NCG210360_COMPLETE FILE - HISTORICAL_20130716

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
DOC TYPE
1� HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ J G)3 /JT% it,
YYYYMMDD

Pickle, Ken
From:
Georgoulias, Bethany
Sent:
Tuesday, July 16, 2013 12:08 PM
To:
Pickle, Ken; Smith, Danny
Cc:
Bennett, Bradley
Subject:
RE: Carolina Bark
Okay, we'll put them on the list for the batch renewal, unless RRO directs us otherwise. Thanks, guys.
Bg
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ j Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: htp://i3ortal.ncdenr,or_q/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Tuesday, July 16, 2013 11:56 AM
To: Smith, Danny
Cc: Georgoulias, Bethany; Bennett, Bradley
Subject: Carolina Bark
Danny,
I think the path of least resistance for us now is to go ahead and issue NCG21 coverage to Carolina Bark, anticipating that
eventually ali their discharges will cease being surface water discharges (whether stormwater or wastewater), and
instead will be directed to the city's land application system, and under a permit from Matt Fleahman.
(Alternative approaches that jump to mind are to require an individual wastewater permit, or to require coverage under
the compost general permit. But, the proposed APS permit is the best response, it seems to me. Until that happens, their
discharges can be covered under NCG21 nearly as well as under NCG24, and at no additional effort on our part.)
So, we are preparing to go ahead with re -issuance of NCG210360 to Carolina Bark, effective August 1.
Let me know if RRO thinks there's a better approach.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]

�1
Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, July 16, 2013 11:18 AM
To: Georgoulias, Bethany
Cc: Bennett, Bradley
Subject: RE: Carolina Bark NCG210360
Danny to check in with Matt Fleahman in APS.
Danny recalls that the agreed upon resolution was for Carolina Bark to build a pump station and force main and to
deliver the flow to a City (Seaboard) lagoon for land application. Danny's not aware that any permit application has yet
been received by APS. He's checking and will call back. I suppose that will influence his perspective on whether he
wants NCG21 coverage for Carolina Bark.
kbp
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: http://i)ortal.ncdenr.org/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Tuesday, July 16, 2013 11:05 AM
To: Georgoulias, Bethany
Subject: RE: Carolina Bark
Yes, NCG21360.
Talking to Danny on the phone right now.
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(a)ncdenr.gov
Website: http://portal.ncdenr.ora/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins. Director
Division of Water Quality
September 12, 2008
,Willis s Tayl�o_r,
CFT LLC
PO Box 395
Seaboard, NC 27876
Subject: NPDES Stormwater Permit Coverage Renewal
Carolina Bark Products
CO C Number NCG210360
North—� ampton County
Dear Permiltee:
In response to your renewal application for continued coverage under stormwater General Permit NCG210000 the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater General Permit. This permit has been 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.
The following information is included with your permit package:
• A new Certificate of Coverage
• A copy of stormwater General Stormwater Permit NCG210000
• A copy of the 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 to the General Permit include the following:
• Permit cover page, second paragraph — The General Permit now may cover activities that DWQ determines to be similar in
either the process, or in the exposed materials, to the Timber Products Industry.
• Part I Section A — A new provision that facilities draining to 303(d) listed waters, or in watersheds with an approved TMDL,
may not be eligible for continued coverage at the next renewal of the General Permit
• Part I Section B second paragraph — A new clarification that the permit does not authorize discharges that DWQ determines
are wastewaters.
• Part II Section A — The required contents of the Stormwater Pollution Prevention Plan have been expanded and clarified.
• Part II Section B Table 1 —A new requirement to sample stormwater discharges twice per year for those facilities with
exposed piles of certain materials remaining on site longer than seven days.
• Part II Section B Tables 2 and 3 and following — For permittees with exposed piles, there are 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 II Section B — For permittees with exposed piles, 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.
• Part 11 Section C — Clarification that under the qualitative monitoring provisions of the permit, the permittee is obligated to
respond to repeated observations of stormwater pollution. DWQ may impose additional stormwater management
requirements if the permittee is non -responsive, or if the responses are ineffective.
Your coverage under the General Permit is transferable only through the specific action of DWQ.
AloihCarolina
,,vatimally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.uslsulstormwater,html 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

NPDES Stormwater Permit Coverage Renewal
Permit Number NCG_210_360
Page 2
This permit does not affect the legal requirements to obtain other permits which may be required by NCDENR, 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 Bethany GeargIias of the Central Office Stormwater
Permitting Unit at [phone].
Sincerely,
for Coleen H. Sullins
cc: DWQ Central Files
Stormwater Permitting Unit Files
gal legal gh Regional Office

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG210000
CERTIFICATE OF COVERAGE No. NCG210360
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,
CFT LLC
is hereby authorized to discharge stormwater from a facility located at
Carolina Bark Products
Hwy.186 E
Soaboardr
Northampto County
to receiving waters designated as Cypress Creek" ordaris_M f1- nd), a class C;NSW stream in the
Chowan River Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, 111, IV, V, and VI of General Permit No. NCG210000 as attached.
This certificate of coverage shall become effective September 15, 2008.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day September 12, 200&
t51..-.eCl y 1&�11-e--#-~
for Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Michael F. Easley, Governor
of WATF� William G. Ross Jr., Secretary
OCR pG North Carolina Department of Environment and Natural Resources
C j J � ��1 -7 Coleen H. Sullins, Director
Divisicn of Water Quality
C�
March 17, 2008
Mr. Willis P. Taylor
Carolina Bark Products
P.O. Box 395
Seaboard, NC 27g76
Subject: Resolution of Permitting Issues
Carolina Bark Products
NPDES Storrnwater Certificate of Coverage
'�NCG210360r���
Seaboard, NC
Northampton County
Dear Mr. Taylor:
The Division of Water Quality is reviewing the novel proposal Carolina Bark has submitted to eliminate
wastewater and stormwater discharges at Seaboard. We are still conferring among several units about the
proposal, and intend to give you an answer within a few weeks.
The currently active stormwater Certificate of Coverage NCG210360 expires in April 2008, and in a letter
to you dated November 14, 2007, the Raleigh Regional Office (RRO) stated that coverage under the
permit would not be renewed. Due to the time required for your engineered submittal and our review and
decision making, as well as Time for constructing the changes at your facility, your coverage under the
permit ,will have expired before all actions / permitting decisions are complete.
Therefore, Carolina Bark should continue under the current and renewed stormwater permit. Your
application for renewal is already on file, so it will be processed.
Thank you for your attention to this matter. If you have comments or questions, please call me at 919-
791-4200.
Sincer y,
Danny Smi
Surface Water Protection Supervisor
Raleigh Regional Office
xc: Central Files
RRO/SWP files
Ken Pickle, SPU
'4CL)E�`;;:
Raleigh Regional Office 1623 Nfail Service Center phone[phone] Cu s tomer S ervic e
Water Quality Section Raleigh, NC 27699-1628 facsimile (919788-7159 1-877-623-6748

Re: Review of Carolina Bark Proposal
Subject: Re: Review of Carolina Bark Proposal
From: Ken Pickle <[e-mail]>
Date: Mon, 14 Jan 2008 14:48:11 -0500
To: Myrl Nisely <[e-mail]>
CC: Keith Larick <Keith,[e-mail]>
Myrl,
See my comments, inserted below.
Myrl Nisely wrote:
IThe rationale and calculations presented look as though the proposed system should
work.
I've just done a brief spot check, but I concur that so far it seems tht the concept
that there will be no discharge from the windrows seems to be holding up.
I would note, though, from their Porometer Analyses, that aged bark will hold
less water than the in -process windrow material. I presume this commercially
ready bark is stored on Pile 8 on the drawings, which does not have the same
containment berms as the windrows. Am I seeing that correctly?
I do not remember that we discussed any exception for the finished bark pile. My
expectation is that it will also have the short retaining berms. I don't see an
indication on the drawing that Pile 8 is to be treated any differently than Piles 1 -
7.
As noted in their letter report, they still have not submitted a design for the pond
at the low end of the site. The concept discussed in our meeting was that the pond
could be a source of fire water for the windrows, as well as a necessary measure in
order to avoid a stormwater permit . I think that RRO should withhold your ok until
we see the design drawing, design details, and design talcs for the pond. The pond
excavation could potentially be the source for some of the soil necessary to build
the berms.
Without the pond, it seems their approach would be: we have no wastewater discharge,
but we do need a stormwater permit.
With the pond, it seems their approach would be: we have neither wastewater nor
stormwater discharges. Please ok that we need neither permit.
Ken
They are shooting for an operation that will have no permit. We can always drop
by to evaluate, but it will be up to DWQ to keep them in our radar every so often.
Myrl
of 1 1/14/2008 2:48 PM

Carolina Bark, Seabord, North Hampton County
Subject: Carolina Bark, Seabord, North Hampton County
From: Ken Pickle <ken,[e-mail]>
Date: Mon, 11 Feb 2008 12:42:57 -0500
To: Myr1 Nisely <[e-mail]>
CC: Danny Smith <[e-mail]>, Bradley Bennett <Bradl ey.B ennett@ncmail. net>,
Bethany Georgoulias<[e-mail]>, Keith Larick <[e-mail]>
Myrl,
a) Do you want to reply to Carolina Bark as to the acceptability of their response to
your requirements, or do you want me to?
b) For the benefit of the other readers, recall that: Following RRO inspection and
subsequent enforcement, I had a face-to-face meeting with Mid -Atlantic and
representatives of the facility in December (Keith Larick and I met with them); I
received engineering calculations and a design narrative for Carolina Bark on January
2, 2008, from the environmental consultant, Mid -Atlantic. Follow-up civil
construction drawings were received January 29, 2008, from the civil consultant, Jeff
Robinson & Associates.
c) Carolina Bark currently holds our stormwater permit NCG210360 which will expire
4/30/08.
d) Based on an inspection and subsequent enforcement actions by RRO, Carolina Bark
has asked for our review of new construction intended to eliminate all wastewater
discharges from the site, and to eliminate stormwater discharges from the site up to
the 25-yr, 24-hr rain. They have provided the materials typically required for
permit review, except that their purpose is to have our review in support of the
conclusion that no permit of any sort is required.
e) I find their concept acceptable by the regulations, and their site layout and
calculations supportive of the proposed approach. I have one remaining concern on
eliminating the stormwater permit coverage, however.
f) WASTEWATER - They propose to use on -site clay soils located from 20"-108" below
surface to construct berms around each windrow. Based on the retention provided by
the berms, and on the absorbtion provided by the bulk ground wood (mulch), they
present calculations to show that in excess of 5, 25-yr storms would be required to
produce a wastewater discharge from the site - otherwise no wastewater discharge is
produced. I judge the talcs reasonable, and the viability of simple berms good, and
so conclude that they have presented a realistic basis -to conclude that a wastewater
discharge will not occur from this site except by system failure or gross lack of
attention.
g) STORMWATER.- The other areas of the site (other than the windrows) will drain to
the proposed holding pond located at the low end of the site. The volume
calculations establish that the pond has the volume to contain the 25-yr, 24-hr
rainfall from the site without any discharge (including 1' freeboard). The necessary
holding volume is made available by the periodic pumping of the pond in order to
provide regular moisture content in the windrows to prevent fires. On the point of
the reliability of the pumping down, I'm not so sure. It seems to me that we could
go ahead and renew their coverage under NCG21 in the next couple of months. Then, if
they get two weeks of rain (when they wouldn't be applying rainwater for fire
control, obviously), and the pond fills up, they would still have a permit to
discharge the stormwater.
In my opinion, the best end result here is: build the berms around the windrows, and
thereby eliminate any wastewater discharges; build the pond and use the collected
stormwater for moisture content for fire control; keep stormwater coverage under
NCG21 so that any unanticipated stormwater discharge is not 'discharging without a
permit.'
To me it looks like there is one possible point of negotiation with them on the above
approach. They might comment, "We thought that if we built the pond, DWQ would not
1 of 2 2/11/2008 12:46 PM

Carolina Bark, Seabord, North Hampton County
have a stormwater discharge, and we could eliminate the stormwater permit. If you're
going to require a permit anyway, we'll eliminate the pond, or we will build a much
smaller pond (cheaper)." I would point out that the pond might be viewed as a
back-up system for the berms around the windrows, just in case of a failure there.
That could prevent a circumstance of discharging wastewater without a permit. It
seems to me that they will likely excavate the pond, and use the clay soils as the
berm material. 5o, a hole of some size will be there, already. It seems to me that
we should push for the full size pond (25-yr), and the stormwater permit coverage,
too.
Do you want to write them, or do you want me to?
Ken
2 of 2 2/11/2008 12:46 PM

Re: Carol: Sark, Seabord, North Hampton County
Subject: Re: Carolina Bark, Seabord, North Hampton County
From: Ken Pickle <[e-mail]>
Date: Mon, 11 Feb 2008 15:03:02 -0500
To: Keith Larick <[e-mail]>
CC: Bradley Bennett <[e-mail]>, Myrl Nisely <[e-mail]>, Danny
Smith <Danny,[e-mail]>, Bethany Georgoulias<[e-mail]>, Jon
Risgaard <[e-mail]>
Hi Keith,
Just to clarify, and just so that we in stormwater don't make a call that might
should fall to you guys in AP:
Their proposal is to spray collected stormwater onto the wood chip piles for moisture
control/fire control. They have asserted that the windrow will absorb all the water,
and that none will leave the windrow, up to as much as the equivalent of -5, 25-yr
storms. I can provide you with the bench top data in support of their assertion as
to the liquid absorbtion capacity of the windrowed wood chips, if you didn't get a.
copy in our meeting. So, they have asserted that between the absorbtive capacity of
the chips, and the confining berms, there will not be any discharge to surface waters
from the windrows, and therefore no wastewater discharge to surface waters, and no
recycle down to the stormwater collection pond.
I think I understand that per your program, that since they won't be spraying
wastewater (just stormwater), then therefore they don't need a recycle permit.
However, I'm unsure how your program might look at what happens after the collected
stormwater is sprayed onto the windrows. For example, I'm not sure how/if your
program might evaluate the possibility of a groundwater impact underneath the
windrows. So, on this point, or on any other related points, can you provide some
comment wrt the Carolina Bark facility?
I note that last week while on a site visit with Jon Risgaard, I believe Jon was
struggling with a similar question wrt how to address the liquid that might be at the
interface between the windrow base and the supporting soil surface.
Ken
Keith Larick wrote:
Ken Pickle wrote:
Thanks, Bradley.
Keith, would you comment, please?
Ken
Bradley Bennett wrote:
Ken
I just add one thing to your comments. In terms of the wastewater part fo
the project, we need to make sure that AP is okay with the proposal and.it
meets their criteria as a nondischarge system.
BB
Ken Pickle wrote:
1 of 3 2/1 1/2008 3:05 PM

Re: Carolina Bark, Seabord, North Hampton County
Myrl,
a) Do you want to reply to Carolina Bark as to the acceptability of their
response to your requirements, or do you want me to?
b) For the benefit of the other readers, recall that: Following RRO
inspection and subsequent enforcement, I had a face-to-face meeting with
Mid -Atlantic and representatives of the facility in December (Keith
Larick and I met with them); I received engineering calculations and a
design narrative for Carolina Bark on January 2, 2008, from the
environmental consultant, Mid -Atlantic. Follow-up civil construction
drawings were received'January 29, 2008, from the civil consultant, Jeff
Robinson & Associates.
c) Carolina Bark currently holds our stormwater permit NCG210360 which
will expire 4/30/08.
d) Based on an inspection and subsequent enforcement actions by RRO,
Carolina Bark has asked for our review of new construction intended to
eliminate all wastewater discharges from the site, and to eliminate
stormwater discharges from the site up to the 25-yr, 24-hr rain. They
have provided the materials typically required for permit review, except
that their purpose is to have our review in support of the conclusion
that no permit of any sort is required.
e) I find their concept acceptable by the regulations, and their site
layout and calculations supportive of the proposed approach. I have one
remaining concern on eliminating the stormwater permit coverage, however.
f) WASTEWATER - They propose to use on -site clay soils located from
20"-108" below surface to construct berms around each windrow. Based on
the retention provided by the berms, and on the absorbtion provided by
the bulk ground wood (mulch), they present calculations to show that in
excess of 5, 25-yr storms would be required to produce a wastewater
discharge from the site - otherwise no wastewater discharge is produced.
I judge the calcs reasonable, and the viability of simple berms good, and
so conclude that they have presented a realistic basis to conclude that a
wastewater discharge will not occur from this site except by system
failure or gross lack of attention.
g) STORMWATER - The other areas of the site (other than the windrows)
will drain to the proposed holding pond located at the low end of the
site. The volume calculations establish that the pond has the volume to
contain the 25-yr, 24-hr rainfall from the site without any discharge
(including 1' freeboard). The necessary holding volume is made available
by the periodic pumping of the pond in order to provide regular moisture
content in the windrows to prevent fires. On the point of the
reliability of the pumping down, I'm not so sure. It seems to me that we
could go ahead and renew their coverage under NCG21 in the next couple of
months. Then, if they get two weeks of rain (when they wouldn't be
applying rainwater for fire control, obviously), and the pond fills up,
they would still have a permit to discharge the stormwater.
In my opinion, the best end result here is: build the berms around the
windrows, and thereby eliminate any wastewater discharges; build the pond
and use the collected stormwater for moisture content for fire control;
keep stormwater coverage under NCG21 so that any unanticipated stormwater
discharge is not 'discharging without a permit.'
To me it looks like there is one possible point of negotiation with them
on the above approach. They might comment, "We thought that if we built
the pond, DWQ would not have a stormwater discharge, and we could
eliminate the stormwater permit. If you're going to require a permit
anyway, we'll eliminate the pond, or we will build a much smaller pond
(cheaper)." I would point out that the pond might be viewed as a back-up
2 of 3 2/11/2008 3:05 PM

