NCG060139_COMPLETE FILE - HISTORICAL_20181113

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT N0.
1v
DOC TYPE
� HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑� � �b 11 13
YYYYMMDD

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON,A
Interim Director
Smithfield Fresh Meats Corporation
Attn-. Terry Orness, General Manager
PO Box 49
Clinton, NC 28329
NORTH CAROLINA
EnWronmental Quality
November 13, 2018
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG060000
Smithfield Fresh Meats Corporation
Smithfield Fresh Meats Corp - Clinton, Certificate of Coverage NCG060139
Sampson County
Dear Mr, Orness-.
On November 8, 2018, a site inspection was conducted for the Smithfield Fresh Meats Corp - Clinton facility
located at 424 East Railroad Street, Clinton, Sampson County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Mr. Rick Bowen, 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 NGG060000 under Certificate of
Coverage NCG060139. Permit coverage authorizes the discharge of Stormwater from the facility to receiving
waters designated as Rowans Branch (Chestnut Pond), a Class C-,Sw waterbody 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 NCGO60000
permit. Please refer to the enclosed Compliance Inspection Report for additional comments and observations
made during the inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments,
or needs assistance with understanding any aspect of your permit, please contact me at [phone] or by e-
mail at [e-mail].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure
eci Rick Bowen, Environmental Manager -- Smithfield Fresh Meats Corporation ✓
cc: FRO — DEMLR, Stormwater Files-NCG060139
®� � North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Fayetteville Regional Office i 22S Green Street, Suite 7141 Fayetteville, North Carolina 28301
°� 910,433,3300

Permit: NCO060139
SOC:
County: Sampson
Region: Fayetteville
Contact Person: Rick Bowen
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Compliance Inspection Report
Effective: 11/01/18 Expiration: 05/31/21 Owner: Smithfield Fresh Meat Corporation
Effective: Expiration: Facility: Smithfield Fresh Meats Corp - Clinton
424 E Railroad St
Clinton NC 28328
Title: Environmental Manager Phone: [phone]
Inspection Date: 11108l201$ i�mev "- O
Primary Inspector: Mike Lalxz
Secondary Inspector(s):
Certification: Phone:
Rick Bowen 910-299-3051
Exit Time: 01:20PM
Phone: [phone] ExV2
339y
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Food/Tobacco/Soaps/Cosmetics/Public Warehousing Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page:

Permit: NCGoe0139 Owner - Facility: Smithfield Fresh Meat Corporation
Inspection Date: 11/08/2018 tnspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to ensure compliance with the conditions of NPDES Stormwater General Permit NCG060000, Met
with Rick Bowen, Environmental Manager. Reviewed facility's Stormwater Pollution Prevention Plan, which contains all
permit required components and is reviewed/updated annually. Also reviewed associated documentation related to
housekeeping practices, employee training, facility inspections, spill reports, etc. Analytical and Qualitative monitoring
records for the facility's two stormwater discharge outfalls were provided for review. Facility has been in the Tier Two monthly
monitoring schedule for several years due to consecutive and on -going exceedanoes of the benchmark value for fecal
coliform. Based on facility records, they have taken a proactive approach in addressing these exceedances. For example,
several internal storm drains located in areas of live animal holding and other processing areas have been rerouted to be
connected to the facility's onsite wastewater system. During site observations, several recommendations were made by the
inspector regarding the potential for controlling the frequency and amount of stormwater discharges as well as further
reducing and/or eliminating the exposure risks that are likely associated with the benchmark exceedances of the fecal
coliform parameter. For example, covering the area where the empty live hog trailers are staged for rinsing and/or rerouting
the stormwater runoff in this area to the facility's wastewater system. Options under the Tier Three response actions were
also discussed such as decreasing the monitoring frequency for the parameters where benchmark values are consistently
being met while maintaining the Tier Two monthly monitoring schedule for fecal coliform.
Page: 2

permit; NCGO60139 Owner - Facility: Smithfield Fresh Meat Corporation
Inspection Dater 11 /0812018 Inspection Type : Compliance 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-annualty?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were'all 'outfalls obsenied'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
■❑❑❑
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■❑❑❑
■❑❑❑
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■❑[in
Yes No NA NE
❑ ❑ ❑
Yes No NA HE
N ❑ ❑ ❑
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Yes No NA NE
■❑❑❑
--0 ❑ ❑ ❑
❑❑■❑
■❑❑❑
Page: 3

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
Mr. Terry Orness
Smithfield Fresh Meats Corporation
P.O. Box 49
Clinton, N.C. 28329
Dear Mr. Orness:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. TOBY VINSON, JR,
Interim Director
February 13, 2018
F E B 1 9 2018
Subject: NPDES Stormwater Permit NCG060139
Smithfield Fresh Meats Corporation
Formerly Smithfield Farmland Corporation
Sampson County
Division personnel received your request to revise your stormwater permit Certificate of Coverage to accurately
reflect your new company and/or facility name.
Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General
Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the
requirements of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between
North Carolina and the U.S. Environmental Protection Agency.
If you have any questions or need further information, please contact the Stormwater Permitting Program
at [phone].
State of North Carolina I Environmental Quality � Energy, Mineral, and Land Resources
Central Office 1 1612 Mail Service Center I Raleigh, NC 27609
919 707 9200

Sincerely,
Original Signed by Robert D. Patterson, P.E.
for William E. Toby Vinson, Jr., PE, CPESC, CPM
Interim Director
Division of Energy, Mineral and Land Resources
cc: Fayetteville Regional Office
Central Files

- -
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060139
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
424 E Railroad Street
Clinton
Sampson County
to receiving waters designated as Rowans Branch (Chestnut Pond), a Class C, SW waterbody in
the Cape Fear River Basin; in accordance with the effluent limitations, monitoring requirements,
and other conditions set forth in Parts I, 11, II1, and IV of General Permit No. NCG060000 as
attached.
This certificate of coverage shall become effective February 13, 2018.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day February 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
1' Land Quality Section/Stormwater Permitting
NC®ENR
National Pollutant Discharge Elimination System
—�r PERMIT NAME/OWNERSHIP CHANGE FORM
FM hn01_ N! uio Ngiawl RfSaunClJ
FOR AGENCY USE ONLY
Date Received
Year
Month Da
1. Please enter the permit number for which the change is requested.
NPDES Permit (or) Certificate of Coverage
C, I S 1 O 1 1 1 1 N I ;C I G 10 16 0 1 1 3 9
II. Permit status prior to requested change.
a. Permit issued to (company name): Smithfield Farmland Corp.
b. Person legally responsible for permit: Jeff Wall
First MI Last
c. Facility name (discharge):
d. Facility address:
General Manager
Title
PO Box 49
Permit Holder Mailing Address
Clinton N.C. 28329
City State Zip
[phone] [phone]
Phone - Fax
Smithfield - Clinton Plant
424 East Railroad Street
Address
Clinton N.C. 28328
City State Zip
e. Facility contact person: Rick M. Bowen [phone]
First / MI / Last Phone
111. 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:
JAN ,26 2013
bE0A!VAI+'>•D (6N111V
�5fbR fflRtkm,^i111 IILr.
d. Facility name (discharge):
e. Facility address:
Smithfield Fresh Meats Corp
Terry Orness
First Ml Last
General Mana
Title
PO Box 49
Permit Holder Mailing Address
Clinton N.C. 28329
City State Zip
[phone] [e-mail]
Phone E-mail Address
Smithfield Fresh Meats Corp - Clinton
424 East Railroad Street
Address
Clinton N.C. 28328
City State Zip
f. Facility contact person: Rick M Bowen
First M1 Last
[phone] [e-mail] ^
Phone E-mail Address
W. Permit contact information (if different from the person legally responsible for the permit)
Revised Jan 27, 2014

NPDES PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
Permit contact: Rick M Bowen
First MI Last
Enviornmental Manager
Title
PO Box 49
Mailing Address
Clinton N.C. 28329
City State Zip
(910-) 299-3051 fbowen(a_,)smithfield.com
Phone E-mail Address
V. Will the permitted facility continue to conduct the same industrial activities conducted prior
to this ownership or name change?
® Yes
❑ 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.
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):
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
APPLICANT 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. !_
Ihs-
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

4
CONTRIBUTION AGREEMENT
This Contribution Agreement (this "Agreement") is entered into with an effective date and
time of 11:51 p.m., Eastern Time, on December 31, 2017 (the "Effective Time") by and between
Smithfield Packaged Meats Corp., a Delaware corporation (the "Contributing Party"), and
Smithfield Fresh Meats Corp., a Delaware corporation (the "Subsidiary").
Ii-al l Intl55161 M
A. As of the Effective Time, the Contributing Party is the sole stockholder of the
Subsidiary.
B. Prior to the Effective Time, the Contributing Party (i) directly owns all of the issued
and outstanding membership interests (the "Interests") of Premium Pet Health, LLC, a Delaware
limited liability company ("PPH"), and (ii) is the record and beneficial owner of those certain
distribution centers, fresh meat plants and fresh meat assets, properties and contract rights listed
on Exhibit A attached hereto (collectively, the "Contributed Assets").
C. Prior to the Effective Time, PPH may hold certain liabilities and payables owed by
the Contributing Party, and by certain of its subsidiaries that are disregarded as separate from the
Contributing Party for U.S. federal income tax purposes ("DREs"), to PPH (the "PPH
Receivables"), including, for the avoidance of doubt, liabilities and payables acquired or assumed
by, or otherwise transferred to, the Contributing Party (i) in connection with the merger of each of
Stefano Foods, Inc., Smithfield Global Products, Inc. and Smithfield Farmland Corp. with and into
the Contributing Party, and (i i) pursuant to the Distribution Agreement entered into by and between
the Contributing Party and Armour-Eckrich Meats LLC dated as of October 29, 2017.
D. Prior to the Effective Time, PPH may also hold certain liabilities and payables (the
"PPH Payables") owed to Smithfield Foods, Inc., the Contributing Party and certain of their direct
and indirect subsidiaries (collectively, "Smithfield").
E. The Contributing Party has agreed to contribute the Contributed Assets to the
Subsidiary in accordance with the terms and conditions set forth below.
NOW, THEREFORE, in consideration of the premises and for good and valuable
consideration, the receipt and sufficiency of which are hereby acknowledged, the parties agree as
follows:
ARTICLE I
TRANSACTIONS
1.1 Pre -Contribution Assignments
(a) Distribution and Acceptance. Immediately prior to the Effective Time, PPH
hereby distributes, assigns, conveys and delivers to the Contributing Party all of PPH's right, title
and interest in and to any and all PPH Receivables, and the Contributing Party hereby accepts such
96179629

distribution, assignment, conveyance and delivery of such PPH Receivables, the composition and
amount of which is to be determined immediately prior to the Effective Time (the "Distribution').
(b) Assumption. Immediately prior to the Effective Time, the Contributing
Party assumes any and all PPH Payables, the composition and amount of which is to be determined
immediately prior to the Effective Time.
1.2 Contribution.
(a) Contribution and Acceptance. Effective as of the Effective 'rime, the
Contributing Party hereby assigns, transfers, conveys and delivers to the Subsidiary, and the
Subsidiary hereby accepts the assignment, transfer, conveyance and delivery of, the Contributed
Assets, and assumes the related obligations, as a contribution to the capital of the Subsidiary (the
"Contribution").
(b) Excluded Assets. The parties hereby acknowledge and agree that the
Contributing Party owns certain assets and properties in addition to the Contributed Assets
(collectively, the "Excluded Assets"), and that the Excluded Assets are being retained by the
Contributing Party and are not being contributed or transferred as part of the Contribution.
(c) Acknowledgment of Relationship. The parties hereby acknowledge and
agree that the Contributing Party is the sole stockholder of the Subsidiary and that, as such, the
Contributing Party is the holder of 100% of the outstanding stock of the Subsidiary.
(d) General Representations. and Warranties of the Contributing Party. The
Contributing Party hereby makes the following representations and warranties to the Subsidiary as
of the Effective Time: (i) the Contributing Party has the capacity and full authority to enter into
this Agreement and to perform the obligations of the Contributing Party under this Agreement;
and (ii) the Contributing Party has not made, and has not contracted for, any assignment, sale,
exchange or other transfer of the Contributed Assets or any portion of them (other than as set forth
in this Agreement).
1.3 Related Actions and Further Assurances.
(a) Related Actions. On and after the Effective Time, and after giving due
regard to subsections (b) and (c) immediattely below, each party shall promptly take such actions
as may be reasonably requested in writing by the other party (including, without limitation, the
execution of additional agreements, instruments or documents) for the purpose of evidencing or
effectuating the transactions contemplated by this Agreement (the "Related Transfer Actions").
(b) Specific Actions. Without limiting the scope of the Related Transfer
Actions, the parties specifically acknowledge and agree as follows: (i) if any Contributed Asset is
real property, the parties shall execute a mutually satisfactory deed for the conveyance of such real
property from the Contributing Party to the Subsidiary and shall cause such deed to be recorded in
compliance with applicable law; and (ii) if any Contributed Asset is evidenced by a necessary
instrument of title (other than real property), the parties shall execute appropriate and mutually
satisfactory documentation for the transfer of such title, and shall cause such documentation to be
filed or recorded, as applicable, in accordance with applicable law.
-2—
96179629

(c) No Other Instruments of Transfer. The parties acknowledge and agree that,
except as required by subsection (b) immediately above with respect to any real property and any
property evidenced by a necessary instrument of title, their mutual execution and delivery of this
Agreement shall be sufficient to evidence and effectuate the Contribution, and the parties shall not
require any separate or additional instrument of transfer in connection with the Contribution.
Notwithstanding the above, an additional instrument of transfer with respect to the Contribution
may be executed and delivered with the mutual consent of both the Contributing Party and the
Subsidiary (with the understanding that each such party, in such party's sole discretion, may grant
or withhold any such consent).
1.4 Governing Law and Amendment.
(a) Governing Law. The laws of the State of Delaware (without regard to those
laws involving conflicts or choice of law) shall govern this Agreement and all matters that relate
to its interpretation or enforcement.
(b) Amendment. Amendments to this Agreement shall not be binding, valid or
enforceable unless they are approved in writing by authorized officers of each of the parties.
1.5 Other General Matters.
(a) Disregarded Transfer. It is the intention of the Contributing Party, PPH,
and the Subsidiary that the Pre -Contribution Assignments be disregarded for U.S. federal income
tax purposes.
(b) Section 351 Transfer. It is the intention of the parties that the transfer of any
property (within the meaning of section 351) pursuant to Contribution qualify as a transfer under
section 351 of the Internal Revenue Code of 1986, as amended.
(c) Miscellaneous. This Agreement shall be binding upon, and enforceable
against, the parties and all of their permitted assignees and successors in title or interest. Captions
and headings are used in this Agreement for convenience only and shall not affect its interpretation
or enforcement. Any terms such as "hereby," "herein" and similar references shall be deemed to
refer to this Agreement as a whole, rather than to any particular provision. Terms defined in the
singular in this Agreement shall be deemed to include their respective plurals, and vice versa. Any
prior oral agreements with respect to the subject matter of this Agreement have been integrated
into this Agreement as deemed necessary by the parties and are superseded by this Agreement.
A Counterparts. This Agreement may be executed in counterparts, each of
which shall be deemed an original and all of which shall constitute, when taken together, a single
binding instrument.
(Signature Page to Follow)
-3—
96179629

FJ
IN WITNESS WHEREOF, the parties have caused this Agreement to be executed by their
duly authorized representatives as of the Effective Time.
Contributing Party: Smithfield Packaged Meats Corp.,
a Delaware corporation
Name. Michael H. Cole
Title: Vice President & Secretary
Subsidiary: Smithfield Fresh Meats Corp.,
a Delaware corporation
By: J�-(, �-6L
Name: Michael H. Cole
Title: Vice President & Secretary
[SIGNATURE PAGE TO SP_-MC/SF'MC CONTRIBUTION AGREEMENT]

Exhibit A
Contributed Assets
Contracts related to fresh meats, fresh meats customer lists and other intangibles related to fresh
meats.
Fresh Meats Plants
Smithfield, VA (formerly PPH)
Denver, CO
Orange City, IA
Sioux City, IA
Tarheel, NC
Milan, MO
Salt Lake City, UT
Smithfield North, VA
Denison, IA
Crete, NE
Monmouth, LL
Clinton, NC
Distribution Centers
Clayton, NC
Newport News, VA
Crete, NE
Monmouth, U,
Exhibit A- I
96179629

z
Delaware Page 1
The First State
I, .TEFFREY 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,
SR# 20176947282�"'
You may verify this certificate online at corp.delaware.gov/authver.shtml
\ql
Vany W. q W heM, S.psr7ry or 5e�lr
Authentication: 203529372
Date:11-07-17

State of Delamare
Secreiarg of State
Dhision of Corporations
Delh,ered 01:27 P-11 11106017
FILED 02:27 P11111062017 CERTIFICATE OF INCORPORATION
SR 20176947282 - ReNuntber 6605607
OF
SMITHFIELD rRESH MEATS CORP.
ARTICLE FIRST
The name of the corporation is Smithfield Fresh Meats Corp. (the "Corporation").
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 narne 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 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 tender 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 Oenerai Corporation law shall 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.

