NCS000302_COMPLIANCE_20090807

—STORMWATER-DIVISION-CODING-SHEET
PERMIT NO.
CS oco
DOC TYPE
*FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
COMPLIA
OTHER
DOC DATE
❑ kMQ2 UU�1o'
YYYYM M DD

North Carolina
Beverly Eaves Perdue
Governor
Mr. Russ Powell
Vice President
Braswell Milling Company
105 Cross Street
P. O. Box 669
Nashville, NC 27856
Dear Mr. Powell:
Ak
r
NC®ENR
Department of Environment and Natural
Division of Water Quality
Coleen H. Sullins
Director
August 7, 2009
Subject: Compliance Evaluation Inspection
Stormwater Permit NCS000302
Braswell Milling Company
Nashville, NC
Nash County
Resources
0
Dee Freeman
Secretary
On August 3, 2008, Dave Parnell of the Raleigh Regional Office of the Division of Water Quality,
performed a compliance evaluation inspection (CEI) at your feed mill company. David Holloman,
Assistant Mill Superintendent and Kensey Murray, Feed Mill Superintendent, were available for the
inspection and their assistance was appreciated. This inspection was conducted to determine Braswell
Milling Company's compliance with its NPDES stormwater permit. Observations during the inspection
are as follows:
Although, Mr. Holleman and Mr. Murray noted there had been no significant spills in the last three
years, there was no list of significant spills within the Stormwater Pollution Prevention Plan (SP3)
as required by your permit. Please include a section tab and list within the SP3.
2. The SP3 had been reviewed and updated during the calendar year as required.
3. There was documented records of employee training required within the SP3.
4. Analytical monitoring is required semi-annually by the permit. The monitoring is currently being
conducted and reported as specified in your stormwater permit. Continue to follow Table 2 in your
Stormwater Permit, for analytical monitoring frequency. Qualitative monitoring is required semi-
annually, and is currently being conducted as specified in your stormwater permit, as well.
Nor0.`thCarolina
,lVatitrally
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: wxw.ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Braswell Milling Company Page 2
5. All Stormwater Discharge Outfalls (SDO) were inspected, as was secondary containment and
vehicle maintenance areas. All were found to be in compliance. There was a clear understanding
of the stormwater program by Mr. Murray and Mr. Holloman.
There was significant improvement in your facility's stormwater program since the November 24, 2008
inspection. Thank you for your diligence in following the intent of your stormwater permit. Your facility
is considered to be in compliance as of this inspection. If you have any questions or comments, please
contact Mr. Dave Parnell at [phone] or by email at david parnellaa nemail.net.
Sincerely,
Dave Parnell
Environmental Specialist
Surface Water Protection Section
Enclosure: August 3, 2009 Compliance Evaluation Inspection
V
O/SWP fil
ater Quality Central Files

Compliance Inspection Report
Permit: NCS000302 Effective: 03/01/09 Expiration: 02/28/14 Owner: Braswell Milling Company
SOC: Effective: Expiration: Facility: Braswell Milling Company
County: Nash 105 Cross St
Region: Raleigh
Nashville NC 27856
Contact Person: Russ Powell Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/03/2009 Entry Time: 01:30 PM Exit Time: 03:00 PM
Primary Inspector: David R Parnell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm water
(See attachment summary)
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000302 Owner - Facility: Braswell Milling Company
Inspection Date: 08/03/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: NCS000302 Owner - Facility: Braswell Milling Company
Inspection Date: 08/03/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
❑
❑
# Does the Plan include a General Location (LISGS) map?
■
❑
❑
❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑
■
Cl
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑
❑
# Does the facility provide all necessary secondary containment?
■
❑
❑
❑
# Does the Plan include a BMP summary?
■
❑
❑
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
❑
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
❑
❑
# Does the facility provide and document Employee Training?
■
❑
❑
❑
# Does the Plan include a list of Responsible Party(s)?
■
❑
❑
❑
# Is the Plan reviewed and updated annually?
■
❑
❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑
❑
Comment: Although there have been no significant spills in last three years reported,
there should be a list within the S133 to demonstrate that there are none or if spills have
occured, a place to list them.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
❑
❑
❑
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
■
❑
❑
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■
❑
❑
❑
Comment:
Permit and Qutfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
W
0
❑
❑
# Were all outfalls observed during the inspection?
■
❑
❑
❑
# If the facility has representative outfall status, is it properly documented by the Division?
❑
■
❑
❑
# Has the facility evaluated all illicit (non Stormwater) discharges?
■
❑
❑
❑
Page, 3