Re: Caro11�-_
Bark, Seabord, North Hampton County
w'
system for the berms around the windrows, just in case of a failure
there. That could prevent a circumstance of discharging wastewater
without a permit. It seems to me that they will likely excavate the
pond, and use the clay soils as the berm material. So, a hole of some
size will be there, already. It seems to me that we should push for the
full size pond (25--yr), and the stormwater permit coverage, too.
Do you want to write them, or do you want me to?
Ken
Ken,
I assume any leachate resulting from water they spray on the piles will be
contained by the berms. If their proposal is to spray only collected stormwater
(or possibly well water if the pond is empty) on to the piles, then there is no
need for a non -discharge permit.
They would only need a permit for a recycle system if they were spraying
wastewater.
Keith
3 of 3 2/1 1/2008 3:05 PM

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
February 15, 2008
Mr. Willis P. Taylor
Carolina Bark Products
P.O. Box 395
Seaboard, NC 27876
Subject: Resolution of Permitting Issues
Carolina Bark Products
NPDES Stormwater Certificate of Coverage
NCG210360
Seaboard, NC
Northampton County
Dear Mr. Taylor:
The Division of Water Quality is reviewing the novel proposal Carolina Bark has submitted to eliminate
wastewater and stormwater discharges at Seaboard. We are still conferring among several units about the
proposal, and intend to give you an answer within a few weeks.
The currently active stormwater Certificate of Coverage NCG210360 expires in April 2008, and in a letter
to you dated November 14, 2007, the Raleigh Regional Office (RRO) stated that coverage under the
permit would not be renewed. Due to the time required for your engineered submittal and our review and
decision making, as well as time for constructing the changes at your facility if the OK is granted, your
coverage under the permit will have expired before all actions can be completed.
In the interim period, Carolina Bark should continue under the current and renewed stormwater permit.
Your application for renewal is already on file, so we will process it. This effectively reverses RRO's
November 14; 2007 letter notifying you that DWQ would not allow you to renew under NCG21. We
regret the extra step, and hope to arrive at a satisfactory solution for your production facility in the near
future.
If you have comments or questions, please call me at 919-791-4200.
Sincerely,
at% MAI s�i,q_n�ey�l brY
Myrl A. Nisely
Environmental Chemist
Raleigh Regional Office
xc: Central Files
RRO/SWP files
Ken Pickle, SPU
Raleigh Regional Office 1628 Mail Service Center phone [phone] Customer Service
Water Quality Section Raleigh, NC 27699-1628 facsimile (919788-7159 1-877-623-6748
+t:�'�;h

�OF W A T�c9Q
O G�
c) rl
7
O ^c
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
v
March 17, 2008
Mr. Willis P. Taylor P
Carolina Bark Products V'
P.O. Box 395
Seaboard, NC 27876R�
Subject: Resolution of Permitting Issues
Carolina Bark Products
NPDES Stormwater Certificate of Coverage
NCG2103 60
Seaboard, NC
Northampton County
Dear Mr. Taylor:
The Division of Water Quality is reviewing the novel proposal Carolina Bark has submitted to eliminate
wastewater and stormwater discharges at Seaboard. We are still conferring among several units about the
proposal, and intend to give you an answer within a few weeks.
The currently active stormwater Certificate of Coverage NCG210360 expires in April 2008, and in a letter
to you dated November 14, 2007, the Raleigh Regional Office (RRO) stated that coverage under the
permit would not be renewed. Due to the time required for your engineered submittal and our review and
decision making, as well as time for constructing the changes at your facility, your coverage under the
permit will have expired before all actions / permitting decisions are complete.
Therefore, Carolina Bark should continue under the current and renewed stormwater permit. Your
application for renewal is already on file, so it will be processed.
Thank you for your attention to this matter. If you have comments or questions, please call me at 919-
791-4200.
Jy,
l
Danny Smi
Surface Water Protection Supervisor
Raleigh Regional Office
xc: Central Files
RRO/SWP files
Ken Pickle, SPU
Raleigh Regional Office 1628 Mail Service Center phone [phone] Customer Service
Water Quality Section Raleigh, NC 27699-1628 facsimile (919788-7159 1-877-623-6748
��:=:s
P+ICI)Et�;i

Carolina Bark
Subject: Carolina Bark
From: Ken Pickle <ken.pickle@ncmall .net>
Date: Mon, 17 Mar 2008 09:46:45 -0500
To: "'Dan Nielsen (E-mail)"' <[e-mail]>
CC: Darin McClure <[e-mail]>, Myr] Nisely <[e-mail]>, Bradley
Bennett <[e-mail]>
Dan,
I apologize for not yet returning your couple of calls over the last month. Your
December 28, 2007 letter report to Danny Smith asked for the ok on a "no permit
required" approach, We have hit an internal snag with getting all DWQ groups
comfortable with the Carolina Bark proposal. This has as much to do with our
programmatic coordination as it does with the physical circumstances and proposed
modifications at Carolina Bark. 1 apologize for our delay.
I'm sending you this electronic copy of our letter to Perk Taylor in advance of our
site visit tomorrow. I'd like to send it to Mr. Taylor, too. Do you have an email
address for him?
We're asking Carolina Bark to continue under the existing Certificate of Coverage
NCG210360 (valid until 4/30/08), and the renewed NCG21 (valid beginning 5/l/08) while
we work to produce clear direction for Carolina Bark.
Ken
Content -Type: application/msword
CarBarkRenewSW408.doc
Content -Encoding: base64 '
1 of] 3/17/2008 9:47 AM

Carolina Bark
L
Subject: Carolina Bark
From: Ken Pickle <[e-mail]>
Date: Mon, 17 Mar 2008 10:09:26 -0500
To: [e-mail]
CC. Myrl Nisely <myrl.nisely@ncmail. net>, Bradley Bennett <[e-mail]>
Mr. Taylor,
T apologize for our delay in responding to your December 28, 2007 (by Mid -Atlantic)
proposal on stormwater and wastewater controls. I'm forwarding the attached letter
from DWQ's Raleigh Regional Office in advance of our site visit tomorrow.
DWQ is now requesting that you continue under the stormwater general permit
(NCG210000) for the remainder of the current per duration (i.e. through 4/30/08),
and then likewise continue under the general permit after it is renewed by our unit
(on 5/l/08), until such time (pretty soon we hope) as we can provide clearer
direction for Carolina Bark. Our site visit tomorrow is intended to help us with
that task.
Ken Pickle
[phone]x584
Content -Type: application/msword ,
CarBarkRenewSW408.doe
Content -Encoding: base64
l of 1 3/17/2008 10:09 AM

Carolina Bark Mulcher/Composter meeting with Mid -Atlantic
Subject: Carolina Bark Mulcher/Composter meeting with Mid -Atlantic
From: Ken Pickle <[e-mail]>
Date: Wed, 21 Nov 2007 15:33:37 -0500
To: Myrl Nisely <myrl.nisely a ncmat'Lnet>
CC: Bethany Georgoulias<[e-mail]>, Bradley Bennett
<[e-mail]>, Gil Vinzani <[e-mail]>
Myrl,
FYI , no action, update only. `
Darin McClure and Dan Nielsen(?) from Mid -Atlantic met with me this morning to
discuss two topics. First, infiltration schemes under NCG14; and second,
infiltration as a part of stormwater permitting to address Danny's/your November 14,
2007 letter to Carolina Bark in Seaboard (North Hampton County.)
As you predicted on the second topic, I had to re-establish DWQ solidarity on the
point that we believe that flows that contact windrows are wastewaters. Again, as
you reported, Dan had to talk a long time (to be sure that I understood the site and
project circumstances) building up to the crux of the issue, which is our current
working distinction between wastewater and stormwater on these sites.
He reported their current status vis-a-vis permitting options as:
a) At a dead end with Keith Larrick, RRO, and AP for a recycle permit due to the site
being too small to accomodate the buffer/set-back requirements under the rules of
that program.
b) Exploring with me the possibility of a stormwater permit for the composting -water
recycle system plus the discharge that occurs only in response to rainfall. This
gets to the wastewater/stormwater point that you discouraged them on, and that I
re -discouraged them on this morning. They sought to somehow make the jump from an
infiltration system handling mixed NCG14 waters to why can't we similarly permit
composter wastewater (and in this circumstance it suited their objective to argue
that the leachate-wastewater was really stormwater) under a stormwater permit? They
quite amiably suggested that on the point of definition of wastewater we might need a
legal determination. I quite amiably responded that we had received such comments
before (Wallace Farms) and that the lawsuit route had evaporated when we did not
cave, and when another alternative was present (discharge to CMUD).
c) They did note that Carolina Bark wants to comply, and they implied that the delay
from your visit in 2003 to your 11/14/07 letter was at least partly due to pursuing
with Keith a recycle system permit, and the delay encountered in stepping through
that program before reaching a dead end. I advised them to check out the new 2T rules
in Keith's program to see if new opportunities might now exist for Carolina Bark.
They also reported that Carolina Bark hired several engineers previously who either
did not understand the big picture, or were not hired to address the big picture of
permitting. They further reported that Carolina Bark has stopped using fertilizer as
a process accelerant in the windrows.
d) They had not explored an NPDES wastewater permit for this site, but 1 gave them
Gil Vinzani's name and Matt Matthews' name as contacts.
I observed that it appeared that they now understood DWQ's perspective, and that I
was open to reconsidering a stormwater permit if they could propose a clever way to
allow us to permit the discharge within the constraints that apply to our program,
but that it was very unlikely we would backslide on our wastewater/stormwater
distinction. I re -iterated that when NCG21 is renewed in 2008, we will be looking at
which discharges may no longer qualify as stormwater.
Based on the little I know about their circumstances, it occurs to me that their
best/only remaining alternative to closing down or covering the site, would be to
install a wastewater treatment system and obtain a wastewater permit from Gil. I
imagine that they might be able to recycle the process water (currently obtained from
l of2 11/21/2007 3:40 PM

Carolina Bark Mulcher/Composter meeting with Mid -Atlantic
a dedicated on -site well) from a new pond rather than the well, and that any overflow
from that "process pond" could flow to a "waste treatment pond", and the discharge
from that pond must meet the limits Gil places in his NPDES wastewater permit.
Without knowledge of the actual flow numbers involved, my hope in this two -pond
system is that perhaps there would be a reduced volume of wastewater that may have to
be treated, and consequently a reduced operating cost, perhaps even the possibility
of a batch operation on the wastewater pond, rather than a more traditional
flow -through operation. It all depends on the physical facts as to site
configuration and leachate volume and recycle demand. The second pond (the
wastewater treatment pond, as opposed to the process water pond) might even be
located on an adjacent piece of property that Carolina Bark might be'able to lease or
buy, as reported by Dan and Darin. They indicated that a pump would be required to
deliver wastewater to this adjacent property. It seems to me that this avenue of
investigation is all that's left to them, and that it actually may be very
promising. Gil's group would have to evaluate all this, of course.
Ken
2 of 2 1 1/21/2007 3:40 PM

Carolina Bark Mulcher/Composter meeting with Mid -Atlantic
Subject: Carolina Bark Mulcher/Composter meeting with Mid -Atlantic NCC 2 t 0_?6 0
From: Ken Pickle <[e-mail]>
Date: Wed, 21 Nov 2007 15:33:37 -0500
To: Myrl Nisely <[e-mail]>
CC: Bethany Georgoulias <[e-mail]>, Bradley Bennett
<[e-mail]>, Gil Vinzani <[e-mail]>
Myrl,
FYI , no action, update only.
Darin McClure and Dan Nielsen(?) from Mid -Atlantic met with me this morning to
discuss two topics. First, infiltration schemes under NCG14; and second,
infiltration as a part of stormwater permitting to address Danny's/your November 14,
2007 letter to Carolina Bark in Seaboard (North Hampton County.)
As you predicted on the second topic, I had to re-establish DWQ solidarity on the
point that we believe that flows that contact windrows are wastewaters. Again, as
you reported, Dan had to talk a long time (to be sure that I understood the site and
project circumstances) building up to the crux of the issue, which is our current
working distinction between wastewater and stormwater on these sites.
He reported their current status vis-a-vis permitting options as:
a) At a dead end with Keith Larrick, RRO, and AP for a recycle permit due to the site
being too small to accomodate the buffer/set-back requirements under the rules of
that program.
b) Exploring with me the possibility of a stormwater permit for the composting -water
recycle system plus the discharge that occurs only in response to rainfall. This
gets to the wastewater/stormwater point that you discouraged them on, and that I
re -discouraged them on this morning. They sought to somehow make the jump from an
infiltration system handling mixed NCG14 waters to why can't we similarly permit
composter wastewater (and in this circumstance it suited their objective to argue
that the leachate-wastewater was really stormwater) under a stormwater permit? They
quite amiably suggested that on the point of definition of wastewater we might need a
legal determination. I quite amiably responded that we had received such comments
before (Wallace Farms) and that the lawsuit route had evaporated when we did not
cave, and when another alternative was present (discharge to CMUD).
c) They did note that Carolina Bark wants to comply, and they implied that the delay
from your visit in 2003 to your 11/14/07 letter was at least partly due to pursuing
with Keith a recycle system permit, and the delay encountered in stepping through
that program before reaching a dead end. I advised them to check out the new 2T rules
in Keith's program to see if new opportunities might now exist for Carolina Bark.
They also reported that Carolina Bark hired several engineers previously who either
did not understand the big picture, or were not hired to address the big picture of
permitting. They further reported that Carolina Bark has stopped using fertilizer as
a process accelerant in the windrows.
d) They had not explored an NPDES wastewater permit for this site, but I gave them
Gil Vinzani's name and Matt Matthews' name as contacts.
I observed that it appeared that they now understood DWQ's perspective, and that I
was open to reconsidering a stormwater permit if they could propose a clever way to
allow us to permit the discharge within the constraints that apply to our program,
but that it was very unlikely we would backslide on our wastewater/stormwater
distinction. I re -iterated that when NCG21 is renewed in 2008, we will be looking at
which discharges may no longer qualify as stormwater.
Based on the little I know about their circumstances, it occurs to me that their
best/only remaining alternative to closing down or covering the site, would be to
install a wastewater treatment system and obtain a wastewater permit from Gil. I
imagine that they might be able to recycle the process water (currently obtained from
1 of2 1 1/21/2007 3:39 PM

Carolina Bark Mulcher/Composter meeting with Mid -Atlantic
a dedicated on -site well) from a new pond rather than the well, and that any overflow
from that "process pond" could flow to a "waste treatment pond", and the discharge
from that pond must meet the limits Gil places in his NPDES wastewater permit.
Without knowledge of the actual flow numbers involved, my hope in this two -pond
system is that perhaps there would be a reduced volume of wastewater that may have to
be treated, and consequently a reduced operating cost, perhaps even the possibility
of a batch operation on the wastewater pond, rather than a more traditional
flow -through operation. It all depends on the physical facts as to site
configuration and leachate volume and recycle demand. The second pond (the
wastewater treatment pond, as opposed to the process water pond) might even be
located on an adjacent piece of property that Carolina Bark might be able to lease or
buy, as reported by Dan and Darin. They indicated that a pump would be required to
deliver wastewater to this adjacent property. It seems to me that this avenue of
investigation is all that's left to them, and that it actually may be very
promising. Gil's group would have to evaluate all this, of course.
Ken
2 of 2 11/21/2007 3:39 PM