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 mace, alter or repeal Bylaws of the Corporation but
the stockholders may make additional Bylaws and may alter or rcpeal 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-fottrths (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

J �
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, lines, 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, 2017,
[Signature Page Follows]

w ,s I
IN WITNESS WHEREOF, i have signed this certificate of incorporation this Yd day of
November, 2017.
,/VC."
Michael IT Cole
Incorporator
[Signature Page to Smithfield Fresh Mears Corp. Cert f cale of Incorporation]

=orm W_9
Request for Taxpayer
Give Form to the
'Rev Dent
Identification Number and Certification
requester, Do not
of the
Department of the Treasury
Send to the IRS.
nlemal Revenue Service
1 Name (as shown on your income tax return) Name rs required on this line; do not leave this line blank
SMITHFIELD PACKAGED MEATS CORP.
2 Business namo/daregarded entity name, if different from above
m
41
Cl
a
3 Check appropriate box for federal tax classification, check only one of the follovnng seven boxes
4 Exemptions (codes apply only to
c
H
❑ Individual/sole proprietor or ❑d C Corporation ❑ S Corporation ElPannership ❑ TrusVestale
certain entities, not individuals, see
instructions on page 3)
m c
single -member LLC
❑ Limited $ability company Enter the tax classification (C-C corporation, S=S corporation, P�parinership) r+
Exempt payee tads (i1 any)
o n
Note. For a single -member Li that is disregarded. do not check LLC. check the approprlate box in the line above for
Exemption from FATCA reporting
I
the lax classification of the single -member owner
code (if any) E
a` o
❑ Other isee instructions)ts
e» US)
i,-'.-
5 Address (number, street, and apl, or suite no)
Requester's name and address (optional)
u
¢
200 COMMERCE STREET
m
m
6 City, state, and 21P code
w
SMITHFIELD, VA 23430
7 List account numbers) here (optimal)
yer Identification Number (TIN)
Taxpa-
Enter your TIN in the appropriate box. The TIN provided must match the name given on line 1 to avoid
SGClal security number
backup withholding For individuals, this Is generally your social security number (55N) However, fora
resident alien, sole proprietor, or disregarded entity, see the Part I instructions on page 3. For other
entities, it is your employer identification number (EIN) If you do not have a number, see Mow to get a
TIN on page 3.
Note. It the account is in more than are name, see the Instructions for line 1 and the chart on page 4 tot
guidelines on whose number to enter
Certification
or
num
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. 1 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 t 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 i form of any) Indicating that 1 am exempt from FATCA reporting is correct
Certification instructtons. 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 indivldua) 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
Sign I Signature of % l��5[1 /� , l 7
Here U.S person h ��yrL Dace a / (�(,J�
General Instruction
Section references are to the Internal Revenue Coda unless otherwise noted
Future developments Intotmallan about developments affecting Form W-9 (such
as legislative enacted after we release a) is at www im 9ov/Av9
Purpose of Form
An individual or entity (Form W-9 requested who is required to file an information
return with the IRS must obtain your correct taxpayer identification number (TIN)
which may be your social secunty number (SSN), individual taxpayer identihcatian
number (ITiN), adoption taxpayer identification number (ATIN), or employer
identification number (EIN), to report on an information return the amount paid to
you, or other amount reportable on an information return Examples of informatlon
rejUmS Include, but are not limited to, the lollowmg
+ Form 1099-INT (interest 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 1099-6 (proceeds from real estate transactions)
• Form 1099-K (merchant card and third parry network transactions)
Form 109E (home mongage Interest), 1098-E (student loan Interest), 1098-T
(tuition)
• Form 1099-C (canceled debt)
• Form 1099-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
Y you do not return Form W-9 to the requester with a 7W, you might be, subject
to backup withhoidmg See What is backup wilhhofdrng? on page 2
By signing the filled -out form, you
i Certify that the TIN you are gluing 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 If
applicable, you are also certifying that as s U S person, your allocable share of
any pannership income from a U S trade or business is not subject to the
withholding tax on forelgn partners' share of effectively connected income, and
4 Certify that FATCA codes) 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 funher Information
Cat No 10231K Form W-9(Rev 12-2014)

�.a
Energy, Mineral &
Land Resources
ENVIRONMENTAL QUALITY
October 17, 2017
Jeff Wall
Smithfield Farmland Corporation
ROY COOPER
Qorernar
MICHAfL S,. REGAN
Secretary
TRACY DAVIS
Director
Subject: NPDES General Permit Renewal and Electronic Reporting Requirements
Smithfield -Clinton Plant
NPDES Permit Certificate of Coverage (COC) Number: NCG060139
Dear NPDES Permittee:
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 (htt oo. I Bc DP4).
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 North Carolina I Environmental Quality I Energy, Mineral and Land Resources
512 N. Salisbury Street 11612 Mail Service Center I Raleigh, North Carolina .27699-1612
919 707 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 questionsabout which form you
need. Changes to other contacts can be e-maiied to Laura Alexander at Iaura:alexandergncdenr.eov.
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; 20.16.
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: G6-to the following website and enter the discharge outfall
number, type of discharge, receiving water information, representative outfall status'!nformation,.and
other details no later than November 30, 2017. The website will walk you through.all steps.
The website is: https:/Ideg.nc:g6vlabout/stormwater-program/stormwater-outfall-collecti_o_n
For more information on EPA's NPDES. Electronic Reporting Rule, visit
http://www2.epa.gov/compliance/final-national-pollutant-discharge-elimination-system=npdes-
electronic-reportins=rule. For more information on electronic reporting to NC DEMLR, visit
http:/ldeg.nc.gov/about/divisionslenergy,mineral=land=resources/stormwaterl-ereporting--rule or
contact Bethany Georgoulias at [phone] or via email at bethahy.;e6e> oulias@hcdenr:eov„or
Robert Patterson at [phone] or via email at [e-mail].
Sincerely,
Annette Lucas, P.E.
Supervisor, DEMLR Stormwater Program
Cc: Stormwater Program Permiffile
Nothing Compares—..'
State of North Caronna.I Environmental Quality I Energy,Mtnerai and Land Resources
512 N. Sallsbury street l 164 Wail Servke Center I Raleigh North Carolina 27699-I6I2
919 707 9200

Fayetteville Division 2592 Hope Mills Road -- Fayetteville, NC 28306 [phone] 1864-8774 fax
CHAIN OF CUSTODY RECORD
PAGE 1 OF 1
CLIENT NAM E8 AODRESS:
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B = HNO3 (pH<2) + <6°C
C = H2SC4 (pH<2) + <6°C
D = NaOH + <6°C
E = ZN Acetate + <6°C
F = HCI
G = Sodium Trio
CONTACT PERSON:
Dc'n✓n S" � �-'
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Turnaround time: REGULAR RUSH
Comments or Special Hazards:
pH Field : ph Field: Water Level #1 IS DATA FOR REG, COMPLIANCE PURPOSE?
Temp Field 1: Fld CL2: Water Level #2 NO YES WHICH:
Temp Field 2: Field Chlorine: ____

Lawyer, Mike
From: Mullen, Dale G. <[e-mail]>
Sent: Wednesday, January 22, 2014 6:38 PM
To: Lawyer, Mike
Subject: Smithfield Clinton
Attachments: Chemical Release -Spill Report.PDF
Mike: Please find attached the Chemical Release/ Spill Report that contains information about the October 31, 2013,
sulfuric acid spill. It is important to note that the spill was contained completely onsite in a confined area on a hard
surface. It did not result in a discharge to the POTW, storm water system, surface water, or ground water. It was
neutralized and collected before disposal. See attachment.
Thanks,
Dale G. Mullen
McGuireWoods LLP
One James Center
901 East Cary Street
Richmond, VA 23219-4030
804.775.4710 (Direct Line)
804.698.2098 (Direct FAX)
[e-mail]
http://www.mcguirewoods.com
This e-mail may contain confidential or privileged information. If you are not the intended recipient, please advise by
return e-mail and delete immediately without reading or forwarding to others.

CHEMICAL RELEASE 1 SPILL REPORT
INVESTIGATION REPORT
Initial Incident Response
Date of Incident: 10/31/13 Investigation Reference Number:
Type of Report: _ Near Miss Minor Release/Spill X Major Release/Spill _ Fire
Explosion _Other
Release/Spill Reported By: Chad Allen__ _
Reported To: Susan Melchor Time: 7:45 pm
Equipment Involved: Lull Sulfuric Acid Tote
— Snow _ Fog X Other
Page I of 4
_ Approx. Temperature: 70 degree F Wind Direction: South Wind Speed: 5 mph
Humidity: High X Low
Was an evacuation necessary? Yes List area(s) of evacuation Rendering building, area adjacent waste
Eater break room and the spill area
Was the Emergency Response Team called to respond: Yes IF Yes, list responder names:
:Ben Strickland
'Demetrius Eason
Gary Walters
a is
Bob Blair Brian Gained__
Nick, Holloman. TT Lenny Spell
Were outside emergency personnel used? No If Yes, who responded:
Were Contractor Employees Involved: Yes Contractor Company: 301 Environmental Clean Up, Inc.
Address: 4800 Front St., Stedman, NC 2839I Phone: [phone]

Page 2 of 4
Determining the Facts 1 Cause(s)
List type of chemical involved: 98.6% Sulfuric Acid
Duration of Spill / Release: Immediate spill of liquid
Quantity of chemical released / spilled: (attach calculations) 330 gallons _
Estimated $ value of damaged property/equipment: $403.60 for acid costs no damage to Lull
List type of equipment involved: Lull, acid tote
Was product contaminated: No Describe:
Estimated S value of product damaged: �0.00
List any unusual observations of the incident scene:
Was environmental department notified: Yes Who: Susan Melchor and_Susan Murphy_
Were Federal, State, Local Agencies notified; List Case #;
Were pictures taken of incident scene: Yes
Create a timellne of all activities and person(s) involved before, during, and conclusion of the incident:
(attach any additional sheets to the report)
7:30 pm Chad Allen uses the lull to go get tote of acid from chemical storage area
7:45 pm Tote breaks free of lull and falls to the g[ md. Tote ruptures and spills 330 gallons of sulfuric acid _
7:49 pm Ben Strickland contacted about spilt and he contacts members of Hazmat team for assistance, Ben instructs
Susan to barricade area and that no one. goes into the area until hazmat team arrives. f __
8:05 pm Ben Strickland and other members arrive done protective gear and access the situation with evacuation area
expanded
8. t 0 13m Storm drain covered to ens re acid does not leave proverM..Pump check at Outfall 2 to ensure no acid had
leave facility.
8:20 pm neutralizing agent and absorbent agent application begins.
8:30 pra Gary Walters arrives and Ben turns over Incident Command and Ben Strickland assumes role of Operations
Chief
9:30 pm Rendering allowed to resume operations.
10:00 pm treatment of acid spill completed and saw dust arrives from Murphy Browns LLC,
10:20 pm Saw dust application begins
11:30 pm Saw dust awlication concluded.

Page 3 of 4
11,45 Rm mitizadon of acid in storm drain begins
12:15 am flushing of storm drain begins with runoffbeing captured into totes
12:30 am flushing o erations continued until 9:00 am on 11/1113
9:00 am 301 Environmental Clean Up, Inc. arrives on site for cleanup operations and operations turned over to Chip
Humphrey
1:15 m cleanup operations completed and operations completed
1-,20 pm Gary Walters terminates command and facility reopens all areas.
Primary Source of Spill / Release: (check one primary)
Oil Drain Valve _ Barrel _ Tank _ Compressor _ Pump
Condenser —Evaporator _Pipe _ Valve — Vessel
X Other / Explain;
Chemical tote for sulfuric acid
Contributing Cause(s): (check all that apply)
_ Human Factors —Design Shortcomings , X Equipment Failure —Corrosion
_ Power )Failure X Inadequate Maintenance X Equipment Defect _ Process Upset
—Mechanical Damage _Inadequate Labeling Administrative _ Engineering
Other / Expaain:
Recommended Changes to Prevent Recurrence: (check all that apply)
Administrative
___. Operating Procedures
_ Management of Change Procedures
Emergency Response Procedures
X Safe Work Practices
Labeling / Identification
X Additional Training
Other (explain below)
En ineerin
_ Design
Equipment
Piping
— Safety Equipment
Mechanical Protection ! Access
_ Controls
Other (explain below)
Explain basis for change and implementation plan: (include root cause)
Facility along with supplier must address the inspection of totes before use at the facility to ensure they are
physically sound. Dammed totes will not be accepted on site. Operators must not only visually inspect the
tires of the Lull before use but the tire nressure must he checked..tn ensure thev are adeounteiv inflated. Tl
decreased tire pressure prevented the lull from traveling on a/level diane' The tote damage from excess use
The weight of the liouid shiftiAo when tiYe lull
allowed the tote to fracture and roll to the lower side of thMvehicle `ihde_the tire nrAsure was decreased.
1
Waste Water Supervisor nce tendent

Page 4 of 4
Attachments
Attachment I Picture of spit!
Attachment 2 Picture of stornn water protection
Attachment 3 Picture of area after neutralization and application of saw dust
Attachment 4 Picture of area after dry clean up before final wash down
Attachment 5 Picture of temporary storage of solids Following clean up operations
Attachment b Site map of event
The Incident Investigation has been reviewed, root causes identified and recommended changes have been
implemented. By acknowledging the findings and results of this report the investigation will be deemed
closed and tiled and logged on the Chemical Release / Spill log in the powerhouse office. This report will be
maintained for a minimum of (5) years and will be used in upcoming Process Hazard Analysis.
Engineering:
Environmental Manager:
Plant Safety Manager:
Plant Senior Manager:
Date:
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McGuireWoods LLP
One lames Center
901 East Cary Street
Richmond, VA 23219-4030
Te 1804.7 75.1000
Fax [phone]
www.mcgu i rewoods.com
Dale G. Mullen
Direct: 1.804.775.4710
WGUIREWOODS
December 16, 2013
Via Electronic Mail and USPS
Tom Reeder, Director
Division of Water Resources
North Carolina Department
of Environment and Natural Resources
217 W. Jones Street
Raleigh, NC 27603
Re: Smithfield Clinton Plant
Voluntary Disclosure of Noncompliance
Dear Mr. Reeder:
dmu Ilen0mcguirewoods,com
Fax: I.804.698.2098
I am Benne Hutson's law partner and this letter is written as a follow up to the telephone
conversation you had with Benne, Matt Matthews and others this morning (December 16, 2013).
As Benne told you and Matt this morning, our firm represents Smithfield Clinton Plant
("Smithfield Clinton"), This pork processing facility is located at 424 E. Railroad St., Clinton N.C.
28328. Smithfield Clinton has discovered, and is continuing to investigate, alleged irregularities
in its laboratory testing and reporting concerning its Industrial User Pretreatment Permit (AUP")
that arise from the events described below. Additionally, two other points were brought to our
attention concerning a flow meter and process chemicals. The facts, as they are now known,
are also disclosed here and. are similarly under review for corrective action if necessary. The
purpose of this letter is to make a voluntary disclosure of these alleged violations to the North
Carolina Department of Environment and Natural Resources ("NCDENR") in accordance with
NCDENR's policy document entitled Enforcement Penalty for Self -Reported Violations (the
"Disclosure Policy").
This letter is provided as a follow up to verbal self -reporting made by telephone call by
Benne Hutson to you and Matt Mathews, Water Quality Section Chief for the North Carolina,
Division of Water Resources. Additionally, I called Jeff Vreugdenhil, Public Works & Utilities
Director and was in frequent phone contact on December 16, 2013, with Lisa Osthues,
Environmental Programs Manager for the City of Clinton.
The following is a summary of the preliminary results of Smithfield Clinton's investigation
to date. As investigation continues, if facts different than, or in addition to, those described in
this letter are discovered, we will provide that information to you promptly. If any additional
Atlanta Austin I Baltimore I Brussels i Charlotte I Charlottesville I Chicago I Houston I Jacksonville London
Los Angeles I f`'ew York I Norlolk I Pittsburgh I Raleigh I Richmond I Tysons Comer I Washington, D.C. I Wilmington

Tom Reeder, Director
December 16, 2013
Page 2 _ _ _._.....,,—
violations are discovered in this investigation, Smithfield Clinton intends to report them within
twenty one (21) days of discovery.
Background
Smithfield Clinton operates a pretreatment facility under an Industrial User Permit ("IUP")
issued by the City of Clinton, NC, ("City"). The term of the IUP is from December 6, 2010, until
September 1, 2014. The lUP is administered by the City under the provisions of North Carolina
General Statutes § 143-215.1. Pretreatment is provided by the Plant which then discharges to
the collection system to the Norman H. Larkins Water Pollution Control Facility ("WPCF").
There are four (4) pipes that discharge to the City of Clinton. One pipe is regulated by
IUP #0006. Pipe OD1 is a regulated discharge of pretreated wastewater generated from pork
processing and rendering and washing market hog and finished product trucks. The other three
(3) pipes are domestic wastewater and are regulated by the City of Clinton sewer use ordinance
but not the IUP.
The City of Clinton owns and operates the Larkins WPCF. The facility is permitted for an
average daily flow of 5.0 million gallons and subject to the Division of Water Resources'
("DWRs") most stringent effluent discharge limits. The Larkins Facility discharges into Williams
Old Mill Branch under a NPDES permit administered by the state of North Carolina. The City
has adopted a Sewer Use Ordinance ("SUO"). The SUO establishes legally enforceable
standards for protection of the City's sewer collection system and the WPCF. The SUO covers
flows, organic loadings, temperature, toxins, heavy metals, and many other possible
characteristics.
As part of the operation of the permitted pretreatment facility, Smithfield Clinton also
operates a state -certified laboratory for collecting and analyzing pretreatment compliance
samples under the IUP. Some relevant IUP compliance parameters for the Clinton Plant are set
out in Figure 1.
Figure 1. Plant Compliance Parameters (IUP, Part 1, Section F, p. 6)
Parameter
Limit
Monitoring
Method
Flow
1.6 m d
Dail
NIA
BOD
2,085 min. - 17,827 max. lbs./day
Process days
C
TSS
5,317 lbs./clay
Daily
C
NH3N
2,221 IbsJday
Daily
C
H
6.5 to 9.0
Daily
G
Oil and Grease
500 M IL
Weekly/ I Day
G
COD
Monitor
Daily
C
E

Tom Reeder, Director
December 16, 2013
Paae 3
Potential Violations
Multiple Analysis of Same Sample without Notation
The facts, circumstances, and accuracy of each of these allegations are all under
review. However, based on the facts developed to date, it appears that the practices for
laboratory testing and reporting of compliance samples may have deviated from or violated
Smithfield Clinton company policy, North Carolina laboratory certification regulations and the
IUP issued by the City under the provisions of North Carolina General Statutes § 143-215.1.
Smithfield Clinton has taken immediate corrective measures and is continuing its investigation
of this, which includes reviewing each element of its compliance sampling and laboratory testing
at the Clinton Plant.
TSSI Ammonia
On or about October 23, 2013, laboratory analysis was being conducted for IUP
compliance from composite samples gathered on October 22, 2013. A laboratory analyst
("Analyst") alleges that TSS testing and solids were out of compliance (high). Analyst alleges
that the immediate supervisor ("Supervisor") saw that the values were high and Supervisor ran
another test on the same sample with a different result (compliant). It is alleged, that there was
no mention of multiple laboratory tests with different results kept on file in the bench sheets or
laboratory records, Discussions I had with Lisa Osthues on December 16, 2013, indicate that
the Plant actually received a Notice of Violation ("NOV") on November 18, 2013, for Plant TSS
exceedences from October 23, 2013.
On or about November 8, 2013, the same Analyst was allegedly running UP compliance
samples and got a reading that was slightly out of compliance for ammonia (2,402 lbs./day),
When the Supervisor was notified, the Supervisor ran the same sample again and found it was
compliant for ammonia (2,195 Ibs.lday).
While the precise number and extent of any testing .and re -testing events is unclear,
when interviewed on December 12, 2013, the Supervisor said there were possibly re -testing
non -compliant samples from the Analyst an estimated ten (10) times in the about the past two
(2) years for either TSS or ammonia. This number was an estimate and is not verified.
pH
It has been alleged that pH sampling may have routinely been conducted by sampling
for pH compliance until a compliant sample was obtained under the idea that pH compliance
could be achieved on a 15-minute rolling time frame from the time of sample collection. While
this general practice has been discussed and confirmed with Lisa Osthues, she indicated that
non -compliant pH samples should be reflected in the operator log. Notation in the operator log
has neither been confirmed nor refuted yet through investigation but will be the subject of further
review and correction as necessary.
On or about November 6, 2013, there was some delay in receipt of lime used for
process neutralization and pH control at the Plant. It has been alleged that during this delay the
Q

Tom Reeder, Director
December 16, 2013
Page 4
pH of water being discharged to the City was averaging 4.8 (which was out of compliance with
the IUP). The operator attempted to use "caustic" to correct the issue but the pumping system
was not operating properly. It has been alleged that pH was allowed to remain out of
compliance for longer than fifteen (15) minutes and possibly for as long as four (4) hours until
the lime truck arrived. It has been alleged that this may have caused problems for the City
WPCF but it is not known if this caused an occurrence of non-compliance for the City.
Flow Meter
It has been alleged that the flow meter at the Clinton Facility is not properly calibrated.
This allegation is based primarily on observation made of the amount of water withdrawn from
the production wells compared to the amount of metered effluent flow by the meter. There are
numerous other explanations for the difference in measured. pretreated effluent flow monitoring
and water withdrawal. This would primarily impact billing between Smithfield Clinton and the
City WPCF but this could also potentially impact computation of daily load. Discussion with Lisa
Osthues confirms a variety of other possible explanations in the difference and further confirms
that there is little likelihood that there is actually a problem with the flow meter as it is regularly
calibrated. Nevertheless, Smithfield Clinton intends to thoroughly research the facts behind this
allegation and report its findings as a supplement to this report.
Contained Spill of Process Chemical
A contained spill of process chemical (H2SO4) that was not released to the environment
occurred on or about October 31, 2013. A question was first raised internally at Smithfield
Clinton concerning the level and type of response to the contained event. It is believed that the
acid was contained, neutralized and then soaked up with some biological material before being
stored in a manner that would prevent release to the environment. In our phone conversation
on December 16, 2013, this occurrence was discussed with Lisa Osthues who asked additional
questions and expressed her professional concerns. Smithfield Clinton is committed to making
a response that is responsible, legally compliant, and satisfactory to the Department and the
City and will cooperate in a response that meets any specific area of concern.
Smithfield Clinton believes that process chemical is currently contained to an area on a
paved surface and safely stored pending ultimate disposal and that this process chemical poses
no unreasonable threat of release to the environment. Nevertheless, Smithfield Clinton is
committed to responsible and compliant environmental practices and in the process of
determining the ultimate disposal method that is both safe and compliant. Smithfield Clinton
understands the Department or the City may have questions or input and welcomes the
opportunity to discuss preferred responses or to clarify points of information for the Department
or the City. This will be the subject of a supplement to this letter if needed or requested.
Disclosure Policy Conditions
The following address each of the conditions for penalty mitigation set forth in Section A
of the "Policy" section of the Disclosure Policy:
4

