NCS000134_Fact sheet binder_20230816

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 8/14/2023
Permit Number NCS000134
Owner/Facility Name Avoca,LLC/Avoca Farms—Merry Hill
2833 (325411)/Medicinal Chemicals and Botanical
SIC(NAICS)Code/Category Products
2087 311930 (secondary SIC/NAICS
Basin Name/Sub-basin number Chowan/03-01-04
Receiving Stream/HUC UT to Salmon Creek/030102030705
Stream Classification/Stream Segment C;NSW/25-24
Is the stream impaired on 303 d list]? No
Any TMDLs? No
Any threatened and/or endangered species? Yes; See Section 2 below
Any compliance concerns? See Section 2 below
Any permit mods since lastpermit? See Section 1 below
New expiration date 8/31/2028
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The Avoca Farms—Merry Hill facility is a sage processing plant. The extracts are used in flavorings,
additives, fragrances, and dietary supplements. The facility performs agronomic operations and research,
chemical plant operations, and research and development. Per the facility's 2008 SWPPP, the plant is
classified as a RCRA Large Quantity Generator of hazardous waste related to the facility's
manufacturing operations. Clary sage material is stored in bags or a shed and all other botanical
materials are stored in supersacks or tankers/silos. All solvents are stored in tanks within bermed
enclosures. Outdoor activities consist primarily of raw material receiving, recycled waste storage, and
bulk material storage and processing.
The site previously had a manganese landfill. Per additional information provided 3/17/2023, the landfill
was established/used and closed by R.J. Reynolds Company prior to 2002. The land where the landfill
was located is no longer owned by Avoca/Ashland.
Per the information provided during the permit renewal, changes since the previous permit include:
• Building 1005-1 added January 2017 for expanded operation of Sclareol Recrystallization (SFG)
and Sclareolide. All tanks, vessels, materials, etc. are covered and surrounded by berms.
• #2 Diesel Fuel storage tanks previously enclosed by an earthen berm replaced by a single double
walled above ground storage tank.
Outfall SW001:
Drainage area consists of a warehouse, parts storage areas, manufacturing process buildings (process
controls for extraction, finished goods, infeed of botanical materials, botanical extraction,
recrystallization process of sclareol), WWTP, and a parking area. Potential pollutants include: finished
products, raw materials, hexane, heptane, ethyl acetate, ethanol, sclareol, raw botanical materials,
industrial wastewater, and wastewater chemicals.
Page 1 of 9

Outfall SWO03:
Drainage area consists of biomass boilers, cooling tower, diesel fuel tank, a conversion building (for
sclareolide production and recovery), sage processing, botanical extraction, extraction processes, sage
shed, chemical storage building, maintenance shop, and a parking area. Potential pollutants include:
cooling tower chemicals, wood chips, diesel fuel, chloroform, hexane, methanol, ethanol, ethyl acetate,
raw botanical materials, sage plant, and finished products.
Outfall SWO04:
Drainage area consists of a conversion building (for sclareolide production and recovery), boiler room,
material storage building, and undeveloped land. Potential pollutants include hexane, methanol, ethanol,
ethyl acetate, boiler chemicals, and hazardous waste storage.
Outfall SWO07:
Drainage area consists of an office building, research lab, greenhouse, small lab, and a parking area.
Potential pollutants include lab chemicals.
Outfall SWO08:
Drainage area consists of recrystallization process of sclareol. Potential pollutants include hexane,
heptane, ethyl acetate, and sclareol.
Additional Outfalls
Outfall SWO02:
Drainage area consists of driveways and grassy area. No industrial activity occurs in the drainage area.
Outfall 005:
Non-contact cooling water discharge covered under NPDES permit NCG500046 (previously
NC0003506).
Outfall SWO06:
Drainage area consists of a roof drain of a storage area. The pipe was filled in and closed in 2008.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
Page 2 of 9

material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• December 2015 to December 2022, benchmarks exceeded for:
0 001: pH min not reached 2x, COD exceeded 3x, TSS exceeded 6x, TP exceeded 3x
0 004: pH min not reached 2x
• August 2015 to January 2023 benchmarks exceeded for:
o 003: pH min not reached 1 Ix, COD exceeded 63x, TSS exceeded 20x, TN exceeded 3x,
TP exceeded 49x
• Monitoring for Total Recoverable Lead was required by the previous permit but sampling did not
begin until June 2020
o No benchmark exceedances between June 2020 and December 2022
• Outfall SW003 was in Tier II during previous permit cycle
• Last permit renewal granted ROS for:
o Outfall 001 is granted representative outfall status for Outfall 002
o Outfall 003 is granted representative outfall status for Outfalls 006 and 007
• Per the March 2023 inspection report:
o BMPs and monitoring activities appear to be in good order with the exception of SW003
o Expansion project in 2016 included a new building and concrete loading ramp. This
expansion area drains to an existing natural vegetated low area in close proximity to
SW002. This should be designated as a new outfall and evaluated for representative
outfall status (ROS)with SW001 and SW002.
■ Additional info provided 5/30/2023: Drainage areas 002 and 008 are similar by
activity and located in close proximity to each other. The building expansion
(drainage basin 008) drains by ditch to the natural vegetated low area; the same
area as 002, but a separate point source. Permittee indicated that 002 (the larger
drainage area)would be representative of 008. Permittee will submit request for
ROS after further evaluation and document in their SP3 plan.
o The sage receiving/storage building and surrounding area drains to SW003. This outfall
has consistently exceeded benchmark values for COD, TSS, pH, Total Nitrogen, and
Total Phosphorus. The primary BMP for this area is removal of spilled product and
sweeping; however, based on past exceedances of benchmark values, this BMP does not
appear to be sufficient. The facility should evaluate and consider additional BMPs for this
process area.
o Based on history of benchmark exceedances (more than 4 exceedances during the permit
cycle) the facility should continue monitoring under the Tier 3 response and provide a
written plan of action for SW003.
Threatened/Endangered Species:
There are endangered species in the vicinity of discharge, including Atlantic Sturgeon(Acipenser
oxyrinchus oxyrinchus;NC status: E; Federal status: E) and Shortnose Sturgeon(Acipenser
brevirostrum;NC status: E; Federal status: E). In the nearby vicinity, there are threatened species and
species of concern, including Eastern Pondmussel (Ligumia nasuta;NC status: T), Alewife Floater
Page 3 of 9

(Anodonta implicata; NC status: T), Timber Rattlesnake (Crotalus horridus; NC status: SC), and
Eastern Big-eared Bat(Corynorhinus rafinesquii macrotis;NC status: SC).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for December 2015 to December 2022. Quantitative sampling included pH, TSS, COD, total
recoverable lead, total nitrogen, and total phosphorus.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below are tables of the
proposed monitoring for each outfall at the Avoca Farms—Merry Hill site.
Outfall SWO01
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Total Phosphorus BASIS: Discharge potential indicator
Quarterly monitoring
Ethanol BASIS: Potential pollutant from drainage area
Page 4 of 9

Outfalls SWO03 and SWO04
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Total Phosphorus BASIS: Discharge potential indicator
Quarterly monitoring
Ethanol BASIS: Potential pollutant from drainage area
Quarterly monitoring
Methanol BASIS: Potential pollutant from drainage area
Outfalls SWO07 and SWO08
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BM? effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Total Rainfall Quarterly monitoring
BASIS: Discharge potential indicator
Page 5 of 9

Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Total Phosphorus BASIS: Discharge potential indicator
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
Page 6 of 9

benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
(SGT-HEM)
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation (40 CFR
133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Total Nitrogen 30 mg/L TKN +Nitrate+Nitrite Benchmarks (Expressed in mg/L of
N
Total Phosphorus 2 mg/L BPJ; Based on wastewater permit limits for NSW waters
Ethanol 3,900 mg/L I '/2 FAV
Methanol (Total) 6,400 mg/L Species Mean Acute Value of two 96-hour equilibrium EC50
endpoints for Lepomis machrochiris (bluegill)
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
Page 7 of 9

example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Changes from previous permit to draft:
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• Feasibility study requirement removed per updated stormwater program requirements
• eDMR requirement added
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Outfall-specific monitoring been implemented to reflect industrial activity and potential
pollutants specific to each discharge area
• BOD monitoring added for all outfalls due to industrial activities and materials stored onsite
• Ethanol monitoring added for outfalls SW001, SW003, and SWO04
• Methanol monitoring added for outfall SWO03 and SWO04
• Lead monitoring removed from outfalls SW001, SW003, SWO04, and SWO07
• Outfall SWO08 added based on information provided during permit renewal
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• None
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 3/7/2023
• Initial contact with Regional Office: 3/7/2023
Page 8 of 9

• Draft sent to CO peer review: 6/15/2023
• Draft sent to Regional Office: 6/30/2023
• Final permit sent for supervisor signature: 8/14/2023
Section 7. Comments received on draft permit:
• Maria Dunn(NCWRC; via email 7/31/2023): The permit looks to update existing allowances to
better ensure the exceedance of concerning parameters does not occur and that monitoring/
compliance of permit conditions is clarified. NCWRC has no specific comment other than an
appreciation of proposed permit modifications to better protect surface waters.
Page 9 of 9

Publisher's Certificate of Publication
STATE OF NORTH CAROLINA PUBLIC NOTICE
COUNTY OF HERTFORD NORTH NMENTCAROLINAL
ENVIRONMENTAL
MANAGEMENT COMMISSION
INTENT TO ISSUE
Ashley Vansant, being duly sworn, on oath says NPDES STORMWATER
he is and during all times herein stated has been DISCHARGE PERMITS
Publisher of Roanoke-Chowan Publications, Inc. The North Carolina
publisher and printer of the The Roanoke-Chowan Environmental Management
News-Herald (the"Newspaper"), has full knowledge Commission proposes to issue
of the facts herein stated as follows: NPDES stormwater discharge
permit(s)to the persons)listed
below. Public comment or
1. The Newspaper printed the copy of the matter objection to the draft permits
attached hereto (the"Notice") was copied from the is Invited. Written comments
columns of the Newspaper and was printed and regarding the proposed permit
published in the English language on the following will the
accepted until 30 days
P 99 after the publish date of this
days and dates: notice and considered in the
final determination regarding
07/08/23 permit issuance and permit
provisions. The Director of the
NC Division of Energy, Mineral,
2. The sum charged by the Newspaper for said and Land Resources (DEMLR)
publication is the actual lowest classified rate paid may hold a public hearing
b commercial customer for an advertisement of should there be a significant
de -a oublic re
similar size and frequency in the same newspaper Please mail commentsnand and/or
inin which the Notice was published. information requests to DEMLR
at 1612 Mail Service Center,
3. There are no agreements between the News- Raleigh,NC 27699-1612.
publisher, manager or printer and the officer -Avoca, , C 795[PO Box 129,
paper, P 9 P Merry Hill,NC 27957-0129f has
or attorney charged with the duty of placing the at- requested renewal of permit
tached legal advertising notice whereby any advan- NCS000134 for the Avoca
tage, gain or profit accrued to said officer or attorney Farms — Merry Hill in Bertie
County.This facility discharges
to an unnamed tributary to
Salmon Creek in the Chowan
River Basin. Interested persons 'n;r�
may visit DEMLR at 512 N.
Salisbury Street, Raleigh, NC
27604 to review information on /J(
file. Additional information on
NPDES permits and this notice )k)]7l.may be found on our webshe: R-SjoMjW
https://deq.nc.gov/about/ 2k?���gfam
f1�n
divisions/energy-mineral-and-
land-resources/stormwate r/
Ashley Vansant, Publisher s t o r m w a t e r-program/
stormwater-public-notices, or
Subscribed and sworn to before me this by contacting erianna Young at
brianna.vounara)deG.nc.gov or
8th Day of July, 2023 919-707-3647.
y�o ESKq�o Roanoke-Chowan:
Jul.8,2023
INTENT
�'11 �' .jrA^_^•,.t, p"' :'NOTARY'..m
'-`. PUBLIC i m
e
9T<ARGE'P
Mary Jo Eskridge, Notary Public
State of Alabama at Large
My commission expires 03-02-2026
Account#300317
Ad# 1672394
NC DEQ/DIVISION OF ENERGY
1612 MAIL SERVICE CENTER
RALEIGH NC 27699

Young, Brianna A
From: Dunn, Maria T.
Sent: Monday,July 31, 2023 8:38 AM
To: Young, Brianna A
Subject: RE: Draft NPDES stormwater permit NCS000134
Thank you Brianna for the opportunity to review and provide comment.
The permit looks to update existing allowances to better ensure the exceedance of concerning parameters does not
occur and that monitoring/compliance of permit conditions is clarified. NCWRC has no specific comment other than an
appreciation of proposed permit modifications to better protect surface waters.
Take care,
Maria
------------------------------
Maria T. Dunn
Coastal Coordinator
NC Wildlife Resources Commission
943 Washington Sq. Mall
Washington, NC 27889
252-495-5554
www.ncwildlife.org
Email correspondence to and from this sender is subject to the N.C.Public Records Law and may be disclosed to third parties.
From:Young, Brianna A<[e-mail]>
Sent: Friday,June 30, 2023 8:41 AM
To: Dunn, Maria T. <[e-mail]>
Subject: Draft NPDES stormwater permit NCS000134
Good morning,
Please find attached a copy of the draft NPDES stormwater permit for Avoca Farms—Merry Hill (NCS000134).This
facility discharges to an area with threatened and/or endangered species. Please provide any comments on the draft
permit by July 31, 2023.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
1

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

Young, Brianna A
From: Moore, Bill
Sent: Tuesday, May 30, 2023 2:24 PM
To: Young, Brianna A
Cc: Dumpor, Samir; Prakash, Varun
Subject: RE: Avoca Farms NCS000134 - Bertie County
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, May 30, 2023 11:57 AM
To: Moore, Bill<[e-mail]>
Cc: Dumpor, Samir<[e-mail]>; Prakash, Varun <[e-mail]>
Subject: RE:Avoca Farms NCS000134- Bertie County
Good afternoon,
I have a few questions from the inspection report.
1. The report states an expansion area drains to an existing natural vegetated low area in close proximity to SW002
and should be designated as a new outfall with ROS. Can you provide more information on this? Did you inform
the permittee?The drainage area does not go to any existing outfalls or sheet flow?
Drainage areas 002 &008 are similar by activity and located in close proximity to each other. The building
expansion (drainage basin 008) drains by ditch to the natural vegetated low area;the same area as 002, but a
separate point source. Brian indicated that 002 (the larger drainage area)would be representative of 008. They
will submit request for ROS after further evaluation and document in their SP3 plan. Yes, permittee informed &
agreed with assessment.
2. The report states the SW003 BMP does not appear to be sufficient and the facility should evaluate and consider
additional BMPs for this process area. Do you feel a BMP condition needs to be added to the permit, or is this
something the facility should just do on their own and keep a record of?
The additional BMPs for the 003 outfall were suggested during my inspection. By follow-up conversation, Brian
advised that the facility has already implemented some additional BMPs and waiting on information regarding
mechanical sweepers.
The implementation of the additional BMPs should be addressed in their Written Action Plan.
3. Outfall 006: Information provided to the Division previously states this outfall SW006 has been plugged, and the
permittee confirmed that today, but the inspection report seems to indicate the outfall is active. Is 006 an active
outfall?
The existing SDO 007 could be representative of SDO004&SDO005. SDO006 has been plugged for several
years. SP3 should be updated to reflect the current status of these outfalls.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
i

Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Moore, Bill<[e-mail]>
Sent: Friday, May 26, 2023 12:04 PM
To:Young, Brianna A<[e-mail]>
Cc: Dumpor, Samir<[e-mail]>; Prakash, Varun <[e-mail]>
Subject:Avoca Farms NCS000134- Bertie County
Hey Brianna,
Please see attached inspection report. We can discuss, let me know if you have questions.
Bill Moore, Environmental Engineer
Division of Energy, Mineral and Land Resources
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Phone: [phone]
D_ E 7,7 A-
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

Young, Brianna A
From: Brian Conner <[e-mail]>
Sent: Tuesday, May 30, 2023 11:26 AM
To: Young, Brianna A
Subject: RE: [External] RE: Avoca Farms— Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
No, Stormwater outfall 006 is not active. It has been plugged and is no longer an outfall.
Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, May 30, 2023 11:25 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
"""This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.—
Good morning Brian,
Is outfall SWO06 active? Information previously provided to the Division states the outfall was plugged, however,the
March 2023 inspection report from DEMLR staff indicates the outfall is operational. Please confirm the operational
status of outfall SW006.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
1

Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent:Tuesday, March 28, 2023 12:18 PM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
Thank you for this information. I will reach out with any other questions.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Monday, March 27, 2023 2:37 PM
To:Young, Brianna A<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Ms. Young,
Please see the attached updated files.
The "Stormwater Outfall Data" should now have all buildings,tanks, and cooling towers listed.The outfall table should
now have all buildings assigned to an outfall. Rainwater is routed to the intakes outlined on the map which then run to
the designated outfalls.
Also, during the on-site inspection that occurred last week(3/22/23) by NCDEQ representative Mr. Bill Moore we
determined that a newly installed drainage pipe south of building 1003-10 would be designated Outfall #008. Mr. Moore
agreed that this outfall is represented by outfall#001. Mr. Moore added this information to his map for updates.
We have been analyzing samples for Lead as required. I overlooked this in the attached spreadsheet due to lead not
having a listed Benchmark in Table 3 on page 7 of Permit No. NCS000134. I now have the past 3 years of lead data listed
2

in the spreadsheets.The lead data has been included on the monthly and semi-annual reports that we have submitted
to NCDEQ.
If you have any more questions, please do not hesitate to contact me.
Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent: Monday, March 27, 2023 10:06 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
"'This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.—
Good afternoon,
I have a few more follow-up questions.The map provided does not have the drainage areas outlined for each outfall.
The spreadsheet you provided has structures listed that are not included in the outfall table above it and there are
structures (buildings, storage tanks, and cooling towers) in the provided site map that are not included in the
spreadsheet. Please provide an updated site map that has drainage area boundaries identified and/or a list of all
structures and which drainage basin/outfall they belong to.
Additionally, monitoring for Total Recoverable Lead was required in the current permit, however, monitoring results for
this data was not provided. Please provide these results or an explanation for why total lead was not tested for.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, INC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
3

From:Young, Brianna A
Sent: Friday, March 17, 2023 3:20 PM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
Good afternoon,
Thank you for submitting this information. I will reach out with any questions once I have reviewed everything.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Friday, March 17, 2023 10:37 AM
To:Young, Brianna A<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Ms. Young,
Below are the answers to the recent questions you had concerning the Avoca LLC Stormwater Permit renewal:
• Please provide outfall coordinates for all outfalls in either degree or decimal format. The information previously
provided has an unusable format.
I have attached a spreadsheet titled "Avoca Stormwater Outfall Data"which has the coordinates of the
outfalls listed.
• Please provide information on when the landfill onsite closed.
The Manganese Landfill is not located on-site at Avoca.The landfill was established/used and closed by R.J.
Reynolds Company prior to me working at Avoca. It was located on property to the east of the current Avoca
site. I am not exactly sure of the year of closure as it was long before my time (pre-2002).The land where the
4

landfill was located is no longer owned by Avoca/Ashland. I believe it was sold to Rial Corporation in 2006 to
build a golf course. From what I understand that property has been sold several times since 2006.
• Please provide a site map that has each drainage area outlined with the outfall clearly identified.
Site map is attached.
• Please provide a list of chemicals currently stored onsite.
The attached spreadsheet titled "Avoca Stormwater Outfall Data" has the contents of each building listed. I
also attached a copy of the site's The main chemicals on site are: Hexane, Heptane, Ethanol, and Ethyl
acetate. I can send a copy of out Tier II Inventory report if needed.
• Please provide confirmation of which process buildings and activities are in which drainage areas.The
information previously provided does not specify(it just states process buildings).
The attached spreadsheet titled"Avoca Stormwater Outfall Data" has the buildings in each outfall area listed.
• Please provide more information on outfall SW006. Per information in our permit file history, outfall SWO03 was
previously granted Representative Outfall Status for SW006, but none of the information received to date
mentions this outfall.
I have attached a copy of the 2008 Stormwater Application Response letter that describes outfall#SW006.
Outfall SWO06 was a pipe roof drain that has been filled in and closed since 2008. 1 believe this closure may
have come as a recommendation from DEQ inspector Bill Moore
If there is any more information needed, please do not hesitate to contact me.
Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent:Thursday, March 16, 2023 12:32 PM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
"'This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.—
Good afternoon,
After reviewing all the information provided, I have some follow-up questions.
• Please provide outfall coordinates for all outfalls in either degree or decimal format. The information previously
provided has an unusable format.
• Please provide information on when the landfill onsite closed.
• Please provide a site map that has each drainage area outlined with the outfall clearly identified.
• Please provide a list of chemicals currently stored onsite.
• Please provide confirmation of which process buildings and activities are in which drainage areas.The
information previously provided does not specify(it just states process buildings).
5

• Please provide more information on outfall SW006. Per information in our permit file history, outfall SWO03 was
previously granted Representative Outfall Status for SW006, but none of the information received to date
mentions this outfall.
Please let me know if you have any questions on this request.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent:Tuesday, March 14, 2023 9:13 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
Brian,
Thank you for providing this information. I will reach out with any questions once I've had a chance to review
everything.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
6

Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Monday, March 13, 2023 2:14 PM
To:Young, Brianna A<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Dear NCDENR Representative:
Below is the information requested in an email received on March 7, 2023,from Brianna Young concerning the renewal
of Avoca LLC Stormwater Permit No. NCS000134. Most of this information was submitted in November 2019 when the
original permit renewal was due. However, a new permit was never issued, and the site has continued to operate under
the current/previous permit as instructed to do so by NCDEQ.
Please accept this information as requested to fulfill the requirements of the permit renewal process.
Site Name: Avoca LLC/Ashland LLC
Permit No: NCS000134
Address: 841 Avoca Farm Road
Merry Hill, NC 27957
SIC Code(s): 2833, 2087
NAICS Code(s): 325411, 311930
Industrial Activity:
The Avoca LLC site performs extractions of botanical (plant) materials.The extractions occur in a variety of equipment
and buildings on site using various solvents to extract specific ingredients or oils from plant materials.The extracts are
used in flavorings, additives,fragrances, and dietary supplements.The sage material is stored in bags or in sheds.All
other botanical materials arrive and are stored in supersacks or tankers/silos.All solvents are stored in tanks within
bermed enclosures.
Stormwater Outfall Information:
Outfalls (5):
001— N—826,792.838 E—2,676,440.763
Lat. =36.001940 Long. =-76.710280
Pipe with drains entering from driveways, parking, and process building roof tops.
002 - N—827,000.000 E—2,676,385.000

Trench/swale with draining driveway and lawn area.
003 - N—827,049.748 E—2,676,376.332
Pipe with drains entering from driveways, parking, and process building roof tops.
004- N—827,868.399 E—2,676,503.241
Pipe from boiler room roof drains.
007 - N—827,508.226 E—2,677,103.800
Pipe with drains entering from driveways, parking, and process building roof tops.
Monitoring Data:
A summary of all Analytical and Qualitative Analysis for each outfall is attached in spreadsheets.
Also, an updated list of the site's Best Management Practices (BMPs) is attached.
Operational Changes since renewal application dated 11/4/2019:
The only operational changes at the site since the submittal of the 2019 Permit Renewal application is with the No. 2
diesel fuel storage area.The 2 Diesel Fuel storage tanks previously enclosed by an earthen berm has now been replaced
by a single double walled above ground storage tank.
Delegation of Signature Authority:
The Stormwater Delegation of Signature Authority (DOSA) form is attached.This form was also submitted via the on-line
method and a hard copy was mailed to: NCDEMLR Stormwater Program, 1612 MSC, Raleigh, NC 27699-1612 as required.
eDMR Registration:
The registration for eDMR reporting was completed in December 2019. 1 have attached a copy of the information that
was submitted.
I have attached a copy of the original permit renewal documents that were submitted in November 2019 as well as the
updated information. I also mailed copies of this information. If there is more needed, please do not hesitate to contact
me.
Sincerely,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent: Friday, March 10, 2023 9:19 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
"""This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.—
Good morning,
8

Next week is fine. Thank you for the quick response.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Friday, March 10, 2023 8:21 AM
To:Young, Brianna A<[e-mail]>
Subject: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Ms. Young,
I am working to get this information updated. I should have it all to you early next week if that is OK?
Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, March 7, 2023 11:36 AM
To: Brian Conner<[e-mail]>
Subject:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
"'This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.—
Good morning,
9

The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000134.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action.
I am working on renewing the individual stormwater permit for the Avoca Farms—Merry Hill WWTP
(NCS000134). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity occurring onsite;
• Confirmation on the number of outfalls and associated coordinates;
• Description of industrial activity in each drainage area;
• SIC (NAICS) code;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility,contact information for the permit, and the regulated stormwater outfall(s)for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below,where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Geor og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePUment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
10

NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, INC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
,:,,, D E 'k�'�
kl ;
NORTH CAROLINA -
Department of Environmental quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
This e-mail contains information which may be privileged,confidential,proprietary,trade secret and/or otherwise legally protected. It is not intended for
transmission to,or receipt by,any unauthorized persons.If you are not the intended recipient,please do not distribute this e-mail.Instead,please delete this e-mail
from your system without copying it,and notify us that you received it in error,so that our address record can be corrected.If you are not the intended recipient
you are notified that disclosing,copying,distributing or taking any action in reliance on the contents of this information is strictly prohibited.No waiver of any
applicable privileges or legal protections is intended(and nothing herein shall constitute such a waiver),and all rights are reserved.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
11

Avoca,LLC
PO Sox 129
841 Avoca Farm Rd
IV Avoca, LLC Merry Hill,NC 27957
Phone: [phone]
The World's Premier Botanical Extraction Company Fax: [phone]
March 13, 2023
NCDENR RECEIVED
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) 24 201-3
1612 Mail Service Center
Raleigh, NC 27604 DENT R-Stormwater Program
Subject: Stormwater Permit No. NCS000134 Permit Renewal
Avoca LLC—Bertie County—North Carolina
Dear NCDENR Representative:
Below is the information requested in an email received on March 7, 2023, from Brianna Young
concerning the renewal of Avoca LLC Stormwater Permit No. NCS000134. Most of this information was
submitted in November 2019 when the original permit renewal was due. However, a new permit was
never issued, and the site has continued to operate under the current/previous permit as instructed to
do so by NCDEQ.
Please accept this information as requested to fulfill the requirements of the permit renewal process.
Site Name: Avoca LLC/Ashland LLC
Permit No: NC5000134
Address: 841 Avoca Farm Road
Merry Hill, NC 27957
SIC Code(s): 2833, 2087
NAICS Code(s): 325411, 311930
Industrial Activity:
The Avoca LLC site performs extractions of botanical (plant) materials.The extractions occur in a variety
of equipment and buildings on site using various solvents to extract specific ingredients or oils from
plant materials.The extracts are used in flavorings, additives, fragrances, and dietary supplements.The
sage material is stored in bags or in sheds. All other botanical materials arrive and are stored in
supersacks or tankers/silos. All solvents are stored in tanks within bermed enclosures.

Stormwater Outfall Information:
Outfalls(5):
001— N—826,792.838 E—2,676,440.763
Lat.=36.001940 Long._-76.710280
Pipe with drains entering from driveways, parking, and process building roof tops.
002- N—827,000.000 E—2,676,385.000
Trench/swale with draining driveway and lawn area.
003 - N—827,049.748 E—2,676,376.332
Pipe with drains entering from driveways, parking,and process building roof tops.
004- N—827,868.399 E—2,676,503.241
Pipe from boiler room roof drains.
007- N—827,508.226 E—2,677,103.800
Pipe with drains entering from driveways, parking, and process building roof tops.
Monitoring Data:
A summary of all Analytical and Qualitative Analysis for each outfall is attached in spreadsheets.
Also, an updated list of the site's Best Management Practices(BMPs) is attached.
Operational Changes since renewal application dated 11/4/2019:
The only operational changes at the site since the submittal of the 2019 Permit Renewal application is
with the No. 2 diesel fuel storage area.The 2 Diesel Fuel storage tanks previously enclosed by an
earthen berm has now been replaced by a single double walled above ground storage tank.
Delegation of Signature Authority:
The Stormwater Delegation of Signature Authority(DOSA) form is attached.This form was also
submitted via the on-line method and a hard copy was mailed to: NCDEMLR Stormwater Program, 1612
MSC, Raleigh, NC 27699-1612 as required.
eDMR Registration:
The registration for eDMR reporting was completed in December 2019. 1 have attached a copy of the
information that was submitted.

I have attached a copy of the original permit renewal documents that were submitted in November
2019 as well as the updated information. If there is more needed, please do not hesitate to contact me.
Sincerely,
Akc�V l.O�l
ly��
Brian Conner
EHS Manager
Avoca LLC

EQ� NPDES Storm water Permit Contact Update
Request
NPDES Permit Enter your NPDES stormwater permit number or Certificate of Coverage(COC)number.
Number* NCS000134
Begins with NCS,NCG,or NCGNE(no exposure)
Facility Name* Avoca LLC
(Used to verify permit number)
Check permit contact information for your permit by running a Stormwater Permit Summary Report.
Guidance for COC holders: Do not enter the General Permit number with all 0's (for example, NCG030000) but
instead your Certificate of Coverge (COC) number.
Check all that Owner Affiliation (Legally Responsible Individual) Update
apply,* ( Permit Ownership Transfer or Facility Name Change
Delegation of Signature Authority (DOSA)
>; Permit Contact Update
Billing Contact Update
Facility Contact Update
I Other Contact Update
Permit Contact Update
Provide new permit contact information
* This person should REPLACE the current permit contact.
This person should just be added as another permit contact.
New Contact Name* First and Last Name
Brian M. Conner
E-mail Address* [e-mail]
Phone No.* 1-252-482-2133
Mailing Address* PO Box 129
Merry Hill, NC 27957

Physical Address If different than mailing address
841 Avoca Farm Road
Merry Hill, NC 27957
Add another permit contact if needed by clicking the'Add'button below
Billing Contact Update
Provide new billing contact information
Note: This person will REPLACE the current billing contact.We can only designate one billing contact in our
permitting database.
New Contact Name* First and Last Name
Brian M. Conner
E-mail Address* [e-mail]
Phone No.* 1-252-482-2133
Mailing Address* PO Box 129
Merry Hill, NC 27957
Physical Address If different than mailing address
841 Avoca Farm Road
Merry Hill, NC 27957
Facility Contact Update
Provide new facility contact information
* This person should REPLACE the current facility contact.
This person should just be added as another facility contact.
New Contact Name* First and Last Name
Brian M. Conner
E-mail Address* [e-mail]
Phone No.* 1-252-482-2133
Mailing Address* PO Box 129
Merry Hill, NC 27957

Physical Address If different than mailing address
841 Avoca Farm Road
Merry Hill, NC 27957
Add another facility contact if needed by clicking the'Add'button below
Person(s) with Delegation of Signature Authority (DOSA)
Complete and sign this Stormwater Permit Delegation of Signature Authority Form.Then upload it below. We can
begin making updates with this submittal, but please note that you must mail in the original signed copy to our
office in accordance with requirements in 40 CFR 122.22.
Mail the hard copy to: DEMLR Stormwater Program (Attn: Stormwater Program Administrative Specialist), 1612
MSC, Raleigh, NC 27699-1612
Delegation of Please upload the signed"Stormwater Permit Delegation of Signature Authority Form"
Signature Authority* Avoca LLC Stormwater DOSA Form.pdf 626.77KB
pdf only
Submitter's Name* Please enter your FIRST and LAST name
Brian M. Conner
Phone Number* Please enter your phone number
252-482-2133
Any format is fine.
Email Address* Please enter a valid e-mail address
[e-mail]
A confirmation of submission will be e-mailed to this address.
* By checking the box and signing below, I certify that:
I have given true, accurate, and complete information on this form;
I agree that submission of this form is a "transaction" subject to Chapter 66,Article 40 of the NC General Statutes (the
"Uniform Electronic Transactions Act");
I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes
(the "Uniform Electronic Transactions Act");
I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written
signature (except for any uploaded Owner Affiliation Change or Delegation of Signature of Authority forms, which
also must be mailed in with original signature);AND
I intend to electronically sign and submit this Permit Contact Update Request form.

Signature*
Date 3/13/2023
Questions? Contact [e-mail].

Avoca, LLC Storm Water Analytical Monitoring Results
Permit No.NC5000134
Outfall#:001
Sample Date Total Flow Total Rainfall pH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
12/22/2015 0.052 0.7 7.68 65.0 127.0 14.40 2.78
6/23/2016 0.155 2.1 7.17 51.0 142.0 2.77 0.51
12/19/2016 0.088 1.2 7.14 86.0 23.0 3.31 0.86
6/20/2017 0.096 1.3 6.79 49.0 41.0 2.31 0.77
1/23/2018 0.015 0.2 7.64 496.0 125.0 12.40 4.02
1/4/2019 0.022 0.3 7.S1 142.0 105.0 1.90 0.56
7/23/2019 0.273 3.7 4.97 61.0 123.0 4.45 0.70
6/16/2020 0.111 1.5 7.50 47.0 28.0 3.04 1.26
12/14/2020 0.088 1.2 6.08 240.0 302.0 5.25 2.91
6/21/2021 0.184 2.5 6.76 56.0 16.0 1.74 0.39
12/30/2021 0.022 0.3 5.18 40.0 19.0 2.06 0.39
7/31/2022 0.066 0.9 6.96 44.0 23.0 1.35 0.47
12/15/2022 0.074 1 7.40 26.0 36.0 0.74 0.32
Average 0.096 1.3 6.83 107.9 1 85.4 4.29 1.23

Avoca, LLC Storm Water Analytical Monitoring Results
Permit No.NCS000134
Outfall#:003
Sample Date Total Flow Total Rainfall pH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
8/8/2015 0.046 0.7 8.59 64.0 3.6 4.73 0.65
8/31/2015 0.039 0.6 6.73 725.0 36.0 1 17.35 6.74
9/25/2015 0.117 1.8 4.47 4228.0 68.0 23.73 7.68
10/28/2015 0.033 0.5 6.96 318.0 18.0 1.72 1.04
11/19/2015 0.078 1.2 6.63 498.0 134.0 11.22 2.86
12/25/2015 0.046 0.7 6.62 1149.0 90.0 43.66 5.98
2/4/2016 0.143 2.2 6.85 344.0 102.0 5.53 1.59
2/16/2016 0.072 1.1 7.03 217.0 273.0 5.76 1.31
3/28/2019 0.091 1.4 7.60 271.0 19.0 6.17 2.10
5/3/2016 0.052 0.8 7.09 218.0 57.0 6.10 1 1.56
6/7/2016 0.078 1.2 7.02 196.0 169.0 5.21 1.24
6/23/2016 0.137 2.1 7.14 340.0 233.0 5.15 1.44
7/19/2016 0.065 1 6.73 206.0 9.7 7.54 0.94
8/8/2016 0.13 2 7.74 95.0 77.0 1.75 0.67
9/19/2016 0.072 1.1 8.01 2800.0 49.0 3.94 1 0.71
11/4/2016 0.052 0.8 6.58 240.0 19.0 6.45 2.70
11/14/2016 0.02 0.3 6.91 482.0 34.0 12.25 0.98
12/19/2016 0.078 1.2 6.81 95.0 28.0 8.79 2.03
1/23/2017 0.039 0.6 6.93 171.0 21.0 3.81 2.47
2/8/2017 0.039 0.6 7.16 1770.0 353.0 35.80 12.76
3/31/2017 0.091 1.4 6.71 1080.0 153.0 18.36 20.46
4/24/2017 0.15 2.3 6.51 59.0 5.2 7.67 0.64
5/23/2017 0.111 1.7 6.61 250.0 7.4 5.23 2.60
6/20/2017 0.085 1.3 6.62 251.0 48.0 6.41 2.24
7/17/2017 0.098 1.5 7.10 276.0 57.0 6.52 2.63
8/8/2017 0.052 0.8 7.54 168.0 20.0 4.76 15.48
10/10/2017 0.033 0.5 6.93 957.0 59.0 19.72 8.76
10/29/2017 0.072 1.1 7.81 328.0 19.0 7.15 4.02
12/6/2017 0.023 0.35 7.70 522.0 115.0 15.86 4.58
1/23/2018 0.013 0.2 7.71 351.0 101.0 8.51 2.88
1/23/2018 0.013 0.2 7.71 324.0 100.0 10.57 2.92
2/28/2019 0.033 0.5 7.64 266.0 48.0 9.16 5.44
3/12/2018 0.065 1 7.13 283.0 42.0 6.00 3.35
4/24/2018 0.085 1.3 7.06 217.0 14.0 5.31 1.95
5/18/2018 0.039 0.6 7.07 515.0 46.0 6.13 5.55
9/15/2018 0.137 2.1 7.60 26.0 6.9 1.09 0.25
9/16/2018 0.13 2 7.52 28.0 6.1 1.08 0.25
10/11/2018 0.065 1 6.99 442.0 26.0 14.86 5.58
11/15/2018 0.065 1 7.51 462.0 133.0 12.14 3.40
1/4/2019 0.02 0.3 7.46 61.0 58.0 3.07 1.54
2/11/2019 0.065 1 7.42 595.0 83.0 16.94 6.21
2/11/2019 0.065 1 7.42 701.0 93.0 16.69 5.91
3/26/2019 0.033 0.5 6.67 41.0 17.0 3.03 0.38
4/9/2019 0.15 2.3 8.24 179.0 18.0 7.05 2.57
6/5/2019 0.039 0.6 7.65 392.0 1 45.0 11.05 2.28

Sample Date Total Flow Total Rainfall pH COD TSS Total phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
7/23/2019 0.241 3.7 5.10 276.0 48.0 8.05 1.85
2/7/2020 0.265 3.6 7.01 188.0 393.0 1 6.65 0.02
2/19/2020 0.022 0.3 6.10 94.0 25.0 5.06 1.00
3/23/2020 0.066 0.9 7.21 211.0 35.0 13.06 2.64
4/13/2020 0.033 0.5 6.48 305.0 95.0 8.10 3.02
5/19/2020 0.033 0.5 8.47 334.0 63.0 7.25 1 3.52
6/16/2020 0.098 1.5 7.22 1290.0 349.0 19.99 11.06
8/10/2020 0.039 0.6 5.74 823.0 206.0 12.45 5.20
9/9/2020 0.078 1.2 7.51 455.0 44.0 14.47 5.40
9/29/2020 0.104 1.6 4.72 1260.0 136.0 21.46 8.90
10/30/2020 0.013 0.2 7.10 61.0 62.0 3.50 0.75
11/11/2020 0.339 5.2 4.54 1210.0 318.0 29.68 6.34
12/14/2020 0.078 1.2 6.21 437.0 40.0 13.22 4.72
1/31/2021 0.085 1.3 6.22 163.0 15.0 6.88 1.92
2/18/2021 0.111 1.7 7.15 465.0 54.0 8.52 3.08
3/16/2021 0.065 1 7.66 356.0 55.0 12.61 2.76
5/30/2021 0.156 2.4 4.82 247.0 46.0 6.93 2.94
5/31/2021 0.156 2.4 4.82 247.0 46.0 6.93 2.94
6/21/2021 0.163 2.5 7.68 307.0 48.0 7.47 2.78
7/19/2021 0.052 0.8 4.71 756.0 32.0 12.76 4.55
9/22/2021 0.02 0.3 7.17 134.0 114.0 3.86 0.80
9/23/2021 0.02 0.3 7.95 165.0 298.0 5.74 1.02
10/29/2021 0.013 0.2 5.03 5.1 74.0 9.44 4.63
11/22/2021 0.033 0.5 8.02 594.0 61.0 14.14 6.73
12/30/2021 0.02 0.3 5.12 42.0 17.0 1.45 0.36
2/24/2022 0.007 0.1 6.10 507.0 21.0 7.62 3.25
3/9/2022 0.078 1.2 4.08 441.0 24.0 11.38 5.13
4/18/2022 0.072 1.1 7.69 1360.0 225.0 14.77 7.12
5/13/2022 0.059 0.9 8.37 894.0 474.0 40.00 3.26
7/31/2022 0.059 0.9 7.01 63.0 18.0 2.64 0.88
7/31/2022 0.059 0.9 7.01 63.0 19.0 2.64 0.78
8/16/2022 0.046 0.7 7.23 105.0 14.0 3.29 0.76
9/30/2022 0.411 6.3 6.49 36.0 19.0 1.17 0.39
11/1/2022 0.039 0.6 6.45 34.0 25.0 1.98 0.28
11/30/2022 0.039 0.6 7.81 88.0 37.0 4.50 0.58
12/15/2022 0.065 1 7.20 <20 12.0 0.74 0.36
1/22/2023 0.059 0.9 6.27 35.0 3.9 13.38 0.59
Average 0.08 1.20 6.87 459.9 81.5 9.81 3.43

Avoca, LLC Storm Water Analytical Monitoring Results
Permit No.NCS000134
Outfall#:004
Sample Date Total Flow Total Rainfall pH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
12/22/2015 0.013 0.7 6.64 <20 <2.8 0.57 <0.04
6/23/2016 0.039 2.1 6.82 <20 6.80 1 0.72 0.07
12/19/2016 0.022 1.2 7.02 <20 <2.7 0.15 0.18
6/20/2017 0.024 1.3 6.95 20.00 <2.6 0.52 0.08
1/23/2018 0.004 0.2 7.76 24.00 <3.1 1.57 0.14
1/4/2019 0.006 0.3 7.39 <20 <2.6 <0.51 0.06
7/23/2019 0.069 3.7 4.87 24.00 12.00 1.90 0.10
6/16/2020 0.028 1.5 7.91 <20 <2.6 0.47 0.08
12/14/2020 0.022 1.2 6.52 <20 <2.6 0.07 0.14
6/21/2021 0.047 2.5 7.14 <20 <2.6 0.42 1 0.15
12/30/2021 0.006 0.3 5.18 40.00 19.00 2.06 0.39
7/31/2022 0.017 0.9 7.23 <20 <2.5 0.78 0.12
12/15/2022 0.019 1 6.70 <20 4.50 0.16 0.13
Average 0.684 0.700 1 0.991 #VALUEI #VALUEI 3.563 #VALUEI

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 001
The scale for Clarity, Floating Solids,and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating SuspendedSolids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 Light BrownNone 3 2 2 No No No
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Light None 2 2 1 No No No
Brown
7/23/2019 Light Gray None 2 2 1 No No No
6/16/2020 Clear None 1 2 1 No No No
12/14/2020 Clear None 2 1 1 No No No
6/21/2021 Lightbrown None 2 1 1 No No No
12/30/2021 Clear None 1 1 1 No No No
7/31/2022 Light None 1 1 1 No No No
Brown
12/15/2022 Clear None 1 1 1 No No No

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 002
The scale for Clarity, Floating Solids,and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Floating Suspended
"Samplee Color Odor Clarity Solids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 LightNone 1 1 1 No No No
Brown
6/23/2016 Light None 1 1 1 No No No
Brown
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 2 1 No No No
6/16/2020 Clear None 1 1 1 No No No
12/14/2020 Clear None 1 1 1 No No No
6/21/2021 Clear None 1 2 1 No No No
12/30/2021 Clear None 1 2 1 No No No
7/31/2022 Clear None 1 2 1 No No No
12/15/2022 Clear None 1 1 2 1 1 No No No