F WATF Michael F. Easley, Governor
9 William G. Ross Jr., Secretary
`OCR QG North Carolina Department of Environment and Natural Resources
cor Coleen H. Sullins, Director
Division of Water Quality
November 14, 2007
CERTIFIED MAIL 7006 0810 0002 6049 5402
RETURN RECEIPT REQUESTED
Mr. Willis P. Taylor
Carolina Bark Products
P.O. Box 395
Seaboard, NC 27876
Subject: Stormwater Permit Renewal Disallowed
Carolina Bark Products
NPDES Stormwater Permit NCG210360
Seaboard, NC
Northampton County
Dear Mr. Taylor:
On October 27, 2003 Ms. Judy Garrett and Mr. Myrl Nisely of the Raleigh Regional Office of
Division of Water Quality, conducted an inspection and determined that discharges of
unauthorized process wastewaters from Carolina Bark into Cypress Swamp was occurring. An
effort was made to establish and permit a non -discharge recycle system, but this encountered
technical barriers, and was not accomplished. There has been no satisfactory resolution of this
issue since that time.
Stormwater permit NCG21060 expires on April 30, 2008. An alternative method for handling
wastewater generated at the facility must be identified and designed before,the stormwater
permit expires on April 30, 2008. Discharges after that date taking place without a permit will
subject Carolina Bark to civil penalty assessments of up to $25,000 per day.
Accordingly, an application for a wastewater permit is to be submitted to either the Discharge
Section or the Non -discharge permitting Section by December 31, 2007, depending upon
technology selected. If an Authorization to Construct (AtC) request is needed (for a
discharging system), it is to be submitted to the Construction, Grants and Loans Section for
approval by the end of January 2008.
If you have comments or questions, please call Keith Larick or Myrl Nisely of the Raleigh
Regional Office at 919-791-4200.
Sincerely,
Danny Smith
Raleigh Regional Supervisor
Surface Water Protection Section
xc: Bradley Bennett, Stormwater Permitting
Keith Larick, RRO Aquifer Protection Section
Central Files
Raleigh Regional Office 1628 Mail Service Center phone [phone] Customer Service
Water Quality Section Raleigh, NC 27699-1628 facsimile [phone] 1-877-623-6748
TWAT
NCD NR

ti �QF W 9 Michael F. Easley
`fit QG Governor
</J William G. Ross Jr., Secretary
y Department of Environment and Natural Resources
4 `r Alan W. Klimek, P.E., Director
Division of Water Quality
April 25, 2003
Mr. W. P. Taylor, Member CET, LLC
Carolina Bark Products
PO Box 395
Seaboard, NC 27876
Subject: General Permit No. NCG210360
Carolina Bark Products
COC NCG210360
Northampton County
Dear Mr. Taylor:
In accordance with your application for discharge permit, for coverage under NCG210000, received on October
20, 2002 and the subsequent information that you submitted at our request, 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 May 9, 1994 (or as subsequently amended).
If any parts, measurement frequencies or sampling requirements contained in this permit ai-e 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 Water
Quality. 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 the Division
of Water Quality 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 Bill Mills at telephone number 919/733-5083 ext.
61
Sincerely,
ad.ti ;, � .� y.�w-. its<!"��� �' ,v,l�.°•"
Alan W. Klimek, P.E.
cc: Raleigh Regional Office
Central Files
Stormwater and General Permits Unit Files
_
�� '1 A
19T V —PIR
Customer Service
1 800 623-7748
Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG210000
CERTIFICATE OF COVERAGE No. NCG210360
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELINIINATION 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,
CFT, LLC. TIA Carolina Bark Products
is hereby authorized tostormwater from a facility located at
Carolina Bark Products
Highway 186 East
east of Seaboard
Northampton County
to receiving waters designated as an unnamed tributary to Cypress Creek in the Chowan River Basin in accordance
with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, 11, III, IV, V, VI and
VII of General Permit No. NCG210000 as attached.
This certificate of coverage shall become effective April 25, 2003.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 25, 2003_
TLIAM, C.
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

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Markers
Name: Discharge Site-NCG210360
Short Name: Dschrg
Coordinates: 036' 29' 16.8" N, 077' 25' 05.0" W
Comment: Carolina Bark Products, Subbasin 030102, Chowan River Basin, Northampton
County, unnamed tributary to Cypress Creek, Class C-NSW, Quad A29SW

.1
JF
Proposed Agenda for Meeting to Review Status of Carolina Bark Permit
Wednesday, January 5, 2011, 9:30 AM
RRO Second Floor Conference Room
Discussion Items
1) quick review of pictures of the site
2) review the 7 year communication history in order to establish an awareness of
previous technical discussions and attitudes on the part of both DWQ and Carolina Bark
(CBark)
3) explore technical options
4) arrive at a technical and regulatory position that DWQ will insist on achieving,
projecting the likely impacts on both CBark and West Fraser Lumber Co..
5) merits of a meeting with the two companies: attendees, location, timeframe

6
DATA FORM
ROUTINE WETLAND DETERMINATION .
(1987 COE Wetlands Delineation Manual)
Project/Site: Anderson Creek North
Date: January 31, 2007
Applicant/ Owner: Anderson Creek Partners
County: Harnett
Investigator: Amber L. Coleman
State: NC
Do !Normal Circumstances exist on the site? YES NO
Community ID: U land
Is the site significantly disturbed (Atypical Situation)? YES NO
Transect ID:
Is the area a potential Problem Area? (if needed, explain on reverse) YES NO
Plot ID: Whis ering Pines Drive
VEGETATION
Dominant Plant Species
Scientific Name
Stratum
Indicator
1 Bracken fern
Pteridium a uilinum
herb
FACU
2 Loblolly pine
Pines taeda
canopy
FAG
3 Turkey oak
Quercus laevis
canopy
NI
4
5
6
7
8
9
10
11
12
13
14
15
16
Percent of Dominant Species that are OBL, FACW, or FAC Kexcluding FAC- : 33%
Remarks:
HYDROLOGY
[ ] Recorded Data (Describe in Remarks)
[ j Stream, Lake, or Tide Gauge
[ ] Aerial Photographs
[ ] Other
[XI No Recorded Data Available
FIELD OBSERVATIONS
Depth of Surface Water
Depth of Free Water in Pit
Depth to Saturated Soil
WETLAND HYDROLOGY INDICATORS
Primary Indicators:
[ ] Inundated
[ ] Saturated in Upper 12 Inches
[ ] Water Marks
[ ] Drift Lines
[ ] Sediment Deposits
[ ] Drainage Patterns in Wetlands
- (in) Secondary Indicators (2 or more Required)
[ ] Oxidized Root Channels in Upper 12 inches
(in) [ ] Water -stained Leaves
[ ] Local Soil Survey Data
(in) i ] FAC-Neutral Test
Other Ex lain in Remarks

t
J
Status Review Meeting on Carolina Bark, Tuesday July 28, 2009
and again on January 5, 2011 @ 9:30 AM, C.R. 42
Attendees: Dandy Smith, Jay Zimmernnan, Matt Fleahman, .Ton Risgaard, David Goodrich, Ken
Pickle, Michael Scott, Tom Ascenzo, Myrl Nisely
History of the Permitting of this Bark Processing Facilitv:
(Will view Webshots photos as needed)
NCG210360 was issued 4/25/03 and expired 4130108. it was reissued 8/1/209 (mistakenly) as
discussed below.
On October 27, 2003, samples were taken from puddles about 1/3 ofthe way from the North
fence line separating the lumber mill (now West Fraser) from Carolina Bark (CBark).
Location
Conductivity
Tem .
D.O.
H
BOD
Upstream North
1760
20.2
0.51
5.3
3900
Upstream South
1971
22.4
0.44
3.6
19,000
Downstream Near Hwy641
22.)
0.70
3.2
1700
Units
mhos/cm
Degrees C
m JIl
Std scale
m T/l
Location
Nutrients — NI-13
TKN
NO2 +NO3
Total P
Upstream North
0.19
6.4
0.03
3.9
Upstream South
59
120
0.08
16
Downstream Near Hwy
3.$
14
0.64
5.4
Units
nig/1
I mg/1
m&l
1112/1
In a letter dated 12/5/2003, they were told that release of what amounted to wastewater was to
either stop or be treated to acceptable levels. (7 yrs agog) They were to submit a plan by 1/31/04.
WQ0024420: An incomplete plan for recycle was submitted to Duane Leith 8/25/04. In letter
dated 11/1/04 he asked for more info by 12/l/04. They answered in a letter of 1 1/29/04 with all
but a water balance. They were working on that data.
Letter dated 5/20/05 to them states that the water balance never arrived, so the application is
being returned. If they submit the absent data it will require a ne-w application and ne,,v fee.
WQ0028987: review of a new submittal again lacked many details. Letter of 8/25/05 requested
more info by 9/23/05. [side comment — many of the missing details they claim to have answered
earlier were again requested in this letter. Do we hold on to an earlier submittal and use info
from it?] CBark verbally asked for an extension to 1 1/2/05.
Letter of 12/12/05 returned this package because data was never submitted. (is now 2 yrs from
original 2003 letter)

P
SOILS
Map Unit Name (Series and Phase):
Drainage Class:
Taxonomy (Subgroup):
Field Observations Confirm Mapped Type? YES NO
Depth Horizon
inches
Matrix Color
Munsell Moist
PROFILE DESCRIPTION
Mottle Colors Mottle Texture, Concretions,
Munsell Moist Abundance/Contrast Structure, etc.
0-6
10YR616
S
6-9
10YR 311
SL
9 - 18+
10YR 5/6
LS
HYDRIC SOIL INDICATORS:
[ ] Histosol
[ ] Histic Epipedon
[ ] Sulfidic Odor
[ ] Aquic Moisture Regime
[ ] Reducing Conditions
Gle ed or Low-Chroma Colors
[ ] Concretions
[ ] High Organic Content in Surface Layer in Sandy Soils
[ ] Organic Streaking in Sandy Soils
[ ] Listed on Local Hydric Soils List
[ ] Listed on National Hydric Soils List
Other (Explain in Remarks
Remarks:
WETLAND DETERMINATION
Hydrophytic Vegetation Present? YES NO
Wetland Hydrology Present? YES NO Is this Sampling Point Within a Wetland? YES NO
Hydric Soil Present? YES NO
Remarks:

Page 2
WQ0029752: CBark reapplied 1/12/06.
A staff report by Keith I crick resulted from a site visit 2/15/06. Mulch stored beyond map
designations, concerns about wells, hydrogeological study and many other details from APS
point of view.
Letter 6/12/06 from .I. Zimmerman requested additional info again in 30 days. Outlined the
requirements for wells and buffer zones.
CBark engaged Mid -Atlantic Consultants, letter 7/7106. Spoke of 3 possible approaches.
Letter received 7/11/06 asked for 120 day extension, wonders if there is a way to remain covered
by NCG21. Letter of 8/7/06 from Larick denied that possibility, reset clock to 9/11/06
Letter .10/19/07 returned this package because information was never submitted.
Letter 11/14/07 from Danny Smith titled Storrnwater Permit Renewal Disallowed. Permit
expired 4/30/08. Alternative must be found, or fines for discharging w/o permit would begiil
4/3 0.
.mail 11/21/07 from Ken Pickle to Myrl Nisely et al summarized discussion with Mid -Atlantic
On 8/1/08 NCG210365 was inadvertently reissued to C13ark as part ol'a batch renewal event by
Bradley's group. Tllis one had not been flagged for denial. Still in effect until 2013.
Sunimary of Issues
Soil maps show a blue line stream travels down the center of this site, exiting through a culvert
under Hwy 186 into a swamp.
A mulch facility field trip showed clearly that leachate comes from the piles into the stream. At
the time of this visit, CBark was creating a pond. No A to C, no input from us, apparently. Has
no liner. A discharge pipe was installed, so releases occur Linder the reissued NCG21. Any
sampling data in their possession?
On an advertised visit on 6/9/09, it was found that CBark had raised (lie level of the discharge
pipe and allegedly has been pumping down the pond level to create the illusio1i of a non -
discharge pond before our arrival. Previous pictures just before that visit, unknown to them,
clearly show a discharge and that this was a last minute modification. Samples taken that day:
Analytical Results from Sampling Carolina Bark on 6/9/2009
Field Parameters All in mg/I
T, deg C pH Conduct DO Total P NH3 NO2+NO3 TKN Tot N BOD5
Influent 22.0 5.9 138 0.14 1.2 0.03 0.02 2.5 2.52 56
MidPoint 25.5 4.5 605 0.09 7.3 0.31 0.03 7.2 7.23 260
Effluent 28.3 3.4 880 0.05 11 0.32 0.08 6.9 6.98 280

T
DATA FORM
ROUTINE WETLAND DETERMINATION
(1987 COE Wetlands Delineation Manual)
Project/Site: Anderson Creek North
Date: January 31, 2007
Applicant 1 Owner: Anderson Creek Partners
County: Harnett
Investigator: Amber Coleman 1 Melissa Ruiz
State: NC
Do Normal Circumstances exist on the site? YES NO
Community ID: Wetland
Is the site si nificantl disturbed Atypical. Situation)? YES NO
Transect ID:
Is the area a potential Problem Area? (if needed, explain on reverse) YES NO
Plot ID: Whispering Pines Drive
IIXe%�III [d:i
Dominant Plant Species
Scientific Name
Stratum
Indicator
1 Fetterbush
L onia lucida
shrub
FACW
2 Laurel -leaf greenbriar
Smilax laurifolia
vine
FACW}
3 Giant cane
Arundinaria gigantea
herb
FACW
4 Inkberry
flex coriacea
shrub
FACW
5 Tulip poplar
Lidodendron tuli ifera
canopy
FAC
6
7
8
9
10
11
12
13
14
15
16
Percent of Dominant Species that are OBL, FACW, or FAC(excluding FAC-): 100%
Remarks:
HYDROLOGY
[ j Recorded Data (Describe in Remarks) WETLAND HYDROLOGY INDICATORS
[ ] Stream, Lake, or Tide Gauge Primary Indicators:
[ ] Aerial Photographs [ ] Inundated
[ ] Other [ x ] Saturated in Upper 12 Inches
[ ] Water Marks
[X] No Recorded Data Available [ ] Drift Lines
[ x ] Sediment Deposits
FIELD OBSERVATIONS [ x ] Drainage Patterns in Wetlands
Depth of Surface Water - (in) Secondary Indicators (2 or more Required)
[ ] Oxidized Root Channels in Upper 12 inches
Depth of Free Water in Pit - (in) [ ] Water -stained Leaves
[ ] Local Soil Survey Data
Depth to Saturated Soil 6 (in) [ j FAC-Neutral Test
Other (Explain in Remarks

Page 3
Additional pictures on 7/21/09 show water again discharging from the newly relocated pipe. See
Powerpoint file Carolina Bark Modification.ppt. Bottom line: the request made in 2003 to stop
discharging wastewater has not been ftilfilled.
Stormwater from the Lumber Mill also travels to the CBark pond via Outfall 001 of the lumber
co permit.
Another more comprehensive round of sampling of Effluent and Downstream (across H«ry 186)
was made on 8/25/2009:
Location
Conduc
tivit
Temp C.
p1-I
D.O.,mg/l
BOD53 mg/l
E1111-lent
885
27.4
._3 G1 ":.'.
'3-05. T
630
Do-mistream
854
27.1
=. �3.65,
4r&VI= �
--
Reference stream
1 1 1
2i.
6.26
6.05
2
Location
Nutrients —
TKN, mg/I
NO2 +NO3, mg/l
Total P, mg/I
NH3, m /I
Effluent
.04
72
.03
12
Reference stream
.06
.86
.12
.11
Arsenic,
Cadmium,
Chromium,
Copper,
Iron,
Nickel,
Lead,
Zinc,
Location
u /I
ug/l
ua/I
ug/I
LIg/I
tt /l
ug/l
Lin/l
Effluent
9.8
1.9
47
w -9
1000-
23
10
Rel. stream
2.3
1.0
t0
2.3
2200
10
10
15
Surface Water Standards 15NCAC 213.0211
Dissolved Oxygen, DO
DajIv av a. 5.0, Instantaneous thin of 4 ma/I
H
6 to 9 standard units
Best- Usage Conditions
Suitable for aquatic life propagation and
maintenance
Arsenic
50 ug/l
Cadmium
2.0 ug/l
Total Chromium
50 ug/l
Copper
7 ug/l
Iron
1.0 mall = 1000 ug/l
Nickel
88 utr/l
Lead
25 ug/l
Zinc
50 ug/I

SOILS
Map Unit Name (Series and Phase):
I Drainage Class:
Taxonomy (Subgroup):
Field Observations Confirm Mapped Type? YES NO
Depth Horizon Matrix Color
inches Munsell Moist
PROFILE DESCRIPTION
Mottle Colors Mottle Texture, Concretions,
Munsell Moist Abundance/Contrast Structure, etc.
0 — 36 +
A
10YR 2/1
muck
HYDRIC SOIL INDICATORS:
[ x ] Histosol
[ ] Histic Epipedon
( ] Sulfidic Odor
[) Aquic Moisture Regime
[ ] Reducing Conditions
Gle ed or Low-Chroma Colors
[ ] Concretions
[ ] High Organic Content in Surface Layer in Sandy Soils
[ ] Organic Streaking in Sandy Soils
[ ] Listed on Local Hydric Soils List
[ ] Listed on National Hydric Soils List
I Other Ex lain in Remarks
Remarks:
Some sandy sediment on surface —6 inches
WETLAND DETERMINATION
Hydrophytic Vegetation Present? YES NO
Wetland Hydrology Present? YES NO Is this Sampling Point Within a Wetland? YES NO
Hydric Soil Present? YES NO
Remarks:

Status Review Meeting on Carolina Bark, Tuesday July 28, 9:30 AM, C.R. #2
Attendees: Danny Smith, Jay Zimmerman, Matt Fleahman, Ken Pickle, Myrl Nisely
14istoa of the -Permitting of this Bark Processing Facility: (View Current Layout Webshots)
NCG210360 was issued 4/25/03 and expired 4/30/08. It was later reissued as discussed below.
On October 27, 2003, samples were taken from puddles about 1/3 of the way from the North
fence line separating the lumber mill from Carolina Bark (CBark).
Location
Conductivity
Temp.
D.O.
pH
BOD
Upstream North
1760
20.2
0.51
5.3
3900
Upstream South
1971
22.4
0.44
3.6
39,000
Downstream Near Hw
641
22.3
0.70
3.2
1700
Units
mhos/cm
Degrees C
m l
Std scale
mg/1
Location
Nutrients — NH3
TKN
NO2 +NO3
Total P j
Upstream North
0.19
6.4
0.03
3.9
Upstream South
59
120 i
0.08
16
Downstream Near Hwy
3.8
14
0.64
5.4
Units
mg/1
mg/1
mg/l
mg/1
In a letter dated 12/3/2003, they were told that release of what amounted to wastewater was to
either stop or be treated to acceptable levels. They were to submit a plan by 1/31/04.
WQ0024420: An incomplete plan for recycle was submitted to Duane Leith 8/25/04. In letter
dated 11/1/04 he asked for more info by 12/1/04. They answered in a letter of 11/29/04 with all
but a water balance. They were working on that data.
Letter dated 5/20/05 states that the water balance never arrived, so the application is being
returned. If they submit the absent data it will require a new application and new fee.
WQ0028987: review of a new submittal again lacked many details. Letter of 8/25/05 requested
more info by 8/23/05. [side comment — many of the missing details said to have been answered
earlier were again requested in this letter. Did they not understanding that starting over was from
scratch? Do we ever hold on to an earlier submitted and use info from it?] CBark verbally asked
for extension to 11/2/05.
Letter of 12/12/05 returned this package because data was never submitted.
WQ0029752: CBark reapplied 1/12/06.
A staff report by Keith Larick resulted from a site visit 2/15/06. Mulch stored beyond map
designations, concerns about wells, hydrogeological study and many other details from APS
point of view.

