ARTICLE EIGHTH
Whenever a compromise or arrangement is proposed between the Corporation and its
creditors or any class of them and/or between the Corporation and its stockholders or any class of
them, any court of equitable jurisdiction within the State of Delaware may, on the application in a
summary way of the Corporation or of any creditor or stockholder thereof, or on the application
of any receiver or receivers appointed for the Corporation under the provisions of Section 291 of
the Delaware General Corporation Law or on the application of trustees in dissolution or of any
receiver or receivers appointed for the Corporation under the provisions of Section 279 of the
Delaware Gencral Corporation Law order a meeting of the creditors or class of creditors, and/or
of the stockholders or class of stockholders of the Corporation, as the case may be, to be summoned
in such manner as the said court directs. If a majority in number representing three -fourths (3/4)
in value of the creditors or class of creditors, and/or of the stockholders or class of stockholders of
the Corporation, as the case may be, agree to any compromise or arrangement and to any
reorganization of the Corporation as a consequence of such compromise or arrangement, the said
compromise or arrangement and the said reorganization shall, if sanctioned by the court to which
the said application has been made, be binding on all the creditors or class of creditors, and/or on
all the of the stockholders or class of stockholders, of the Corporation, as the case may be, and also
on the Corporation.
ARTICLE NINTH
No director of the Corporation shall be liable to the Corporation or its stockholders for
monetary damages for breach or breaches of fiduciary duties as a director, provided that the
provisions of this article shall not eliminate or limit the liability of a director (i) for any breach of
the director's duty of loyalty to the Corporation or its stockholders, (ii) for acts or omissions not
in good faith or which involve intentional misconduct or a knowing violation of the law, (iii) under
Section 174 of the Delaware General Corporation Law, or (iv) for any transaction for which the
director derived an improper personal benefit. The Corporation shall, to the fullest extent permitted
by Section 145 of the Delaware General Corporation Law, as the same may hereafter be amended

or supplemented, indemnify any and all directors, officers, employees and agents of the
Corporation whom it shall have power to indemnify under such Section from and against any and
all expenses {including attorneys' fees), judgments, fines, amounts paid in settlement and other
liabilities in respect of all matters referred to in or covered by such Section. The indemnification
provided for herein shall not be deemed exclusive of any other rights to which those indemnified
may be entitled under any bylaw, agreement, vote of stockholders or disinterested directors, or
otherwise, and shall continue as to a person who has ceased to be a director, officer, employee or
agent and shall inure to the benefit of the heirs, executors, administrators and personal
representatives of such director, officer, employee or agent. No amendment to or repeal of this
Article NINTH shall apply to or have any effect on the Iiability or alleged liability of any person
for or with respect to any acts or omissions of such person occurring prior to such amendment or
repeal.
ARTICLE TENTH
This Certificate of Incorporation shall be effective as of 12:01 a.m., Eastern Time, on
November 8, 2017.
[Signature Page Follows]

IN WITNESS WHEREOF, I have signed this certificate of incorporation this 31d day of
November, 2017.
Michael II. Cole
Incorporator
[Signature Page to Smithfield Fresh Meats Corp. Certificate of Incorporation]

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060126
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYS
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,
Smithfield Fresh Meats Corporation
is hereby authorized to discharge stormwater from a facility located at:
Smithfield Fresh Meats Corporation
15855 Hwy 87 W
Tar Heel
Bladen County
to receiving waters designated as Goodman Swamp, a Class C, SW waterbody in the Lumber
River Basin; in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts 1, 11, 111, and IV of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective March 13, 2018.
"Phis Certificate of -Coverage shall remain in effect for the duration of the General Permit.
Signed this day March 13, 2018.
for William E. Vinson, Jr., P.E., Interim Director
Division of Energy, Mineral, and Land Resources
By the Authority of the Environmental Management Commission

.�.r.r
116F;A'
NC®ENR
Ham.,.. or.,......
e,.�iAo�nenT u.o Nm�AL aeao q-
Division of Energy, Mineral & Land Resources
Land Quality Section/Stormwater Permitting
National Pollutant Discharge Elimination System
PERMIT NAME/OWNERSHIP CHANGE FORM
FOR AGENCY USE ONLY
Date Received
Year
Mantra
Day
rr
1. Please enter the permit number for which the change is requested.
NPDES Permit
(or) Certificate of Coverage
1�101
II. Permit status prior to requested change.
a. Permit issued to (company name);
J�itit ;�' 1 +c' 1 c� rf1 Jea ( -/" d'1
b. Person legally responsible for permit:
_ Cn L0, IHel)
First o MI Last
RECEIVED
Title
MAR 07 2010
111111 V
Permit H ]der Mailing Address ..l
^� _f
)-g3 L
/ 2[ �1 A) c—
lZip
DENR-LAND QUALITY
STORW ATER PERMITTING
City State
(`fit 0 ) 7 7 T (, } gt, �, 52 e 7
Facility
P one Fax
c. name (discharge):
d. Facility address:
1 N LA t.J
Address
A- fL e.A) � _. �d a � 2
e. Facility contact person:
p �7
City State �zii�/
J�� 1j�,dL� P 6L, 'r 5 ( `�� �) U ` d'
First 1 M1 I Last Phone
Ill. Please provide the following for the requested hange (revised permit).
a. Request for change is a result of:
flange in ownership of the facility
- "
[Name change of the facility or owner
If other please explain:
j
b. Permit issued to (company name):
wt i aN. Fr61-5
c. Person legally responsible for permit:
I A)KX)Jow OF, i�Al
First M1 Last
Title
0x
Permit Holder Mailing Address
.r A yLA ee, I L-
city state zip
Phone, E-mail Address
�.
d. Facility name (discharge): 'S-" -'eJj tg1^ 'A FC' S 6) — Jj`,Q�►rt ���1
e. Facility address: .�j$55 �li,t�Lost_�'�
�Ij�Addre
ity State l Zip
f. Facility contact person: �t� tm?f �IG
First M[ Last
Phone E-mail Address
IV. Permit contact information (ifdifferent from the person legally responsible for the permit)
Revised Jan. 27, 2014
6*hvL—

NPDES PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
Permit contact: / d
�First �} MI Last
L1 �'! _L t ) �"V1 n W+�4�
60X yy3 Title
TMailing Address
City State Zip
Phone E-mail Address
V Will the permitted facility continue to conduct the same industrial activities conducted prior
tot eownership or name change?
Yes
❑ No (please explain) j
Required -Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS
V1. ARE INCOMPLETE OR MISSING:
YThis completed application is required for both name change and/or ownership change
_11/1equestS.
Legal documentation of the transfer of ownership (such'as relevant pages of a contract deed,
or a bill of sale) is required for an ownership change request. Articles of incorporation are
not sufficient for an ownership change.
The certifications below must be completed and signed by both the permit holder prior to the change, and
the new applicant in the case of an ownership change request. For a name change request, the signed
Applicant's Certification is sufficient.
PER jVIICERTIFICATION (Permit holder prior to ownership change):
1, �_,T st that this application for a name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not
completed and that if all required supporting information is not included, this application package will be
returned -as incom..p!ete.•C__.__.......... - ....-.----- .......... ...
9� I
�12; }
S i mature_ Date
APPLICANT CERI�FICATION `j
1, �.[���t'1 AN/
' , attes?thWat this application for a name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not
completed and that if all required supporting information is not included, this application package will be
returned as incomplete.
Signature Date
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Energy, Mineral and Land Resources
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Revised Jan, 27, 2014
1

Delaware Page
The First State
1, JEFFREY Ff. BULLOCK, SECRETARY OF STATE OF THE STATE OF
DELAWARE, DO HEREBY CERTIFY THE ATTACHED IS A TRUE AND CORRECT
COPY OF THE CERTIFICATE OF INCORPORATION OF "SMITHFIELD FRESH
MEATS CORP.", FILED IN THIS OFFICE ON THE SIXTH DAY OF
NOVEMBER, A.D. 20I7, AT 2:27 O'CLOCK P.M.
AND I DO HEREBY FURTHER CERTIFY THAT THE EFFECTIVE DATE OF
THE AFORESAID CERTIFICATE OF INCORPORATION IS THE EIGHTH DAY OF
NOVEMBER, A.D. 2017 AT 12:01 O'CLOCK A.M.
A FILED COPY OF THIS CERTIFICATE HAS BEEN FORWARDED TO THE
NEW CASTLE COUNTY RECORDER OF DEEDS.
6605607 8100
SR# 20176947282
You may verify this certificate online at corp.delaware.gov/authver.shtml
\11 i .
Mary �r, 6Woc�, f�cntary d firta
Authentication: 203529372
Date: 11-07-17

Harris; Robert
From: Bailey, Keith
Sent: Monday, January 08, 2018 12:46 PM
To: Prentice, Charlie; Harris, Robert; Bowen, Frederick; Barnett, Joseph W.; Park, Christy; Strong,
Kerry B., McAuley, Pam; Meyer, John
Subject: Fwd: Legal docs name change
Attachments: image001.jpg; ATT00001.htm; Smithfield Fresh Meats Corp.-DE-Incorpo ration.pdf;
ATT00002.htm; Certificate of Amendment (Name Change) EFFECTIVE 10-30-2017.pdf;
ATT00003. htm
Here the legal does required for the ownership change. It is a new owner for everyone except Charlotte.
Tax ID to follow.
Keith Bailey
Smithfield Foods , Inc
757 613 1283,
Begin forwarded message:
From: "Saunders, Kelly" <ksaunder_s a,smithf eld.com>
Date: January 8, 2018 at 12:28:52 PM EST
To: "Bailey, Keith" <kbailey(a-)smithfield.com>
Cc: "Meyer, John" <jwmeyer smithfield.com>
Subject: RE: Legal does name change
Keith,
The legal documents are attached. Smithfield Fresh Meats Corp. is a new entity this was not a name
change. John Morrell & Co. changed its name to Smithfield Packaged Meats Corp.
The facilities that fall under packaged and fresh are noted below.
Smithfield Packaged Meats Corp. are:
Cumming, GA
Charlotte, NC (formerly Stefano Foods)
Wilson, NC
Kinston, NC
Smithfield Fresh Meats Corp. are:
Tar Heel, NC
Clinton, NC
Clayton, NC
Thank you,
Kelly N. Saunders
Paralegal

Stale of Delaware
secretan. of State
fthlon of Corporations
Delhered 02:27 P]f M061017
MD 02:27 P1f M0612617 CERTIFICATE OF INCORPORATION
SR 201769.47282 - FIIe\umber 6605607
OF
SMITHFIELD FRESH MEATS CORP.
ARTICLE FIRST
The name of the corporation is Smithfield Fresh Meats Corp. (the "Corporation"l.
ARTICLE SECOND
The address of the Corporation's Registered Office in the State of Delaware is 1209 Orange
Street, Corporation Trust Center, in the City of Wilmington, County of New Castle, State of
Delaware, 19901. The name of the Registered Agent at such address is The Corporation Trust
Company.
ARTICLE THIRD
The purpose of the Corporation is to engage in any lawful act or activity for which
` corporations may be organized under the General Corporation Law of Delaware, but the
Corporation is not formed to engage in any act or activity requiring the consent or approval of any
state or federal official, department, board, agency or other body without such consent or approval
first being obtained.
ARTICLE FOURTH
The total number of shares of eapital stock of the Corporation which the Corporation shall
have authority to issue is 1,000 shares, with no par value.
ARTICLE FIFTH
A. The business and affairs of the Corporation shall be managed by or under the
direction of a board of directors (the "Board"), except as may be otherwise provided in the
Delaware General Corporation Law or in this Certificate of Incorporation. If any such provision
is made in this Certificate of Incorporation, the powers and duties conferred or imposed upon the
Board by the Delaware General Corporation law shalt be exercised or performed to such extent
and by such person or persons as shall be provided for in this Certificate of Incorporation.
B. Unless and except to the extent that the Bylaws of the Corporation shall be so .
required, the election of directors of the Corporation need not be by written ballot,

1 1 }
ARTICLE SIXTH
The name and mailing address of the incorporator is:
Michael H. Cole
C/o Smithfield Foods, Inc.
200 Commerce Street
Smithfield, Virginia 23430
ARTICLE SEVENTH
The Board is expressly authorized to make, alter or repeal Bylaws of the Corporation but
the stockholders may make additional Bylaws and may alter or repeal any Bylaw whether adopted
by them or otherwise.
ARTICLE EIGHTH
Whenever a compromise or arrangement is proposed between the Corporation and its .
creditors or any class of them and/or between the Corporation and its stockholders or any class of
them, any court of equitable jurisdiction within the State of Delaware may, on the application in a
summary way of the Corporation or of any creditor or stockholder thereof, or on the application
of any receiver or receivers appointed for the Corporation under the provisions of Section 291 of
the Delaware General Corporation Law or on the application of trustees in dissolution or of any
receiver or receivers appointed for the Corporation under the provisions of Section 279 of the .
Delaware General Corporation Law order a meeting of the creditors or class of creditors, and/or
of the stockholders or class of stockholders of the Corporation, as the case may be, to be summoned
in such manner as the said court directs. If a majority in number representing three -fourths (3/4)
in value of the creditors or class of creditors, and/or of the stockholders or class of stockholders of
the Corporation, as the case may be, agree to any compromise or arrangement and to any
reorganization of the Corporation as a consequence of such compromise or arrangement, the said
compromise or arrangement and the said reorganization shall, if sanctioned by the court to which
the said application has been made, be binding on all the creditors or class of creditors, and/or on
all the of the stockholders or class of stockholders, of the Corporation, as the case may be, and also
on the Corporation.
ARTICLE NINTH
No director of the Corporation shall be liable to the Corporation or its stockholders for
monetary damages for breach or breaches of fiduciary duties as a director, provided that the
provisions of this article shall not eliminate or limit the liability of director (i) for any breach of
the director's duty of loyalty to the Corporation or its stockholders, (ii) for acts or omissions not
in good faith or which involve intentional misconduct or a knowing violation of the law, (iii) under
Section 174 of the Delaware General Corporation Law, or (iv) for any transaction for which the
director derived an improper personal benefit. The Corporation shall, to the fullest extent permitted
by Section 145 of the Delaware General Corporation Law, as the same may hereafter be amended
is

or supplemented, indemnify any and all directors, officers, employees and agents of the
Corporation whom it shall have power to indemnify under such Section from and against any and
all expenses (including attorneys' fees), judgments, fines, amounts paid in settlement and other
liabilities in respect of all matters referred to in or covered by such Section. The indemnification
provided for herein shall not be deemed exclusive of any other rights to which those indemnified
may be entitled under any bylaw, agreement, vote of stockholders or disinterested directors, or
otherwise, and shall continue as to a person who has ceased to be a director, officer, employee or
agent and shall inure to the benefit of the heirs, executors, administrators and personal
representatives of such director, officer, employee or agent. No amendment to or repeal of this
Article NINTH shall apply to or have any effect on the liability or alleged liability of any person
for or with respect to any acts or omissions of such person occurring prior to such amendment or
repeal.
ARTICLE TENTH
This Certificate of Incorporation shall be effective as of 12:01 a.m., Eastern Time, on
November 8, 201'7,
rSignature Page Follows]

IN WITNESS WHEREOF, I have signed this certificate of incorporation this 31 day of

Fom, W-9
Request for Taxpayer
Give Form to the
Rev. December2o
Identification Plumber and Certification
requester. Da not
Department o1 the Treasury
send t0 the IRS.
Internal Revenue Service
1 Name (as shown on your income tax return), Name is required on this line: do not leave this line blank.
SMITHFIELD PACKAGED MEATS CORP.
N2
Business name/disregarded entity name, if different from above
m
t7r
3 Check appropriate box for federal tax classification; check only one of the following seven boxes:
4 Exemptions (codes apply only to
o
❑ IndividuaVsole proprietor or ❑v C Corporation ❑ S Corporation ❑ Partnership ❑ Trust/estwe
certain entities, not individuals; see
instructions on page 3):
o
❑single -member LLC
Limited liability company. Enter the tax cfassilication (C=C corporation, S=S corporation, P=partnership) ►
Exempt payee code (if any) 5
p
Note. For a single -member LLC that is disregarded, do not check LLC; check the appropriate box in the line above for
Exemption from FATCA reporting
c
the tax classification of the single -member owner.
code (if any) E
d❑
is
Other (see instructions) ►
tww•r �•.� • m.Mr.mea a u tl. a.011
%
6 Address (number, street, and apt, or suite no.)
Requester's name and address (optional)
COL
200 COMMERCE STREET
6 City, state, and ZIP code
SMITHFIELD, VA 23430
7 List account numbers) here (optional)
Taxpayer Identification Number (TIN)
Enter your TIN in the appropriate box. The TIN provided must match the name given on line 1 to avoid
Social security number
backup withholding. For individuals, this is generally your social security number ( However, for a
resident alien, sole proprietor, or disregarded entity, see the Part I instructions on page 3. For other
page
- [I] -I
Ll
I I
entitles, it is your empiover identification number (EIN). If you do not have a number, see How to get a
TIN on page 3. or
Note. If the account is in more than one name, see the instructions for line 1 and the chart on page 4 for IEmployer Identification number
guidelines on whose number to enter. 76- 2 1 3 1 3 1 2 1 4 1 7 1 1
Under penalties of perjury, I certify that:
1. The number shown on this form is my correct taxpayer identification number (or I am waiting for a number to be issued to me); and
2. I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue
Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest or dividends, or (c) the IRS has notified me that I am
no longer subject to backup withholding; and
3. 1 am a U.S. citizen or other U.S. person (defined below); and
4. The FATCA code(s) entered on this form (if any) indicating that I am exempt from FATCA reporting is correct.
Certification instructions. You must cross out item 2 above if you have been notified by the IRS that you are currently subject to backup withholding
because you have failed to report all interest and dividends on your tax return. For real estate transactions, item 2 does not apply. For mortgage
interest paid, acquisition or abandonment of secured property, cancellation of debt, contributions to an individual retirement arrangement (IRA), and
generally, payments other than interest and dividends, you are not required to sign the certification, but you must provide your correct TIN. See the
instructions on page 3.
Her y Signature roof �! - 1� ���y Date► Here I u.s.peraon► ]�'�f'' /�Jit[' U�Y.I
General I
Section references are to the Internal Revenue Code unless otherwise noted.
Future developments. Information about developments affecting Form W-9 (such
as legislation enacted after we release it) is at www,irs,gov0w9.
Purpose of Form
An individual or entity (Form W-9 requester) who is required to file an information
return with the IRS must obtain your correct taxpayer identification number (TIN)
which may be your social security number (SS% Individual taxpayer identification
number QTIN), adoption taxpayer identification number (ATIN), or employer
identification number (EIN), to report an an information return the amount paid to
you, or other amount reportable on an information return. Examples of information
returns include, but are not limited to, the following;
• Form 1099-INT finterest earned or paid)
• Form 1099-DIV (dividends, including those from stocks or mutual funds)
• Form 1099-MISC (various types of income, prizes, awards, or gross proceeds)
• Form 1099-8 (stock or mutual fund sales and certain other transactions by
brokers)
• Form 1099-S (proceeds from real estate transactions)
• Form 1099-K {merchant card and third party network transactions)
• Form 1098 (home mortgage Interest), 1098-E (student loan Interest), 1098-T
{tuition)
• Form 1099-C (canceled debt)
• Form 1 D99-A (acquisition or abandonment of secured property)
Use Form W-9 only if you are a U.S. person (including a resident alien), to
provide your Correct TIN.
H you do not retum Form W-9 to the requester with a TIN, you might be subject
to backup withholding, See What is backup withholding? on page 2.
By signing the Tilled -out form, you;
1. Certify that the TIN you are giving is correct (or you are waiting for a number
to be issued),
2. Certify that you are not subject to backup withholding, or
3. Claim exemption from backup withholding if you are a U.S. exempt payee. It
applicable, you are also certifying that as a U.S, person, your allocable share of
any partnership income from a U.S, trade or business Is not subject to the
withholding tax on foreign partners' share of effectively connected income, and
4. Certify that FATCA cadets) entered on this form (if any) Indicating that you are
exempt from the FATCA reporting, is correct. See What is FATCA reporting? on
page 2 for further information.
Cat. No. 10231X Form W-9 (Rev, 12.2014)

S.
Harris; Robert
From: Bailey, Keith
Sent: Monday, January 08, 2018 12:50 PM
To: Harris, Robert; Bowen, Frederick; Prentice, Charlie; Strong, Kerry B.; McAuley, Pam; Barnett,
Joseph W.; Park, Christy; Meyer, John
Subject: Fwd: Legal docs name change
Attachments: image001.jpg, ATT00001.htm; image004.jpg; ATT00002.htm; FEIN Smithfield Fresh Meats
Corp.pdf; ATT00003.htm; W9 w 200 Commerce Str address.pdf; ATT00004.htm
See federal tax ID number below.
Keith Bailey
Smithfield Foods, Inc
757 613 1283,
Begin forwarded message:
From: "Saunders, Kelly" <ksaundcrs a,smithficld.com>
Date: January 8, 2018 at 12:41:00 PM EST
To: "Bailey, Keith" <kbailey(i�smithfield.com>
Cc: "Meyer, John" <iwmever a,smithfield.com>
Subject: RE: Legal does name change
Smithfield Fresh Meats Corp. tax id number is 30-1010290
Smithfield Packaged Meats Corp. tax id number is 36-2332471
Kelly N. Saunders
Paralegal

3/1/2018
ATT00001 (003).htm
E;
(757) 357-$161 tel
[phone] fax
[phone] mobile
[e-mail]
Smithfield Foods
2O0 Commerce Street
Smithfield, VA 23430
www.smithfieldfoods.com
From: Saunders, Kelly
Sent: Monday, January 08, 201812:29 PM
To: Bailey, Keith <[e-mail] >
Cc: Meyer, John <[e-mail] >
Subject: RE: Legal docs name change
Keith,
The legal documents are attached. Smithfield Fresh Meats Corp. is a new entity this was not a name change. John Morrell & Co. changed its name to
Smithfield Packaged Meats Corp.
The facilities that fall under packaged and fresh are noted below.
Smithfield Packaged Meats Corp. are:
Cumming, GA
Charlotte, NC (formerly Stefano Foods)
Wilson, NC
Kinston, NC
file:ll/C:/Users/buddyharris/AppData[Local/Microsoft/W indowslTemporary%20intemet%20FileslContent. butlook17CU24XLI/ATT00001 %20(003).htm
1/2

3/1/2018
A7T00001 (003).htm
Smithfield Fresh Meats Corp. are:
Tar Heel, NC
Clinton, NC
Clayton, NC
Thank you,
Kelly N. Saunders
Paralegal
file:lllC:(Users/buddyharrislAppDatalLocallMicrosoftlWindowslTemporary%201ntemet%20FileslContent.Outlookt7CU24XLIlATT00001 %20(003).htm
212

K"
Energy, Mineral &
Lond Resources
ENVIRONMENTAL OLIALf'rY
October 17, 2017
Calvin Held
Smithfield Farmland Corporation -Tarheel Division
15855 Hwy 87 W
Tar Heel, NC 28392
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Subject: NPDES General Permit Renewal and Electronic Reporting Requirements
Smithfield Packing (Tar Heel Division)
NPDES Permit Certificate of Coverage (COC) Number: NCG060126
Dear NPDES Permittee:
TRACY DAVIS
Di?vector
The General Permit this facility is covered under expires on October 31, 2017. Our records indicate that
your annual fees are up to date; therefore, your coverage will be automatically renewed unless you
submit a rescission request for this permit. If you no longer need this permit, a rescission form can be
found on our website (http://goo.gi/BcgDP4).
The Stormwater Program plans to reissue this General Permit for one year with no changes. This
action has been posted for public comment on our website above (see the table of General Permits) and
published in area newspapers statewide. The public comment period for the reissuance action concludes
on November 1, 2017, and the new General Permit is scheduled to become effective on November 16,
2017, Upon issuance of the final General Permit, your coverage will be renewed for the one year
period. Instead of being mailed new Certificates of Coverage (COCs), each permittee should print off
the new General Permit Cover Page from our Stormwater Program website (with revised effective and
expiration dates) after issuance in mid -November.
Although the renewal process is automatic this year, two items require your action:
(1) you must review your permit contact information and notify us of any changes no later
than November 15, 2017.
(2) You must submit outfall information on-line for this site in preparation for electronic data
monitoring report (eDMR) requirements no later than November 30, 2017.
Permit Contact Information
Please review the permit contact information we have in our database. you can do this by clicking on
the "review the permit contacts for your facility" link on the website above and entering your permit
COC number. Ensure that Owner Affiliation and Permit Contact are accurate, and that e-mail addresses
are provided. (Note that if you already did this recently, we may not have entered the changes yet.)
''Nothing Compares.-�.-.
SState of Not-th Carchro ; Environmental Quality i Energy. Ntlnesal and Land Re,ous ces
512 N. Salisbury Street i 1612 Mail Service Center i Raleigh, North Carolimi 27699-1a12
919 70"1' 9200

To update contact information for your permit: you may simply e-mail us changes to contact
information, unless there is a change to the Owner Affiliation. Because Owner Affiliation is the person
legally responsible for the permit, we require a copy of the signed Owner Affiliation Change Form (on
our website) to make this change. Be aware that a change in company name or ownership requires a
different form (also on the website), so please contact us if you have questions about which form you
need. Changes to other contacts can be e-mailed to Laura Alexander at laura.alexander ncdenr. ov.
Submitting Outfall Information for E-Reporting
The U.S. Environmental Protection Agency (EPA) finalized the National Pollutant Discharge Elimination
System (NPDES) Electronic Reporting Rule in December 2015. The rule requires NPDES regulated
facilities to report certain information electronically, instead of filing written paper reports. EPA is
phasing in the requirements of the rule over a 5-year period. The first phase required regulated entities
to submit Data Monitoring Reports (DMRs) electronically starting on December 21, 2016,
We realize that deadline has passed, and EPA is aware that NC is working on expanding the State's
eDMR System (currently available to NPDES Wastewater Permit -holders) to include Stormwater
Program DMR reporting. As soon as eDMR is available for your permit, we will notify you. In the
meantime, we must collect information about the discharge outfalls at your facility to prepare the
system to flow data to EPA as the new federal rule mandates.
To submit outfall information to DEQ: Go to the following website and enter the discharge outfall
number, type of discharge, receiving water information, representative outfall status information, and
other details no later than November 30, 2017. The website will walk you through all steps.
The website i5: https_ZZdeg.nc.gov/about/stormwater-program/stormwater-outfall-collection
For more information on EPA's NPDES Electronic Reporting Rule, visit
http://www2.epa.gov/compliance/final-national-pollutant-discharge-elir ination-system-fides-
electronic -reporting -rule. For more information on electronic reporting to NC DEMLR, visit
http://deg.nc,goy/about/divisions/energy-mineral-land-resources/stormwater/ereporting rule or
contact Bethany Georgoulias at [phone] or via email at [e-mail], or
Robert Patterson at [phone] or via email at robert.patterson(@ncdenr.gov.
Sincerely,
aY,�,.e PM .4w,G
Annette Lucas, P.E.
Supervisor, DEMLR Stormwater Program
Cc: Stormwater Program Permit File
-75' —Nothing Compares_-___
State of North CArortna I Environmental Quality I Energy. Mineral and Land Resources
512 N. Salisbury Street I Ibl2 Mail Service Center I Raleigh, North Carolina 2769Q-1612
919 707 9200

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
February 21, 2018
Smithfield Farmland Corporation
Attn: Donovan Owens, General Manager
PO Box 99
Tar Heel, NC 28392
ROY COOPER
Governor
MICI-IAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG060000
Smithfield Farmland Corporation
Smithfield Packing (Tar Heel Division), Certificate of Coverage NCG060126
Bladen County
Dear Mr. Owens:
On February 19, 2018, a site inspection was conducted for the Smithfield Packing (Tar Heel Division) facility
located at 15855 Highway 87 West, Tar Heel, Bladen County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Mr. Robert (Buddy) Harris, Environmental Manager, was also
present during the inspection and his time and assistance is greatly appreciated. The site visit and file review
revealed that the subject facility is covered by NPDES Stormwater General Permit N00060000 under
Certificate of Coverage NCG060126. Permit coverage authorizes the discharge of stormwater from the
facility to receiving waters designated as Goodman Swamp, a Class QSw waterbody in the Lumber River
Basin and a Class C segment of the Cape Fear River in the Cape Fear River Basin.
As a result of the inspection, the facility was found to be in compliance with the conditions of the NCG060000
permit. Please refer to the enclosed Ccmp!iance Inspection Report for additional comments and.
observations made during the inspection.
Please be advised that violations of the NPDES Stormwater 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 contact me at (910)
433-3394 or by e-mail at [e-mail].
Sincerely,
eichaelLawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure
ec: Robert P. Harris, Jr., Environmental Manager — Smithfield Packing (Tar Heel Division) ✓
Timothy L. Weaver, Wastewater Superintendent — Smithfield Packing (Tar Heel Division)✓
cc: FRO --- DEMLR, Stormwater Files-NCG060126
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, NC 29301
910-433-3300

r
Permit: NCG060126
SOC:
County: Bladen
Region: Fayetteville
Compliance Inspection Report
Effective: 11/16/17 Expiration: 10/31/18 Owner: Smithfield Farmland Corporation - Tarheel
Division
Effective: Expiration: Facility: Smithfield Packing (Tar Heel Division)
PO Box 99
Contact Person: Robert P Harris
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Tar Heel NC 28392
Title: Environmental Manager Phone: [phone]
Certification: Phone:
Robert P Harris 910-862-5248
Inspection Date: 02/19/2018 Entry Time: 9:30AM
Primary Inspector: Mike Lawyer ��,�
Secondary Inspector(s):
Exit Time: 12:15PM
Phone: [phone] ExV-2131
33T/
Reason foi Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Food/Tobacco/Soaps/Cosmetics/Public Warehousing Slormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