Tom Reeder, Director
December 16, 2013
Page.5
The deficiency was not due to a lack of good faith efforts to understand or
comply with applicable environmental, health or safety laws, or a lack of
good faith efforts to correct past deficiencies.
The IUP requires Smithfield Clinton to report all data run with the proper test methods, at
the defined sample point, and using correct sample protocol (grab or composite). Smithfield
Clinton employs environmental professionals for Plant personnel to contact with questions. A
certified laboratory requires training and both the Analyst and Supervisor are believed to have
had the required training. Smithfield Clinton employees are required to take annual online
ethics training. Smithfield Clinton has an internal electronic reporting system, if results are
within 10% of permit limit, and if they are out of compliance. The Supervisor would likely have
attended annual Smithfield Clinton environmental conferences where permit compliance is
emphasized.
2. The deficiency was not done knowingly and willfully.
If either the laboratory analyst or the immediate supervisor is found to have knowingly or
willfully violated state law or permit conditions, then those actions would fall beyond the scope of
their employment and outside the bounds of Smithfield Clinton policy and procedure.
3. The deficiency did not cause a significant harm to the environment or risk
to public health.
The alleged or potential violations disclosed in this letter did not result in any actual harm
(serious or otherwise) and did not present an imminent and substantial endangerment to human
health or the environment. The violations also did not violate any judicial order, administrative
order, or consent agreement.
4. The regulated person or entity voluntarily notifies the Department of the
deficiency before the Department learns of it and completely discloses the
deficiency to the Department in writing. A disclosure is not considered to
be "voluntary" if (i) that disclosure is required by law, regulation or permit
and if (ii) self -monitoring for such deficiency is required of a facility or part
of a facility.
Smithfield Clinton's discovery and reporting of the potential for irregularities and alleged
or possible violations is purely voluntary. These discoveries were not the result, direct or
indirect, of any monitoring or document review process prescribed by statute, regulation, permit,
judicial or administrative order, consent agreement, or any other authority or compulsory
process.
Smithfield Clinton voluntarily and promptly notified the Department and the City of these
matters by telephone calls by Benne Hutson to Tom Reeder, Director and Matt Mathews, Water
Quality Section Chief for the North Carolina, Division of Water Resources on December 16,
2013, and my calls to Jeff Vreugdenhil, City of Clinton, Public Works & Utilities Director and Lisa
Osthues, Environmental Programs Manager all on December 16, 2013. This letter constitutes
Smithfield Clinton's initial written disclosure of this matter based on its investigation to date.
A

Tom Reeder, Director
December 16, 2013
Page 6
Neither of the conditions cited in the Disclosure Policy as rendering a disclosure as not
"voluntary" apply.
S. The regulated person or entity, upon discovery of the deficiency, takes
immediate and effective action under appropriate technical supervision to
cease or remediate any continuing violation, avoid repeated violations, and
remediate the deficiency or where appropriate, agrees in writing with the
Department to take those' steps needed to address the deficiency in a
manner that is acceptable to the Department.
As a result of the events described in this letter, Smithfield Clinton has removed both the
Analyst and Supervisor from duties during the pendency of this investigation. A certified third -
party laboratory services vendor has been retained to conduct UP compliance sampling.
Smithfield Clinton is not only reviewing these allegations, but also its practices, policies and
procedures for compliance sampling and laboratory analysis at the Clinton Plant, Smithfield
Clinton is vitally interested in preventing any recurrence of any violation.
6. Other Considerations.
a. No Repeat Violations.
Smithfield Clinton has not previously experienced a violation of this nature at this facility.
Smithfield Clinton did receive one Notice of Violation on November 18, 2013, from the City for
TSS exceedences occurring on October 23, 2013. Smithfield Clinton was assessed a penalty
point value of 0.5 for this single, minor violation. There is no basis for any claim of a pattern of
federal, state, or local violations by Smithfield Clinton. Smithfield Clinton has not previously
sought or received penalty mitigation from NCDENR or any federal or local agency for a
violation of solid or hazardous waste management laws or regulations.
b. Discovery and Disclosure Independent of Government or Third Party
Plaintiff.
The events and circumstances described in this letter were discovered and reported
solely as. a result of actions by Smithfield Clinton and its internal review of any allegations.
Smithfield Clinton's disclosure was not prompted by government complaint, citizen suit, or third
party plaintiff.
C. Cooperation.
In discovering and disclosing the alleged or possible violations described in this letter,
Smithfield Clinton has fully complied with the Disclosure Policy and its requirements. Smithfield
Clinton stands ready to provide information and otherwise cooperate fully with the Department
or the City in any further review or investigation of this matter.
Based on the considerations discussed above, Smithfield Clinton believes that it has met
the requirements for penalty mitigation set forth in the Disclosure Policy. Again, we would be
happy to answer any questions or provide information needed for the review of this matter.
9

Tom Reeder, Director
December 16, 2013
Page 7
I am available to discuss any aspect of this disclosure at the following numbers:
804.775,4710 (Direct) or 804.887.0778 (Mobile).
dML, �� Sincerely,
5.
DOL/ Gj
Dale G. Mullen
DGM
cc: Matt Matthews, Water Quality Section Chief
Joseph Wiggins, Section Chief, Chemistry Laboratory
Jeff Vreugdenhil, City of Clinton, Public Works & Utilities Director
Lisa Osthues, City of Clinton, Environmental Programs Manager
7

Smith�eld.
December 4, 2013
NC Department of Environment and Natural Resources
Division of Energy, Mineral and Land Resources
Stormwater Permitting Unit
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Mr. Mike Lawyer/Stormwater Unit
Fayetteville Regional Office
225 Green Street
Suite 714
Fayetteville, North Carolina 28301-5095
P0Box 49
Clinton, NC 28329
[phone] tel
(910) 592-741 l fax
DEC 9 2013
RE: Assessment of Best Management Practices for Facilities that Use or Process Animal Fats/ Byproducts
Smithfield/ Farmland — Clinton, NC
Certificate of Coverage No. 060139
Gentlemen:
Enclosed are a narrative description of material handling activities conducted at the Smithfield/ Farmland facility
located at 424 East Railroad Street in Clinton, North Carolina and a feasibility evaluation as to whether reduced
exposure can be achieved at the site. A proposed corrective action plan is also enclosed. These documents are
being submitted as required under Part II Section E: Assessment of BMPs of the North Carolina DENR General
Storm Water Permit No. NCG060000, for facilities handling rendered fats and oils.
If you have questions or concerns, please contact me at 910-299-3000, or Susan Murphy at Smithfield- Farmland at
816-243-2730.
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.
Sincerely,
'�4�
Jeff Wall
Clinton Plant Manager
Enclosures:
• Material Handling Activities and Reduced Exposure Evaluations
• Proposed Corrective Action Plan

Assessment of Best Management Practices
The following is a narrative description of the industrial activities performed in 16 management areas of
the plant, potential avenues of stormwater contamination, and Best Management Practices (BMPs) in
place to reduce or eliminate stormwater contact with significant materials and activities.
Facilitv Wide Implemented BMPs
o Pest Management
■ Applications and maintenance by licensed contractor
■ Bait stations for rodent control are protected from stormwater
a Employee Training
■ Annually
o Inspections
■ Monthly
Area 1— East Shipping Dock & Lard Loadout
Activities
o Boxed products loaded onto trailers DEC 9 2013
o Lard loaded from overhead tanks into tankers
o Smokehouse stacks on roof
Control Measures Implemented
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling operating procedures
o Minimizing exposure
■ Trailer loading is under cover
■ Lard loading is under cover
o Operation and Maintenance
■ Delivery drivers stay with trucks during transfer operations
■ Delivery drivers monitor hose connections
■ Security guard shack at East Shipping Dock staffed 2417
■ Drop inlet catch basins in the lard loadout are covered with drain mats
during transfer operations
• Unloading and loading operating procedures
■ Equipment checked regularly, leaks cleaned up immediately, and repairs
completed as soon as possible
■ Routine maintenance and inspection of air emissions control equipment
o Spill Prevention and Response
• SPCC plan and employee training for oil products
■ HazComm and Spill Response Procedures
■ Absorbent materials readily available
Area 2 -JP Maintenance Dock, Fuel Oil Receiving, & Bulk Salt Storage
• Activities
o Trailer unloading
o No.6 fuel oil unloading

o Bulk salt receiving
Control Measures Implemented
o Structural
■ Bulk salt tanks and brine tank in secondary containment that drains to wastewater
o Good Housekeeping
■ Fugitively released salt cleaned up as needed.
■ Waste handling SOPS
■ Routine inspections of tanks and piping
o Minimizing exposure
■ Trailer unloading under roof
o Operation and Maintenance
■ Delivery drivers required to stay with trucks during transfer operations
■ Delivery drivers monitor hose connections
• Unloading and loading SOPS
■ Equipment checked regularly, leaks cleaned up immediately, and repairs
completed as soon as possible
• Unloading and loading SOPS
■ Containers are clearly labeled with contents
o Spill Prevention and Response
• SPCC for oil products
■ HazComm and Spill Response Procedures
■ Absorbent stored in Parts Room and available throughout the plant
Area 3 - Unuaved Vehicle Parkina, BTL Shipoinq Dock. Air Compressors, Break Area. Trash
Compactor, and Ootfa_II #1
• Activities
o Truck and trailer parking on unpaved (graveled) area
o Product loading dock
o Air compressors on pad in containment
o Unloading of diesel fuel for fire suppression system
o Break area outside the cafeteria
o Waste collection
o Stormwater discharge at Outfall #1
• Control Measures Implemented
o Structural
■ Retaining wall between unpaved (graveled) parking area and loading dock
■ Air compressors on an elevated concrete pad with a containment wall
■ Break area under roof
■ Diesel fuel tank in secondary containment inside building
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling SOPs
■ Routine inspections of the area
o Minimizing exposure
• Covered shipping docks
• Enclosed trash compactor

o Operation and Maintenance
■ Trucks and equipment checked regularly for leaks
• Leaks cleaned up and sujuesrepaired as -soon as possible.
■ Delivery drivers stay with trucks during transfer operations
■ Unloading and loading SON including operator handling & transporting
■ Containers clearly labeled with contents
■ Equipment monitored for small leaks, prompt cleanup and leaks repaired
o Spill Prevention and Response
■ SPCC for oil products
• HazComm and Spill Response Procedures
■ Absorbent materials in the Parts Room
Area 4- Livestock Receiving Area
• Activities
o Live animal unloading
• Control Measures Implemented
o Structural
■ Trench drain to wastewater treatment from the loading dock area
o Good Housekeeping
■ Daily housekeeping
o Minimizing exposure
■ Covered animal unloading chutes
o Spill Prevention and Response
• SPCC for oil products
■ HazComm and Spill Response Procedures
• Absorbent materials in Central Receiving and Wastewater
o Management of Runoff
■ Drop Inlet Catch basins direct runoff to a containment pit at Outfall #2; a minimum
of 30 minutes, storm water is pumped to the wastewater treatment plant, before
there is a storm water flow at the Outfall
Area 5-Central Receiving Warehouse & Scrao Metal Dumoster
• Activities
o Receiving area for drums and totes of detergents
o Scrap metal accumulation
• Control Measures Implemented
a Structural
o Good Housekeeping
■ Regular pickup and disposal of scrap metal
■ Waste handling SOPs
■ Routine inspections of drums, tanks, containers
o Minimizing exposure
■ Covered unloading dock
o Operation and Maintenance
• Unloading and loading SOPS
■ Containers clearly labeled with contents

• Containers closed
■ Operator training on handling & transporting
o Spill Prevention and Response
• SPCC for oil products
■ HazComm and Spill Response Procedures
■ Drums and totes stored on secondary containment inside the warehouse
■ Absorbent materials in warehouse
Area 6 -Propane Storage, Used Equipment Storage, and Outfall #2
• Activities
o Outside scrap metal and used equipment storage
o Tractor trailer parking
o Stormwater retention pit, first flush pumping, and discharge
Control Measures Implemented
o Structural
o Good Housekeeping
■ Regular disposal of scrap materials
■ Waste handling SOPs
o Minimizing exposure
• Fluids drained from all used equipment
o Operation and Maintenance
■ Hoses checked for potential methanol leaks
■ Equipment replaced or repaired if leaks are discovered
o Spill Prevention and Response
■ HazComm and Spill Response Procedures
■ Absorbent materials at Central Receiving
Area 7—Rendering & Live Haul Staging
• Activities
o Live animal truck staging area
o Truck and trailer parking prior to loading with rendered materials
o Yellow grease tank load -out
o Unloading of inedibles
o Chemical unloading and storage
o Waste collection in open trash containers
o Rendering and byproduct storage
• Potential Pollutants
o BOD, TSS, oil & grease, TKN, fecal coliforms, and pH
• Control Measures Implemented
o Structural
■ Trench drain outside door at load -out to wastewater
■ Grease tanks, diesel tank and chemical tanks within secondary containment that is
drained to wastewater treatment
• Inedible floor bin area sloped to a trench drain that flows into the rendering
building

■ Concrete wall along the north, northwest side of the rendering building to redirect
any material that leaks outside the building back into the building to enter the
rendering process
■ Asphalt on the east side built up to redirect any wash down water back into the
rendering building to be coffected and pumped to the wastewater pretreatment
■ Trench drain also collects materials that may leak and transfers to wastewater
• Open trash container area flows to wastewater
o Good Housekeeping
• Removal of fugitive materials
• Waste handling SOPs
■ Recycling or proper disposal of drums that accumulate
a Minimizing exposure
■ Loading rendered byproducts inside with bay open on the west side only
■ Inedible floor bin area is partially roofed
o Operation and Maintenance
■ Delivery drivers required to stay with trucks during transfer operations
■ Unloading and loading SOPs
■ Containers clearly labeled with contents
■ Pumps, equipment and connections are checked regularly for leaks and repaired
as soon as possible
■ Containers are closed
o Spill Prevention and Response
• SPCC for oil products
■ HazComm and Spill Response Procedures
• Absorbent materials available at wastewater
o Management of Runoff
• Drop Inlet Catch basins direct runoff to a containment pit at Outfall #2; a minimum
of 30 minutes, storm water is pumped to the wastewater treatment plant, before
there is a storm water flow at the Outfall
• Concrete berm on south side directs runoff on the paved driveway towards
wastewater system drains
Area 8-Wastewater
• Activities
o Truck and trailer parking
o Open top trailer parking
o Sludge loading
o Fuel and chemical unloading
o Fuel and chemical storage
o Empty drum and tote storage
a Wastewater pretreatment
• Control Measures Implemented
o Structural
• Sludge spilled in this area routed to drains which go to wastewater
■ Fuel and chemical tanks and associate piping located in secondary containment
■ Secondary containment drains to wastewater
o Good Housekeeping

■ Regular pickup and disposal of garbage and waste materials
■ Regular disposal of empty drums
■ Regular totes pickup by vendors
o Minimizing exposure
■ Sludge loading under cover
o Operation and Maintenance
■ Proper cleaning of drums and totes & storage in designated areas
■ Delivery drivers required to stay with trucks during transfer operations to observe
hoses and hose connections
■ Unloading and loading SOPs
■ Containers clearly labeled with contents
■ Containers closed
■ Tanks, containers, and piping inspected regularly and repaired as needed
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
■ Spill response materials located in wastewater
o Management of Runoff
■ Runoff diverted to wastewater treatment
Area 9— Blood P l a s m a Loadout
• Activities
o Blood Plasma loading
o Backup blood plasma load -out
• Potential Pollutants
o BOD, TKN, oil & grease, and pH
• Control Measures Implemented
o Structural
■ Blood plasma load -out located in secondary containment that drains to wastewater
treatment
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling SOPs
o Operation and Maintenance
■ Drivers required to stay with trucks during transfer operations
■ Equipment connections are checked regularly for leaks
■ Equipment leaks repaired as soon as possible
■ Loading SOPs
o Spill Prevention and Response
■ HazComm and Spill Response Procedures
■ Spill response materials available at wastewater treatment
Area 10 ---Casings & Wastewater Tank
• Activities
o Wastewater collection tank
o Casings production

Potential Pollutants
o BOD, TSS, oils and grease, TKN, fecal coliforms, and pH
Control Measures Implemented
o Structural
■ Elevated loading dock has a trench drain that leads to a containment that drains
to the wastewater treatment plant.
■ Trench drains at the top of casing load -out ramp that drains via a trough to the
drum concrete containment area.
• Bulk chemical tanks and casing drums in secondary containment that drains to
wastewater
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling SOPs
• Routine inspections of drums, tanks, containers
o Minimizing exposure
o Operation and Maintenance
■ Delivery drivers stay with trucks during transfer operations
■ Unloading and loading SOPs
• Containers clearly labeled with contents
■ Containers kept closed
■ Routine inspections of tanks and piping
o Spill Prevention and Response
■ HazComm and Spill Response Procedures
■ Spill response materials available at wastewater
o Management of Runoff
• Grassy area allows permeation of storm water
Areal I - Hydraulic Compressor Area
Activities
o Hydraulic fluid transfer to recycling
• Control Measures Implemented
o Structural
■ Trench drain to secondary containment with pump to transfer leaked fluid to a tote
■ Tote of leaked fluid and water is staged on secondary containment
o Good Housekeeping
■ Waste handling SOPs
o Minimizing exposure
■ Hydraulic system located inside metal storage building
o Operation and Maintenance
■ Routine inspection of tote and secondary containment and transfer to recycling
o Spill Prevention and Response
• SPCC for oil products
• HazComm and Spill Response Procedures
Area 12-Used Oil Storage
0 Activities

o used oil transfer and storage
Control Measures Implemented
o Structural
• Berm around outside transfer area
• Used oil tank in secondary containment
o Good Housekeeping
■ Routine inspections of drums, tanks, containers
o Minimizing exposure
■ Roof over tank and containers
o Operation and Maintenance
■ Operator training on handling & transporting
■ Containers clearly labeled with contents
■ Containers closed
o Spill Prevention and Response
• SPCC for oil products
■ HazComm and Spill Response Procedures
• Absorbent materials at wastewater
Area 13 -Truck Wash Bay and Outside Wash Pad
Activities
o Live haul trailer washing
■ Enclosed trailer wash
■ Outside concrete wash pad
■ Solids collection equipment and loadout
Control Measures Implemented
o Structural
■ Concrete wash pad is sloped to a drain which leads to wastewater,
■ Enclosed wash bay has drains that flow to wastewater
o Good Housekeeping
■ Waste handling SOPs
■ Routine inspections of drums, totes and containers
o Spill Prevention and Response
■ HazComm and Spill Response Procedures
Area 14-Trash Dock, Bulk Sanitation Chemical Storage, Inedible Load -out, Microwave Grease
Storage & Liquid Smoke Storage
Activities
o Shipping of recyclables and pallets
o Unloading bulk sanitation chemicals
o Inedible load -out
o Grease collection from microwave cooking of bacon
o Liquid smoke storage
o Break area
• Control Measures Implemented
o Structural
■ Area drains to wastewater treatment

■ The inedible load -out area surrounded by containment that drains to wastewater
treatment
■ Two grease tanks for microwave bacon process and liquid smoke tank located in
secondary containment
• Grease tank and liquid smoke containment is pumped to wastewater treatment
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling SOPs
■ Routine inspections of drums, tanks, containers
o Minimizing exposure
■ Enclosed trash compactor
■ Covered recyclables loading dock
• Covered conveyor for inedible transfer to dump trucks
o Operation and Maintenance
■ Delivery drivers stay with trucks during transfer operations
• Equipment and connections checked for leaks
• Unloading SOPs
■ Containers clearly labeled with contents
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
■ Absorbent materials -- Chem. Room, LPC Eng. Room, WW & 701 security office
Area 15 -Fuel Island, Fuel Storage & Trailer Parkin
• Activities
o Fuel storage
a Company vehicle fueling
o Truck and trailer parking
• Control Measures implemented
o Structural
■ Fuel storage tanks and piping located inside secondary containment
• Oil water separator collection system surrounding fueling island
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling SOPs
o Minimizing exposure
■ Covered fuel area
o Operation and Maintenance
■ Delivery drivers required to stay with trucks during transfer operations
• Unloading and loading SOPs
• Containers clearly labeled with contents
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
■ Absorbent materials stored at fuel island
o Management of Runoff

• Oil water separator
Area 16-Employee Parking Lots
Activities
o Employee parking
• 701 parking on southeast corner of property (graveled)
■ Employee parking across Railroad Street north of the plant (graveled)
■ BLT paved parking
Control Measures Implemented
o Good Housekeeping
• Regular pickup and disposal of garbage and waste materials
■ Some parking lots allow the permeation of storm water to slow down runoff
Evaluation of wildlife/ animals on -site:
Numerous birds (pigeons) have been observed at the East Loading Dock and at Rendering. 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.