Letter 6/12/06 from J. Zimmerman requested additional info again in 30 days. Outlined the
requirements for wells and buffer zones.
CBark engaged Mid -Atlantic Consultants, letter 7/7/06. Spoke of 3 possible approaches.
Letter received 7/11/06 asked for 120 day extension, wonders if is a way to remain covered by
NCG21. Letter of 8/7/06 from Larick denied that possibility, reset clock to 9/11/06
Letter 10/19/07 returned this package because information was never submitted.
Letter 11/14/07 from Danny Smith titled Stormwater Permit Renewal Disallowed. Permit
expired 4/30/08. Alternative must be found, or fines for discharging w/o permit would begin
4/3 0.
Email from Ken Pickle to Myrl Nisely et al summarized discussion with Mid -Atlantic
NCG210365 was inadvertently reissued to CBark as part of an batch renewal event by Bradley's
group. This one had not been flagged for denial. Still in effect today.
Summary of Issues
Soil maps show a blue line stream travels down the center of this site, exiting through a culvert
under Hwy 186 into a swamp. What are the ramifications?
A mulch facility field trip showed clearly that leachate comes from the piles into the stream. At
the time of this visit, CBark was creating a pond. No A to C, no input from us, apparently. Has
no liner. A discharge line was installed and releases occur under the reissued NCG21.
On an advertised visit on 6/9/09, it was found that CBark had raised the level of the discharge
pipe and allegedly has been pumping down the pond to create a non -discharge pond before our
arrival. Pictures unknown to them clearly show this modification. Samples taken that day:
Influent
MidPoint
Effluent
Analytical Results from Sat
Field Parameters
T, deg C pH
Conduct
DO
22.0 5.9
138
0.14
25.5 4.5
605
0.09
28.3 3.4
880
0.05
npling Carolina Bark on 6/9/2009
All in mg/I
Total P
NH3
NO2+NO3
1.2
0.03
0.02
7.3
0.31
0.03
11
0.32
0.08
TKN
Tot N
BOD5
2.5
2.52
56
7.2
7.23
260
6.9
6.98
280
Additional picture on 7/21/09 show water again discharging from the newly relocated pipe. *.ppt
Stormwater from Lumber Mill also travels to the CBark pond.
The request made in 2003 to stop discharging wastewater has not been fulfilled.

Status Review Meeting on Carolina Bark, Tuesday July 28, 9:30 AM, C.R. #2
Attendees: Danny Smith, Jay Zimmerman, Matt Fleahman, Ken Pickle, Myrl Nisely
Agenda
Permitting History & Efforts to Establish Another Kind of Permit
Summary of Issues
Mulch Tour Observations Blue Line Stream Digging New Pond
Recent Sampling Results
Obtaining Buffer Zone Waivers
How To Line An Existing Pond
Should We Call of a Meeting Here with Carolina Bark?
Discussion
Next Steps

� A -7 / a 3 - /1 4
- 2 _Allo 7 2A,0111 ` -&VS
2 MAI
Ul
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!�-,
-

Pickle, Ken
From: Nisely, Myrl
ent: Monday, August 24, 2009 1:08 PM
o: Pickle, Ken
Subject: RE: Carolina Bark
Judy Garrett and I made plans to go, and then were set back a couple of times. We finally will do so tomorrow morning.
Then it'll be a couple of weeks before results are back. We'll huddle with you as soon as the data is known. So for now,
you are free to put your attention on whatever seems most important to you!
M
From: Pickle, Ken
Sent: Monday, August 24, 2009 12:39 PM
To: Nisely, Myrl
Cc: Garrett, Judy; Smith, Danny; Georgoulias, Bethany; Bennett, Bradley; Zimmerman, Jay; Risgaard, Jon; Bennett,
Bradley
Subject: Carolina Bark
Myrl,
I've got a really busy September and October, and I'm wondering if the planned sampling trip and subsequent NOV letter
to Carolina Bark is still on your schedule.
I just want to confirm that I didn't miss something in the last four weeks since our meeting July 28. (I'm certainly not
expediting RRO - - I'm the world's worst at schedules, so I have no interest in beginning any discussion about schedules.)
eally, 1 just want to make sure that you're not waiting on me for something, and if not, I'm interested in when I might
need to contribute again on their issues.
For the moment, they have coverage under our NCG21 for good or bad.
Ken
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties.

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Pickle, Ken
From: Pickle, Ken
Sent: Monday, September 21, 2009 3:57 PM
To: Nisely, Myrl
Cc: Bennett, Bradley; Georgoulias, Bethany; Sullivan, Shelton
Subject: FW: Carolina Bark
Attachments: CBarkNOV909.docx
Myrl,
Thanks for the update. We'll be looking for the review draft.
Ken
Bethany, Bradley, Shelton:
FYI, No Action, yet.
Ken
From: Nisely, Myrl
Sent: Friday, September 18, 2009 2:34 PM
To: Pickle, Ken
Subject: RE: Carolina Bark
Ken, I was throwing away old emails when I came to this one. Attached is a rough DRAFT that I have sent to Danny. He
knows he wants to reword some of it, then we'll pass it to Jay Zimmerman and finally to you. I am sending it now to
provide the sampling results.
Have a great weekend, if you haven't already left the office!
Myrl
From: Pickle, Ken
Sent: Monday, August 24, 2009 12:39 PM
To: Nisely, Myri
Cc: Garrett, Judy; Smith, Danny; Georgoullas, Bethany; Bennett, Bradley; Zimmerman, Jay; Risgaard, Jon; Bennett,
Bradley
Subject: Carolina Bark
Myrl,
I've got a really busy September and October, and I'm wondering if the planned sampling trip and subsequent NOV letter
to Carolina Bark is still on your schedule.
I just want to confirm that I didn't miss something in the last four weeks since our meeting July 28. (I'm certainly not
expediting RRO - - I'm the world's worst at schedules, so I have no interest in beginning any discussion about schedules
Really, I just want to make sure that you're not waiting on me for something, and if not, I'm interested in when i might
need to contribute again on their issues.
For the moment, they have coverage under our NCG21 for good or bad.
Ken
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties.

i
28
flouted Event
Hydrograph Discharge Table
Time
Inflow
Elevation
Clv A
Clv B
Civ C PfAsr Wr A Wr B Wr C Wr D Exfil
Outflow
(hrs)
cfs
ft
cfs
cfs
cfs cfs cfs cfs cfs cfs cfs
cfs
27.40
0.000
549.66
6.541
0.098
----- ----- ----- ----- ----- ----- -----
0.098
27.42
0.000
549.66
6.541
0.098
----- ----- ----- ----- ----- ----- -----
0.098
27.43
0.000
549.66
6.541
0.097
- --- ----- ----- ----- ----- ----- -----
0.097
27.45
0.000
549.66
6.541
0.097
----- --- - ----- ----- ----- ----- -----
0.097
27.47
0.000
549.66
6.541
0.096
----- ----- ----- ----- ----- ----- -----
0.096
27.48
0.000
549.66
6.541
0.096
----- ----- ----- ----- ----- ----- -----
0.096
27.50
0.000
549.66
6.541
0.095
----- ----- ----- -- -- ----- ----- -----
0.095
27.52
0,000
549.66
6.541
0.095
----- ----- ----- ----- ----- ----- -----
0.095
27.53
0.000
549.65
6.541
0.094
----- ----- ----- ----- ----- ----- -----
0.094
27.55
0.000
549.65
6.541
0.094
----- ----- ----- ----- ----- ----- -----
0.094
27.57
0.000
549.65
6.541
0.093
----- ----- ----- ----- ----- ----- -----
0,094
27.58
0.000
549.65
6.541
0.093
----- ----- ----- ----- ----- ----- -----
0.093
27,60
0.000
549.65
6.541
0.093
----- ----- ----- ----- ----- ----- -----
0.093
27.62
0.000
549,65
6.541
0.092
----- ----- ----- -- -- ----- ----- -----
0.092
27.63
0.000
549.65
6.541
0.092
----- ----- ----- ----- ----- ----- -----
0.092
27.65
0.000
549.65
6.541
0.091
----- ----- ----- ----- -- - ----- -----
0.091
27.67
0.000
549.65
6.541
0.091
----- ----- ----- ----- ----- ----- -----
0.091
27.68
0.000
549.65
6.541
0.090
----- ----- ----- ----- ---- - --- -----
0.090
27.70
0.000
549.65
6.541
0.090
----- ----- ----- ----- ----- ----- -----
0.090
27.72
0.000
549.65
6.541
0,090
----- ----- ----- ----- ----- ----- -----
0.090
27.73
0.000
549.65
6.541
0.089
----- ----- ----- ----- ----- ----- -----
0.089
27.75
0.000
549.65
6.541
0.089
----- ----- ----- ----- ----- ----- -----
0.089
27.77
0.000
549.65
6.541
0.088
----- ----- ----- ----- --- ----- -----
0.088
27.78
0.000
549.65
6.541
0.088
----- ----- ----- ----- ----- ----- -----
0.088
27.80
0.000
549.65
6.541
0.088
----- ----- ----- ----- ----- ----- -----
0.088
27.82
0.000
549.65
6.541
0.087
----- ----- ----- ----- ----- ----- -----
0.087
27.83
0.000
549.65
6.541
0.087
----- ----- ----- ----- ----- ----- -----
0.087
27.85
0.000
549.65
6.541
0.087
----- ----- ----- ----- ----- ----- -----
0.087
27.87
0.000
549.65
6.541
0.086
----- ----- ----- ----- ----- ----- -----
0.086
27.88
0.000
549.65
6.541
0.086
----- ----- ----- ----- ----- ----- -----
0.086
27.90
0.000
549.65
6.541
0.086
----- ----- ----- ----- ----- ----- -----
0.086
27.92
0.000
549.65
6.541
0.086
----- ----- ----- ----- ----- ---- -----
0,086
27.93
0.000
549.65
6.541
0.085
----- ----- ----- ----- ----- --- -----
0.085
27.95
0.000
549,65
6.541
0.085
----- ----- ---- ----- - --- ----- -----
0.085
27.97
0.000
549.65
6.541
0.085
----- ----- ----- ----- ----- ----- -----
0.085
27.98
0.000
549.65
6.541
0.084
----- ----- ----- -- -- ---- ----- -----
0.084
28.00
0.000
549.65
6.541
0,084
----- ----- ----- ----- ----- ----- -----
0.084
28.02
0.000
549.65
6.541
0.084
----- ----- ----- ----- ----- ----- -----
0.084
28.03
0.000
549.65
6.541
0.083
----- ----- ----- ----- ----- ----- -----
0.083
28.05
0.000
549.64
6.541
0.083
----- ----- ----- -- -- ----- ----- -----
0.083
28.07
0.000
549.64
6.541
0.083
----- ----- ----- ----- ----- ----- -----
0.083
28,08
0.000
549.64
6.541
0.083
----- ----- ----- ----- ----- ----- -----
0.083
28.10
0.000
549.64
6.541
0.082
----- ----- ----- ----- ----- ----- -----
0.082
28.12
0.000
549.64
6.541
0.082
----- ----- ----- -- -- ----- ----- -----
0,082
28.13
0.000
549.64
6.541
0.082
----- ----- ----- ----- ----- ----- -----
0.082
28.15
0.000
549.64
6.541
0.081
----- ----- ----- ----- ----- ----- -----
0.081
28.17
0.000
549.64
6.541
0.081
----- ----- ----- ----- ----- ----- -----
0.081
28.18
0.000
549.64
6.541
0.081
----- ----- ----- -- -- ----- ----- -----
0.081
28.20
0,000
549,64
6.541
0.081
----- -- - ----- ----- ----- ----- -----
0.081
28.22
0.000
549.64
6.541
0.080
----- ----- ----- ----- ----- ----- -----
0.080
28.23
0.000
549.64
6.541
0.080
----- ----- ----- ----- ----- ----- -----
0.080
28,25
0.000
549.64
6.541
0.080
----- ----- ----- -- -- ----- ----- -----
0.080
28.27
0.000
549.64
6.541
0.079
----- ----- ----- ----- ----- ---- -----
0.079
28.28
0,000
549.64
6.541
0,079
----- ----- ----- ----- ----- ----- -----
0.079
Continues on next page...

, A A
NC®EN
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September `'?, 2009
CERTIFIED MAIL 7008 1140 0002 6738 5792
RETURN RECEIPT REQUESTED
Mr. Willis P. Taylor
Carolina Bark Products
P.O. Box 395
Seaboard, NC 27876
Subject: Notice of Violation
Case No. NOV-2009-PC-0744
Non -Compliant Discharge of Wastewater
Carolina Bark Products
NPDES Stonilwater Certificate of Coverage NCG210360
Seaboard, NC
Northampton County
Dear Mr. Taylor:
Background
A long communication history has developed since 2003 between Carolina Bark and tile Division
regarding the release of water from the processing of bark at your Seaboard location. Contamination of
a water of the state known as Jordan's Millpond has continued since DWQ first made it known that the
discharge was illegal and needed to be stopped. Carolina Bark held the above stormwater permit at that.
time. DWQ determined that a different permit was needed to address the fact that the discharge had
wastewater characteristics.
There have been a number of proposals made by your company to remedy this problem, followed by
either rejections of the ideas or requests for more information by DWQ. When the requested
information was not submitted, progress toward an appropriate permit unfortunately stopped. The
stormwater permit expired in the meantime. In 2008 a renewal of the stormwater permit was issued,
filrther extending the confusion and the discharging of what is known to be a wastewater. The
comingled stormwater/wastewater cannot be discharged under a stormwater permit.
Present Conditions
Because the release is wastewater created by the mixing of process water and stormwater, the discharge
has wastewater characteristics. This is a violation of 143.215.1(1 1) "Cause or permit discharges raider
GS143.214.7 that result in water pollution." On August 25, 2009 samples taken of the effluent
discharge pipe and measurements taken across the road in the stream entering the swamp showed values
that result in this Notice of Violation. Stream standard violations for dissolved oxygen (DO) and pI-i
were recorded downstream of the discharge.
One
NotthCarolina
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: www,newaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]a-6748
An Equal Opportunity/Affirmative Action Employer— 50% Recyoledl10% Post Consumer Paper