A 1
1 i
Permit: NCG060126 Owner - Facility: Smithfield Farmland Corporation - Tarheel Division
fnspoction Date: - 02119/2018 - Inspoctior Type : Comptiance Evaluation . . • •- Reason for Visit-- Routtna
Inspection Summary:
Met with Robert (Buddy) Harris, Environmental Manager. Made observations of site conditions including stormwater
discharge outfalls; storage areas for drums and totes within required secondary containment structures, loading/off-loading
areas, and wastewater system. Reviewed facility's Stormwater Pollution Prevention Plan (SPPP), which was last revised on
212118 and contained all permit -required components. The SPPP indicates that no significant spills have occurred at the
facility since 2010. A recommendation was made to specifically document an updated list of any significant spills for the
previous three years or notation that no spills have occurred during each annual review/update as detailed in Part ll, he
A, item 8(a) of the NCG060000 permit. Additional documentation of the annual non-stormwater certification and monthly
checklist for secondary containment areas was also provided for review. According to the SPPP, the facility's last sampling
events of stormwater discharges were conducted in June and August of 2013 both of which showed exceedances of the
benchmark value for fecal coliform. Along with previous and consistent benchmark exceedances for fecal coliform, facility
has been in the Tier Two monthly monitoring schedule over the past two permit cycles. After the 2013 sampling events,
steps have been taken to reduce the potential for stormwater discharge. Since that time, analytical monitoring records
indicating 'No Flow' for the facility's two stormwater outfalls have been submitted on a monthly basis per the Tier Two permit
conditions. Based on this, Mr. Harris inquired about continuing to submit monitoring records on a monthly basis. The
Fayetteville Regional Office is willing to consider decreasing the monitoring and reporting frequency to quarterly provided that
our office receives a letter from the facility outlining the steps mentioned above to reduce the potential for stormwater
discharge. The letter should also detail the work that is currently underway to reroute the trucks bringing in the live hogs and
any other actions that have been or will be taken to address stormwater runoff/discharge from industrial activity areas. A
copy of the detailed site map showing industrial activity areas, site topography, all drainage features and structures,
drainage area boundaries, direction of flow in each drainage area, etc. should also be provided with the letter. The decision to
decrease monitoring/reporting frequency will have a contingency that if/when a stormwater discharge occurs resulting from a
measurable storm event as defined by the permit, then monthly monitoring/reporting shall resume.
Page: 2

Permit: NCGO60126 Owner - Facility: Smithfield Farmland Corporation - Tarheei Division
Inspection Date: 02/19/2018 Inspection Type : Cnmpliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices"?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment: Not Evaluated. See comment below.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: Monthly analytical monitoring records for the past several years indicate 'No Flow'. See
inspection summary, for further details.
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non Stormwater) discharges?
Comment:
Yes No NA NE
■❑❑❑
❑ ❑ ❑
IN ❑ ❑ ❑
®❑❑❑
■❑❑❑
N ❑ ❑ ❑
■❑❑❑
■❑❑❑
■❑❑❑
❑ ❑ ❑
❑ .❑ ❑
❑ ❑ ❑
■❑❑❑
s❑❑❑
■❑❑❑
Yes No NA NE
❑❑❑■
Yes No NA NE
❑❑e❑
Yes No NA NE
■❑❑❑
N 1111 ❑
❑ ❑ E ❑
■❑❑❑
Page: 3

Smithfield
Farmland
FRESH MEAT GROUP
November 27, 2013
-NC Department of Environment and Natural Resources w __
Division of Energy, Mineral and Land Resources
Stormwater Permitting Unit
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Fayetteville Regional Office DEC 2 2013
225 Green Street
Suite 714
Fayetteville, North Carolina 28301-5095
RE: Assessment of Best Management Practices for Facilities that Use or Process Animal Fats/
Byproducts, Smithfield Packing Company, 15855 Highway 87 West Tar Heel, NC 28392
Certificate of Coverage No. 060126
To those concerned:
Enclosed is a narrative description of material handling activities conducted at the Smithfield/ Farmland
facility located at 15855 Highway 87 West in Tar Heel, North Carolina and a feasibility evaluation as to
whether reduced exposure can be achieved at the site. A proposed plan is shown. These documents
are being submitted as required under Section E: Assessment of BMPS of the State of North Carolina
DENR General Permit No. NCG060000 to discharge stormwater under the National Pollutant Discharge
Elimination System for facilities primarily engaged in Food and Kindred Products activities.
Target Date for
Additional BMPs
Completion
Provide stormwater pollution prevention training for livestock truck drivers
1-Jun-14
Identify and implement additional pollutant source reduction practices (e.g. street
sweeping, draining of trailer after unloading, good housekeeping)
1-Jun-14
Identify and implement additional pollutant source reduction practices
1-Jun-14
Implement stormwater inlet, catch basin, and conveyance inspection and cleaning
program
1-1un-14
Identify management strategies for existing vegetative swales
1-Jun-14

If you have questions or concerns, please contact me at 910-862-7675 or Susan Murphy at Smithfield
Farmland at 816-243-2730.
Sincerely,
i
Kyle Narron /
General Manager
fly di s signature I certify dat this report is accurate wtd complete to the best of my knowledge
Enclosure
• Material Handling Activities and Reduced Exposure Evaluations

Smithfnelci
FarmIand
;RESH YEAT GROUP
Assessment of Best Management Practices
Smithfield Tar Heel, NC
Material Handling Activities, Stormwater Flow, and Potential Pollutants
As part of the plant design, storm water exposed in significant areas of industrial activity is
contained on site, and treated in the onsite wastewater treatment plant. A review of site storm
water conveyance systems and flow of storm water off site was conducted, resulting in the
assessment of four geographical areas. Each area is described, and general industrial activities
such as these were assessed:
• Outdoor storage locations
• Loading and unloading operations DEC 2 2013
• Material handling activities
• Waste management practices
• Dust generation processes
Potential storm water exposure pollutants were identified. Best Management Practices (BMPs)
that are currently implemented and additional BMPs that are recommended are listed for each of
the four areas:
Area 1 — North Front of Facility Outfall 41 via concrete culvert, receiving waters
are the Cape Fear River in Cape Fear Basin
• Activities
o Employee parking
o Entrance & exit road for live haul trucks
• Potential Pollutants
o BOD, TSS, TKN, oil & grease, fecal coliform, pH
• Control Measures Implemented
o Structural
■ Retention pond with a weir
o Good Housekeeping
■ Daily
■ Regular cleanup including weekly street sweeping
o Employee Training
■ Annually
o inspections to assess BMP effectiveness
■ Monthly
o Monitoring
o Monthly sampling - quantitative and qualitative analyses for
comparison to Benchmarks

Area 2 - South Front and South End of Facility-- Outfall #2 as sheet flow to
Goodman's Swamp, receiving waters are Big Swamp River in Lumber River Basin
• Activities
o Employee parking
_— o Livestock truck staging _
-- - - - - - - o Livestock -unloading --- --- - -- - - - - - - -
o Livestock holding pens
• Potential Pollutants
o BOD, TSS, TKN, oil & grease, fecal coliforms, pH
• Control Measures Implemented
o Structural
■ Sloped concrete pad at livestock unloading
o Good Housekeeping
■ Daily cleanup of area
o Management of Runoff
■ Grassy Swale
o Employee Training
■ Annually
o Inspections to assess BMP effectiveness
■ Monthly
o Monitoring
■ Monthly sampling - quantitative and qualitative
analyses and comparison to benchmarks
Area 3 - West Side of Facility Rear Corm water from this area discharges to the
wastewater treatment plant during typical and expected weather circumstances
Activities
o
truck and trailer parking
o
trailer and pallet washing
o
wastewater pretreatment
o
rendering and byproduct storage
o
solid waste collection
o
chemical storage
o
used oil storage
o
maintenance
o
used equipment storage
o
empty drum and tote storage
o
truck weighing
o
generators
o
fuel storage
o
company vehicle fileling

• Potential Pollutants
o BOD, TSS, oil & grease, fecal coliforms, pH, manganese,
copper
• Control Measures Implemented
o Structural
■ Sloped concrete pad at livestock unloading
-----_--- -- opedtrailer wash area wither urn edAo-
-_- wastewater pretreatment —
Pallet
■ wash flows into the raw wet pit then to
wastewater pretreatment
■ Used oil tank and rendered material tanks located inside
containment
■ Curbed concrete area at Rendering drains via catch
basin to pretreatment
■ Air emissions scrubbers at Rendering
■ Bulk chemical tanks in secondary containment that
drains to wastewater
■ Drums and totes of chemicals stored in bermed area
■ Diesel tanks at both Generator Buildings in secondary
containment
■ Catch basins at pallet and trailer wash, between the
plant building and rendering, the back of rendering, and
wastewater pretreatment buildings route flow to the
wastewater pretreatment system
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste
materials
■ Waste handling SOPS
■ Routine inspections of drums, tanks, containers
o Minimizing exposure
■ Polymers stored and mixed in a roofed building with a
concrete floor
■ Enclosed trash compacters with drains underneath to
convey liquids to the wastewater treatment plant
■ Used oil transfer area is covered by a roof
■ Rendered material load -outs located inside
■ Used equipment cleaned and drained of fluids
■ Used equipment stored on covered concrete pad at
Engineering
■ Drums and totes of chemicals stored in roofed area
■ Generators are located inside

o Operation and Maintenance
■ Proper cleaning of drums and totes & storage in designated
areas
■ Delivery drivers required to stay with trucks during transfer
operations
■ Controlled access to company fueling
• Unloading and loading SOPs
--C-o-ntai-nm-me-elearb, labeled with eontents
�Containers are closed — -- --- - - - -- - -- --- ---
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
o Management of Runoff
■ Grassy Swale
■ Fresh product trailer purge & runoff from wash area pumped
to containment area then to effluent storage basin at
wastewater treatment plant
• Catch basins at the rear of the plant direct runoff to a
containment basin/ splitter structure; first flush is pumped to
the effluent storage basin at the wastewater treatment plant;
if flow exceeds the capacity of the pump, two gates can be
opened to discharge to Outfall #2 via a ditch
o Pest Management
■ Applications and maintenance by licensed contractor
■ Bait stations for rodent control are protected from
stormwater
o Employee Training
• Annually
o' Inspections
■ Monthly
Area 4 — Wastewater Treatment Plant --storm water in this area discharges to the
onsite wastewater treatment plant
a Activities
o Wastewater treatment and discharge
o Chemical storage
Potential Pollutants
o BOD, TSS, oil & grease, fecal coliforms, pH
Control Measures Implemented
o Good Housekeeping
• Daily
■ Regular pickup and disposal of waste materials
■ Dry clean-up utilized
• Routine inspections of drums, tanks, containers and piping
o Operation and Maintenance
■ SOPs for material handling
• Preventative maintenance of equipment
o Management of Runoff
0 Runoff flows northeasterly into vegetated area

o Employee Training
■ Annually
o Inspections to assess BMP effectiveness
• Monthiy
Evaluation of wildlife/ animals on -site:
_ _ . __ _ it s_including_1;0 O:F-Te s aand• seagulCs-have_been_o serve .at wamwate"r=(On-the- Mil
gallon emergency storage lagoon). Deer, fox, bear, turkeys, alligators, snakes, feral cats and
feral dogs are occasionally seen on the property. Wildlife contributes to fecal coliforms at the
site; however, the primary contributor of these microorganisms is the manure from pigs being
transported on -site for processing.
Feasibility Study
Material handling and processing activities exposed to rainfall and run-on flows were reviewed
to determine the feasibility of changing methods of operation and/or storage practices to
eliminate or reduce exposure to rainfall and run-on flows. The following table summarizes
findings.
Exposed Activities
Feasibility
Corrective Actions
Rank
Technical
Economic
Livestock trailer traffic
before and after
unloading (Areas 1, 2
& 3)
Y
Y
Provide stormwater pollution
prevention training for livestock truck
drivers
1
Y
Y
Identify and implement additional
pollutant source reduction practices
(e.g. street sweeping, draining of
trailer after unloading, good
housekeeping)
2
Y
Y
Identify and implement additional
pollutant source reduction practices
3
Y
Y
Implement stormwater inlet, catch
basin, and conveyance inspection and
cleaning program
4
Y
Y
Identify management strategies for
existing vegetative swales
S

~� 7
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Calvin Held
Smithfield Packing Company Inc
15855 Hwy 87 W
Tar Heel, NC 28392
Dear Permittee:
Charles Wakild, P. E.
Director
December 4, 2012
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Smithfield Packing (Tar Heel Division)
COC Number NCG060126
Bladen 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. Genera! -Permit a4thorizes 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 lI 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/web/wq/ws/suhttp://portal.ncdenr.org/web/wglws/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: 919M7.6492
Internet: www.ncwale�uali�.org
An Equal Opportunity 1 Affirmative Action Employer
NorthCarolina
Naturally

Calvin Held
December 4, 2012
Page 2of2
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 B, C: A lower TSS benchmark of 50 mg/I for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections B, 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 B, 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 B, 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: DWQ Central 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. NCG060126
STORM WATER
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,
Smithfield Packing Company Inc
is hereby authorized to discharge stormwater from a facility located at:
Smithfield Packing (Tar Heel Division)
PO Box 99
Tar Heel
Biaden County
to receiving waters designated as Goodman Swamp, a class C;Sw waterbody in the Lumber
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. 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 4ei day of December, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

\o�OF W A rFRQG Beverly Eaves Perdue, Governor
{� Dee Freeman, Secretary
> North Carolina Department of Environment and Natural Resources
a -c
Coleen H. Sullins, Director
Division of Water Quality
SURFACE WATER PROTECTION SECTION
PERMIT NAME/OWNERSHIP CHANGE FORM
I. Please enter the permit number for which the change is requested.
NPDES Permit (or) Certificate of Coverage
N I C I S 10 1 p 1 OTC N G G p +r, O I 2f.
1I. Permit status rior to requested change. p
a. Permit issued to (company name): m;4� ieu PD(�.ir M o�, - rar R �iy1600 }
b. Person legally responsible for permit: elrnt Qr n" S
Fi st Mt bast
V & e n e raa AA&n
Title
87 taQS�—
rmit Holder Mailing Address
-ar fdcaA N L 2. 83q
City �^ State Zip
(110 ) SG2_-7L7S ( ) —
Phone Fax
c. Facility name (discharge): S i i #,id iV
d. Facility address: 15 5 S 7 role -$+-
Address
Toter H cell N C. 283 9'L
City State Zip
e. Facility contact person: 5yj W j a.. L-a"t, (Cl ID ) 8 79 - %. 8
First 1 MI Last Phone
III. Please provide the following for the requested change (revised permit).
a. Request for change is a result of: ❑ Change in ownership of the facility
Name change of the facility or owner
If other please explain:
b. Permit issued to (company name):
c. Person legally responsible for permit:
MAR 15 2012
DENR • WATER QUALITY
WETLAN08MD STORMWATER BRANCH
Sc,.Ir't L
Cojvi n
First ""MI —Last
V P 1 Ge4trod Man r
Title
15855 Hl v5 , 87 Wf-4
rmit flolder Mailing Address
NG T 283a2
City a hf ZC I State Zip
(ql b ) 862- 76 75 v irl htu 5 trrl wh iv tj. C-Cyn
Phone E-mail Address
d. Facility name (discharge): 6c-n1t. 0,5 64yr2_.
e. Facility address: 6CWLe, aq.
Address
s4MQ-
City State 'Lip
f. Facility contact person: —T 0Ome's A. (;rtz f)
First M] Last
(AID } VL1-5C3$ s"^`���.(D/V_�
Phone &Jnail Address
Revised 812008

PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
W. Permit contact information (if different from the person legally responsible for the permit)
Permit contact: 7[homwt, A. Grea-e)
First ml Last
Fn v; n endal Am ,en
Title
�5855 _f-I cai� w _E 7 (tea,
Mailing Address
PC, .2 Cl
T City Gx♦ State Lip
(tl to )irQ -7675 gam -4 c>m5,rczng�> cyr,4 vq1,414.com
Phone E-mail Addr
V. Will the permitted facility continue to conduct the same industrial activities conducted prior
to this ownership or name change?
XYes
❑ No (please explain)
VI. Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS
ARE INCOMPLETE OR MISSING:
❑ This completed application is required for both name change and/or ownership change
requests.
❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed,
or a bill of sale) is required for an ownership change request. Articles of incorporation are
not sufficient for an ownership change.
.....................................................................................................4.................
The certifications below must be completed and signed by both the permit holder prior to the change, and
the new applicant in the case of an ownership change request. For a name change request, the signed
Applicant's Certification is sufficient.
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
I, , attest that this application for a name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not
completed and that if all required supporting information is not included, this application package will be
returned as incomplete.
Signature Date
APVLICANT CERTIFICATION
I;=, attest that this application for a name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not
completed and that if all required supporting information is not included, this application package will be
returned as incomplete.
Ila 3 2sm 2—
Signature Date
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Water Quality
Surface Water Protection Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Revised V2008

mj®
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Sylwia Labudde, Coordinator Environmental
Smithfield Packing (Tar Heel Division)
PO Box 99
Tar Heel, NC 28392
Dear Permiee:
Division of Water Quality
Charles Wakild, P.E.
Director
March 5, 2012
Subject: NPDES Stormwater Permit Coverage Renewal
Smithfield Packing (Tar Heel Division)
COC Number NCG060126
Bladen 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 website 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 Jennifer ]ones 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: 91 M07-63001 FAX [phone] L Customer Service: 1-877-623-6748
Internet www.ncwaterquality.org
An Equal Opportunity 1 Affirmative AcJcn Employer
One
North Carolina
;Vatmallf

oFWFrzq Permit Coverage
Renewal Application Form
5 National Pollutant Discharge Elimination System Certificate of Coverage Number
Stormwater General Permit NCG060000 NCG060126
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
Smithfield Packing Company Inc
Sylwia Labudde, Coordinator Environmental
PO Box 99
Tar Heel, NC 28392
910-862-7675 Ext.605
910-862-5276
[e-mail]
FacilitvlPermit Contact Information
Facility Name:
Smithfield Packing (Tar Heel Division)
Facility Physical Address:
PO Box 99
Tar Heel, NC 28392
Facility Contact:
Sylwia Labudde, Coordinator Environmental
Mailing Address:
PO Box 99
Tar Heel,NC 28392
Phone Number:
910-862-7675 Ext.605
Fax Number:
910-862-5276
E-mail address:
[e-mail]
Discharge Information
Receiving Stream:
Goodman Swamp
Stream Class:
C;Sw
Basin:
Lumber River Basin
Sub -Basin:
03-07-53
Number of Outfalls:
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://h2o. enr.state.nc. us/su/Impaired Waters TMDU
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
SW General Permit Coverage Renewal
Please return this completed renewal application form to: Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Smi4hfield
CERTIFIED MAIL#
February 1", 2012
Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
To Whom It May Concern:
G_ iAr a i- (('Ci C `) p Y
RE: Smithfield Packing Company, Tar Heel Division
Stormwater General Permit # NCG06000
COC # NCG060126
Smithfield Packing Co —Tar Heel
Environmental Department
P 0 Box 99
Tar Heel, NC 28392
Smithfield Packing Facility would like to notify the Division of Water Quality our desire to
maintain permit coverage once the general NPDES Storm water permit is renewed. Our current
certificate of coverage is set to expire on October 315L, 2012 and we are expected to receive a
six month renewal notice in the near future which will be completed and returned to the state
office.
If there are any questions, please do not hesitate to contact me at my email or cell phone 910
874-5638
Thank you for your time,
Tom Green
Environmental Coordinator
Smithfield Packing Company, Tar Heel Division
[e-mail]

6G
k«A
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
February 8, 2011
Smithfield Packing Company, Tar Heel Division
Attn: Sylwia LaBudde, Environmental Coordinator
PO Box 99
Tar Heel, NC 28392
Subject: Chlorine Dioxide Application Study
Smithfield -Tar Heel Facility-NCG060126
Bladen County
Dear Ms. LaBudde:
0
Dee Freeman
Secretary
k "(20W[No
1716
ip
FEB
1 0 2011
DENR - WATER QUAUTy
WETiAM AND FUMWATER BRANCH
Upon review of your letter dated June 28, 2010 regarding a Request to Conduct a Chlorine Dioxide Application Study at
the Smithfield -Tar Heel facility in Bladen County, along with additional information received via letters dated September
10, 2010 and January 21, 2011 as well as an e-mail received on February 1, 2011, staff with the Fayetteville Regional
Office of the Division of Water Quality hereby approves your request.
Procedures for application shall be carried out as detailed in the Maintenance SOP #5 that was provided with the
September 10, 2010 letter. These procedures include, but are not limited to: application by authorized personnel only, use
of an industrial sweeper equipped with a spray bar capable of discharging at a rate of 3.6 gallons per minute, application
not occurring during or immediately preceding a rain event, etc. In addition, application shall only occur in areas of the
facility that drain to Outfall #002.
In order to facilitate continued use of the proposed chlorine dioxide solution, chloride and toxicity will be monitored at
Outfall #002. This monitoring is in addition to and should coincide with the Analytical Monitoring as described in the
NCG060000 general stormwater permit for which the facility has coverage. Reports of this additional monitoring should be
provided to the Fayetteville Regional Office within 30 days from receipt of the results of analysis. To account for possible
seasonal fluctuations and provide a high level of confidence regarding success, our office recommends a minimum time
frame of twelve months to conduct the study.
Should the need arise to modify any part of the proposed study; you should contact this office for approval prior to making
any such modifications. if you have any questions or concerns, please contact Mike Lawyer or myself at [phone].
Sincerely,
a'.�iW"
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSH: MLlml
cc: FRO -Surface Water Protection
Stormwater Permitting Unit
Location: 225 Green Street, Suite 714. Fayetteville. North Carolina 28301
Phone: [phone] FAX [phone] Customer Service: 1.877-623-6748
Internet: httpafporial.ncdenr.ora?webiw.q
None
rthCarolina .
;Vaturally
An Equal Qpporlunity h Affirmative Action Emnloyer

j;A
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
November 10.2010
Smithfield Packing Company, Tar Neel Division
Attn: Sylwia LaI3udde, Environmental Coordinator
1'0 Box 99
Tar Heel, NC 28392
Subject: Chlorine Dioxide Application Study
Smithfield -Tar 1-ieel Facility-NCG060126
Bladen County
Dear Ms. LaBudde:
Dee Freeman
Secretary
Staff with the Fayetteville Regional Office as well as the Stormwater Permitting Unit of the Division of
Water Quality has reviewed your letter dated September 10, 2010 in response to our comments and concerns
regarding the Request to Conduct a Chlorine Dioxide Application Study at the Smithfield -Tar Heel facility
located in Bladen County. While the majority of our concerns and suggestions have been addressed, the issue of
conducting toxicity testing is unresolved. Due to the unknown nature of residual effects of the chlorine dioxide
solution as well as the potential for toxic effects on fish and other aquatic life, we cannot approve your request
without the ability to conduct toxicity testing in addition to chloride and the other parameters as listed in the
NCG060000 general permit. We understand your position that a laboratory may need advance notice of an
incoming sample so that they can be prepared to run the test, however it is not clear in your letter how many
laboratories with which you have communicated. We encourage you to contact other labs in the state that may
be able to offer their services with varying degrees of notification. Staff in the regional office or with the
Stormwater Permitting Unit can assist you in obtaining contact information for other labs if needed.
BSH: MLlml
cc: PRO -Surface Water Protection
Stormwater Permitting Unit
Location: 225 Green Street, Suite 714, Fayetteville, North Carolina 28301
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterouality.org
An Equal Opporiuniry I Afri,rnative Action Emplayer
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section-
t�
i i Zip l0
DENR -- �!'Arr rt fltlALiTY
waflsndr & Y[s•.rfv 3tP_; 9ranch
otic
NorthCarolina
Naturallrf

NCDEHR•
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
August 27, 2010
Smithfield Packing Company, Tar Heel Division
Attn: Sylwia LaBudde, Environmental Coordinator
PO Box 99
Tar Heel, NC 28392
Subject: Chlorine Dioxide Application Study
Smithfield -Tar Heel Facility-NCG060126
Biaden County
Dear Ms. LaBudde:
Dee Freeman
mg
Secre
nn
!1
AUG v o ?01�
DENR C`t1AL!
ratland.,
The Division of Water Quality is in receipt of your letter regarding Request to Conduct a Chlorine
Dioxide Application Study at the Smithfield -Tar Heel facility located in Bladen County. Staff with the
Fayetteville Regional Office as well as the Stormwater Permitting Unit in Raleigh have reviewed your proposal
and offer the following comments and concerns.
We recognize the purpose of the study would be to address the concern of the amount of fecal coliform
present in stormwater runoff from the facility, which based on recent monitoring events, has exceeded the
Benchmark Value contained in the current NCG060000 general stormwater permit. While this is certainly a
valid concern and should be addressed accordingly, our lack of knowledge and experience with the use of a
chlorine dioxide solution for this purpose raises other concerns with residual pollutants/by-products after
breakdown, possible toxicity to receiving waters, and overall effectiveness. We suggest including monitoring
parameters such as chlorides and/or effluent toxicity testing in addition to the current parameters in the general
permit including fecal coliform, the parameter of concern.
The study proposes application "...periodically throughout the week during non -rainy days..." and
discusses adjusting "...the frequency of application as needed." This approach is certainly appropriate and
reasonable, however there is no detail as to how these procedures would be carried out or properly enforced.
Please provide a more comprehensive SOP and list the responsible personnel as well as necessary actions to be
taken in the event of a spill/release or observations of impacts to the receiving waters. Additionally, we
recommend that the study be conducted throughout a twelve month period to accommodate for any necessary
adjustments as well as seasonal fluctuations.
Lastly, according to the study proposal, monitoring of residual chlorine has already begun to establish
baseline figures, which was measured at levels between 17-50pg/L of free chlorine. Based on the nature of the
chlorine dioxide solution as purported in the attached research, analysis for residual chlorine may not be an
Location: 225 Green Street, Suite 714, Fayetteville, North Carolina 28301
Phone: 91"33-33001 FAX: [phone] Customer Service:1-877-623-6748
Internet: www ricwateryuality.org
NonhCarolina
An Equal Opportunity 1 Alfrmalive Action Employer

appropriate test as opposed to chlorides; chlorites, or other chlorine salts. Also, the study implies reporting any
values less than 501ig/L as zero. We would not concur with this request and ask that all values be reported as the
value determined during analysis. Any background or baseline figures wouid be used in comparison with data
obtained during the study for purposes of'determining any residuals/effects of the chlorine dioxide solution.
Division staff that has reviewed the proposal feels as though the study is worthwhile and along with you
and your staff look forward to positive results with no negative impacts to water duality. However, prior to
further review and approval of this request, you are asked to respond to the Fayetteville Regional Office in
addressing the aforementioned concerns.
Sincerely,
Beiinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSI -I: MI./ml
cc: FRO -Surface Water Protection
Stormwater Permitting Unit

1
Sprinkle, Dina
From: [e-mail]
Sent: Tuesday, May 18, 2010 11:29 AM
To: Sprinkle, Dina
Subject: RE: Change of contact for Tar Heel
Dina;
Thank you. Please put me down as the contact person for all of the permits in your system.
We have had issues with renewal and fee notices going to a variety of people and this way
they will all make it back to me. Again, thank you for your help.
Sylwia LaBudde
Environmental Coordinator
Smithfield Packing Co., Tar Heel Division
15855 Highway 87 West
Tar Heel, NC 28392
Work [phone] x 605
Cell [phone]
Fax [phone]
sylwialabudde(lsmithfield.com
-----Original Message -----
From: Sprinkle, Dina [mailto:dina.sprinkle[ncdenr.gov]
Sent: Tuesday, May 18, 2010 10:00 AM
To: Labudde, Sylwia
Subject: RE: Change of contact for Tar Heel
Good Morning Sylwia,
Here is a breakdown on what we have in our permit database:
Owner -
Facility -
Active Permits
Owner -
Facility -
Active Permits
WS0601006
Smithfield Packing Company,
Smithfield Packing (Tar Heel
- NCG060126 and WQ0014868
(-: to »x- a tv
Smithfield Packing Company,
Tarheel Plant
Inc
Division)
Inc
- NCO078344, WQ0010892, WS0601002,
®ENR--FR®
MAY 2 4 1010
DWQ
When I make ownership changes, it affects all permits for that owner.
I'm only informing you of this because WQ0010892 (Reuse permit),
W50601002 and WS0601006 (Water Supply Well Constructions permits) were not listed on your e-
mail and I didn't want to make any changes that affected these permits without your
permission.
Also, unfortunately, I will not be able to update the records for the Public Water Supply
permit and the Air permit as I do not have access to non-DWQ permits. If you have trouble
finding contacts for these permits, please let me know and I will see if I can assist you.
Thanks and I look forward to hearing from you,
Dina
1

R!
Dina Sprinkle
NCDENR/DWQ/Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Office - [phone]
Fax - [phone]
dina.sprinkle(ancdenr.eov
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.
-----Original Message -----
From: [e-mail] [mailto:[e-mail]]
Sent: Monday, May 17, 2010 3:19 PM
To: Sprinkle, Dina
Cc: paulwright(@Smithfield.com
Subject: Change of contact for Tar Heel
Importance: High
Dina,
Per our earlier conversation; please note that the contacts for Smithfield Packing Company,
Tar.Heel Division have changed for the following permits:
PWS - 309527
NPDES Stormwater - NCG060126
NPDES Wastewater - NC0078344
Title V Air Permit - 07221T13
Land Application - WQ0014868
I will be the main contact for all correspondence associated with the above stated permits
(including billing and renewals).
Main Contact:
Sylwia LaBudde
Environmental Coordinator
Smithfield Packing Co., Tar Heel Division
PO BOX 99
Tar Heel, NC 28392
2