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 003
The scale for Clarity, Floating Solids,and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating Suspended Foam? Oil Sheen? Erosion?
Solids Solids
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
8/8/2015 Gray None 3 2 2 No No No
8/31/2015 Light None 2 1 1 No No No
Brown
9/25/2015 Light Gray None 2 2 1 No No No
10/28/2015 Light None 2 1 1 No No No
Brown
11/19/2015 Light Gray None 2 1 1 No No No
12/25/2015 Gray None 3 2 2 No No No
2/4/2016 Light Gray None 2 2 1 No No No
2/16/2016 Light Gray None 2 2 1 No No No
3/28/2019 Light Gray None 2 2 1 No No No
5/3/2016 Light Gray None 2 2 1 No No No
6/7/2016 Light Gray None 2 2 1 No No No
6/23/2016 LightBrown None 2 2 1 No No No
7/19/2016 LightBrown None 1 1 1 No No No
8/8/2016 Clear None 1 2 2 No No No
9/19/2016 Clear None 1 1 1 No No No
11/4/2016 Light Gray None 1 1 1 No No No
11/14/2016 Light Gray None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
1/23/2017 Light Gray None 1 1 1 No No No
2/8/2017 Gray None 3 1 1 No No No
3/31/2017 Light Gray None 2 2 1 No No No
4/24/2017 Clear None 1 1 1 No No No
5/23/2017 Clear None 1 1 1 No No No

"Sample Floating Suspended e Color Odor Clarity Solids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
Light
6/20/2017 Brown None 2 2 2 No No No
7/17/2017 Light None 3 1 2 No No No
Brown
Light
8/8/2017 Brown None 2 3 1 No No No
10/10/2017 LightBrown None 2 1 1 No No No
10/29/2017 Clear None 1 1 1 No No No
12/6/2017 Brown None 4 1 4 No No No
1/23/2018 LightBrown None 2 1 1 No No No
1/23/2018 LightBrown None 2 1 1 No No No
2/28/2018 LightBrown None 2 2 1 No No No
3/12/2018 Clear None 2 1 1 No No No
4/24/2018 Clear None 1 1 1 No No No
5/18/2018 LightBrown None 2 1 1 No No No
9/15/2018 Light Gray None 2 2 2 No No No
9/16/2018 Clear None 1 1 1 No No No
10/11/2018 LightBrown None 2 2 2 No No No
11/15/2018 Light Gray None 2 2 2 No No No
1/4/2019 Clear None 1 2 1 No No No
2/11/2019 LightBrown None 2 1 1 No No No
2/11/2019 LightBrown None 2 1 1 No No No
3/26/2019 Light Gray None 2 1 1 No No No
4/9/2019 LightBrown None 2 1 1 No No No
6/5/2019 LightBrown None 2 3 2 No No No
7/23/2019 Light Gray None 2 2 2 No No No
7/23/2019 Light Gray None 2 2 2 No No No
2/7/2020 Light Gray None 2 2 2 No No No

"Sample Floating Suspended e Color Odor Clarity Solids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
2/19/2020 Clear No 1 1 1 No No No
3/23/2020 Clear None 1 1 1 No No No
4/13/2020 Light Grey None 1 2 1 No No No
5/19/2020 Light Grey None 2 1 1 No No No
6/16/2020 Clear None 1 2 1 No No No
8/10/2020 Lightbrown None 2 3 2 No No No
9/9/2020 Lightbrown None 2 1 1 No No No
9/29/2020 Light grey None 2 1 1 No No No
10/30/2020 Light grey None 2 1 1 No No No
11/11/2020 Light grey None 2 2 2 No No No
12/14/2020 Clear None 2 1 1 No No No
1/31/2021 Clear None 1 1 1 No No No
2/18/2021 Clear None 1 1 1 No No No
3/16/2021 Clear None 1 1 1 No No No
5/30/2021 Clear None 1 2 1 No No No
5/31/2021 Clear None 1 2 1 No No No
6/21/2021 Lightbrown None 2 1 1 No No No
7/19/2021 Light brown None 2 1 1 No No No
9/22/2021 Clear None 1 2 1 No No No
9/23/2021 Clear None 1 2 1 No No No
10/29/2021 Clear None 1 1 1 No No No
11/22/2021 Clear None 1 1 1 No No No
12/30/2021 Clear None 1 2 1 No No No
2/24/2022 Lightbrown None 2 1 1 No No No
3/9/2022 Lightbrown None 2 1 1 No No No
4/18/2022 Lightbrown None 2 1 1 No No No
5/13/2022 Light Gray None 2 2 1 No No No
7/31/2022 Clear None 1 1 1 No No No
8/16/2022 Clear None 1 1 1 No No No
9/30/2022 Clear None 1 1 1 No No No
11/1/2022 Clear None 1 1 1 No No No
11/30/2022 Clear None 1 1 1 No No No
12/15/2022 Clear None 1 1 1 No No No
1/22/2023 1 Clear None 1 1 1 No No No

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 004
The scale for Clarity, Floating Solids,and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Floating Suspended
"Samplee Color Odor Clarity Solids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 Clear None 1 1 1 No No No
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 1 1 No No No
6/16/2020 Clear None 1 1 1 No No No
12/14/2020 Clear None 1 1 1 No No No
6/21/2021 Clear None 1 1 1 No No No
12/30/2021 Clear None 1 1 1 No No No
7/31/2022 Clear None 1 1 1 No No No
12/15/2022 1 Clear I None 1 1 1 No No No

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 007
The scale for Clarity, Floating Solids,and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Floating Suspended
"Samplee Color Odor Clarity Solids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 Clear None 2 1 1 No No No
6/23/2016 Clear None 2 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 2 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Light Gray None 2 2 1 No No No
6/16/2020 Light Gray None 2 2 1 No No No
12/14/2020 Clear None 1 1 1 No No No
6/21/2021 Clear None 1 1 1 No No No
12/30/2021 Clear None 1 1 1 No No No
7/31/2022 Clear None 1 1 1 No No No
12/15/2022 1 Clear None 1 1 1 No No No

BEST MANAGEMENT PRACTICES (BMPs)
AVOCA, LLC
Stormwater Permit No. NCS000134
BMP 1 - Containment Berms: Avoca, LLC has spill containment berms installed
around each of its fuel, solvent, and other processing tanks. These berms are large enough
to hold the total capacity of at least one of the contained tanks plus a minimum of 10%.
The following is a listing of the containment areas and their locations:
1) No. 2 Fuel Oil Storage and Unloading, West of Building 1001-2
2) Gasoline Storage and Unloading,North of Building 1004-2
3) Emergency Generator Fuel Storage, South of Building 1004-1
4) Emergency Generator Fuel Storage, South of Building 1001-1
5) Hazardous Waste Storage, Building 1003-5
6) Tank Farm, North of Building 1001-1
7) Tank Farm, South of Building 1001-1
S) Unloading Station, South of Building 1001-2
9) Sclareol Recrystallization& Storage tanks,Building 1003-10
10)Chemical Storage, 1003-7
11) Botanical Extraction Process & Storage tanks,North of Building 1001-11
12) Biomass Extraction Process & Storage tanks, Building 1004-2
13)Sclareolide and Sclareol Recrystallization Process& Storage tanks,Building
1005-1
BMP 2 -Weekly monitoring of all areas listed in BMP 1: Monitoring includes
inspection of equipment and tanks within containments as well as all areas of the facility.
The operational status of the processes, housekeeping and cleanliness, condition of
equipment and tanks, and notification of spills and leaks are noted as well as any
corrective actions taken.
BMP 3 -Annual monitoring of the areas listed in BMP 1: Monitoring includes in
depth inspection of equipment and tanks within containments as well as all areas of the
facility. Parameters of inspection include: housekeeping and cleanliness, operating
condition of equipment, evidence of spills and/or leaks, stormwater conveyance (i.e.
condition of valves, flow channels, etc...), erosion evidence, actions required to remedy
any problems, and the date the problem was resolved.
BMP 4 -Monitor berm contents: Avoca, LLC keeps its spill containment berm drains
closed and locked. All pumps and valves are capped when not in use. The berms are
either drained by the boiler operator or pumped to Avoca's Tertiary Lagoon. All rain
water is inspected before it is drained to determine if there it has oil sheen or other

contaminates. In the case of a spill, the berms can be pumped out with a suction tanker or
either directly pumped to Avoca's Waste Water Treatment facility. The spilled liquid can
be either treated and disposed of or reused.
BMP 5 -Hazardous waste storage: All hazardous waste is stored in a concrete dike area
with a protective roof covering the containment. There are signs stating that Hazardous
waste is to be stored in this area only.
BMP 6 -Analytical Monitoring: Analytical monitoring of stormwater runoff is
performed as stated in Stormwater Permit No.NCS000134. Analytical monitoring of
outfalls #001, #003, and#004 is performed quarterly and outfall #003 is monitored
monthly. The temperature and pH are recorded at the time of sampling. The samples are
put on ice and sent to Environment 1 located in Greenville, NC where they are analyzed
for Nitrogen, Phosphorous, Total Suspended Solids, COD, and pH. The analytical
monitoring results are kept at Avoca, LLC and sent to NCDENR within 30 days of
receiving the results from Environment 1.
BMP 7- Qualitative Monitoring: Qualitative monitoring of Stormwater Runoff is
performed as stated in Stormwater Permit No.NCS000134. Qualitative monitoring of
outfalls#001,#002,#003, #004, and#007 is performed twice annually. Outfall #005 is
not monitored under the stormwater permit as it is covered under a separate NPDES
permit. The qualitative results are kept on file at Avoca, LLC.
BMP 8 -Training: Training of all Avoca, LLC personnel occurs annually. Employees
are trained in the safe handling of chemicals, spill prevention of chemicals, location of
shutoff valves, who to contact in case of a spill, location of containment equipment, and
operation and maintenance of containment equipment.
BMP 9—Spill Clean-Up: Hazardous waste clean-up and major Spills are handled be an
outside contractor. AVOCA, LLC has a contract with Eastern Environmental
Management, located in Rocky Mount, NC to handle all it's major spill incidents.
BMP 10—Covered Waste: All waste drums for scrap metal are to be covered until the
drums are inspected to be empty. Drums are then crushed and placed in the metal
recycling bins for recycling. All other waste materials are disposed of in waste containers
that have roofs or are staged under a covering.

c�0STAR
�C,(�
ROY COOPER
Governor
ELIZABETH S.BISER .W
Secretary aaiwvnm
DOUGLAS R.ANSEL NORTH CAROLINA
Interim Director Environmental Quality
Stormwater Delegation of Signature Authority Form (DDSA)
This form shall be used to delegate signature authority from the permit Owner (Permittee) to
another party. Only the Responsible Official defined below may submit permit applications and
reports required by the permit (such as Data Monitoring Reports and Annual Reports) until this
form is completed and submitted to the DEMLR Stormwater Program. Please note that delegating
signature authority does not relieve the Permit Owner from the responsibility and compliance for
permit compliance.
Permit Owner:The legal entity to which/whom a permit has been issued and may be an individual
or an organization such as a company or government agency. Every Owner is required to have a
Responsible Official who meets the legal signature authority requirements in 40 CFR 122.22,
summarized below:
• For a corporation,the Responsible Official shall be a president,secretary,treasurer,or vice president
in charge of a principal business function,or another individual who performs similar functions for
the corporation,or the manager of one or more manufacturing,production,or operating facilities
who is authorized to make management decisions about the facility operation.
• For a partnership or sole proprietorship,the Responsible Official shall be a general partner or the
proprietor,respectively;or
• For a municipality,State,Federal,or other public agency,the Responsible Official shall be eithera
principal executive officer[City/County Manager] orranking elected official[Mayor].
Please mail the DDSA Form with original wet signatures to: NCDEMLR Stormwater
Program, 1612 MSC,Raleigh, NC 27699-1612
Name of Organizational Entity AV OC,, LLC
Responsible Official Name
en
Responsible Official Title:
Email Address: C�uuS � �� @ � Phone 252^ 2 2%33
Mailing Address PD goy %261
City State Zip code 219 S-7
D QNorth.,. Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh,North Carolina 27699-1612
wxnFi r w
Nif-1711 914.707.9200

A. Persons to Receive Signature Authority
The signatures of the persons listed below indicates their acceptance of signatory authority.
Attach additional pages if you need more space.
Delegated Party Name v, , M. Cor,,,c,r
Delegated Party Title E kS ntna ems'
Permit Numbers) N G S 00 019 Lf
Email Address: 1p,%,a�- CO r1�1Cv °l 0.5 h(t�.�c(•c. Phone
MailingAddress PO $ax 129
city NI F-1:11 State �L Zip code 2-jc_S-7
Signature of Delegated Party
indicating acceptance of
Signatory Authority:
Date ?� I'JJ Zflz3
Delegated Party Name
Delegated Party Title
Permit Number(s)
Email Address: Phone
Mailing Address
city State Zip code
Signature of Delegated Party
indicating acceptance of
Signatory Authority:
Date
Delegated Party Name
Delegated Party Title
Permit Number(s)
Email Address: Phone
Mailing Address
city State Zip code
Signature of Delegated Party
indicating acceptance of
Signatory Authority:
Date
Stormwater Permit Delegation of Signatory Authority Form
Page 2

B. Responsible Official Signature
The Responsible Official, as identified in accordance with 40 CFR 122.22, is the appropriate
individual with the authority to sign and submit reports for the organization.
As the Responsible Official,I, �.��,�s-����5 Gfe'v ASUI (printed name),
have the authorityto enter into this Agreement for
PW0C0 �_L (Owner/Organization Name).
I requestthat the DEMLR Stormwater Program include the persons listed in Part A of this
form signatory authority for the above-named permit.
I acknowledge that I,and the persons listed in Part A of this form work at/for my
organization and have authorityto act as a signatory for purposes of the NCDEQ's
electronic document systems.
By submitting this application,I,jti�%yvac Ge"Asa44 (printed name),have read,
understand,and accept the terms and conditions of the stormwater permit(s)for which I
am the Responsible Official.
Responsible ic' Signature
V<5.."Acsnk 3 - 13-2Q 3
Title Date
Stormwater Permit Delegation of Signatory Authority Form
Page 3

Avoca,LLC
LLC
PO Box 129
Avoca, L LC 841 Avoca Farm Rd
Merry Hill,NC 27957
The World's Premier Botanical Extraction Company Phone:
2133:252-482-
I
February 21, 2020
RE:Delegation of Signatory Authority for Environmental, Health,&Safety Reports and Documents !
I
To Whom it may Concern:
i
I
As President of Avoca LLC, I duly authorize the ENS Manager of Avoca LLC to sign,certify,and submit all
reports,applications, notifications,and other documents associated with the below referenced permits
and reports for the 3 Avoca sites located at Merry Hill, NC,Summerville, SC,and Menomonee Falls,WI:
Air Quality—Annual Compliance Certifications,SARA 313 R Annual Reports,Annual Emissions Inventory
Reports,Semi-Annual Reports,Semi-Annual MON Reports,Semi-Annual Boiler Reports, Periodic
Equipment CEDRI Reports
BATF—Annual Alcohol User Report
EPA—Annual Pesticide Producer Report i
i
Wastewater Treatment—Monthly Reports,Quarterly Groundwater Monitoring Reports,Annual Lab
Certification
Stormwater—Monthly Reports,Quarterly Reports
Hazardous Waste—Biennial Hazardous Waste Report
Tier If-Annual Report
OSHA—Annual 300 Log
Our current EHS Manager is Brian Conner,who can be contacted with any questions at(252)482-2133.
Sincerely,
Augustinus Gerritsen
President
Avoca LLC

eDMR Owner Verification Report
Permit No. : NCS000134 Version: 3.00 Permt Status: Expired
Owner/Permittee : Avoca LLC
Owner/Permittee PO Box 129
Address: Merry Hill, NC 279570129
Responsible Official: Augustinus Gerritsen
Resp. Official Title: VP
Facility Name : Avoca - Merry Hill WWTP
Facility Address: 841 Avoca Farm Rd
Merry Hill, NC 27957
Registered for eDMR? : Yes
Page#: 1
Date: 3/13/2023

' NC Department of Environmental Quality
Division of Energy, Mineral and Land Resources
NORTH CAROLINA
Enviranmr[W Quality
Stormwater eReporting Registration Form
Completion of the Stormwater Electronic Reporting (eReporting) Registration Form is a required
step for the Owner to obtain the privilege of submitting electronic reports to DEQ and in lieu of
submitting paper reports.
In addition, this form allows for Owners to designate Responsible Officials and Facility
Administrators who can act on their behalf.
A. Owner Information
The Owner is the legal entity to which/whom permits have been issued. The Owner maybe an
individual or organization. Every Owner is required to have a Responsible Official who meets
the legal signature authority requirements in 40 CFR 122.22.
• For a corporation, this individual shall a president, secretary, treasurer, or vice-president in
charge of a principal business function, or another individual who performs similar functions
for the corporation, or the manager of one or more manufacturing, production, or operating
facilities who is authorized to make management decisions about the facility operation.
• For a partnership or sole proprietorship, this individual shall be a general partner or the
proprietor, respectively; or
• For a municipality, State, Federal, or other public agency, this individual shall be either a
principal executive officer or ranking elected official.
Owner Name: Avoca, LLC
Responsible Official Name: Augustinus Gerritsen Title: President
Does the Responsible Official If Yes,
already have an eDMR account? 0 Yes 0 No User ID:
Email Address: [e-mail] Phone: [phone]
------------
Mailing Address: P.O. BOX 129
City: Merry Hill state: N C zip: 27957
Stormwater Electronic Reporting Registration Form
Pagel

B. Permit Information
Include all stormwater permit currently held by the Owner(both Individual and General permits).
Designate any persons to be designated as Facility Administrators for each permit. Include all
persons to have Facility Administrator privileges in the same box. Attach additional pages if you
need more space.
%rmit'No. Facility Name Facility Address
Facility Administrator(s)'
if a ` licable)
NCS000134 Avoca, LLC 841 Avoca Farts Road,Merry HIII,NC 27957 Brian Conner
Stormwater Electronic Reporting Registration Form
Page 2

C. Facility Administrator Information
Include the following information for all Facility Administrators listed in Part B. Attach additional
pages if you need more space.
Facility Administrator for Permit Number:
Name: Brian Conner Title: EHS Manager
Do you already have an eDMR 13 If Yes,
account? Yes ® No User ID:
Organization: Avoca, LLC
Email Address: [e-mail] I Phone: [phone]
Mailing Address: P.O. Box 129
City: Merry Hill State: NC Zip: 127957
Facility Administrator for Permit Number:
Name: Title:
Do you already have an eDMR If Yes,
account? f7 Yes ® No user ID:
Organization:
Email Address: Phone:
Mailing Address:
City: State: Zip:
Facility Administrator for Permit Number:
Name: Title:
Do you already have an eDMR If Yes,
account? ©Yes ® No User ID;
Organization:
Email Address: Phone:
Mailing Address:
City: State: Zip:
Facility Administrator for Permit Number:
Name: Title:
Do you already have an eDMR El If Yes,
account? Yes 0 No User ID:
Organization:
Email Address: Phone:
Mailing Address:
City: State: Zip:
Facility Administrator for Permit Number:
Name: Title:
Do you already have an eDMR El If Yes,
account? Yes E1 No User ID:
Organization:
Email Address: Phone:
Mailing Address:
City: State: Zip:
Stormwater Electronic Reporting Registration Form
Page 3

D. Responsible Official Authorization
I, Augustinus Gerritsen (printed name), certify that I
meet the legal signatory authority requirements under 40 CFR 122.22, to make this request on
behalf of.Avoca, LLC (Owner/Organization Name).
Signature Date
Stormwater Electronic Reporting Registration Form
Page 4

Avoca,LLC
Arx PO Box 129
xt,,- Avoca LLC 841 Avoca Farm Rd
1 Merry Hill,NC 27957
Phone: [phone]
The World's Premier Botanical Extraction Company Fax: [phone]
11/26/2020
DEMLR Stormwater Program eDMR
Attn: Suzanne McCoy
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: Delegation of Signature Authority Letter
Dear DEMLR Stormwater Program staff:
By notice of this letter, I hereby signatory authority to each of the individuals listed in the
attached Table 1 for all permit applications, discharge monitoring reports, and other information
relating to the operations at the subject facility as required by all applicable federal, state, and
local environmental agencies specifically within the requirements for signatory authority as
specified in 15A NCAC 213 _0506.
If you have any questions regarding this letter, please contact Suzanne McCoy at
Suzanne.McCoy @ncdenr.gov or [phone].
Sincerely,
Augustinu er sen
Preside A oca LLC
PO Box 129, Merry Hill NC 27957
[e-mail]
Office: 252-482-2133
Mobile: [phone]

Table 1: Individuals to be Granted Signatory Authority
eDMR User ID Permit Nos,
Individual (if applicable) for which this person shall have
signatoy authority
Brian Conner NCS000134

RECEIVED
a"R ')s. 77+�
r-. . : j?J
SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF iW ` ^WAter program
NPDES STORMWATCR PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete-
(Do not submit the site Stornnwater Pollution Prevention Play)
Initials
9DMe-- 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage ofrnaterials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas fo; each outfall,
building locations and impervious surfaces should be clearly noted.
`gjYv�C. 2. A summary of Analytical Monitoring results during the term of the existing perinit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall numbei,
parameters sampled,lab results,date sampled, and storm event data.
Zyn 4- 3. A suminaty of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations,and date monitoring conducted.
BM C. 4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned,please include
information on these BMP's.
S. A short narrative describing any significant changes in industrial activities at the
permitted facility. Sigmficant changes could include the addition or deletion of
work processes, changes in material handling practices,changes in material storage
practices,and/or changes in the raw materials used by the facility.
p�rnC� 6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility(Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 34 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