� ® 1
Permit: NCS000302 Owner - Facility: Braswell Milling Company
Inspection Date: 08/03/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: ROS not needed for this facility.
Page: 4

December 16, 2008 N (, S 0 0 0 3 0 ?/
Mr. Danny Smith
Regional Supervisor
Surface Water Protection Section
Dear Mr. Smith
In response to the compliance evaluation inspection performed by Dave Parnell on
November 24, 2008 this is Braswell Milling Companies planned schedule to achieve
compliance with the violations noted by Mr. Parnell.
1) Training will be updated annually as needed or as new employees are hired.
Retraining of current employees is scheduled for our January, 2009 safety
meeting.
2) Current analytical testing is being done for the last quarter of 2008. Samples were
delivered to Southern Testing Lab. on December 16, 2008.
3) Current forms will be kept up to date for any significant spills that occur.
4) Stormwater Pollution Prevention Plan is being reviewed and updated by Mid -
Atlantic Associates Inc. Their representative will be here on December 23, 2008
to evaluate and review the plan.
If you have any questions or comments please contact:
Kersey Murray or David Holloman
252-459-2143
Thank You //////// /�//���
(Zea'- �z' " ��
David Holloman
Assistant Mill Superintendent
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® Michael F. Easley, Governor
Ronald Scott Braswell
Braswell Milling Company
105 Cross Street
Nashville, NC 27856
Dear Mr. Braswell:
William G Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
December 2, 2008
Coleen H. Sullins, Director
Division of Water Quality
DENR RALEIGH F.
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000302
Braswell Milling Company
Nash County
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft
very carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from this facility's current permit:
2008
Analytical monitoring changes:
1. The analytical monitoring for Total Suspended Solids, Nitrogen and Phosphorus was maintained for the
sampling requirements in this permit. Additional monitoring will include COD.
Based on the lack of data and potential pollutants from this operation, all of the parameters for the
original permit will be maintained in the renewal. COD will be included in the renewal permit because it
could be a potential pollutant at a feed manufacture.
2. pH has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in
Part II Section B. The permittee must also document the total precipitation for each event. If no discharge
occurs during the sampling period, the permittee must submit a monitoring report indicating "No Flow"
within 30 days of the end of the six-month sampling period. Additionally, samples must be taken a
minimum of 60 days apart, as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark
values require the permittee to increase monitoring, increase management actions, increase record
keeping, and/or install stormwater Best Management Practices (BMPs) in a tiered program. If the
sampling results are above a benchmark value, or outside of the benchmark range, for any parameter at
any outfall then the facility shall follow the Tier 1 guidelines which require a facility inspection within
two weeks and implementation of a mitigation plan within two months. If during the tern of this permit,
the sampling results are above the benchmark values, or outside of the benchmark range, for any specific
parameter at a specific discharge outfall two times in a row (consecutive), then the facility shall follow the
Tier 2 guidelines which require a repetition of the steps listed for Tier 1 and also immediately institute
monthly monitoring for all parameters at every outfall where a sampling result exceeded the benchmark
value for two consecutive samples.
5. You are required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part II Section B. Qualitative monitoring is required regardless of
representative outfall status.
I rrthCarolina
,Uhtrally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.encstate.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirma0ve Action Employer -50% Recycled/10%Post Consumer Paper