Work [phone] x 605
Cell [phone]
Fax [phone]
svlwialabudde(@smithfield.com
Additionally, please edit your records to reflect the individuals listed below as they relate
to these permits.
Signatory Authority on DMR Reports ONLY (Permittee):
Paul Wright
Plant Engineer
PO BOX 99
Tar Heel, NC 28392
Work [phone] x 244
Cell [phone]
Fax [phone]
[e-mail]
Operator in Responsible Charge (ORC) on DMR Reports ONLY:
Timothy Weaver
Wastewater Supervisor
PO BOX 99
Tar Neel, NC 28392
Work [phone] x 760
Cell [phone]
Fax [phone]
timweaver(@smithfield.com
3

r
Please remove Larry Johnson, Randy Clark and Charles Fierro from all of your records since
they are no longer employed with Smithfield.
Sylwia LaBudde
Environmental Coordinator
Smithfield Packing Co., Tar Heel Division
PO BOX 99
Tar Heel, NC 28392
Work [phone] x 605
Cell [phone]
Fax [phone]
[e-mail]
This communication (including any attachments) is confidential and is intended to be
privileged pursuant to applicable law. -
If you are not the intended recipient, or the employee or agent responsible for delivering it
to the intended recipient,then you are hereby notified that the dissemination, distribution
or copying of this communication is prohibited. If you -received this communication in error,
please notify Smithfield Foods, Inc. immediately by telephone (+1
757-365-3000) and then delete this communication and destroy all copies thereof.
This communication (including any attachments) is confidential and is intended to be
privileged pursuant to applicable law.
If you are not the intended recipient, or the employee or agent responsible for delivering it
to the intended recipient,then you are hereby notified that the dissemination, distribution
or copying of this communication is prohibited. If you received this communication in error,
please notify Smithfield Foods, Inc. immediately by telephone [phone]) and then
delete this communication and destroy all copies thereof.
2

[Fwd: aut1a11 monitoring]
Subject: [Fwd: outfall monitoring]
From: Mike Lawyer <[e-mail]>
Date: Tue, 31 Mar 2009 09:01:34 -0400
To: Bethany Georgoulias <Bethany.GeorgouIlas a ncmai].net>
Meant to copy you on this.
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 correspondence to and from this address may be subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Subject: outfall monitoring
From: Mike Lawyer <[e-mail]>
Date: Tue, 3 l Mar 2009 08:56:13 -0400
To: jeff-mussclwllitc@smithl:ield.cotn
Jeff,
Per our telephone conversation on March 19, 2009, monitoring should continue at the
outfall located at the south end of the facility where recent analyses have shown
exceedances for fecal coliform. Based on recent spill history and the relatively high
values of fecal coliform at this outfall, the DWQ is not comfortable with excluding
monitoring at this location. As exceedances have occurred twice in a row for the fecal
coliform parameter at this outfall, monthly monitoring for this parameter shall
continue until such time as three consecutive samples show results below the benchmark
value or all practical measures to address this issue have been taken and the DWQ
determines that the monitoring frequency may be reduced. You are asked to please
provide the Fayetteville Regional Office of the DWQ with any and all measures or
actions that are taken to try and address the fecal coliform concern.
Also, it -has been hrought to my attention that the truck entrance road to the plant
where hogs are transported in and products are transported out is considered as part
of Smithfield's industrial activity. Therefore, monitoring of the outfall located
adjacent to this entrance road should be reinstituted.
If you or your staff has any questions or concerns with these matters, please contact
me or Bethany Georgoulias with the Stormwater Permitting Unit in Raleigh at
919-807-6372.
Thanks,
Mike
Michael Lawyer
Environmental Specialist
NCDENR--Division of Water Quality
Surface Water Protection Section
I oft 3/31/2009 10:28 AM

[]`\�,d: out1a11 monitoring]
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax; (91C)986-0707
*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.
----...... __ "' _.---1.... .-...- --- .
oatfall monitoring.eml
Content -Type: message/r022
i '
Content -Encoding: 7bit
ol ? 3/31/2009 10:28 AM

Michael 1% Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Suliins, Director
Division of Water Qu,rlity
December 17, 2008
Jeff Musselwhite
Smithfield Packing Company, Inc.
15855 Highway 87 West
Tarheel, NC 28392
Subject: NPDES Stormwater Permit Coverage Renewal
Smithfield Packing Company, Inc.
COC Number NCG060126
Bladen County
Dear Permittee:
In response to your renewal application for continued coverage under stormwater General Permit NCG06000D, 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 stormwater General Permit NCGO60000
• A copy of a Technical Bulletin for the General Permit
• Five copies of the Discharge Monitoring Report (DMR) Form
• Five copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater only, and it specifies your obligations with respect to stormwater
discharge controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself with all
the changes in the reissued permit.
The more significant changes in the General Permit since your last Certificate of Coverage. include the following:
• Part I Section A — A new notation that the No Exposure Exclusion from permitting option may be available to the
permittee.
• Part I Section A — A new provision that facilities draining to 303(d) listed waters, or in watersheds with an approved TMDL,
may not be eligible for renewed coverage under the General Permit.
• Part 11 Section B Table 1 — An increased sampling frequency from once per year to twice per year.
• Part 11 Section B Table 3 — Benchmark concentrations now replace cutoff concentrations; the elimination of the option to
avoid sampling based on cutoff concentrations.
• Part 11 Section B — New provisions requiring the permittee to execute Tier One and Tier Two response actions, based on
the first benchmark exceedence (Tier One) and the second consecutive benchmark exceedence (Tier Two). Tier Two
requires that the permittee institute monthly monitoring instead of twice -per -year monitoring, until three consecutive
monitoring events show no benchmark exceedences.
• Part 11 Section B — A new provision that four exceedences of any particular bench mark will trigger increased DWQ
involvement in the permittee's stormwater management and control actions. DWQ may direct the permittee to apply for
an individual permit, or may direct the implementation or installation of specific stormwater control measures.
Noi[hCarolina
,1vlTtl!!'fTr!f�
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699.1617 Phone [phone] Customer Service
lntemet: h2o.enr.slate.nc.uslsulslormwaler.htrnl 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer-50% Recycledl10% Post Consumer Paper

Permit Reissuance Letter — Permit NCG060126
Page 2
Your coverage under the General Permit is transferable gj2ly through the specific action of DWQ. The Division may require
modification and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by DDNR, 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 Sarah Young of the Central Office Stormwater Permitting
Unit ai [phone].
Sincerely,
for Coleen H. Sullins
cc: DWQ Central Files
Stormwater Permitting Unit Files
Fayetteville Regional Office
DEN R- Foo
JAN 3 203
®WQ

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. 060000
CERTIFICATE OF COVERAGE No. 060126
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,
Smithfield Packing Company, Inc.
is hereby authorized to discharge stormwater from a facility located at
Smithfield Packing (Tarheel Division)
15855 Highway 87 N
Tar Heel
Bladen County
_.. - to receiving waters designated as Goodman Swamp and the Cape Fear River, a class C SW WS-V stream,
in the Lumber River Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts 1, 11, III, IV, V, and VI of General Permit -No. NCG060000 as attached.
This certificate of coverage shall become effective December 17, 2008.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day December 17, 2008.
for Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Michael F. Easley. Governor
William G. Ross Jr., secretary
CC
ry North Carolina Department of Environment and Natural Resources
Q Coleen H. Sullins, Director
Division of Water Quality
September 10, 2008
Jeff Musselwhite, Environmental Coordinator
Smithfield Packing (Tar Heel Division)
PO Box 99
Tar Heel, NC 28392
Subject: COMPLIANCE EVALUATION INSPECTION
Smithfield Packing Company Inc
Smithfield Packing (Tar Heel Division)
NPDES Stormwater General Permit-NCG060126
Bladen County
Dcar Mr. Musselwhite:
On September 4, 2008, I, Michael Lawyer from the Fayetteville Regional Office of the Division
of Water Quality; conducted a site inspection at the Smithfield Packing (Tar Heel Division) facility
located at 15855 Highway 87 South in Tar Heel, Bladen County, North Carolina. A copy of the
Compliance Inspection Report is enclosed for your review. Your time and assistance during the
inspection is greatly appreciated. Stormwater from this facility drains to both Goodman Swamp, a Class
C;Sw stream, located in the Lumber River Basin and a portion of the Cape Fear River in the Cape Fear
River Basin. The site visit and file review revealed that the subject facility is covered by NPDES
Stormwater General Permit-NCG060126.
Accordingly; the following observations were noted during the Division of Water Quality
inspection:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
im lemented.
Yes ■ No ❑
2) Qualitative Monitorin1l
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
es® No❑
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
'es ■ No ❑
Other Observations:
Please refer to the enclosed Compliance Inspection Report for additional comments and observations
made during the inspection.
Nor`thCarolina
'Alalurall (
North Carolina Diciiion or Water Quality 225 Green Street, Suite 714 Favetteville. NC 28301-5043 Phone [phone] Customer Senice
lntemeE ww\t ,--wgterquality-are Fax [phone]
An Equal OpportunitylAffrmative Action Employer —50% Recycled110% Post Consumer Paper

Requested Response:
You are asked to please provide to this office a schematic of the facility's stornlwater drainage system to
include all drains, catch basins, pipes, ditches, etc, as well as the stornlwater containment structure. The
schematic should also show the flow path and terminal points of all outfalls.
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,
Co111111ents, or needs assistance with understanding any aspect of your permit, please do not hesitate to
contact me at [phone].
Sincerely,
Michael Lawyer
Environmental Specialist
Enclosure
cc: PRO -Surface Water Protection
Nl'S-Assistance & Compliance Oversight Unit

Permit: NCG060126
SOC:
County: Bladen
Region: Fayetteville
Compliance Inspection Report
Effective: 09/01/02 Expiration: 08/31/07 Owner: Smithfield Packing Company Inc
Effective: Expiration: Facility: Smithfield Packing (Tar Heel Division)
PO Box 99
Contact Person: Jeff Musseiwhite
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Jeff Musselwhite
Related Permits:
Title: Environmental Coordinator
Certification
Tar Heel NC 28392
Phone: [phone]
Phone:
Phone: [phone]
Inspection Date: 09/04/2008 Ent TirW. 10:00 4M Exit Time: 12:40 PM
Primary Inspector: Mike Lawyer Phone: [phone]
Exilz_w
``�� 33z9
Belinda S Henson -ldCl Phone: [phone] Exj326
Reason for Inspection: Routine Inspection Type: Compliance Evaluation 33?L
Permit Inspection Type: Food/Tobacco/Soaps/Cosmetics/Public Warehousing
Stormwater Discharge COC
Facility Status: EM Compliant D Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG060126 Owner - Facility: Smithfield Packing Company Inc
N.
Inspection Date: 09/04/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The previous NCG060000 general permit expired on August 31, 2007 and a revised general permit was issued on
November 1, 2007. The facility has submitted for renewal of permit coverage, but a renewed Certificate of Coverage has
not yet been issued by the Stormwater Permitting Unit, therefore at the time of inspection, compliance is based on the
requirements and conditions of the expired permit. Inspection conducted with Mr. Jeff Musselwhite, Environmental
Coordinator. Observations were made of the grounds of the facility including stormwater ditchesloutfalls and secondary
containment of above -ground storage tanks. Facility has a stormwater containment structure incoporated into their
drainage system that collects and holds the majority of stormwater runoff from process and vehicle traffic areas.
According to Mr. Musselwhite, this structure is designed to pump the "first flush" runoff for 30-45 minutes to the facility's
wastewater treatment system and then gates can be manually opened to allow any remaining uncontaminated stormwater
to be released to a ditch leading to stormwater outfall 002. A review of the facility's Slormwater Pollution Prevention Plan
(SPPP) was conducted, which was last updated earlier in 2008 and contained all permit -required components. Some
minor revisions/additions to the detailed site map was discussed. Records of Qualitative and Analytical Monitoring were
reviewed. Sampiing results from July 2008 at outfall 002 showed that all parameters were below cut-off concentrations
except for fecal coliform, which was 11,000 col/1 00 mL. This exceedance was contributed to the animal offloading area,
which is located near the ditch leading to outfall 002 that is beyond the stormwater containment structure. It was
expressed to Mr. Musselwhite that measures should be taken to try and address this issue.
Page: 2

I
Permit: NCG060126 Owner - Facility: Smithfield Packing Company Inc
Inspection Date: 09/04/2008 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
n
n
n
# Does the Plan include a General Location (USGS) map?
■
n
n
o
# Does the Plan include a "Narrative Description of Practices"?
■
n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
n
n
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
n
n
n
# Has the facility evaluated feasible alternatives to current practices?
■
n
n
n
# Does the facility provide all necessary secondary containment?
■
n
n
n
# Does the Plan include a l3MP summary?
■
n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
In
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
n
n
# Does the facility provide and document Employee Training?
■
n
n
n
# Does the Plan include a list of Responsible Party(s)?
■
n
n
n
# Is the Plan reviewed and updated annually?
■
F1
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
■
n
n
n
Comment:
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
n
n
n
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
■
n
n
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
n
■
o
Comment: Sampling results from July 2008 from outfall 002 show all parameters
below cut-off concentrations except for fecal coliform, which was 11,000 col/100mL.
Facility should evaluate for possible measures to address this issue.
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■
n
n
n
# Were all outfalls observed during the inspection?
■
n
n
❑
# If the facility has representative outfall status, is it properly documented by the Division?
In
n
■
n
# Has the facility evaluated all illicit (non stormwater) discharges?
■
n
n
n
Page: 3

Permit: NCGO60126 Owner - Facility: Smithfield Packing Company Inc
N
Inspection Date: 09/04/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Facility has two outfalls, 001 and 002, however 001 consists of a
stormwater pond that only receives runoff from a portion of the roof where no activities
occur and an employee parking area. Therefore, analytical monitoring is not required at
this outfall, but visual monitoring should continue.
Page: 4

<,
SMITHFIELD FOODS, - TARHEEL, NC
DESCRIPTION OF EXISTING WASTEWATER TREATMENT FACILITIES
(REVISIED MAY 2006)
I. INTRODUCTION
The treatment facilities at the Smithfield Foods — Tarheel Division packing plant were
constructed in 1992. Pretreatment consists of an inline chopper pump and dissolved
air flotation, while major wastewater treatment unit processes consist of. anaerobic
basins, anoxic basins, activated sludge including aeration basins and final clarifiers,
tertiary filtration, reaeration, UV disinfection, and effluent storage. In I996; water
reuse facilities, including flocculation, settling, filtration, and disinfection were
constructed.
H. PRETREATMENT FACILITIES
Wastewaters from the packing plant, utility building, and reefer truck wash combine
in a raw waste wet pit. Pen wastes and wastewater from a nearby cold storage
building are both pumped to the raw waste wet pit. The combined flow passes
through an in line chopper pump. The flow is then pumped by three 2050-gpm, self -
priming pumps to three 36-inch diameter by 84-inch long rotating screens with 0.03-
inch openings. After screening the wastewater flows by gravity to a 60-ft diameter by
12-ft side water depth dissolved air flotation system (DAF). This DAF unit is
equipped with a recycle pressurization system, four surface skimmers and two sludge
rakes. DAF skimmings and bottom solids are pumped separately to a holding tank.
This material is then dewatered on one 2 meter belt filter presses prior to being
conveyed to a load -out for disposal at an off -site composting facility.
After flotation, the wastewater enters an adjacent wet pit where it is pumped by three
2100-gpm, self -priming pumps to the waste treatment site.
III. WASTEWATER TREATMENT FACILITIES
Sanitary wastewater treatment facilities consist of flow equalization followed by a
packaged activated sludge system. Treated sanitary waste is combined with effluent from
the process waste treatment effluent reaeration basin. Aerobically digested waste
activated sludge is disposed by hauling to the Public Works Commission, Fayetteville,
NC.
The pretreated wastewater flow from the packing plant is pumped to the wastewater
treatment plant site and discharged into the anaerobic splitter structure for distribution to
the anaerobic basins. This splitter is designed for expansion to serve three basins. Two
anaerobic basins are provided for removal of BOD and suspended solids. The basins

IL
equalize the flow rate over a 7-day period to the remainder of the treatment units by
allowing the water surface to rise and fall during the week.
The basins are constructed of earthen berms with dimensions at the maximum water
surface of 409 feet by 274 feet, 3:1 exterior sideslopes, 2.5:1 interior slideslopes, a
maximum depth of 25.5 feet, and 2 feet of freeboard at the maximum water level. The
basins are lined with 60-mil high -density polyethylene (HDPE) and are provided with
floating covers of 100-mil HDPE. Baffle curtains hang from the covers to reduce short-
circuiting. Biogas (methane), which is produced during the anaerobic treatment process,
is collected under the floating covers and removed by one of two blowers that discharge
the biogas to the packing plant for use in a boiler to produce steam. The biogas blowers
are housed in a building and are each capable of handling 650 scfm of gas. Provisions are
available to flare biogas not utilized by the boiler system
Following the anaerobic basin system, the equalized flow enters the' anoxic splitter
structure which serves three concrete -lined anoxic basins with provisions to serve a
fourth basin in the future. Each of the anoxic basins has dimensions at the water surface
of 87.5 feet, 2:1 interior sideslopes, a water depth of 16.6 feet, and contains a volume of
411,200 gallons. The basins are concrete lined and each is equipped with a 25-hp floating
mixers. Currently, two of the three anoxic basins are in service.
These basins are kept in an anoxic state to promote denitrification, which allows oxygen
to be recovered from the nitrates present in return flow from the downstream activated
sludge system. Alkalinity is released by this denitrification process and reutilized in the
activated sludge basins. The anoxic system was included in the design as an economy
measure for alkalinity and oxygen recovery and is not required to achieve the desired
treatment of design loadings. The subsequent activated sludge system is sufficient to treat
the design waste loads without the anoxic system.
Effluent from the anoxic basins is combined in the aeration splitter structure and
distributed to three aeration basins. The splitter structure is designed for expansion to
serve four aeration basins.
The three aeration basins are part of the activated sludge system and supply the oxygen
and mixing for BOD and ammonia nitrogen reduction. Each of the three concrete -paved
aeration basins has dimensions at the water surface of 150 feet by 105 feet, 2.1 interior
sideslopes, water depth of 15 feet, and contains a volume of 1,043,450 gallons. The total
volume under aeration is 3,130,350 gallons.
Oxygen is supplied to the basins by a subsurface diffuser system consisting of
approximately 1,360 perforated -membrane tubular diffusers per basins. Four centrifugal
blowers provide air for the diffuser system. Three of the blowers were provided as part of
the original plant construction and have been upgraded to a rating of 6900 scfm at 7.7
psig. The south blower, with a rating of 6900 scfm at 7.7 psig, was subsequently added.

4
Aeration basin effluent combines and flows by gravity to the clarifier splitter structure
serving the four final clarifiers. Mixed liquor can be pumped by two 2100-gpm from the
inlet side of this splitter box back to the anoxic splitter structure. Currently, mixed liquor
is not being returned to the anoxic splitter structure.
Three of the clarifiers have inside dimensions of 50-foot diameter by 12-foot side water
depth. The surface area of each of these units is 1,964 square feet. The clarifiers are
equipped with hydraulic sludge removal tubes. Recently, a fourth clarifier, with a plow
type of mechanism, has been placed into service. This clarifier has a diameter of 65 feet
with a 14-foot side water depth. The surface area of this unit is 3,320 square feet.
Sludge pumping facilities consist of three recycle activated sludge (RAS) pumps and two
waste activated sludge (WAS) pumps. The RAS pumps are each designed to pump 1,050
gpm of settled clarifier sludge and return the flow to either the aeration basin splitter
structure or, as is currently done, to the anoxic basin splitter structure. The two WAS
pumps are each designed for 150 gpm and waste the sludge to the DAF system at the
packing plant pretreatment facilities. One pump is considered as a standby unit. WAS is
thickened and removed with the DAF skimmings for subsequent dewatering and disposal
as described previously.
Clarifier effluent is combined and flows by gravity to a wet well/diversion structure.
From this structure, the wastewater can be directed to the filtration splitter structure for
the tertiary filter system, be pumped to the holding pond, or be pumped to the water reuse
system.
The tertiary filter system consist of four (4) 6'x 6' fuzz filters. Two of the filters are for
wastewater use and 2 filters are for the water reuse system. Each filter is rated at 1,080
gpm. Backwash flow is directed by gravity to a backwash pit and pumped back to the
aeration splitter structure.
Filter effluent flows to a reaeration chamber to allow the oxygen level of the plant
effluent to be increased to meet the discharge permit levels. The basin has dimensions of
25 feet long by 15 feet wide and a water depth of 10 feet containing a volume of 28,050
gallons. This basin was designed for a flow rate of 4.0 mgd with a corresponding
detention time of 10.1 minutes. The oxygen necessary to raise the D.O. level is provided
by a coarse -bubble diffuser system supplied with air from the aeration blowers at a design
rate of 490 scfin.
Reaerated effluent flows by gravity to two parallel ultraviolet (UV) disinfection systems
to reduce the fecal coliform count. One of the UV systems consists of a concrete channel
with dimensions of 29 feet long by 2.5 feet wide with a water depth of two feet. Three
UV banks in the channel hold a total of 240 low -intensity tubes. Effluent from the
channel flows to the Final Effluent Wet Well where it is chlorinated and pumped for
reuse in evaporative condensers at the packing plant.

From the Final Effluent Wet Well, the plant effluent can either be discharged to the Cape
Fear River by using the final effluent pumps or diverted to the holding pond if the
effluent is not of sufficient quality for discharge. This is accomplished by adjusting the
discharge valves on the final effluent pumps. Final effluent is pumped by three 1,050-
gpm, self -priming pumps. Effluent is sampled and metered prior to discharge to the river.
The holding pond is constructed of earthen dikes with 3:1 exterior sideslopes, 2.5:1
interior sideslopes and is lined with 60-mil HDPE. The pond has a surface area of 23.2
acres, a maximum storage depth of 12 feet and contains a volume of 90,000,000 gallons
with two feet of freeboard. Holding pond contents can be discharged to the filtration
system, the final clarifier splitter, or reintroduced into the activated sludge system for
further treatment and discharge.
IV. WATER REUSE FACILITIES
As discussed previously, effluent from the wastewater treatment final clarifiers flows to a
wet well/diversion structure. This structure allows up to 1,450 gpm (2.0mgd) to be
diverted to the water reuse treatment system by two self -priming pumps. One pump is
equipped with a variable -speed drive; the other pump operates at a constant speed. This
wet pit/diversion structure also allows all or a portion of the final clarifier effluent to be
pumped to the holding pond.
Prior to reuse filtration, the flow is split and chemically treated by the addition of a
coagulant and a flocculant in two flocculation tanks. Flocculated effluent flows by
gravity to two incline -plate settling basins for sedimentation of the flocculated solids
prior to the filters, Clarified flow then enters two of the fuzz filters, which have a flow
rate of 1,080 gpm each.
Filtered effluent flows by gravity to a contact basin to allow the reuse flow to be
disinfected prior to use in the plant. If the contact tank must be bypassed due to
equipment problems or if reuse water is not needed in the plant, filtered effluent can be
bypassed into the reaeration basin. The serpentine -baffled contact tank has dimensions of
30 feet by 24.7 feet wide by 9 feet deep and has a volume of 38,150 gallons.
Disinfected effluent is pumped to a storage tank at the packing plant, or to the holding
pond by two variable -speed pumps; each with a capacity of 300 gpm to 1,450 gpm.
Related facilities for the water reuse system are the alum tank and feed pump, the
polymer feed system and the Sodium Hypochlorite Feed System and storage facilities.

®ENR-FRO
APR 15 2008
®WO
NCDENR Fayetteville Regional Office
Systel Building,
225 Green St., Suite 714
Fayetteville, NC 28301-5094
Attn.: Ms. Belinda Henson
Dear Ms. Henson:
Please find attached a copy of the spill report for the spill of hydraulic fluid that occurred
at the Smithfield Packing Tar Heel Plant on April b, 2008. As we discussed on the phone
Monday April 7, we collected all of the spilled material that we could using our vacuum
pumper truck, absorbent, and then removed the top layer of soil in the area where the spill
occurred.
The material at no time entered surface waters of the state.
Please advise if you require any further information..
Sincerely,
Jeff Musselwhite
Environmental Coordinator
Smithfield Packing, Tar Heel Plant
Cc: Keith Bailey, Ken Wilson
The Smithfield Packing Company, Inc. P.O. Box 99 Tar Heel, NC 28392
Tar Heel Division Phone [phone] Fax [phone]

SMITHFIELD PACKING CO., TAR HEEL DIVISION
SPILL NOTIFICATION REPORT
Date/Time of Spill: April 6, 2008 Approx. 1500 Hrs.
Date of Report: April 8, 2008
Person Filing Report: Jeff Musselwhite
Title: Env. Coordinator
Phone Number:910 - 862 - 2458
Location of Spill: Hyd. Fluid Transfer station
Facility: Tar Heel Division
between Kill Shoo and Livestock
Water Body Affected: None
Quantity: Approximately 100
Material Spilled/Released: Used Hydraulic Fluid
Gallons
Point of Contact at Spill Site: Michele Christensen
Source of Spill: Tote containing used hydraulic fluid
How Did Spill Occur ?: Fork Lift was attempting to transfer tote to used oil container and tote overturned.
Clean Up/Corrective Action Taken: The tote was staged on top of a plastic containment located within a
concrete containment therefore the majority of spilled material was contained. The pumper truck was used
to pump up all of the material that was possible and then absorbant mats and granules were used to clean
up the rest. The top layer of soil was removed and stored under shelter for further treament at a later date.
The site was backfilled with crush and run.
NOTIFICATION
DATE/TIME NOTIFIED: 4/6/2008 1619 Hrs.
NAME: Bill Gill
Title: V.P. Environmental - Smithfield Foods BY WHOM: EMS SYSTEM
DATE/TIME NOTIFIED:4/6/2008 1619 Hrs.
NAME; Ken Wilson
Title: plant Manger BY WHOWEMS SYSTEM
NAME: Belinda Henson BY WHOM.Jeff Musselwhite
Title: DENR Regional Su ervisor WQ DATEITiME NOTIFIED: 4/07/2008 Approximately 0830 hrs
NAME: BY WHOM: Jeff Musselwhite
DATE/TIME NOTIFIED:
NAME: BY WHOM:

01/05/2008 13:33
9197339612
WET AND SH2O BRANCH
PAGE 61/63
WArF,Q
QG
7
r,
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
WETLANDS AND STORMWATER BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
FAX: [phone]
PHONE: [phone]
TELECOPY TO: - �SULI KP,
FAX NUMBER: 9 I o - `f 0-0�
FROM: Upvv v4l'A .. ,
PHONE e1_Q_, # OF PAGES INCLUDING THIS SHEET:
COMMENTS:

01/05/2008 13:33 9197339612 WET AND SH2O BRANCH PAGE 02/03
Michael r. taslew Lsovemor
O*0� "IF
�pG Winlam G. Ross Jr., Sacratary
North Caro4na Department of Environment and Natural Resources
r Alan W. Klimek, P.E., Director
v �-1 pivlsfon of Water Quality
August 23, 2002
JEFF MUSSELWHITE
SMITHFIELD PACKING CO - TAR HEEL
PO BOX 99
TAR HEEL, NC 28392
Subject: NPDES Stormwater Permit Renewal
Smithfield Packing Co - Tar Heel
COC Number NCM60126
Bladen County
Dear Pertmittee:
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 yov 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
Fayettevillt Regional Office
N. C. Dlvislon of Water Quallty 1617 Mail Service Center Raleigh, NC 27699.1617 [phone]
MMMA
ON
'NCR
Customer Service
1- 800-623-7748

01/05/2008 13:33 9197339612 WET AND SH2O BRANCH
i
PAGE 03/03
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DW ISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCGO60126
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
1n 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,
SMnMFM,LD PACKING CO
is hereby authorised to discharge stormwater from a facility located at
SMrIIH IELD PACKING CO - TAR HEEL
15855 HIGHWAY 87 N
TAR HEEL
BLADEN COUNTY
to receiving waters designated as Goodman Swamp and the Cape Fear River, a class C SW WS-V stream, in the
Lumber River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set
forth in Parts I,11, 111, IV, V, and VI of General Permit No. NCG060004 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

JEFF MUSSELWHITE
SMITHFIELD PACKING CO - TAR HEEL
PO BOX 99
TAR HEEL, NC 28392
Dear Permittee:
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
Pir.-F\r!�
August 23, 2002 #�
i�G 2 9 2002
Subject: NPDES Stormwater Permit Renewal
Smithfield Packing Co - Tar Heel
COC Number NCG060126
Bladen County
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
cc: Central Files
Stormwater & General Permits Unit Files
Fayetteville Regional Office
Sincerely,
4
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
eMA
NCDENR
Customer Service
1-800-623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060126
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,
SMITHFIELD PACKING CO
is hereby authorized to discharge storm water from a facility located at
SMITHMLD PACKING CO - TAR HEEL
15855 HIGHWAY 87 N
TAR HEEL
BLADEN COUNTY
to receiving waters designated as Goodman Swamp and the Cape Fear River, a class C SW WS-V stream, in the
Lumber River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set
forth in Parts 1, II, 1I1, IV, V, and VI of General Permit No. NCGO60000 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