DEC 9 2013
Assessment of Best Management Practices and Proposed Corrective Actions
In addition to continuing to complete (1) paving projects to address TSS and stagnant water removal; (2)
roof cleaning projects and (3) assessment of impact of pumping first flush stormwater to wastewater
pretreament, the following BMPs have been considered for implementation.
Exposed
Feasibility
POTENTIAL Corrective
Rank
Proposed
Activities
Actions
Date of
Completion
Technical
Economic
Outfall #2
Y
Y
Ensure pump to remove first
3
4/15/2014
flush to wastewater is correctly
sized for rainfall runoff,
establish and implement 00
program; implement a backup
Ian
Outfall #2
Y
Y
Implement a regularly
1
6/112014
scheduled cleaning of storm
water collection pit
Loading and
Y
Y
Determine schedule for and
4
Unloading,
implement a sweeping
trailer parking
program to control sediment
Site Wide
Y
Y
Implement a regularly
2
4/15/2014
scheduled cleaning of
accessible storm water drop
inlets and catch basins to
remove sediment.
Unloading &
Y
Y
Discourage pigeons from
4
Rendering
roosting on -site (East Loading
Dock,Rendering)
Loading and
Y
Y
Assess condition of drain inlet
4
Unloading
structures, repair or replace
damaged inlets
Site Wide
Y
Y
Replace drop inlet grates with
2
8/15/2014
more narrow spaced grating to
keep trash out, or implement
matting to filter out sediments
and other pollutants at inlets
where large quantities of
sediment collect

}
-'�4 1F 1� � * P M C 1Y�Y ¢� p•M
November 28, 2013 Clinton Plant
POBox 49
Clinton, NC 28329
NC Department of Environment and Natural Resources [phone] tel
Division of Energy, Mineral and Land Resources [phone] fax
Stormwater Permitting Unit
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Mr. Mike Lawyer/Stormwater Unit
Fayetteville Regional Office
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/ Farmland — Clinton, NC
Certificate of Coverage No. 060139 y
DEC 5 2013
Gentlemen: i I
Enclosed are a narrative description of material handling activities cond`ucted'a't the Sin`itlifield/ I
Farmland facility located at 424 East Railroad Street in Clinton, North Carolina and a feasibility
evaluation as to whether reduced exposure can be achieved at the site. A proposed corrective action
plan is also enclosed. These documents are being submitted as required under Part II Section E:
Assessment of BMPs of the North Carolina DENR General Storm Water Permit No. NCG060000, for
facilities handling rendered fats and oils.
if you have questions or concerns, please contact me at 910-299-3000, or Susan Murphy at Smithfield -
Farmland at 816-243-2730.
Sincerely,
Jeff all
Clinton Plant Manager
Enclosures:
• Material Handling Activities and Reduced Exposure Evaluations
• Proposed Corrective Action Plan

Assessment of Best Management Practices
The following is a narrative description of the industrial activities performed in 16 management areas of
the plant, potential avenues of stormwater contamination, and Best Management Practices (BMPs) in
place to reduce or eliminate stormwater contact with significant materials and activities.
Facility Wide Implemented BMPs
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 1— East ShivDina Dock & Lard Loadout
• Activities
o Boxed products loaded onto trailers
o Lard loaded from overhead tanks into tankers
o Smokehouse stacks on roof -
• Control Measures Implemented
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling operating procedures
DEC 5 2013
o Minimizing exposure
• Trailer loading is under cover
■ Lard loading is under cover
o Operation and Maintenance
■ Delivery drivers stay with trucks during transfer operations
■ Delivery drivers monitor hose connections
■ Security guard shack at East Shipping Dock staffed 2417
■ Drop inlet catch basins in the lard loadout are covered with drain mats
during transfer operations
■ Unloading and loading operating procedures
■ Equipment checked regularly, leaks cleaned up immediately, and repairs
completed as soon as possible
■ Routine maintenance and inspection of air emissions control equipment
o Spill Prevention and Response
■ SPCC plan and employee training for oil products
■ HazComm and Spill Response Procedures
■ Absorbent materials readily available
Area 2 -JP Maintenance Dock Fuel Oil Receiving, & Bulk Salt Storage
• Activities
o Trailer unloading
o No.6 fuel oil unloading

o Bulk salt receiving
Control Measures Implemented
o Structural
■ Bulk salt tanks and brine tank in secondary containment that drains to wastewater
o Good Housekeeping
• Fugitively released salt cleaned up as needed.
i Waste handling SOPs
■ Routine inspections of tanks and piping
o Minimizing exposure
• Trailer unloading under roof
o Operation and Maintenance
■ Delivery drivers required to stay with trucks during transfer operations
■ Delivery drivers monitor hose connections
■ Unloading and loading SON
■ Equipment checked regularly, leaks cleaned up immediately, and repairs
completed as soon as possible
■ Unloading and loading SOPS
■ Containers are clearly labeled with contents
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
■ Absorbent stored in Parts Room and available throughout the plant
Area 3 - Unpaved Vehicle Parkins. BTL ShloDins Dock. Air Compressors. Break Area. Trash
Compactor, and Outfall #1
• Activities
o Truck and trailer parking on unpaved (graveled) area
o Product loading dock
o Air compressors on pad in containment
a Unloading of diesel fuel for fire suppression system
o Break area outside the cafeteria
o Waste collection
o Stormwater discharge at Outfall #1
• Control Measures Implemented
o Structural
■ Retaining wall between unpaved (graveled) parking area and loading dock
■ Air compressors on an elevated concrete pad with a containment wall
■ Break area under roof
■ Diesel fuel tank in secondary containment inside building
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
• Waste handling SOPs
■ Routine inspections of the area
o Minimizing exposure
■ Covered shipping docks
■ Enclosed trash compactor

o Operation and Maintenance
■ Trucks and equipment checked regularly for leaks
• Leaks cleaned up and sDAes repaired as -soon as possible.
• Delivery drivers stay with trucks during transfer operations
• Unloading and loading SON including operator handling & transporting
■ Containers clearly labeled with contents
■ Equipment monitored for small leaks, prompt cleanup and leaks repaired
o Spill Prevention and Response
• SPCC for oil products
■ HazComm and Spill Response Procedures
■ Absorbent materials in the Parts Room
Area 4- Livestock Receiving Area
Activities
o Live animal unloading
Control Measures Implemented
o Structural
• Trench drain to wastewater treatment from the loading dock area
o Good Housekeeping
■ Daily housekeeping
o Minimizing exposure
■ Covered animal unloading chutes
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
• Absorbent materials in Central Receiving and Wastewater
o Management of Runoff
Drop Inlet Catch basins direct runoff to a containment pit at Outfall #2; a minimum
of 30 minutes, storm water is pumped to the wastewater treatment plant, before
there is a storm water flow at the Outfall
Area 5-Central Receivina Warehouse & ScraD Metal Dumoster
• Activities
o Receiving area for drums and totes of detergents
o Scrap metal accumulation
• Control Measures Implemented
o Structural
o Good Housekeeping
■ Regular pickup and disposal of scrap metal
• Waste handling SOPS
■ Routine inspections of drums, tanks, containers
o Minimizing exposure
■ Covered unloading dock
o Operation and Maintenance
• Unloading and loading SOPS
■ Containers clearly labeled with contents

■ Containers closed
■ Operator training on handling & transporting
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
■ Drums and totes stored on secondary containment inside the warehouse
■ Absorbent materials in warehouse
Area 6—Prooane Storaae. Used Eauioment Storaae, and Outfali #2
• Activities
o Outside scrap metal and used equipment storage
o Tractor trailer parking
o Stormwater retention pit, first flush pumping, and discharge
• Control Measures Implemented
o Structural
o Good Housekeeping
■ Regular disposal of scrap materials
■ Waste handling SOPs
o Minimizing exposure
■ Fluids drained from all used equipment
o Operation and Maintenance
■ Hoses checked for potential methanol leaks
■ Equipment replaced or repaired if leaks are discovered
o Spill Prevention and Response
■ HazComm and Spill Response Procedures
■ Absorbent materials at Central Receiving
Area T—Rendering S Live Haul Staging
• Activities
o Live animal truck staging area
o Truck and trailer parking prior to loading with rendered materials
o Yellow grease tank load -out
o Unloading of inedibles
o Chemical unloading and storage
o Waste collection in open trash containers
o Rendering and byproduct storage
• Potential Pollutants
o BOD, TSS, oil & grease, TKN, fecal coliforms, and pH
• Control Measures Implemented
o Structural
■ Trench drain outside door at load -out to wastewater
■ Grease tanks, diesel tank and chemical tanks within secondary containment that is
drained to wastewater treatment
■ Inedible floor bin area sloped to a trench drain that flows into the rendering
building

■ Concrete wall along the north, northwest side of the rendering building to redirect
any material that leaks outside the building back into the building to enter the
rendering process
■ Asphalt on the east side built up to redirect any wash down water back into the
rendering building to be collected and pumped to the wastewater pretreatment
■ Trench drain also collects materials that may leak and transfers to wastewater
■ Open trash container area flows to wastewater
o Good Housekeeping
■ Removal of fugitive materials
• Waste handling SOPs
■ Recycling or proper disposal of drums that accumulate
o Minimizing exposure
■ Loading rendered byproducts inside with bay open on the west side only
■ Inedible floor bin area is partially roofed
o Operation and Maintenance
■ Delivery drivers required to stay with trucks during transfer operations
■ Unloading and loading SOPs
■ Containers clearly labeled with contents
■ Pumps, equipment and connections are checked regularly for leaks and repaired
as soon as possible
■ Containers are closed
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
■ Absorbent materials available at wastewater
o Management of Runoff
■ Drop Inlet Catch basins direct runoff to a containment pit at Outfall #2; a minimum
of 30 minutes, storm water is pumped to the wastewater treatment plant, before
there is a storm water flow at the Outfall
■ Concrete berm on south side directs runoff on the paved driveway towards
wastewater system drains
Area 8-Wastewater
• Activities
o Truck and trailer parking
o Open top trailer parking
o Sludge loading
o Fuel and chemical unloading
o Fuel and chemical storage
a Empty drum and tote storage
o Wastewater pretreatment
• Control Measures Implemented
o Structural
■ Sludge spilled in this area routed to drains which go to wastewater
■ Fuel and chemical tanks and associate piping located in secondary containment
• Secondary containment drains to wastewater
o Good Housekeeping

■ Regular pickup and disposal of garbage and waste materials
■ Regular disposal of empty drums
■ Regular totes pickup by vendors
o Minimizing exposure
■ Sludge loading under cover
o Operation and Maintenance
■ Proper cleaning of drums and totes & storage in designated areas
■ Delivery drivers required to stay with trucks during transfer operations to observe
hoses and hose connections
■ Unloading and loading SOPs
■ Containers clearly labeled with contents
■ Containers closed
• Tanks, containers, and piping inspected regularly and repaired as needed
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
■ Spill response materials located in wastewater
o Management of Runoff
■ Runoff diverted to wastewater treatment
Area 9— Blood P l a s m a Loadout
• Activities
o Blood Plasma loading
o Backup blood plasma load -out
• Potential Pollutants
o BOD, TKN, oil & grease, and pH
• Control Measures Implemented
o Structural
■ Blood plasma load -out located in secondary containment that drains to wastewater
treatment
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling SOPs
o Operation and Maintenance
■ Drivers required to stay with trucks during transfer operations
■ Equipment connections are checked regularly for leaks
■ Equipment leaks repaired as soon as possible
■ Loading SOPs
o Spill Prevention and Response
■ HazComm and Spill Response Procedures
■ Spill response materials available at wastewater treatment
Area 10 —Casings & Wastewater Tank_
• Activities
o Wastewater collection tank
o Casings production

• Potential Pollutants
o BOD, TSS, oils and grease, TKN, fecal coliforms, and pH
• Control Measures Implemented
o Structural
■ Elevated loading dock has a trench drain that leads to a containment that drains
to the wastewater treatment plant.
■ Trench drains at the top of casing load -out ramp that drains via a trough to the
drum concrete containment area.
■ Bulk chemical tanks and casing drums in secondary containment that drains to
wastewater
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling SOPS
■ Routine inspections of drums, tanks, containers
o Minimizing exposure
o Operation and Maintenance
■ Delivery drivers stay with trucks during transfer operations
• Unloading and loading SOPS
■ Containers clearly labeled with contents
• Containers kept closed
• Routine inspections of tanks and piping
o Spill Prevention and Response
■ HazComm and Spill Response Procedures
■ Spill response materials available at wastewater
o Management of Runoff
■ Grassy area allows permeation of storm water
Area 11 - Hvdraulic Compressor Area
• Activities
o Hydraulic fluid transfer to recycling
• Control Measures Implemented
o Structural
■ Trench drain to secondary containment with pump to transfer leaked fluid to a tote
■ Tote of leaked fluid and water is staged on secondary containment
o Good Housekeeping
■ Waste handling SOPs
o Minimizing exposure
■ Hydraulic system located inside metal storage building
o Operation and Maintenance
■ Routine inspection of tote and secondary containment and transfer to recycling
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
Area 12-Used Oil Storage
Activities

o used oil transfer and storage
Control Measures Implemented
o Structural
• Berm around outside transfer area
■ Used oil tank in secondary containment
o Good Housekeeping
■ Routine inspections of drums, tanks, containers
o Minimizing exposure
■ Roof over tank and containers
o Operation and Maintenance
■ Operator training on handling & transporting
■ Containers clearly labeled with contents
• Containers closed
o Spill Prevention and Response
■ SPCC for oil products
• HazComm and Spill Response Procedures
■ Absorbent materials at wastewater
Area 13 -Truck Wash Bay and Outside Wash Pad
• Activities ^
o Live haul trailer washing
■ Enclosed trailer wash
■ Outside concrete wash pad
■ Solids collection equipment and loadout
• Control Measures Implemented
o Structural
■ Concrete wash pad is sloped to a drain which leads to wastewater.
■ Enclosed wash bay has drains that flow to wastewater
o Good Housekeeping
■ Waste handling SOPS
• Routine inspections of drums, totes and containers
o Spill Prevention and Response
■ HazComm and Spill Response Procedures
Area 14-Trash Dock Bulk Sanitation Chemical Storage, Inedible Load -out Microwave Grease
Storage & Liquid Smoke Storage
• Activities
o Shipping of recyclables and pallets
o Unloading bulk sanitation chemicals
o Inedible load -out
o Grease collection from microwave cooking of bacon
o Liquid smoke storage
o Break area
• Control Measures Implemented
o Structural
■ Area drains to wastewater treatment

The inedible load -out area surrounded by containment that drains to wastewater
treatment
■ Two grease tanks for microwave bacon process and liquid smoke tank located in
secondary containment
■ Grease tank and liquid smoke containment is pumped to wastewater treatment
o Good Housekeeping
• Regular pickup and disposal of garbage and waste materials
■ Waste handling SOPS
• Routine inspections of drums, tanks, containers
o Minimizing exposure
■ Enclosed trash compactor
■ Covered recyclables loading dock
• Covered conveyor for inedible transfer to dump trucks
o Operation and Maintenance
■ Delivery drivers stay with trucks during transfer operations
■ Equipment and connections checked for leaks
• Unloading SOPS
■ Containers clearly labeled with contents
o Spill Prevention and Response
■ SPCC for oil products
• HazComm and Spill Response Procedures
■ Absorbent materials — Chem. Room, LPC Eng. Room, WW & 701 security office
Area 15 -Fuel Island Fuel Stora e & Trailer Parkin
• Activities
o Fuel storage
o Company vehicle fueling
o Truck and trailer parking
• Control Measures Implemented
o Structural
■ Fuel storage tanks and piping located inside secondary containment
■ Oil water separator collection system surrounding fueling island
o Good Housekeeping
■ Regular pickup and disposal of garbage and waste materials
■ Waste handling SOPs
o Minimizing exposure
■ Covered fuel area
o Operation and Maintenance
■ Delivery drivers required to stay with trucks during transfer operations
■ Unloading and loading SOPs
■ Containers clearly labeled with contents
o Spill Prevention and Response
■ SPCC for oil products
■ HazComm and Spill Response Procedures
■ Absorbent materials stored at fuel island
o Management of Runoff

■ Oil water separator
Area 16- Employee Parking„ Lots
• Activities
o Employee parking
■ 701 parking on southeast corner of property (graveled)
■ Employee parking across Railroad Street north of the plant (graveled)
■ BLT paved parking
• Control Measures Implemented
o Good Housekeeping
• Regular pickup and disposal of garbage and waste materials
• Some parking lots allow the permeation of storm water to slow down runoff
Evaluation of wildlife/ animals on -site:
Numerous birds (pigeons) have been observed at the East Loading Dock and at Rendering. 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.

Assessment of Best Management Practices and Proposed Corrective Actions
In addition to continuing to complete (1) paving projects to address TSS and stagnant water removal; (2)
roof cleaning projects and (3) assessment of impact of pumping first Flush stormwater to wastewater
pretreament, the following BMPs have been considered for implementation.
Exposed
Feasibility
POTENTIAL Corrective
Rank
Proposed
Activities
Actions
Date of
Completion
Technical
Economic
Outfall #2
Y
Y
Ensure pump to remove first
3
4/15/2014
flush to wastewater is correctly
sized for rainfall runoff,
establish and implement 00
program; implement a backup
Ian
Outfall #2
Y
Y
Implement a regularly
1
6/1/2014
scheduled cleaning of storm
water collection pit
Loading and
Y
Y
Determine schedule for and
4
Unloading,
implement a sweeping
trailer parking
program to control sediment
Site Wide
Y
Y
Implement a regularly
2
4/15/2014
scheduled cleaning of
accessible storm water drop
inlets and catch basins to
remove sediment.
Unloading &
Y
Y
Discourage pigeons from
4
Rendering
roosting on -site (East Loading
Dock, Rendering)
Loading and
Y
Y
Assess condition of drain inlet
4
Unloading
structures, repair or replace
damaged inlets
Site Wide
Y
Y
Replace drop inlet grates with
2
8/15/2014
more narrow spaced grating to
keep trash out, or implement
matting to filter out sediments
and other pollutants at inlets
where large quantities of
sediment collect
DEC 5 2013

DENR- FRO
AUK 2 9 2013
Smithf ield.
August 27, 2013
Ms. Belinda Henson
Regional Supervisor -Fayetteville Regional Office
Division of Water Quality
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
SEP 3 2013
Re: Notification of Exceeding Fecal Benchmark Range in Permit No. NCG060000
Stormwater Outfall No.2
Dear Ms. Henson:
OWC).
The Smithfield Clinton Plant received certified laboratory results on August 01, 2013, via
email, that documents exceeding the TSS benchmark range on four occasions at
Stormwater Outfall No. 2. The facility will continue to perform the Tier 1, 2, and 3
requirements in the current permit.
Date
pH
COD
TSS
O&G
Fecal
12/5/12
7.20
122
23.8
5
1182
01/11/13
7.29
91
89
6
56000
02/23/13
7.54
116
132
7
60000
03/24/13
8.69
60
41.9
5
48000
04/12/2013
8.8
414
345
8
38000
05/ 19/2013
6.92
215
153
10
60000
06/ 17/2013
7.52
243
56
5
60000
7/09/2013
7.29
90
138
48
120000
The facility is currently working on or has completed the following BMPs to address
meeting the benchmark range(s) in the current permit.
• Dye Testing Drains
• Started Smoke Testing storm drains around the site on Sunday, July
28, 2013, No cross connections were identified around the Rendering
Facility and Casings Building drains tested.
• Removing & replacing deteriorated asphalt with concrete in specific
areas and pavement on Southwest side of the facility.
• Ceased all dry weather discharges from Outfall No. 2
• Pumping first flush from rain events to the onsite wastewater
pretreatment system for treatment and disposal into the POTW's
collection system.