30 w
Routed Event
Hydrograph Discharge Table
Time
Inflow
Elevation
Clv A
Clv B
Clv C PfRsr Wr A Wr B Wr C Wr D
Exfil Outflow
(hrs)
cfs
ft
cfs
cfs
cfs cfs cfs cfs cis cfs
cfs cfs
29.20
0.000
549.63
6.541
0.065
----- ----- ----- ----- ----- - ---
----- 0,065
29.22
0.000
549.63
6.541
0.065
-- -- ----- ----- ----- ----- -----
----- 0.065
29.23
0.000
549.63
6.541
0,065
----- ----- ----- ----- ----- -----
----- 0.065
29.25
0.000
549.63
6.541
0.065
----- ----- ----- ----- ----- -----
----- 0.065
29.27
0.000
549.63
6.541
0.064
----- ----- ----- ----- ----- -----
----- 0.064
29.28
0.000
549,63
6.541
0.064
----- ----- ----- ---- ----- -----
----- 0.064
29.30
0.000
549.62
6.541
0.064
----- ----- ----- ----- ----- -----
----- 0.064
29.32
0.000
549.62
6.541
0.064
----- ----- ----- ----- ----- -----
----- 0.064
29.33
0.000
549.62
6,541
0.064
-- -- ----- ----- ----- ----- -----
----- 0.064
29.35
0.000
549.62
6.541
0.063
----- - -- ----- ----- ----- -----
----- 0.063
29.37
0.000
549.62
6.541
0.063
----- ----- ----- ----- ----- -----
----- 0.063
29.38
0.000
549.62
6.541
0.063
- -- ----- ----- ----- ----- -----
----- 0.063
29.40
0.000
549.62
6.541
0.063
-- -- ----- ----- ---=- ----- ---
----- 0,063
29.42
0.000
549.62
6.541
0.062
----- ----- ----- -- -- ----- -----
----- 0.062
29.43
0.000
549.62
6.541
0.062
---- ----- ----- ----- ----- -----
----- 0.062
29.45
0.000
549.62
6.541
0.062
-- -- ----- ----- ----- ----- -----
----- 0.062
29.47
0.000
549.62
6.541
0.062
----- ----- ----- ---- ----- -----
----- 0.062
29.48
0.000
549.62
6.541
0.062
---- ----- ----- ----- ----- -----
----- 0.062
29.50
0.000
549.62
6.541
0.061
----- ----- ----- ----- ----- -----
----- 0.061
29.52
0.000
549.62
6.541
0.061
----- ----- ----- ----- ----- -----
----- 0.061
29.53
0.000
549.62
6.541
0.061
----- ----- ----- ----- ----- -----
----- 0.061
29.55
0.000
549.62
6.541
0.061
----- ----- ----- ----- ----- -----
- --- 0.061
29.57
0.000
549.62
6.541
0.061
----- ---- ----- ----- ----- -----
----- 0.061
29.58
0.000
549.62
6.541
0.060
----- ----- ---- ---- ----- - ---
----- 0.060
29.60
0.000
549.62
6.541
0,060
----- ----- ----- ----- ----- -----
----- 0.060
29.62
0.000
549.62
6.541
0.060
----- ----- ----- ----- ----- -----
----- 0.060
29.63
0.000
549.62
6.541
0.060
----- ----- ----- ---- ----- -----
----- 0.060
29.65
0,000
549.62
6.541
0.060
----- ----- ----- ----- ----- ----
----- 0.059
29.67
0.000
549.62
6.541
0.059
----- ----- ----- ----- ----- -----
----- 0.059
29.68
0.000
549.62
6.541
0.059
----- ----- ----- ----- ---- -----
----- 0.059
29.70
0.000
549.62
6.541
0.059
----- ----- ----- ---- ---- -----
----- 0.059
29.72
0.000
549.62
6.541
0.059
----- ----- ----- -- -- ----- -----
----- 0.059
29.73
0.000
549.62
6.541
0.058
---- --- ----- ----- ----- -----
----- 0.058
29.75
0.000
549.62
6.541
0.058
----- ----- ----- ----- ----- - ---
----- 0.058
29.77
0.000
549.62
6.541
0.058
----- ----- ----- ----- ----- ----
----- 0.058
29.78
0.000
549.62
6.541
0,058
----- ----- ----- ----- ----- -----
- --- 0.058
29.80
0.000
549.62
6.541
0.058
----- ----- - --- ----- ----- -----
----- 0.058
29.B2
0.000
549.62
6.541
0.057
----- ----- ----- ----- ----- -----
----- 0.057
29.83
0.000
549.62
6.541
0.057
----- - -- ----- ----- ----- -----
----- 0.057
29.85
0.000
549.62
6.541
0,057
----- ----- ----- ----- ----- -----
----- 0.057
29.87
0.000
549.62
6.541
0.057
----- ----- ----- ----- ----- -----
----- 0.057
29.88
0.000
549.62
6.541
0.057
----- ----- ----- ----- ----- ----
----- 0.057
29.90
0.000
549.62
6.541
0.056
----- -- -- ----- ----- ----- -----
----- 0.056
29.92
0.000
549.62
6.541
0,056
----- ----- ----- ----- ----- -----
----- 0.056
29.93
0.000
549.62
6.541
0.056
----- ----- ----- ----- ----- -----
----- 0,056
29.95
0.000
549.62
6.541
0.056
----- ----- ----- ----- ----- -----
----- 0.056
29.97
0.000
549.62
6.541
0.056
----- ----- ----- ----- ----- -----
----- 0.056
29.98
0.000
549.62
6.541
0.055
----- ----- ----- ----- ----- -----
----- 0.055
30.00
0.000
549.62
6.541
0.055
----- ----- ----- ----- ----- -----
----- 0.055
30.02
0.000
549.62
6.541
0.055
----- ----- ----- ----- ----- -----
----- 0.055
30.03
0,000
549.62
6.541
0.055
----- ----- ----- ----- ----- -----
----- 0.055
30.05
0.000
549.62
6,541
0.055
----- ----- ----- ----- ----- -----
----- 0.055
30.07
0.000
549.62
6.541
0.055
----- ----- ----- ----- ----- -----
----- 0.055
30.08
0.000
549.61
6.541
0.054
----- ----- ----- ----- ----- -----
----- 0.054
Continues on next page...

Carolina Bark NOV-2009-PC-Oxxx, September 2009 Page 2 of 3
Location
Conduc
tivit
Temp C
pH
D.O.,mg/l
BODS, nig/1
Effluent
885
27.4
3 61
- 3 OS
6 30
Downstream
854
27.1
F3-5 M:--
Reference stream
1 1 1
23.3
6.26
6.05
2
Nutrients —
TKN,
NO2 +NO3,
Total P,
Location
NH3, m 7/l
m<=/1
m+=/I
m .T/1
Effluent
.04
7.2
.03
12
Reference stream
.06
.86
.12
.11
Location
Arsenic,
Cadmium,
Chromium,
Copper,
iron,
Nickel,
Lead,
Zinc,
ug/1
ug/I
ua/I
uu/1
a /I
Ug/I
ug/I
Ug/I
Effluent
9.8
1.9
47
=9 7 =
W 000=
23
10
=500='=`
Ref. stream
2.3
1.0
10
2.3
2200
10
10
15
Action Steps
Carolina Bark must obtain a total recycle permit since treatment of this wastewater cannot be
economically achieved. Accordingly, on or before September 30, 2009 Carolina Bark is to respond to
this NOV with a new application for a recycle permit. Your operation will be allowed to continue as
long as progress toward the new penrlit continues in a timely manner. In the communications between
DWQ and Carolina Bark, if timelines established by DWQ are not met, you will be considered in
violation and enforcement or an injunction to cease operation will be pursued.
If you have questions about this Notice, please contact me at 919-791-4200.
Sincerely,
Danny Smith
Surface Water Protection Supervisor
Raleigh Regional Office
cc: RRO / SWP File
Central Office Files
Non -Point Source and Compliance Office
Jay Zimmerman, Aquifer Protection Section
Surface Water Standards 15NCAC 2B.0211
Dissolved Oxygen, DO
Daily avg. 5.0, lnstantancous min of 4 mtr/1
H
6 to 9 standard. units
Best Usage Conditions
Suitable for aquatic life propagation and maintenance
Arsenic
50 uQ/1
Cadmium
2.0 ug/l
Total Chromium
50 ua/l
Copper
7 ug/l
Iron
1.0 m /l (= 1000 u /l
Nickel
88 ue/1
Lead
25 uu/I
Zinc
50 ug/I

i
d
31
Routed Event
Hydrograph Discharge Table
Time
Inflow
Elevation
Clv A
Clv B
Clv C PfRsr Wr A Wr B Wr C Wr" D
Exfil Outflow
(hrs)
cfs
ft
cfs
cfs
cfs cfs cfs cfs cfs cfs
cfs cfs
30.10
0.000
549.61
6.541
0.054
----- ----- ----- ----- ----- -----
----- 0.054
30.12
0.000
549.61
6.541
0.054
----- ----- ----- -- - ---- -----
----- 0.054
30.13
0.000
549.61
6.541
0.054
----- ----- ----- ----- ----- -----
----- 0.054
30.15
0.000
549.61
6.541
0.054
----- ----- ----- ----- ----- -----
----- 0.054
30.17
0.000
549.61
6.541
0.053
----- ----- ----- ----- ----- -----
----- 0.053
30.18
0.000
549.61
6.541
0.053
----- ----- ----- ----- ----- -----
----- 0.053
30.20
0.000
549.61
6.541
0.053
---- ----- ----- ----- ----- -----
----- 0.053
30.22
0.000
549.61
6.541
0.053
----- ----- ----- ----- ----- -----
----- 0.053
30.23
0.000
549.61
6.541
0.053
----- ----- ----- -- -- ---- ----
----- 0.053
30.25
0.000
549.61
6.541
0.052
----- ----- ----- ----- ----- -----
----- 0.052
30.27
0.000
549.61
6.541
0.052
----- ----- ----- ----- ----- -----
----- 0.052
30.28
0.000
549.61
6.541
0.052
----- ----- ----- ----- ---- -----
----- 0.052
30.30
0.000
549.61
6.541
0.052
---- ----- ----- -- -- ----- -----
----- 0.052
30.32
0.000
549.61
6.541
0.052
---- ----- ----- ----- ----- -----
----- 0.052
30.33
0.000
549.61
6.541
0.052
----- ----- ----- ----- ----- -----
----- 0.052
30.35
0.000
549.61
6.541
0.051
----- ----- ----- ----- ----- -----
----- 0.051
30.37
0.000
549.61
6.541
0.051
---- ----- ---- ----- ----- -----
----- 0.051
30.38
0.000
549.61
6.541
0.051
----- ----- ----- ---- ----- -----
----- 0.051
30.40
0.000
549.61
6.541
0.051
----- ----- ----- ----- ----- -----
----- 0.051
30.42
0.000
549.61
6.541
0.051
---- ---- ---- ----- ----- -----
----- 0.051
30.43
0.000
549.61
6.541
0.050
----- ----- ----- ----- ----- -----
----- 0.050
30.45
0.000
549.61
6.541
0.050
----- ----- ----- ----- ---- ----
----- 0.050
30.47
0.000
549.61
6.541
0.050
----- ----- ---- ----- ----- -----
----- 0.050
30.48
0.000
549.61
6.541
0.050
----- ----- ----- ----- ----- -----
----- 0.050
30.50
0.000
549.61
6.541
0.050
----- ----- ----- ----- ----- -----
----- 0.050
30.52
0.000
549.61
6.541
0.050
----- ----- ----- -- -- - --- ----
----- 0.050
30.53
0.000
549.61
6.541
0.049
---- ----- ---- ----- ----- -----
----- 0.049
30.55
0.000
549.61
6.541
0.049
----- ----- ----- ----- ----- -----
----- 0.049
30.57
0.000
549.61
6.541
0.049
----- ----- ----- ----- ----- ----
----- 0.049
30.58
0.000
549.61
6.541
0.049
----- ----- ---- ----- ---- -- --
----- 0.049
30.60
0.000
549.61
6.541
0.049
----- ----- ----- ----- ----- -----
----- 0.049
30.62
0.000
549.61
6.541
0.049
----- ----- ----- ----- ----- -----
----- 0.049
30.63
0.000
549.61
6.541
0.048
- --- ----- ---- ----- ----- -----
----- 0.048
30.65
0.000
549.61
6.541
0.048
----- ----- ----- ----- ----- -----
----- 0.048
30.67
0.000
549.61
6.541
0.048
----- ----- ----- -- - ----- -----
----- 0.048
30.68
0.000
549.61
6.541
0.048
----- ----- ----- ----- - -- -----
----- 0.048
30.70
0.000
549.61
6.541
0.048
----- ----- ----- ----- ----- -----
----- 0.048
30.72
0.000
549.61
6.541
0.048
----- ----- ----- ----- ----- -----
----- 0.048
30.73
0.000
549.61
6.541
0.047
----- ----- ----- ----- - -- -----
----- 0.047
30.75
0.000
549.61
6.541
0.047
----- ----- ----- ----- ----- -----
----- 0.047
30.77
0.000
549.61
6.541
0.047
----- ----- ----- ----- ----- -----
----- 0.047
30.78
0.000
549.61
6.541
0.047
----- ----- ----- --- - ----- -----
----- 0.047
30.80
0.000
549.61
6.541
0.047
----- ----- ----- ----- ----- -----
----- 0.047
30.82
0.000
549.61
6.541
0.047
----- ----- ----- ----- ----- ----
----- 0.047
30.83
0.000
549.61
6.541
0.046
----- ---- ----- ----- ----- -----
----- 0.046
30.85
0.000
549.61
6.541
0.046
----- ----- ----- ----- ----- -----
----- 0.046
30.87
0.000
549.61
6.541
0.046
----- ----- ----- ----- ----- -----
----- 0.046
30.88
0.000
549.61
6.541
0.046
- --- ---- ----- ----- ----- -----
---- 0.046
30.90
0.000
549.61
6.541
0.046
----- ----- ----- ----- ----- -----
----- 0.046
30.92
0.000
549.61
6.541
0.046
----- - --- ----- ----- ----- -----
----- 0.046
30.93
0.000
549.61
6.541
0.046
----- ----- ----- ----- ----- -----
---- 0.045
30.95
0.000
549.61
6.541
0.045
---- ----- ----- --- - ----- -----
----- 0.045
30.97
0.000
549.61
6.541
0.045
----- - --- ----- ----- ----- ----
----- 0.045
30.98
0.000
549.61
6.541
0.045
----- ----- ----- ----- ----- -----
----- 0.045
Continues on next page...

Carolina Bark NOV-2009-PC-Oxxx, September 2009

32 A'
Routed Event
Hydrograph Discharge Table
Time
Inflow
Elevation
Clv A
Clv B
Clv C PfRsr Wr A Wr B Wr C Wr D Exfil
Outflow
(hrs)
CIS
It
cfs
cfs
cfs cfs cfs cfs CIS cfs CIS
CIS
31.00
0.000
549.61
6.541
0.045
----- ----- ----- ---- ----- ----- -----
0.045
31.02
0.000
549.60
6.541
0.045
----- ----- ---- ----- ----- ----- -----
0.045
31.03
0.000
549.60
6.541
0.045
----- ----- ----- ----- ----- ----- -----
0.045
31.05
0.000
549.60
6.541
0.044
----- ----- ----- ---- ----- ----- -----
0.044
31.07
0.000
549.60
6.541
0.044
----- --- - ----- ----- ----- ---- ----
0.044
31.08
0.000
549.60
6.541
0.044
----- ----- ----- ----- ----- ----- -----
0.044
31.10
0.000
549.60
6.541
0.044
----- ----- ----- ----- ----- ----- ----
0.044
31.12
0.000
549.60
6.541
0.044
----- ----- ----- ---- ----- ----- -----
0.044
31.13
0.000
549.60
6.541
0.044
----- ----- ----- ----- ----- ----- -----
0.044
31.15
0.000
549.60
6.541
0.043
----- ----- ----- ----- ----= ----- -----
0.043
31.17
0.000
549.60
6.541
0.043
----- ----- ----- ----- ----- ----- -----
0.043
31. i 8
0.000
549.60
6.541
0.043
----- ----- ----- ----- ----- ----- -----
0.043
31.20
0.000
549.60
6.541
0.043
----- ----- ----- ----- ----- ----- -----
0.043
31.22
0.000
549.60
6.541
0.043
----- ----- ----- ----- ----- ----- ---
0.043
31.23
0.000
549.60
6.541
0.043
----- ----- ----- ----- ----- ----- ----
0.043
31.25
0.000
549.60
6.541
0.043
----- ----- ----- ---- ----- ----- -----
0.043
31.27
0.000
549.60
6.541
0.042
----- ----- ----- ----- ----- ----- -----
0.042
31.28
0.000
549.60
6.541
0.042
----- ----- ---- ----- ----- ----- -----
0.042
31.30
0.000
549.60
6.541
0.042
----- ----- ----- ----- ----- ----- -----
0.042
31.32
0.000
549.60
6.541
0.042
----- ----- ----- --- ----- ----- -----
0.042
31.33
0.000
549.60
6.541
0.042
----- ----- ----- ----- ----- ----- -----
0.042
31.35
0.000
549.60
6.541
0.042
----- ----- ----- ----- ---- ----- -----
0.042
31.37
0.000
549.60
6.541
0.042
----- ----- ----- ----- ----- ---- ----
0.042
31.38
0.000
549.60
6.541
0.041
----- ----- ----- ----- ----- ----- ----
0.041
31.40
0.000
549.60
6.541
0.041
----- ----- ---- ----- ----- ----- -----
0.041
31.42
0.000
549.60
6.541
0.041
----- ----- ---- ----- ---- ----- -----
0.041
31.43
0.000
549.60
6.541
0.041
----- ----- ----- ----- ----- ----- -----
0.041
31.45
0.000
549.60
6.541
0.041
----- ----- ----- ----- ----- ----- -----
0.041
31.47
0.000
549.60
6.541
0.041
----- ----- ----- ----- ----- ----- -----
0.041
31.48
0.000
549.60
6.541
0.041
----- ----- ----- ----- ---- ----- -----
0.041
31.50
0.000
549.60
6.541
0.040
---- ----- ----- ----- ----- ----- -----
0.040
31.52
0.000
549.60
6.541
0.040
----- ----- ----- --- ----- ----- -----
0.040
31.53
0.000
549.60
6.541
0.040
----- ----- ----- ----- - --- ----- -----
0.040
31.55
0.000
549.60
6.541
0.040
----- ----- ----- ----- ----- ----- -----
0,040
31.57
0.000
549.60
6.541
0.040
----- ----- ----- --- ----- ----- -----
0.040
31.58
0.000
549.60
6.541
0.040
----- ----- ----- ----- ----- ----- -----
0.040
31.60
0.000
549.60
6.541
0.040
----- ----- ----- ----- ----- ----- -----
0.040
31.62
0.000
549.60
6.541
0.040
----- ----- ----- ----- ----- ----- -----
0.040
31.63
0.000
549.60
6.541
0.040
----- ----- ----- ----- ----- ----- -----
0.040
31.65
0.000
549.60
6.541
0.039
---- ----- ----- - --- ----- ----- -----
0.039
31.67
0.000
549.60
6.541
0.039
----- ----- ----- ----- - --- ----- -----
0.039
31.68
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- -----
0.039
31.70
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- -----
0.039
31.72
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- -----
0.039
31.73
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- -----
0.039
31.75
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- -----
0.039
31.77
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- -----
0.039
31.78
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- ----
0.039
31.80
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- -----
0.039
31.82
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- -----
0.039
31.83
0.000
549.60
6.541
0.039
----- ----- ----- ----- ----- ----- -----
0.039
31.85
0.000
549.60
6.541
0.038
---- ----- ----- ----- ----- ----- -----
0.038
31.87
0.000
549.60
6.541
0.038
----- ----- ----- ----- ----- ----- -----
0.038
31.88
0.000
549.60
6.541
0.038
----- ----- ----- ----- ----- ----- -----
0.038
{M
,'I
Continues on next page...