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
DCccnther 27, 2001
WILLIAM D GILL.
SMI'CHFI LD I"OODS INC-CARC)LINA
PO BOX 447
SMITI-IFII-LD, VA 23430
Subject: NPDES Storniwatcr Permit Renewal
SI•' ITI-IFIELD FOODS INC-CAROI.,INA
Cf.)C NLHnhel' NCC;060126
Bl,Iden County
Derr Permittee:
Ylttlr' facility IS Currently covered fur stornlWuter dischar".c undCI- General Permit NCGU6f)f)00, 'Phis perrllit expires
on August 31. 2002. The Division staff is Currently in the prnccss of rcwrilin�� Illis permit anal is SChc(lulcd to have
the: permit rcis.tuc(l by late summer of 2002. Once Ilrc permit is reissued. your facility would he eligible for
CrnitinuC(I Covcra,(,'c under the reissued permit.
In or(ler 10 assure your continued coverage uncicr the "Cncral pernlit, you must rhhly to the Nvision of Water
Qu.11ity (DWQ) for IrenCW.d of your permit C0VC1':h'c. TO make this renewal process easier. we arc inl'ormin�, you in
adyarlCC that yow- permit will be Cxpirin�,. I nCl0SCd you Will find a General Permit Coverage Renewal
Application Furor. "rile application must he cerrnplcicel :Ind rcturncd by March 4. 2002 in order to ISStrr'C C(lntinucd
Coycr.r"c uncicr the "elleral permit.
Failure to rcqucst rerlCWal within this time period mery result in a cavil :Issessment ol'al leas[ $250.00. Larger
penalties may be assessed dcpcnding on the (IClin(yucncy of llic re(Itlest. l)ischaroe of slornlwatcr from yrrur facility
Without coveratIC uncicr a valid stormwater NPDhL'S penult Would constiurte a violation of NCGS 143-215.1 and
Could result in aSSeSSmCn[S of Civil hCnalticS of up to $10.000 per clay.
Please note that recent ledcral legislalion has extended the "no CxposurC exclusion" to all operators of' industrial
facilities in any of the I I Catc"ories of "storm wiUcr diSCharics assuci,rted With industrial activity," (except
C0111MRICtI011 aCtivi(ics), I1 you ICCI your facility can Certify a condition of "no exposure", I.C. the facilty industrial
rllatcrials and operations are not Cxposccl to storm Water, you Can apply for [lie no exposure CXClusiorl. I-nr additional
inforrrlation contact the Central Office Storrnwater Staff rnenrhcr listed below or Check the Stormwatcr & General
Permits Unit Weil Site at htlpalh2o.Cnr.sta[e.ne.us/su/stormwalcr.hlnal
II' the Suhjcct slormwatcr discharge to Waters of the state has been [crnlinawd, please complete file enclosed
Rescission Request Furan. Mailing instructions arc listed on the houont (41he Corin, You will he aotilied when the
rescission process has hCL'rl Completed.
11 you hayC any quCS6011, regarding the permit renewal procedurCs please contact Ricky Revels of the Fayetteville
Regional Oflicu al d 10-486-1541 or Aisha Lau ol' the Central ()fficc Swrrnwater Unit at [phone], ext. 578
Sincerely.
Bradley Bennett. Supervisor
Slormwalcr anal General PerrllilS Uni[
cc: Central Files
Faveltevillc RC,ion'Il Ofl'icc
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 Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary C) E H IV R
A. Preston Howard, Jr., P.E., Director ;�'`-;}YA(j`��F,�T;i'"��1 y� 1
l 1
July 29, 1994
4UG 9 1994
Mr. Lawrence D. Livel ENV, MANAGEMENT
PO Box 447
y RA-YETTEVILLiE REG- OFFICF
Smithfield, NC 23430
Subject: General Permit No. NCG060000
Smithfield Foods, Inc.
COC N00060126
Bladen County
Dear Mr. Lively:
In accordance with your application for discharge permit received on April 29, 1994, 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 .l 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 Aisha Lau at telephone number 919/733-5083.
Sincerely, t)1116 � Hgs ig�
CgLeB
A. Preston Howard, Jr., P. E.
cc: '-Fayetteville Regional -Office- -
P.O. Box 29535, Raleigh, North Carolina 27626.0535 Telephone [phone] FAX [phone]
An Equal Opporton}ty Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
GENERAL PERMIT NO, NCG060000
ERTIFI ATE OF COVERAGE No. N 126
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute I43-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Smithfield Foods, Inc.
is hereby authorized to discharge stormwater from a facility located at
Carolina Food Processors, Inc.
Rt. 1, Box 189
Tar Heel
Bladen County
to receiving waters designated as Goodman Swamp in the Cumber River Basin, and the Cape Fear River 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 Pennit No. NCG060000 as attached.
This certificate of coverage shall become effective July 29, 1994.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day July 29, 1994.
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

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Stag 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
A 74
UEHNF1
September 11, 1997
WILLIAM D. GILL
SMITHFIELD FOODS, INC-CAROLINA
PO BOX 447
SMITHFIELD, VA 23430
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCGO60126
Bladen 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 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency
dated December 6, 1983.
The following information is included with your permit package:
■ 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 forth 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 Fquat Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Permit No. NCG060000
TABLE OF CONTENTS
PART I
INTRODUCTION
Section A:
General Permit Coverage
Section B:
Permitted Activities
Section C:
Permit Renewal
PART II
MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A:
Stormwater Pollution Prevention Plan
Section B:
Analytical Monitoring Requirements
Section C:
Qualitative Monitoring Requirements
Section D:
On -Site Vehicle Maintenance Monitoring Requirements
PART III
STANDARD CONDITIONS
Section A:
Compliance and Liability
I . Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
5. Oil and Hazardous Substance Liability
6. Property Rights
7. Severabillty
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
Section B:
General Conditions
1. Continuation of the Expired General Permit
2. Transfers
3. ' When an Individual Permit May be Required
4. When an Individual Permit May be Requested
5. Signatory Requirements
i

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND
NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission and the Federal Water Pollution Control Act, as amended, this permit is
hereby issued to all owners or operators, hereafter permittees, which are covered by this permit as
evidenced by receipt of a Certificate of Coverage by the Environmental Management Commission
to allow the discharge of stormwater to the surface waters of North Carolina or separate storm
sewer systems conveying stormwater to surface waters in accordance with the terms and
conditions set forth herein.
Coverage under this general permit is applicable to all owners or operators of stormwater point
source discharges associated with activities classified as establishments primarily engaged in
activities classified as Food and Kindred Products [standard industrial classification (SIC) 20),
Tobacco Products (SIC 21), Soaps, Detergents and Cleaning Preparations; Perfumes, Cosmetics
and Other Toilet Preparations (SIC 284), Drugs (SIC 283), and Public Warehousing and Storage
(SIC 4221-4225).
The General Permit shall become effective on September 1, 1997.
The General Permit shall expire at midnight on August 31, 2002.
Signed this day August 22, 1997.
A. Preston Howard, Jr., P.E., Direct r
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No. NCG060000
6. General Permit Modification, Revocation and Reissuance, or
Termination
7. Certificate of Coverage Actions
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
I.
Representative Sampling
2.
Recording Results
3.
Flow Measurements
4.
Test Procedures
5.
Non-Stormwater Discharges
6.
Representative Outfall
7.
Records Retention
8.
Inspection and Entry
Section E: Reporting Requirements
l .
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
5.
Planned Changes
6.
Anticipated Noncompliance
7.
Bypass
8.
Twenty-four Hour Reporting
9.
Other Noncompliance
10.
Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
ii

Permit No. NCG060000
PART I INTRODUCTION
SECTION A: GENERAL PERMIT COVERAGE
All persons desiring to be covered by this General Permit must register with the Division of Water
Quality by the filing of a Notice of Intent (NOI) and applicable fees. The N01 shall be submitted
and a certificate of coverage issued prior to any discharge of stormwater associated with industrial
activity that has a point source discharge to the surface waters of the state.
Any owner or operator not wishing to be covered or limited by this General Permit may make
application for an individual NPDES permit in accordance with NPDES procedures in 15A NCAC
2H .0100, stating the reasons supporting the request. Any application for an individual permit
should be made at least 180 days prior to commencement of discharge.
This General Permit does not cover activities or discharges covered by an individual NPDES
permit until the individual permit has expired or has been revoked. Any person conducting an
activity covered by an individual permit but which could be covered by this General Permit may
request that the individual permit be revoked and coverage under this General Permit be provided.
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this permit.
SECTION B: PERMITTED ACTIVITIES
Until this permit expires or is modified or revoked, the pertnittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system which has been
adequately treated and managed in accordance with the terms and conditions of this General
Permit. All discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization or approval.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
SECTION C: PERMIT RENEWAL
Dischargers covered by general permits need not submit new Notices of Intent or renewal requests
unless so directed by the Division. If the Division chooses not to renew a general permit, all
facilities covered under that general permit shall be notified to submit applications for individual
permits.
Part 1 Page 1 of 1

Permit No. NCG060000
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The Permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as the
Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this general permit. The Plan shall include, at a minimum,
the following items:
1, Site Plan. The site plan shall provide a description of the physical facility and the potential
pollutant sources which may be expected to contribute to contamination of stormwater
discharges. The site plan shall contain the following;
(a) A general location map (USGS quadrangle map or appropriately drafted equivalent
map), showing the facility's location in relation to transportation routes and surface
waters, the name of the receiving water(s) to which the stormwater outfall(s)
discharges, or if the discharge is to a municipal separate storm sewer system, the
name of the municipality and the ultimate receiving waters; and accurate latitude
and longitude of the point(s) of discharge.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices.
(c) A site map drawn to scale with the distance legend indicating location of industrial
activities (including storage of materials, disposal areas, process areas and loading
and unloading areas), drainage structures, drainage areas for each outfall and
activities occurring in the drainage area, building locations, existing BMPs and
impervious surfaces, and the percentage of each drainage aura that is impervious.
For each outfall, a narrative description of the potential pollutants which could be
expected to be present in the stormwater discharge.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the 3 previous years and any corrective actions taken to mitigate spill
impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part II1, Standard Conditions, Section
B, Paragraph S.
2. Stormwater Management Plan. The stormwater management plan shall contain a narrative
description of the materials management practices employed which control or minimize the
exposure of significant materials to stormwater, including structural and nonstructural
measures. The stormwater management plan, at a minimum, shall incorporate the
following -
(a) Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
of materials and processes to stormwater. Wherever pructical, the permittee shall
Part Il Page 1 of 6

Permit No. NCG060000
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is not
practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Schedule. A schedule to provide secondary containment
for bulk storage of liquid materials, storage of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority chemicals,
or storage of hazardous substances to prevent leaks and spills from contaminating
stormwater runoff. if the secondary containment devices are connected directly to
stormwater conveyance systems, the connection shall be controlled by manually
activated valves or other similar devices [which shall be secured with a locking
mechanism] and any stormwater that accumulates in the containment area shall be at
a minimum visually observed for color, foam, outfall staining, visible sheens and
dry weather flow, prior to release of the accumulated stormwater. Accumulated
stormwater shall be released if found to be uncontaminated by the material stored
within the containment area. Records documenting the individual making the
observation, the description of the accumulated stormwater and the date and time of
the release shall be kept for a period of five years.
(c) BMP Summary. A narrative description shall be provided of Best Management
Practices (BMPs) to be considered such as, but not limited to, oil and grease
separation, debris control, vegetative filter strips, infiltration and stormwater
detention or retention, where necessary. The need for structural BMPs shall be
based on the assessment of potential of sources to contribute significant quantities
of pollutants to stormwater discharges and data collected through monitoring of
stormwater discharges.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or team) responsible for implementing the
SPRP shall be identified. A responsible person shall be on -site at all times during facility
operations that have the. potential to contaminate stormwater runoff through spills or
exposure of materials associated with the facility operations. The SPRP must be site
stormwater specific. Therefore, a SPCC plan may be a component of the SPRP, but may
not be sufficient to completely address the stormwater aspects of the SPRP. The common
elements of the SPCC with the SPRP may be incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative maintenance
program shall be developed. The program shall document schedules of inspections and
maintenance activities of stormwater control systems, plant equipment and systems.
Inspection of material handling areas and regular cleaning schedules of these areas shall be
incorporated into the program.
5. Employee Training. Training schedules shall be developed and training provided at a
minimum on an annual basis on proper spill response and cleanup procedures and
preventative maintenance activities for all personnel involved in any of the facility's
operations that have the potential to contaminate stormwater runoff. Facility personnel (or
team) responsible for implementing the training shall be identified.
b. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
Part II Page 2 of 6

Permit No. NCG060000
7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the
potential for the discharge of pollutants to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis.
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with Part
I1I, Standard Conditions, Section B, Paragraph 5) to the Director that the changes have
been made.
Facility Inspection Program. Facilities are required to inspect all stormwater systems on at
least a semiannual schedule, once in the fall (September -November) and once during the
spring (April - June). The inspection and any subsequent maintenance activities performed
shall be documented, recording date and time of inspection, individual(s) making the
inspection and a narrative description of the facility's stormwater control systems, plant
equipment and systems. Records of these inspections shall be incorporated into the
Stor nwater Pollution Prevention Plan.
Stormwater discharge characteristic monitoring as required in Part II of this permit shall be
performed in addition to facility inspections.
9. Implementation. The perraittee shall document all monitoring, measurements, inspections
and maintenance activities and training provided to employees, including the log of the
sampling data and of activities taken to implement BMPs associated with the industrial
activities, including vehicle maintenance activities. Such documentation shall be kept on -
site for a period of five years and made available to the Director or his authorized
representative immediately upon request.
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
During the.period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge stormwater subject to the provisions of this permit. Analytical monitoring of
Stormwater discharges shall be performed as specified below in Table 1.
For each parameter, the arithmetic mean of all analytical sampling results collected during the term of the
permit shall be calculated for each individual outfall. The computed arithmetic mean is then compared to
the cut-off concentrations listed below in Table 2. If the arithmetic mean is less than the specified dut-off
concentration for a given parameter, then the facility is not required to continue annual analytical
monitoring for that parameter (at that outfall) during the remaining term of the permit unless a significant
change in facility operations or configuration occurs. If a cut-off concentration results in discontinued
analytical monitoring at an individual discharge outfall, the permittee is required to maintain facility
operations that ensure the continuation of stormwater runoff quality.
r ar of gut -off ongen=iQg cogditions,Analytical results from sampling during the final year of
the permit coverage must be submitted with the permit renewal application. All analytical monitoring shall
be performed during a representative storm event.
Part II Page 3 of 6

Permit No. NCG060000
Table 1. Analvtical Monitoring Requirements
T` c n r � C �gE �tt�z
�Cli rac er stzcs
rskA'S �" f .
nits �
�"i`.zi-`s- Il i I�i� II , '
y 'are iienc ::
�Y' . P" T�'
e'
^*yr '•k-�v „5
"guQutian
Total Suspended Solids
m
annually
Grab
SDO
Oil and Grease
MgA
annually
Grab
SDO
Fecal Coliform4
per 100 ml.
annually
Grab
SDO
H
S.U.
annually
Grab
SDO
Chemical Oxygen Demand
IngA
annually
Grab
SDO
Total Rainfalls
inches
annually-
-
Event Durations
minutes
annually-
-
Total Flows
MG
annually
-
SDO
Footnotes: --
I Measurement Frequency: Once per year during a representative storm event. A year is defined as the 12 month period
beginning on the month and day of issuance of the Certificate of Coverage.
2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the pond shall
be collected within the first 30 minutes of discharge. If the detention pond discharges only in response to a storm event
exceeding a ten year design storm, then no analytical monitoring is required and only qualitative monitoring shall be
Perforated.
3 Sample Location. Samples shall be collected at each stormwater discharge outfall (SDO) unless representative outfall
status has been granted.
4 Fecal Coliform sampling applicable only to facilities processing meats.
5 For each sampled representative storm event the total precipitation, storm duration, and total flow must be monitored.
Total flow shall be either; (a) measured continuously, (b) calculated based on the amount of area draining to the outfall, the
amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the measurement of flow at
20 minute intervals during the rainfall event.
Table 2, Cut-off Concentrations for Anal tics! Monitoring Requirements
�i�SCtl$Il f:. a.r4cM�Wp3.._. ��}} pp.r����++.
Total Sus ended Solids
100 m
Oil and Grease
30 m
Fecal Coliform
1,000 per 100 ml
H1
within range 6.0 - 9.0 s.u,
Chemical Oxygen Demand
120 m
Footnotes-
1 pH cannot be averaged due to the nature of the logarithmic pH scale. The most recent -pH sample result shall be used for
cut-off concentration purposes.
Part Il Page 4 of 6

Permit No. NCG060000
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of representative
outfall status and shall be performed as specified below in Table 3. Qualitative monitoring is for the
purpose of evaluating the effectiveness of the Stormwater Pollution Prevention Plan (SPPP) and assessing
new sources of stormwater pollution. No analytical tests are required. Qualitative monitoring of
stormwater outfalls does not need to be performed during a representative storm event.
De first e monitorinagyenj dudog he cgvergagf ft& pennit muggo' id e ' ' 'a
anWytigW monitQn g event (regardless of the season). All other qualitative monitoring will be performed
twice per year, once in the spring (April - June) and once in the fall (September - November).
Table 3. Qualitative Monitoring Requirements
G arge�hairacterltt�t
�>�B��'r�sr �z�'''
requetr
�P �r� x�"�mO�JII,
W11��nt©ir�n
Color
Semi -Annual
SDO
Odor
Semi -Annual
SDO
Clarit
Semi -Annual
SDO
Floating Solids
Semi -Annual
SDO
Suspended Solids
Semi -Annual
SDO
Foam
Semi -Annual
SDO
Oil Sheen
Semi -Annual
SDO
t er obvious indicators
of stormwaterpollution
,Semi -Annual
SDO
Fogtnotes:
l Monitoring Location: Qualitative monitoring shall be performed at each
stormwater discharge outfall (SDO) regardless of representative outfall status.
SECTION D: ON -SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on -site which uses more than 55 gallons
of new motor oil per month when averaged over the calendar year shall perform analytical monitoring as
specified below in Table 4. This monitoring shall be performed at all outfalls which discharge stormwater
runoff from the vehicle maintenance areas.
For each parameter, the arithmetic mean of all analytical sampling results collected during the coverage of
the permit shall be calculated for each individual outfall. The computed arithmetic mean is then compared
to the cut-off concentrations listed below in Table 5. If the arithmetic mean is less than the specified cut-
off concentration for a given parameter, then the facility is not required to continue annual analytical
monitoring for that parameter (at that outfall) during the remaining coverage of the permit unless a
significant change in facility operations or configuration occurs. If a cut-off concentration results in
discontinued analytical monitoring at an individual discharge outfall, the permittee is required to maintain
facility operations that ensure the continuation of stormwater runoff quality.
Part II Page 5 of 6

Permit No. NCG060000
during the final year of
analytical monitoring shall
be performed during a representative storm event.
Table 4. Analytical Monitoring Requirements for On -Site. Vehicle Maintenance
piscitar��� it�r2l�terustt
�f� rr m "��, �
� e�ts�x+lrme tad
7v�� q�r a �:
�$' limp ��
H
standard
annually
Grab
SDO
Oil and Grease
Me
annually
Grab
SDO
Total Suspended Solids
m
annually
Grab
SDO
New Motor Oil Usage
allons/month
annuaUx
Estimate
SDO
Total Flow3
MG
annually
Grab
SDO
Eutautcs
l if the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the pond shall
be collected within the first 30 minutes of discharge. If the detention pond discharges only in response to a storm event
exceeding a ten year design storm, then no analytical monitoring is required and only qualitative monitoring shall be
performed.
z Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) that discharges
stortwater runoff from area(s) where vehicle maintenance activities occur.
3 Total flow shall be; (a) measured continuously, (b) calculated based on the amount of area draining to the
outfall, the amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the
measurement of flow at 20 minute intervals during the rainfall event. Total precipitation and duration of the
rainfall event measured shall result from the sampled representative storm event.
Table 5. Cut-off Concentrations for On -Site Vehicle Maintenance Activities
ti QL` Nl'%N,Y;.wl�''
H 1
within range 6.0 - 9.0
Oil and Grease
30 m
Total Sus nded Solids
I00 m
Footnotes:
1 pH cannot be averaged due to the nature of the logarithmic pH scale. The most recent pH sample result shall be used
for cut-off concentration purposes.
Part II Page 6 of 6

Permit No. NCG060000
PART III STANDARD CONDITIONS FOR NPDES STORMWATER GENERAL
PERMITS
SECTION A: COMPLIANCE AND LIABILITY
n
The permittee shall comply with'Limitations and Controls specified for stormwater
discharges in accordance with the following schedule:
Existing Facilities: The Stormwater Pollution Prevention Plan shall be developed and
implemented within 12 months of the effective date of the initial certificate of coverage
issued pursuant to this general permit and updated thereafter on an annual basis.
Secondary containment, as specified in Part II, Section A, Paragraph 2(b) of this permit,
shall be accomplished within 12 months of the effective date of the initial certificate of
coverage.
Proposed Facilities. The Stormwater Pollution Prevention Plan shall be developed and
implemented prior to the beginning of discharges from the operation of the industrial
activity and be updated thereafter on an annual basis. Secondary containment, as specified
in Part 11, Section A, Paragraph 2(b) of this permit shall be accomplished prior to the
beginning of discharges from the operation of the industrial activity.
The permittee must comply with all conditions of this general permit. Any permit
noncompliance constitutes a violation of the Clean Water Act and is grounds for
enforcement action; for certificate of coverage termination, revocation and reissuance, or
modification; or denial of a certificate of coverage upon renewal application.
a. The permittee shall comply with standards or prohibitions established under section
307(a) of the Clean Water Act for toxic pollutants within the time provided in the
regulations that establish these standards or prohibitions, even if the permit has not
yet been modified to incorporate the requirement.
b . The Clean Water Act provides that any person who violates a permit condition is
subject to a civil penalty not to exceed $25,000 per day for each violation. Any
person who negligently violates any permit condition is subject to criminal penalties
of $2,500 to $25,000 per day of violation, or imprisonment for not more than 1
year, or both. Any person who knowingly violates permit conditions is subject to
criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for
not more than 3 years, or both. Also, any person who violates a permit condition
may be assessed an administrative penalty not to exceed $10,000 per violation with
the maximum amount not to exceed $125,000. [Ref; Section 309 of the Federal Act
33 USC 1319 and 40 CFR 122.41(a).]
c . Under state law, a daily civil penalty of not more than ten thousand dollars
($10,000) per violation may be assessed against any person who violates or fails to
act in accordance with the terms, conditions, or requirements of a permit. [Ref:
North Carolina General Statutes 143-215.6A]
Part III Page 1 of 9 Pages

Permit No. NCG060000
d. Any person may be assessed an administrative penalty by the Director for violating
section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or
limitation implementing any of such sections in a permit issued under section 402 of
the Act. Administrative penalties for Class I violations are not to exceed $10,000
per violation, with the maximum amount of any Class I penalty assessed not to
exceed $25,000. Penalties for Class 11 violations are not to exceed $10,000 per day
for each day during which the violation continues, with the maximum amount of
any Class II penalty not to exceed $125,000.
The permittee shall take all reasonable steps to minimize or prevent any discharge in
violation of this general permit which has a reasonable likelihood of adversely affecting
human health or the environment.
4. Civil and Criminal Liability
Except as provided in Section C of this permit regarding bypassing of stormwater control
facilities, nothing in this general permit shall be construed to relieve the permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3,
143-215.6A, 143-215.6B, 143-215.6C or Section 309 of the Federal Act, 33 USC 1319.
Furthermore, the permittee is responsible for consequential damages, such as fish kills,
even though the responsibility for effective compliance may be temporarily suspended.
.4+...._. �� + _M, In,
Nothing in this general permit shall be construed to preclude the institution of any legal
action or relieve the permittee from any responsibilities, liabilities, or penalties to which the
permittee is or may be subject to under NCGS 143-215.75 et seq. or Section 311 of the
Federal Act, 33 USC 1321.
The issuance of this general permit does not convey any property rights in either real or
personal property, or any exclusive privileges, nor does it authorize any injury to private
property or any invasion of personal rights, nor any infringement of Federal, State or local
laws or regulations.
7. Sevgility
The provisions of this general permit are severable, and if any provision of this general
permit, or the application of any provision of this general permit to any circumstances, is
held invalid, the application of such provision to other circumstances, and the remainder of
this general permit, shall not be affected thereby.
The permittee shall furnish to the Director, within a reasonable time, any information which
the Director may request to determine whether cause exists for modifying, revoking and
reissuing, or terminating the certificate of coverage issued pursuant to this general permit or
to determine compliance with this general permit. The permittee shall also furnish to the
Director upon request, copies of records required to be kept by this general permit.
Part III Page 2 of 9 Pages

Permit No. NCG060000
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
general permit shall, upon conviction, be punished by a fine of not more than $10,000 per
violation, or by imprisonment for not more than two years per violation, or by both. If a
conviction of a person is for a violation committed after a first conviction of such person
under this paragraph, punishment is a fine of not more that $20,000 per day of violation, or
by imprisonment of not more than 4 years, or both.
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this general permit, including monitoring reports or reports of compliance
or noncompliance shall, upon conviction, be punished by a fine of not more than $10,000
per violation, or by imprisonment for not more than two years per violation, or by both.
SECTION B: GENERAL CONDITIONS
An expired general permit continues in force and effect until the general permit is reissued
or a new general permit is issued. Those facilities authorized to discharge under the
expiring general permit are covered until the general permit is reissued or a new general
permit is issued.
2, Transfers
The certificate of coverage issued pursuant to this general permit is not transferable to any
person except 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.
3. When an I di i ual &rmij Maye RNUiMd
The Director may require any owner/operator authorized to discharge under a certificate of
coverage issued pursuant to this general permit to apply for and obtain an individual permit
or coverage under an alternative general permit. Any interested person may petition the
Director to take action under this paragraph. Cases where an individual permit may be
required include, but are not limited to, the following:
a. The discharger is a significant contributor of pollutants;
b . Conditions at the permitted site change, altering the constituents and/or
characteristics of the discharge such that the discharge no longer qualifies for a
general permit;
c. The discharge violates the terms or conditions of this general permit;
d . A change has occurred in the availability of demonstrated technology or practices
for the control or abatement of pollutants applicable to the point source;
Part III Page 3 of 9 Pages

Permit No. NCG060000
e. Effluent limitations are promulgated for the point sources covered by this general
permit;
f . A water quality management plan containing requirements applicable to such point
sources is approved after the issuance of this general permit.
g. The Director determines at his own discretion that an individual permit is required.
Any permittee operating under this general permit may request to be excluded from the
coverage of this general permit by applying for an individual permit. When an individual
permit is issued to an owner/operator the applicability of this general permit is automatically
terminated on the effective date of the individual permit.
All applications, reports, or information submitted to the Director shall be signed and
certified.
a. All notices of intent to be covered under this general permit shall be signed as
follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of
this Section, a responsible corporate officer means: (a) a president,
secretary, treasurer or vice president of the corporation in charge of a
principal business function, or any other person who performs similar
policy or decision making functions for the corporation, or (b) the manager
of one or more manufacturing production or operating facilities employing
more than 250 persons or having gross annual sales or expenditures
exceeding 25 million (in second quarter 1980 dollars), if authority to sign
documents has been assigned or delegated to the manager in accordance
with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the
proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a
principal executive officer or ranking elected official.
b. All reports required by the general permit and other information requested by the
Director shall be signed by a person described above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having
responsibility for the overall operation of the regulated facility or activity,
such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or
position having overall responsibility for environmental matters for the
company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
Part III Page 4 of 9 Pages

Permit No. NCG060000
(3) The written authorization is submitted to the Director.
C. Any person signing a document under paragraphs a. or b. of this section shall make
the following certification -
"I certify, under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly 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 fines and imprisonment for knowing violations."
6. Qpneral PeKmLt Modification, RqwocAfion d Rgissuanp& or TMtion
The issuance of this general permit does not prohibit the Director from reopening and
modifying the general permit, revoking and reissuing the general permit, or terminating the
general permit as allowed by the laws, rules, and regulations contained in Title 40, Code of
Federal Regulations, Parts 122 and 123; Title I5A of the North Carolina Administrative
Code, Subchapter 2H .0100; and North Carolina General Statute 143-215.1 et. al.
After public notice and opportunity for a hearing, the general permit may be terminated for
cause. The filing of a request for a general permit modification, revocation and reissuance,
or termination does not stay any general permit condition. The certificate of coverage shall
expire when the general permit is terminated.
The certificate of coverage issued in accordance with this general permit may be modified,
revoked and reissued, or terminated for cause. The notification of planned changes or
anticipated noncompliance does not stay any general permit condition.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
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
pem7ittee to achieve compliance with the conditions of this general permit. Proper
operation and maintenance also includes adequate laboratory controls and appropriate
quality assurance procedures. This provision requires the operation of back-up or auxiliary
facilities or similar systems which are installed by a permittee only when the operation is
necessary to achieve compliance with the conditions of the general permit.
It shall not be a defense for a perrnittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
condition of this general permit.
Part III Page 5 of 9 Pages

Permit No. NCG060000
1 :, 1 • • • ql . c � •
Bypass is prohibited and the Director may take enforcement action against a permittee for
bypass unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property
damage; and
b. There -were no feasible alternatives to the bypass, such as the use of auxiliary
control facilities, retention of stormwater or maintenance during normal periods of
equipment downtime or dry weather. This condition is not satisfied if adequate
backup controls should have been installed in the exercise of reasonable engineering
judgment to prevent a bypass which occurred during normal periods of equipment
downtime or preventive maintenance; and
C. The permittee submitted notices as required under Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director
may approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Samples collected and measurements taken, as required herein, shall be characteristic of the
volume and nature of the permitted discharge. Analytical sampling shall be performed
during a representative storm event. Samples shall be taken on a day and time that is
characteristic of the discharge. All samples shall be taken before the discharge joins or is
diluted by any other waste stream, body of water, or substance. Monitoring points as
specified in this permit shall not be changed without notification to and approval of the
Director.
For each measurement, sample, inspection or maintenance activity performed or collected
pursuant to the requirements of this general permit, the permittee shall record the following
information:
a. The date, exact place, and time of sampling, measurements, inspection or
maintenance activity;
b. The individual(s) who performed the sampling, measurements, inspection or
maintenance activity;
C. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
Part III Page 6 of 9 Pages