• Extended the first flush pump time to attempt to improve stormwater
discharge. The pump is operated in automatic until it volume of
precipitation is greater than what the pump can pump and discharge
from the outfall has started.
• Washing down the Livestock receiving area.
• Redirected some storm drains to prevent dry weather discharges.
• issued PO to Gannett Fleming to include some of the following:
■ Development of Preventive Maintenance & Good
Housekeeping Program
■ Assessment of Best Management Practices
■ Review of Existing Stormwater Controls
• Performing monthly and/or as needed maintenance on the Wastewater
and Stormwater Collection System.
• Employed a Facility Crew to help address housekeeping and maintain
grounds.
• All Secondary Containments are pumped to the facility's wastewater
treatment collection system and/or transported to wastewater for
treatment and disposal.
• Added additional secondary containment structures.
• Minimizing potholes to prevent standing and stagnant water.
• Removing old ductwork and piping on the roof of the Rendering
Building.
• Removed storm drains from high -risk areas.
• installed a high-level alarm in the LPC Side wastewater collection
system.
• Corrected drainage issues at the BTL Shipping & Receiving Dock
• Installed diversion lines on some roof drains to divert precipitation and
dry weather discharge to the wastewater collection system.
• Plugged drain in high-risk/traffic area that discharged to the
stormwater collection system.
Please contact me with any questions or concerns and I will continue to keep Mike
Lawyer current with progress at the facility.
Thank you for working with me on this matter.
Sincerely,
�1 "U
Norman Johnson
Environmental Manager
Smithfield —Clinton Plant
cc: Mike Lawyer, NCDENR

ov
ithfield..
August 12, 2013
Mr. Bradley Bennett
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Transfer Permit Holder and Authorized Representative(s) for NPDES General Permit
NCG060000 Certificate of Coverage NCG060139.
Dear Mr. Bennett:
This letter is to inform you Kyle Narron, General Manager for the Smithfield —Clinton Plant
is no longer the authorized representative for the NPDES General Permit NCG060000.
To comply with the signatory requirements in NPDES General Permit NCG060000, I Jeffrey
Wall, General Manager for the Smithfield —Clinton Plant will be the authorized representative
for the permit.
Additionally, I respectfully request that Michael McNulty, Glenn Clark and Norman Johnson
be approved/given signatory authority for this permit.
Please feel free to contact me with any questions, comments or concerns at [phone].
Since y,
J effre al l
General Manager
Smithfield —Clinton Plant
cc: Files
Charles Wakild, P.E., Director DWQ
Fayetteville Regional Office
Stormwater Permitting Unit
Michael McNulty, Assistant General Manager
Glenn Clark, Director of Operation
Norman Johnson, Environmental Manager
I }
AUG % 6 201E
p rat - wAru QuZin

Smithfield.
August 12, 2013
Mr. Bradley Bennett
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Transfer Permit Holder and Authorized Representative(s) for NPDES General Permit
NCG060000 Certificate of Coverage NCG060139.
Dear Mr. Bennett:
This letter is to inform you Kyle N_arron, General Manager for the Smithfield —Clinton Plant
is no longer the authorized representative for the NPDES General Permit NCG060000.
To comply with the signatory requirements in NPDES General Permit NCG060000, I Je_Je_ ffrey
Wall, General Manager for the Smithfield —Clinton Plant will be the authorized representative
for the permit.
Additionally, I respectfully request that Michael McNulty, Glenn Clark and Norman Johnson
be approved/given signatory authority for this permit.
Please feel free to contact me with any questions, comments or concerns at [phone].
Since y,
Jet e all
General Manager
Smithfield —Clinton Plant
cc: Files
Charles Wakild, P.E., Director DWQ
Fayetteville Regional Office
Stormwater Permitting Unit
Michael McNulty, Assistant General Manager
Glenn Clark, Director of Operation
Nonnan Johnson; Environmental Manager

X91. ' N.N
JUL Z G 2013
Smithf field
July 24, 2013
Ms. Belinda Henson
Regional Supervisor -Fayetteville Regional Office
Division of Water Quality
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Re: Notification of Exceeding Fecal Benchmark Range in Permit No. NCG060000
Stormwater Outfall No.2
Dear M.s. Henson;
The Smithfield Clinton Plant received certified laboratory results on June 28, 2013, via
email, that documents exceeding the COD benchmark range on four occasions at
Stormwater Outfall No. 2. The facility will continue to perform the Tier 1, 2, and 3
requirements in the current permit.
I
Date
pH
COD
TSS
O&G
Fecal
12/5/12
7.20
122
23.8
5
1182
O1/11/13
7.29
91
89
6
56000
02/23/13
7.54
116
132
7
60000
03/24/13
8.69
60
41.9
5
48000
04/12/2013
&8
414
345
8
38000
05/19/2013
6.92
215
153
10
60000
06/17/2013
7.52
243
56
5
60000
The facility is currently working on or has completed the following BMPs to address
meeting the benchmark range(s) in the current permit.
• Dye Testing Drains
• Smoke Testing approved by USDA's. There has to be no Production
for Keen Plumbing to conduct test. Testing is scheduled to start on
July 28, 2013 pending weather permitting and no last minute
production demands.
• Removing & replacing deteriorated asphalt with concrete in specific
areas and pavement on Southwest side of the facility.
• Ceased all dry weather discharges from Outfall No. 2

• Pumping first flush from rain events to the onsite wastewater
pretreatment system for treatment and disposal into the POTW's
collection system.
• Washing down the Livestock receiving area.
• Redirected some storm drains to prevent dry weather discharges.
• Issued PO to Gannett Fleming to include some of the following:
■ Development of Preventive Maintenance & Good
Housekeeping Program
■ Assessment of Best Management Practices
Review of Existing Stormwater Controls
• Performing monthly and/or as needed maintenance on the Wastewater
and Stormwater Collection System.
• Employed a Facility Crew to help address housekeeping and maintain
grounds.
• All Secondary Containments are pumped to the facility's wastewater
treatment collection system and/or transported to wastewater for
treatment and disposal.
• Added additional secondary containment structures.
• Minimizing potholes to prevent standing and stagnant water.
• Removing old ductwork and piping on the roof of the Rendering
Building.
• Removed storm drains from high -risk areas.
• Installed a high-level alarm in the LPC Side wastewater collection
System,
• Corrected drainage issues at the BTL Shipping & Receiving Dock
• Installed diversion lines on some roof drains to divert precipitation and
dry weather discharge to the wastewater collection system.
• Plugged drain in high-risk/traffic area that discharged to the
stormwater collection system.
Please contact me with any questions or concerns and 1 will continue to keep Mike
Lawyer current with progress at the facility.
Thank you for working with me on this matter.
Sincerely,
Norman Johnson
Environmental Manager
Smithfield —Clinton Plant
cc: Mike Lawyer, NCDENR

Smith{ield.
May 9, 2013
Ms. Belinda Henson
Regional Supervisor -Fayetteville Regional Office
Division of Water Quality
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
RECEIVED
Re: Notification of Exceeding Fecal Benchmark Range in Permit No. NCG060000
Stormwater Outfall No.2
Dear Ms, Henson:
The Smithfield Clinton Plant received certified laboratory results on April 09, 2013, via
email, that documents exceeding the Fecal benchmark range on four occasions at
Stormwater Outfall No. 2. The facility will continue to perform the Tier 1, 2, and 3
requirements in the current permit.
Date
PH
COD
TSS
O&G
Fecal
12/5/12
7.20
122
23.8
5
1182
01/11/13
7.29
91
89
6
56000
02/23/13
7.54
116
132
7
60000
03/24/13
8.69
60
41.9
5
48000
04/12/2013
8.8
1414
345
8
1 38000
The facility is currently working on or has completed the following BMPs to address
meeting the benchmark range(s) in the current permit_
• Dye Testing Drains
• Smoke Testing awaiting USDA's approval and Production for
scheduling Keen Plumbing to conduct test.
• Removing & replacing deteriorated asphalt with concrete in specific
areas and pavement on Southwest side of the facility.
• Ceased all dry weather discharges from Outfall No. 2
• Pumping first flush from rain events to the onsite wastewater
pretreatment system for treatment and disposal into the POTW's
collection system.
• Washing down the Livestock receiving area.
• Redirected some storm drains to prevent dry weather discharges.
• Issued PO to Gannett Fleming to include some of the following:

■ Development of Preventive Maintenance & Good
Housekeeping Program
■ Assessment of Best Management Practices
■ Review of Existing Stormwater Controls
• Performing monthly and/or as needed maintenance on the Wastewater
and Stormwater Collection System.
• Employed a Facility Crew to help address housekeeping and maintain
grounds.
• All Secondary Containments are pumped to the facility's wastewater
treatment collection system and/or transported to wastewater for
treatment and disposal.
• Added additional secondary containment structures.
• Minimizing potholes to prevent standing and stagnant water.
• Removing old ductwork and piping on the roof of the Rendering
Building.
• Removed storm drains from high -risk areas.
• Installed a high-level alarm in the LPC Side wastewater collection
system.
• Corrected drainage issues at the BTL Shipping & Receiving Dock
• Installed diversion lines on some roof drains to divert precipitation and
dry weather discharge to the wastewater collection system.
Please contact me with any questions or concerns and I will continue to keep Mike
Lawyer current with progress at the facility.
Thank you for working with me on this matter.
Sincerely,
Norman Johnson
Environmental Manager
Smithfield —Clinton Plant
cc: Mike Lawyer, NCDENR

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
February 14, 2013
Kyle Narron, General Manager
Smithfield Packing Company -Clinton Plant
424 East Railroad Street
Clinton, NC 28328
Subject: COMPLIANCE EVALUATION INSPECTION
Smithfield Packing Company
Clinton Plant
NPDES Stormwater General Perm it-NCG060139
Sampson County
Dear Mr. Narron:
Dee Freeman
Secretary
On February 4, 2013, 1, Hughie White and Trent Allen from the Fayetteville Regional Office of
the Division of Water Quality, conducted a site inspection for the Smithfield -Clinton facility located on
Railroad Street in Clinton, Sampson County, North Carolina. A copy of the inspection report is attached
for your review. Ms. Susan Melchor was also present during the inspection and her time and assistance
is greatly appreciated. Stormwater from the facility drains to Rowan Creek, a Class C-Sw water located
in the Cape Fear River Basin. The site visit and file review revealed that the subject facility is covered
by NPDES Stormwater General Permit-NCG060139.
Accordingly, the following observations were noted during the Division of Water Quality
inspection (please see the attached addendum for information about your permit):
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
implemented.
es ■ No ❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
es ■ No ❑
Location: 225 Green Street, Suite 714. Fayetteville, North Carolina 28301
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterauality.oM
An Equal OppDrtun \Affirmative Action Employer
oli
NorthCarolina
;Vaturallry

N
3) Analytical Monitorin
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
es ■ No ❑
Other Observations:
Please refer to the enclosed inspection report for additional comments and observations.
Please be advised that violations of the NPDES General Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff has any questions,
comments, or needs assistance with understanding any aspect of your permit, please do not hesitate to
contact me at [phone].
Sincerely,,
✓�� .L.w GL'
Hughie White
Environmental Specialist
Enclosure
cc: Norman Johnson, Environmental Manager -Clinton Plant
FRO -Surface Water Protection
WBS Compliance and Permits Unit

Compliance Inspection Report
Permit: NCGO60139 Effective: 12/01/12 Expiration: 10/31/17 Owner: Smithfield - Clinton Plant
SOC: Effective: Expiration: Facility: Smithfield -Clinton Plant
County: Sampson 424 E Railroad St
Region: Fayetteville
Clinton NC 28328
Contact Person: Kyle Narron Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 02J0412013 Entry Time: 09:30 AM Exit Time: 01:00 PM
Primary Inspector: Hughie White Phone: [phone]
Secondary Inspector(s): _ Ext.708
J,
Mike Lawyer % Phone: [phone] Ext.729
Trent Alien./ Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: FoodlTobacco/Soaps/Cosmetics)Public Warehousing
Stormwater Discharge COC
Facility Status: Y Compliant ❑ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1

Permit: NCGO60139 Owner - Facility: Smithfield - Clinton Plant
Inspection Date: 0210412013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The Stormwater Pollution Prevention Plan was avaibale for review. All required components appeared to be included in
the plan. As noted during this inspection, it is suggested that the plan needed to be better organized. Removal of
outdated lab sheets and DMR's is one suggestion. Also, in regards to the plan, be sure to properly document when the
annual updates of the plan are performed. A copy of the Certificate of Coverage and Permit were available for review.
The current stormwater permit for this facility was just issued two months ago in December 2012. Please be aware that
the new permit has a third tier.response action in addition to the previous two tier program. This facility is currently
operating under the Tier Two response plan which, requires monthly monitoring for all parameters, due to continuous
benchmark exceedances for Fecal Coliform, Total Suspended Solids, and Chemical Oxygen Demand. The facility is
currently trying to identify and eliminate the potential causes of the benchmark exceedance. At the time of this inspection,
the facility has started a repaving project. The plan is to eventually repave the entire area surrounding the hog barn and
BTL buildings. The old broken asphalt and pothole repair materials is believed to be the source for the Total Suspended
Solids. Additional measures are being taken to address the issue the fecal coliform.
As a reminder, the Tier Three response action requires that if any benchmark exceedance occurs for any specific
parameter at any specific outfall on four occasions, the permittee shall notify the Regional Supervisor, in writing, within 30
days of receipt of the fourth analytical results. The Division may require additional monitoring, installation of structual
stormwater controls, implement other measures, rescind the General Stormwater Permit and issue an Individual
Stormwater Permit, etc.
All outfalls were observed during this inspection.
Page: 2

Permit: NCGo84139 Owner - Facility: Smithfield - Ciinton Plant
Inspection Date: 02/04/2013 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
Cl
n
# 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
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑
n
# Does the facility provide all necessary secondary containment?
■
n
n
n
# Does the Plan include a BMP summary?
■ n
n n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■ n
n n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■ n
❑ ❑
#floes the facility provide and document Employee Training?
■ n
n n
# Does the Plan include a list of Responsible Party(s)? ■ Cl n Cl
# Is the Plan reviewed and updated annually? ■ ❑ ❑ Q
# Does the Plan include a Stormwater Facility Inspection Program? ■ n n n
Has the Stormwater Pollution Prevention Plan been implemented? ■ n n n
Comment: It was noted during the inspection that the Pollution Prevention Plan
needed to be more organized and that some of the older documentation, such as lab
results, can be removed to help with the better organization of the plan. Also, be sure to
keep the documentation that shows the Plan is being updated annually.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
❑
❑
❑
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
n
Comment:
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
n
# If the facility has representative outfall status, is it properly documented by the Division?
❑
❑
■
❑
Page: 3

Permit: NCG060139 Owner - Facility: Smithfield - Clinton Plant
ti
Inspection Date: 02/04/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment:
Page: 4

n}
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Kyle Narron
Smithfield - Clinton Plant
424 E Railroad St
Clinton, NC 28328
Dear Permittee:
Division of Water Quality
Charles Wakild, P. E.
Director
December 4, 2012
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Smithfield -Clinton Plant
COC Number NCGO60139
Sampson 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 Octeber
1S, 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 NCGO60000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://portal.ncdenr.org/web/wq/ws/su/npdessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mall Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] l FAX: [phone]
Internet www.ncwaterquality-OQ
An Equal Opportunity! Affirmative Action Employer
One
Noi-thCarolina
Naturally

A'
Kyle Narron
December4, 2012
Page 2 of 2
Some of the changes include:
Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections 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/1 for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections 8, C: The monitoring parameter Oil & Grease (0&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate or -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. NCG060139
STORMWATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Smithfield - Clinton Plant
is hereby authorized to discharge stormwater from a facility located at:
Smithfield -Clinton Plant
424 E Railroad St
Clinton
Sampson County
to receiving waters designated as Rowans Branch (Chestnut Pond), a class C;Sw waterbody in
the Cape Fear River Basin in accordance with the effluent limitations, monitoring
requirements, and other conditions set forth in Parts 1, 1I, 111, and IV of General Permit No.
NCG060000 as attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 411,day of December, 2012.
for Charles Wakild, P:E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

NC®ENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Kyle Narron
Smithfield - Clinton Plant
424 E Railroad St
Clinton, NC 28328
Dear Permittee:
Division of Water Quality
Charles Wakild, R E.
Director
December 4, 2012
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Smithfield -Clinton Plant
COC Number NCG060139
Sampson County
In response to your renewal application for continued coverage under stormwater General Permit NCG060000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCG060000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period,of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (htti)://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/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 Carollna 27604
Phone: [phone]W 1 FAX: [phone]
Internet: www-ncwalP.--auaIitv,oru
An Equal Opportunity l,1`m,,,tive A3t:on Employer
N One hCarolina
atmrally

Kyle Narron
December 4, 2012
Page 2 of 2
Some of the changes include:
• Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections 8, 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 (O&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections 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,, /
far 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. NCG060139
STORMWATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Smithfield - Clinton Plant
is hereby authorized to discharge stormwater from a facility located at:
Smithfield -Clinton Plant
424 E Railroad St
Clinton
Sampson County
to receiving waters designated as Rowans Branch (Chestnut Pond), a class C;Sw waterbody in
the Cape Fear River Basin in accordance with the effluent limitations, monitoring
requirements, and other conditions set forth in Parts [, 11, 1[[, 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 41h day of December, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

®ENR-FRO
MAR 19 2012
Smithfield
March 15, 2012
Mr. 1 fughie White
Environmental Specialist
NCDENR
225 Grucn Street, Suite 714
Fayetteville, NC 29301-5043
Re: February 10, 2012 Compliance Inspection Report
I)e:ar Mr. White:
DWO
The Smithfield Packing Co, Clinton Plant will be taking the following [measures to prevent continuously exceeding the
benchmark values in NPDES Stormwater Permit-NC060139.
• Implemented process control sampling and analysis of water in Outfall No. I to identify the source of high
conductive readings. Once the source is identified, it will be redirected and/or treated with an approved
method.
• Increased process control sampling and analysis to monitor the pH, COD, and TSS.
• Continue to eliminate dry weather discharges from Oulfall No. I and Outfall No. 2.
• Install a submersible pump and gate in Outfall No. 2 to pump all dry weather discharge and a portion of the
first flush stormwater to the onsite wastewater treatment system. "Ibis system will be in operation on/or
before May 01, 2012.
• Cease the use of Crush and Run Gravel in pothole..s around the site ott/or before April 01, 2012.
• Continue to patch potholes around the facility with asphalt patch and/or concrete.
• Continue to apply an interior sealant to Bulk 'Tank Secondary Containment Structures. All structures will be
sealed on/or before August Ili, 2012.
• The containment wall at the BTL Air Compressors wi11 be elevated to prevent any overspray during cleaning
and maintenance.
• Implement a rotating cleaning schedule of the stormwater collection system for Outfall No. I and Outfall
No.2. A section of each system will be cleaned on a monthly basis.
• Continue to modify stormdram covers to prevent large debris from entering the stormwater collection system.
• The containment around the BTI. Hydraulic Room will be sealed and the contaminated soil around the area
will be removed onlor before May 15, 2012. "Ihe soil has been sampled, analyzed by Environmental Chemist
and the Sampson County Landfill is awaiting approval from their contract approver. EMA is coordinating
this disposal with Smithfield.
• Evaluate relocating the approved sampling point for Outfall No.1.
• Evaluate and lest Best Management Products with the approval of NCDENR.
Please do not hesitate to contact me at [phone] with any que sfions or concerns.
Sincerely,
Norman Johnson
1;nvironnrcnlai Manager
Smithfield -Clinton Plant

KEEP THIS TICKET
is ticket MUST be presented to cashier on leaving parking
:a. Charges are for the use of Parking space only. This
Impany assumes no responsibility for loss through fire,
;ft, collision or otherwise to the car or contents.
CABS PARKED OWNER RISK
CARCILINATIME LOCK YOUR CAR 7045362700
u1PMENT CO., INC.