Pickle, Ken
From:
Pickle, Ken
Sent:
Thursday, October 08, 2009 9:41 AM
To:
Nisely, Myrl
Cc:
Bennett, Bradley; Smith, Danny; Georgoulias, Bethany; Zimmerman, Jay; Matthews, Matt
Subject:
Carolina Bark
Myrl,
Just a couple of comments on the elements in your DRAFT letter to Carolina Bark. ( I know in September you indicated
that you and Danny would be re -wording it before running it past Jay Z. and me.)
1. The letter asserts that the discharges leaving the site are wastewaters. I'm on board with that. Both as to
character of the flow, and as to origin of the flow. This approach is consistent with the perspective that DWQ-
SPU and APS are trying to get established in the timber and composting industries. (It's already established in our
minds.)
Further, the letter cites stream standard violations established by your August 25, 2009 sampling event. That
means we have evidence that the site is having a real, negative impact on the receiving water. in my mind this
further solidifies the NOV call far action by Carolina Bbrk. My suggestion at this point would be that your
strategy could be to consider this wqs violation as a strong call for DWQ-RRO action. Programmatically for SPU,
however, 1 wouldn't want to let this confuse or overshadow the ww vs sw call based on flow origin and
supported by discharge characteristics. I mean, I wouldn't want wqs violations to somehow become the new
standard for establishing the ww vs sw call. The DRAFT letter is ok on this point, 1 just wouldn't want to get
carried away in the re -write and confuse our basis for the ww vs sw call. In my eyes, the wqs violation is a
corroborating factor for the issuance of the NOV and required Carolina Bark response; but the wqs violation by
itself is not a sufficient basis for the ww vs sw determination.
[Contrary perspectives? I can see that there might be. But, the contrary approach that I imagine would create a
workload burden on the ROs to implement. 1 mean, if wqs violation is the new standard for ww vs sw, then l
think the ROs will be swamped with sampling to establish who will be allowed to have a sw permit, vs. who will
have to get a wastewater permit. The industries, of course, would love it. It would make sense to them that if
there is evidence that they are harming the creek, they need to stop it. But, the minor pollutant contributions
from a small site wastewater discharge would seem to them to be inconsequential, and suitable for a sw permit.
What's lost in this perspective is that potentially degrading pollutant levels can be difficult/impossible to fudge
visually. So, the fact that a site doesn't see the pollution, or its effect, hides the significance. This is a tough issue
we face with facilities that have ww and sw discharges that may resemble each other, like in composting, timber,
mining, marinas, etc. to one degree or another. They don't see the problem that we see.]
3. The fetter directs CB to obtain a recycle permit, and threatens that RRO will enforce and will seek an
injunction to stop operations at the facility unless CB shows continuing progress toward obtaining such a
permit. You know this part of our procedures better than I do. It catches my eye that the DRAFT specifically
directs them as to which regulatory solution to seek (recycle permit) based on our presumed knowledge of their
financial ability (ie, we say treatment can't be economically achieved). It might be helpful to qualify our
statement with something like, "As you have reported to us verbally that CB considers it economically infeasible
to treat the wastewater, we direct you to obtain a pump and haul, or a recycle permit. We are receptive to
other regulatory responses to the illegal discharge of wastewater, although what those options may be is not
apparent to us now ...... OR something like that.

Page 4
7. The affected land shall be graded so as to prevent collection of pools of water that are,
or likely to become, noxious or foul. Necessary structures such as drainage ditches or
conduits shall be constructed or installed when required to prevent such conditions.
8. Existing vegetation or vegetated earthen berms shall be maintained between the mine
and public thoroughfares whenever practical to screen the operation from the public.
9. Sufficient buffer (minimum 50 foot -undisturbed) shall be maintained between any
excavation and any mining permit boundary to protect adjacent property.
10. A. No on -site disposal of refuse or other solid waste that is generated outside of the
mining permit area shall be allowed within the boundaries of the mining permit
area unless authorization to conduct said disposal has first been obtained from
both the Division of Waste Management and the Land Quality Section,
Department of Environment and Natural Resources. The method of disposal
shall be consistent with the.approved reclamation plan.
B. Mining refuse as defined by G.S. 74-49 (14) of The Mining Act of 1971
generated on -site and directly associated with the mining activity may be
disposed of in a designated refuse area. All other waste products must be
disposed of in a disposal facility approved by the Division of Waste
Management. No petroleum products, acids, solvents or their storage containers
or any other material that may be considered hazardous shall be disposed of
within the permitted area.
C. For the purposes of this permit, the Division of Land Resources considers the
following materials to be "mining refuse" (in addition to those specifically listed
under G.S. 74-49 (14) of the N.C. Mining -Act of.1971.):
1.
2.
3.
4.
5.
6.
on -site generated
conveyor belts
wire cables
land clearing debris
v-belts
steel reinforced air hoses
drill steel
D. If mining refuse is to be permanently disposed within the mining permit
boundary, the following information must be provided to and approved by the
Division of Land Resources prior to commencement of such disposal:
1. the approximate boundaries and size of the refuse disposal area-,
2. a list of refuse items to be disposed-,
3. verification that a minimum of 4 feet of cover will be provided over the
refuse;
4. verification that the refuse will be disposed at least 4 feet above the
seasonally high water table; and,

4. 1 wonder if JZ needs to sign this letter, too. Just a question to consider. I mean, I understand that DS will sign
because there is a surface water issue here. But, the regulatory fix is an APS fix, rather than a Surface Water
Protection fix. I guess DS and JZ will work that out as they think best.
Ken
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be
disclosed to third parties.

Page 5
5. verification that a permanent vegetative groundcover will be established.
11. An Annual Reclamation Report shall be submitted on a form supplied by the
Department by February 1 of each year until reclamation is completed and approved.
12. The operator shall notify the Department in writing of the desire to delete, modify or
otherwise change any part of the mining, reclamation, or erosion/sediment control plan
contained in the approved application for a mining permit or any approved revision to it.
Approval to'implement such changes must be obtained from the Department prior to
on -site implementation of the revisions.
13. The security, which was posted pursuant to N.C.G.S. 74-54 in the form of a $17,400.00
Irrevocable Standby Letter of Credit, is sufficient to cover the operation as indicated in
the approved application. This security must remain in force for this permit to be valid.
The total affected land shall not exceed the bonded acreage.
14. A. Authorized representatives, -of the Division of Archives and History shall be
granted access to the site to determine the presence of significant
archaeological resources.
B. Pursuant to N. C. G. S. 70 Article 3, "The Unmarked Human Burial and Human
Skeletal Remains Protection Act," should the operator or any person in his
employ encounter human skeletal remains, immediate notification shall be
provided to the county medical examiner and the chief archaeologist, North
Carolina Division of Archives and History.

Analytical Results from Sampling Carolina Bark on 6/9/2009
Field Parameters *
All in mg/1
T, deg C pH
DO Total P
NH3 NO2+NO3 TKN
Tot N
Influent 25.6 6.2
0.51 1.2
0.03 0.02 2.5
2.52
Mid Point 26.7 5.1
0.19 7.3
0.31 0.03 7.2
7.23
Effluent 29.4 4.3
0.05 11
0.32 0.08 6.9
6.98
4-? 5w
* Field notes were lost. Values from
�o�ncht 2
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30
4D
memory. Trends were clearly seen.
BOD5
56
260
280
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2. Who makes that determination
3. Who issues it?
4. Are their any exceptions to that?
5. Who decides if someone falls under an exception? C. What are the state water quality standards?
1. What do they protect against?
2. what would constitute a violation of those standards
3. Who determines if there is a violation?
III. This case:
A. Are you familiar with the site owned by Defendant?
B. How did you become familiar?
1. What did Chatham County notify you of
a. How/why did they notify you
b. Do you maintain that documentati as part of your official file?
C. Do you routinely receive such do umentation in the course of day-
to-day business
2. What did Corps notify you of
J. a. How/why did they notify y
b. Do you maintain that doe entation as part of your official file?
C. Do you routinely receiv such documentation in the course of day-
to-day business
4. Did you go to the site your IP Do you routinely make such inspections?
Is that part of your job?
5. Who was present whe , ou went to the site?
b. What activities took place during this visit?
C. Describe what you saw at that site?
D. Are those activities that would normally require a 401?
1. Why?
2. How do you,know?
3. Did they have one?
4. How do you know?
E. Are those activities that would normally require a state stormwater permit?
I. Why?
2. How'do you know?
3. Did they have one?
4. How do you know?
F. Did those activities comply with state water quality standards?
1. Why?
2. How do you know?
3. Were they allowed to violate state water quality standards?
G: Did you follow up?
1. What kind of notifications were they sent?
2. Does your office routinely sent those kinds of notifications?
3. What is the purpose of it?
4. What does it say?
H. Did you receive any kind of response/achieve a result?

Michael F. Easley, Governor
�F ATFR William G. Ross Jr., Secretary
O� QG North Carolina Department of Environment and Natural Resources
7 Coleen H. Sullins, Director
Division of Water Quality
Q �
November 14, 2007
CERTIFIED MAIL 7006 0810 0002 6049 5402 p ".
RETURN RECEIPT RE VESTED
Mr. Willis P. Taylor
NOV 1 6 2007
Carolina Bark Products fl>=µR _ WASE ous" B�anoh
P.O. Box 395
Seaboard, NC 27876
Subject: Stormwater Permit Renewal Disallowed
Carolina Bark Products
NPDES Stormwater Permit NCG210360
Seaboard, NC
Northampton County
Dear Mr. Taylor:
On October 27, 2003 Ms. Judy Garrett and Mr. Myrl Nisely of the Raleigh Regional Office of
Division of Water Quality, conducted an inspection and determined that discharges of
unauthorized process wastewaters from Carolina Bark into Cypress Swamp was occurring. An
effort was made to establish and permit a non -discharge recycle system, but this encountered
technical barriers, and was not accomplished. There has been no satisfactory resolution of this
issue since that time.
Stormwater permit NCG21060 expires on April 30, 2008, An alternative method for handling
wastewater generated at the facility must be identified and designed before the stormwater
permit expires on April 30, 2008. Discharges after that date taking place without a permit will
subject Carolina Bark to civil penalty assessments of up to $25,000 per day.
Accordingly, an application for a wastewater permit is to be submitted to either the Discharge
Section or the Non -discharge permitting Section by December 31, 2007, depending upon
technology selected. If an Authorization to Construct (AtC) request is needed (for a
discharging system), it is to be submitted to the Construction, Grants and Loans Section for
approval by the end of January 2008.
If you have comments or questions, please call Keith Larick/Myrlisely of the Raleigh
Regional Office at 919-791-4200.
cere,ly,
Danny ith
Raleigh Regional Supervisor
Surface Water Protection Section
xc: Bradley Bennett, Stormwater Permitting
Keith Larick, RRO Aquifer Protection Section
Central Files ►V'Ir
Raleigh Regional Office 1628 Mail Service Center phone [phone] Customer Service
Water Quality Section Raleigh, NC 27699-1628 facsimile [phone] 1-877-623-6748

JEFF ROBINSON
& ASSOCIATES, LLPC
Date: January 28, 2008
Name: Mr.. Ken Pickle'
Company: NC Division of Water Quality
J RA #:
04-005
Subject:
Carolina Bark
Sent Via:
Overnight UPS
From:
Jeff B. Robinson, P.E. 1 W.P. Taylor
CC:
(2) copies, Dan Smith
.!A N 2 9
DENR _ W, 7'6,0040
P +�
etla�& : , ' 6 , Q040
■ Description:
(2) copies Site Plan, sheets 1 - 2 of 2, revised dated January 24, 2008.
■ Remarks:
Please find the enclosed drawings and calcs. for the stormwater retention pond for
Carolina Bark Products, Seaboard,N.C. for your review. I believe this is the final piece of
information we need to begin construction. We would like to begin construction
immediately in order to meet the April 1, 2008 deadline. Your comments are greatly
appreciated. Perk Taylor
W.P. Taylor
P.O. Box 635
Franklin, VA 23851
757-328-2215
CONSULTING ENGINEER
Post Office Box fib, Emporia, Va 23847 Fax: [phone], Ph: 434-634-8665

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Carolina Bark Products
4400 NC Highway 186
Seaboard, North Carolina 27876
Partial Site Plan

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JEFF ROBINSON 434-634-0254
& ASSOCIATES, LLPC
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Carolina Bark Products
4400 NC Highway 186 �
Seaboard, North Carolina 27876
Partial Site Plan

ABSORPTION CAPACITY OF WINDROWS
CAROLINA BARK FACILITY
MID -ATLANTIC JOB NUMBER: R1756.00
Volume of Windrow
Height
Width at Base
Length at Base
Sidewalls- Rise
Run
15 feet
60 feet
600 feet
1 feet
Ofeet
Prepared By: DMM
Checked By:
Volume 405,000 cubic feet
Available Storage Capacity of Windrow
Percent of windrow volume able to
absorb water (based on lab data)
Available water storage capacity:
Percent available capacity filed
with irrigation water:
Available water storage capacity:
47.2
191,160 cubic feet (assumes no process water)
95,580 cubic feet
Calculate Volume of 25 year Storm That Falls on Windrow Footprint
Rainfall of 25-year storm 6.62 inches
0.5517 feet
19,860 cubic feet
Number of storm events windrow can hold prior to saturation: 4.81 ���

.r.1A T 4 r ' Wchael F. Easiey, Governor
J �!� 5' William G. Ross Jr., Secretary
O� pG North Carolina Department of Environment and Natural Resources
Ci7 7 coleen H. Sullins, Director
Division of Water Quality -
November 14, 2007
2
CERTIFIED MAIL 7006 0810 0002 6049 5402
RET>\t_tiRRECEIPT REQUESTED ?y I
Mr. Willis P. Ta-vlor d '5�u�
Carolina Bark Products f
P.O. Box 395 4,f li1an75
Seaboard, NC 27876
Subject-. Stormwater Permit Renewal Disallowed
Carolina Bart: Products
NPDES StormNN,ater Permit NCG210360
Seaboard. NC
Northampton Count
Dcar lvlr. Taylor. -
On October 27, 2003 Ms, Judy Garrett and Mr. Mvrl Nisely of the Raleigh Regional Office of
Division of Water Quality_ conducted an inspection and determined.that discharges of
unauthorized process wastewaters from Carolina Bark into Cypress Swamp was occurring. An
effort'vas made to establish and permit a non -discharge recycle system, but this encountered
technical barriers, and was not accomplished. There has been no satisfactory resolution of this
issue since that time.
Stormwater permit NCG2.1060 expires on April 30, 2008, An alternative method for handling
wastewater generated at the facility must be identified and designed before the stormwater
permit expires on April 30. 2008. Discharges after that date taking place: without a permit will
subject Carolina Bark to civil penalty assessments of up to $23,000 per day.
Accordingiv, an application for a wastewater permit is to be submitted to either the Discharge
Section or the Non -discharge permiring Section by December 31: 2007, depending upon
?echnology selected. if a,-i Authorization to Construct (ArC) r2queat is needed (for a
_.__.-h r-T , - s- te�_tj i? is to be submitted to the Construction, Gran?s ar�d Loans Section for
aaaroval by the end of January 2008.
If \^ou have comments or CUz Stions. please call Keith Larick or Myrl'Nisely o; the Raleigh
Regional Office at 919-791-1200.
Dann\- Smith
Raleigh Regional Supervisor
Surface Water Protection Section
xc: Bradley Bennett; Stormwater Permitting
Keith Larick, PRO Aquifer Protection Section
Central Files I
Raleigh Regional Office 1629 Mail Service Center phone [phone] Customer Service
Water Qualm, Section Raleigh NC 27699-1628. facsimile [phone] 1-877-623-6749
NCDEN'