Permit Coverage
Renewal Application Forr>�
NCDENR National Pollutant Discharge Elimination System ICS000114_
S Permit Number
N
Stormwater Individual Permit
Please provide your permit number In box in the upper right hand corner,complete the information in the space provided
below and return the completed renewal form along with the required supplemental Information to the address indicated.
Owner information *Address tow Qpeerm1t correspondence will be mailed
Owner(Organization Name: �2aco_ 1.Uc.� �la�ad 4-_L
Owner Contact: ;�,
Mailing Address: M
vv 1 Q -..-la S
Phone Number: Z.2 -2l3
Fax Number: ZS2 - 2.
E-mail address: mutt S_C�_P_vr't Sevt , C0W_I
Facility information
Facility Name: �ti l0CA rovYnc, M
Facility Physical Address: 0134\ R\j Cu 5avWt o
't -say
Facility Contact: rid. O61el y
Mailing Address: p.0• Q)03 621
'Mew ,1t I tsL Z"1-151
Phone Number: 4 2-1111,116
Fax Number:
E-mail address: Sojc► n. CoyvgV& CA s1nlancl. CQhr►
Permit information n
Permit Contact: t5yian �nn2�/
Mailing Address: P,O. Q m 128
mey..v \-lit1,Qc- Z"IRS-I
Phone Number: UILSI's L1W2-2133
Fax Number: C2S2 L1 -Q,622.
E-mail address: 10Amn . CO v.ner @ aS avi . to►�
Discharge Information
Receiving Stream: CV-eey,
Stream Class: S
Basin: b p wo n :�1C�r S�v1
Sub-Basin:
Number of Outfalls:
Facility/Activity FacilitylActimity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
az,\" Q0. l o oc'-1 t.tlCcs Gov�s���[kec� �n Ja�.va,r� �011 . "phis Vs�,1�..A OlDf- &S
L'):S ► 4&a. Saw,e selavcoVile- 0_V'A SVG atirva}iOnS a% utas !Pr ©ncirotkA i n
8ui1 '� k !0 01-1 aw,rl 1oa3-1 o -she. �„�\�;� oena i irs ytsselc acre, Ca�nn�leh¢l4r Coveye Gl
w'd ein Cc a W;lm 2yVv�5,
CERTIFICATION
I certify that I amg ill h t e i ormation contained in the application and that to the best of my knowledge and belief
such information Iru
Signature Date
Print or-type name of person signing above Title
SW Individual Permit Coverage Renewal
Please return this completed application form Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

�a
z�zr
a
M
ip
A SLNW AND PU!FOR
� D D
AVWA
w -
p � .
-�-
law-
9:�..
a f3
nT�' �

Avoca, Inc. Storm Water Analytical Monitoring Results
Permit No.NC5000134
OUtfWI#:001
"SampleDate Total Flow Total Rainfall pH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
12/22/2015 0.052 0.7 7.68 65.0 127.0 14.40 2.78
6/23/2016 0.155 2.1 7.17 51.0 142.0 2.77 0.51
12/19/2016 0.088 1.2 7.14 86.0 23.0 3.31 0.86
6/20/2017 0.096 1.3 6.79 49.0 41.0 2.31 0.77
1/23/2018 0.015 0.2 7.64 496.0 125.0 12.40 4.02
1/4/2019 0.022 0.3 751 142.0 105.0 1.90 0.56
7/23/2029 0.273 3.7 4.97 61.0 123.0 4.45 0.70
Average 1 0.100242857 1.357142857 1 6.99 135.7 98.0 5.93 1.46

Avoca, Inc. Storm Water Analytical Monitoring Results
Permit No. NCS000134
Outfall#:003
"SampleDate Total Flow Total Rainfall pH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
8/8/2015 0 046 0.7 8.59 64.0 3.6 4.73 0.65
8/31/2015 0.039 0.6 6.73 725.0 36 0 17.35 6.74
9/25/2015 0.117 1.8 4.47 4228.0 68.0 23.73 7.68
10/28/2015 0.033 0 5 6.96 318.0 18.0 1.72 1.04
11/19/2015 0.078 1.2 6.63 498.0 1340 11.22 2.86
12/25/2015 0.046 0.7 6.62 1149.0 90.0 43.66 5.98
2/4/2016 0.143 2.2 6.85 344.0 102.0 5.53 1.59
2/16/2016 0.072 1.1 7.03 217.0 273.0 5.76 1.31
3/28/2019 0.091 1.4 7.60 271.0 19.0 6.17 2.10
5/3/2016 0 052 0.8 7.09 218.0 57.0 6.10 1.56
6/7/2016 0.078 1.2 702 196.0 169.0 5.21 1.24
6/23/2016 0.137 2.1 7.14 3400 233.0 5.15 1.44
7/19/2016 0.065 1 6.73 2060 9.7 7.54 0.94
8/8/2016 0.13 2 7.74 95.0 77.0 1.75 0.67
9/19/2016 0.072 1.1 8.01 2800.0 49.0 3.94 0.71
11/4/2016 0.052 0.8 6.58 240.0 19.0 6.45 2.70
11/14/2016 0.02 0.3 6.91 482.0 34.0 12.25 0.98
12/19/2016 0.078 1.2 6.81 95.0 28.0 8.79 2.03
1/23/2017 0.039 0.6 6.93 171.0 21.0 3.81 2.47
2/8/2017 0.039 0.6 7.16 1770.0 353.0 35.80 12.76
3/31/2017 0.091 1.4 6.71 1080.0 153.0 18.36 20.46
4/24/2017 0.15 2.3 6.51 59.0 5.2 7.67 0.64
5/23/2017 0.111 17 6.61 250.0 7.4 5.23 2.60
6/20/2017 0.085 13 6.62 251.0 48.0 6.41 2.24
7/17/2017 0.098 1.5 7.10 276.0 57.0 6.52 2.63
8/8/2017 0.052 1 0.8 7.54 168.0 20.0 4.76 15.48
10/10/2017 0.033 1 05 6.93 957.0 t 59.0 1 19.72 8.76

Sample Date Total Flow Total Rainfall pH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
10/29/2017 0.072 1.1 7.81 328.0 19.0 7.15 4.02
12/6/2017 0.023 0.35 7.70 522.0 115.0 15.86 4.58
1/23/2018 0.013 0.2 7.71 351.0 101.0 8.51 2.88
1/23/2018 0.013 0.2 7.71 324.0 100.0 10.57 2.92
2/28/2019 0.033 0.5 7.64 266.0 48.0 9.16 5.44
3/12/2018 0.065 1 7.13 283.0 42.0 6.00 3.35
4/24/2018 0.085 1.3 7.06 217.0 14 0 5.31 1.95
5/18/2018 0.039 0.6 7.07 515.0 460 6.13 5.55
9/15/2018 0137 2.1 7.60 26.0 6.9 1.09 0.25
9/16/2018 0.13 2 7.52 28.0 6.1 1.08 0.25
10/11/2018 0.065 1 6.99 442.0 26 0 14.86 5.58
11/15/2018 0.065 1 7.51 462.0 133.0 12.14 3.40
1/4/2019 0.02 0.3 7.46 61.0 58.0 3.07 1.54
2/11/2019 0.065 1 7.42 595.0 83 0 16.94 6.21
2/11/2019 0.065 1 7.42 701.0 930 16.69 5.91
3/26/2019 0.033 0.5 6.67 41.0 17.0 3.03 0.38
4/9/2019 0.15 2.3 8.24 179.0 18.0 7.05 2.57
6/5/2019 0.039 0.6 7.65 392.0 45.0 11.05 2.28
7/23/2019 0.241 3.7 5.10 276.0 48.0 8.05 1.85
7/23/2019 0.241 3.7 5.12 416.0 82.0 13.01 2.80
Average 0.08 1.19 7.07 508.4 69.0 1 9.83 3.70

Avoca, Inc. Storm Water Analytical Monitoring Results
Permit No. NCS000134
Outfall#:004
Sample Date Total Flow Total Rainfall pH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
12/22/2015 0.013 0.7 6.64 <20 <2.8 0.57 <0.04
6/23/2016 0.039 2.1 6.82 <20 6.80 0.72 0.07
12/19/2016 0.022 1.2 7.02 <20 <2.7 0.15 0.18
6/20/2017 0.024 1.3 6.95 20.00 <2.6 0.52 0.08
1/23/2018 0.004 0.2 776 24.00 <3.1 157 0.14
1/4/2019 0.006 0.3 7.39 <20 < 2.6 <0.51 0.06
7/23/2019 0.069 1 3.7 4.87 1 24.00 12.00 1 1.90 1 0.10
Average 0.188405797 0,189189189 1.36345 #VALUE! #VALUE! 1 0.3 #VALUE!

Avoca.. Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 001
The scale for Clarity,Floating Solids,and Suspended Solids is 1-5.1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating Suspended Foam? Oil Sheen? Erosion?
Solids Solids
(1-5) Yes/No Yes/No Yes/No
12/22/2015 Light Brown None 3 2 2 No No No
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Light BrownNone 2 2 1 No No No
7/23/2019 Light Gray None 2 2 1 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall#: 002
The scale for Clarity, Floating Solids,and Suspended Solids is 1-5.1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating SuspendedSolids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 Light None 1 1 1 No No No
Brown
6/23/2016 LightBrown None 1 1 1 No jjN
o No
12/19/2016 Clear None 1 1 1 No o No
6/20/2017 Clear None 1 1 1 No o No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 2 1 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall#: 003
The scale for Clarity,Floating Solids,and Suspended Solids is 1-5.7.Is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating SuspendedSolids Solids Foam? Oil Sheen? Erosion?
{1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
8/8/2015 Gray None 3 2 2 No No No
8/31/2015 BLiight None 2 1 1 No No No
9/25/2015 Light Gray None 2 2 1 No No No
10/28/2015 Light None 2 1 1 No No No
Brown
11/19/2015 Light Gray None 2 1 1 No No No
12/25/2015 Gray None 3 2 2 No No No
2/4/2016 Light Gray None 2 2 1 No No No
2/16/2016 Light Gray None 2 2 1 No No No
3/28/2019 Light Gray None 2 2 1 No No No
5/3/2016 Light Gray None 2 2 1 No No No
6/7/2016 Light Gray None 2 2 1 No No No
6/23/2016 Light None 2 2 1 No No No
Brown
7/19/2016 LightBrown None 1 1 1 No No No
8/8/2016 Clear None 1 2 2 No No No
9/19/2016 Clear None 1 1 1 No No No
11/4/2016 Light Grayj None 1 1 1 No No No
11/14/2016 Light Gray None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
1/23/2017 Light Gray None 1 1 1 No No No
2/8/2017 Gray None 3 1 1 No No No
3/31/2017 Light Gray None 2 2 1 No No No
4/24/2017 Clear None 1 1 1 No No No
5/23/2017 Clear None I 1 I 1 1 1 No No No

Sample Date Color Odor Clarity Floating SuspendedSolids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
6/20/2017 LightBrown None 2 2 2 No No No
7/17/2017 LightBrown None 3 1 2 No No No
8/8/2017 LightBrown None 2 3 1 No No No
10/10/2017 LightBrown None 2 1 1 No No No
10/29/2017 Clear None 1 1 1 No No No
12/6/2017 Brown None 4 1 4 No No No
1/23/2018 LightBrown None 2 1 1 No No No
1/23/2018 LightBrown None 2 1 1 No No No
2/28/2018 LightBrown None 2 2 1 No No No
3/12/2018 Clear None 2 1 1 No No No
4/24/2018 Clear None 1 1 1 No No No
5/18/2018 LightBrown None 2 1 1 No No No
9/15/2018 Light Grayl
None 2 2 2 No No No
9/16/2018 Clear None 1 1 1 No No No
10/11/2018 LightBrown None 2 2 2 No No No
11/15/2018 Light Gray None 2 2 2 No No No
1/4/2019 Clear None 1 2 1 No No No
2/11/2019 Light BrownNone 2 1 1 No No No
2/11/2019 LightBrown None 2 1 1 No No No
3/26/2019 Light Gray None 2 1 1 No No No
4/9/2019 LightBrown None 2 1 1 No No No
6/5/2019 LightBrown None 2 3 2 No No No
7/23/2019 Light Grayl
None 2 2 2 No No No
7/23/2019 Light Gray None 2 2 2 No No No

Avoca, Inc, Storm Water Visual Monitoring Results
Permit No. NCS000134
outfall #: 004
The scale for Clarity,Floating Solids,and Suspended Solids is 1-5.1 is very clear or none present to 5 Is high
or covered.
Sample pate Color Odor Clarity Floating SuspendedSolids Solids Foam? Oil Sheen? Erosion?
(1-5} (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 Clear None 1 1 1 No No No
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 1 1 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 007
The scale for Clarity,Floating Solids,and Suspended Solids is 1-5. 1 Is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating SuspendedSolids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 Clear None 2 1 1 No No No
6/23/2016 Clear None 2 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 2 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Light Gray None 2 2 1 No No No

BEST MANAGEMENT PRACTICES (BMPs)
AVOCA, LLC
Stormwater Permit No. NCS000134
BMP 1 - Containment Berms: Avoca, LLC has spill containment berms installed
around each of its fuel,solvent,and other processing tanks. These berms are large enough
to hold the total capacity of at least one of the contained tanks plus a minimum of 10%.
The following is a listing of the containment areas and their locations:
1) Fuel Oil Storage and Unloading,West of Building 1001-2
2) Gasoline Storage and Unloading, South of Building 10024
3) Emergency Generator Fuel Storage,Near Cooling Tower
4) Emergency Generator Fuel Storage, South of Building 1001-1 ,
5) Hazardous Waste Storage,Building 1003-5
b) Tank Farm, South of 1001-1
7) Tank Farm,North of Building 1001-1
8) Tank Farm,West of Building 1003-2
9) Unloading Station,South of Building 1001-2
10) Sclareol Recrystallization& Storage tanks,Building 1003-10
11)Chemical Storage, 1003-7
12) Botanical Extraction Process & Storage tanks,North of Building 1001-11
13) Biomass Extraction Process&Storage tanks,Building 1004-2
14)Limited Use Generator, South of Buildmg 1004-1
15)Sclareolide and Sclareol Recrystallization storage tanks,Building 1005-1
BMP 2-Weekly monitoring of all areas listed in BMP 1: Monitoring includes
inspection of equipment and tanks within containments as well as all areas of the facility.
The operational status of the processes,housekeeping and cleanliness, condition of
equipment and tanks,and notification of spills and leaks are noted as well as any
corrective actions taken.
BMP 3 -Annual monitoring of the areas listed in BMP 1: Monitoring includes in
depth inspection of equipment and tanks within containments as well as all areas of the
facility.Parameters of inspection include:housekeeping and cleanliness, operating
condition of equipment, evidence of spills and/or leaks, stormwater conveyance(i.e.
condition of valves,flow channels, etc,.,), erosion evidence, actions required to remedy
any problems, and the date the problem was resolved.
BMP 4-Monitor berm contents: Avoca,LLC keeps its spill containment been drains
closed and locked.All pumps and valves are capped when not in use. The berms are
either drained by the boiler operator or pumped to Avoca's Tertiary Lagoon. All rain

water is inspected before it is drained to determine if there it has oil sheen or other
contaminates. In the case of a spill,the berms can be pumped out with a suction tanker or
either directly pumped to Avoca's Waste Water Treatment facility. The spilled liquid can
be either treated and disposed of or reused.
BMP 5-Hazardous waste storage: All hazardous waste is stored in a concrete dike area
with a protective roof covering the containment.There are signs stating that Hazardous
waste is to be stored in this area only.
BMP 6 -Analytical Monitoring: Analytical monitoring of stormwater runoff is
performed as stated in Stormwater Permit No.NCS000134.Analytical monitoring of
outfails#001,#003, and#004 is performed quarterly and outfall#003 is monitored
monthly.The temperature and pH are recorded at the time of sampling.The samples are
put on ice and sent to Environmental 1 located in Greenville,NC where they are analyzed
for Nitrogen,Phosphorous,Total Suspended Solids, COD,and pH. The analytical
monitoring results are kept at Avoca,LLC and sent to NCDENR within 30 days of
receiving the results from Environmental 1,
BMP 7-Qualitative Monitoring: Qualitative monitoring of Stormwater Runoff is
performed as stated in Stormwater Permit No.NCS000134. Qualitative monitoring of
outfails#001,#002,#003,#004,#006, and#007 is performed twice annually. Outfall
#005 is not monitored under the stormwater permit as it is covered under a separate
NPDES permit. The qualitative results are kept on file at Avoca,LLC.
BMP 8-Training: Training of all Avoca,Incorporated personnel occurs annually.
Employees are trained in the safe handling of chemicals,spill prevention of chemicals,
location of shutoff valves,who to contact in case of a spill,location of containment
equipment,and operation and maintenance of containment equipment.
BMP 9--Spill Clean-Up: Hazardous waste clean-up and major Spills are handled be an
outside contractor.AVOCA,LLC has a contract with Inco,Inc, located in Rocky Mount,
NC to handle all it's major spill incidents.
BMP 10--Covered Waste: All waste drums for scrap metal are to be covered.A tarp is
used to cover the scrap metal container which is used to store crushed drums at Avoca,
LLC.

2019 Notice of Significant Changes at the Avoca, LLC Facility
Stormwater Permit No. NCS000134
Addition of Building 1005-1:
Building 1005-1 was constructed in January 2017 for the expanded operation of
Sclareol Recrystallization(SFG)and Sclareolide. Building 1005-1 operates in the same
manner with the same materials as buildings 1001-1 and 1003-10 have for many years.
The sle purpose of this building was to allow for more production of the SFG and
Sclareolide products. All tanks,vessels,materials, etc. are covered and surrounded by
berms that meet all requirements. Building 1005-1 is inspected at the same frequency as
all other buildings listed in the BMPs.
All prior material handling and storage practices are currently in effect at Avoca,
LLC. The major Raw Materials handled at the facility also remain the same as in the past
notification.
Avoca,LLC. always strives to maintain a healthy environment and to prevent
pollution of the land, air, and water of the surrounding area. Avoca,LLC. understands the
importance of maintaining a natural,unpolluted environment and makes certain that its
actions in no way have adverse effects on the surrounding ecosystems. Avoca,LLC,also
realizes the importance of maintaining a safe workplace and shrives to always meet all
OSHA and other general safety guidelines.Avoca,LLC.will continue its policy of
maintaining the condition of the environment and safety of its facility through proper
management of its processes and through the training of its employees to meet the criteria
set forth to sustain a healthy, safe workplace and environment.

STORMWATER POLLUTION PREVENTION PLAN"
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources-Stormwater Permitting
Facility Name: No to,'Pew 2W
Permit Number S
Location Address ,jp T--WfYrl
�y errvu t I I) L 2.'I 9 57
County. `
e
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel property gather and evaluate the information required by the SPPP
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations"
Sign(according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date
NA COU Pye-%\Aevy'
Print or—L44/naylie of person signing above Title
SPPP Certification 10/13

Young, Brianna A
From: Brian Conner <[e-mail]>
Sent: Monday, March 27, 2023 2:37 PM
To: Young, Brianna A
Subject: RE: [External] RE: Avoca Farms— Merry Hill WWTP stormwater permit NCS000134
Attachments: Analytical Summary Data.xlsx;Avoca Stormwater Oufall Data.xlsx; Avoca Stormwater
Map.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Ms. Young,
Please see the attached updated files.
The "stormwater Outfall Data" should now have all buildings,tanks, and cooling towers listed.The outfall table should
now have all buildings assigned to an outfall. Rainwater is routed to the intakes outlined on the map which then run to
the designated outfalls.
Also, during the on-site inspection that occurred last week(3/22/23) by NCDEQ representative Mr. Bill Moore we
determined that a newly installed drainage pipe south of building 1003-10 would be designated Outfall #008. Mr. Moore
agreed that this outfall is represented by outfall#001. Mr. Moore added this information to his map for updates.
We have been analyzing samples for Lead as required. I overlooked this in the attached spreadsheet due to lead not
having a listed Benchmark in Table 3 on page 7 of Permit No. NCS000134. I now have the past 3 years of lead data listed
in the spreadsheets.The lead data has been included on the monthly and semi-annual reports that we have submitted
to NCDEQ.
If you have any more questions, please do not hesitate to contact me.
Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent: Monday, March 27, 2023 10:06 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
"""This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.—
Good afternoon,
I have a few more follow-up questions.The map provided does not have the drainage areas outlined for each outfall.
The spreadsheet you provided has structures listed that are not included in the outfall table above it and there are
1

structures (buildings, storage tanks, and cooling towers) in the provided site map that are not included in the
spreadsheet. Please provide an updated site map that has drainage area boundaries identified and/or a list of all
structures and which drainage basin/outfall they belong to.
Additionally, monitoring for Total Recoverable Lead was required in the current permit, however, monitoring results for
this data was not provided. Please provide these results or an explanation for why total lead was not tested for.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent: Friday, March 17, 2023 3:20 PM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
Good afternoon,
Thank you for submitting this information. I will reach out with any questions once I have reviewed everything.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
2

Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Friday, March 17, 2023 10:37 AM
To:Young, Brianna A<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Ms. Young,
Below are the answers to the recent questions you had concerning the Avoca LLC Stormwater Permit renewal:
• Please provide outfall coordinates for all outfalls in either degree or decimal format. The information previously
provided has an unusable format.
I have attached a spreadsheet titled "Avoca Stormwater Outfall Data"which has the coordinates of the
outfalls listed.
• Please provide information on when the landfill onsite closed.
The Manganese Landfill is not located on-site at Avoca.The landfill was established/used and closed by R.J.
Reynolds Company prior to me working at Avoca. It was located on property to the east of the current Avoca
site. I am not exactly sure of the year of closure as it was long before my time (pre-2002).The land where the
landfill was located is no longer owned by Avoca/Ashland. I believe it was sold to Rial Corporation in 2006 to
build a golf course. From what I understand that property has been sold several times since 2006.
• Please provide a site map that has each drainage area outlined with the outfall clearly identified.
Site map is attached.
• Please provide a list of chemicals currently stored onsite.
The attached spreadsheet titled "Avoca Stormwater Outfall Data" has the contents of each building listed. I
also attached a copy of the site's The main chemicals on site are: Hexane, Heptane, Ethanol, and Ethyl
acetate. I can send a copy of out Tier II Inventory report if needed.
• Please provide confirmation of which process buildings and activities are in which drainage areas.The
information previously provided does not specify(it just states process buildings).
The attached spreadsheet titled "Avoca Stormwater Outfall Data" has the buildings in each outfall area listed.
• Please provide more information on outfall SW006. Per information in our permit file history, outfall SWO03 was
previously granted Representative Outfall Status for SW006, but none of the information received to date
mentions this outfall.
I have attached a copy of the 2008 Stormwater Application Response letter that describes outfall#SW006.
Outfall SWO06 was a pipe roof drain that has been filled in and closed since 2008. 1 believe this closure may
have come as a recommendation from DEQ inspector Bill Moore
If there is any more information needed, please do not hesitate to contact me.
3

Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent:Thursday, March 16, 2023 12:32 PM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
***This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.—
Good afternoon,
After reviewing all the information provided, I have some follow-up questions.
• Please provide outfall coordinates for all outfalls in either degree or decimal format.The information previously
provided has an unusable format.
• Please provide information on when the landfill onsite closed.
• Please provide a site map that has each drainage area outlined with the outfall clearly identified.
• Please provide a list of chemicals currently stored onsite.
• Please provide confirmation of which process buildings and activities are in which drainage areas.The
information previously provided does not specify(it just states process buildings).
• Please provide more information on outfall SW006. Per information in our permit file history, outfall SWO03 was
previously granted Representative Outfall Status for SW006, but none of the information received to date
mentions this outfall.
Please let me know if you have any questions on this request.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, INC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
4

From:Young, Brianna A
Sent:Tuesday, March 14, 2023 9:13 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
Brian,
Thank you for providing this information. I will reach out with any questions once I've had a chance to review
everything.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Monday, March 13, 2023 2:14 PM
To:Young, Brianna A<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Dear NCDENR Representative:
Below is the information requested in an email received on March 7, 2023,from Brianna Young concerning the renewal
of Avoca LLC Stormwater Permit No. NCS000134. Most of this information was submitted in November 2019 when the
original permit renewal was due. However, a new permit was never issued, and the site has continued to operate under
the current/previous permit as instructed to do so by NCDEQ.
Please accept this information as requested to fulfill the requirements of the permit renewal process.
Site Name: Avoca LLC/Ashland LLC
Permit No: NCS000134
5

Address: 841 Avoca Farm Road
Merry Hill, NC 27957
SIC Code(s): 2833, 2087
NAICS Code(s): 325411, 311930
Industrial Activity:
The Avoca LLC site performs extractions of botanical (plant) materials.The extractions occur in a variety of equipment
and buildings on site using various solvents to extract specific ingredients or oils from plant materials.The extracts are
used in flavorings, additives,fragrances, and dietary supplements.The sage material is stored in bags or in sheds.All
other botanical materials arrive and are stored in supersacks or tankers/silos.All solvents are stored in tanks within
bermed enclosures.
Stormwater Outfall Information:
Outfalls (5):
001— N—826,792.838 E—2,676,440.763
Lat. =36.001940 Long. =-76.710280
Pipe with drains entering from driveways, parking, and process building roof tops.
002 - N—827,000.000 E—2,676,385.000
Trench/swale with draining driveway and lawn area.
003 - N—827,049.748 E—2,676,376.332
Pipe with drains entering from driveways, parking, and process building roof tops.
004- N—827,868.399 E—2,676,503.241
Pipe from boiler room roof drains.
007 - N—827,508.226 E—2,677,103.800
Pipe with drains entering from driveways, parking, and process building roof tops.
Monitoring Data:
A summary of all Analytical and Qualitative Analysis for each outfall is attached in spreadsheets.
Also, an updated list of the site's Best Management Practices (BMPs) is attached.
Operational Changes since renewal application dated 11/4/2019:
The only operational changes at the site since the submittal of the 2019 Permit Renewal application is with the No. 2
diesel fuel storage area.The 2 Diesel Fuel storage tanks previously enclosed by an earthen berm has now been replaced
by a single double walled above ground storage tank.
Delegation of Signature Authority:
The Stormwater Delegation of Signature Authority (DOSA) form is attached. This form was also submitted via the on-line
method and a hard copy was mailed to: NCDEMLR Stormwater Program, 1612 MSC, Raleigh, NC 27699-1612 as required.
eDMR Registration:
6

The registration for eDMR reporting was completed in December 2019. 1 have attached a copy of the information that
was submitted.
I have attached a copy of the original permit renewal documents that were submitted in November 2019 as well as the
updated information. I also mailed copies of this information. If there is more needed, please do not hesitate to contact
me.
Sincerely,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent: Friday, March 10, 2023 9:19 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
"'This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.-
Good morning,
Next week is fine.Thank you for the quick response.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Friday, March 10, 2023 8:21 AM
To:Young, Brianna A<[e-mail]>
Subject: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134

CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Ms. Young,
I am working to get this information updated. I should have it all to you early next week if that is OK?
Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From: Young, Brianna A<[e-mail]>
Sent:Tuesday, March 7, 2023 11:36 AM
To: Brian Conner<[e-mail]>
Subject: Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
***This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.***
Good morning,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000134.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action.
I am working on renewing the individual stormwater permit for the Avoca Farms—Merry Hill WWTP
(NCS000134). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity occurring onsite;
• Confirmation on the number of outfalls and associated coordinates;
• Description of industrial activity in each drainage area;
• SIC (NAICS) code;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility,contact information for the permit, and the regulated stormwater outfall(s)for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below,where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
8

• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany Georgoulias
• Stormwater outfall information: Email Bethany Geor_og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePayment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, INC 27604
,�: D_ E "7'�
t4p�
NORTH CAROLINA
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
This e-mail contains information which may be privileged,confidential,proprietary,trade secret and/or otherwise legally protected.It is not intended for
transmission to,or receipt by,any unauthorized persons.If you are not the intended recipient,please do not distribute this e-mail.Instead,please delete this e-mail
from your system without copying it,and notify us that you received it in error,so that our address record can be corrected.If you are not the intended recipient
you are notified that disclosing,copying,distributing or taking any action in reliance on the contents of this information is strictly prohibited.No waiver of any
applicable privileges or legal protections is intended(and nothing herein shall constitute such a waiver),and all rights are reserved.
9

�g
G-
DOS¢.
Wit
O:J3
a e_
� a �
�f aeg 4
4. G
i
6 O=
'An a
m� �•.r gg Rgg
mmm m mm:m:
H��-me
mmmmmmmmmmm 9�
m
�A
�= 2
III p
a�a� � loll
ppppggpp@@pp
In
NOV. I
�= o
o�
N�

Avoca, LLC Stormwater OL
Outfall # Longitude Latitude Drainage Area
1 760 42'48" 360 3' 05" 4.5
2 760 42'48" 360 3' 06" N/A
3 760 42'48" 360 3' 06" 4.2
4 760 42'44" 360 3' 10" 1
5 760 42'44" 360 3' 10" N/A
6 760 42'48" 360 3' 10" N/A
7 760 42'40" 360 3' 06" 1.4
8 760 42'48" 360 3' 03" 0.5
Avoca, LLC Building [
BUILDING # PURPOSE PROCESS/ USE
1001-10 OFFICE OFFICE
1001-6 OFFICE OFFICE
1001-7 OLD SHIPPING & STORAGE
RECEIVING
1001-1 CONVERSION SCLAREOLIDE PRODUCTION, RECOVERY
PROCESS
1001-4 BOILER ROOM CONTAINS 3 BOILERS
1001-3 OLD PILOT PLANT MATERIAL STORAGE
1001-5 BOILER STORAGE STORAGE
BLDG.
1001-2 ROTOCELL SAGE PROCESSING
1001-11 CROWN 1 VARIOUS BOTANICAL EXTRACTIONS
1003-5 SAGE SHED STORAGE OF FRESH CUT SAGE

1003-7 CHEMICAL STORAGE STORAGE OF CHEMICALS
BLDGS.
CT COOLING TOWER COOLING TOWER CONTROLS AND
CONTROL BLDGS. (3) CHEMICAL FEED
1003-2 M-13 VARIOUS EXTRACTION PROCESSES
1004-2 CROWN 2 VARIOUS BOTANICAL EXTRACTIONS
(EXTRACTOR BLDG.)
CROWN 2 PROCESS CONTROLS FOR EXTRACTIONS,
1004-1 (CONTROL/INFEED) FINISHED GOODS, INFEED OF BOTANICAL
MATERIALS
SH SCALE HOUSE USED TO WEIGH TRUCKS
1003-9 GUARD HOUSE CHECK-IN STATIONS FOR PLANT SITE
SHIPPING AND
1003-4 RECEIVING, WHITE WAREHOUSE AND PROCESS AREA FOR
BEANS & WATER EXTRACTIONS
WAREHOUSE
1003-10 RECRYSTALLIZATION RECRYSTALLIZATION PROCESS OF
(SFG) SCLAREOL
1003-3 & 1003-6 WASTE WATER TMT. TREATMENT OF PLANT INDUSTIRAL WASTE
1003-1 MAINTENANCE SHOP MAINTENANCE OF PLANT, QUALITY
& QC LAB CONTROL LAB FOR PRODUCTS
1002-1 MEETING ROOM / MEETING ROOM, MAINTENANCE STORAGE,
STORAGE CONTRACTOR STAGING AREA
DESIGNATED DESIGNATED SMOKING AREA, PARTS
1002-2 SMOKING AREA& STORAGE
STORAGE
1002-7 STORAGE NEW PARTS STORAGE
1002-16 R & D LAB RESEARCH LAB
1002-15 GREENHOUSE PLANTS FOR R&D
1002-14 OLD LAB SMALL LAB EXPERIMENTS
1005-1 SDE/SFG RECRYSTALLIZATION PROCESS OF
SCLAREOL
BB BIOMASS BOILERS BIOMASS BOILERS

FUEL STORAGE FOR BOILERS AND
FT DIESEL FUEL TANK
GENERATORS

Wall Data
Buildings in Drainage Area Comments
1004-1, 1004-2, 1003-3,
1003-4, 1003-6, 1005-1,
1003-9, 1003-10, SH, 1002-
1, 1002-2, 1002-7
N/A "Outfall" is a swell/trench that has
very little flow
1001-1, 1001-2, 1001-11,
1003-2, 1003-5, 1003-7,
1003-1, CT, BB, FT
1001-3, 1001-4, 1001-5 Roof drains that are impervious
N/A NPDES Parshall Flume Outfall (NOT
STORMWATER)
N/A CLOSED/ REMOVED
1001-10, 1001-6, 1001-7,
1002-14, 1002-15, 1002-16,
1003-1
1005-1 New building area, Outfall #001 is
representative
)ata
MATERIALS USED/STORED IN AREA
NEW FILTERS, DOCUMENT STORAGE
HEXANE, METHANOL, EMPTY SILOS
BOILER CHEMICALS, NO.2 FUEL OIL, PROPANE
DRUMMED CHEMICAL STORAGE (HEXANE, ETHANOL,
ETHYL ACETATE, METHANOL), HAZARDOUS WASTE
STORAGE
FIRE SUPPLIES, CLEAN-UP MATERIALS, BOILER
CHEMICALS
HEXANE, SAGE PLANT
VARIOUS SOLVENTS (HEXANE, ETHANOL), RAW
BOTANICAL MATERIALS, AND FINISHED PRODUCTS IN
PROCESS
SAGE (DURING OPERATION)

VARIOUS SOLVENTS IN DRUMS (HEXANE, ETHANOL,
ETHYL ACETATE, METHANOL), SAGE JAR SAMPLING
BUIDLING IS DIRECTLY SOUTH
COOLING TOWER CHEMICALS
VARIOUS SOLVENTS (ETHANOL, CHLOROFORM), RAW
MATERIALS, AND FINISHED PRODUCTS IN PROCESS
VARIOUS SOLVENTS (HEXANE, ETHANOL), RAW
BOTANICAL MATERIALS, AND FINISHED PRODUCTS IN
PROCESS
RAW BOTANICAL MATERIALS AND FINISHED PRODUCTS
SCALES
WAREHOUSE FOR FINISHED GOODS & RAW MATERIALS
HEPTANE, ETHYL ACETATE, SCLAREOL
INDUSTRIAL WASTE WATER, WASTE WATER CHEMICALS,
EMPTY SILOS
TOOLS, PARTS, SMALL QUANTITY LAB CHEMICALS
TOOLS, PARTS, CLEANING SUPPLIES STORAGE
SMOKING SECTION, EQUIPMENT
PARTS, HOSES
SMALL QUANTITY LAB CHEMICALS
PLANTS
SMALL QUANTITY LAB CHEMICALS, LAB EQUIPMENT
HEXANE, HEPTANE, ETHYL ACETATE, SCLAREOL
WOOD CHIPS

DIESEL FUEL

Avoca, LLC Storm Water Analytical Monitoring Results
Permit No.NCS000134
Outfall#:001
Sample Date Total Flow Total Rainfall pH COD TSS Total Lead Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L mg/L
12/22/2015 0.052 0.7 7.68 65.0 127.0 14.40 2.78
6/23/2016 0.155 2.1 7.17 51.0 142.0 2.77 0.51
12/19/2016 0.088 1.2 7.14 86.0 23.0 3.31 0.86
6/20/2017 0.096 1.3 6.79 49.0 41.0 2.31 0.77
1/23/2018 0.015 0.2 7.64 496.0 125.0 12.40 4.02
1/4/2019 0.022 0.3 7.51 142.0 105.0 1.90 0.56
7/23/2019 0.273 3.7 4.97 61.0 123.0 4.45 0.70
6/16/2020 0.111 1.5 7.50 47.0 28.0 3.04 <0.005 1.26
12/14/2020 0.088 1.2 6.08 240.0 302.0 5.25 0.017 2.91
6/21/2021 0.184 2.5 6.76 56.0 16.0 1.74 <0.005 0.39
12/30/2021 0.022 0.3 5.18 40.0 19.0 2.06 <0.005 0.39
7/31/2022 0.066 0.9 6.96 44.0 23.0 1.35 <0.005 0.47
12/15/2022 0.074 1 7.40 26.0 36.0 0.74 <0.005 0.32
Total Average 0.096 1.3 6.83 107.9 85.4 4.29 1.23
Recent 1 year Average 0.070 0.950 7.180 35.000 29.500 1.045 0.395
Benchmark/Limit 6 to 9 120 100 30 2

Avoca, LLC Storm Water Analytical Monitoring Results
Permit No.NCS000134
Outfall#:003
Sample Date Total Flow Total Rainfall pH COD TSS Tota I Lead Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L mg/L
8/8/2015 0.046 0.7 8.59 64.0 3.6 4.73 0.65
8/31/2015 0.039 0.6 6.73 725.0 36.0 17.35 6.74
9/25/2015 0.117 1.8 4.47 4228.0 68.0 23.73 7.68
10/28/2015 0.033 0.5 6.96 318.0 18.0 1.72 1.04
11/19/2015 0.078 1.2 6.63 498.0 134.0 11.22 2.86
12/25/2015 0.046 0.7 6.62 1149.0 90.0 43.66 5.98
2/4/2016 0.143 2.2 6.85 344.0 102.0 5.53 1.59
2/16/2016 0.072 1.1 7.03 217.0 273.0 5.76 1.31
3/28/2019 0.091 1.4 7.60 271.0 19.0 6.17 2.10
5/3/2016 0.052 0.8 7.09 218.0 57.0 6.10 1.56
6/7/2016 0.078 1.2 7.02 196.0 169.0 5.21 1.24
6/23/2016 0.137 2.1 7.14 340.0 233.0 5.15 1.44
7/19/2016 0.065 1 6.73 206.0 9.7 7.54 0.94
8/8/2016 0.13 2 7.74 95.0 77.0 1.75 0.67
9/19/2016 0.072 1.1 8.01 2800.0 49.0 3.94 0.71
11/4/2016 0.052 0.8 6.58 240.0 19.0 6.45 2.70
11/14/2016 0.02 0.3 6.91 482.0 34.0 12.25 0.98
12/19/2016 0.078 1.2 6.81 95.0 28.0 8.79 2.03
1/23/2017 0.039 0.6 6.93 171.0 21.0 3.81 2.47
2/8/2017 0.039 0.6 7.16 1770.0 353.0 35.80 12.76
3/31/2017 0.091 1.4 6.71 1080.0 153.0 18.36 20.46
4/24/2017 0.15 2.3 6.51 59.0 5.2 7.67 0.64
5/23/2017 0.111 1.7 6.61 250.0 7.4 5.23 2.60
6/20/2017 0.085 1.3 6.62 251.0 48.0 6.41 2.24
7/17/2017 0.098 1.5 7.10 276.0 57.0 6.52 2.63
8/8/2017 0.052 0.8 7.54 168.0 20.0 4.76 15.48
10/10/2017 0.033 0.5 6.93 957.0 59.0 19.72 8.76
10/29/2017 0.072 1.1 7.81 328.0 19.0 7.15 4.02
12/6/2017 0.023 0.35 7.70 522.0 115.0 15.86 4.58
1/23/2018 0.013 0.2 7.71 351.0 101.0 8.51 2.88
1/23/2018 0.013 0.2 7.71 324.0 100.0 10.57 2.92
2/28/2019 0.033 0.5 7.64 266.0 48.0 9.16 5.44
3/12/2018 0.065 1 7.13 283.0 42.0 6.00 3.35
4/24/2018 0.085 1.3 7.06 217.0 14.0 5.31 1.95
5/18/2018 0.039 0.6 7.07 515.0 46.0 6.13 5.55
9/15/2018 0.137 2.1 7.60 26.0 6.9 1.09 0.25
9/16/2018 0.13 2 7.52 28.0 6.1 1.08 0.25
10/11/2018 0.065 1 6.99 442.0 26.0 14.86 5.58
11/15/2018 0.065 1 7.51 462.0 133.0 12.14 3.40
1/4/2019 0.02 0.3 7.46 61.0 58.0 3.07 1.54
2/11/2019 0.065 1 7.42 595.0 83.0 16.94 6.21
2/11/2019 0.065 1 7.42 701.0 93.0 16.69 5.91
3/26/2019 0.033 0.5 6.67 41.0 17.0 3.03 0.38
4/9/2019 0.15 2.3 8.24 179.0 18.0 7.05 2.57
6/5/2019 0.039 0.6 7.65 392.0 45.0 11.05 2.28
7/23/2019 0.241 3.7 5.10 276.0 48.0 8.05 1.85
2/7/2020 0.265 3.6 7.01 188.0 393.0 6.65 0.023 0.02
2/19/2020 0.022 0.3 6.10 94.0 25.0 5.06 <0.005 1.00
3/23/2020 0.066 1 0.9 7.21 211.0 35.0 13.06 <0.005 2.64
4/13/2020 0.033 0.5 6.48 305.0 95.0 8.10 0.006 3.02
5/19/2020 0.033 0.5 8.47 334.0 63.0 7.25 <0.005 3.52

Sample Date Total Flow Total Rainfall pH COD TSS Total Lead Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L mg/L
6/16/2020 0.098 1.5 7.22 1290.0 349.0 19.99 <0.005 11.06
8/10/2020 0.039 0.6 5.74 823.0 206.0 12.45 0.011 5.20
9/9/2020 0.078 1.2 7.51 455.0 44.0 14.47 <0.005 5.40
9/29/2020 0.104 1.6 4.72 1260.0 136.0 21.46 <0.005 8.90
10/30/2020 0.013 0.2 7.10 61.0 62.0 3.50 <0.005 0.75
11/11/2020 0.339 5.2 4.54 1210.0 318.0 29.68 0.009 6.34
12/14/2020 0.078 1.2 6.21 437.0 40.0 13.22 <0.005 4.72
1/31/2021 0.085 1.3 6.22 163.0 15.0 6.88 <0.005 1.92
2/18/2021 0.111 1.7 7.15 465.0 54.0 8.52 <0.005 3.08
3/16/2021 0.065 1 7.66 356.0 55.0 12.61 <0.005 2.76
5/30/2021 0.156 2.4 4.82 247.0 46.0 6.93 <0.005 2.94
5/31/2021 0.156 2.4 4.82 247.0 46.0 6.93 <0.005 2.94
6/21/2021 0.163 2.5 7.68 307.0 48.0 7.47 <0.005 2.78
7/19/2021 0.052 0.8 4.71 756.0 32.0 12.76 <0.005 4.55
9/22/2021 0.02 0.3 7.17 134.0 114.0 3.86 0.009 0.80
9/23/2021 0.02 0.3 7.95 165.0 298.0 5.74 0.014 1.02
10/29/2021 0.013 0.2 5.03 5.1 74.0 9.44 <0.005 4.63
11/22/2021 0.033 0.5 8.02 594.0 61.0 14.14 <0.005 6.73
12/30/2021 0.02 0.3 5.12 42.0 17.0 1.45 <0.005 0.36
2/24/2022 0.007 0.1 6.10 507.0 21.0 7.62 <0.005 3.25
3/9/2022 0.078 1.2 4.08 441.0 24.0 11.38 <0.005 5.13
4/18/2022 0.072 1.1 7.69 1360.0 225.0 14.77 <0.005 7.12
5/13/2022 0.059 0.9 8.37 894.0 474.0 40.00 <0.005 3.26
7/31/2022 0.059 0.9 7.01 63.0 18.0 2.64 <0.005 0.88
7/31/2022 0.059 0.9 7.01 63.0 19.0 2.64 <0.005 0.78
8/16/2022 0.046 0.7 7.23 105.0 14.0 3.29 <0.005 0.76
9/30/2022 0.411 6.3 6.49 36.0 19.0 1.17 <0.005 0.39
11/1/2022 0.039 0.6 6.45 34.0 25.0 1.98 <0.005 0.28
11/30/2022 0.039 0.6 7.81 88.0 37.0 4.50 <0.005 0.58
12/15/2022 0.065 1 7.20 <20 12.0 0.74 <0.005 0.36
1/22/2023 0.059 0.9 6.27 35.0 3.9 13.38 <0.005 0.59
3/2/2023 0.039 0.6 6.25 <20 27.0 1.98 <0.005 0.43
Total Average 0.08 1.19 6.86 459.9 80.8 9.72 3.40
Recent 1 year Average 0.09 1.31 6.82 311.90 74.83 8.21 1.71
-Benchmark/Li mit 6 to 9 120 100 30 2