Fayetteville Division
2592 ]lope Mills Rd
Fayetteville. NC 28306
910.864.1920 Phone
910.864.8774 Fax
Certificate of Analysis
NC DENR - DWQ (Surface Water)
Mr. Danny Strickland Project: Creek Sample - Cattail Branch@ Clinton Date Reported: February , 2012
225 Green Street, #714 Date Received: January 3112
Fayetteville NC, 28301 Sampled By: Danny Strickland Date Sampled: January 31, 2012
Creek Sample, Lrab
1201575-01
Analyte
Result
Unit
Analysis Date/Time
Analyst
Method Qualifier
Analyzed by: Kcrobac - FayetteviilQ Division
Amazonia as N
<0.100
mg/L
2/1/12
10:24
AMM SM 20th Ed. 4500 NH3 C
BOD
11.8
mg/L
2/2/12
7:00
DSK
SM 20th Ed. 5210 B
Coliform, Fecal
100
per 100 ml
1/31/12
15:00
AMM
SM 20th Ed. 9222 D
Nitrate as N
7.95
mg/L
2I2/12
9:25
JAW
EPA 300.0
Nitrite as N
0.629
mg/L
2/2/12
9:25
JAW
EPA 300.0
Phosphorus, Total
1.3
mg/1-
2/7/12
1 1:54
AMM
SM 20th Ed. 4500 P F
Total Kjeldahl Nitrogen
7.84
ing/L
2/7/12
16:10
AMM
SM 20th, 450ONC
Qualifier Definitions
State Certifications:
NCDNR #11
NCDOH #37714
USDA #3787
Respectfully Submitted
Robert Dermer
Robert Dermer. Division Manager
Thank you for your business_ We invlle yoar It, "aback. an urrr level o%serwce to 1 ut. Please contact the INvi.ciun rlduna er, Rohm Ueruler a ll rl-N6.l-1920, Jame.% Nokev. Prti videat, to
junre,�.nukcs(✓Um+crahac•.curtr fir i'rerol� r Hoce. ul,U, at oxwor.horre antic'-ohae.unn w0h arm cnaunenb or sui;,�ectrnirs.
Page l OP l

9�
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Kyle Narron, General Manager
Smithfield -Clinton Plant
424 E Railroad St
Clinton, NC 28328
Dear Permittee:
Division of Water Quality
Charles Wakild, P.E.
Director
March 5, 2012
Subject: NPDES Stormwater Permit Coverage Renewal
Smithfield -Clinton Plant
COC Number NCG060139
Sampson 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 Bethany Georgoulias 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: [phone] FAX: 919M7-64941 Customer Service: 1-877-623-6748
Internet www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
one
North Carolina
naturally

O4 WAQf Permit Coverage
o��`� Renewal Application Form
National Pollutant Discharge Elimination System Certificate of Coverage Number
Stormwater General Permit NCGO6000D -NCG060139
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 *Reissued Permit will be mailed to the owner address
Owner / Organization Name
Owner Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Smithfield - Clinton Plant
Kyle Narron, General Manager
424 E Railroad St
Clinton, NC 28328
910-299-3000 Ext.
910-299-3001
FacilitvlPermit Contact Information
Facility Name:
Smithfield -Clinton Plant
Facility Physical Address:
424 E Railroad St
Clinton, NC 28328
Facility Contact:
Norman Johnson, Environmental Manager
Mailing Address:
424 E Railroad St
Clinton,NC 28328
Phone Number:
Fax Number:
E-mail address:
Discharge Information
Receiving Stream:
Stream Class:
Basin:
Sub -Basin:
Number of Outfalls:
Rowans Branch (Chestnut Pond)
C; Sw
Cape Fear River Basin
03-06-19
Impaired WaterslTMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes ❑ No ❑ Don't Know
for information on these waters refer to http.y/hZoenrstate.nc. us/su/Imparred Waters iMDU
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

Fayetteville Division
2592 Elope Mills Rd
Favettcvillc. NC 29306
910.864. i 920 Phone
910.864.8774 Fax
Certificate of Analysis
NC DENR - DWQ (Surface Water) Date Reported: February �6, 2012
Ms. Belinda Henson Project: Creek Sample - Cattail Branch, Clinton p ry
225 Green Street, d714 Date Received: February 14, 2012
Fayetteville NC, 28301 Sampled By: B. Henson Date Sampled: February 14, 2012
Creek Sample, Arab
1202256-01
Analyte Result Unit Analysis Date/Time Analyst Method Qualifier
Analyzed by: Microbac - Fayetteville Division
Ammonia as N
<0.100
mg/L
2/16/12
9:26
AMM SM 20th Ed. 4500 NH3 C
BOD
7.25
mg/L
2/15/12
7:00
DSK
SM 20th Ed. 5210 B
Coliform, Fecal
58
per 100 ml
2/14/12
15:50
AMM
SM 20th Ed. 9222 D
Nitrate as N
6,96
m[r L
2/16/12
9:17
JAW
EPA 300.0
Nitrite as N
0.725
mg/L
2/16/12
9:17
JAW
EPA 300.0
Phosphorus, Total
2.5
mg/L
2/23/12
12:30
AMM
SM 20th Ed. 4500 P F
Total Kjeldahl Nitrogen
1.40
mg/L
2/21/12
15:55
AMM
SM 20th, 450ONC
Qualifier Definitions
65 The glucose/glutamic acid standard exceeded the range of 198 130.5 mg/L.
State Certifications:
NCDNR #11
NCDOH #37714
USDA #3787
Respectfully Submitted
Robert Dermer
Robert Dermer, Division Manager
G5
Thank you for your business We i ivae mr.1vedhock on our level ajwrvicc to tvn. !'base conurcI the Mvizinn hlanager, Roherr lturnerai 9N1-w64-19?fr, Jame, Neke+, 1'reudem, at
lame+.nnkrs micrnhuc.rnm or lrevur }iucce, Chi!), an t Ire or.ho1'cenLCrahac.canl +rich
Page 1 of 1

����
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Kyle Narron, General Manager
Smithfield Packing Company -Clinton Plant
1.424 East Railroad Street
Clinton, NC 28328
Division of Water Quality
Charles Wakild, P. E.
Director
February 16, 2012
Subject: COMPLIANCE EVALUATION INSPECTION
Smithfield Packing Company
Clinton Plant
NPDES Stormwater Permit-NCG060139
Sampson County
Dear Mr. Narron:
Dee Freeman
Secretary
On February 14, 2012, I, Hughie White and Trent Allen from the Fayetteville Regional Office of the
Division of Water Quality, conducted a site inspection at the Smithfield -Clinton facility located on Railroad
Street in Clinton, Sampson County, North Carolina. A copy of the Compliance Inspection Report is attached for
your review, Mr. Norman Johnson and Mrs. Susan Melchor were also present during the inspection and their
time and assistance was greatly appreciated. Stormwater from this facility drains to Rowan Creek, a Class C-Sw
water located in the Cape Fear River Basin. The site visit and file review revealed that the subject facility is
covered by NPDES Stormwater Permit-NCG060139.
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 implemented.
es ■ No ❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
[Yes ■ No El
Location: 225 Green Street, Svile 714, Fayettevilte, North Carolina 28301 One
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748 NorthCarol i na
Internet: www.ncwaterquality.osg
An Equal Opportunity 1 Alfirmalive Action Employer ;Vaturally

3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
es■ No❑
Other Observations:
Please refer to the attached Compliance Inspection Report for additional observations and comments. As noted
within this inspection report, benchmark values have been continuously exceeded for several parameters since
2008. It is understood that evaluations of possible causes of benchmark value exceedances have been
performed and also that potential source controls, operational controls, and physical improvements have been
made to reduce stormwater concentrations. However, it appears that additional measures need to be taken due
to the continuous exceedances of benchmark values.
Also, high -conductivity readings have been discovered at stormwater outfalI #1. Conductivity is not a required
monitored parameter for this stormwater permit, but the high readings do indicate the possibility of an unknown
source of waste being released via the storm drains. This issue needs to be evaluated as well.
You are asked to respond to this office, in writing, by March 16, 2012. Your response should include an
immediate and long term plan of action detailing what additional measures will be taken to address the issues
stated above. Failing to identify and eliminate potential sources of stormwater benchmark exceedances could
result in stricter permit requirements for future permits. This current stormwater permit will expire on October
31, 2012.
Please be advised that violations of the NPDES Permit are subject to a civil penalty assessment of up to
$25,000 per day for each violation. If you or your staff has any questions, comments, or needs assistance with
understanding any aspect of your permit, please do not hesitate to contact me at [phone].
Sincerely,
Hughie White
Environmental Specialist
Attachment
cc: Norman Johnson, Environmental Manager -Clinton Plant
L R O-Surface-Water -_Protection
WBS Compliance and Permits Unit
Location: 225 Green Street, Suite 714, FayetteviiEe, North Carolina 28301 One
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 Noah C arol i n a
Internet: www,ncwaterqualiry.org �tCltllrllC�f
An Equal Opportunity 1 Affirmative Action Ern toyer

Compliance Inspection Report
Permit: NCG060139 Effective: 11/01/07 Expiration: 10/31/12 Owner: Smithfield -Clinton Plant
SOC: Effective: Expiration: Facility: Smithfield -Clinton Plant
County: Sampson 424 E Railroad St
Region: Fayetteville
Clinton NC 28328
Contact Person: Kyle Narron Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 02/14/2012 EntryTime: 10:00 AM Exit Time: 01:45 PM
Primary Inspector: Hughie White Phone: [phone]
.�l<<f
Secondary Inspector(s): � Ext.70e
/GIW,1"X_V : Mike Lawye�. Phone: [phone] Ext.729
Trent AllerF'��,.�y+�L Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: FoodrrobaccolSoaps/Cosmetics!Public Warehousing
Stormwater Discharge COC
Facility Status: ■ Compliant Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1

Permit: NCG060139 owner - Facility: Smithfield - Clinton Plant
Inspection Date: 02/14/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The stormwater pollution prevention plan appeared to be complete. All required components of the plan were included.
Qualitative and analytical monitoring is currently being performed monthly. The benchmark values for Total Suspended
Solids, Fecal Coliform, and Chemical Oxygen Demand have repeatedly been exceeded since 2008. Exceedances of the
benchmark values require the permittee to increase monitoring, increase management actions, increase recordkeeping,
and install stormwater Best Management Practices (BMP's) in a tiered program. Currently, this facility is having to meet
the requirements of Tier Two.
Continuous benchmark exceedances for this length of time is a cause for concern. A more aggressive approach to
stormwater BMP's needs to be implemented. Failing to implement additional BMP's, could result in even stricter
stormwater permit requirements.
All outfalls were observed during this inspection.
Page: 2

Permit: NCGO60139 Owner - Facility: Smithfield - Clinton Plant
Inspection Date: 02/1412012 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
# Does the Plan include a General Location (USGS) map?
■
n
n
n
# Does the Plan include a "Narrative Description of Practices"?
■
❑
n
n
# Does the Plan include a detailed site reap 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
# Has the fackity 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 BMP summary?
■
n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
n
n
# Does the facility provide and document Employee Training?
■
❑
n
n
# Does the Plan include a list of Responsible Party(s)?
■ ❑
❑ n
# Is the Plan reviewed and updated annually?
■ n
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: Qualitative monitoring is being performed monthly.
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
n
Comment: Analytical monitoring is being performed monthly because of continuous
benchmark exceedances.
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
n
# If the facility has representative outfall status, is it properly documented by the Division?
n
❑
■
n
# Has the facility evaluated all illicit (non Stormwater) discharges?
■
n
n
n
Comment:
Page: 3

Incident Report
ReportNumber: 201101510
Incident Type: Spill (Oil, Chemical, non -sewage)
Category: Incident
Incident Started: 0712612011
County: Sampson
City:
Farm #:
Responsible Party:
Owner:
Perrnit:
Facility:
First Name: Norman
Middle Name:
Last Name: Johnson
Address
City/State/Zip Clinton NC 28328
Phone- [phone]
Material Category: Estimated Qty: UOM
Other 1500 gal
On -Site Contact:
First/Mid/Last Name:
Norman Johnson
Company Name:
Phone:
910299305
Pager/Mobile Phone
I
Reported By:
First]MidlLast Name:
Norman Johnson
Company Name:
Address:
424 E Railroad St
City/State/Zip:
Clinton NC 28328
Phone:
[phone]
Pager/Mobile Phone:
1
Chemical Name Reportable Qty. lbs. Reportable Qty. kgs.
DD:MM:SS Decimal Position Method:
Latitude: Position Accuracy:
Longitude: Position Datum:
Location of Incident: Smithfield Packing Plant, Clinton Facility
Address: 424 L K"iIwad St
City/State/Zip Clinton ,JC 28328
Report Created 08/01/11 10:27 AM Page l

Cause/Observation:
Spill was caused by electricallmechnical problems in a
wastewater liftstation at the rendering portion of the facility
Wastewater exited rendering door traveled overland to storm
drain #129 and offsite via Stormwater Oultall #2,
Directions:
Facility is iocatedon Railroad Street Clinton, N.C.
Action Taken: Comments:
Recoverable liquid/material was removed via vac truck Site Plant is also going to installed control gate on the stormwater outfall in
cleaned. To prevent future spills from leaving site the company is case of future spills.
installing a floor drain that wilt be routed back to secondary SPILLED MATERIAL WAS RENDERING WASTEWATER, ESTIMATED
containment and wastewater. 1,500 GALLONS SPILLED.
EST 1,000 GALLONS RECOVERED
No visible wastewater in ditchisurface waters per Mr. Johnson.
Incident Questions:
Did the Material reach the Surface Water? Yes
Surface Water Name? Rowans Branch (Chestnut Pond)
Did the Spill result in a Fish Kill? Unknown
If the Spill was from a storage tank indicate type.
Containment? Yes
Cleanup Complete? Yes
Water Supply Wells within 1500ft Unknown
Conveyance: Ditch
Estimated Number of fish?
(Above Ground or Under Ground)
Groundwater Impacted : Unknown
Event Type Event Date Due Date Comment
Report Entered 2011-08-01 09:55:00
Report Received 2011-07-26 07:44:00
Referred to Regional Office - Primary Contact 2011-07-26 07A4:00
Incident Start 2011-07-26 06:50:00
Report Created 08I01111 10:27 AM Page 2

Incident closed
Requested Additional Information
Standard Agencies Notified:
Agency Name
201 1-07-26 12:00:00
201 1-07-26 12:00:00
Phone First Name M.I
Written report requested July 26, 2
Last Name Contact Date
Other Agencies Notified:
Agency Name Phone First Name M.i. Last Name Contact Date
DWQ Information:
Report Taken By: Report Entered By: Regional Contact:
Paul E Rawls Paul E Rawls Paul E Rawls
Phone:
Date/Time: 2011-07-26 07:44:00 PM 2011-08-01 09:55:00 AM 2011-07-26 07:44,00 PM
Referred Via: Phone Phone
Did DWQ request an additional written report? 2011-07-26 12:00 00 AM
If yes, What additional information is needed? Written report requested .lul. 26, 201 1 received Jul} 11, 2011
Report Created 08/01/11 10:27 AM Page 3

Smithf field.
.luly 31, 2011
Mr. Paul Rawls
Environmental Specialist
NCDENIt.. _ .._ ...
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Subject: Release of. Process Wastewater
Dear Mr. Rawls:
This letter is to follow up the verbal report given to you on July 26, 2011 at approximately 7:44 PM.
On Tuesday, Rely 267 2011, at approximately 6:50 AM, the Smithfield --Clinton Plant had a release of
approximately 1,500-2,000 gallons of process wastewater from an entrance/exit door, due to the lift -
station located in the Rendering Plant. The release was due to an electrical and mechanical issue with
the lift -station. Due to the (tendering Plant drain system, storm drain No: 129 and outfallNo.2 was
affected by the release, prior to applying the storm drain block/rubber mat on storm drain No.129 to
contain the wastewater on the concrete and to minimize the impact to the stormwater collection
system while working on the lift -station.
The clectrical issue was corrected and the isolation valve was replaced, due to the broken internal
gate. The following actions were immediately taken to recover the process wastewater contained and
released. A contract vacuum truck cleaned Storm drain No.129 and outfall No.2 to prevent any future
stormwater pollution and discharged wastewater recovered into the wastewater treatment plant lift
station for proper disposal. The wastewater and grit from the concrete was recovered will) the contract
vacuum truck and discharged into the wastewater treatment plant lift station for proper disposal. The
affected area was washed down to reprove chi recover any residual on the concrete from the release.
Based on visual observations of approximately two miles of the City's Stortnwater System, there was
no visible impact down stream.
To prevent any future release from under the entrance/exit door, a floor drain is being installed in front
of the door. '!'Ire drain will discharge any flowing liquid into the secondary contaimnent for the
receiving/floor bias for the Rendering Plant, which will be pumped to the Rendering lift -station for
proper treatment and disposal. We will also be installing an emergency/stormwater discharge control
gate in outfall No.2 to contain any future release (s) on site.
Please do not hesitate to contact me at [phone] with any questions or concerns.
sincerely, iJ
Norman Johnson
Environmental Manager
Smithfield —Clinton Plant

Rawls, Paul
From: Johnson, Norman [[e-mail]
Sent: Thursday, January 06, 2011 4:29 PM
To: Rawls, Paul
Cc: Johnson, Norman
Subject: Emailing: NPDES Authorized Representative for COC- NCG060139.pdf
Attachments: NPDES Authorized Representative for COC- NCG060139.pdf
Mr. Rawls,
First, I hope you had a safe and happy holiday. We now a have new General Manager and I
wanted to provide you with a copy of what I am submitting to Raleigh.
Please contact me with any questions or concerns.
Thanks,
The message is ready to be sent with the following file or link attachments:
NPDES Authorized Representative for COC- NCG060139.pdf
Note: To protect against computer viruses, e-mail programs may prevent sending or receiving
certain types of file attachments. Check your e-mail security settings to determine how
attachments are handled.
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.
I