Carolina Bark Mul cher/Com poster meeting with Mid -Atlantic
Subject: Carolina Bark Mulcher/Composter meeting with Mid -Atlantic,
From: Ken Pickle <[e-mail]>
Date: Wed, 21 Nov 2007 15:33:37 -0500
To: Myrl Nisely <[e-mail]>
CC: Bethany Georgoulias <[e-mail]>, Bradley Bennett
<[e-mail]>, Gil Vinzani <[e-mail]>
Myrl,
FYI , no action, update only.
Darin McClure and Dan Nielsen(?) from Mid -Atlantic met with me this morning to
discuss two topics. First, infiltration schemes under NCG14; and second,
infiltration as a part of stormwater permitting to address Danny's/your November 14,
2007 letter to Carolina Bark in Seaboard (North Hampton County.)
As you predicted on the second topic, I had to re-establish DWQ solidarity on the
point that we believe that flows that contact windrows are wastewaters. Again, as
you reported, Dan had to talk a long time (to be sure that I understood the site and
project circumstances) building up to the crux of the issue, which is our current
working distinction between wastewater and stormwater on these sites.
He reported their current status vis-a-vis permitting options as:
a) At a dead end with Keith Larrick, RRO, and AP for a recycle permit due to the site
being too small to accomodate the buffer/set-back requirements under the rules of
that program.
b) Exploring with me the possibility of a stormwater permit for the composting -water
recycle system plus the discharge that occurs only in response to rainfall. This
gets to the wastewater/stormwater point that you discouraged them on, and that I
re -discouraged them on'this morning. They sought to somehow make the jump from an
infiltration system handling mixed NCG14 waters to why can't we similarly permit
composter wastewater (and in this circumstance it suited their objective to argue
that the leachate-wastewater was really stormwater) under a stormwater permit? They
quite amiably suggested that on the point of definition of wastewater we might need a
legal determination. I quite amiably responded that we had received such comments
before (Wallace Farms) and that the lawsuit route had evaporated when we did not
cave, and when another alternative was present (discharge to CMUD).
c) They did note that Carolina Bark wants to comply, and they implied that the delay
from your visit in 2003 to your 11/14/07 letter was at least partly due to pursuing
with Keith a recycle system permit, and the delay encountered in stepping through
that program before reaching a dead end. I advised them to check out the new 2T rules
in Keith's program to see if new opportunities might now exist for Carolina Bark.
They also reported that Carolina Bark hired several engineers previously who either
did not understand the big picture, or were not hired to address the big picture of
permitting. They further reported that Carolina Bark has stopped using fertilizer as
a process accelerant in the windrows.
d) They had not explored an NPDES wastewater permit for this site, but I gave them
Gil Vinzani's name and Matt Matthews' name as contacts.
I observed that it appeared that they now understood DWQ's perspective, and that I
was open to reconsidering a stormwater permit if they could propose a clever way to
allow us to permit the discharge within the constraints that apply to our program,
but that it was very unlikely we would backslide on our wastewater/stormwater
distinction. I re -iterated that when NCG21 is renewed in 2008, we will be looking at
which discharges may no longer qualify as stormwater.
Based on the little I know about their circumstances, it occurs to me that their
best/only remaining alternative to closing down or covering the site, would be to
install a wastewater treatment system and obtain a wastewater permit from Gil. I
imagine that they might be able to recycle the process water (currently obtained from
l of 11/21/2007 3:58 PM

Carolina Bark Mulcher/Composter meeting with Mid -Atlantic
a dedicated on -site well) from a new pond rather than the well, and that any overflow
from that "process pond" could flow to a "waste treatment pond", and the discharge
from that pond must meet the limits Gil places in his NPDES wastewater permit.
Without knowledge of the actual flow numbers involved, my hope in this two --pond
system is that perhaps there would be a reduced volume of wastewater that may have to
be treated, and consequently a reduced operating cost, perhaps even the possibility
of a batch operation on the wastewater pond, rather than a more traditional
flow -through operation. It all depends on the physical facts as to site
configuration and leachate volume and recycle demand. The second pond (the
wastewater treatment pond, as opposed to the process water pond) might even be
located on an adjacent piece of property that Carolina Bark might be able to lease or
buy, as reported by Dan and Darin. They indicated that a pump would be required to
deliver wastewater to this adjacent property. It seems to me that this avenue of
investigation is all that's left to them, and that it actually may be very
promising. Gil's group would have to evaluate all this, of course.
Ken
2 of 2 1 1/21/2007 3:58 PM

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Submittor
Carolona Bark Products
Address
P O Box 395
Seaboard, NC 27876
email
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Fax
252-589-1642
Date Received
Hate Completed
-' JRPeters • • • •
POROMETER ANALYSIS
D812&07
0829107
Account No. 4609010
Submission No. 83613
Lab ID sample ID
Container
Total Poro6 %6 Ca i Air S co%
Bulk DensitV
Mvlat Bulk
Density
Moisture
1—Initial %
Moisture
2703344 Pile 5- New Grind
55.61 47.20 7.41
10.56
28.615
73.6
63.095
Explanation of Ferris
Total Porosity
Calculated amount of total pore space in the sample.
Container Capacity
Calrolatsd amount of water the sample will hold against gravity.
Air Space
Calculated amount of space in the sample that will not hold water against gravity.
Bulk Density
Calculated density of the materiai when completely dry.
Moist Bulk Density
Calculated density of the material after draining excess water
% Moisture
Catrulated moisture of the sample after soaking,
Initial % Moisture
Calculated moisture oft he sample as reaerv&l
% Working Moisture
Additional moistening of sample was required to facilitate analysis,
Technical Support NeeilaWe
E°Il tree [phone] art 46
Released by Lin Shaub
Lab Admin. Assistant
8r29/2007
Fax : (81o) 391,1337

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J.R. Peters Testing Laboratory
605B Grant Way, A11en1own PA 18106-9316
PhOM W135225752 Fax 6i"91.1337
Submitior
Carolina Bark Products
Address
PO Box 395
Seaboard, NG 27976
email
Carrtlrw-ls3rx4moeo-n net
Fax
252 5B9-1642
Date Received 09/06106
Date Completed M14106
POROMETER ANALYSES
Account N0.4609010
ID
Sample ID
Total Porosi ,G
Container
Ca act Air 5 ace°/,
Bulk Densi
Moist Bulk
Density
9L Moisture
initial %LaG
Moisture
2606260
ed Ba*
81.49
51.31 30.36
9.76
29.62
76.57
67.06
Explanation of Terms:
Total Porosity Calculated amount of total pore space in the sample,
Container Capar Calculated amount of water the sample wilt hold against gravity.
Air SPaco Calculated amount of spaoe in the sample fiat will not hold water against gravity.
Bulk Density Calculated density of file material when completely dry.
Moist Bulk Dens Calculated density of the material after draining excess water.
% Moisture Calculated moisture of the sample after soaking.
Initial % Mcisturi Calculated moisture of the sample as received.
% Working Mois Additional moistening of sample was required to facilitate analysis.
Released by C. Peters
Manager nt Analytical Services
9l14l7.006

J.R. Peters Testing Laboratory
a 5556 Grant Way, Allentown PA 10106.0318
Phone886•S225752 Fax610-391•1337
POROMETER ANALYSES
SubmMor Carolina gar* Products
Account No. 4609010
Q
Address PO 13ox'395
Submission No. 70260
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Seaboard, NC 27876
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2510495 Sand Mix 85.37
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Bulk Denslty Calculated density of the material when completaty dry.
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Moist Bulk Dens Calculated density of the material after draining excess water.
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% Moisture Calculated moisture of the sample attar soaking.
Initial % Moistun Calculated moisture of the sample as received.
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Manager d Anar tcaf SeNcov
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J.R. Peters. Testing laboratory
6a59 Gr*M VAq, A11 iftM PA 1010"315
Phpf�at]8$-5728762 PAx810-5�1-138i
SVbmtttar Camlina Bark Products
Addr"s PO Box 395
Seaboard, NO 27876
Rtnall MrCim ULWI&LM
Fa-g 252 584-1 U
Oste Reoelved 03Q"5
00 Completed 0Q131f06
PORO METER ANALYSES
AMC un t No. 460201 Q
Sample no, 2502446
b
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ota u
roydal %
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2 9JNow
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1 B .
3A.0 i QA8
1 30,13
40
1 fi .91
EWan0on of Terms:
Tutga Parosily Calculated amount of total pore scace In the sample.
Container CapacCelouisted amount of water N1e_5alt'rple wlP told agalimt gnv ty.
Air Space Catfil.rWad amount of space In tha sample ttat wilt, not hold Water against gravity.
Sulk Donsdty Galculated dsnalfy of Ow matariai Aen cor-Oetaly dry.
Wist Hulk Dans Calculated density of the materiel oflar drWning excess avatar.
55 tu4alstwe Cralwloted moisture at the sample o"r soaking.
Initial %Mo'tstureCaloulated moisture of the sample as reaelved.
% WorkJng Mois Additional rnoWaaing of sample was required to faclliteto analysis.
ftewb try C. Paters
Man4ar of Anelytk4 3errrices
are uaoo5

Rx Odte/Time . 01=C-03-2007(MON) 03:20 12525891324 P.006
12/02/2007 20:31 12525891324 CAROLINA BARK PAGE 06/07
St=anie Vaughan
From: Ted Bifderback (tbilderback&c.mcom]
Sent: Monday, February 24, 2003 7:33 PM
To: [e-mail]
Cc: Ted_8i1derbackdncsu.edu
Subject: Physical Property Data
RN-141
Camllna Bark Prod
PPhys.xls (...
Bob:
Please find attached an Excel file that provides physical property analysis data as well
as the particle size analyses sent last week.
The physical property data supports conclusions based upon particle size analysis. The
aged pine bark has the highest air space volume (30%) and the lowest' container capacity
(approximately 50YO and available water content
values (approximately 19�). Addition of fine particle components such as
sand will decrease air space and increase container capacity and available water content;
most likely closer to the other two pine bark samples tested. However, although the 50!50
and the 3-4 month old sample have very good physical properties now —they will continue to
break down and the aged sample will likely change less over time than the other 2 products
teatod.
The lower available water content, is expected as water is held inside of pine bark
particles, particularly after particles age,become softer and allow water to penetrate
into interior pores. Although the water is there, it is not removed with our 15 bar
extractor, therefore it is accounted for as unavailable water content.
All three samples have acceptable physical property values. The aged product would he
excellent used alone in propagation, or used as a potting substrate with additon of sand
or other stable fine particle components. Although more frequent irrigation would be
appropriate, many crops such as azalea would flourish in the aged product as a stand alone
potting component.
If you have questions concerning my comments please contact me_
Ted E. Bilderback
Professor and Extension Nursery Specialist
Dtpartment of horticultural Science
Box 7609
North Carolina State University
Raleigh, NC 27695-7609
Direct Phone [phone]
FAX ; 919-515-7747
e-mail: Ted_ Bilderback®nceu.edu
WebPage http://www.ces.nc3u.edu/depts/hort/Rursery/

PHYSICAL PROPERTIES OF CAROLINA BARK PRODUCTS
Substrate
Total
Air
Container
Description
Porosity
Space
Capacity
".
%
%
(% volume)
50150 MIX
84.86
26.48
58.38
100% AGED BARK
79.77
30.41
49.36
100% 3-4 MONTHS OLC
83.75
25.42
58.33
Sieve No.
114"
#10
#25
• #35
#60
#140
pan
0
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co
Q
v
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7E Cy
Available
Water
4�
32,41
18.65
34.03
Particle Size distribution of
Sieve Size
50l50 AGED
6.3mm
2mm
15.39%
0.71 mrn
37.07%
0.5mm
213,19%
0.25mm
8.64%
0.106mm
7.53%
Omm
2.56%
0.63%
22.34%
38.02%
21.31%
7,01 %
7,07%
3.10%
1.15%
Unavailable
Water
%
25,97
30.71
24.30
Mvaomt.
16.66%
37.36%
26.91 %
8.35%
7.53%
2.65%
0.55%
Bulk
Density
(glcc)
0.17
0.18
0.17

CAROLINA BARK PRODUCTS 34,
STORMWATER PERMIT NCG210136
SEABOARD, NORTH CAROLINA
MID -ATLANTIC JOB NO. 0OR1756.00
Prepared For:
Mr. Danny Smith
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, North Carolina 27699
Prepared By:
Mid -Atlantic Associates, Inc.
409 Rogers View Court
Raleigh, North Carolina 27610
December 28, 2007
Mom -ATLANTIC
ASSOCIATES. INC.
Eaginrr,in% A fnri,onweaiul Solnrioo.

MID -ATLANTIC
ASSOCIATES, INC.
Engineering & Environmental Solutions
409 Rogers View Court /Raleigh /North Carolina 127610
800-486-7568 / 919-250-9918 /919-250-9950 Facsimile
www.maaontinecom
December 28, 2007
Mr. Danny Smith
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, North Carolina 27699
Subject: CAROLINA BARK PRODUCTS
STORMWATER PERMIT NCG210136
SEABOARD, NORTH CAROLINA
MID -ATLANTIC JOB NO.00R1756.00
Dear Mr. Smith:
On behalf of Carolina Bark Products, LLC (CBP), Mid -Atlantic Associates, Inc. (Mid -
Atlantic) submits this letter updating NCDENR on activities associated with stormwater
permitting at the CBP facility in Seaboard, North Carolina (Drawing 1).
Carolina Bark Products receives bark via conveyor from an adjacent paper manufacturing
facility and degrades the bark into a commercial nursery bedding product. This process
entails grinding the raw material bark, placing the bark in windrows and moistening the
windrowed bark (for fire protection via temperature control). Within several months, the
bark degrades to the final product and is transported off site. Raw material storage (both
pre and post grind) is typically less than 200 cubic yards. The windrowed bark maximum
capacity is approximately 150,000 cubic yards.
The CBP facility currently operates under General Permit Number NCG210136
(stormwater permit). In a letter dated November 14, 2007 Division of Water Quality
informed CBP that renewal of this stormwater permit, which is due to expire April 30,
2008, is `disallowed'. This letter cites the discharge of unauthorized process water as the
reason the stormwater permit will not be renewed.
Carolina Bark Products has been evaluating alternative means of handling stormwater at
the facility since this issue has been raised including several meetings with various
Sections of NCDENR. Most recently, meetings have been held with Mr. Ken Pickle on
November 21, 2007 and Mr. Pickle and Mr. Keith Larick on December 5, 2007 to discuss
the issues presented by the conditions at the facility.
MID -ATLANTIC
ASSOC IATFS.INC.
En,=inrrrk,t d EnsirnrNrntn7 Solptioni

Carolina Sark Products December 28, 2007
Stormwater Permitting Page 2
Seaboard, North Carolina
Based on these meetings, CBP came to understand that the Division considers any water
that discharges from the bark windrows is a 'process' water. This is because rainwater
impinges on the bark windrows and combines with water applied for fire control prior to
discharging from the windrows. The stormwater permit does not allow the mixing of
stormwater and process water. Further, the Division has stated that if a process water
and a stormwater mix, the resultant water is a process water. Thus, the Division has
determined, under the current configuration of the facility, that the water discharging from
the CBP facility is an unauthorized discharge of process water. It is worth noting that there
have been no substantive changes in the operation at this facility since Stormwater
Permit NCG210'h36_was issued on May 1, 2003.
After careful evaluation, CBP has established an objective of eliminating water discharges
from the bark windrows as well as containing all stormwater on site. This concept was
discussed with Mr. Pickle and Mr. Larck during the December 5, 2007 meeting. Both Mr.
Pickle and Mr. Larick considered the concept viable pending review of the technical
details. Since this proposed approach precludes the need for a discharge permit or a non -
discharge permit, the conventional means of conveying technical details, the permit
application, has been eliminated. Therefore, we have included a review of the approach
with technical support to this letter. Due to time constraints and the pending mid -holiday
deadline established in the Division's November 14, 2007 correspondence, the pond
design has not been completed. This will be provided under separate cover when
completed. Pond sizing calculations are included.
— PROCESS WATER DISCHARGE ELIMINATION
As defined by the Division, process water at the CBP facility is water that discharges from
the windrowed bark. As a part of CBP's quality control initiatives, windrowed bark samples
are periodically collected and tested. Among the tests conducted is the capacity of the
material to absorb water. Laboratory reports of porometer analysis are attached and show
an average Container Capacity of approximately 50% (Attachment A). Container Capacity
is defined the amount of water the test sample will hold against gravity. This suggests that
each cubic yard of windrowed bark will hold one-half cubic yard of water (approximately
100 gallons of water) before water discharges from the sample.
A typical bark windrow is approximately 70 feet wide, 600 feet long and 15 feet tall with
the sides sloped at a 1 to 1 ratio. Thus, the volume of this windrow is approximately
M 18,300 cubic yards (Attachment B). Based on the porometer tests, this windrow has the
capacity to retain approximately 1.8 million gallons of water. If we assume the 50% of this
capacity is inaccessible (consumed by fire suppression water or precipitation), this 'real
world' windrow has the capacity to absorb 900,000 gallons of water.
Seaboard, North Carolina is located approximately equal distant from Raleigh and
Washington, North Carolina. The average of the 25-year, 24-hour storm rainfall for these
MID -ATLANTIC
ASSOC IATE 5.1NC.
4:exixrrring A Effrirammrval Salrrioei