Avoca, LLC Storm Water Analytical Monitoring Results
Permit No.NCS000134
Outfall#:004
Sample Date Total Flow Total Rainfall pH COD TSS Total Lead Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L mg/L
12/22/2015 0.013 0.7 6.64 <20 <2.8 0.57 <0.04
6/23/2016 0.039 2.1 6.82 <20 6.80 0.72 0.07
12/19/2016 0.022 1.2 7.02 <20 <2.7 0.15 0.18
6/20/2017 0.024 1.3 6.95 20.00 <2.6 0.52 0.08
1/23/2018 0.004 0.2 7.76 24.00 <3.1 1.57 0.14
1/4/2019 0.006 0.3 7.39 <20 <2.6 <0.51 0.06
7/23/2019 0.069 3.7 4.87 24.00 12.00 1.90 0.10
6/16/2020 0.028 1.5 7.91 <20 <2.6 0.47 <0.005 0.08
12/14/2020 0.022 1.2 6.52 <20 <2.6 0.07 <0.005 0.14
6/21/2021 0.047 2.5 7.14 <20 <2.6 0.42 <0.005 0.15
12/30/2021 0.006 0.3 5.18 40.00 19.00 2.06 <0.005 0.39
7/31/2022 0.017 0.9 7.23 <20 <2.5 0.78 <0.005 0.12
12/15/2022 0.019 1 6.70 <20 4.50 0.16 <0.005 0.13
Total Average 0.684 0.700 0.991 #VALUE! #VALUE! 3.563 #VALUE!
Recent 1 year Average 0.895 0.900 1.079 #VALUE! #VALUE! 4.875 0.923
Benchmark/Limit 6 to 9 120 100 1 30 2

Young, Brianna A
From: Brian Conner <[e-mail]>
Sent: Friday, March 17, 2023 10:37 AM
To: Young, Brianna A
Subject: RE: [External] RE: Avoca Farms— Merry Hill WWTP Stormwater permit NCS000134
Attachments: Avoca Stormwater Oufall Data.xlsx; Avoca Stormwater Map.pdf; Storm Water App.
Response - 2008.doc
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Ms. Young,
Below are the answers to the recent questions you had concerning the Avoca LLC Stormwater Permit renewal:
• Please provide outfall coordinates for all outfalls in either degree or decimal format. The information previously
provided has an unusable format.
I have attached a spreadsheet titled "Avoca Stormwater Outfall Data"which has the coordinates of the
outfalls listed.
• Please provide information on when the landfill onsite closed.
The Manganese Landfill is not located on-site at Avoca.The landfill was established/used and closed by R.J.
Reynolds Company prior to me working at Avoca. It was located on property to the east of the current Avoca
site. I am not exactly sure of the year of closure as it was long before my time (pre-2002).The land where the
landfill was located is no longer owned by Avoca/Ashland. I believe it was sold to Rial Corporation in 2006 to
build a golf course. From what I understand that property has been sold several times since 2006.
• Please provide a site map that has each drainage area outlined with the outfall clearly identified.
Site map is attached.
• Please provide a list of chemicals currently stored onsite.
The attached spreadsheet titled"Avoca Stormwater Outfall Data" has the contents of each building listed. I
also attached a copy of the site's The main chemicals on site are: Hexane, Heptane, Ethanol, and Ethyl
acetate. I can send a copy of out Tier II Inventory report if needed.
• Please provide confirmation of which process buildings and activities are in which drainage areas.The
information previously provided does not specify(it just states process buildings).
The attached spreadsheet titled "Avoca Stormwater Outfall Data" has the buildings in each outfall area listed.
• Please provide more information on outfall SW006. Per information in our permit file history, outfall SWO03 was
previously granted Representative Outfall Status for SW006, but none of the information received to date
mentions this outfall.
I have attached a copy of the 2008 Stormwater Application Response letter that describes outfall#SW006.
Outfall SWO06 was a pipe roof drain that has been filled in and closed since 2008. 1 believe this closure may
have come as a recommendation from DEQ inspector Bill Moore
If there is any more information needed, please do not hesitate to contact me.
1

Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent:Thursday, March 16, 2023 12:32 PM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
***This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.***
Good afternoon,
After reviewing all the information provided, I have some follow-up questions.
• Please provide outfall coordinates for all outfalls in either degree or decimal format.The information previously
provided has an unusable format.
• Please provide information on when the landfill onsite closed.
• Please provide a site map that has each drainage area outlined with the outfall clearly identified.
• Please provide a list of chemicals currently stored onsite.
• Please provide confirmation of which process buildings and activities are in which drainage areas.The
information previously provided does not specify(it just states process buildings).
• Please provide more information on outfall SW006. Per information in our permit file history, outfall SWO03 was
previously granted Representative Outfall Status for SW006, but none of the information received to date
mentions this outfall.
Please let me know if you have any questions on this request.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, INC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
2

From:Young, Brianna A
Sent:Tuesday, March 14, 2023 9:13 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
Brian,
Thank you for providing this information. I will reach out with any questions once I've had a chance to review
everything.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Monday, March 13, 2023 2:14 PM
To:Young, Brianna A<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Dear NCDENR Representative:
Below is the information requested in an email received on March 7, 2023,from Brianna Young concerning the renewal
of Avoca LLC Stormwater Permit No. NCS000134. Most of this information was submitted in November 2019 when the
original permit renewal was due. However, a new permit was never issued, and the site has continued to operate under
the current/previous permit as instructed to do so by NCDEQ.
Please accept this information as requested to fulfill the requirements of the permit renewal process.
Site Name: Avoca LLC/Ashland LLC
Permit No: NCS000134
3

Address: 841 Avoca Farm Road
Merry Hill, NC 27957
SIC Code(s): 2833, 2087
NAICS Code(s): 325411, 311930
Industrial Activity:
The Avoca LLC site performs extractions of botanical (plant) materials.The extractions occur in a variety of equipment
and buildings on site using various solvents to extract specific ingredients or oils from plant materials.The extracts are
used in flavorings, additives,fragrances, and dietary supplements.The sage material is stored in bags or in sheds.All
other botanical materials arrive and are stored in supersacks or tankers/silos.All solvents are stored in tanks within
bermed enclosures.
Stormwater Outfall Information:
Outfalls (5):
001— N—826,792.838 E—2,676,440.763
Lat. =36.001940 Long. =-76.710280
Pipe with drains entering from driveways, parking, and process building roof tops.
002 - N—827,000.000 E—2,676,385.000
Trench/swale with draining driveway and lawn area.
003 - N—827,049.748 E—2,676,376.332
Pipe with drains entering from driveways, parking, and process building roof tops.
004- N—827,868.399 E—2,676,503.241
Pipe from boiler room roof drains.
007 - N—827,508.226 E—2,677,103.800
Pipe with drains entering from driveways, parking, and process building roof tops.
Monitoring Data:
A summary of all Analytical and Qualitative Analysis for each outfall is attached in spreadsheets.
Also, an updated list of the site's Best Management Practices (BMPs) is attached.
Operational Changes since renewal application dated 11/4/2019:
The only operational changes at the site since the submittal of the 2019 Permit Renewal application is with the No. 2
diesel fuel storage area.The 2 Diesel Fuel storage tanks previously enclosed by an earthen berm has now been replaced
by a single double walled above ground storage tank.
Delegation of Signature Authority:
The Stormwater Delegation of Signature Authority (DOSA) form is attached. This form was also submitted via the on-line
method and a hard copy was mailed to: NCDEMLR Stormwater Program, 1612 MSC, Raleigh, NC 27699-1612 as required.
4

eDMR Registration:
The registration for eDMR reporting was completed in December 2019. 1 have attached a copy of the information that
was submitted.
I have attached a copy of the original permit renewal documents that were submitted in November 2019 as well as the
updated information. I also mailed copies of this information. If there is more needed, please do not hesitate to contact
me.
Sincerely,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent: Friday, March 10, 2023 9:19 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
"'This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.-
Good morning,
Next week is fine. Thank you for the quick response.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Friday, March 10, 2023 8:21 AM
5

To:Young, Brianna A<[e-mail]>
Subject: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Ms. Young,
I am working to get this information updated. I should have it all to you early next week if that is OK?
Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From: Young, Brianna A<[e-mail]>
Sent:Tuesday, March 7, 2023 11:36 AM
To: Brian Conner<[e-mail]>
Subject: Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
***This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.—
Good morning,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000134.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action.
I am working on renewing the individual stormwater permit for the Avoca Farms—Merry Hill WWTP
(NCS000134). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity occurring onsite;
• Confirmation on the number of outfalls and associated coordinates;
• Description of industrial activity in each drainage area;
• SIC (NAICS) code;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility,contact information for the permit, and the regulated stormwater outfall(s)for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below,where applicable:
6

• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Georgoulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePayment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, INC 27604
t�: D E '�7'��
cl ;
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
This e-mail contains information which may be privileged,confidential,proprietary,trade secret and/or otherwise legally protected.It is not intended for
transmission to,or receipt by,any unauthorized persons.If you are not the intended recipient,please do not distribute this e-mail.Instead,please delete this e-mail
from your system without copying it,and notify us that you received it in error,so that our address record can be corrected.If you are not the intended recipient
7

you are notified that disclosing,copying,distributing or taking any action in reliance on the contents of this information is strictly prohibited.No waiver of any
applicable privileges or legal protections is intended(and nothing herein shall constitute such a waiver),and all rights are reserved.
8

January 8, 2008
Mr. Robert Patterson
NCDENR-Division of Water Quality
1617 Mail Service Center
Raleigh,NC 27699-1617
Subject: Storm Water Permit Renewal
Outfall Monitoring Questions
Avoca, Inc.
Merry Hill, Bertie County,North Carolina
Permit No. NCS000134
Dear Mr. Patterson,
Avoca, Inc. applied for a Storm Water discharge permit renewal on May 5, 2004. I was
contacted by Mr. Robert Patterson of the NC Division of Water Quality on January 7,
2008 concerning the monitoring records that were submitted with the permit application.
There seems to be some questions about why certain Outfalls have been monitored while
others have not. As the descriptions below will show, a representative sample has been
taken from each Outfall area with some outfalls being grouped together.
The original permit application dated September 30, 1992 grouped several of the outfalls
together for monitoring purposes. The outfalls are grouped as follows:
1) Outfalls #1 and#2 are grouped together and sampled at the location of Outfall#1
due to their close proximity and overlapping of sources.
2) Outfalls #3 and#7 are also grouped together and sampled at Outfall#3 due to the
fact that field verification disclosed that runoff from both areas have the same
characteristics and share the same sources.
3) Outfall#6 is identified as a roof drain with no baseline flow from the pipe and no
process discharges on the roof of the pump house. Therefore outfall#6 was
treated as a roof of a storage area and exempt from the permitting process.
4) Outfall#4 includes storm drainage from some process areas as well as the boiler
room and is sampled.
5) Outfall#5 is a discharge of non-contact cooling water and is covered by NPDES
Permit No. NC0003506.
I have attached a copy of the original permit application as well as other supporting
documentation concerning the grouping of the sampling of the Outfalls. I also have
monitoring records since 1992 that follow the sampling plan as listed in the permit
application. If there are any questions concerning this matter,please contact me. AS
always, Avoca, Inc. wishes to maintain a strong relationship with the Division of Water
Quality to protect our environment.

Sincerely,
Brian Conner
Environmental, Health & Safety Manager
Avoca, Inc.
[phone] ext. 287
[e-mail]

�g
G-
DOS¢.
Wit
O:J3
a e_
� a �
�f aeg 4
4. G
i
6 O=
'An a
m� �•.r gg Rgg
mmm m mm:m:
H��-me
mmmmmmmmmmm 9�
m
�A
�= 2
III p
a�a� � loll
ppppggpp@@pp
In
NOV. I
�= o
o�
N�

Avoca, LLC Stormwater OL
Outfall # Longitude Latitude Drainage Area
1 760 42' 48" 360 3' 05" 4.5
2 760 42' 48" 360 3' 06" N/A
3 760 42' 48" 360 3' 06" 4.2
4 760 42' 44" 360 3' 10" 1
5 760 42' 44" 360 3' 10" N/A
6 760 42' 48" 360 3' 10" N/A
7 760 42' 40" 360 3' 06" 1.4
Avoca, LLC Building [
BUILDING # PURPOSE PROCESS/ USE
1001-10 OFFICE OFFICE
1001-6 OFFICE OFFICE
1001-7 OLD SHIPPING & STORAGE
RECEIVING
1001-1 CONVERSION SCLAREOLIDE PRODUCTION, RECOVERY
PROCESS
1001-4 BOILER ROOM CONTAINS 3 BOILERS
1001-3 OLD PILOT PLANT MATERIAL STORAGE
1001-5 BOILER STORAGE STORAGE
BLDG.
X CONTROLHOUSE
1001-2 ROTOCELL SAGE PROCESSING
1001-11 CROWN 1 VARIOUS BOTANICAL EXTRACTIONS
1003-5 SAGE SHED STORAGE OF FRESH CUT SAGE
1003-7 CHEMICAL STORAGE STORAGE OF CHEMICALS
BLDG.
COOLING TOWER COOLING TOWER CONTROLS AND
CONTROL BLDG. CHEMICAL FEED

1003-2 M-13 VARIOUS EXTRACTION PROCESSES
1004-2 CROWN 2 VARIOUS BOTANICAL EXTRACTIONS
(EXTRACTOR BLDG.)
CROWN 2 PROCESS CONTROLS FOR EXTRACTIONS,
1004-1 (CONTROL/INFEED) FINISHED GOODS, INFEED OF BOTANICAL
MATERIALS
X SCALE HOUSE USED TO WEIGH TRUCKS
1003-9 GUARD HOUSE CHECK-IN STATIONS FOR PLANT SITE
SHIPPING AND
1003-4 RECEIVING, WHITE WAREHOUSE AND PROCESS AREA FOR
BEANS & WATER EXTRACTIONS
WAREHOUSE
1003-10 RECRYSTALLIZATION RECRYSTALLIZATION PROCESS OF
(SFG) SCLAREOL
1003-3 & 6 WASTE WATER TMT. TREATMENT OF PLANT INDUSTIRAL WASTE
1003-1 MAINTENANCE SHOP MAINTENANCE OF PLANT, QUALITY
& QC LAB CONTROL LAB FOR PRODUCTS
1002-16 R & D LAB RESEARCH LAB
1002-15 GREENHOUSE PLANTS FOR R&D
1002-14 OLD LAB SMALL LAB EXPERIMENTS
1005-1 SDE/SFG RECRYSTALLIZATION PROCESS OF
SCLAREOL

Wall Data
Buildings in Drainage Area Comments
1004-1, 1004-2, 1003-3,
1003-4, 1003-6, 1005-1,
1003-10
N/A "Outfall" is a swell/trench that has
very little flow
1001-1, 1001-2, 1001-11,
1003-5, 1003-7, 1003-1
1001-1, 1001-4, 1001-3 Roof drains that are impervious
N/A NPDES Parshall Flume Outfall (NOT
STORMWATER)
N/A CLOSED/ REMOVED
1001-10, 1002-16, 1002-14
)ata
MATERIALS USED/STORED IN AREA
NEW FILTERS, DOCUMENT STORAGE These are not listed in
HEXANE, METHANOL
Do not know what drai
BOILER CHEMICALS, NO.2 FUEL OIL, PROPANE
DRUMMED CHEMICAL STORAGE (HEXANE, ETHANOL,
ETHYL ACETATE, METHANOL), HAZARDOUS WASTE
STORAGE
FIRE SUPPLIES, CLEAN-UP MATERIALS, BOILER
CHEMICALS
HEXANE, SAGE PLANT
VARIOUS SOLVENTS (HEXANE, ETHANOL), RAW
BOTANICAL MATERIALS, AND FINISHED PRODUCTS IN
PROCESS
SAGE (DURING OPERATION)
VARIOUS SOLVENTS IN DRUMS (HEXANE, ETHANOL,
ETHYL ACETATE, METHANOL)
COOLING TOWER CHEMICALS

VARIOUS SOLVENTS (ETHANOL, CHLOROFORM), RAW
MATERIALS, AND FINISHED PRODUCTS IN PROCESS
VARIOUS SOLVENTS (HEXANE, ETHANOL), RAW
BOTANICAL MATERIALS, AND FINISHED PRODUCTS IN
PROCESS
RAW BOTANICAL MATERIALS AND FINISHED PRODUCTS
SCALES
WAREHOUSE FOR FINISHED GOODS & RAW MATERIALS
HEPTANE, ETHYL ACETATE, SCLAREOL
INDUSTRIAL WASTE WATER, WASTE WATER CHEMICALS
TOOLS, PARTS, SMALL QUANTITY LAB CHEMICALS
SMALL QUANTITY LAB CHEMICALS
PLANTS
SMALL QUANTITY LAB CHEMICALS, LAB EQUIPMENT
HEXANE, HEPTANE, ETHYL ACETATE, SCLAREOL

the table above
ingae area in

Young, Brianna A
From: Brian Conner <[e-mail]>
Sent: Monday, March 13, 2023 2:14 PM
To: Young, Brianna A; Georgoulias, Bethany
Subject: RE: [External] RE: Avoca Farms— Merry Hill WWTP Stormwater permit NCS000134
Attachments: 2019 Stormwater Permit Renewal.pdf; Avoca LLC Stormwater DOSA Form.pdf;Avoca
LLC 2023 Stormwater Permit Renewal.pdf, eDMR Registration.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Dear NCDENR Representative:
Below is the information requested in an email received on March 7, 2023,from Brianna Young concerning the renewal
of Avoca LLC Stormwater Permit No. NCS000134. Most of this information was submitted in November 2019 when the
original permit renewal was due. However, a new permit was never issued, and the site has continued to operate under
the current/previous permit as instructed to do so by NCDEQ.
Please accept this information as requested to fulfill the requirements of the permit renewal process.
Site Name: Avoca LLC/Ashland LLC
Permit No: NCS000134
Address: 841 Avoca Farm Road
Merry Hill, NC 27957
SIC Code(s): 2833, 2087
NAICS Code(s): 325411, 311930
Industrial Activity:
The Avoca LLC site performs extractions of botanical (plant) materials.The extractions occur in a variety of equipment
and buildings on site using various solvents to extract specific ingredients or oils from plant materials.The extracts are
used in flavorings, additives,fragrances, and dietary supplements.The sage material is stored in bags or in sheds.All
other botanical materials arrive and are stored in supersacks or tankers/silos.All solvents are stored in tanks within
bermed enclosures.
Stormwater Outfall Information:
Outfalls (5):
001— N—826,792.838 E—2,676,440.763
Lat. =36.001940 Long. =-76.710280
Pipe with drains entering from driveways, parking, and process building roof tops.
1

002 - N—827,000.000 E—2,676,385.000
Trench/swale with draining driveway and lawn area.
003 - N—827,049.748 E—2,676,376.332
Pipe with drains entering from driveways, parking, and process building roof tops.
004- N—827,868.399 E—2,676,503.241
Pipe from boiler room roof drains.
007 - N—827,508.226 E—2,677,103.800
Pipe with drains entering from driveways, parking, and process building roof tops.
Monitoring Data:
A summary of all Analytical and Qualitative Analysis for each outfall is attached in spreadsheets.
Also, an updated list of the site's Best Management Practices (BMPs) is attached.
Operational Changes since renewal application dated 11/4/2019:
The only operational changes at the site since the submittal of the 2019 Permit Renewal application is with the No. 2
diesel fuel storage area.The 2 Diesel Fuel storage tanks previously enclosed by an earthen berm has now been replaced
by a single double walled above ground storage tank.
Delegation of Signature Authority:
The Stormwater Delegation of Signature Authority (DOSA) form is attached. This form was also submitted via the on-line
method and a hard copy was mailed to: NCDEMLR Stormwater Program, 1612 MSC, Raleigh, NC 27699-1612 as required.
eDMR Registration:
The registration for eDMR reporting was completed in December 2019. 1 have attached a copy of the information that
was submitted.
I have attached a copy of the original permit renewal documents that were submitted in November 2019 as well as the
updated information. I also mailed copies of this information. If there is more needed, please do not hesitate to contact
me.
Sincerely,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent: Friday, March 10, 2023 9:19 AM
To: Brian Conner<[e-mail]>
Subject: RE: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
"""This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.—
Good morning,
2

Next week is fine. Thank you for the quick response.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Brian Conner<[e-mail]>
Sent: Friday, March 10, 2023 8:21 AM
To:Young, Brianna A<[e-mail]>
Subject: [External] RE:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Ms. Young,
I am working to get this information updated. I should have it all to you early next week if that is OK?
Thanks,
Brian Conner
EHS Manager
Avoca LLC/Ashland
Email: [e-mail]
[phone]
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, March 7, 2023 11:36 AM
To: Brian Conner<[e-mail]>
Subject:Avoca Farms—Merry Hill WWTP stormwater permit NCS000134
***This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.***
Good morning,
3

The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000134.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action.
I am working on renewing the individual stormwater permit for the Avoca Farms—Merry Hill WWTP
(NCS000134). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity occurring onsite;
• Confirmation on the number of outfalls and associated coordinates;
• Description of industrial activity in each drainage area;
• SIC (NAICS) code;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility,contact information for the permit, and the regulated stormwater outfall(s)for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below,where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Geor og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePUment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
4

NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, INC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
,:,,- D E 'k�'�
kl ;
NORTH CAROLINA -
Department of Environmental quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
This e-mail contains information which may be privileged,confidential,proprietary,trade secret and/or otherwise legally protected. It is not intended for
transmission to,or receipt by,any unauthorized persons.If you are not the intended recipient,please do not distribute this e-mail.Instead,please delete this e-mail
from your system without copying it,and notify us that you received it in error,so that our address record can be corrected.If you are not the intended recipient
you are notified that disclosing,copying,distributing or taking any action in reliance on the contents of this information is strictly prohibited.No waiver of any
applicable privileges or legal protections is intended(and nothing herein shall constitute such a waiver),and all rights are reserved.
5

Avoca,LLC
Pa Box 129
841 Avoca Farm Rd
Avoca, LLC Meri-y Hill,NC 27957
C� -- Phone• 252-482-2133
The World's Premier Botanical Extraction Company Fax: [phone]
March 13,2023
NCDENR
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
1612 Mail Service Center
Raleigh, NC 27604
Subject: Stormwater Permit No. NCS000134 Permit Renewal
Avoca LLC--Bertie County North Carolina
Dear NCDENR Representative:
Below is the information requested in an email received on March 7, 2023, from Brianna Young
concerning the renewal of Avoca LLC Stormwater Permit No. NCS000134. Most of this information was
submitted in November 2019 when the original permit renewal was due. However,a new permit was
never issued, and the site has continued to operate under the current/previous permit as instructed to
do so by NCDEQ.
Please accept this information as requested to fulfill the requirements of the permit renewal process.
Site Name: Avoca LLC/Ashland LLC
Permit No: NCS000134
Address: 841 Avoca Farm Road
Merry Hill, NC 27957
SIC Code(s): 2833,2087
NAICS Code(s):325411, 311930
Industrial Activity:
The Avoca LLC site performs extractions of botanical (plant) materials.The extractions occur in a variety
of equipment and buildings on site using various solvents to extract specific ingredients or oils from
plant materials.The extracts are used in flavorings, additives, fragrances, and dietary supplements. The
sage material is stored in bags or in sheds.All other botanical materials arrive and are stored in
supersacks or tankers/silos. All solvents are stored in tanks within bermed enclosures.