December 23, 2010
Ms. Sarah Young
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Aut sized Rep tative for NPDES General Permit NCG060000 Certificate of
Covera e NCG060139,
Dear Ms. Young:
This letter is to inform you Ken Wilson_ General Manager for the Smithfield —Clinton Plant is
no longer the authorized representative for the NPDES General Permit NCG060000.
To comply with the signatory requirements in NPDES General Permit NCG060000, I Kyle
Narron, General Manager for the Smithfield —Clinton Plant will be the authorized
representative for the permit.
Please feel free to contact me with any questions, comments or concerns at [phone],
Sincerely,
�IaA�
Kyle Narron
General Manager
Smithfield —Clinton Plant
cc: Files
Fayetteville Regional Office
Stormwater Permitting Unit
Q�Q E , "0 ta�'j S�-cul
[JAN 1 2 2011

s
�llll I JII n Sit:!<,{r7i uai�T'i
September 307 2010
Norman Johnson
Environmental Manager
Smithfield Packing Company
424 East Railroad Street
Clinton, North Carolina 25328
Subject: COMPLIANCE EVALUATION INSPECTION
Smithfield Packing Company
Clinton Facility
NPDES Stormwater General Permit NCG0060139
Sampson County
Dear NIr. Johnson:
Enclosed please find the Compliance Evaluation Inspection report for the inspection and technical
assistance conducted September 21, 2010. 1 would like to thank you for time taken to participate in the
inspection and discussion of storinwater related items.
Stormwater from the subject facility drains to Rowan Crcek, Class C-SNN, waters located in the Cape
Fear River Basin. The inspection and file review revealed that the subject facility is covered by NPDES
Stormwater General Permit NCG060139. A review of stormwater monitoring data indicates there are
several items that should be addressed, discussed below. Please respond to items noted below as
indicted:
]) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPI') has been developed, recorded, and properly
implemented.
Yes 0 No ❑
All records reviewed were neat and well managed.
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
�'es ■ No ❑
;
- www.ncwaterguaiity.org
rl

Mr. Johnson
September 30, 2010
Page 2 of 2
3) Analytical Nlonitori
Analytical monitoring was reviewed and discussed during the inspection. Based on the review of that
data it is apparent that the site has exceeded benchmark values outlined in the permit for some time. As
you may know exceedences of benchmark values require increased monitoring, management actions,
record keeping and/or installation of storrnwater Best Management Practices in it tiered program. Such
exceedences indicate high concentrations of pollutants are being discharged from the site via
stormxvater. Based on the above you are asked to submit the following information by October 29, 2010:
1) A summary of all stormwater related data for- the period ,July 1, 2008 to the present.
2) A summary or list of all action taken to address benchmark- exceedences for the last two years. This
should include but not necessarily limited to action taken to isolate and/or redirect stormwater flow,
investigation of site drainage and changes in staff training.
3) A Plan of action to address the benchmark exceedences. The plan of action should at a minimum
include the actions outlined in your permit and should include time frames for the required action.
4 Other
While the site is generally neat and well managed it was noted that debris is still an ongoing issue.
Please reinforce to plant personnel that spills and debris can travel offsite during rain events and can
lead to degradation of surface water. Good housekeeping practices should be stressed whenever
possible.
1 would like to again thank you for your time during the inspection and if you have questions,
comments, or need further assistance, please do not hesitate to contact me at [phone].
Sincerely,
Paul E. Rawls
Environmental Program ConSarltant
11113R: PhR/per
hnclosure: Inspection Report
ec: Mike Lawyer, FRO-Surfacc Water Protection
MIS -Assistance & Compliance Oversight Unit
D\VQ Central Files

Compliance Inspection Report
Permit: NCGO60139 Effective: 11/01/07 Expiration: 10/31/12 Owner: Smithfield - Clinton Plant
SOC: Effective: Expiration: Facility: Smithfield -Clinton Plant
County: Sampson 424 E Railroad St
Region: Fayetteville
Clinton NC 28328
Contact Person: Ken-•Wil" Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification; Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/21/2010 Entry Time: 09:50 AM Exit Time: 12 40 PM
r `/lu• -133 3
Primary Inspector: Paul E Rawls ^-� ? _.... Phone: 919=733-50&3
%7=7"1G*1`e
Blinda S Henson 6"-7rxi1td031J Phone: [phone] Ext.726
Reason for Inspection: Routine Inspection Type: Stormwater
Permit Inspection Type: Food/Tobacco/Soaps/Cosmetics/Public Warehousing
Stormwater Discharge COC
Facility Status: ® Compliant rl Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

Permit: NCGO60139 Owner - Facility: Smithfield - Clinton Plant
Inspection Date: 09/21/2010 Inspection Type: Stormwater Reason for Visit: Routine
Inspection Summary:
Analytical monitoring was reviewed and discussed during the inspection. Based on the review of that data it is apparent
that the site has exceeded benchmark values outlined in the permit for some time. As you may know exceedences of
benchmark values require increased monitoring, management actions, record keeping and/or' Installation of stormwater
Best Management Practices in a tiered program. Such exceedences indicate high concentrations of pollutants are being
discharged from the site via stormwater. Based on the above you are asked to submit the following information by
October 29, 2010:
1) A summary of all stormwater related data for the period July 1, 2008 to the present.
2) A summary or list of all action taken to address benchmark exceedences for the last two years. This should include but
not necessarily limited to action taken to isolate and/or redirect stormwater flow, investigation of site drainage and
changes in staff training.
3) A plan of action to address the benchmark exceedences. The plan of action should at a minimum include the actions
outlined in your permit and should include time frames for the required action.
Page: 2

Permit: NCGO60 139 Owner - Facility: Smithfield - Clinton Plant
Inspection Date: 09121/2010 Inspection Type: Slormwater
Reason for Visit:
Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
in
n
Fi
# Does the Plan include a General Location (USGS) map?
®
n
n
n
# 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
in
# Does the Plan include a t3MP summary?
■
n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
in
# 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?
■
n
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: All information reviewed was neat and well managed.
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
n
Comment: See Summary section of this report.
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
n
# If the facility has representative outfall status, is it properly documented by the Division?
n
n
■
n
# Has the facility evaluated all illicit (non Stormwater) discharges?
■
n
n
n
Comment:
Page: 3

Smithfield
October 22, 2009
Mr. Mike Lawyer
Environmental Specialist
NCDENR
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Subject: Release of Process / Sanitation Water Incident No. 1017
Dear Mr. Lawyer:
This letter is to follow up the verbal report given to Chris at NCDENR on Saturday, October 17, 2009
at approximately 1:52 PM. On Saturday, October 17, 2009 at approximately 1:30 AM, the Smithfield
--Clinton Plant had a release of approximately 500 gallons of process /sanitation water from the
process manhole by the 701-gate employee entrance due to am unknown obstruction izi the discharge
line. Due to the location of the manhole, storm drain No.11 &10 was slightly affected by the release
prior to applying the storm drain block/rubber mat on storm drain No.11 to contain the wastewater on
the asphalt and to minimize the impact to the stormwater collection system, wlvle working on the
wastewater collection system to remove the obstruction.
Once the obstruction was removed from the process manhole, the following actions were immediately
taken to recover the pro cess/sanitation wastewater contained. The wastewater and grit on the asobalt
was recovered by Keens Plumbing using a commercial vacuum truck and discharged into the
wastewater treatment plant lift station for proper disposal. The affected area was washed down to
remove & recover any residual on the asphalt and the stormwater collection system was jetted and
vacuumed out to prevent any future stormwater pollution.
Based on the visual observations of the stormwater drain No. 11 &10, the Smithfield —Clinton Plant is
confident that the wastewater released was contained on site and no further action is necessary.
Please do not hesitate to contact me at [phone] with any questions or concerns.
Sincerely,
Norman Johnson
Environmental Manager
Smithfield —Clinton Plant

Smit�eld,
October 22, 2009
Mr. Mike Lawyer
Environmental Specialist
NCDENR
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Subject: Release of Process / Sanitation Water Incident No. 1021
Dear Mr, Lawyer:
This letter is to follow up the verbal report given to you on Wednesday, October 21, 2009 at
approximately 4.36 PM. On Wednesday, October 21, 2009 at approximately 4:30 .AM, the Southfield
—Clinton Plant had a release of approximately 500 gallons of process /sanitation water from the
process manhole by the 701-gate employee entrance possible due to grease and/or the accumulation of
solids in the discharge line. Keens Plumbing just vigorously cleaned the collection system on
Saturday, October 17, 2009 using a commercial jetter with an 1114" fine and vacuum truck. Due to the
location of the manhole, storm drain No. I I & 10 was slightly affected by the release prior to applying
the storm drain block/rubber mat on storm drain No.I I to contain the wastewater on the asphalt and to
minimize the impact to the stormwater collection system, while working on the wastewater collection
system to remove the obstruction.
Once the obstruction was removed from the process manhole, the following actions were immediately
taken to recover the process/sanitation wastewater contained. The wastewater and grit on the asphalt
was recovered by Keens Plumbing using a commercial vacuum truck and discharged into the
wastewater treatment plant lift station for proper disposal. The affected area was washed down to
remove & recover any residual on the asphalt and the stormwater collection system was jetted and
vacuumed out to prevent any future stormwater pollution.
Based on the visual observations of the stormwater drain No.I 1 & 10, the Smithfield —Clinton Plant is
confident that the wastewater released was contained on site and no further cleaning is required.
We will continue to monitor and perform maintenance on the wastewater collection system to prevent
any future issues.
Please do not hesitate to contact me at [phone] with any questions or concerns.
Sincerely,
Norman Johnson
Environmental Manager
Smithfield —Clinton Plant

Smithfield..
November 17, 2008
Ms. Sarah Young
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Authorized Representative for NPDES General Termit NCG060000 Certificate of
Coverage NCG060139.
Dear Ms_ Young:
This letter is to inform you Glenn Clark, Interim General Manager for the Smithfield —Clinton
Plant is no longer the authorized representative for the NPDES General Permit NCG060000.
To comply with the signatory requirements in NPDES General. Permit NCG060000, I Ken
Wilson, General Manager for the Smithfield —Clinton Plant will be the authorized
representative for the permit.
Please feel free to contact me with any questions, comments or concerns at [phone].
Z incince7:rely,
Ken Wilson
General. Manager
Smithfield —Clinton Plant
cc: Files
Fayetteville Regional Office
Stormwater Permitting Unit
Glenn Clark, Smithfield --Clinton Plant

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
November 7, 2008
Mr. Glenn Clark
Smithfield -Clinton Plant
424 East Railroad Street
Clinton, NC 28328
Coleen H. Sullins, Director
Division of Water Quality
DEN1 —FRO
NOV 10 2008
DWQ
Subject: NPDES General Permit NCG060000
Certificate of Coverage NCG060139
Smithfield -Clinton Plant
Formerly Premium Standard Farms, Inc.
Sampson County
Dear Mr. Clark:
Division personnel have reviewed and approved your request to transfer your coverage under the General
Permit, received on July 18, 2008.
Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General
Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements
of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and
the U.S. Environmental Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at [phone], or at
[e-mail].
Sincerely,
ORIGINAL SIGNED 5
KEN PICKLE
Coleen H. Sullins
cc: DWQ Central Files.
Fayetteville Regional Office
Stormwater. Permitting Unit
None
r hCarolina
atura!!�
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG06139
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-CLINTON PLANT
is hereby authorized to discharge stormwater from a facility located at
SMITHFIELD-CLINTON PLANT
424 EAST RAILROAD STREET
CLINTON
SAMPSON COUNTY
to receiving waters designated as Rowan, a class C SW stream, in the Cape Fear River Basin, in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, III, and IV, V and VI of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective November 7, 2008.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day November 7, 2008. ORIGINAL SiGNEI a'
KEN PICKLE:
for Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

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�x N
Division of Water Quality t Lltlts�
Surface Water Protection Section,-�
1617 Mail Service Center T
Raleigh, N.C. 27699-1617
Reference: Ownership & Signature Authority Change for Stormwater Permit COC No.
NCG060139 Sampson County
To Whom It May Concern.
I have attached the following documents to change ownership & signature authority for
''tormwater General Permit No. NCG060000: A copy of the COC issued on Novem -er
01, 2007, the Surface Water Protection Section Permit Name/Ownership Change Form,
that the previous permittee John Allis the Director of Operations (Plant) is unavailable to
sign the permittee certification section, since he is no longer an employee of'Premium
Standard Farms, Inc. and the Smithfield —Clinton Plant.
Assumption Agreement between Premium Standard Farrns, LLC and Clinton Plant, LLC,
Certificate of Merger for the Clinton Plant, LLC into The Smithfield Packing Company,
Inc.
Please do not hesitate to contact Norman Johnson at [phone] with any questions
or concerns.
Sincerely, J
�ilne n Clark
Interim General Manager
Smithfield —Clinton Plant

Smit�eld_
July 25, 2008
Division of Water Quality
Surface Water Protection Section
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Reference: Ownership & Signature Authority Change for Stormwater Permit COC No.
NCG060139 Sampson County
To Whom it May Concern:
I have attached the following documents to change ownership & signature authority for
Stormwater General Permit No. NCG060000: A copy of the COC issued on November
01, 2007, the Surface Water Protection Section Permit Name/Ownership Change Form,
that the previous permittee John Allis the Director of Operations (Plant) is unavailable to
sign the permittee certification section, since he is no longer an employee of Premium
Standard Farms, Inc. and the Smithfield —Clinton Plant_
Assumption Agreement between Premium Standard Farms, LLC and Clinton Plant, LLC,
Certificate of Merger for the Clinton Plant, LLC into The Smithfield Packing Company,
Inc.
Please do not hesitate to contact Norman Johnson at [phone] with any questions
or concerns.
Sincerely,
lean Clark
Interim General Manager
Smithfield —Clinton Plant

w
Michael F. Easley, Governor
ha2z�
ter"
.0 -C
William G. Ross Jr,, Secreary
North Carolina Department of Environment and Natural Resources
I. Please enter the permit number for which the change is requested.
Alan W. Klimek, P.E. Director
Division of Water Quality
NPDBS Permit (or) Certificate of Coverage
II. Permit status prior to status change.
a. Permit issued to (company name): l4 r G r%A r &.\-yv \ S -FL ✓t d®t moo( Tp% G.
b. Person legally responsible foi• permit: i41 d S
First 1 Ml 1 Last 1
r,/r I't L�"✓ C"I t%I'1-Gr'y4f.`✓/lS C ip%KKt/
Title
a-fdt Ea s i- Kam: Sra o.-a(�-
Permit holder Mailing Address
City state Zip
(911V) z 9 9 - -3 (gia)Rq-_3pa f
Phone Fax
c. Facility name (discharge): pr -e- r^ = w wt L+yL vt o(ot--d FA-e psn 5;
d. Facility address: 4;t t'i E^c j- IQK r Iran a( Sfr-�-�f
Address
Gl;r.�or. N.(-._ a2r3PLW
City State Zip
e. Facility contact person: 41/orrV'%A -\ j- kr%5 oLn ( tc').245 — 305-l
First / MI 1 Last Phone
III. Please provide the following for the requested change (revised permit).
Revised 712005
a. Request for change is a result of: U Change in ownership of the facility
e Name change of the facility or owner
If other please explain:
b. Permit issued to (company name):
c. Person legally responsible for permit:
d. Facility name (discharge):
e. Facility address:
SP.": fh-F; zIa - LI/►,-Ar--L
CrIon- y C
First / MII Last
1'.t ff— r- : G--c P% -f- r -rL f ►'V*` n IN -e- ✓`
Title
q 14f Ea s f
Permit Holder Mailing Address
G! •�-f0r ". C, 2 £r3.-
City State Zip
Me A9 4- GOO tCr%0---A -k 5r.%-41'F>'e
Phone E-mail Address
sj')- Eo'5:'-F 12n: frame vI S�rt,G (-
Address
C- [ : •` f- e� Av. C— A 46-3 ;L ff
City State Zip
€. Facility contact person: �rnv'.+� J a ln✓� S' a'-\
First 1 MI / Last
(91v)d4 g-3o1 Ylprwtin ���hnSt"+(ylSMlfhl�:c<�Lsh1
Phone E-mail Address '

PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
IV. Permit contact information: (if different from the person legally responsible for the permit)
Permit contact: s - V) o vIL
First I IVIl1 Last
Title
Mailing Address
fr
City State Zip
Ar t:.1yac...5 �.Sµ.'fd F:elr/ t<o�
Phone E-m Address
V. Will the permitted facility continue to conduct the same industrial activities conducted prior to
this ownership or name change?
e Yes
❑ No (please explain)
VI. Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE
.INCOMPLETE OR MISSING:
e' This completed application is required for both name change and/or ownership change requests.
f' 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.
m .c �� r to—s. 101 .tif
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
attest that this application for a name/ownershi?
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 p kage will be returned as 'neomplete.
APPLICANT CERTIFICATION:
r, ��.E/[iItl 6191eK _, 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 pa age will be re ed incomplete.
signit=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 7/2105

Smithfield
July 25, 2008
Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Reference: Stormwater Discharge Outfall (SDO) Monitoring Report for Year 1 Period 1
To Whom It May Concern:
Enclosed is the Stormwater Discharge Outfall (SDO) Monitoring Report for Year 1
Period 1 January 2008 to June 30, 2008.
I have also•suubmitted:documents.to the:Surface=Water: Protection- Section to change
o�hip_&-signature"authority for Stormwater General Permit No. NCG060000: the
previous permittee John Allis the Director of Operations (Plant) is unavailable to sign the
monitoring report, since he is no longer an employee of Premium Standard Farms, Inc.
and the Smithfield —Clinton Plant.
Please do not hesitate to contact Norman Johnson at [phone] with any questions
or concerns.
Sincerely,
Glenn Clark
Interim General Manager
Smithfield —Clinton Plant

Incident Report
Report Number: 200801454
Incident Type: Spill (Oil, Chemical, non -sewage) On -Site Contact:
Category: Incident First/Mid/Last Name: Norman Johnson
Incident Started: 05/09/2008 Company Name: Smithfiled Foods
County: Sampson Phone: [phone]
City: Clinton Pager/Mobile Phone: 1
Farm #:
Responsible Party: Reported By:
Owner: Premium Standard Farms Inc First/Mid/Last Name: Norman Johnson
Permit: NCG060139 Company Name:
Facility: Premium Standard Farms Inc Address:
First Name: John
Middle Name: City/State/Zip:
Last Name: Allis Phone: [phone]
Address PO Box 49 Pager/Mobile Phone: /
City/State/Zip: Clinton NC 2832900
Phone:
Material Category: Estimated Qty: UOM
Other 5000 gal
DD:MM:SS Decimal
Latitude:
Longitude:
Location of Incident: Smithfield Plant in Clinton
Address: 424 E Railroad St
Chemical Name Reportable City. lbs. Reportable Qty. kgs.
Position Method:
Position Accuracy:
Position Datum:
CitylStatelZip Clinton NC 28328
Report Created 05/15/08 10:59 AM
Page 1

Cause/Observation:
Six inch fire system line broke inside rendering department,
which allowed approximately 3000-5000 gallons of potentially
contaminated water to blow open door and enter storm drain
near building that leads to facility's siormwaler outfall #2.
According to EM report, there was nothing to clean up as the
water had evaporated. Mr. Johnson explained that that meant
there were no puddles on the asphalt area around the storm
drain to clean up and that the majority of the spill entered the
drain and left the property. Mr. Johnson also explained that he
was unaware of where flow would ultimately end up after leaving
the outfall and property. He further explained that the rendering
area had been shut down for the day and there should have
been a wash down of the area reducing the amount of
contaminates that could be in the water.
Action Taken:
None.
Incident Questions:
Did the Material reach the Surface Water? Unknown
Surface Water Name?
Did the Spill result in a Fish Kill? No
If the Spill was from a storage tank indicate type.
Containment? Unknown
Cleanup Complete? Unknown
Water Supply Wells within 1500ft : Unknown
Event Type
Requested Additional Information
Incident closed
Directions:
Comments:
Site visit conducted on 5112108 by Mike Lawyer and Hughie White to
locate point of entry into receiving stream and to determine if there were
any impacts. Due to elapsed time from date of spill to site visit and
significant rain events over the weekend, no impacts were observed that
would necessitate any cleanup or other actions by permittee. Discussions
were held with facility personnel as to how to avoid possible spills
reaching the receiving stream in the future. Mr. Johnson expressed
interest in installing a sluice gate at the outfall that could be closed in the
event of a spill, preventing flow from traveling beyond the outfall and
allowing cleanup procedures in a confined area.
Conveyance
Estimated Number of fish? 0
(Above Ground or Under Ground)
Groundwater Impacted : Unknown
Event Date Due Date Comment
2008-05-15 11:00:00
Report Created 05/15/08 10:59 AM Page 2