Permit No. NCG060000
Where required, appropriate flow measurement devices and methods consistent with
accepted scientific practices shall be selected and used to ensure the accuracy and reliability
of measurements of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations
published pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts,
and to regulations published pursuant to Section 304(g), 33 USC 1314, of the Federal
Water Pollution Control Act, as Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this general permit, all test procedures
must produce minimum detection and reporting levels and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure.
5. Ngn-Slounw=r D' char es
If a monitored storm event coincides with a non-stormwater discharge, the permittee shall
separately monitor all parameters as required under the non-stormwater discharge permit
and provide this information with the stormwater discharge monitoring report.
6. Representative Outfail
If a facility has multiple discharge locations with substantially identical stormwater
discharges that are required to be sampled, the permittee may petition the Director for
representative outfall status. If it is established that the stormwater discharges are
substantially identical and the permittee is granted representative outfall status, then
sampling requirements may be performed at a reduced number of outfalls.
MINEFTM • 4
Visual monitoring shall be documented and records maintained at the facility along with the
Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be
maintained on -site. The permittee shall retain records of all monitoring information,
including 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 at least 5 years from the date of the sample, measurement, report or
application. This period may be extended by request of the Director at any time.
a. TM1T$ =.r. M ' N
The permittee shall allow the Director, or an authorized representative (including an
authorized contractor acting as a representative of the Director), or in the case of a facility
which discharges through a municipal separate storm sewer system, an authorized
representative of a municipal operator or the separate storm sewer system receiving the
discharge, upon the presentation of credentials and other documents as may be required by
law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located
or conducted, or where records must be kept under the conditions of this general
pest;
Part III Page 7 of 9 Pages

Permit No. NCG060000
b . Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this general permit;
C. Inspect at reasonable times any facilities, equipment (including -monitoring and
control equipment), practices, or operations regulated or required under this general
permit; and
d . Sample or monitor at reasonable times, for the purposes of assuring general permit
compliance or as otherwise authorized by the Clean Water Act, any substances or
parameters at any location.
SECTION E: REPORTING REQUIREMENTS
h
Samples analyzed in accordance with the terms of this permit shall be submitted to the
Division on Discharge Monitoring Report forms provided by the Director. Submittals shall
be received by the Division no later than 30 days from the date the facility receives the
sampling results from the laboratory.
Documentation of the qualitative monitoring associated with the initial analytical monitoring
event shall be included with the required analytical monitoring submittal for the first year of
the permit coverage.
Analytical results from sampling during the final year of the permit coverage shall be
submitted with the permit renewal application.
Duplicate signed copies of all reports required herein, shall be submitted to the following
address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
Post Office Box 29535
Raleigh, North Carolina 27626-0535
M RITT i s X670
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308
of the Federal Act, 33 USC 1318, all -reports prepared in accordance with the terms shall be
available for public inspection at the offices of the Division of Water Quality As required
by the Act, analytical data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as
provided for in NCGS 143-215.6B or in Section 309 of the Federal Act.
If the storm event monitored in accordance with this general permit coincides with a non-
stormwater discharge, the permittee shall separately monitor all parameters as required
Part III Page 8 of 9 Pages

Permit No. NCG060000
under the non-stormwater discharge permit and provide this information with the
stormwater discharge monitoring report.
The permittee shall give notice to the Director as soon as possible of any planned changes at
the permitted facility which could significantly alter the nature or quantity of pollutants
discharged. This notification requirement includes pollutants which are not specifically
listed in the general permit or subject to notification requirements under 40 CFR Part
122.42 (a).
5. Anticipgted Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes at
the permitted facility which may result in noncompliance with the general permit
requirements.
7. Bypass
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it
shall submit prior notice, if possible at least ten days before the date of the bypass;
including an evaluation of the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of.
becoming aware of an unanticipated bypass.
8. Twenty-four Hour$eoorting
The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission Shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes; the
period of noncompliance, including exact dates and times, and if the noncompliance has not
been corrected, the anticipated time compliance is expected to continue; and steps taken or
planned to reduce, eliminate, and prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case -by -case basis if the oral report has
been received within 24 hours.
The permittee shall report all instances of noncompliance not reported under 24 hour
reporting at the time monitoring reports are submitted.
10. Qher Information
Where the permittee becomes aware that it failed to submit any relevant facts in a Notice of
Intent to be covered under this general permit or in any report to the Director, it shall
promptly submit such facts or information.
Part III Page 9 of 9 Pages

PART IV LIMITATIONS REOPENER
This general permit shall be modified or alternatively, revoked and reissued, to comply with any
applicable effluent guideline or water quality standard issued or approved under Sections 302(b)
(2) (c), and (d), 304(b) (2) and 307(a) of the Clean Water Act, if the effluent guideline or water
quality standard so issued or approved:
a. Contains different conditions or is otherwise more stringent than any effluent limitation in
the general permit; or
b. Controls any pollutant not limited in the general permit.
The general permit as modified or reissued under this paragraph shall also contain any other
requirements in the Act then applicable.
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days
after being billed by the Division. Failure to pay the fee in timely manner in accordance with 15A
NCAC 2H .0105(b)(4) may cause this Division to initiate action to revoke the Certificate of
Coverage.
PART VI DEFINITIONS
+:
See Clean Water Act.
The arithmetic mean of any set of values is the summation of the individual values divided
by the number of individual values.
This permit regulates stormwater discharges. Non-stormwater discharges which shall be
allowed in the stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
(b) Uncontaminated groundwater, foundation drains, air -conditioner condensate
without added chemicals, springs, discharges of uncontaminated potable water,
waterline and fire hydrant flushings, water from footing drains, flows from riparian
habitats and wetlands.
(c) Discharges resulting from fire -fighting or fire -fighting training.
Parts IV, V and VI Page 1 of 5

Permit No. NCG060000
Measures or practices used to reduce the amount of pollution entering surface waters.
BMPs may take the form of a process, activity, or physical structure.
5. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control
facility including the collection system, which is not a designed or established operating
mode for the facility.
6. Bulir Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single
above ground storage container having a capacity of greater than 660 gallons or with
multiple above ground storage containers located in close proximity to each other having a
total combined storage capacity of greater than 1,320 gallons.
The Certificate of Coverage (COC) is the cover sheet which accompanies the general penuit
upon issuance and lists the facility name, location, receiving stream, river basin, effective
date of coverage under the permit and is signed by the Director.
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as
amended, 33 USC 1251, et. seq.
9. Divisisw or DWQ
The Division of Water Quality, Department of Environment, Health and Natural Resources.
1 " t—•_ 1
The Director of the Division of Water Quality, the permit issuing authority.
The North Carolina Environmental Management Commission.
12. Grab Samnle
An individual samples collected instantaneously. Grab samples that will be directly
analyzed or qualitatively monitored must be taken within the first 30 minutes of discharge.
13. Haw— doas _Substance
Any substance designated under 40 CFR Part It 6 pursuant to Section 311 of the Clean
Water Act.
Part VI Page 2 of 5 Pages

Permit No. NCG060000
14, Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and
which is not a land treatment facility, a surface impoundment, an injection well, a
hazardous waste long-term storage facility or a surface storage facility.
ITIMETUMPMM_ - � . +.pit
A stormwater collection system within an incorporated area of local self-government such
as a city or town.
16. NotiggofI e t
The state application form which, when submitted to the Division, officially indicates the
facility's notice of intent to seek coverage under a general pernut.
Any material of any nature, consolidated or unconsolidated, that overlies a mineral deposit,
excluding topsoil or similar naturally -occurring surface materials that are not disturbed by
mining operations.
18. P.ennittee
The owner or operator issued a certificate of coverage pursuant to this general permit.
19. Point Source Discharge gf Stormv_yater
Any discernible, confined and discrete conveyance including, but not specifically limited
to, any pipe, ditch, channel, tunnel, conduit, well, or discrete fissure from which
stormwater is or may be discharged to waters of the state.
A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm
event may contain up to 10 consecutive hours of no precipitation. For example, if it rains for 2
hours without producing any collectable discharge, and then stops, a sample may be collected if a
rain producing a discharge begins again within the next 10 hours.
1
When it is established that the discharge of stormwater runoff from a single outfall is
representative of the discharges at multiple outfalls, the DWQ may grant representative
outfall status. Representative outfall status allows the pem-duee to perform analytical
monitoring at a reduced number of outfalls.
22. Rime Wager Dis-charae
The discharge of rinse water from equipment cleaning areas associated with industrial
activity. Rinse waters from vehicle and equipment cleaning areas are process wastewaters
and do not include washwaters utilizing any type of detergent or cleaning agent.
Part VI Page 3 of 5 Pages

Permit No. NCG060000
Spill containment for the contents of the single largest tank within the containment structure
plus sufficient freeboard to allow for the 25-year, 24-hour storm event.
24. Seclion 313 Water PrJori1y Chemcal
A chemical or chemical category which:
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund
Amendments and Reauthorization Act (SARA) of 1986, also titled the Emergency
Planning and Community Right -to -Know Act of 1986;
b . Is present at or above threshold levels at a facility subject to SARA title III, Section
313 reporting requirements; and
c. That meet at least one of the following criteria:
(1) Is listed in appendix D of 40 CFR part 122 on either Table H (organic
priority pollutants), Table III (certain metals, cyanides, and phenols) or
Table IV (certain toxic pollutants and hazardous substances);
(2) Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the
CWA at 40 CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality
criteria.
Means substantial physical damage to property, damage to the control facilities which
causes them to become inoperable, or substantial and permanent loss of natural resources
which can reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
26. %gpi,�ac nt M=fials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents,
and plastic pellets; finished materials such as metallic products; raw materials used in food
processing or production; hazardous substances designated under section 101(14) of
CERCLA; any chemical the facility is required to report pursuant to section 313 of Title III
of SARA; fertilizers; pesticides; and waste products such as ashes, slag and sludge that
have the potential to be released with stormwater discharges.
27. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of
reportable quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and
CFR 117.21) or section 102 of CERCLA (Ref: 40 CFR 302.4).
28. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately
following rainfall or as a result of snowmelt.
Part VI Page 4 of 5 Pages

Permit No. NCG060000
The discharge from any point source which is used for collecting and conveying
stormwater and which is directly related to manufacturing, processing or raw material
storage areas at an industrial site. Facilities considered to be engaged in "industrial
activities" include those activities defined in 40 CFR 122.26(b)(14). The term does not
include discharges from facilities or activities excluded from the NPDES program.
A comprehensive site -specific plan which details measures and practices to reduce
stormwater pollution and is based on an evaluation of the pollution potential of the site.
1 -4 •��
The ma_xiatum 24 hour precipitation event expected to be equaled or exceeded on the
average once in ten yews. Design storin inibruiatioti can be found in the State of Noah
Carolina Erosion and Sediment Control Planning and Design Manu.tl.
The flow corresponding to the time period over which the sample collection occurs. Total
flow shall be either, (a) measured continuously, (b) calculated based on the amount of area
draining to the outfall, the amount of built -upon (impervious) area, and the total amount of
rainfall, or (c) estimated by the measurement of flow at 20 minute intervals during the
rainfall event.
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
34, Upset
Means an exceptional incident in which'there is unintentional and temporary noncompliance
with technology based permit effluent limitations because of factors beyond the reasonable
control of the pern- tUee. An upset does not include noncompliance to the extent caused by
operational error, improperly designed treatment or control facilities, inadequate treatment
or control facilities, lack of preventive maintenance, or careless or improper operation.
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning
operations, or airport deicing operations.
36. Vi$iblg Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported by
water, air, gravity, or ice from its site of origin which can be seen with the unaided eye.
511111101111
- i
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the
average, once in 25 years.
Part VI Page 5 of 5 Pages

Facility Name: SMITHFIELD FOODS, INC-CAROLINA
Certificate of Coverage Number: NCGO60126
Location Address: ROUTE 1, BOX 189
TAR HEEL, NC 28392
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information required by
the SPPP. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information gathered is, to the best of my
knowledge and belief, true, accurate, and complete."
"I certify that the SPPP has been developed, signed and retained at the facility location and the SPPP has
been fully implemented at the named facility location in accordance with the terms and conditions of the
stonnwater general permit."
"I am aware that there are significant penalties for falsifying information, including the possibility of fines
and imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. Return
within 30 days of receipt if the date on your initial Certificate of Coverage is before
September 1, 1996. If your initial Certificate of Coverage was issued after September
1, 1996, sign and return this certification within 30 days of implementation of your
Stomwater Pollution Prevention Plan. DO NOT SEND THE STORMWATER
POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
(signature)
(print/type name)
(title)
Return To:
Division of Water Quality
Stormwater Group
P.O. Box 29535
Raleigh, NC 27626-0535
SPPP Certification 9/97

NORTH CAROLINA DIVISION OF WATER OU LITY
The stormwater__ permitting
Rr=am_'s jobjective_ is to
reduce the poll to ant 19ad in
stormwater runoff by:
1- Educating the permitted
community about stormwater
pollutants,
2- Encouraging the use of Best
Management Practices (BMPs)
to minimize the entry of
pollutants into stormwater, and
3- Using collected analytical data
to assess stormwater's
contribution to water pollution
to help prioritize controls in
problem areas.
❑ Implementation of a
Stormwater Pollution
Prevention Platt (SPPP) (Part
IL Section A).
13 Provide secondary containment
for all built storage of liquid
materials. (Part 11, Section A:
2. (b))•
© Perform annual analytical
monitoring and submit the
results on the monitoring report
forms provided with the permit.
(Part II, Section B).
❑ Perform and document semi-
annual qualitative monitoring.
(Part II, Section Q.
f
If a facility has more than one
stormwater outfall then the permit
requires that all outfalls subject to
the permit be monitored. However,
the permit also allows for the
facility to request "Representative
Outfall Status". Representative
outfall status allows the facility to
perform analytical monitoring at a
reduced number of outfalls.
Application is made by a letter to
the Stormwater Group clearly
explaining which outfall(s) is/are to
be considered representative of other
discharges from the site. A copy of
the site map used in the SPPP that
deEineates drainage areas, industrial
activities, and any other potential
Stormwater pollutant exposures shall
be included with the letter to support
the application.
The Stormwater Pollution
Prevention Plan should include the
use of Best Management Practices
(BMP's) to control the discharge of
pollutants from a facility's
stormwater outfalls. BMP's include
a variety of things that the
industrial facility can do in order to
minimize the potential for
pollutants to get into the stormwater
draining from a facility. The
following outlines some potential
types of BMP's.
Non -Structural BMP's
Some examples of non-structural
(practices or activities) BMP's are as
follows.
• Eliminate exposure of materials
and equipment wherever
possible by moving materials
'and equipment to indoor
locations.
• A very effective and cost
effective BMP is to practice
good housekeeping on -site.
Keep materials handled and
stored at the -facility in an
orderly fashion.
• Examine process and exchange
hazardous materials for non-
hazardous ones wherever
possible.
• Establish routine leak and
maintenance checks to
minimize the chance of spills
before they occur.. When spills
do occur, clean them up
immediately.
Establish bulk storage tank
protocols that minimize the risk
of spills during loading and
unloading procedures.
Store used pallets and process
waste dumpsters inside or under
a roof where water cannot flow
on or around them.
,Srructural BMP's
Some examples of structural
(equipment or devices) BMP's are as
follows:
• Build containment dikes around
the loading areas of bulk liquid
storage containers.
• Where practical, change
painting operations from liquid
systems to powdered systems
that don't generate solvent
wastes.
• Build roofs and secondary
containment around any
materials stored outside so that
stormwater doesn't run onto
them and carry pollutants away
with it.
category 11 _Exemption
Facilities with the SIC codes 20,
21, 22, 23, 2434, 25, 265. 267,
27, 283, 285, 30, 31 (except 311),
323, 34 (except 3441, 35, 36, 37
(except 373), 38, 39, and 4221-
4225 that eliminate all of their
potential stormwater exposures do
not require a stormwater permit.
Facilities with these SIC codes that
meet these conditions are said to
meet the category 11 exemption,
and need to send a letter explaining
their situation to the stormwater
group so that they may be
considered for permit exemption. If
a facility changes its operations so
as to be exempt after it has already
obtained a permit it may send a
letter explaining the changes that
have been made and request
rescission of their existing permit.

Other
u
a t'
Northon i
stormwater
Program
The following documents are
available through the stormwater
permitting group by calling
[phone].
• Summary of Pederal NatlQ[al
Pollutant Discharae_App 'cation
RCgulations forOvate
Discharges Associated_ with
Industrial Activities_
• Stormwaler Pot I_Utio0
Prevention Plans fo
S4M.wacer Bunoffat IsIduadal
Activities,
• Stormwater Pollution
Prevention . Platt _ Guidance
Document.
• Stormwater Manaaernent
C •..4 u.•+__�
Another excellent source of
information is the North Carolina
Office of Waste Reduction. They
have lots of specific information on
how to minimize pollutants at
various types of industries. They
may be reached at (919) 5714100.
CoMmonly asked --- g st.� iens
1) Do all stormwater outfalls
need to be analytically
monitored?
Only those outfalls that drain areas
of the facility associated with the
industrial activity need to be
monitored. Also, see previous
discussion on representative outfall
status.
2) What happens if when I
pull samples for my
annual analytical
monitoring I'm unable to
get a sample for one of
the parameters?
If this happens it is fine to go ahead
and just sample for the missing
parameter during the next
representative storm event, just be
sure to note the total rainfall, event
duration, and total flow apart from
the initial monitoring data.
3) Does a certified lab need
to be used to analyze
stormwater samples?
Yes, a North Carolina certified lab
must be used to perform analytical
monitoring. The only exception to
this rule is when measuring the
value of pH. pH values should be
measured in the field because they
may change considerably between
when the sample is pulled and it is
analyzed at the laboratory.
4) How do you average the
first year's analytical
monitoring results?
The measured concentration of a
particular pollutant collected during
the first year's analytical monitoring
is the average value for that
parameter since dividing it by one
gives the same value for cut-off
purposes.
5) What If I Sell My
Business Or The Name
of My Business
Changes ?
The Division views changes of
name or ownership as a minor
modification and requires the
Director's approval. Name and
ownership changes require you to
complete a Name/Ownership
Change Form (available from the
Division) and to pay a $100
processing fee.
6) What Do I Do When My
Stormwater Permit
Expires?
In the State of North Carolina, the
Stormwater General Permit is in
forge and effect and covered
facilities are allowed to continue
discharging under the permit until
the general permit is reissued or a
new general permit is issued.
Changes in Reissued
General Rertmits
Some stormwater general permits
have been reissued in 1997 for a
new five year term. Several
important changes from the
previous version of these permits
are:
Revision to the parameters
and frequency for analytical
monitoring and the addition of
cutoff concentrations for each
parameter.
Sample types are now all grab
samples (no composite
sampling).
The definition of the
Representative Storm Event
for the analytical monitoring
has changed (see the
definitions section of the
permit) and the sample
window of April through
November has been dropped.
Discharge Monitoring
Reports should be submitted
to the Division of Water
Quality within 30 days of the
date the facilty receives the
laboratory results instead of
waiting until the end of the
year.
Other .-Information
Additional Technical Bulletins
will be available in the future
from the Division. Contact us at:
N.C. Division of Water Quality
Water Quality Section
Stormwater and General Permits Unit
P.O. Box 29535
Raleigh, N.C. 27626-0535
919-733-5083
Fax [phone]
Check the Division's Web Site at:
http://pluto.ehnr.state,nc,us/wghome.html
for a link to the Stormwater Unit soon to be added
Please make us aware of any
issues you feel should be addressed
in future Technical Bulletins.
August 29, 1997
-2 -

STORMWATER DISCHARGE MONITORING REPORT (DMR)
Please Mail OJ2'nal And One Co 2y To Mailing Address On Back Of This Form
Part A: Facility Information
Samples Collected In Calendar Year: —
Certificate Of Coverage No. NCGO6
Facility Name
Facility Contact
GENERAL PERMIT NO. NCGO60000
(all samples shall be reported following receipt from tab, but no later than January 31 of the following year)
County of Facility
Name of Laboratory
Lab Certification #
Facility Contact Phone No.
Part B: Specific Monitoring Requirements
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Footnote I Fecal Coliform samplingit, applicable only to facilities processing meats.
Does the facility perform vehicle washing and fueling?— yes —no
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? yes _no
(if yes, complete Part Q
Part C: Vehicle Maintenance Activity Monitoring Requirements
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Part D: Storm Event Characteristics
Total Event Precipitation (inches):
Event Duration (hours):
(if more than one storm event was sampled)
Total Event Precipitation (inches):
Event Duration (hours):
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly 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 fines and imprisonment for knowing violations."
(Signature of Permittee) (Date)
MAILING ADDRESS:
Attn: Central Files
DEHNR
N. C. Division of Water Quality
P.O. Box 29535
Raleigh, NC 27626-0535
Farm DMR06

0104�'�
A
STORMWA TER DISCHARGE OUTFALL (SDO)
QUALITATIVE MONITORING REPORT
Certificate of Coverage No. NCG
Facility Name:
County:— _ _ Phone No.:
Inspector:
Date of Inspection:
By this signature, I certify that this report is accurate and complete to the best of my
knowledge:
(Signature of Permrttee or Designee)
1. Outfall Description
Outfall No.: Structure (pipe, ditch. etc.):
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:
3. Odor
Describe any distinct ordors that the discharge may have (i.e. smells strongly of oil, weak
chlorine odor, etc.):
8/22i97

4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and
10 is very cloudy:
1 2 3 4 5 6 7 8 9 10
5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater
discharge where 1 is no solids and 10 is the surface covered in floating solids:
1 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the
stormwater discharge where I is no solids and 10 is extemely muddy:
1 2 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stornwater discharge? YES NO
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? YES NO
9. Other Obvious Indicators of Stormwater Pollution:
List and describe:
NOTE: Low clarity, high solids and/or the presence of foam or oil sheens may be
indicative of pollutant exposure. These conditions may warrant further
investigation.
8/22/97

STORMWATER DISCHARGE MONITORING REPORT (DMR)
Please Mail Original And One Copy To Mailing Address On Back Of This Form
GENERAL PERMIT NO. NCGO60000
Part A: Facility Information
Samples Collected In Calendar Year: (ail samples shall be reported following receipt from lab, but no later than January 31 or the following year)
Certificate Of Coverage No. NCGO County of Facility
Facility Name Name of Laboratory
Facility Contact Lab Certification #
Facility Contact Phone No. (----)
Part B: Specific Monitoring Requirements
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Footnote I Fecal Coliform sampling applicable only to facilities processing meats.
Does the facility perform vehicle washing and fueling?— yes —no
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? _ yes _no
{if yes, complete Part Q
Part C: Vehicle Maintenance Activity Monitoring Requirements
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Part D. Storm Event Characteristics
Total Event Precipitation (inches):
Event Duration (hours):
(if more than one storm event was sampled)
Total Event Precipitation (inches):
Event Duration (hours):
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly 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 fines and imprisonment for knowing violations."
(Signature of Permittee) (Date)
MAILING ADDRESS:
Attn: Central Files
DEHNR
N. C. Division of Water Quality
P.O. Box 29535
Raleigh, NC 27626-0535
Foes DMR06

STORMWATER DISCHARGE MONITORING REPORT (DMR)
Please Mail Original And One Copy To Mailing Address On Back Of This Form-0
GENERAL PERMIT NO. NCG060000
Part A: Facility Information
Samples Collected In Calendar Year: (A samples shall be reported following receipt from lab, but no later than January 31 of the following year)
Certificate 'Of Coverage No. NCG06 County of Facility
Facility Name Name of Laboratory
Facility Contact Lab Certification #
Facility Contact Phone No.
Part B: Specific Monitoring Requirements
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Footnote I Fecal Coliform sampling applicable only to facilities processing meats.
Does the facility perform vehicle washing and fueling?_ yes —no
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? — yes —no
(if yes, complete Part Q
Part C: Vehicle Maintenance Activity Monitoring Requirements
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Part D: Storm Event Characteristics
Total Event Precipitation (inches):
Event Duration (hours):
(if more than one storm event was sampled)
Total Event Precipitation (inches):
Event Duration (hours):
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly 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 fines and imprisonment for knowing violations."
(Signature of Permittee) (Date)
MAILING ADDRESS:
Attn: Central Files
DEHNR
N. C. Division of Water Quality
P.O. Box 29535
Raleigh, NC 27626-0535
Form DMR06

STORMWATER DISCHARGE MONITORING REPORT (DMR)
Please Mail Original And One C2a To Mailing Address On Back Of This Form
GENERAL PERMIT NO. NCG060000
Part A: Facility Information
Samples Collected In Calendar Year: (all samples shall be reported following receipt from lab, but no later than January 31 of the following year)
Certificate Of Coverage No. NCG06 County of Facility
Facility Name Name of Laboratory
Facility Contact Lab Certification #
Facility Contact Phone No. }
Part B: Specific Monitoring Requirements
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Footnote t Facal Coliform sampling applicable only to facilities processing meats.
Does the facility perform vehicle washing and fueling?_ yes —no
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? T yes ,no
(if yes, complete Part Q
Part C: Vehicle Maintenance Activity Monitoring Requirements
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Part D: Storm Event Characteristics
Total Event Precipitation (inches):
Event Duration (hours):
(if more than one storm event was sampled)
Total Event Precipitation (inches):
Event Duration (hours):
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly 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 fines and imprisonment for knowing violations."
(Signature of Permittee) (Date)
MAILING ADDRESS:
Attn: Central Files
DEHNR
N. C. Division of Water Quality
P.O. Box 29535
Raleigh, NC 27626-0535
Form DMR06

STORMWATER DISCHARGE MONITORING REPORT (DMR)
Please Mail Ori inal And One C2Ey To Mailing Address On Back Of This Form
GENERAL PERMIT NO. NCGO60000
Part A: Facility Information
Samples Collected In Calendar Year: (all samples shall be reported following receipt from lab, but no later than January 31 of the following year)
Certificate Of Coverage No. NCGO6 County of Facility
Facility Name Name of Laboratory
Facility Contact Lab Certification #
Facility Contact Phone No. (. )
Part B: Specific Monitorine Requirements
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Does the facility perform vehicle washing and fueling?— yes —no
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new .motor oil per month? _ yes —no
(if yes, complete Part Q
Part C: Vehicle Maintenance Activi Monitoring Requirements
IN
A
Form DMR06

Part D: Storm Event Characteristics
Total Event Precipitation (inches):
Event Duration (hours):
(if more than one storm event was sampled)
Total Event Precipitation (inches):
Event Duration (hours):
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly 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 fines and imprisonment for knowing violations."
(Signature of Permittee) (Date)
MAILING ADDRESS:
Attn: Central Files
DEHNR
N. C. Division of Water Quality
P.O. Box 29535
Raleigh, NC 27626-0535
Form DMR06

STORMWATER DISCHARGE OUTFALL (SDO)
QUALITATIVE MONITORING REPORT
Certificate of Coverage No,
Facility Name:
County:
Inspector:
Date of Inspection: _
Phone No.: ( i
By this signature. I certify that this report is accurate and complete to the best of my
knowledge:
(Signature of Permittee or Designee)
1. Outfall Description
Outl'all No.,. Structure (pipe, ditch, etc.):
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe; the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:
3. Odor
Describe any distinct ordors that the discharge may have (i.e. smells strongly of oil, weak
chlorine odor, etc.):
8/22/97

4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and
10 is very cloudy:
1 2 3 4 5 6 7 8 9 l0
5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater
discharge where 1 is no solids and 10 is the surface covered in floating solids:
1 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the
stormwater discharge where 1 is no solids and 10 is extemely muddy:
1 2 3 4 5 6 7 8 9 10
7. Foam
is there any foam in the stormwater discharge? YES NO
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? YES NO
9. Other Obvious Indicators of Stormwater Pollution:
List and describe:
NOTE: Low clarity, high solids and/or the presence of foam or oil sheens may be
indicative of pollutant exposure, These conditions may warrant further
investigation.
8/22/97

STORMWATER DISCHARGE OUTFALL (SDO)
QUALITATIVE MONITORING REPORT
Certificate ot' Coverage No. NCG
Facility Nante:
County: Phone No.:
Inspector:
Date of Inspection:
By this signature, I certify that this report is accurate and complete to the best of illy
knowledge:
(Mgnarure of Permittee or Designee)
1. Outfall Description
Outfall No.:_ Structure (pipe, ditch. etc.):
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:
3. Odor
Describe any distinct ordors that the discharge may have (i.e. smells strongly of oil, weak
chlorine odor, etc.):
8/22/97

4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and
10 is very cloudy:
1 2 3 4 5 6 7 8 9 10
5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater
discharge where 1 is no solids and 10 is the surface covered in floating solids:
1 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the
stormwater discharge where i is no solids and 10 is extemely muddy:
1 2 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? YES NO
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? YES NO
9. Other Obvious Indicators of Stormwater Pollution:
List and describe:
NOTE: how clarity, high solids and/or the presence of foam or oil sheens may be
indicative of pollutant exposure. These conditions may warrant further
investigation.
8/22197

STORMWATER DISCHARGE OUTFALL (SDO)
QUALITATIVE MONITORING REPORT
Certificate of Coverage No. NCG
Facility Name:
County:
Inspector:_
Date of Inspection:
Phone No.:
lay this signature, I certify that this report is accurate and complete to the best of my
knowledge:
(Signature of Permittee or Designee)
1.. Outfall Description
Outfall No.: Structure (pipe, ditch, etc.):
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:
3. Odor
Describe any distinct ordors that the discharge may have (i.e. smells strongly of oil, weak
chlorine odor, etc.):
8/22197