Stormwater Outfall Information:
Outfalls (5):
001-- N—826,792.838 E—2,676,440.763
Lat. = 36.001940 Long. _-76.710280
Pipe with drains entering from driveways, parking, and process building roof tops.
002- N—827,000.000 E—2,676,385.000
Trench/swale with draining driveway and lawn area.
003 - N—827,049.748 E—2,676,376.332
Pipe with drains entering from driveways, parking, and process building roof tops.
004- N—827,868.399 E—2,676,503.241
Pipe from boiler room roof drains.
007- N—827,508.226 E--2,677,103.800
Pipe with drains entering from driveways, parking, and process building roof tops.
Monitoring Data:
A summary of all Analytical and Qualitative Analysis for each outfall is attached in spreadsheets.
Also, an updated list of the site's Best Management Practices (BMPs) is attached.
Operational Changes since renewal application dated 11/4/2019:
The only operational changes at the site since the submittal of the 2019 Permit Renewal application is
with the No. 2 diesel fuel storage area.The 2 Diesel Fuel storage tanks previously enclosed by an
earthen berm has now been replaced by a single double walled above ground storage tank.
Delegation of Signature Authority:
The Stormwater Delegation of Signature Authority(D05A)form is attached. This form was also
submitted via the on-line method and a hard copy was mailed to: NCDEMLR Stormwater Program, 1612
MSC, Raleigh, NC 27699-1612 as required.
eDMR Registration:
The registration for eDMR reporting was completed in December 2019. 1 have attached a copy of the
information that was submitted.

I have attached a copy of the original permit renewal documents that were submitted in November
2019 as well as the updated information. If there is more needed, please do not hesitate to contact me.
Sincerely,
Brian Conner
EFTS Manager
Avoca LLC

NPDES Permit Enter your NPDES stormwater permit number or Certificate of Coverage(COG)number
Number* NCS000134
Begins with NCS, NCG,or NCGNE(no exposEire)
Facility Name* Avoca LLC
(Used to verify permit number)
Check permit contact information for your permit by running a Stormwater Permit Summary Report.
Guidance for COC holders: Do not enter the General Permit number with all 0's (for example, NCG030000) but
instead your Certificate of Coverge (COC) number.
Check all that Owner Affiliation (Legally Responsible Individual) Update
apply:* Permit Ownership Transfer or Facility Name Change
Delegation of Signature Authority (DOSA)
Permit Contact Update
Billing Contact Update
Facility Contact Update
Other Contact Update
Permit Contact Update
Provide new permit contact information
This person should REPLACE the current permit contact.
This person should just be added as another permit contact.
New Contact Name* First and Last Name
Brian M. Conner
Email Address* [e-mail]
Phone No.* 1-252-482-2133
Mailing Address* PO Box 129
Merry Hill, NC 27957

Physical Address If different than mailing address
841 Avoca Farm Road
Merry Hill, NC 27957
Add another permit contact if needed by clicking the'Add'button below
Billing Contact Update
Provide new I)illing contact information
Note: This person will REPLACE the current billing contact. We can only designate one billing contact in our
permitting database.
New Contact Name's First and Last Name
Brian M. Conner
E-mail Address` [e-mail]
Phone No.* 1-252-482-2133
Mailing Address* PO Box 129
Merry Hill, NC 27957
Physical Address If different than mailing address
841 Avoca Farm Road
Merry Hill, NC 27957
Facility Contact Update
Provide new facility contact information
This person should REPLACE the current facility contact.
This person should just be added as another facility contact.
New Contact Name First and Last Name
Brian M. Conner
E-mail Address* [e-mail]
Phone No.* 1-252-482-2133
Mailing Address* PO Box 129
Merry Hill, NC 27957

Physical Address If different than mailing address
841 Avoca Farm Road
Merry Hill, NC 27957
Add another facility contact if needed by clicking the'Add'button below
Person(s) with Delegation of Signature Authority (DOSA)
Complete and sign this Stormwater Permit Delegation of Signature Authority Form Then upload it below. We can
begin making updates with this submittal, but please note that you must mail in the original signed copy to our
office in accordance with requirements in 40 CFR 122.22.
Mail the hard copy to. DEMLR Stormwater Program (Attn: Stormwater Program Administrative Specialist), 1612
MSC, Raleigh, NC 27699-1612
Delegation of Please upload the signed"Stormwater Permit Delegation of Signature Authority Form"
Signature Authority* Avoca LLC Stormwater DOSA Form.pdf 626.77KB
pdf only
Submitter's Name* Please enter your FIRST and LAST name
Brian M. Conner
Phone Number` Please enter your phone number
252-482-2133
Any format 3s fine
Email Address* Please enter a valid e-mail address
[e-mail]
A confirmation of submission will be e-mailed to this address
* By checking the box and signing below, I certify that
I have given true, accurate, and complete information on this form;
I agree that submission of this form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the
"Uniform Electronic Transactions Act");
I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes
(the "Uniform Electronic Transactions Act");
I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written
signature (except for any uploaded Owner Affiliation Change or Delegation of Signature of Authority forms, which
also must be mailed in with original signature);AND
intend to electronically sign and submit this Permit Contact Update Request form

Signature*
,kJ� (7// �rrft
Date 3/13/2023
Questions? Contact [e-mail].

Avoca, LLC Storm Water Analytical Monitoring Results
Permit No. NCS000134
Outfall#:001
Sample Date Total Flow Total Rainfall PH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
12/22/2015 0.052 0.7 768 650 127.0 14.40 2.78
6/23/2016 0.155 2.1 7.17 51.0 142.0 2.77 0.51
12/19/2016 0.088 12 7.14 86.0 23.0 3.31 0.86
6/20/2017 0.096 1.3 6.79 49.0 41.0 2.31 0.77
1/23/2018 0.015 0.2 764 496.0 125.0 12.40 4.02
1/4/2019 0.022 0 3 7.51 142.0 105.0 1.90 0.56
7/23/2019 0.273 3.7 497 61.0 123.0 4.45 0.70
6/16/2020 0.111 15 750 47.0 28.0 3.04 1.26
12/14/2020 0 088 1.2 608 2400 302.0 5.25 2.91
6/21/2021 0.184 2.5 6.76 56.0 16.0 1.74 039
12/30/2021 0.022 0.3 5.18 40.0 19.0 1 206 039
7/31/2022 0.066 0.9 6.96 440 23.0 1.35 047
12/15/2022 0.074 1 7.40 260 36 0 0.74 0.32
Average 0.096 1.3 6.83 107.9 1 85.4 4.29 1.23

Avoca, LLC Storm Water Analytical Monitoring Results
Permit No. NCS000134
Outfall##:003
Sample Date Total Flow Total Rainfall pH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
8/8/2015 0.046 0.7 8.59 64.0 3.6 4 73 0.65
8/31/2015 0.039 0 6 6.73 725.0 36.0 1 1735 6.74
9/25/2015 0.117 1.8 4 47 4229.0 69.0 2373 7.68
10/28/2015 0.033 0.5 696 318.0 18.0 1.72 1.04
11/19/2015 0 078 1.2 663 498.0 1340 11.22 2.86
12/25/2015 0.046 0.7 6.62 1149.0 90.0 43.66 5.98
2/4/2016 0.143 2.2 6.85 3440 102.0 5.53 1.59
2/16/2016 0.072 1.1 7.03 2170 273.0 5.76 1.31
3/28/2019 0.091 14 7.60 2710 19.0 6.17 2.10
5/3/2016 0.052 0.8 7.09 218.0 57.0 6.10 1.56
6/7/2016 0.078 12 7.02 196.0 169.0 5.21 1.24
6/23/2016 0.137 2.1 7.14 340.0 233.0 515 1.44
7/19/2016 0.065 1 6.73 206.0 9 7 7.54 0.94
8/8/2016 0.13 2 7.74 950 77.0 1.75 0.67
9/19/2016 0.072 1.1 8.01 28000 49.0 3.94 0.71
11/4/2016 0.052 0.8 6.58 240.0 19.0 645 2.70
11/14/2016 0.02 0.3 691 482.0 340 1225 098
12/19/2016 0.078 12 6.81 95.0 28 0 8.79 2 03
1/23/2017 0.039 0 6 6.93 1710 21.0 3.81 2.47
2/8/2017 0 039 0.6 7.16 17700 353.0 35.80 1276
3/31/2017 0 091 1.4 671 10800 153.0 1836 20.46
4/24/2017 0.15 2.3 651 59.0 5.2 7 67 0.64
5/23/2017 0.111 1.7 661 250.0 7.4 5 23 2.60
6/20/2017 0.085 1.3 662 251.0 48.0 6.41 224
7/17/2017 0.098 1.5 7.10 2760 570 6.52 263
8/8/2017 0.052 0.8 7.54 1680 20.0 4.76 15.48
10/10/2017 0.033 0.5 6.93 9570 59.0 19.72 876
10/29/2017 0.072 1.1 7.81 328.0 19 0 7.15 402
12/6/2017 0.023 035 7.70 522.0 1150 15.86 4 58
1/23/2018 0.013 0.2 7.71 351.0 101.0 851 2.88
1/23/2018 0.013 0.2 771 324.0 100.0 1057 2.92
2/28/2019 0 033 0 5 7.64 266.0 480 9.16 544
3/12/2018 0 065 1 7.13 2830 420 6.00 3.35
4/24/2018 0.085 1.3 7.06 2170 14.0 531 1.95
5/18/2018 0.039 0.6 7 07 515.0 460 6.13 5.55
9/IS/2018 0.137 2.1 7.60 26.0 6 9 1.09 0.25
9/16/2018 0,13 2 7.52 280 6 1 1.08 0.25
10/11/2018 0.065 1 699 4420 26.0 14 86 5.58
11/15/2018 0.065 1 7.51 4620 1330 12.14 340
1/4/2019 0.02 0.3 746 610 58 0 3.07 1.54
2/11/2019 0.065 1 7 42 595 0 83.0 1694 6.21
2/11/2019 0 065 1 7.42 701.0 93.0 1669 5.91
3/26/2019 0.033 0.5 667 410 17.0 3.03 0.38
4/9/2019 0.15 2 3 9.24 179.0 19.0 705 2.57
6/5/2019 0 039 0.6 7.65 3920 45.0 11.05 2.28

Sample Date Total Flow Total Rainfall pH COD TSS Total Nitrogen phosphorus
Million Gal. inches mg/L mg/L mg/L mg/L
7/23/2019 0.241 3.7 5.10 276.0 48.0 8.05 1.85
2/7/2020 0.265 3.6 7.01 188.0 393.0 6.65 0.02
2/19/2020 0.022 0.3 6.10 94.0 25.0 5.06 1.00
3/23/2020 0.066 0.9 7.21 211.0 35.0 1306 2,64
4/13/2020 0.033 0.5 648 3050 95.0 8.10 3,02
5/19/2020 0.033 0.5 847 3340 63.0 7.25 3,52
6/16/2020 0.098 1.5 7.22 12900 349.0 19.99 11.06
8/10/2020 0 039 0.6 574 823.0 206.0 12.45 5,20
9/9/2020 0 078 1.2 7 51 455.0 44.0 14.47 5.40
9/29/2020 0.104 1.6 4.72 1260.0 1360 21.46 8.90
10/30/2020 0.013 0.2 7.10 61.0 620 350 0.75
11111/2020 0.339 5.2 4 54 1210.0 3180 29 68 6.34
12/14/2020 0.078 12 6.21 437.0 400 13.22 4.72
1/31/2021 0 085 13 6.22 1630 15 0 6.88 192
2/18/2021 0.111 17 7.15 465.0 540 8.52 3.08
3/16/2021 0 065 1 7.66 356.0 550 12.61 276
5/30/2021 0 156 2.4 4.82 2470 46.0 6.93 294
5/31/2021 0 156 2.4 4 82 247.0 46.0 6.93 294
6/21/2021 0,163 2.5 768 307.0 48.0 7.47 278
7/19/2021 0.052 0.8 471 756.0 32.0 12.76 4.55
9/22/2021 0.02 0 3 7,17 134.0 1140 3.86 0.80
9/23/2021 002 0 3 7.95 165.0 2980 5.74 1.02
10/29/2021 0 013 0 2 5.03 5.1 740 944 4.63
11/22/2021 0.033 0.5 8.02 594.0 61.0 14.14 673
12/30/2021 0.02 0.3 5.12 42.0 17.0 1.45 0,36
2/24/2022 0.007 0.1 6.10 507.0 210 762 3.25
3/9/2022 0.078 1.2 4.08 441.0 240 1138 5.13
4/18/2022 0.072 1.1 7.69 13600 225.0 14.77 7 12
5/13/2022 0.059 0.9 837 894.0 474.0 40.00 3.26
7/31/2022 0.059 0 9 701 63,0 18.0 2.64 088
7/31/2022 0.059 0 9 701 63.0 19 0 2 64 0.78
8/16/2022 0.046 0.7 7.23 105 0 14.0 3.29 0.76
9/30/2022 0.411 6.3 6.49 360 19.0 1.17 039
11/1/2022 0.039 0.6 645 340 25,0 1.98 0 28
11/30/2022 0.039 0.6 781 88.0 37.0 4 50 1 0.58
12/15/2022 0.065 1 7.20 <20 12 0 0.74 0.36
1/22/2023 0.059 0.9 6.27 350 3.9 13.38 0.59
Average 0.08 1.20 1 6.87 459.9 81.5 9.81 3.43

Avoca, LLC Storm Water Analytical Monitoring Results
Permit No. NCS000134
Outfall#:004
Sample Date Total Flow Total Rainfall pH COD TSS Total phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
12/22/2015 0.013 0.7 664 <20 <2.8 0.57 <0.04
6/23/2016 0,039 2.1 682 <20 6.80 0.72 007
12/19/2016 0.022 12 702 <20 <2.7 015 0 18
6/20/2017 0.024 1.3 6.95 20.00 <2.6 0 52 0.08
1/23/2018 0.004 0.2 7.76 24.00 <3.1 1.57 0.14
1/4/2019 0.006 0.3 7.39 <20 <2.6 <0.51 0.06
7/23/2019 0 069 3 7 4.87 24.00 1200 1 1.90 0.10
6/16/2020 0.028 1.5 7.91 <20 <2 6 0.47 0.08
12/14/2020 0.022 1.2 6.52 <20 <2.6 007 0.14
6/21/2021 0.047 2.5 7.14 <20 <2.6 0.42 0.15
12/30/2021 0.006 0 3 518 40.00 1900 2.06 0.39
7/31/2022 0.017 0.9 7.23 <20 <2.5 078 0 12
12/15/2022 0 019 1 6.70 <20 4.50 0.16 0 13
Average 0.684 0.700 0.991 #VALUE! #VALUE! 3.563 #VALUE!

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 001
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5.1 is very clear or none present to 5 is high
or covered.
Floating Suspended
"Samplee Color Odor Clarity Foam? Oil Sheen? Erosion?
Solids Solids
(1-5) (1-5) (1-5) Yes/ No Yes/No Yes/No
Light
12/22/2015 Brown None 3 2 2 No No No
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Light None 2 2 1 No No No
Brown
7/23/2019 Light Gray None 2 2 1 No No No
6/16/2020 Clear None 1 2 1 No No No
12/14/2020 Clear None 2 1 1 1 No No No
6/21/2021 Lightbrown None 2 1 1 No No No
12/30/2021 Clear None 1 1 1 No No No
7/31/2022 1 Light None 1 1 1 No No No
Brown
12/15/2022 Clear None 1 1 1 No No No

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 002
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating SuspendedSolids Solids Foam? Oil Sheen? Erosion?
(1-5] (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 Light
Brown None 1 1 1 No No No
6/23/2016 Light None 1 1 1 No No No
Brown
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 2 1 No No No
6/16/2020 Clear None 1 1 1 No No No
12/14/2020 Clear None 1 1 1 No No No
6/21/2021 Clear None 1 2 1 No No No
12/30/2021 Clear None 1 2 1 No No No
7/31/2022 Clear None 1 2 1 No No No
12/15/2022 1 Clear None 1 2 1 No No No

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
outfall #: 003
The scale for Clarity, Floating Solids,and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Floating Suspended
"Samplee Color Odor Clarity Solids Solids Foam? Oil Sheen? Erosion?
[1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
8/8/2015 Gray None 3 2 2 No No No
8/31/2015 Light None 2 1 1 No No No
Brown
9/25/2015 Light Gray None 2 2 1 No No No
10/28/2015 Light None 2 1 1 No No No
Brown
11/19/2015 Light Gray None 2 1 1 No No No
12/25/2015 Gray None 3 2 2 No No No
2/4/2016 Light Gray None 2 2 1 No No No
2/16/2016 Light Gray None 2 2 1 No No No
3/28/2019 Light Gray None 2 2 1 No No No
5/3/2016 Light Gray None 2 2 1 No No No
6/7/2016 Light Gray None 2 2 1 No No No
6/23/2016 LightBrown None 2 2 1 No No No
7/19/2016 Light None 1 1 1 No No No
Brown
8/8/2016 Clear None 1 2 2 No No No
9/19/2016 Clear None 1 1 1 No No No
11/4/201.6 Light Gray None 1 1 1 No No No
11/14/2016 Light Gray None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
1/23/2017 Light Gray None 1 1 1 No No No
2/8/2017 Gray None 3 1 1 No No No
3/31/2017 Light Gray None 2 2 1 No No No
4/24/2017 Clear None 1 1 1 No No No
5/23/2017 Clear None 1 1 1 No No No

Floating Suspended"Samplee Color odor Clarity Solids Solids Foam? oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/ No Yes/No
Light
6/20/2017 Brown None 2 2 2 No No No
7/17/2017 Light BrownNone 3 1 2 No No No
8/8/2017 Light BrownNone 2 3 1 No No No
10/10/2017 Light BrownNone 2 1 1 No No No
10/29/2017 Clear None 1 1 1 No No No
12/6/2017 Brown None 4 1 4 No No No
Light
1/23/2018 Brown None 2 1 1 No No No
1/23/2018 LightBrown None 2 1 1 No No No
2/28/2018 LightBrown None 2 2 1 No No No
3/12/2018 Clear None 2 1 1 No No No
4/24/2018 Clear None 1 1 1 No No No
5/18/2018 Light BrownNone 2 1 1 No No No
9/15/2018 Light Gray None 2 2 2 No No No
9/16/2018 Clear None 1 1 1 No No No
10/11/2018 LightBrown None 2 2 2 No No No
11/15/2018 Light Gray None 2 2 2 No No No
1/4/2019 Clear None 1 2 1 No No No
2/11/2019 Light BrownNone 2 1 1 No No No
2/11/2019 LightBrown None 2 1 1 No No No
3/26/2019 Light Gray None 2 1 1 No No No
4/9/2019 Light BrownNone 2 1 1 No No No
6/5/2019 LightBrown None 2 3 2 No No No
7/23/2019 Light Gray None 2 2 2 No No No
7/23/2019 Light Gray None 2 2 2 No No No
2/7/2020 Light Gray None 2 2 2 No No No

"Sample Floating Suspended e Color Odor Clarity Foam? Oil Sheen? Erosion?
Solids Solids
(1-5) (1-5) (1-5) Yes/No Yes/ No Yes/ No
2/19/2020 Clear No 1 1 1 No No No
3/23/2020 Clear None 1 1 1 No No No
4/13/2020 Light Grey None 1 2 1 No No No
5/19/2020 Light Grey None 2 1 1 No No No
6/16/2020 Clear None 1 2 1 No No No
8/10/2020 Light
}gown None 2 3 2 No No No
9/9/2020 Light brownNone 2 1 1 No No No
9/29/2020 Light grey None 2 1 1 No No No
10/30/2020 Light grey None 2 1 1 No No No
11/11/2020 Light grey None 2 2 2 No No No
12/14/2020 Clear None 2 1 1 No No No
1/31/2021 Clear None 1 1 1 No No No
2/18/2021 Clear None 1 1 1 No No No
3/16/2021 Clear None 1 1 1 No No No
5/30/2021 Clear None 1 2 1 No No No
5/31/2021 Clear None 1 2 1 No No Na
6/21/2021 Lightbrown None 2 1 1 No No No
7/19/2021 Lightbrown None 2 1 1 No No No
9/22/2021 Clear None 1 2 1 No No No
9/23/2021 Clear None 1 2 1 No No No
10/29/2021 Clear None 1 1 1 No No No
11/22/2021 Clear None 1 1 1 No No No
12/30/2021 Clear None 1 2 1 No No No Light
2/24/2022 brown None 2 1 1 No No No
3/9/2022 Light brownNone 2 1 1 No No No
4/18/2022 Light brownNone 2 1 1 No No No
5/13/2022 Light Gray None 2 2 1 No No No
7/31/2022 Clear None 1 1 1 No No No
8/16/2022 Clear None 1 1 1 No No No
9/30/2022 Clear None 1 1 1 No No No
11/1/2022 Clear None 1 1 1 No No No
11/30/2022 Clear None 1 1 1 No No No
12/15/2022 Clear None 1 1 1 No No No
1/22/2023 Clear None 1 1 1 No No No