Report Entered
Referred to Regional Office - Primary Contact
Report Received
Incident Stara
Standard Agencies Notified:
Agency Name Phone
Other Agencies Notified:
Agency Name Phone
2008-05-15 10:38:00
2008-05-12 09:00:00
2008-05-09 10:07:00
2008-05-09 07:30:00
First Name M.I. Last Name Contact Date
First Name M.I. Last Name Contact Date
DWQ Information:
Report Taken By: Report Entered By: Regional Contact:
Management Emergency Mike Lawyer Belinda S Henson
Phone:
DatefTime: 2008-05-09 10:07:00 PM 2008-05-15 10:38:00 AM 2008-05-12 09:00:00 AM
Referred Via: Phone Voice mail
Did DWQ request an additional written report?
If yes, What additional information is needed?
Report Created 05/15/08 10:59 AM Page 3

nciden! i.i Sampson County (CLINTON) on 05/09/2008 10:05:28 PM
Page 1 of I
NC Division of Emergency Management
Emergency Report Form (Rev 2.0)
Taken by: J Peters IDate Reported: 05/09/2008 Time Reported: 10:07 PM
Date Occurred: 05/09/2008 Time Occurred: 07:30 PM
Reported by: Norman Johnson Agency: Smithfield Clinton Plant Phone: [phone]
County: Sampson City: CLINTON IFEM Area: E 04
EVENT TYPE
Weather Event: HazMat Event: Other HazMat Event (See Event Description)
Wx Event Name: HazMat Class: Other
HazMat Mode: Fixed Facilitv
FNF Event: Non-FNF Event: SAR Event:
FNF Type:
FNF Class:
Fire Event: Complaint:
OTHER EVENT:
:t : r.5 saz 1
=vent Description: Fire system line broke inside the rendering dept causing pressure to build and release approx 3,000 to 5,000
gallons of contaminated water to outfall #2. Water was sampled and had a PH of 7,53 to 7.76. There was nothing to clean up, it
waporated. 4" f�^�- c6 �*-� c�� ,,. ev 1� o ? "r ("-&e- � 4, xL,1ti'�'
)ermit # NCG060000
lttachments: �_�li:/l�C�,{�&6/317
Deaths: Ilinjuries: JjEvac: JjRadius:
Responsible Party: JJRP Phone:
Point Of Contact: 11POC Phone:
-vent Location: 421tE Railroad St, Clinton, NC
-atitude (decimal degrees ) (NC inland range is 33.840 - 36.588 degrees. Values outside these parameters may be used.)
.ongitude (decimal degrees) (NC inland range is 75.460 - 84.322 degrees. Values outside these parameters may be used.)
JSFS Block-Souare-Point Svstem: Block= Souare= Point=
RRT Request: No JRRT Mission No.: JJRRT Team Number:
COUNTY AGENCIES
LEMC: SO: :]IPD: LFD: CHealth: Sewer: PWRK:
)ther Local Agencies:
STATE AGENCIES
A/C: SHPISWP: Env. Mgt: Water: DRP: CAP: DOT: DMV:
W �.�+, `i�'-¢ ��ta.:^.`�sc�: +,-.�&. �y?e.y..t J .Nth'.. �S,r$d� ltJ •e^�+.,r ,rk.. _:R!.-....,12:a auew.A.r.ri• 1 .., �;�rs,"csSkwSa;*�eaeaa�:'w.7�-n.'.it�.�sk1t .- sv;• .
I:ther State or Federal Agencies:
. it 5'•ofr-..?i`.'n.�Jcv�Z�JY�'-.Y,F.\�.�`,^.5.:'GN.c'y'Y:6_5TY`O'_.-'ti1:L�1.i►`�"`--.x1tt:f.::Y'fv.^-�"f;`!%1Y:6'x/"1x5L't1.:'.t4Sr�::T��:fiTAtll`Arlf:�C.k- S�CIVCC1.'3.�
=M Hours: SAR Hours:
�w 41,,
IMc.#�SolYStl
.y, 305 /
Call #:
ittp:11149.168.212.171EM_l ivelEM Report.NSF1a6413acc304fce698525 66f20012732fl802d 1 ddf427072e9... 5/ 12/2008

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Smithfield.
April 8, 2008
Certified Mail
Ms. Belinda Henson
Regional Supervisor -Fayetteville regional Office
Surface Water Protection
225 Green Street -Suite 714
Fayetteville, NC 28301
Subject: Lard Spill on April 4, 2008
Dear Ms. Henson:
DENR--FRO
i ;-X i U 2008
PO Box49
Clinton, NC 28329
[phone] tel
[phone] fax
Please accept this letter as the written submission for the spill which occurred on April
04,' 2008 at approximately 12:25 PM on the 9Miithfleld' `—'Clinton Plant's premises: As
reported over the phone, approximately 30 - 35 gallons of lard spilt due to overfilling a
tanker trailer. Employees placed socks around the storm drain and used shovels and
squeegees to pick up the spilt lard. Approximately 15 — 18 gallons of lard entered a
storm drain which -was scooped up with a container and the remaining standing water was
pumped with a sump pump. Absorbent was used to absorb any remaining Iard on the
pavement and a sweeper was used to sweep the absorbent from the pavement.
To prevent overfills in the future the holding tank in the lard loft will be deliberately
under -filled. Operations is in the process of developing a time chart of various fill rates
of the dispensed lard amount which will be made available to the load -out crew. Meters
will be calibrated or replaced if necessary.
Should you have any concerns, questions, or comments, please do not hesitate to contact
me.
Sincerely,
Tannis Brockman
EMS` Coordinator
Smithfield Clinton Plant
[phone] ext 2360
JO All1S
ector of Oper'ationslGeneral' Manager
Smithfield'Clinion Plant
[phone]

Micnnrl r. tasiey; Vovenior
William G. Ross 7r., secretury
Nortil Carolina Department of Environment rind Natural Resources
Coleell H. Sullins, Director
Division of Witter Quality
November 1, 2007
John Allis, Dir Operations Plant
Premium Standard Farms Inc
P0. Box 49
Clinton. NC 283290049
Subject: NPDES Stormwater Permit Coverage Renewal
Premium Standard Farms Inc
COC Number NCG060139
Sampson County
Dear Permittee:
In response to your renewal application for continued coverage under stormwater General Permit NCG060000 the Division of
Water Quality (DWQ) is forwarding herewith the reissued 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 NCG060000
• 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 1 Section A —A new notation that the No Exposure Exclusion from permitting option may be available to the
permittee.
• Part I Section A — A now 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 II Section 9 Table 1 —An increased sampling frequency from once per year to twice per year.
• Part II Section B Table 3 — Benchmark concentrations now replace cutoff concentrations; the elimination of the option to
avoid sampling based on cutoff concentrations.
• Part II 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 benchmark 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.
DWQ received a number of comments on a series of general permits similar to this one. A full response to comments can be
found at htip:l/ncwaterquaiity.orglsulindustrialgpinfo.htrn. Some comments resulted in permit modifications, others are
addressed in the response document or Fact Sheet. A few specific requests for clarification are addressed below,
1. What is the deadline for having a revised SPPP that reflects the provisions of the new General Permit? DWO will require
that the permittee have a revised, complete SPPP no later than six months after the date of issue of that permittee's new
Certificate of Coverage.
2. Must analytical results be by a certified lab? What about pH measurements? Ali analytical results obtained to satisfy
NPDES permit requirements must be certified, as directed in North Carolina regulations at 15A NCAC 2H .0800, and as
administered by DWQ's Laboratory Section Certification Branch. This includes field pH measurements OW
NorlhCurnlina
North Carolina Division of Water Quality 1617 Mail Service Center Ralciah, NC 27699-IG 17 Phone [phone]p i 3 Ctistrnner Service
Internet h2c.enr.slate.nc.uslsulslormwaier.hlml 312 N. Salisbury SI, Ralcirth, NC 27604 FAX [phone]
An Equal QpportunilylAfiirmalive Action Employer— 50% Recycledlt0% Post Consumer Paper

royc c
Your coverage under the General Permit is transferable one through the specifir, 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 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 Ken Pickle of the Central Office.Stormwater Permitting Unit
at [phone], ext. 584.
Sincerely,
b4A-'t!/ -/t) in1L'v�
for Coleen H. Sullins
cc: DWQ Central Files
Stormwater Permitting Unit Files
Fayetteville Regional Office

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
August 23, 2002
MARTIN GUTHRIE
PREMIUM STANDARD FARMS INC - CLINTON
PO BOX 49
CLINTON, NC 283290049
Dear Permittee:
Alan W. Klimek, P.E., Director
Division of Water Quality
i
i ft�G 2 9 2002
Subject: NPDES Stormwater. Permit Renewal
Premium Standard Farms Inc - Clinton
COC Number NCG060139
Sampson County
In response to your renewal application for continued coverage under general permit NCG060000, the Division of
Water Quality (DWQ) N 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, 1981
The following information is included with your permit package:
A new Certificate of Coverage
A copy of General Stormwater Permit NCG060000
A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee. from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater
and General Permits Unit at [phone], ext. 578
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Fayetteville Regional Office
AMA
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 AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060139
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,
PREMIUM STANDARD FARMS
is hereby authorized to discharge stormwater from a facility located at
PREMIUM STANDARD FARMS INC - CLINTON
424 E RAILROAD STREET
CLINTON
SAMPSON COUNTY
to receiving waters designated as Rowan Branch, a class C SW stream, in the Cape Fear River Basin in accordance
with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, 11, 111, IV, V, and VI
of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective September 1, 2002,
This Certificate of Coverage shall rernain in effect for the duration of the General Permit.
Signed this day August 23, 2002.
Ley
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
MARTIN GUTHRIE
PREMIUM STANDARD FARMS INC - CLINTON
PO BOX 49
CLINTON, NC 283290049
Dear Permittee:
1�•
NCmU`E'NR
NOR77i^CAR90NA DEPARTMENT OF
ENVIFiONMENT.AND NICruRAL�RESOURCES
7/12/2002 �IUL 2 6 2002
Subject: NPDES Permit Modification -Name and/or Ownership Change
Permit Number NCG060139
Premium Standard Farms Inc - Clinton
Sampson County
In accordance with your request received April 3, 2002, the Division is forwarding the subject permit
modification. This modification documents the change in the ownership of the subject facility. All other terms and
conditions in the original permit remain unchanged and in full effect. This permit modification is issued under the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U. S. Environmental Protection Agency dated December 6, 1983.
This permit modification does not affect the legal requirement to obtain other permits which may be
required by the Division of Water Quality, the Division of Land Resources, Coastal Area Management Act, or any
other Federal or Local government permit that may be required. If you have any questions concerning this permit,
please contact Valery Stephens at the telephone number or address listed below.
Sincerely,
for Ma W. Klimek, P.E.
cc: Central Files
Fayetteville Regional Office, Water Quality Section
Stormwater and General Permits Unit Files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060139
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,
PREMIUM STANDARD FARMS
is hereby authorized to discharge stormwater from a facility located at
PREMIUM STANDARD FARMS INC - CLINTON
424 E RAILROAD STREET
. CLINTON
SAMPSON COUNTY
to receiving waters designated as Rowan Branch, a class C SW stream, in the Cape Fear River Basin in accordance
with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II,1II, IV, V, and VI
of General Permit No. as attached.
This certificate of coverage shall become effective July 12, 2002.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day July 12, 2002.
for Alan W. Klimek, P.E. Director
Division of Water Quality
By Authority of the Environmental Management Commission

oto� w a Tp�Q�
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
MARTIN GU1'HRIE
LUNDY PACKING C(.)MPANY
PO BOX 49
CLINTON, NC 28329
Darr Pcrmiltcc:
December 27, 20Of
8 2002
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
Subject: NPDES Stnrntwatcr Permit Rcncwal
LUNDY PACKING COMPANY
C(:)C Numhcr NCG060139
Sampson County,
Your facility is currently covcrecl for stormwater dischar-c under General Permit NCGUfi[ 000. This pel-li it expires
on August 31, 2002. The Division staff is currently in the process of rewriting this Permit and is schtdulcd 10 have;
the perrnit reissued by late sultrmer Of 2002. Once the permit is reissued• your facility would be eligihlC for
continual cnvcra11c u11dcr the reissued hermil.
111 order t0 assure your COntinucd coverage undca' lhC genera] perrnit, you must apply to the Division of Water
Quality (I)WQ) for renewal 01'your pCnrit coverage. To make this renewal process easier, we are informing you in
advance that your perrnit will be expiring. EnCIOSed you Will find a General l'ennit Coverage Renewal
Application Forin. The application must he coHlplctcd and rCW Ied by March 4. 2002 in Order to assure continued
Covcra,C under the general Permit.
Failure to rcyucst renewal within this time period may result in a civil assessment of at least 5250.00. Larger
penalties Hilly he assessed depending on the clelincluency Of the request. Discharge of slurmwater fr0111 your facility
without coveragC. uncicr a valid stornrwater NPDt'S Permit would constitute a violation of NCGS 143-215.1 and
could result i21 assessnlCnts of Civil penalties 01-up to $10.000 per day.
Please note that recent federal legislation has extended the "no cxposurc exClusion" to all operators of industrial
facilities i❑ any of the 1 I categories of "storm water dischai-es associated with industrial activity," (except
construction activities). If you lee] your facility can certify a conditirrn of "no exposure", i.e. the facilly industrial
materials and operations are not exposed ut stormwaler, you Can ,apply for the no exposure exclusion. For additional
information contact the Central OI-fice Stnrntwatcr Staff mcrnher listed below or check the Stornrwater &, Gencrtl
Permits Unit Web Site at http:/Ih2o.cnr.state.11C.uslsulsto1'11rwatcr.litml
If the suhject slormwater dischar,,o to waters of the state has hccn ternlinaled, please complete the enclosed
Rescission Reuli►est F'onn. Mailing, instructions are listccl nn 11C hnttonl of the furttl. You will he notified when Ills
rescission process has been completed,
if you have any clucslions regarding Elie permit renewal prOCduraS please contact Ricky Rcvcls of the F ivcLlcvillc
Regional Office at 910-486-1541 or Aisha L,au 01'1111e Ccnu-al Office Stornlwatcr Unit at [phone], cxl. 578
Sincerely,
Bradley 1 C1111C t, Supervisor
Slornrwater and General Permils Unit
cc: Central files
lr',tyeltcvillc Ru-ional OfflCc
TA
NCDENR
N. C Division o1 Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

THE LUNDY PACKING COMPANY
A DIVISION OF PREMII3M 5'1'A,MnJARI) I.AI2Ms, I;;\C
P.O. BOX 49 CLINTON, NC 2 8 3 2 9- 0 0 4 9
PHONE [phone] FAX [phone]
March 26, 2001
Mr. William C. Mills, P.E.
Division of Water Quality
NC. Dept. of Environment & Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: The Lundy Packing Company
COC No. NCG060139
General Storm Water Permit No. NCG060000
Dear Mr. Mills:
:J
UENR WATER QUALITY
POINT SOURCE BRANCH
The purpose of this letter is to provide you updated information for The Lundy
Packing Company so you can update the DWQ database. I am the new facility contact
person, Please update the following:
Facility Contact: Martin Guthrie
Phone Number: 910-299-3051
Fax Number: 910-299-3016
E-mail: Ilifil'tlll.kllll�ll'ICil7!;;ti{IIl'IllS[1C.COIl1
If I can provide you any further information for your files, please let me know.
Sincerely,
.w�_ e< ,
Martin Guthrie
Manager of Environmental Affairs

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
,James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
A&4
Ad±Nkft09ffNW11d WIL
IDEHNR
September 11, 1997
GEORGE STICKNEY, SR.
LUNDY PACKING COMPANY, THE
PO BOX 49
CLINTON, NC 28329
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG060139
Sampson 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:
in A copy of the stormwater general permit.
■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit. This form must be completed and returned to the Division within 30 days of receipt of
this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
■ Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program with outlines program components
and addresses frequently asked questions.
■ A corrected Certificate of Coverage if you indicated a name or address change on the Renewal
Form returned to the Division.
Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water
Quality may require modification or revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater Group at telephone number [phone]
Sincerely,
for A. Preston Howard, Jr., P. E.
P.Q. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Ms. Dena L. Pittman
Applied Water Technology
621 Hutton Street, Suite 107
Raleigh, NC 27606
Subject: Request for Identical Outfall Exemption
NCG060139
Lundy Packing Company
Sampson County
Dear Ms. Pittman:
Your request to sample stormwater discharges from outfalls #2 and #3 for the above referenced
facility for purposes of NPDES stormwater permit monitoring requirements has been reviewed by Steve
Ulmer of our Water Quality staff. Your request describes 7 outfalls that discharge stormwater from the
facility.
The requested exemption of outfalls #1, and #4 through # 7 is considered warranted in accordance
with Chapter 40 of the Code of Federal Regulation part 122.21 (g) (7). We authorize you to sample at
outfall #2 and outfall #3, as stormwater discharges representative of the runoff from the Lundy facility for
NPDES stormwater permit monitoring requirements. Please keep in mind that this general permit has two
distinct sections of analytical monitoring. Since outfall #2 drains vehicle maintenance areas as well as
other activities on site, both sets of monitoring requirements may apply to this outfall.
If you have any questions concerning this authorization, please contact Steve Ulmer at (919) 733-
5083, Ext. 545.
cc: Fayetteville Regional Offiicev/
Central Files
Facilities Assessment Unit
Permits and Engineering, NCG060139
Asheville Fayetteville Mooresville
704/251-6208 919/486-1541 704/663-1699
Sincerely,
i
A. Preston Howard, Jr., P.E.
Re,,ional Offices
Ralei«h Wasliin;ton \Wilmington Winston-Salem
919/733-2314 919/946-6481 919/395-3900 919/896-7007
Pollrttion Prevention Pays
P.O. Box 29535. Raleigh, forth Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Eniployer

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. D. Dwight Hudson, Jr.
The Lundy Packing Company
P.O. Box 49
Clinton, NC 28328
Dear Mr, Hudson:
June 17, 1994
JUN 2219941
ENV. MANAGEMENT
FAYETTEVILLE REG. OFFICE
Subject: General Permit No. NCG060000
The Lundy Packing Company
COC NCG060139
Sampson County
In accordance with your application for discharge permit received on May 16, 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 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency. dated
December 6, 1983,
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Environmental Management. The Division of Environmental Management may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Steve Ulmer at telephone number 919/733-
5083.
Sincerl,,
�iinal Signed By
Colleen H. Sullins
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 Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE NO. NCG060139
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,
The Lundy Packing Company
is hereby authorized to discharge stormwater from a facility located at
The Lundy Packing Company
424 Railroad Street
Clinton
Sampson County
to receiving waters designated as Rowan Branch in the Cape Fear River Basin
in accordance with the effluent limitations, monitorin, requirements, and other conditions set forth in Parts I, 11, III
and IV of General Permit No. N00060000 as attached.
This Certificate of Coverage shall become effective June 17, 1994.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day June 17, 1994.
()ajgiral Signed BY
Coleen H. Sullins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of die Environmental Management Comrnission

STATE OF NORTH CAROLINA 25 NE
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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
June 17, 1994
Mr. D. Dwight Hudson, Jr.
The Lundy Packing Company
P.O. Box 49
Clinton, NC 28328
Subject: General Permit No. NCG060000
The Lundy Packing Company
COC NCG060139
Sampson County
Dear Mr. Hudson:
In accordance with your application for discharge permit received on May 16, 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 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Environmental Management. The Division of Environmental Management may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Steve Ulmer at telephone number 919/733-
5083.
Sincerely,
Cri> lnal Signed 13Y
Co!een H. Sullins
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 Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE NO. NCG060139
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,
The Lundy Packing Company
is hereby authorized to discharge stormwater from a facility located at
The Lundy Packing Company
424 Railroad Street
Clinton
Sampson County
to receiving waters designated as Rowan Branch in the Cape Fear River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, II,111
and IV of General Permit No. NCGO60000 as attached.
This Certificate of Coverage shall become effective June 17, 1994.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day June 17, 1994.
^irr �1 �i�?t'Eil BY
U ills
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

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