4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and
10 is very cloudy:
1 2 3 4 5 6 7 8 9 10
5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater
discharge where 1 is no solids and 10 is the surface covered in floating solids:
1 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the
stormwater discharge where 1 is no solids and 10 is extemely muddy:
1 2 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? YES NO
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? YES NO
9. Other Obvious Indicatoirs of Stormwater Pollution:
List and describe:
NOTE: Low clarity, high solids and/or the presence of foam or oil sheens may be
indicative of pollutant exposure. These conditions may warrant further
investigation.
8122/97

STORMWATER DISCHARGE OUTFALL (SDO)
QUALITATIVE MONITORING REPORT
Certificate of Coverage No. NCG
Facility Name:
County: Phone No..
Inspector:
Date of Inspection:
By this signature, I certify that this report is accurate and complete to the best of my
knowledge:
(Signature of Pernzittee or Designee)
1. Outfall Description
Outfall No.: Structure (pipe, ditch, etc.):
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:
3. Odor
Describe any distinct ordors that the discharge may have (i.e. smells strongly of oil, weak
chlorine odor, etc.):
8/22/97

4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and
10 is very cloudy:
1 2 3 4 5 6 7 8 9 10
5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater
discharge where I is no solids and 10 is the surface covered in floating solids:
1 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the
stormwater discharge where 1 is no solids and 10 is extemely muddy:
1 2 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? YES NO
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? YES NO
9. Other Obvious Indicators of Stormwater Pollution:
List and describe:
MOTE: Low clarity, high solids and/or the presence of foam or oil sheens may be
indicative of pollutant exposure. These conditions may warrant further
investigation.
8/22/97

j
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
February 8, 2011
Smithfield Packing Company, Tar Heel Division
Attn: Sylwia LaBudde, Environmental Coordinator
PO Box 99
Tar Heel, NC 28392
Subject: Chlorine Dioxide Application Study
Smithfield -Tar Heel Facility-NCG060126
Bladen County
Dear Ms. LaBudde:
Dee Freeman
Secretary
Upon review of your letter dated June 28, 2010 regarding a Request to Conduct a Chlorine Dioxide Application Study at
the Smithfield -Tar Heel facility in Bladen County, along with additional information received via letters dated September
10, 2010 and January 21, 2011 as well as an e-mail received on February 1, 2011, staff with the Fayetteville Regional
Office of the Division of Water Quality hereby approves your request.
Procedures for application shall be carried out as detailed in the Maintenance SOP #5 that was provided with the
September 10, 2010 letter. These procedures include, but are not limited to: application by authorized personnel only, use
of an industrial sweeper equipped with a spray bar capable of discharging at a rate of 3.6 gallons per minute, application
not occurring during or immediately preceding a rain event, etc. In addition, application shall only occur in areas of the
facility that drain to Outfall #002.
In order to facilitate continued use of the proposed chlorine dioxide solution, chloride and toxicity will be monitored at
Outfall #002. This monitoring is in addition to and should coincide with the Analytical Monitoring as described in the
NCG060000 general stormwater permit for which the facility has coverage. Reports of this additional monitoring should be
provided to the Fayetteville Regional Office within 30 days from receipt of the results of analysis. To account for possible
seasonal fluctuations and provide a high level of confidence regarding success, our office recommends a minimum time
frame of twelve months to conduct the study.
Should the need arise to modify any part of the proposed study; you should contact this office for approval prior to making
any such modifications. If you have any questions or concerns, please contact Mike Lawyer or myself at [phone].
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSH: MLlml
cc: FRO -Surface Water Protection
Stormwater Permitting Unit
Location: 225 Green Street, Suite 714, Fayetteville, North Carolina 28301
Phone [phone] i FAX: 91OA86-07071 Customer Service: 1-877-623-6748
Internet: http:llpartal.ncdenr.arglwehlaq
NorthCarolina
JVatmally
An Equal Opportunity; Affirmative Action Employer

r
Lawyer, Mike
From: Labudde, Sylwia [[e-mail]]
Sent: Tuesday, February 01, 2011 6:42 AM
To: Lawyer, Mike
Cc: Henson, Belinda; Larsen, Cory; Pickle, Ken; Jones, Jennifer
Subject: RE: Toxicity Testing.
Mike,
Thank you for taking the time last week to answer my questions in regards to your email (below). I would like to clarify
the statement in my earlier letter which stated "...vast majority of chlorine dioxide application sites drain to Outfall
4002..."; the intended meaning was to highlight that some of the areas draining into Outfall #002 would not undergo
chlorine dioxide application. We do not intend to apply this solution to any of the areas draining into Outfall #001;
which is the main reason why chloride and toxicity testing is unnecessary in that particular outfall. Fecal figures in both
locations are generally comparable in nature, therefore we will use untreated Outfall #001 as a control to see if fecal
numbers in Outfall#002 change due to treatment or if they simply reflect weather fluctuations.
You also inquired about a possible cause for higher chloride readings in Outfall #002 (avg 54 mg/L) versus Outfall #001
(avg < 5 mg/L). I do not know the reason why Outfall #002 chloride values are higher. The main difference between
these areas are: Outfall #001 receives most of its stormwater runoff from the employee parking lot, while Outfall # 002
receives flow from area where the majority of outside operations occur. There is no historical data for stormwater
runoff to determine acceptable chloride levels. In our case. it may be helpful to compare stormawter chloride levels to
Final Effluent (FE) discharge governed by NPDES Discharge Permit. 2010 FE chloride readings were: FEB-689,APR-
894,JUL-773,and OCT-732 for an average of 772 mg/L.
As far as sampling during representative storm events, the samples taken on 9/27/10 and 11/04/10 meet that
definition. The other two samples were taken so that we could further understand chloride level fluctuations. I
apologize for not clarifying the difference.
Please let me know if I was able to answer all of your questions.
Sylika. fa.Budde
Environmental Coordinator
Smithfield Packing Co., Tar Heel Division
15855 Highway 87 West
Tar Heel, NC 28392
Work [phone] x 605
Fax [phone]
sylwialebuddeCaDsmithfield.com
From: Lawyer, Mike [mailto:[e-mail]]
Sent: Wednesday, January 26, 2011 1:57 PM.
To: Labudde, Sylwia
Cc: Henson, Belinda; Larsen, Cory; Pickle, Ken; Jones, Jennifer
Subject: RE: Toxicity Testing.
Sylwia,
Belinda and I have reviewed your letter and request that additional sampling (chloride and toxicity) be
conducted only at outfall 2. 1 have cc'ed some of the staff with the Stormwater Permitting Unit in Raleigh who
have been involved with this proposed study so that they may also review and comment. According to your
letter, you state that the "...vast majority of chlorine dioxide application sites drain to Outfall #002... which
implies that a portion of the application sites would drain to outfall 001. Based on this as well as the baseline
chloride readings for outfall 001 being < 5 mg/L, which we feel would provide a better comparison of chloride
levels pre -application vs. post -application, we feel that both outfalls should be monitored. Considering also that
the background chloride levels for outfall 002 appearto vary greatly, pre -application vs. post -application

readings at outfall 002 may not provide us with the potential residual information for which we want to
evaluate.
Based on the table you provided with background chloride testing results, the second and third sampling events
(9/27/10 & 9/29/10 respectively) would not be considered as representative storm events. A representative
storm event is defined in the NCG060000 general permit as an "...event that measures greater than 0.1 inches
of rainfall and that is preceded by at- least- 72 hours in which no storm event measuring greater than 0.1 inches
has occurred." Therefore, sampling on 9/27/10 and 9/29/10 would not meet this definition. Also, do you have
any possible explanation for the chloride levels that are already present in the samples taken at outfall 002?
This proposed study is something new for us and we want to be confident that the application of the C1O2
solution will not only provide Smithfield (and possibly other industries) with the ability to control the amount of
fecal coliform in stormwater runoff, but also not introduce another pollutant to the natural resource.
Sincerely,
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] (please note my current e-mail address)
*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: Labudde, Sylwia[mailto:[e-mail]]
Sent: Monday, January 24, 2011 2:47 PM
To: Lawyer, Mike
Subject: Toxicity Testing.
Mike,
Last week I mailed the attached document to Ms. Belinda Henson in regards to stormwater toxicity testing.
Please review it and let me know if you have any questions. Thank you.
Syl via za Budde
Environmental Coordinator
Smithfield Packing Co., Tar Heel Division
15855 Highway 87 West
Tar Heel, NC 28392
Work [phone] x 605
Fax [phone]
sy1wialabudde(a1smithfield.com
This communication (iricluding any attachments) is confidentiai and is intended to be privileged pursuant to applicable law.
If you are not the intended recipient, or the ernployee or agent responsible for delivering it to the intended recipient,then
you are hereby notified that the dissemination. distribution or copying of this communication is prohibited. If you received

this communication in error, please notify Smithfield Foods. Inc, immediately by telephone [phone]) and then delete
th;; communication and destroy all copies thereof.
This communication (including any attachmenis) is confidentiei and is intended to be privileged pursuant to applicable law.
If you are not the intended recipient. or the employee or agent responsible for delivering it to the intended recipient then
you are hereby notified that the disseminalion, disidbulion or copying of this communication is prohibited. If you received
this communication in error, please notify Smithfield Foods. Inc. immediately by telephone [phone]) and then delete
this communication and destroy all copies thereof.

g.
Lawyer, Mike
From: Lawyer, Mike
Sent: Wednesday, January 26, 2011 1:57 PM
To: 'Labudde, Sylwia'
Cc: Henson, Belinda; Larsen, Cory; Pickle, Ken; Jones, Jennifer
Subject: RE: Toxicity Testing.
Attachments: C1O2 Response 01-21-11.pdf
Sylwia,
Belinda and I have reviewed your letter and request that additional sampling (chloride and toxicity) be conducted only at
outfall 2. 1 have cc'ed some of the staff with the Stormwater Permitting Unit in Raleigh who have been involved with this
proposed study so that they may also review and comment. According to your letter, you state that the "...vast majority
of chlorine dioxide application sites drain to Outfall #002...", which implies that a portion of the application sites would
drain to outfall 001. Based on this as well as the baseline chloride readings for outfall 001 being < 5 mg/L, which we feel
would provide a better comparison of chloride levels pre -application vs. post -application, we feel that both outfalls
should be monitored. Considering also that the background chloride levels for outfall 002 appear to vary greatly, pre -
application vs. post -application readings at outfall 002 may not provide us with the potential residual information for
which we want to evaluate.
Based on the table you provided with background chloride testing results, the second and third sampling events
(9/27/10 & 9/29/10 respectively) would not be considered as representative storm events. A representative storm event
is defined in the NCG060000 general permit as an "...event that measures greater than 0.1 inches of rainfall and that is
preceded by at least 72 hours in which no storm event measuring greater than 0.1 inches has occurred." Therefore,
sampling on 9/27/10 and 9/29/10 would not meet this definition. Also, do you have any possible explanation for the
chloride levels that are already present in the samples taken at outfall 002?
This proposed study is something new for us and we want to be confident that the application of the C1O2 solution will
not only provide Smithfield (and possibly other industries) with the ability to control the amount of fecal coliform in
stormwater runoff, but also not introduce another pollutant to the natural resource.
Sincerely,
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] (please note my current e-mail address)
*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: Labudde, Sylwia jmaiIto: sylwialabudde(&Smithfield.com]
Sent: Monday, January 24, 2011 2:47 PM

�T To!"iawyer, Mike
Subject: Toxicity Testing.
Mike,
Last week I mailed the attached document to Ms. Belinda Henson in regards to stormwater toxicity testing. Please review
it and let me know if you have any questions. Thank you.
Sylvia 1'aBudde-
Environmental Coordinator
Smithfield Packing Co., Tar Heel Division
15855 Highway 87 West
Tar Heel, NC 28392
Work [phone] x 605
Fax [phone]
[e-mail]
This communication (including any attachments) is confidential and is intended to he privileged pursuant to applicable law.
If you are not the intended recipient, or the employee or agent responsible for deiivering it to the intended recipient.1hen
you are hereby notified that the dissemination, distribution or copying of this communication is prohibited. If you received
this communication in error, please notify Smithfield Foods, Inc, immediately by telephone [phone]b0) and then delete
this communication and destroy all copies thereof.

Smi4h!flield.
CERTIFIED MAIL # 7000 1530 0001 2610 0969
January 21, 2011
NCDENR DWQ
225 Green Street, Suite 714
Fayetteville, NC 28301
To: Belinda Henson
Cc: Mike Lawyer
RE: Smithfield Packing Company, Tar Heel Division
NPDES Stormwater Permit # NCG060126
Request to Conduct a Chlorine Dioxide Application Study
Dear Ms. Henson,
P0Box 99
Tar Heel, NC 28392
[phone] ext 605 te1
[phone] fax
JAN 2 y 2011
n�TJQ
Per your request, Tar Heel facility has made arrangements with a certified laboratory to conduct acute
toxicity testing of stormwater discharged from Outfall # 002. Since vast majority of chlorine dioxide
application sites drain into Outfall # 002, we request that all testing related to this study solely focus on
this location. Upon approval of the proposed study, Smithfield Packing Company, Inc. — Tar Heel
Division will:
• Continue testing chloride levels in Outfall #002. Please refer to the table below for a summary
of past chloride readings taken during representative storm events.
Date
Outfall # 001
(mg/L)
Outfall # 002
(mg/L)
9/26/2010
< 5
107
9/27/2010
< 5
8
9/29/2010
< 5
18
11/4/2010
No Flow
84
Averages
< 5
54
Conduct acute toxicity testing of stormwater samples from Outfall # 002,
Submit all of the required reports to your office to demonstrate compliance.
Please contact me if you have additional questions or concerns.
Sylwia LaBudde
Environmental C inator
Smithfield Packing Company, Tar Heel Division
[phone] ext.605
[e-mail]

jA
M.: e
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
November 10, 2010
Smithfield Packing Company, Tar Heel Division
Attn: Sylwia LaBudde, Environmental Coordinator
PO Box 99
'Far Heel, NC 28392
Subject: Chlorine Dioxide Application Study
Smithfield -Tar Heel Facility -NCG060126
131aden County
Dear Ms. LaBudde:
Dee Freeman
Secretary
Staff with the Fayetteville Regional Office as well as the Stormwater Permitting Unit of the Division of
Water Quality has reviewed your letter dated September 10, 2010 in response to our comments and concerns
regarding the Request to Conduct a Chlorine Dioxide Application Study at the Smithfield -Tar Heel facility
located in Bladen County. While the majority of our concerns and suggestions have been addressed, the issue of
conducting toxicity testing is unresolved. Due to the unknown nature of residual effects of the chlorine dioxide
solution as well as the potential for toxic effects on fish and other aquatic life, we cannot approve your request
without the ability to conduct toxicity testing in addition to chloride and the other parameters as listed in the
NCG060600 general permit. We understand your position that a laboratory may need advance notice of an
incoming sample so that they can be prepared to run the test, however it is not clear in your letter how many
laboratories with which you have communicated. We encourage you to contact other tabs in the state that may
be able to offer their services with varying degrees of notification. Staff in the regional office or with the
Stormwater Permitting Unit can assist you in obtaining contact information for other labs if needed.
BSH: ML/ml
cc: FRO -Surface Water Protection
Stormwater Permitting Unit
Location: 225 Green Street, Suite 714, Fayetteville, North Carolina 28301
Phone: [phone] FAX 910A86-07071 Customer Service: 1-877-623-6748
Hemet: www.ncwaterguality.org
4 Equal Opportunity', Af rniative 40on Employer
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
North Carolina
Naturally

Smithfield.
CERTIFIED MAIL # 7000 1530 0001 2610 0792
4 7000 1530 00012610 0808
September 10, 2010
NCDENR DWQ
225 Green Street, Suite 714
Fayetteville, NC 28301
To: Belinda Henson
Cc: Mike Lawyer
RE: Smithfield Packing Company, Tar Heel Division
NPDES Stormwater Permit # NCGO60126
Request to Conduct a Chlorine Dioxide Application Study
Dear Ms.Henson:
1'UBux99
Tau I Icel. NC 28392
(910) 8622-7675 cxt 605 tO
[phone] rux
®ENR-FRO
SEP 13 2010
I7WO
This letters contains responses to a letter from your office dated August 27, 2010 in
regards to the proposed Chlorine Dioxide Application Study.
To addresses your concerns about responsible personnel, proper application procedures
and spill/release, we devised Maintenance SOP#5 — Chlorine Dioxide (C102) Application, which
is attached to this letter.
In regards to additional monitoring, the Tar Heel Wastewater Lab is not certified to
perform chloride and toxicity testing; therefore all samples will have to be sent to an offsite
contract lab. Chloride samples can be stored for up to 28 days, while toxicity samples have less
than a 36-hour hold time. Additionally, the lab requires advance notification for all toxicity
sampling. Due to unpredictability of discharge events, we are not able to provide the lab with
the proper notice; therefore we request for chloride to be the preferred parameter being
measured. Effective immediately, we will begin analyzing stormwater runoff from both outfalls
for chloride in order to establish a baseline levels prior to chlorine dioxide application. Once
sufficient number of samples is collected to make a determination of pre -study chloride levels,
they will be reported to your office for further review.

Lastly, since both your office and research agrees that chlorine residual is not an
appropriate parameter to measure chlorine dioxide residual effects, unless otherwise
instructed by your office, we will discontinue such measurements.
Thank you for taking the time to review our proposal. I look forward to your response.
Please contact me if you have additional questions or concerns.
Sylwia LaBudde
Environme Coordinator
Smithfield Packing Company, Tar Heel Division
[phone] ext.605
[e-mail]

ti
rJmitkLDocument Originator:
iela .
5ylwia LaBudde
Tar Heel N.C.
Maintenance SOP # 5
Chlorine Dioxide (C102) Application
1. Purpose:
To insure that chlorine dioxide (C102) solution application is performed by trained, authorized
personnel and in accordance with all legal requirements.
Scope:
Personnel involved in tasks associated with chlorine dioxide solution application.
3. Procedure / Requirements:
Only Authorized Personnel will be allowed to mix and apply chlorine dioxide solution onto
facility roads. Table below lists Authorized Personnel in the Tar Heel Facility:
Ronnie Burns
Jimmy Thompson
Wayne Haddock
Application will be made using an industrial sweeper equipped with a spray bar capable of
discharging the chlorine dioxide solution at a rate of 3.6 eallons. per minute.
Application cannot be made during or immediately proceeding rain. Prior to application,
Authorized Personnel will review local weather forecast, as well as record atmospheric
conditions in the Chlorine Dioxide Application Log. Under ideal operational and weather
conditions, approximately 3-5 applications shall take place each week.
• Treatment will take place on the road leading from the 4;oWfet
OLLEP
offloading areas in Livestock. Particular attention shall rt
visible residue and/or debris. Chlorine Dioxide Solution Preparation: COPY
• Any person involved in chlorine dioxide solution preparation shall wear proper PPE
(Personal Protective Equipment) that at a minimum shall include chemical resistant
gloves, eyewear protection, long sleeve shirt and pants.
• Chlorine dioxide will be obtained from a discharge point behind Rendering, next to the Room
Air Scrubber; access point remains locked at all times (see picture below). Keys to the
discharge valve are located in the Environmental Office, as well as inside the sweeper truck
cabin.
DENR-FRO
SEP 13 2010
DWQ
Origination Date: 09/09/10 latest revision date: 09/09/10
Revision # Original Page I of 2

Document Originator:
.�mzt�fi�ld sylwia LaBudde
Tar Heel N.C.
Maintenance SOP # 5
Chlorine Dioxide (C102) Application
In order to obtain a 10 Ppm solution, extract "- 8mL of C102 and add to -200 gallons of
potable water (the capacity of a tank on the industrial sweeper- see attached STARFIRE S-4
document). To aid in CI02 retrieval a 5-gallon bucket and a measuring container will be
located in the sweeper truck cabin. Any remaining C102 solution shall be immediately
discarded into a pretreatment drain.
Spill/Release Response
In the event of a spill/release involving chlorine dioxide, persons not wearing protective equipment and
clothing should be restricted from contaminated areas until cleanup has been completed. The following steps
should be undertaken following a spill or release:
• Do not touch the spilled material; stop the leak if it is possible to do so without risk; avoid inhalation.
• Immediately notify the Environmental Coordinator at (9101 874-5638:
• Remove all sources of heat and ignition.
Allow agent to evaporate while providing all available ventilation. Personnel may also use a large
amount of a concentrated solution of reducing agent (bisulfites or soda ash to dilute the chlorine
dioxide. After the spill has been neutralized, shovel slurry into a suitable container.
4. Responsibilities:
Buildings & Grounds Maintenance Manager and authorized personnel listed in this SOP.
5. Training:
As needed, but at least annually Buildings & Grounds Maintenance Manager and authorized
personnel listed in this SOP.
6. Location(s):
The controlled hard copy of this SOP and training records will be located in the Environmental
Office and in Buildings & Grounds Maintenance Manager's office. Refer to master list of
postings (EMS SOP #1-C) for additional locations.
7. Consequences of Deviation from Procedure:
Failure to follow above procedures may result in Notices of Violations (NOV's) and penalties. It
may also result in disciplinary action for personnel not following proper procedure.
• "..."° CONTROLLED
COPY
(Y
Environm I Coordinator DENR-FRO Plant Engineer
SEP 13 2010
Origination Date: 09/09/10 Latesi revision date: 09/09110
Revision N Original D, n fO Page 2 of 2

Chlorine Dioxide (C102) Application Log — Tar Heel
Completed forms should be returned to the Environmental Office
DATE
TIME
WEATHER CONDITIONS
(e.g. 85F, partly cloudy, no rain forecasted)
COMMENTS
OPERATOR NAME
(Print)
OPERATOR
SIGNATURE
Revision Date: 09-09-10

Smitheld.
CERTIFIED MAIL # 7000 1530 0001 2610 0792
# 70001530 00012610 0808
September 10, 2010
NCDENR DWQ
225 Green Street, Suite 714
Fayetteville, NC 28301
To: Belinda Henson
Cc: ° Mike_Lawyer'�
RE: Smithfield Packing Company, Tar Heel Division
NPDES Stormwater Permit # NCG060126
P0Box 99
Tar Heel, SIC 28392
[phone] ext 605 tel
[phone] I'ax
DENR--FRO
Request to Conduct a Chlorine Dioxide Application Study
Dear Ms.Henson:
SEP 13 2010
DWO
This letters contains responses to a letter from your office dated August 27, 2010 in
regards to the proposed Chlorine Dioxide Application Study.
To addresses your concerns about responsible personnel, proper application procedures
and spill/release, we devised Maintenance SOP#5 — Chlorine Dioxide (C102) Application, which
is attached to this letter.
In regards to additional monitoring, the Tar Heel Wastewater Lab is not certified to
perform chloride and toxicity testing; therefore all samples will have to be sent to an offsite
contract lab. Chloride samples can be stored for up to 28 days, while toxicity samples have less
than a 36-hour hold time. Additionally, the lab requires advance notification for all toxicity
sampling. Due to unpredictability of discharge events, we are not able to provide the lab with
the proper notice; therefore we request for chloride to be the preferred parameter being
measured. Effective immediately, we will begin analyzing stormwater runoff from both outfalls
for chloride in order to establish a baseline levels prior to chlorine dioxide application. Once
sufficient number of samples is collected to make a determination of pre -study chloride levels,
they will be reported to your office for further review.

Lastly, since both your office and research agrees that chlorine residual is not an
appropriate parameter to measure chlorine dioxide residual effects, unless otherwise
instructed by your office, we will discontinue such measurements.
Thank you for taking the time to review our proposal. I look forward to your response.
Please contact me if you have additional questions or concerns.
Sylwia LaBudde
Environme Coordinator
Smithfield Packing Company, Tar Heel Division
[phone] ext.605
[e-mail]

Document Originator:
s><1Li Iifueldi Sylwia LaBudde
Tar Heel N.C.
Maintenance SOP # 5
Chlorine Dioxide (C102) Application
1. Purpose:
To insure that chlorine dioxide (CI02) solution application is performed by trained, authorized
personnel and in accordance with all legal requirements.
2. Scope:
Personnel involved in tasks associated with chlorine dioxide solution application.
3. Procedure / Requirements: ,
• Only Authorized Personnel will be allowed to mix and apply chlorine dioxide solution onto
facility roads. Table below lists Authorized Personnel in the Tar Heel Facility:
Ronnie Burns
Jimmy Thompson
Wayne Haddock
Application will be made using an industrial sweeper equipped with a spray bar capable of
discharging the chlorine dioxide solution at a rate of 3.6 gallons per minute.
• Application cannot be made during or immediately proceeding rain. Prior to application,
Authorized Personnel will review local weather forecast, as well as record atmospheric
conditions in the Chlorine Dioxide Application Log. Under ideal operational and weather
conditions, approximately 3-5 applications shall take place each week.
• Treatment will take place on the road leading from the front security gates to the
offloading areas in Livestock. Particular attention shall be paid to o a i
visible residue and/or debris. CONTRULLED
Chlorine Dioxide Solution Preparation: � PY
• Any person involved in chlorine dioxide solution preparation shall wear prop
(Personal Protective Equipment) that at a minimum shall include chemical resistant
gloves, eyewear protection, long sleeve shirt and pants.
Chlorine dioxide will be obtained from a discharge point behind Rendering, next to the Room
Air Scrubber; access point remains locked at all times (see picture below). Keys to the
discharge valve are located in the Environmental Office, as well as inside the sweeper truck
cabin.
®ENR-FRO
SEP 13 2010
DWO
Origination Date: 09/09/t0
Revision 9 Original
Latest revision date: 09/09/10
Page I of 2

Document Originator:
Smitiafield
Tar Heel N.C. I
5ylwia LaBudde
Maintenance SOP # 5
Chlorine Dioxide (C102) Application
In order to obtain a 10 ppm solution, extract — 8mL of C102 and add to —200 gallons of
potable water (the capacity of a tank on the industrial sweeper- see attached STARFIRE 5-4
document). To aid in C102 retrieval a 5-gallon bucket and a measuring container will be
located in the sweeper truck cabin. Any remaining CI02 solution shall be immediately
discarded into a pretreatment drain.
Spill/Release Response
In the event of a spill/release involving chlorine dioxide, persons not wearing protective equipment and
clothing should be restricted from contaminated areas until cleanup has been completed. The following steps
should be undertaken following a spill or release:
Do not touch the spilled material; stop the leak if it is possible to do so without risk; avoid inhalation.
• Immediately notify the Environmental Coordinator at (9101,874-5638.
Remove all sources of heat and ignition.
• Allow agent to evaporate while providing all available ventilation. Personnel may also use a large
amount of a concentrated solution of reducing agent (bisulfites or soda ash to dilute the chlorine
dioxide. After the spill has been neutralized, shovel slurry into a suitable container.
4. Responsibilities:
Buildings & Grounds Maintenance Manager and authorized personnel listed in this SOP.
S. Training:
As needed, but at least annually Buildings & Grounds Maintenance Manager and authorized
personnel listed in this SOP.
6. Location(s):
The controlled hard copy of this SOP and training records will be located in the Environmental
Office and in Buildings & Grounds Maintenance Manager's office. Refer to master list of
postings (EMS SOP it1-C) for additional locations.
7. Consequences of Deviation from Procedure:
Failure to follow above procedures may result in Notices of Violations (NOV's) and penalties. it
may also result in disciplinary action for personnel not following proper, procedure.
8. Approvals: CONTROLLED
COPY
Environm 1 Coordinator DEN R-FRO Plant Engineer
Origination Datc: WWI
RcviMan N Original
SEP 13 2010
l.nt�st revision Date: 09109/l0
DWO
!'age 2 of 2

Chlorine Dioxide (CIOZ) Application Log — Tar Heel
Completed forms should be returned to the Environmental Office
DATE
TIME
WEATHER CONDITIONS
(e.g. 85F, partly cloudy, no rain forecasted)
COMMENTS
OPERATOR NAME
(Print)
OPERATOR
SIGNATURE
Revision Date: 09-09-10

YIF
1 ....�
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
August 27, 2010
Smithfield Packing Company, Tar Heel Division
Attn: Sylwia LaBudde. Environmental Coordinator
PO Box 99
Tar Heel, NC 28392
Subject: Chlorine Dioxide Application Study
Smithfield -Tar Heel Facility-NCG060126
Bladen County
Dear Ms. LaBudde:
Dee Freeman
Secretary
The Division of Water Quality is in receipt of your letter regarding Request to Conduct a Chlorine
Dioxide Application Study at the Smithfield -Tar I -feel facility located in Bladen County. Staff with the
Fayetteville Regional Office as well as the Stormwater Permitting Unit in Raleigh have reviewed your proposal
and offer the following comments and concerns.
We recognize the purpose of the study would be to address the concern of the amount of fecal coliform
present in stormwater runoff from the facility, which based on recent monitoring events, has exceeded the
Benchmark Value contained in the current NCG060000 general stormwater permit. While this is certainly a
valid concern and should be addressed accordingly, our lack of knowledge and experience with the use of a
chlorine dioxide solution for this purpose raises other concerns with residual pollutants/by-products after
breakdown, possible toxicity to receiving waters, and overall effectiveness. We suggest including monitoring
parameters such as chlorides and/or effluent toxicity testing in addition to the current parameters in the general
permit including fecal coliform, the parameter of concern.
The study proposes application "...periodically throughout the week during non -rainy days..." and
discusses adjusting "...the frequency of application as needed." This approach is certainly appropriate and
reasonable, however there is no detail as to how these procedures would be carried out or properly enforced.
Please provide a more comprehensive SOP and list the responsible personnel as well as necessary actions to be
taken in the event of a spill/release or observations of impacts to the receiving waters. Additionally, we
recommend that the study be conducted throughout a twelve month period to accommodate for any necessary
adjustments as well as seasonal fluctuations.
Lastly, according to the study proposal, monitoring of residual chlorine has already begun to establish
baseline figures, which was measured at levels between 17-50pg/L of free chlorine. Based on the nature of the
chlorine dioxide solution as purported in the attached research, analysis for residual chlorine may not be an
Location: 225 Green Street, Suite 714, Fayetteville, North Carofna 28301
Phone: 91OA33-33001 FAX: [phone] Customer service: 1-877-623-6748
Internet: www.ncwateravalitv.ora
An Equal Opportunily 1 Affirmative Action Employer
NorthCarolina
Naturally

appropriate test as opposed to chlorides, chlorites, or other chlorine salts. Also, the study implies reporting any
values less than 50pgIL as zero. We would not concur with this request and ask that all values be reported as the
value determined during analysis. Any background or baseline figures would be used in comparison With data
obtained during the study for purposes of determining any residuals/effects of the chlorine dioxide solution.
Division staff that has reviewed the proposal feels as though the study is worthwhile and along with you
and your staff look forward to positive results with no negative impacts to water quality. However, prior to
further review and approval of this request, you are asked to respond to the Fayetteville Regional Oft -ice in
addressing the aforementioned concerns.
Sincerely,
I Q�
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSI+ MLlml
cc: FRO -Surface Water Protection
Stonn,vater Permitting Unit