Qr. Braswell
�raswell Milling Comopano
Permit No. NCS000302
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6. You are responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall
parameter is in this permit, however.)
8. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical
and qualitative monitoring. This requirement appears in all Individual Stormwater permits, however it
only applies to facilities that do vehicle maintenance. if the facility begins vehicle maintenance during the
permitted timeframe then the requirements shall apply.
Other permit changes:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants
in each outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of
significant spills that have occurred in the past three years and also must certify that the outfalls have
been inspected to ensure that they do not contain non-stormwater discharges. Additional information is
provided in Part II Section A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part 1I Section A.
More details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II '
Section A. The plan must also be updated annually to include a list of significant spills and to certify that
the outfalls do not contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial
materials and activities are not exposed to precipitation or runoff as described in 40 CFR §122.26(g), the
facility may qualify for a No Exposure Exclusion from NPDES stormwater discharge permit
requirements. Additional information is provided in Part I Section A.
Please submit any comments to me no later than thirty (30) days following your receipt of the draft.
Comments should be sent to the address listed at the bottom of this page. If no adverse comments are
received from the public or from you, this permit will likely be issued in about two months.
If you have any questions or comments concerning this draft permit, contact Brian Lowther at [phone]
or [e-mail]
Sincerely,
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
cc: Raleigh Regional Office
Stormwater Permitting Unit
Attachments: Draft Permit

Permit: NCS000302 Owner • Facility: Braswell Milling Company
Inspection Date: 11/25/2008 Inspection Type: Stormwater Reason for Visit: Routine
Inspection Summary:
Page: 2

a
Compliance Inspection Report
Permit: NCS000302 Effective: 08/31/01 Expiration: 08/31/06 Owner: Braswell Milling Company
SOC: Effective: Expiration: Facility: Braswell Milling Company
County: Nash 105 Cross St
Region: Raleigh
Nashville NC 27856
Contact Person: Russ Powell Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 11/25/2008 Entry Time: 10,00 AM Exit Time: 11,30 AM
Primary Inspector: David R Parnell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
E Storm water
(See attachment summary)
Inspection Type: Stormwater
Page: 1

0
Braswell Milling Company, 11/25/08 Page 2 of i
a
If you need assistance with understanding the analytical monitoring requirements or any other
aspects of your permit, please contact Mr. Parnell. Please be aware that all violations may result
in the assessment of civil penalties in an amount of up to $25,000 per day per violation. Please
reply within 30 days of your receipt of this letter with a narrative and your planned schedule to
achieve compliance with all permit requirements. If you have any questions or comments, please
contact Dave Parnell at 919 791-4200.
Si crely,
r �
Danny S ith
Regional Supervisor
Surface Water Protection Section
Enclosures
cc: RRO/SWP files
Water Quality Central Files

ATF9 so
IOr
0 ©5�
November 25, 2008
CERTIFIED MAIL 7007 2680 0001 8696 7384
RETURN RECEIPT REQUESTED
Mr. Russ Powell
Vice President
Braswell Milling Company
105 Cross Street
P. O. Box 669
Nashville, NC 27856
Subject: Notice of Violation
es
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Case No. NOV-2008-PC-0815
Compliance Evaluation Inspection
Stormwater Permit NCS000302
Braswell Milling Company
Nashville, NC
Nash County
Dear Mr. Powell:
Cole" H. Sullins, Director
Division of Water Quality
On November 24, 2008 Dave Parnell of the Raleigh Regional Office of the Division of Water
Quality performed a compliance evaluation inspection at your feed mill company. Kensey Murray,
Feed Mill Superintendent, was available for the inspection and his assistance was appreciated. This
inspection was conducted to determine Braswell's compliance with its NPDES stormwater permit.
The following observations noted below, resulted in this letter being a Notice of Violation, but
because there have been improvements since the last inspection in 2006; there will be no civil
penalty assemssment for the non -compliant issues at this time. Observations during the inspection
are as follows:
There was no documented record of employee training required by the Stormwater Pollution
Prevention Plan.
2. There was no recent record of analytical monitoring required quarterly by the permit now in effect.
The last analytical monitoring was conducted February 13, 2008.
3. Although, Mr. Murray noted there had been spills in the last three years, there was no list of
significant spills in the Stormwater Pollution Prevention Plan as required by your permit.
4. The Stormwater Pollution Prevention Plan has not been reviewed and updated annually as required.
rCaro ina
urally
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection
Internet h2o encstate.nc.us 1628 Mail Service Center Raleigh, NC 27699-1628
An Equal OpportunitylAff rmatve Acton Employer— 50% Recycled110% Post Consumer Paper
Phone [phone] Customer Service
FAX [phone]