Carolina Bark Products December 28, 2007
Stormwater Permitting Page 3
Seaboard, North Carolina
locations is 6.6 inches. A 6.6-inch rainfall over the foot print of this windrow (70 feet by
600 feet) is approximately 173,000 gallons. Thus, the typical real world bark windrow has
the capacity to store in excess of five 25-year, 24-hour storms without a discharge.
This suggests that even consecutive extraordinary rainfall events will not result in a
discharge of process water at the CBP facility.
In order to prevent stormwater runoff from contacting the bark windrows, CBP proposes
to construct soil berms around each windrow or group of windrows (Drawing 2). These
berms will also be used to segregate windrowed bark of various ages. Native soils
approximately 20 to 108 inches below land surface, which are clayey in nature, will be
used to construct the berms (Attachment C).
I With the high absorption capacity of the windrowed bark and the berm network, process
i — water generation as defined by the Division is eliminated.
STORMWATER DISCHARGE ELIMINATION
Although the elimination of process water as described above will allow the facility to
discharge stormwater under the General Permit, CBP has recognized that this stormwater
could be put to beneficial use. The plan is to retain stormwater in a stormwater retention
pond and use this water to supplement the fire suppression water needs at the facility.
Since the retention pond will only capture stormwater (i.e. not process water), the
proposed 'recycle system' does not require a Non -discharge Recycle Permit.
As the feasibility of retaining stormwater was evaluated, the potential to eliminate all
stormwater discharge was realized. Borrowing from design criterion used for Non -
discharge permitting for wastewater disposal, a stormwater retention pond capable of
holding a 25-year, 24-hour storm plus one foot of freeboard was evaluated. The run off
calculations are detailed in Attachment D and the run off and retention pond areas V
illustrated in Drawing 3.
Based on local topography and surface conditions, the 25-year, 24-hour storm will be
contained in a stormwater retention pond with a capacity of 1,440,000 gallons (192,000
cubic feet). Stormwater retention pond design details are currently being developed by
Jeff Robinson & Associates, LLC and will be submitted to the Division upon completion in
January 2008.
The stormwater retention pond will be equipped with a fire suppression pumping system
for the windrowed bark. This system operates as a fire prevention system by wetting the
windrowed bark to prevent temperatures from getting too high within the windrowed bark.
This system can pump water at a rate of 78 gallons per minute (gpm). The pump system
can remove the entire 25-year, 24-hour storm volume from the pond in approximately 13
days. The .volume for a 2-year, 24-hour storm can be removed in approximately 7 days.
MID -ATLANTIC
ASSOC IATES. INC.
Enginrrring d EF0,0-mrayal 501ationa

Carolina Bark Products December 28, 2007
Stormwater Permitting Page 4
Seaboard, North Carolina
These are conservative time frames since evaporation and exfiltration from the pond have
not been considered. As shown. above, the windrowed bark has ample storage capacity
to absorb this water even after the 25-year, 24-hour storm.
0
Using the conservative design criterion developed for Non -discharge permitted waste
disposal system for this stormwater retention pond, coupled with the safety factor offered
by the stormwater recycle system, the CBP facility becomes a `no discharge' facility (not
to be confused with a non -discharge facility). As such, permits associated with water
management at this facility will not be required.
SCHEDULE
Bark typically remains in windrows from four to six months. As each windrow matures and
is removed from the facility, the berm construction will commence for the recently
removed windrow. Therefore, we anticipate that the berm construction will be completed
in approximately six months or by June 30, 2008.
Pond construction will be initiated in the winter with an anticipated completion date on or
before April 30, 2008. Thus, water discharges from the CBP facility will be terminated
prior to the expiration of the current General Permit.
We would appreciate your acknowledgement that the approach we have presented here
is a viable strategy to eliminate discharges from the facility. Since considerable resources
will be required to implement this plan, CBP will not commit to construction until CBP has
received comments from the Division. The above schedule is based on a timely response
from the Division. If you have any questions, please do not hesitate to contact the
undersigned at 250-9918 or Perk Taylor at 757-657-2009.
Sincerely,
MIDJel.
TIC ASSOCIATES, INC.
%.�1�, a�{i{4�liJflpf/f0
'l f`Q�lk CA?0( I�
ES
it ss� S �140_74\R
Danlsen,�PE SEAL !l Darin M. McClure, PE
Principal Engineer I8149 l Principal Engineer
Attachments .�''•�' *%,.. ..W-- 4P,.
L
•. H. N1E ..
Cc: Perk Taylor
Ken Pickle
Keith Larick
MID -ATLANTIC
ASSOC IATE SjNC_
EaFinre+ine 6 Enrlrow arval Solufiops
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REFERENCES:
1. JACKSON, NC AND CLARESVILLE, VA DIGITAL RASTER GRAPHIC FILES, USGS.
SCALE: 1:12,000
SCANNED FROM 1:24,OU0-SCALE TOPOGRAPHIC MAPS (JACKSON, NC, 1974
AND CLARESVILLE, VA, 1997) PUBLISHED BY THE USGS.
Feet
2. INSET MAP DIGITAL DATA FROM BUREAU OF TRANSPORTATION O
5OO 1,000
2,000
STATISTICS, WASHINGTON, D.C.
TOPOGRAPHIC SITE
DRAWN i P—
DATE:
BY:
DECEMBER 2007
T�
�I1J-ATLANTIC
LOCATION MAP
DRAFT
.�oB No:
CAROLINA BARK PRODUCTS
CHECK:
000R1756.00
ASSOCIATES . I N C .
$hglneerl ll8 & Fhrl;-0nMenf?71 u011t !1 ��h3
4400 N.C. HIGHWAY 186
ENG.
CHECK:
GIS NO:
01G-R1756.OQ-1
SEABOARD, NORTH CAROLINA
APPROVAL: J�
DWG NO: I

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Submittor
Carolona Bark Products
Address
P O Box 395
Seaboard, NC 27876
email
llinabarincpl.flet
Fax
252-5139-1642
Date Received
Data Gompleted
,.o JRPeters . •
POROMETER ANALYSIS
06f26l07
06129/07
Account No. 4605010
Submission No. 83613
Lab ID
Sample ID
ToUd Poros
Container
Ca i Air S ce%
BulkDomity
Moist Bulk
I Density
% Moisture
Initial a%
I Moisture
2703344
Pile 5- New Grind i
55.61
1 47.20 1 7,41
1 10.56
1 28.615
1 73.6
1 63,095
E*Ianation of Terms:
Tool Porosity
Container Capacity
Air Space
Bulk Density
Moist Bulk Density
% Moisture
initial % Moisture
% Working Moisture
TochnicM Support Available
Calculated amount of total pore space in the sample.
Calculated amount of water the sample will hold against gravity.
Calculated amount of spaoe in the sample that will not hold water against gravity.
Calculated density of the matedai when completely dry.
Calculated density of the material artier draining excess water.
Calculated moisture of the sample artier soaking.
Calculated m6sture of the sample as received.
Additional moistening of sample was required to facilitate analysis.
toll free [phone] exl 46
Released by Lin 5haub
Lab Admin. Asaistanl
EV2912007
Fax: (010) $01.1337

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6e55 Grant Way, Allentrnm PA 18106-9316
Phone 866-5n.5752 Fax 6f0391.1397
Submitlor Carolina Bark Products
Address PO Box 395
Seaboard, NC 271376
email wrt4wLPARAdrnnenet
Fax [phone]
Date Received 69/06106
Dale Completed 09114/06
POROMETER ANALYSES
AccountNo.4609010
"ID
yarn Ie ID
Total Porosi ti
Canfainer
Ca ac i6
Moist Bulk
Air 5 ace% Sulk Densi Densit
% W clo sture
Initial %
MAolsture
6t}
Aged Ba14c t
61.49
51 31
30.36 _ 9.76 29.62____ _
76.57
67.D6
Explanation of Terms:
Total Porosity Calculated amount of total pore space in the sample.
Container Capac Calculated amount of water the sample will hold against gravity.
Air Space Calculated amount of space in the sample that will not hold water against gravity.
Bulk Density Calculated density of the material when completely dry.
Moist Bulk Dens Calculated densily of the material after draining excess water.
% Moisture Calculated moisture of the sample after soaking.
Initial % Mcistun Calcutafad moisture of the sample as received.
% Worldng Ws Additional moistening of sampte was required to facilitate analysis.
Released by C. Pelers
Manager of Arelytc2l Services
EW 4CL006

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0.656 Grant Way, Allanrown PA f81O&9318
Phone 8a&622-5752 Fax [phone]
POROMETER ANALYSES
Submittor
Carolina Sark products Aocount No. WOO 10
Address
PO Box 395 Submission No, 70260
Seaboard, NC 27876
email
caro4Aebersb&1B.n�s
Fax
252 559-1642
Date Received
10117J05
Date Compluwl I OV20105
Air
Explanalion of Terms:
ulk
Total Porosity UIGNeted amount of total pore spaos in to sample.
Container Cape( Calculated amount of water the sample WV hold against gravity.
Air Spaoa Galculated amount of space In the sample thal will not hold water against gravfty.
Bulk Density Calculated density of the material When completely dry.
Moist Bulk Dens Calculated density of the maiErial after draining excess water,
% Moisture Calculated moisture of the sample after soaking.
Initial % Maistun Calculated moisture of the sample as received.
% Working Mols Additnaf moistening of sample was required W facilitate analysis
Moist Bulk
Released dy C. Peters
Mannar a Analytical Services
101i012005

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PORQ EVER ANALYSES
3VbfAIttor CArDHha Bark Producxs Amount No,46D3010
Addr"s PO 60,x 396 , Sampie rd, 2502448
Uabowd, NO 27B76
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TW(I rally Calcmisted amountof total pore space In the eampia,
CtantalrW CapacCalouisted amount of wale[ ttYe.5a114)W 4 Hold apainot gravity.
Air Spam i:aWfsted arnount of atsece.tn Iha $arr * tbetWfll nut hold water agairistgnaaity.
Bulk DsrWW Qalculatsa density of the material vdtaq 00rr-Os0ly dry,
Wist 8u0c Done CelmIged densty of the matvUl oiler drelning arse water.
% WIsture C,aloulatad molst tire otthe sonle after soeking.
Initial % WsturrQalvulated Moi$Wre of the sample 86 reoahred.
4� Nrorking Moss Addttional rnoWenln0 of sample was required to facllitale analybie.
Rete&sad by C. PfAara
MenV9; 0 Ansly" Ser kes
N5tr1005

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ABSORPTION CAPACITY OF WINDROWS
CAROLINA BARK FACILITY
MID -ATLANTIC JOB NUMBER: R1756.00
Volume of Windrow
Height 15 feet
Width at Base 70 feet
Length at Base 600 feet
Sidewalls- Rise 1 feet
Run 11 feet
Prepared By: DMM l2'2-7 !a�
Checked By:
Volume 495,000 cubic feet
Available Storage Capacity of Windrow
Percent of windrow volume able to
absorb water (based on lab data)
Available water storage capacity:
Percent available capacity filled
with irrigation water:
Available water storage capacity:
50
247,500 cubic feet (assumes no process water)
50
123,750 cubic feet
Calculate Volume of 25-year Storm That Falls on Windrow Footprint
Rainfall of 25-year storm
6.62 inches
0.5517 feet
23,170 cubic feet
Number of storm events windrow can hold prior to saturation: 5.34

Herbert and Associates, Ltd.
TESTING 0 ENGINEERING & INSPECTING
POST OFFICE BOX 6475E - VIRGINIA REACH, VA 23464 - PHONE [phone]
June 27, 2005
W. P. Taylor & Co.
_ J- Box 63"--
rani<lin: 'Virginia 2 3 8 ES
RE: Coro'ina Bark P rac-;ucfs
!4 10 N '' LH 1 ohwa'J f S6
r
SeGboara, N.C. 2 %876
Dear NAr- Taylor -
in,
accordance witl! your request, Herbert and Associate-, Lid. obtained
-Ind far; somples for permeability Tests on the above-rr ;tioneed proiect-
Tranrsmitted herein are the results as follows:
Sample # { - Lt. gray motfle red & orange -.lay
,-r ermeability Rate K=0.0006x i � r4
I trust' this is the information you require. If you have any �=:estiors, please feel
-Free to call upon us-
PpQp clEbmined,
Herbert and Associates, L cf'...
John A. Herbert, S.E.T.
President
`-)

Herbert and Associates, Ltd.,
P. O. Box 64758
Virginia Beach, Virginia 23464
Telephone: [phone]
Fax, (757j 545-6889
'-,'V. P_ Taylor & Co_,
P. O: Box 635
rankiin, Virginic;.. 23851
ine following was ,noted.
Cate: 6-8-05
Job Numder: 05-9528
Projedi Carolina Barr. Products Plant
Locutio�-,: Seaboard. N.C.
1 went to Caroling: Bark Products in Seaboard, N.C. as reques led to observe
and obtain a sample of soil removed from on area that is a proposed
drainage pond.
The material taken front the field wos brought back #o,he laboratory for a
permeability test. The results fro.--,, that jest will be reported once the test is
completed.
The test hole is as follows:
0" No Topsoil
0" - 12" Tap mottle orange, moist, Fine ,o ver,. fine sand (SP)
12% 20" Orange mottle tan, moist, fine to very fine sand with trace
of cloy (SP
20"-108" Lt. gray mottle red & orange, vvet, clay (C! )
108" Water Table
Inspection Conducted by- !ohn Herber*
Respectfully submitted,
Herbert and Assoc ^tes, Ltd..
Jon A. Herbert, S.F.T
'President

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ASSOCIATE S, I N C.
Engineering & Environmental Solutions
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BY— I DATE
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Carolina Bark Runoff Calculations
Performed by:
Checked by: OWA is(w? �0`1
Actual Runoff from Site
Storage (S) = (10001CN) - 10 where:
CN = 56.1 Runoff Curve Number
S = 7.8253
Q* = [(P - 0.2S)^2] I (P + 0.8S) where:
Q* = effective runoff depth in inches
P = precipitation in inches = 6.6 25yr124hr storm
S = storage in inches
Q* = 1.97 inches
Volume of Runoff from storm (Vt) = Q* (ft.) x Area of Site (sq. ft.)
Total Area of Site = 26.90 acres 1 acre =
Total Area of Site = 1,171,764 sq. ft,
Vt = 192,485 cu. Ft. 1 cu. Ft. _
Vt = 1,439,983 gallons
43,560 sq. ft.
7A81 gallons

Northampton County, North Carolina
165
TABLE 15.--SOIL AND WATER FEATURES --Continued
I
I Flooding
1 High water table I Risk of corrosion
Soil name and 114ydro-I I
1 I I i l I
map symbol I
logic{ Frequency I Duration
(Months I Depth I Kind (Months (Uncoated 1Concrete
Igroup
I I
I ! I I I steel I
I
I 1
I I Ft I I I I
I
LtD: I
I I
I I
I 1 I I I I
I l I I I I
Turbeville-------I
I
C
(None -------- I ---
I I
1 --- 1 >6.0 1 --- I --- ]High ----- (High.
Ly----------------I
- C
(None -------- I ---
I i I I I I
I --- 10.5-1.51ApparentlNov-AprlHigh ----- (High.
Lynchburg I
I I
I I
I I I I I I
I
NoA, NoB, NoC ----- I
B
{None -------- I ---
I I I I I I
I --- 14.0-6.OlApparentlJan-MarlModerate (High.
Norfolk
NuB*: I
1 I
I I
I ! l I I I
I I I I I 1
Norfolk ---- - ----- I
B
[None -------- I ---
I I
I --- 14.0-6.OlApparentlian-MarlModerate (High_
1
Urban land. 1
I 1
I l I I I I
I I I I I I
I
OcA--------------- j
C
I I
(None -------- I ---
I I I I ] I
I --- 11.0-2.51APParentlDec-Apr[High ----- (Moderate.
Ocilla I
I I
I I I I I I
I
PcB2, PcD2, PCE2, 1
I I
I !
1 I I I I I
! I I I I I
PgE2------------- I
B
INone--------I ---
I --- 1 >6.0 1 --- I --- (High ----- (High.
Pacolet 1
I 1
I I I ! 1 I
f
PtA----------------I
A
[ I
INone----------I ---
I I I I I I
] --- 11.5-3.OIAPparentlDec-Apr[Low ------ (High.
Pactolus I
I I
I I I I I I
I
Ra----------------I
B/D
I I
INone--------I ---
I I I 1 I I
I --- I 0-1-OIAPparentlNov-Apr]High-----IHigh.
Rains I
I I
I I I 1 I I
I
Ro----------------I
D
I I I I I 1 I I
loccasional (Brief-----(Nov-Jung 0-1.OIApparentlNov-MaylHigh ----- IHigh.
Roanoke I
I I
! I I I I I
I
Se ---------------- I
C
I I
]Rare -------- I ---
l I I I I I
I --- 12.0-4.0[APParentloec-MarlLow ------ IModerate.
Seabrook I
I I
I 1 1 I 1 I
I
StA--------------- I
B
I I
(Rare -------- I ---
I I I I I I
I --- 14.0-6.OlApparentiDec-JunlModerate IHigh.
State k
I 1
I I I I I I
1
TaB---------------I
- A
I I
INone--------I ---
i I I I I I
I --- I >6.0 I --- I --- (Low ------ IModerate.
Tarboro I
l I
f I I 1 I I
I
Te-----------------I
B/D
(Rare -------- I ---
1 --- I 0-1.OIApparentlNov-Apr]High-----IHigh.
Tomotley
I
TrA, TrS, Ts A,
I I
I 1 1 I l I
TsB, TsC, TtB2,
TuB-------------- I
C
INone--------I ---
1 --- 1 >6.0 1 --- I --- IHigh------IHigh.
Turbeville 1
I 1
l I I 1 I I
i
TxB*: I
I l
I I
I I I 1 I I
I I I 1 I I
Turbeville-------I
C
INone-------- 1 ---
I --- 1 >6.0 1 --- [ --- IHigh-----IHigh.
i
Urban land. 1
I I
I I
1 I I I I I
I 1 I [ I I
I
Ud*. I
I l
I I
I I I I I I
I I I ! I I
Udorthents
I
WaA----------------I
D
l I
IRare--------I ---
I I I 1 I I
I --- 10.5-1.5IApparentiDec-MarlHigh ----- IHigh.
Wahee
I
WdB, WeD2--------- I
B
I I
INone--------I ---
I 1 I I I I
I --- I >6.0 I --- I `-- [Moderate IHigh.
Wedowee I
I
I
I !
I 1 1 I I I
See footnote at end of table.