Lawyer, Mike
From: Pickle, Ken
Sent: Friday, July 09, 2010 3:20 PM
To: Lawyer, Mike
Cc: Georgoulias, Bethany; Larsen, Cory; Jones, Jennifer
Subject: RE: Smithfield and chlorine dioxide
Mike,
1) Well, Smithfield asks for our permission to conduct a pilot study. I'm not sure what their permit status or
circumstance is, but why would they ask our permission? They can run a pilot program anytime they want,
right? Is this in response to an NOV? Are they proposing this in lieu of a required Tiered response? ......... Or
more likely, are they just trying to be cooperative and inclusive with us as they try to address a discharge
problem? You know, we have set up the Tiered system so that on the occasion of 1, 2, or 3 exceedences, the
permittee can attempt to address his issues without DWQ involvement. It's only upon the 41h exceedence that
he's obligated to get us involved. A few folks have called us earlier, and that's ok -- that's better. if this is where
we are with Smithfield, great and fine.
Maybe the next step for us is to contact Smithfield and find out specifically what they think they are asking of us,
if anything, wrt their obligations under NCG06.
2) Again if they want our involvement in the process earlier than usual, that's fine.
3) . Other items we may want to cover with them eventually include:
a. They observe that they think "fecal conform on asphalt is a contributor" to their monitoring
exceedences. But, apparently not 100%? May want to clarify the site specifics on the point of other
potential source areas.
b. I'm a little concerned that, "It remains a true gas in solution" might be taken to imply that there will not
be any residual chlorine salts left on the asphalt: Note later in the letter, Smithfield references, "the
instability of the molecule in the presence of sun light." So, this material is a gas in solution, but when it
dries out in the sunlight it breaks down into other chlorine species that are not gas(?), and so remain on
the asphalt as salts? 1 don't know the chemistry, of course, but it looks like we should not assume that
there will be no chlorine species deposits on the asphalt. I suspect there will be, and given the high
solubility of most chlorine species, I suspect they will be ready to be washed off in the next rainfall
event.
c. Note Cory's reference of 2 mg/L for zebra mussel control in the Great Lakes, and the apparent contrary
indication in Smithfield's letter citing safe levels of about 10 ppm for fish. Fish are not zebras, i know
(Well most fish aren't zebras, except of course for zebra fish). Need clarification on this point.
d. Smithfield proposes to use a C1O2 solution from their odor control system. What other constituents
might be present in this proposed on -site source of chlorine dioxide? Would this solution otherwise be
a waste material?
They propose to spray the material during non -rainy days. Of course, the stormwater sampling will be
specifically during rainy days - - - - - so, hog scat deposited during a rainy day is not disinfected, and is
immediately accessible to the runoff flow. Now does this work out?
Smithfield offers the reassurance that, "According to most research, we do not anticipate an increase in
chlorine residual in our stormwater runoff." OK, no dissolved gaseous chlorine; but as Cory points out,
what about other chlorine species?
Selective reporting of the instrument readout so that some low readings are reported as zero? NO. Just
report the numbers, and then explain them away later, if justified. DWQ should not agree to this sort of
manipulation of the raw data up front. Nor should we upfront agree to consider the results as zero,
until/unless a supporting rationale is acceptable to us.

h. Again, they offer the reassurance that, "We will monitor chlorine residual in all stormwater samples to
ensure that no additional chlorine is present during the course of the study." But what about other
chlorine species? Mike, as you say, we don't want to swap one pollutant for another,
L As Jennifer commented on, if this is a successful pilot, how do we modify their permit coverage? Keep
them in NCG06? Switch them to a new NCSxxxxx? Maybe we wait until the pilot reaches some
endpoint to decide, but clearly that should figure into our thinking as they go forward.
4) Mike, I know this all sounds like I'm against the proposal, but I'm not. I think this is a worthwhile pilot. I just
want to be sure that their expectations don't exceed what can be supported by the proposed pilot results.
From: Lawyer, Mike
Sent: Friday, July 09, 2010 1:14 PM
To: Pickle, Ken
Cc: Georgoulias, Bethany; Larsen, Cory; Jones, Jennifer
Subject: RE: Smithfield and chlorine dioxide
Ken,
Thanks for speaking with Cindy and getting her input. I do not know if they have considered other structural measures. I
wasn't aware of such systems as a possibility for addressing fecal, so I certainly haven't suggested it to them. Maybe I
should? I agree that its going to take some major effort on their part and not just spraying stuff around to see what
happens and hope for the best. I think Smithfield is willing to do such.
What might be the next steps from our end?
-send Smithfield a letter/e-mail with comments about our review, concerns, and possible additions to the study?
-would this come from us in the region or from SPU?
-if the pilot study seems to work, do we include language in their COC during the next permit renewal, require them to
get an Individual Permit where we can put language in permit text?
Again, thanks to all of you for your review and comments! Its been very helpful and much appreciated.
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: mike.law er ncdenr. ov (please note my current e-mail address)
*E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Pickle, Ken
Sent: Friday, July 09, 2010 12:59 PM
To: Lawyer, Mike
Cc: Georgoulias, Bethany; Larsen, Cory; Jones, Jennifer
Subject: RE: Smithfield and chlorine dioxide

Mike,
spoke to Cindy Moore in aquatic tox on Wednesday.
She didn't have any first hand experience on the specific solution of C1O2. She generally voiced the same concerns that
others have had:
a) Suggested that extended contact time, analogous to a wastewater CCC, might be required;
b) wondered if some means to dechlorinate would be appropriate downslope;
c) and suggested some tox testing of the effluent;
d) observed that the necessary killing contact might be hindered to some degree by solids inclusion of the fecoli.
e) Suggested they could review an MSDS to see what if anything additional might be learned from it.
Mike, looking at all the comments from others here, I still think this is a worthwhile pilot. But, the difficulties that
several of us have listed means, I think, that Smithfield will have to make this a 'project' to make it work. I don't think
this will succeed if they approach this with a low-level effort, and make just one or two attempts to get it right.
Do you know if they considered installing an ozone generator and bubbler? — I believe all it takes is a holding vessel or
pond, and electrical power. I don't really know about initial costs of such equipment.
Ken
From: Pickle, Ken
Sent: Wednesday, July 07, 2010 1:32 PM
To: Jones, Jennifer; Georgoulias, Bethany
Subject: FW: Smithfield and chlorine dioxide
FYI, my earlier note to Cindy Moore.
kbp
From: Pickle, Ken
Sent: Wednesday, July 07, 2010 11:51 AM
To: Moore, Cindy
Cc: Bennett, Bradley; Lawyer, Mike
Subject: Smithfield and chlorine dioxide
Hi Cindy,
I've left you a voice message generally on this question, but I'm following up with more specifics here. I'm not really
sure if you all are the ones to respond to my request. If so, great! If not, can you point me in the right direction?
I work for the Stormwater Permitting Unit in the SWPS. We have a stormwater permittee (Smithfield) in the Fayetteville
Region with recurring fecal coliform exceedances in their stormwater runoff. In order to address the fecal exceedances,
Smithfield is proposing a trial or pilot program featuring the application of a 10 ppm chlorine dioxide solution by running
a sprayer truck over the paved (asphalt) truck staging area where hog trucks wait to be unloaded.
It seems to me there are lots of logistics about the application, timing, area coverage, solution strength, etc. that this
pilot program will have to sort out. But I think a prior question has to do with our posture on using a C1O2 solution for
this purpose, with the understanding that runoff from this asphalt paved area will run about 200 yards through a
vegetated area and vegetated ditch before reaching a receiving water.
How should we view this proposal from an aquatic tox perspective? Any related past experience that might add to our
understanding here? Are you the person I should direct these questions to? Would you recommend some other testing
in addition to the obvious fecal testing that we are primarily concerned about?

Thanks for any reply, see my phone number below if we need to that voice to voice; or, I'll be glad to call you again —
just let me know when you would be available.
Ken Pickle
DWQStormwater Permitting Unit
807-6376
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.

Smithfield.
P O Box 99
Tar Heel, NC 28392
[phone] ext 605 tel
[phone] fax
CERTIFIED MAIL # 7000 1530 0001 2610 1669
June 28, 2010
NCDENR DWQ DENR-FRO
225 Green Street, Suite 714 JUN 2 9 2010
Fayetteville, NC 28301 To: Mike Lawyer D Y Yyp,
Q
RE: Smithfield Packing Company, Tar Heel Division
NPDES Stormwater Permit # NCG060126
Request to Conduct a Chlorine Dioxide Application Study
Mike,
During your recent visit on 2 June 2010, we spoke about conducting a pilot study to
control fecal coliform levels in our stormwater. The Tar Heel facility is looking at methods to
control fecal coliform on asphalt, which we consider to be a contributor to elevated fecal counts
in our stormwater. Over several months we explored various alternatives through extensive
research. It is our belief that using chlorine dioxide solution to control fecal coliform on asphalt
is the safest and most effective method available (see attachment — Overview of Chlorine Dioxide
(C102)). The Tar Heel Facility is requesting permission to conduct a pilot study to evaluate
effectiveness of the above stated method.
Chlorine dioxide solution can be applied to asphalt at very low dosages and still
be vastly effective. According to the article Overview of Chlorine Dioxide (C102), chlorine
dioxide unlike chlorine or hypochlorite, does not form chlorinated hydrocarbons when it comes
in contact with organic matter. It remains a true gas in solutions without hydrolyzing to form
hydrochloric acid (HCI), and can treat water at about 10 ppm with no harmful effects to fish.
Another reason for using chlorine dioxide is the instability of the molecule in the presence of sun
light. The Practical Chlorine Dioxide Volume 1 by Greg D Simpson, PhD states that, "more
recently, others [Wang 1998] determined that chlorite solutions degraded rapidly (half-life —
hours) under laboratory fluorescent lighting and even more rapidly in direct sunlight
(half-life minutes).
Currently we are generating 98 % chlorine dioxide solution for our odor control system.
In order to obtain a 10 ppm solution, we will extract — 8mL of C102 and dilute it to —200 gallons
with water (the capacity of a tank on the industrial sweeper- see attached STARFIRE S-4
document). The solution will be applied periodically throughout the week during non -rainy days

to ensure reasonable chlorine dioxide degradation, while achieving maximum effectiveness.
Based on results, we will adjust the frequency of application as needed. The spray bar on the
industrial sweeper will apply the chlorine dioxide solution at a rate of 3.6 gallons per minute.
Once the solution is applied, it will not be rinsed, but rather be allowed to evaporate. Initial tests
using potable water in the street sweeper sprayer system, conducted on a sunny 85 F day,
resulted in full evaporation in approximately 15-20 minutes.
According to most research, we do not anticipate an increase in chlorine residual in our
stormwater runoff. We began monitoring chlorine residual in both outfalls in order to establish
baseline figures. Using HACH Method 8021, the average Free Chlorine level was between 17-
50 ug/L. These chlorine readings in the absence of chlorine are deceiving and can be attributed
to sensitivity of the portable meter and the presence of suspended solids. For the purpose of this
study we would like to implement a correction factor for any number less than 50 ug/L to be
considered equal to zero. We will monitor chlorine residual in all stormwater samples to ensure
that no additional chlorine is present during the course of the study.
If you have any questions or would like to discuss this further, please do not hesitate to
call me at 910-874-5638.
Sylwia LaBudde
Environmental Coordinator
Smithfield Packing Company, Tar Heel Division
[phone] ext.605
[e-mail]

DENR-FRO
J IRT., 77
�'Arrange ior. a dehtonsfruiion toda
'Y!
STARFIRE S
From chip seal and milling operations to heavy
spring clean-up, the Rewart-Amos Sweeper
Co.'s Starfire S-4 can handle it.
k L
The S-4 is a four wheel, dual engine, mechanical broom street sweeper that has
a compact design, but is as productive as sweepers mounted on larger trucks.
Manufactured with reliability and simplicity in mind, the S-4 is built for day -in and
rt
day -out continuous duty sweeping. The short wheelbase chassis combines tight
00 a.
maneuverability like a 3-wheel sweeper, yet is still capable of traveling at highway
speeds between job -sites.
The benefits of the Starfire S-4 include:
* 4.5 Cubic Yard Hopper - Extremely Fuel Efficient
'J,
* High Performance Sweeping a Ease of Maintenance
IL
* Large Volume Dust Suppression a Simplicity of Design
* Variable Height Dumping * Remarkably Quiet
* Highly Maneuverable 0 Safety Monitoring Camera System
9 Great Mobility a PM-10 Certified
• Rugged Construction • Proudly made in the U.S.A.
GOD &9 A&SM19 OKMA110D
Sweeper Co.
Harrisburg, PA 1 800.482.2302 1 stewart-amos.com

13
General:
Sweeping Path: 10' maximum
Debris Hopper 4.5 cubic yards volumetric
Dump Height tvariablej: 16' to 122'
Turning Radius`: 16'9'
Overall Length*: 19'6"
Overall Height*: 102.5" including Strobe Lights
GVW R `: 19,500#
'Based upon sweeper unit and
GMC W-5500-HD series cob -over chassis
Main Broom:
Length: 58" Diameter: 36'
Type: Chevron
Drive: Hydraulic motor/direct drive and reversible
Mounting: Full floating, trailing arm, with shocks
Lift Control: Hydraulic, in -cab
Speed: Variable with aux. engine rpm
Dirt Shoes: Carbide, 2" wide
Gutter Brooms:
Diameter: 42'
Type: Disposable 4 segment with wire fill
Drive: Hydraulic and reversible
Mounting: Free4loating, trailing arm
Lift Control: Hydraulic, in -cab
Speed: Variable with aux. engine rpm
Conveyor/Elevator:
Type: 7-flight squeegee with replaceable rubber edging
Liner: Bolkn, 2 piece AR steel plates
Chain: HD constant radius roller chain
Sprockets: Urethane
Shafts: Three
Drive: Hydraulic, in -cob, and reversible
Lift Control: hydraulic, in -cab
Elevator Jam Warning: Buzzer and light in -cab
Flushing System: Built-in
Debris Hopper*
Volumetric Ca city: 4.0 cubic yards
Dump Height variable): 16" to 122"
Hopper Door Reach from Side: 44"
Inspection door, window, and safety props
MUM
Sweeper Co.
Hydraulic System:
Pump: Dual tandem gear
Capacity: 20 GPM @ 2000 rpm
Reservoir: 45 gallons
Hydraulic Oil Filter: 10 micron
Water Spray System:
Tank Capacity: 200 gallons
Construction: Polyethylene
Mounting: Removable
Pump: 3.6 GPM electric diaphragm
Spray Nozzles:
• 4 on front spray bar
• 2 on each gutter broom
• 4 on main broom
Fill Hose: 20' with NST coupler with antimsiphon air gap
Water Pump Prefilter: 80 mesh
Electrical Syystem:
Alternator: 120 AMP Voltage: 12 volt
Lights: front and rear strobes; gutter brooms
and rear mounted working lights; license plate;
2 stop/turn/tail; and clearance lights
Backup alarm
Camera and Monitor Safety System:
7" Color monitor with right side gutter
broom and rear mounted color cameras
Instrumentation and Controls:
Sweeper function rocker swilches
Elevator stall alarm and light
Auxiliary engine hour meter and tachometer
Electric throttle
Console night light
Sweeper Engine:
Make: Kubota V24034v4T-E3
Tier 3 Compliant
Horsepower: 47.9 continuous @ 2700 rpm
Type: in -line, four -cylinder turbo diesel
Paint:
Body: Standard white- high -gloss urethane enamel
Undercarriage: Flat black enamel
Harrisburg, PA, USA
800.482.2302
stewart-amos.com
Please Note:
Specifications are subject
to change without notice
Copyright © 4/ 10
Standard Accessories:
Auto pickup in reverse
Auto shutdown for high temperature/low pressure
Independent left and right gutter broom operation
30 gallon, common fuel tank
Operators, parts and maintenance manuals
Warranty Policy:
The Starfire 5-4 sweeper is guaranteed to be
free from defects due to faulty materials and/or
workmanship for a period o 12 months, or 1,000
hours (whichever occurs first). Liability is limited to
replacement of defect parts at factory or authorized
dealer. The standard warranty of the chassis
manufacturer and auxiliary engine applies.
Available Options: (not inducted in base price)
Arrow Board
LED light package in lieu of standard
Strobe/Beacon protector
Gutter broom tilt; in -cob (electric)
Front mounted magnet
100 gallon auxiliary water tank
Dual 3.6 GPM Water pumps for 7.2 GPM
Epo�ry Hopper liner
Stainless steel hopper
Extended warranties
Body paint colors
Others upon request
Wide variety of available chassis—
* *Consult your deafer far details
The Starfire S-4 has built a reputation
for rugged reliability and superior
sweeping performance. Let us build
one for you. Call your dealer today to
arrange for a demonstration.
Sold and Supported Locally by:

lO
DENR-FRO
Overview of Chlorine Dioxide (CIO2) JUN z 9 2010
The compound chlorine dioxide (CIO 2), now commercially important, is not in fact a recQWQ
discovery. The gas was first produced by Humphrey Davy in 1811 when reacting hydrochloric
acid with potassium chlorate. This'yielded "euchlorine", as it was then termed. Watt and
Burgess, whd invented alkaline pulp bleaching in 1834, mentioned euchlorine as a bleaching
agent in their first patent. Chlorine dioxide then became well known as a bleach and later a
disinfectant. Since the beginning of the twentieth century, when it was first used at a Spa in
Ostend, Belgium, C102 has been known as a powerful disinfectant of water. The production of
CI02 from the chlorate is complicated however, and the gas is explosive, so that it could not be
easily utilized practically until the production of sodium chlorite by Olin Corporation in 1940.
Chlorine dioxide could now be released when necessary from the chlorite salt. In municipal
water supplies this is usually done by adding chlorine to the chlorite solution, and in the
laboratory by adding an acid to the chlorite solution. Alliger showed in 1978, ' 2 that C102 could
be applied topically by the individual user.
Although CIOZ is a strong oxidizing agent and a particularly fast disinfectant, there are no reports
in the scientific literature of toxicity by skin contact or ingestion, or moreover of mutagenicity. It
would seem that effective application of this compound as a topical medication for skin
diseases,3'4 as a disinfectant on food, as well as a cold sterilant on instruments and glassware, is
long overdue.
CIO in some respects is chemically similar to chlorine or hypochlorite, the familiar household
bleach. However, C102 reactions with other organic molecules are relatively limited as
compared to chlorine. When C102 is added to a system — whether a wound or a water supply —
more of the biocide is available for disinfection and not consumed by other materials."' Until
1963 hypochlorite was a standard product of the British Pharmacopoeia (for skin medications),
and burn patients even now are bathed in hypochlorite solution at some U.S. burn centers.
However, for many reasons CIO., makes a likely substitute for the better known hypochlorite
since it is far less toxic and irritating when applied to the human body. C102 for example, does
not hydrolyze to form HCl as does chlorine, but remains a true gas dissolved in solution. C102,
unlike chlorine or hypochlorite, does not form chlorinated hydrocarbons when in contact with
organic matter, or readily add to double bonds. This is a prime concern since many chlorinated
hydrocarbons are known to be carcinogenic. Of the amino acids, the building blocks of proteins,
only aromatic amino acids and those containing sulfur react with CIO2. When hypochlorite is
applied to the skin, nitrogen trichloride is formed, a compound which appears in trace quantities
but is toxic and irritating. Also, hypochlorite in swimming pool water produces chloramine, an
eye irritant, and in wastewater, chloroform. Lastly, unlike hypochlorite or chlorine, CIO can
treat water at about 10 ppm with no harmful effects to fish. The LC50 for rainbow trout at 96
hours is 290 ppm.7 For this reason C102, rather than chlorine, is favored in commercial aquarium
water, especially in mammal tanks.8
Residuals of available chlorine in effluents from sewage treatment plants, including the
hypochlorite ion and chloramines, adversely influence aquatic life in receiving waters ---

the potential adverse effects both on the public health and on aquatic ecosystems due to
increased exposure to chlorinated compounds suggests that the use of chlorine relative to
other available techniques for the treatment of sewage and other waste -waters must be
reevaluated.9
At the time of World War 1, when Dakins Solution (0.5% hypochlorite) gained fairly wide
acceptance as a wound disinfectant, CIO, was not similarly adopted as there was, again, no easy
way to produce the gas in small quantities, or to transport it. The application of C102 to the body
is still not practiced, nor does it seem particularly obvious that it can be. 'The gas needs to be
released or "activated", normally done with strong acids or chlorine just before use. This process
appears somewhat unattractive therefore as a disinfectant in the lab or as a home remedy for the
skin. Further, once C102 is activated, shelf life is normally on the order of hours.
(GRAPH NOT SHOWN)
DECAY OF CHLORINE DIOXIDE IN FRESHWATER
From: Development and Evaluation of an Ion Chromatographic Method for Measuring
Chlorite and Chlorate Anions in Bleached Kraft Mill Effluent, NCASL technical bulletin
#673, July 1994, p. 3
However, in dilute solutions, in a closed container and absence of light, C102 can remain stable
for long periods. This is especially the case in chilled water.
A new compound, DIOXIDERM (formerly CTTRONEX) disinfectant gel, makes novel use of
CIO and is available as a "skin cream" in a two-part system.10 The amount to be applied is
mixed just before use, and the chlorine dioxide is released slowly. Because disinfection and
lesion response are so rapid, the needed extra step of mixing seems unimportant, especially when
treating diseases such as diabetic ulcers or pox lesions. Dual or co -dispensers simplify the
application. Similarly, a dual toothpaste and mouthwash, DIOXIBRITE and DIOXIRINSE are
now available which kill all bacteria and deodorize the mouth. DIOXIGUARD Liquid for
instrument and hospital application as well as general topical use, is a fast acting disinfectant.
The shelf life after combining the needed quantity is one day. DIOXIGUARD kills all bacteria,
viruses and fungi within one minute, including mycobacteria and amoeba.
WIDE USE OF CHLORINE DIOXIDE IN INDUSTRY
2

Paper mills in the U.S. generate an enormous quantity of C1021 500 tons daily for bleaching
pulp." Although more expensive than chlorine, it is the bleach material of choice because the
basic properties of cellulose are not altered. The textile industry applies CIO similarly, where
prevention of injury to the fibers is important. Both cellulosic and synthetic materials are
processed in this way, including cottons, acetates, rayons, polyesters, acrylics and nylons. Cotton
is not degraded because the oxidation reaction is highly selective toward lignin and hemicellulose
components of the fiber. CIO does not adversely effect old paper prints or drawings, and will
clean ancient documents without injury to fibers.
The first use of chlorine (CI 2) as a water treatment process in the U.S. occurred in Jersey City in
1908 12, and of chlorine dioxide, at Niagara Falls in 1944.13 C102 now purifies water in over 500
water treatment facilities in the U.S.14 and many more in Europe. Only chlorine dioxide among
the common water treatment disinfectants (ozone, chlorine, chloramine, and chlorine dioxide),
produces no signs of malignancy in test animals.1, CIO is often applied for water treatment
other than disinfection, for example, remedying difficult smell and taste problems. Phenols, in
particular, are quickly oxidized, and without odorous chlorophenols often produced by chlorine.
CIO is considered the best additive for oxidizing iron and manganese impurities in drinking
water, and for eliminating taste and odor due to algae.16 It also removes cyanides sulfides,
aldehydes and mercaptans. C102 as used in water disinfection is more sporicidal than Cl2 17 ,1 s , a
more powerful inactivator of viruses19, and inactivator of cysts.20 In storm water overflow, C102
has proved active toward all viruses examined.21
Another application of C102 is in the bleaching of fats and flour.22
Extensive experience with chlorine dioxide bleaching of tallow (the fat
extracted from meat scraps and dead animals) has shown that this is a safe
chemical bleaching process. The chlorine dioxide selectively converts color
bodies to lighter colored ones without substantial attack on natural antioxidants
in the oil which protect it against aging and rancidity. Tallows bleached with
Chlorine dioxide meets the "Refine and Bleach Test", is color stable, and is
now in use for the manufacture of the highest -grade toilet soaps.23
Many nutrition and toxicology studies have been performed assessing chlorine dioxide's effect on
flour. Treatment of flour with 200 ppm, fed to rats, had no effect after several generations .24,25
Flour treated with uto 500 ppm (5 times the concentration in DioxiCure Gel) fed to puppies had
no untoward effect. 6 Thirteen human subjects fed experimentally for six weeks with flour
products that were treated with doses up to 400 ppm had no detectable toxic symptoms.27 Flour
bleached with normal dosage is not reduced appreciably in nutritive value.28 Essential fatty acids
are generally not effected, but tocopherol and cystine are oxidized.29 Reactivities of 21 amino
acids with C102 were evaluated using an iodmetric assay, only'6 were found to be reactive at pH
6. They were cysteine, histidine, hydroxyproline, proline, tryptophan and tyrosine.76
3

Several other applications within the food industry have been described. The first reported use of
CIO in the canning industry was by Green Giant at LeSueur, Mn. more than 30 years ago. The
objective was to conserve water while at the same time control bacteria.30 When CIO rather
than chlorine is added to process waters recirculated to clean potatoes, starch by-product,
previously extracted for gluing cartons, is upgraded to food grade level and a higher market
value. Also, the fresh water need is reduced 25%. In this particular process 10 ppm C102 is
added to the wash water in order to maintain a I ppm residual .3k Chlorine dioxide is excellent as
a commercial disinfectant in turkey egg sanitation, and its use does not modify the hatching
properties of the fertile eggs.32 The shelf life of tomatoes can be improved by treatment with
CIO 2.33 CIO also finds application in bleaching cherries and as a teat dip for cows to prevent
mastitis. The FDA has recently permitted the use of C102 for disinfecting chickens, beef and
fruits and vegetables.
Masschelein, in his book Chlorine Dioxide, cites the following:
Chlorine dioxide destroys the microorganisms in fish, fruits and vegetables; and
the treatment can be carried out without altering the nutritive and organoleptic
qualities of the foodstuff. It will take place either by 30-minute immersion in an
aqueous solution of 50 to 1,000 mg/1 (50 to 1000ppm) of C102 or by exposure to
air containing 2,000 to 3,000 ppm of C102. This is a very favorable treatment for
the storage of frozen foods. Natural foods such as pepper maybe sterilized by a
treatment with air containing 1,000 to 20,000 ppm of CIO2. The preservation of
melted cheese is facilitated by the addition of 100 to 300 mg/l of CIO to the milk
used for its manufacture, and 100 to 400 mg/1 to its washing water. The bleaching
of oils and greases, particularly those used for alimentary needs, is carried out by a
maximum injection of 20,000 mg/1 of CIO2. The medicinal odor of cleaning
shrimps is eliminated by adding 40 mg/1 to the washing water. A dose of less
than 100 mg/1 of CIO does not seem to hinder the taste or nutritive value.34
The remaining or residual products on fruits and vegetables after treatment with CIO are
apparently chloride and a trace amount of chlorite.35 A recent patent by Frontier Pharmaceutical
involves the lowering of the chlorite residual, and describes a method for the release of CIO at
higher, more physiological pH.
Some industrial applications of CIO other than bleaching or disinfecting include: the treatment
of leather, where CIO oxidizes disulfide bridges of keratin; stabilization of vinyl and latex
enamels; additive in air pollution control for complexing impurities such as mercaptans and
aldehydes; controlling odors of fishmeal and rendering plant water effluents; an oxidant in the
preparation of vaccines 36,37 and neutralizing toxins 38; and a copper etchant in the manufacture
of electronic component parts.
4

DIFFERENCES WITH OTHER OXIDANTS
Although chlorine and chlorine dioxide are both strong oxidizing agents, they differ in reactions
with various organic and inorganic compounds. C102 for example, does not combine with
ammonia as does C12. Chlorine dioxide is a better disinfectant in the presence of organic matter,
and bacterial kill is not appreciably changed with change in pH. Hypochlorite has a higher
oxidation potential and is an indiscriminate "chlorinator", adding a permanent chlorine atom to
organic molecules. This unfortunately, produces a number of unwanted chlorinated
hydrocarbons such as chloroform and chlorophenol. Chemicals found in industrial waste
discharges for example, all react to produce chlorinated by-products that are hazardous to
health.39 CIO2, on the other hand, oxidizes (removes electrons) without adding an atom of its
own to the oxidized product. The pKa for the chlorite ion, chlorous acid equilibrium, is
extremely low at pH 1.8. This is different from the hypochlorous acidlhyopochlorite base ion
pair equilibrium found near neutrality, and indicates the chlorite ion will exist as the dominant
species in drinking water and in the human body.
When purifying water supplies, C102 combines with phenols particularly fast by attacking the
benzene ring. Odorless, tasteless products are formed directly, without intermediate compounds,
as is the case with chlorine.40 CIO may be more effective than copper sulfate in controlling
algae; it is believed to attack the pyrrole ring of the chlorophyll which cleaves the ring and leaves
the chlorophyll inactive. The reaction of CIO with algae, again, forms tasteless, odorless
products.
Olefins react much more rapidly with permangenate than with chlorine dioxide, whereas,
triethylamine is thousands of times more reactive with chlorine dioxide than with permanganate.
Unlike most other oxidizing compounds, C102, and its reduction product C102 , can act either as
oxidizing or reducing agents (NCASI No. 673). Under acid conditions hydrogen peroxide will
reduce C102 to form chlorous acid, but C102 also can be oxidized by chlorine to produce
chlorate, and by ozone to produce C120,5. C102- similarly can oxidize iodide to form iodine, or
be oxidized by hypochlorite ion to form chlorate. Combining C102 with blood causes
methemoglobin by oxidizing Fe to Fee in the red blood cell. Breathing C102 can have this
effect.
When C102 oxidizes organics, it usually takes in one electron and reduces to C102 . C102 can
oxidize some inorganics, like ferric oxide, remove 5 electrons rather than one, and reduce all the
way to chloride. The amount of electron exchange is the oxidizing capacity, not the redox
potential or driving force of the reaction.