Permit: NCS000302 Owner - Facility: Braswell Milling Company
Inspection Date: 11/25/2008 Inspection Type: Stormwater Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
Cl
❑
❑
# Does the Plan include a General Location (USGS) map?
■
❑
❑
❑
# Does the Plan Include a "Narrative Description of Practices"?
■
❑
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑
■
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
❑
M
❑
❑
# Does the facility provide all necessary secondary containment?
■
❑
❑
❑
# Does the Plan include a BMP summary?
®
❑
❑
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
❑
❑
# Does the Plan Include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
❑
❑
# Does the facility provide and document Employee Training?
❑
■
❑
❑
# Does the Plan Include a list of Responsible Party(s)?
■
❑
❑
❑
# Is the Plan reviewed and updated annually?
❑
■
❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑
❑
Comment: There is not a list of spills in the plan. Mr. Murray stated that they were two
that he recalled and they were recorded in his records. Stressed the importance of
employee training and suggested that he add training for stormwater to his safety
meetings and have employees sign their name showing that they attended. The plan
has not been updated in last two years.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
❑
❑
❑
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
❑
M
❑
Cl
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■
❑
❑
❑
Comment: Was last tested 2/13/08, but not in last two quarters. Same for Vehicle
Maintenance (tests at Outfall #2).
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
la
❑
❑
❑
# Were all outfalls observed during the inspection?
■
❑
❑
❑
# If the facility has representative outfall status, is It properly documented by the Division?
❑
■
❑
❑
Page: 3

0 0
Permit: NCS000302 Owner - Facility: Braswell Milling Company
Inspection Date: 11/25/2008 Inspection Type: Stormwater Reason for Visit: Routine
At Has the facility evaluated all illicit (non stormwater) discharges?
Comment: Plant is in good condition. There are no unlabled barrels or other potential
hazards noted. Mr. Murray has a grasp of the stormwater program, but has not
continually administered it.
■ ❑ ❑ ❑
Page: 4

® ® Michael F. Easley, Governor
William G. Ross, Jr.. Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
` Division of Water Quality
February 1, 2006
Mr. Russ Powell CERTIFIED MAIL
Vice President - Feed RETURN RECEIPT REQUESTED
Braswell Foods
105 Cross Street
P.O. Box 669
Nashville, NC 27856
Subject: NOV-2006-PC-0026
Notice of Violation Resulting from Compliance Evaluation
Inspection on 01/12/2006
NPDES Stormwater NCS000302
Braswell Foods -Nashville
`Nash County
Dear Mr. Powell:
The January 12th, 2006 tour that you provided to Ron Boone and Myrl Nisely during their annual
inspection of your facility located at 105 Cross Street in Nashville was greatly appreciated. This
inspection was conducted to determine Braswell's compliance with its NPDES stormwater permit,
NCS000302. This permit, issued 1 September 2001 by authority of North Carolina General Statute
(NCGS) 143-215.1, is intended to prevent pollution of state waters that receive stormwater discharges
from your facility. Please use the permit references listed in this report for further explanation and
compliance details of each item cited.
SITE SUMMARY
Your site is an animal feed production facility that primarily uses nutritional enhancement
chemicals in the production process. Other chemicals are used on site for vehicle and equipment
maintenance, but quantities and usage are minimal and do not qualify your facility as one that
performs on -site vehicle maintenance, as specified in Part 1I, Section D, of your permit.
All stormwater generated at your site is collected via a system of in -ground drains that convey the
stormwater to the Nashville municipal storm sewer system, to an unnamed tributary of Sapony
Creek, a class WS-IV, nutrient sensitive water.
INSPECTION FINDINGS
The list below shows conditions and practices observed during the tour portion of the inspection.
• In general, the site was kept clean and well maintained. The only condition observed during the
inspection that could detrimentally affect the quality of your stormwater discharge was that the
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�l�atural�
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: h2o encstate.nc us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal OpporlunitylAffrmative Action Employer— 50% Recycledl10 % Post Consumer Paper