CI02 (aq) + e = C102- where E° = 0.95V
When oxidizing organic molecules, there is no chlorine atom exchange to produce chlorinated
hydrocarbons.
CHEMICAL REACTIONS at,42,43,44
Preparation of CIO
I. Acidification of chlorite
H+ + NaCI02 --� HC102 + Na+
5HC102 —4 4002 + HCl + 2H20
2. Oxidation of chlorite by hypochlorite - for alkaline bleaching & water treatment
2NaC102 + NaOCI + H2O —� 2002 + NaOH + HCl
3. Oxidation of chlorite by chlorine
2NaC1O2 + C12 —� 2C102 + 2NaCl
4. Reduction of chlorate with sulfur dioxide - used in pulp bleaching
2NaC103 + SO2 --a 2002 + Na2SO4
5. Oxidation of chlorite by persulfate
2NaC102 + Na2S208 —> 2C102 + 2Na2SO4
6. Reduction & acidification of chlorate by oxalic acid
21-1003 + H2C204 --� 2C102 + 2CO2 + 2H20
To inhibit further oxidation, the following are good scavengers of C102: sulfamic acid,
sulfur dioxide, resorcinol, hydroquinone, sodium thiosulfate, sodium bisulfite, sodium sulfite,
sodium arsenite and plumbous oxide. Agents that reduce 002 completely to the chloride ion:
borohydride, iodide at pH 1, sulfurous acid, ferrous chloride manganese and vitamin C.
Ferrous chloride will eliminate chlorate.
{GRAPH NOT SHOWNI
UV-Vis absorption spectra showing the release of CIOZ from sodium chlorite at various pH values. Readings were
taken after 60 minutes at ambient temperature. The initial chlorite concentration was 112 ppm. Notice the loss of
chlorite at 262 nm as the pH is lowered, with the gain of C102 at 360 nm, There is little or no release of C102 above
pH 3.as
Inorganic Reactions:

1. For iodometric analysis
2002 + 2I- —� 2C1O2 + IZ
2. Oxidation of iron
CIO + FeO + NaOH + H2O --a Fe (OH)3 + NaC102
3. Oxidation of manganese
2002 + MnSO4 + 4NaOH -4 Mn02 + 2NaC102 + Na2SO4 + 2H20
4. Oxidation of sodium sulfide
2C1O2 + 2Na2S —� 2NaC1 + Na2SO4 + S
5. Oxidation of nitrogen oxide pollutant
2NO + C102 + H2O —> NO2 + HNO3 + HCl
6. Gas phase reaction with flourine
F2 + 2C102 -+ 2FC1O2
7. In alkaline solution
2CIO2 + 20H- -+ CIO 2- + CIO3-+ H2O
8. Aluminum, magnesium, zinc & cadmium react with CIO
M + xC102 --� M(Ct02)x
9. Disproportionation of chlorite depends upon chlorides
present, pH, and ratio of ingredients
4C102 + 4H+ -a Cl- + 2002 + CIO 3- + 2H+ + H2O
5C102 + 4H+ 4CIO2 + C1- + 2H20
10. With hydrogen peroxide as a reducing agent in commercial
production of chlorite
2002 + H2O2 + 2NaOH —> 2NaC1O2 + 2H20+ O2
11. A highly colored complex is formed when C102 is dissolved in an aqueous
solution of barium chlorite C102 + C102- � C1204
Organic Reactions:
1. With organic compounds in water ---) aldehydes, carboxylic acids, ketones &
quinones
2. With olefins ---) aldehydes, epoxides, chlorohydrins, dichloro-derivatives, and
chloro-and unsaturated ketones.
3. With ethylenic double bonds -+ ketones, epoxides, alcohols
4. With benzene --a no reaction
5. With toluene -+ Ch3, CH2Cl, CH2OH
6. With anthracene 450 -+ anthraquinone,1, 4-dichloroanthracene
7. With phenanthrene -+ diphenic acid, 9-chlorophenanthrene
8, With 3, 4-benzopyrene ---� quinones, traces of chlorinated benzopyrene
(no longer considered carcinogenic)
9. With carboxylic and sulfonic functions -4 no reaction
10. With aldehydes —� carboxylic acids

11. With ketones ---) alcohols
12. With aliphatic amines primary slow or no reaction
secondary slow or no reaction
tertiary rupture of CN bond, no N-oxides formed
13. With triethylamine
H2O+(C2H5)3N + 2002 (C2H5)2NH + 2002 - + CH3CHO + 2H+
14. With phenol -4 P-benzoquinone, 2 chlorobenzoquinone
15. Excess CIO with phenol -� maleic acid, oxalic acid
16. With thiophenols -4 sulfonic acids
17. With tocopherol ---) demethylated derivatives
18. With saturated acids -� no reaction
19. With anhydrides --> no reaction but catalyzes hydrolysis
20. With amino acids: glycine, leucine, serine, alanine, phenylalamine, valine,
hydroxyproline, phenylaminoacetec, aspartic, glutamic acids little, or no reaction
21. With amino acids containing sulfur -4 reactive
22. With methionine -> sulfoxide -> sulfone
23. With aromatic amino acids -+ reactive
24. With tyrosine -> dopaquinone, dopachrome
25. With tryptophan -� idoxyl, isatine, indigo red, trace chlorinated products
26. With thiamine -4 slow reaction
27. With keratin -* hydrosoluble acids
28. With carbohydrates CHO and CH2OH -4 carboxylic functions
29. With vanillin pH4 -> monomethyl ester, 0-formylmuconic acid
30. With pectic acid -� mucic acid, tartaric acid, galacturonic acid
31. With chlorophyll and plant dyes --a color removed.
32. With latex and vinyl enamels -4 delays polymerization
33. With napthaline -> no reaction
34. With ethanol -> no reaction
35. With biacetyl ---) acetic acid, carbon dioxide
36. With 2,3-butaneodiol --+ acetic acid, carbon dioxide
37. With cyclohexene aldehydes, carboxylic acids, epoxides, alcohols, halides,
dienes,
ketones
38. With maleic acid no reaction
39. With fumaric acid no reaction
40. With crotonic acid -a no reaction
41. With cyanides --4 oxidized
42. With nitrites oxidized
43. With sulfides oxidized
Hydrocarbons of longer chain length than Cg are the most oxidizable by CIO 2.`6
The organic compounds most reactive with CIO are tertiary amines and phenols.
8

Unsaturated fatty acids and their esters are generally oxidized at the double bond.
CIO DOES NOT REACT WITH:
hippuric acid, cinnamic acid, betaine, creatine, alanine, phenylalanine, valine, leucine,
asparaginic acid, asparagine, glutaminic acid, serine, hydroxyproline, taurine, aliphatically
combined NH2 groups, amido and imido groups, HO groups in alcohols and HO acids, free or
esterified CO2H groups in mono and polybasic acids, nitrile groups, the CH groups in
homologous series, ring systems such as CA' C,oH,, cyclohexane, and the salts of C5H5N,
yuinoline and piperidine.
Most aliphatic and aromatic hydrocarbons do not react with CIO under normal water
treatment conditions, unless they contain specific reactive groups. Alcohols are resistant at
neutral pH, but under conditions of very low pH, high temperatures or high concentrations,
alcohols can react to produce their corresponding aldehydes or carboxylic acids.47
CIO 2 , chlorite, the reduction product of C102, although a less powerful oxidant, is used to react
with many malodorous and highly toxic compounds such as unsaturated aldehydes, mercaptans,
thioethers, hydrogen sulfide, cyanide and nitrogen dioxide.
{GRAPH NOT SHOWNI
UV-Vis absortion spectra43 for:
• a commercial "stabilized chlorine dioxide oral rinse" at a concentration of 100 ppm chlorite at pH 6.5 (there is
no release of chlorine dioxide shown at 360 nm)
• a solution of sodium chlorite (002- ) at 900 ppm in a phosphate buffer at pH 7
• a sodium chlorate (003 ), at 900 ppm in a phosphate buffer at pH 7
{GRAPH NOT SHOWNI
Uv-Vis spectra of commercially available RetarDex® oral rinse utilizing "stabilized chlorine dioxide" at pH 6.5,
5.15, and 2.2. No C102 is evolved above pH 5 as shown at 360 nm.43

DIOXIDERM AND DIOXIGUARD EXPERIMENTAL DISINFECTANTS
Studies have shown DIOXIGUARD and DIOXIDERM, which are CIO or CIO complexes, to
be two of the fastest disinfectants.48 Bacteria, viruses and even fungi are killed in under I
minute. This rate of deactivation includes mycobacteria, amoeba and spores (non dried). Two
questions immediately come to mind: How does DIOXICURE and DIOXIGUARD work? And,
why are they not toxic?
The method of chlorine dioxide bacterial kill at low ppm concentration seems to occur by the
disruption of protein synthesis and enzyme inactivation. 4950 This is similar to the "time
honored", non -toxic mechanism of some common antibiotics. Oxidation of RNA and DNA do
not appear to take place, or are at least unimportant in the process. The site of action lies in the
soluble fraction of the cell; there appears to be no damage to whole structural components such
as ribosomes.5I Bringmann prepared electron micrographs of chlorine -treated cells immediately
after contact and observed no visual change in the cells, comparable to those killed with bromine
and iodine.52
At high CIO, ppm, the method of rapid bacterial and viral kill appears to be the softening and
destroying of the cell wall or viral envelope.53 Human cells do not have cell walls and are
apparently unaffected. Our skin and bodies are likely protected from the general oxidative
effects of C102 by the many reducing agents in our cells and blood such as catalase, glutathione,
superoxide dismutase, vitamins E, C, A, B complex, uric acid, zinc and selenium. This is
probably the same internal protective mechanism that prevents damage from oxygen and free
radicals. Bacteria and viruses do not contain most of these reducing compounds.
Because CIO is a strong oxidizing agent and also itself a free radical, it quickly neutralizes
reactive molecules, and oxygen free -radicals that are produced in the body by macrophages such
as, NO, 02 , H2O2, HCIO, and OH These oxygen compounds are released in response to stress
or infection and cause inflammation and pain. Other potential irritants found in wounds are
similarly oxidized or reduced, such as leukotrienes, TNF, and interleukin. This neutralizing
Property of C102, combined with its ability to completely disinfect, makes DIOXIDERM and
DIOXIGUARD ideal wound medications. Unlike iodine compounds, healing is not impeded.54
55 Veterinarians have been treating deep wounds and abscesses on tigers and elephants as well as
dogs and cats with outstanding success.56 DIOXIDERM GEL had similar striking results on
human (otherwise non -healing) diabetic ulcers.57 If our body could manage to manufacture
chlorine dioxide, as it does hypochlorite, hydrogen peroxide and superoxide, it would certainly
do so.
CIO is both a small molecule relative to common organic disinfectants and soluble. It is also a
gas and non-ionic. These properties no doubt facilitate the transporting process through the skin
or bacterial cell wall.
10

It is interesting to speculate on the formation of a CIO complex that may be involved in the
disinfection process. Electron configuration of the CIO molecule theoretically allows
combination. CIO will hydrate for example with water, and also can form compounds with the
chlorite ion [CIO2 • CIO ] -.58 A highly colored complex, C20a , is formed when C102 is
dissolved in a solution of barium chlorite. There is evidence that more than one oxidant in a
disinfectant formula will act synergistically in deactivating microorganisms,59 for example
chlorous acid and chlorine dioxide.
As with household bleach, where hypochlorous acid and not chlorine is the active bacteria killer,
it may similarly be chlorous acid although quite unstable, and not chlorine dioxide, which is the
more active of the two species. Chlorous acid has a higher oxidation/reduction potential than
either C102 or hypochlorous acid. In Frontier's particular case, DIOXfDERM GEL maintains the
chlorous acid concentration since the unstable chlorous acid molecules formed when mixing A &
B are far less mobile within a viscous gel matrix. The chlorous molecules can not as easily
combine and evolve chlorine dioxide as would be the case in a liquid. The increase in chlorous
acid may be the reason that the gel form is the faster disinfectant on wounds and burns. The
chemical literature shows that a chloritelacid mixture producing CIO has many more times the
oxidation power than CIO alone at similar pH.60 Interesting too, that the type of acid activator
producing the chlorous acid molecule can have an effect on the oxidizing strength of CIO2, or
CIO mixture.61
IGRAPH NOT SHOWN)
Comparison of the Disinfection Efficiencies Comparison of the Dosage Required to Achieve
Of C102 with C12at pHs of 6.5 and 8.562 a 5-Log Reduction in Viable Bacteria at 60-
Second Contact Time63
NON -TOXICITY
Many evaluations have shown CIO compounds to be non -toxic. Five decades of use have not
indicated any adverse effects on health. The main areas of use have been disinfecting water
supplies, the elimination of unwanted tastes and odors, and bleaching in the pulp and paper and
textile industries. Toxicology tests include ingestion of 002 in drinking water, additions to
tissue culture, injections into the blood, seed disinfection6465, insect egg disinfection, injections
under the skin of animals and into the brains of mice, burns administered to over 1500 rats, and
injections into the stalks of plants. "Standard" tests include, Ames Mutation, Chinese Hamster,
Rabbits Eye, Skin Abrasion, Pharmacodynamics and Teratology.66
In one tissue culture study, highly diluted DioxiDerm liquid was placed on CD4 cells infected
with H.I.V. 67. Viruses were inactivated inside the cell, as well as in the supernatant, and with

little damage to the CD4 cell itself. Daughter cells 6 days later, although not as viable as the
controls, were not infected. This is particularly impressive considering that most virucides are
cytotoxic, even at high dilutions. Similar efficacy and non toxicity was demonstrated on infected
cabbage seeds. 4000 seeds heavily infected with bacteria were soaked for about I/2 hour in C1O2
disinfectant. No bacteria remained after this period, and the seeds then grew normally. 68
In order to reduce air and water pollution the EPA is proposing to substitute chlorine dioxide for
the usual chlorine bleach in all pulp and paper mills throughout the country. This effects 350
installations and costs the industry about $4 billion.69 With a prospect of changing from chlorine
to chlorine dioxide in our water supply, the EPA and American Water Works in the past have
commissioned over 100 papers and studies on the toxicity of C1O2. Many controlled animal
studies on the effects of ingesting sodium chlorite and chlorine dioxide have been conducted
from 1 to 1000 mg1L concentrations. Metabolically, both CIO and C1O2 are rapidly reduced
following ingestion. Radioactive chlorine tests show that most of the tagged chlorine is excreted
from the urine in the form of Cl- ion with a small amount of C1O2-. The no observed effect level,
NOEL, from animal ingestion studies involving CIO and CIO z , ranges to 100 ppm 70•71,72, about
the concentration of Frontier's DioxiDerm gel for topical use. The half life for the elimination of
CIO and CIO from the plasma is less than half that of HOC], hypochlorite.73
In one study, human volunteers drank CIO or CIO2 in solution up to 24 ppm and showed no
adverse effects.74 Several studies examined the effects on reproductive toxicity or teratology.
There is no evidence of fetal malformation or birth defects at C1O2 concentrations, in drinking as
well as skin route, up to 100 ppm'S 76 77 With prolonged feeding toxicity is produced mainly in
the red blood cell. Rats fed up to 1000 mg/I chronically for 6 months showed no significant
hematological changes. After 9 months, however, red blood cell counts, hematacrit and
hemoglobin were decreased in all treatment groups.
Lack of toxicity on a long term, but low level basis is dramatically illustrated by two separate
studies where rats ,78 and honeybees ,79 were fed C1O2 in high doses over a two year period. No ill
effects were noted with up to 100 ppm added to water supply.
In a skin sensitization study, CIO liquid and gel (similar to DIOXIDERM ) were injected
intradermally into guinea pigs, 10 times in about 3 weeks.80 No sensitivity reaction was
observed. At the site of continuous liquid injection, necrotic areas developed due to the low pH
of 2.7. This damage was reversible. The pH of Frontiers DIOXIDERM GEL and DIOXIDERM
Liquid, however, is much higher at pH 4, and would probably avoid this temporary damage. An
ocular irritation study in rabbits indicated redness in the conjunctivae after one hour, which
became normal after 24 hours. The cornea and iris remained unchanged after treatment.
Fast disinfection and non -toxicity are properties normally not found side -by -side in the same
compound. For example, formaldehyde and peracetic acid are strong and often used sterilants,
but they are also toxic and irritating. Because both speeds of deactivation and non -toxicity are
combined in DIOXIDERM biocides, new possibilities are opened for important skin products, as
well as commercial surface disinfection.
12

REFERENCES
` Alliger Patents: # 4,084,747, # 4,330,531
2 Block, S.S., Disinfection, Sterilization and Preservation, 1983, 3rd edition, Lea & Febiger, 172
'Kenyon A.J., DVM, PhD; Hamilton,S_G., B.A.; Douglas, D.M., B.S., Comparison of
Antipseudomonad Activity of Chlorine Dioxide/Chlorous Acid -Containing Gel with
Commercially Available Antiseptics, Amer. Journal of Vet. Research, 1986, 47, No. 5, 1101-
1104,
4 Kenyon, A. J.; Hamilton, S. G.; Douglas, B.S.; Controlled Wound Repair in Guinea Pigs,
Using Antimicrobials that Alter Fibroplasia, Amer. J. of Vet. Res., 1986.47, No. 1, pp 96-101
5 Ingols, R.S.; Ridenour, G.M., Chemical Properties of Chlorine Dioxide, J. Amer. Water Works
Assoc., 1940, 40, 1207
'Sussman, S.; Ward, W.J., Microbiological Control with Chlorine Dioxide Helps Save Energy
MP, 16(7), 24, 1977
7 Acute Toxicity of Sodium Chlorite to Rainbow Trout, Toxicity, Test Report #BW-79-1-387,
Jan. 1979, E G & G Bionomics Aquatic Toxicology Laboratory, Wareham, Mass.
8 Dempster, R. P., Steinhart Aquarium Publications, Sept.1970
9 Dugan, P. R., Use and Misuse of Chlorination for the Protection of Public Water
Supplies, ASM News,1979, 44, No. 3, 101
1° Alliger, Patent 4,330, 531
" Gall, R. J., Chlorine Dioxide, An Overview of its Preparation, Properties and Uses, Hooker
Chemicals & Plastic Corp., Niagra Falls, N. Y., 2
12 Dugan, P. R., Use and Misuse of Chlorination for the Protection of Public Water Supplies and
the Treatment of Wastewater, ASM News,1978, 44, No. 3
" White, G. C., Handbook of Chlorination, Van Nostrand Reinhold, New York, N. Y., 1972, 744
14 Harrington, R.M.; Romano, R.R.; Gates, D., Subchronic Toxicity of Sodium Chlorite in the
Rat, J. Am. College of Tox. 14 (1): 21-33
15 Ozone, Chlorine Dioxide and Chloramines as Alternatives to Chlorine for Disinfection of
Drinking Water, Water Supply Research, 1977, U.S. Environmental Protection Agency,
Cincinnati, Ohio
16 Ridenour, G.M.; Ingols, R.S.; Armbruster, E.H., Water Sewage Works 1960, 97:R83
1� Ibid 12
1s Berndt, H.; Linneweh, H.J., Arch. Hyg. Bacterial. 1969, 153, 41
19 Carlson, S.; Gas u., Wasserfach,1%5, 106, 32
24 Ingo Is, R.S., J. Inst. Water Engrs. 1950, 4:581
21 Smith, J.E.; McVey, J.L. Prepr. Pap. Natl. Meeting, Div. Envir. Chem.; Am. Chem. Soc.,
1973, 13:177; Chem. Abstr.1975, 82:159955
22 FDA Reg: 21CFR 137.105: Other government Regs: FDA, Indirect Food Additives, 21CFR
175, 21CFR 178.1010(6) (34), 21CFR 186.1750. EPA, Safe Drinking Water Act, 40CFR 141,
40CFR141.72, 40CRF 141.74. Exemption from Tolerances on Raw Agricultural Commodities,
40CRF 1801070
23 Upgrading Inedible Fats with Chlorine Dioxide, Olin Chemicals, Product Data Bulletin, Ad-
2127-974
24 Frazer, A.C., et al, J. Sci. Food Agr., 1956, 7, 464
25 Hutchinson, J. B., et al, J. Sci. Food Agr., 1964, 15, 725
13

26 Nakamura, F. I.; Morris, M. L., Cereal Chemical, 1949, 26, 50120
27 Newell, G. W., Cereal Chemical, 1949, 26:160
28 Graham, W. D. et al, J. Pharm. Pharmocol., 1954, 6, 534
29 Moran, T.; Pace, I.; McDermott, E.E., Nature, 1953, 171, 103
30 Field Report, Chlorine Dioxide Gains Favor as Effective Sanitizer, Food Engineering, March
1977
31 Bruce, D.J.; Stevens, P.B, Chlorine Dioxide Key to Successful Retrograde Water System,
Food Processing, April 1977
32 Ernst, R.A., et al, Poult Sci., 1974, 53, 14926
33 Rahman, R.A. et al, U. S_ Nad. Tech. Inform. Serv., 1974, Ref. No. 746, 254, Chem. Abstr.,
vol. 78: 28144, 1973
34 Masschelein, W. J., Chlorine Dioxide, Ann Arbor Science, 1979, 172
35 Thomas, R., Use of CIOZ in Water Treatment of Fruits and Vegetables, FDA GRAS petition
3G0020, 1979
36 We1S1oW, O. S.; Wheelock, F., Suppression of Established Friend Virus Leukemia by Statolon:
Potentiation of Statolon's Leukemosuppressive Activity by Chlorite -Oxidized Oxyamylose,
Infection & Immunity, Jan. 1979, 129-136
37 Hermon, O.S.; Janis, B.; Levy, H.B., Post -Exposure Prophylaxis of Murine Rabies with
Polyuinosinic-Polycytidylic Acid and Chlorite -Oxidized Amylose, Antimicrobial Agents and
Chemotherapy, 1974, 507-511
38 Brazis, A. R., et al, J. Amer. Water Works Assoc., 1959, 51, 902
39 Ibid., 5, 100
40 Stevens, A.; Seeger, D.; Slocum, C., Products of Chlorine Dioxide Treatment of Organic
Materials in Water, Water Supply Research Div., U. S. Environmental Protection Agency,
Cincinnati, Ohio, 1977, 9
41 Ozone, Chlorine Dioxide and Chloramines as Alternatives to Chlorine for Disinfection of
Drinking Water, Water Supply Research, 1977, U.S. Environmental Protection Agency,
Cincinnati, Ohio
42 Masschelein, W. J., Chlorine Dioxide, 1979, Ann Arbor Sceince Pulbishers, Inc.
43 Gordon, G.; Kieffer, R.; Rosenblatt, D., The Chemistry of Chlorine Dioxide, Progress in
Inorganic Chemistry, Wiley-Interscience Publishers,1972 15, 201-286
441bid., 9, 612-631
45 Lynch, E.; Sheerin, A.; Claxson, A.W.; Atherton, M.D.; Rhodes, C.J.; Silwood, C.J.L.;
Naughton, D.P.; Grootveld, M. Free Rad. Res.,1997, 26, 209-234
46 Gordon, G., Kieffer, R. & Rosenblatt, D., The Chemistry of Chlorine Dioxide, Progress in
Inorganic Chemistry, Wiley-Interscience Publishers, 1972, 37, 60
A7 Harrington, R. M., Gates, D., and Romano,R.R., A Review of the Uses Chemistry and Health
Effects of Chlorine Dioxide and the Chlorite Ion. Chlorine Dioxide Panel of the Chemical
Manufacturers Association, Washington, D.C., Apr. 1989. 15
48 Evaluations available by Nelson Labs., BioScience Labs., Liuzzi Microbiology Labs., and the
University of Tennessee Inst. of Agr.
49 Benarde, M. A.; Snow, B. W.; Olivieri, V. P.; Davidson, B., Kinetics and Mechanism of
Bacterial Disinfection of Chlorine Dioxide, Appl. Miocrobiol.,1957, 15, 257-265
14

50 Scatina, J.; Abdel-Rahman, M. The Inhibitory Effect of Alcide, an Antimicrobial Drug, on
Protein Synthesis in E. Coli, J Appl, Tox., 1985, 5, 6,
51 Olivieri, V., Chlorine Dioxide and Protein Synthesis, 1968, Master's Degree Thesis, West
Virginia University
52 Bringmann, G., Electron Microscopic Findings of the Action of Chlorine, Bromine, Iodine,
Copper, Silver and Hydrogen Peroxide on E. coli; Z. Hyg. Infektionskrankh, 1953, 138, 156-166
53 E. M. Photos supplied by Frontier Research, Inc. on request
" Kenyon, A.J.; Hamilton, S., Wound Healing Studied with Alcide: a Topical Sterilant, Amer.
Society of Biol. Chemists 74 h Annual Meeting, San Francisco, CA June 5-9 1983.
55 Kenyon, A.J.; Hamilton, S.G.; Douglas, D.M., Controlled Wound Repair By Anitimicrobials
That Alter Fibroplasia, Amer Assn. For Laboratory Animal Science, 3416 Annual Session Nov. 6-
11,1983.
56 Veterinary reports supplied by Arco Research, Inc. upon request.
57 Reports available from Frontier Pharmaceutical, Inc.., 135 Spagnoli Rd. Melville, N.Y.
11747, tel. [phone], fax [phone]
" Ibid., 37
59 White, J.F.; Taylor, M.C.; Vincent, G.P., Chemistry of Chlorites, Industrial and Engineering
Chemistry. July,1942, 789
60 Ibid., 51
61 Paluch, K.; Otto, J.; Starski, R., Investigations on Reactions of Chlorine Dioxide and Sodium
Chlorite with some Organic Compounds, Roczniki Chemii, Ann. Soc. Chim. Polonorum,1974,
48, 1456
6'Bernarde, M.A.; Israel, B.M.; Olivieri, V.P.; Grandstrom, M.L., Efficiency of Chlorine Dioxide
as a Bactericide, Appl. Microbiol., Sept. 1965, 13, 776
63 Tanner, R.S., Comparative Testing and Evaluation of Hard -Surface Biocides, Jour. Ind.
Microbiology, 1989, 4,145
64Kawada, Hiroshi, Haneda, Tadayoshi, Soil Disinfection by Using Aqueous Chlorine Dioxide
Solutions, Patent application: JP95-111095 13 Apr 1995,
65 Report from Cornell, available from Frontier Pharmaceutical, Inc. upon request.
66 Ibid 49
b7 Pontani, D.R., The In Vitro Effect of DioxiDerm on HIV,
" Ibid 49
69 EPA Seeks Increase in Chlorate, 02 Use, Chemical Marketing Reporter, Nov 8,1993
70 Bull, R. J. et al., Carcinogenic Activity of Reaction Products of Alternate Drinking Water
Disinfectants, Pharmacologist, 1979, 21, No.3, 218
71 Yokose, Y.; Uchida, K.; Nakae, D.; Shiraiwa, K.; Yamamoto, K.; Konishi, Y., Studies of
Carcinogenicity of Sodium Chlorite in B6C3F1 Mice, Env. Health Perspectives, 1987, 76, 205-
210
72 Final Draft Drinking Water Criteria Document on Chlorine Dioxide, Chlorite and Chlorate ,
EPA contract No. 68-C2-0139, Clement International Corp., March 31, 1994
73 Bull, R.J., Health Effects of Drinking Water Disinfectants and Disinfectant By -Products,
Envir. Sci. Tech.,1982,16
" Ibid., 41, 38
15

75 Suh, D.H.; Abdel-Rahman, M.S.; Bull, R.J., Effect of Chlorine Dioxide and Its Metabolites in
Drinking Water of Fetal Development in Rats, I Appl. Toxicol. 1983, 3, 75-79
76 Tuthill, R.W.; Guisti, R.A.; Moore, G.S.; Calabrese, F.J., Health Effects Among Newborns
After Prenatal Exposure to CIO,2 Disinfected Drinking Water, Envir. Health Perspect,1982, 46,
39-45,
77 Gerges, A.-R., Skowronski, Effects of Alcide Gel on Fetal Development on Rats and Mice, J.
of Applied Tox.,1985, 5, No. 2
78 Haag, H.B., The Effects on Rats of Chromic Administration of Sodium Chlorite and
Chlorine Dioxide in Drinking Water, Med. Col. Virginia, Dept. Phys, & Pharm.,
Report to Olin Corp., February 7, 1949
79 Lockett, J., Oxodene: Longevity of Honey Bees, Journal of Econ. Entomology,
vol. 65,No. 1, Feb. 1972
80 Abdel Rahman, M.S., Gerges S.E., Ailiger, H., Toxicity of Alcide, J. Applied
Toxicology, Vol. 2, No. 3, 1982
76 Tan, H.K., Wheeler, W.B., Wei, C.I., Reaction of chlorine dioxide with amino acids and
peptides, Mutation Research, 188: 259-266, 1987
16