Braswell Foods, Compliance Eva ion, January 12, 2006, NCS000302 •" Page 2 of 3
drain valves on secondary containment structures were not locked as required in Part II, Section A,
Paragraph 2b.
The list below shows numerous conditions observed during the interview portion of the inspection.
• The stormwater pollution prevention plan (SP3) was inadequate as follows:
• The site plan component of the SP3 was inadequate as follows:
• The general location map did not show the lines of discharge to waters of the state. The
receiving stream was not labeled with its name and the map did not show an accurate
latitude/longitude of the point(s) of discharge. Finally, the name of the municipality, whose
storm sewer system you discharge to, was not listed (Part II, Section A, Paragraph la).
• The site map did not show the location of Outfall 001 and it did not list the potential
pollutants that could be expected to be present in the stormwater discharge as required in
Part II, Section A, Paragraph 1c.
• The site plan did not include a list of significant spills that occurred at the facility over the
last three years as required in Part H, Section A, Paragraph 1d.
• The site plan did not include a certification that stormwater outfalls had been evaluated for
the presence of non-stormwater discharges as required in Part II, Section A, Paragraph 1 e.
• The stormwater management plan component of the SP3 was inadequate as follows:
As noted above, drain valves on secondary containment structures were not locked during
the inspection. Additionally, records of secondary containment inspections and drainage
activities have not been kept as required in Part H, Section A, Paragraph 2b.
• No spill prevention and response plan (SPRP) has been developed as required in Part 11, Section
A, Paragraph 3.
• No written preventative maintenance and good housekeeping program has been developed as
required in Part II, Section A, Paragraph 4.
• No employee -training program has been developed as required in Part II, Section A, Paragraph
5.
• Those responsible for the coordination, development, implementation, and revision of the SP3
have not been identified by position as required in Part H, Section A, Paragraph 6.
• The SP3 has not been reviewed and appropriately updated on an annual basis as required in Part
II, Section A, Paragraph 7.
• No facility inspection program has been developed as required in Part II, Section A, Paragraph
8.
• Full implementation of the SP3 that you have is questionable. Although the SP3 you have is
well organized, many components are missing or inadequate as noted above. Those that are
inadequate illustrate that your current plan has not been fully implemented as required in Part II,
Section A, Paragraph 9.
Neither qualitative nor quantitative monitoring of your stormwatcr discharge is being accomplished
according to permit requirements. Analytical monitoring for Total Nitrogen has not been
accomplished at all. Although analytical monitoring for other parameters, including one that is not
required by your permit, has been accomplished more frequently than is required, this demonstrates
a misinterpretation of analytical monitoring requirements. Additionally, not all required conditions
have been recorded during sampling events as required (Part II, Section B and Q.
In general, many of the above mentioned conditions and/or practices demonstrate mismanagement of
your stormwater program and/or a misunderstanding of the requirements as stated in your permit. The
most serious findings are as follows:

1 , Braswell Foods, Compliance EvAdWAM ion, January 12, 2006, NCS000302 ® Page 3 of 3
• The overall inadequacy of your SP3 and SPRP.
• The inadequacy of qualitative and quantitative discharge monitoring.
If you need assistance with understanding the analytical monitoring requirements in your permit, please
do not hesitate to contact Mr. Boone or Mr. Nisely. Furthermore, it may be helpful in future
inspections if you were to add a statement to your SP3 that you do not operate vehicle maintenance
activities that use 55-gallons or more of new motor vehicle oil per month. This would eliminate
evaluation of your compliance with Part fI, Section D or your permit.
Please be aware that all violations may result in the assessment of civil penalties in an amount of up to
$25,000 per day per violation. Please reply within 30 days of your receipt of this letter with a narrative
and your planned schedule to achieve compliance with all permit requirements. If you have any
questions or comments please contact Ron Boone at 919-791-4200.
Sincerely,
/_ 1
Kenneth Schuster, P.E.
Raleigh Regional Surface Water Quality Supervisor
cc: Stormwater Permitting Unit
Central Files
Non -Point Source Compliance Enforcement Unit