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 004
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Sample Rate Color Odor Clarity Solids Solids Floating Suspended Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/ No Yes/ No Yes/No
12/22/2015 Clear None 1 1 1 No No No
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 1 1 No No No
6/16/2020 Clear None 1 1 1 No No No
12/14/2020 Clear None 1 1 1 No No No
6/21/2021 Clear None 1 1 1 No No No
12/30/2021 Clear None 1 1 1 No No No
7/31/2022 Clear None 1 1 1 No No No
12/15/2022 Clear I None 1 1 1 No No No

Avoca, LLC Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 007
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Floating Suspended
Sample Date Color Odor Clarity Solids Solids Foam? Oil Sheen? Erosion?
( -5) (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 Clear None 2 1 1 No No No
6/23/2016 Clear None 2 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 2 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Light Gray None 2 2 1 No No No
6/16/2020 Light Gray None 2 2 1 No No No
12/14/2020 Clear None 1 1 1 No No No
6/21/2021 Clear None 1 1 1 No No No
12/30/2021 Clear None 1 1 1 No No No
7/31/2022 Clear None 1 1 1 No No No
12/15/2022 Clear None 1 1 1 No No No

BEST MANAGEMENT PRACTICES (BMPs)
AVOCA, LLC
Starmwater Permit No, NCS0001.34
BMP 1 - Containment Berms: Avoca, LLC has spill containment berms installed
around each of its fuel, solvent, and other processing tanks. These berms are large enough
to hold the total capacity of at least one of the contained tanks plus a minimum of 10%.
The following is a listing of the containment areas and their locations:
1) No. 2 Fuel Oil Storage and Unloading, West of Building 1001-2
2) Gasoline Storage and Unloading, North of Building 1004-2
3) Emergency Generator Fuel Storage, South of Building 1004-1
4) Emergency Generator Fuel Storage, South of Building 1001-1
5) Hazardous Waste Storage, Building 1003-5
6) Tank Farm, North of Building 1001-1
7) Tank Farm, South of Building 1001-1
8) Unloading Station, South of Building 1001-2
9) Sclarcol Recrystallization& Storage tanks, Building 1003-10
10)Chemical Storage, 1003-7
11) Botanical Extraction Process & Storage tanks, North of Building 1001-11
12) Biomass Extraction Process & Storage tanks, Building 1004-2
13)Sclareolide and Sclareol Reclystallization Process & Storage tanks, Building
1005-1
BMP 2 - Weekly monitoring of all areas listed in BMP 1: Monitoring includes
inspection of equipment and tanks within containments as well as all areas of the facility.
The operational status of the processes, housekeeping and cleanliness, condition of
equipment and tanks, and notification of spills and leaks are noted as well as any
corrective actions taken.
BMP 3 - Annual monitoring of the areas listed in BMP 1: Monitoring includes in
depth inspection of equipment and tanks within containments as well as all areas of the
facility. Parameters of inspection include: housekeeping and cleanliness, operating
condition of equipment, evidence of spills and/or leaks, stormwater conveyance (i.e.
condition of valves, flow channels,etc...),erosion evidence, actions required to remedy
any problems, and the date the problem was resolved.
BMP 4 - Monitor berm contents: Avoca, LLC keeps its spill containment berm drains
closed and locked. All pumps and valves are capped when not in use. The berms are
either drained by the boiler operator or pumped to Avoca's Tertiary Lagoon. All rain
water is inspected before it is drained to determine if there it has oil sheen or other

contaminates. In the case of a spill, the berms can be pumped out with a suction tanker or
either directly pumped to Avoca's Waste Water Treatment facility. The spilled liquid can
be either treated and disposed of or reused.
BMP 5 - Hazardous waste storage: All hazardous waste is stored in a concrete dike area
with a protective roof covering the containment. There are signs stating that Hazardous
waste is to be stored in this area only.
BMP 6 -Analytical Monitoring: Analytical monitoring of stormwater runoff is
performed as stated in Stormwater Permit No. NCS000134. Analytical monitoring of
outfalls #001, #003, and #004 is performed quarterly and outfall 4003 is monitored
monthly. The temperature and pH are recorded at the time of sampling. The samples are
put on ice and sent to Environment 1 located in Greenville,NC where they are analyzed
for Nitrogen, Phosphorous, Total Suspended Solids, COD, and pH. The analytical
monitoring results are kept at Avoca, LLC and sent to NCDENR within 30 days of
receiving the results from Environment 1.
BMP 7- Qualitative Monitoring: Qualitative monitoring of Stormwater Runoff is
performed as stated in Stormwater Permit No. NCS000134. Qualitative monitoring of
outfalls##001,4002,4003,4004, and#007 is performed twice annually. Outfall 4005 is
not monitored under the stormwater permit as it is covered under a separate NPDES
permit. The qualitative results are kept on file at Avoca, LLC.
BMP 8 - Training: Training of all Avoca, LLC personnel occurs annually. Employees
are trained in the safe handling of chemicals, spill prevention of chemicals, location of
shutoff valves, who to contact in case of a spill, location of containment equipment, and
operation and maintenance of containment equipment.
BMP 9—Spill Clean-Up: Hazardous waste clean-up and major Spills are handled be an
outside contractor. AVOCA, LLC has a contract with Eastern Environmental
Management, located in Rocky Mount,NC to handle all it's major spill incidents.
BMP 10 --Covered Waste: All waste drums for scrap metal are to be covered until the
drums are inspected to be empty. Drums are then crushed and placed in the metal
recycling bins for recycling. All other waste materials are disposed of in waste containers
that have roofs or are staged under a covering.

pa er
ROY COOPER
Governor
ELIZABETH S.BISER
Secretary v,� r
DOUGLAS It.ANSEL NORTH CAROLINA
Interim Director Environmental Quality
Stormwater Delegation of Signature Authority Form (DOSA)
This form shall be used to delegate signature authority from the permit Owner (Permittee) to
another party. Only the Responsible Official defined below may submit permit applications and
reports required by the permit (such as Data Monitoring Reports and Annual Reports) until this
form is completed and submitted to the DEMLR Stormwater Program. Please note that delegating
signature authority does not relieve the Permit Owner from the responsibility and compliance for
permit compliance.
Permit Owner:The legal entity to which/whom a permit has been issued and may be an individual
or an organization such as a company or government agency. Every Owner is required to have a
Responsible Official who meets the legal signature authority requirements in 40 CFR 122.22,
summarized below:
• For a corporation,the Responsible Official shall be a president,secretary,treasurer,or vice president
in charge of a principal business function,or another individual who performs similar functions for
the corporation,or the manager of one or more manufacturing,production,or operatingfacilides
who is authorized to make management decisions about the facility operation.
• For a partnership or sole proprietorship,the Responsible Official shall be a general partner or the
proprietor,respectively;or
• For a municipality,State,Federal,or other public agency,the Responsible Official shall be either a
principal executive officer[City/County Manager]or ranking elected official[Mayor].
Please mail the DOSA Form with original wet signatures to: NCDEMLR Stormwater
Program, 1612 MSC,Raleigh, NC 27699-1612
Name of Organizational Entity Av®C, LLC
Responsible Official Name
Responsible Official Title: `-
Email Address: T + Phone
c�u�S.�2�ri�p'�r1�Otb►1 �COrh ��`�-t#�32..�'�►33
Mailing Address Pp 90-A %29
City t4e" \-'k"%1 State �� Zip code 2-19 -7
Noroi Carolina Department of Cnvironinental Quality I Division of rner9y,Mineral and Land Resources
512 North Salisbury Street 11612 Mail service Center I Ralei9li,Nortli Carolina 27699-1612
fiSNitTf l:iFx1LA:A
nw.irruio : 919707.9200

A. Persons to Receive Signature Authority
The signatures of the persons listed below indicates their acceptance of signatory authority.
Attach additional pages if you need more space.
Delegated Party Name V- M.
Delegated Party Title 'E"S m &,
Permit Number(s) m C-S 00® 19 LL
Email Address: 1 Phone 492z I13 9
wkan• C=Orlvgev- OLSk IUVV(.CU
MailingAddress P® gox
City, State Zip code -J-Jc°�5�7
Signature of Delegated Party
indicating acceptance of
Signatory Authority: ! r J
Date
Delegated Party Name
Delegated Party Title
Permit Number(s)
Email Address; Phone
MailingAddress
city State Zip code
Signature of Delegated Party
indicating acceptance of
Signatory Authority:
Date
Delegated Party Name
Delegated Party Title
Permit Number(s)
Email Address: Phone
MailingAddress
city State Zip code
Signature of Delegated Party
indicating acceptance of
Signatory Authority:
Date
Stormwater Permit Delegation of Signatory Authority Form
Page 2

B. Responsible Official Signature
The Responsible Official, as identified in accordance with 40 CFR 122.22, is the appropriate
individual with the authority to sign and submit reports for the organization.
As the Responsible Official,1, �" `��'�°�v S C'eg'�%`'11 SCVI (printed name),
have the authority to enter into this Agreement for
PIOC& Lam __ _ (Owner/Organization Name).
I request that the DEMLR Stormwater Program include the persons listed in Part A of this
form signatory authority for the above-named permit.
I acknowledge that 1,and the persons listed in Part A of this form work at/for my
organization and have authority to act as a signatory for purposes of the NCDEQ's
electronic document Systems.
By submitting this application,I, AjqvSk,v_`Wc(enr. (printed name),have read,
understand,and accept the terms and conditions of the stormwaterpermit(s) for which I
am the Responsible Official.
Responsible ic' Signature
V'r'�Sacv- 3 -
Title Date
Stormwater Permit Delegation of Signatory Authority Form
Page 3

Avoca,LLC
PO Box 129
V
y c� 841 Avoca Farm Rd
OL� ca, LLC Merry Hill,ACC 27957
Phone: [phone]
The World's Premier Botanical Extraction Company Fax:[phone]
f
February 21, 2020
RE: Delegation of Signatory Authority for Environmental, Health,&Safety Reports and Documents l
To Whom it may Concern:
i
As President of Avoca LLC, I duly authorize the EHS Manager of Avoca LLC to sign,certify, and submit all
reports,applications, notifications,and other documents associated with the below referenced permits
and reports for the 3 Avoca sites located at Merry Hill, SIC,Summerville, SC, and Menomonee Falls,WI:
Air Quality—Annual Compliance Certifications,SARA 313 R Annual Reports,Annual Emissions Inventory
Reports,Semi-Annual Reports,Semi-Annual MON Reports,Semi-Annual Boiler Reports, Periodic
Equipment CEDRI Reports
RATF—Annual Alcohol User Report
EPA—Annual Pesticide Producer Report
Wastewater Treatment—Monthly Reports, Quarterly Groundwater Monitoring Reports,Annual Lab
Certification
Stormwater—Monthly Reports,Quarterly Reports
Hazardous Waste—Biennial Hazardous Waste Report
Tier 11-Annual Report
OSHA—Annual 300 Log
1
Our current EHS Manager is Brian Conner,who can be contacted with any questions at(252)482-2133.
Sincerely,
Augustinus Gerritsen
President
Avoca LLC

eDMR Owner Verification Report
Permit No. : NCS000.134 Version: 3.00 Permt Status: Expired
Owner/Permittee : Avoca LLC
Owner/Permittee PO Box 129
Address: Merry Hill, NC 279570129
Responsible Official: Augustinus Gerritsen
Resp. Official Title: VP
Facility Name : Avoca - Merry Hill WWTP
Facility Address: 841 Avoca Farm Rd
Merry Hill, NC 27957
Registered for eDMR? : Yes
Page#: 1
Date: 311312023

NC Department of Environmental Quality
1
Division of Energy, Mineral and Land Resources
NORTH CAROLINA
-rnvlronmcntnt QuQRly
Stormwater eReporting Registration Form
Completion of the Stormwater Electronic Reporting (eReporting) Registration Form is a required
step for the Owner to obtain the privilege of submitting electronic reports to DEQ and in lieu of
submitting paper reports.
In addition, this form allows for Owners to designate Responsible Officials and Facility
Administrators who can act on their behalf.
A. Owner Information
The Owner is the legal entity to which/whom permits have been issued. The Owner may be an
individual or organization. Every Owner is required to have a Responsible Official who meets
the legal signature authority requirements in 40 CFR 122.22,
• For a corporation, this individual shall a president, secretary, treasurer, or vice-president in
charge of a principal business function, or another individual who performs similar functions
for the corporation, or the manager of one or more manufacturing, production, or operating
facilities who is authorized to make management decisions about the facility operation.
• For a partnership or sole proprietorship, this individual shall be a general partner or the
proprietor, respectively; or
• For a municipality, State, Federal, or other public agency, this individual shall be either a
principal executive officer or ranking elected official.
Owner Name. Avoca, LLC
Responsible Official Name- Augustinus Gerritsen Title: President
Does the Responsible Official p Yes El No If Iles,
already have an eDMR account? User 11),
Email Address: [e-mail] Phone: [phone]
Mailing Address. P.O. Box 129
City: Merry Hill State: N( zfp: 27957
Stormwater Electronic Reporting Registration Form
Page 1

B. Permit Information
Include all stormwater permit currently held by the Owner(both Individual and General permits).
Designate any persons to be designated as Facility Administrators for each permit. Include all
persons to have Facility Administrator privileges in the same box. Attach additional pages if you
need more space.
Permit No, Facility Name Facility Address
Facility Administrator(s)
if applicable)
NCS000134 Avoca, LLC 841 Avoca Farm Road,Merry Hill,NC27957 Brian Conner
Stormwater Electronic Reporting Registration Form
Page 2

C. Facility Administrator Information
Include the following information for all Facility Administrators listed in Part B. Attach additional
pages if you need more space.
Facility Administrator for Permit Number:
Dame: Brian Conner Title: FHS Manager
Do you already have an eDMR If Yes,
account? ll Yes 0 No User ID,
Organization. Avoca, LLC
Email Address: [e-mail] I Phone: [phone]
Mailing Address: P 0 Box 129
City: Merry Hill State: NC Zip: 27957
Facility Administrator for Permit Number:
Name, Title:
Do you already have an eDMR If Yes,
account? 0 Yes Cl No User ID
Organization:
Email Address Phone.
Mailing Address:
City: State: Zip:
Facility Administrator for Permit Number:
Name. Title
Do you already have an et]MR El If Yes,
account? Yes E7 NO User ID
Organization:
Email Address: Phone:
Mailing Address:
City: State: Zip:
Facility Administrator for Permit Number:
Name: Title:
Do you already have an eDMR Ej If Yes,
account? Yes CI No User ID:
Organization
Email Address: Phone:
Mailing Address, ��
City: State: Zip-
Facility Administrator for Permit Number:
Name: Title.
Do you already have an eDMR If Yes,
account? 17 Yes [] No User ID
Organization:
Email Address: Phone:
Mailing Address:
City, State: zip.
Stormwater Electronic Reporting Registration Form
Page 3

D. Responsible Official Authorization
1, Augustinus Gerritsen (printed name), certify that I
meet the legal signatory authority requirements under 40 CFR 122.22, to make this request on
behalf of Avoca, LLC (Owner/Organization Name),
A \- Z (o— 2.o2O
Signature Date
Stormwater Electronic Reporting Registration Form
Page 4

Avoca,L LC
• PO Box 129
Avoca, 841 Avoca Farm Rd
Merry dill,NC 27957
Phone: [phone]
The World's Premier Botanical Extraction Company Fax: [phone]
11/26/2020
DEMLR Stormwater Program eDMR
Attn• Suzanne McCoy
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: Delegation of Signature Authority Letter
Dear DEMLR Stormwater Program staff,
By notice of this letter, I hereby signatory authority to each of the individuals listed in the
attached Table 1 for all permit applications, discharge monitoring reports, and other information
relating to the operations at the subject facility as required by all applicable federal, state, and
local environmental agencies specifically within the requirements for signatory authority as
specified in 15A NCAC 213 0506.
If you have any questions regarding this letter, please contact Suzanne McCoy at
Suzanne.McCo ncdenr. ov or [phone]
Sincerely,
Augustinu er sen
Preside A oca LLC
PO Box 129, Merry Hill NC 27957
Guus [e-mail]
Office: 252-482-2133
Mobile [phone]

Table 1: Individuals to be Granted Signatory Authority
eDMR User ID Permit Nos.
Individual (if applicable) for which this person shall have
signatory authori
Brian Conner NCS000134

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete-
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
2) 1. A current Site Map fiorn the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of inateiials, disposal areas, process areas and
loading and unloading areas), drainage structuies, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
C� 2. A summary of Analytical Monitoring results during the terns of the existing pert-nit
(if your permit required analytical sampling). Do not submit individual tab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
��►1�- 3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
M 4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned,please include
information on these BMP's.
S. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility(Sign and return:attached forth).
If the final year analytical monitoring of the existing permit terra has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

Permit Coverage
ARARenewal Application Form
NCDENR National Pollutant Discharge Elimination System NPDs:s Permit Number
Stormwater Individual Permit NC' `t�C70
Please provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to whi h erm�t correspondence will be mailed
Owner/Organization Name: isv D Ga_ L LC, AGO W-C.
Owner Contact: A'Ar,uS v' `A v-i
Mailing Address: -1211 _
NI.eYv� 1�1�11, 4JG 2�q3'� m-
Phone Number: GZs�� `i437.. �133
Fax Number: 2.
E-mail address:
Facility Information
Facility Name: av,Mb— M tyv'si WM
Facility Physical Address: kjouk V:CLV—m RQ aA
Facility Contact:
Mailing Address: %0 k2.
Phone Number: 2.,13
Fax Number: (,2,s2.)LA'62-�602.2_
E-mail address: .�Ov.•' '%• CotinnCV Q, Gt SV\\Ana C-®vr;
Permit Information
Permit Contact: _ CY1_1EY' _
Mailing Address: 10,0, Z of \,Iq
Cv%r ',\1,1.9 C. 2--IRS-1 -
Phone Number: Lans—xY LACb 2-ZI3 3
Fax Number: US2_ 41b2.® 1b622m.
E-mail address: v ian • (.® asM 6"+CA . e_'o
Discharge Information 1
Receiving Stream: lontov-% Y'�C
Stream Class; SW
Basin: ® " V,
Sub-Basin: o3-®1_ O q
Number of Outfalls:
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
a��n fit. Sawr,e. Stl��col:de� o>-+d� S�C� �ptv-&kio s as was (ppev i n
�>.} r(��N t�© 1"� `(1� ��Q• 1�''��, t 4dt /1 i�f �ItS�C�� �lCr trJt � 'r � �'aV'LV2�
CERTIFICATION
I certify that I am f ill i h t e i ormation contained in the application and that to the best of my knowledge and belief
such information i tr
Signature Date .. _�—_._���� m
�+LAA V, -
Print or type name of person signing above Title
SW Individual Permit Coverage Renewal
Please return this completed application form Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

O �n
a
n� [
i= � p 0 t •, x g3 i
Y
�� Oi���� n�,�� o;�,�✓ S� g ��Se � � 's ak 45 �� �r
n
lei
� 33 A✓ fiz �? �" 14 iE � ��'
Mie
pIf
A
1 • L � 4 V
ti

3
O J
�
Ln O m r, q:r
CL to
W rV 0 0 0 tt 0 0 ei
L
a
a�
+�+ O 1
0.0 r m m rn U, oMi
aF. , E 'r;zir rV rri r� r", 14 4 ui
z
a�
Ln
_a O o o CD O o o O
WLn m n r,i M H ui ui rri 06
.c
O
O o O o 0 C? o o n
O on Ln r-i ui � 1D 't ui
CA
u E w sn oo lzr �°
M
Vrl
O
T LA O
tQ Z ii = � -i rH � w Ln m cn
O' r,� r-� r-� 6 r-� r, 4 to
a
�= 0 _
L @ 00
a eq
Wco= � " M r� ro NKt
u O " H V-i O 0 r» `l
Ln
0.+ a � M
4
to
ca
C �
r� o m co
co
"
l7 N
V N rn cD 111 N r- Rl
fV
O 0 0Ln � W 0 00 Q
O
a C O C7 0 0 0 0 0 a
Q
Ln 41
l0 LD 1- W 01
C] O O O O O O
O c t =
Q, � m � O M �. m w�
V)
LO N w '7-4 Q

L
Q --1 U-1 dt 00 �t LD 00 rn r-i 0 CD �t �t <t r� -1 0 00 no r� kD iD tt 0 dt no 00 LD
Z5 cD r- 1-0 O 0o rn Ui m r-i to N 1* rn LD r- rz� Ol O � n �. W lD N to '�t r,
0 lD r" -i N LO ri H N r-1 r•i H 0 0 O N 0 N N 1-4 ON 0 N N N 10 00
a
c
fC Llo
ro �rl m N N lD Co CD r, 0 1-1 Ln -t Ln Ln m -4 0 W r, m -1 N lD N
,-, C m n C, N cD ,n � ri r r f m n CA d; N r` oo oU m Lo N 4 Ln F, n
� W + E � N r' -i in co Sri r r1 m lD 00 r i m -i r` cfi �
7 Z
,n 0 0 a o o Q 4 0 0 �? 0 � o 0 0 0 o O � a N 0 0 0 0
vn wo w 00 oo `r 0 N "n ai r` CA m t: m ai t oo ri nn rn 00 ri o Di
rn M cD r-I CA r-{ to r. d' r-4 CO N N m � u) � ct Ln N N
rq
.O o 0 0 o 0 0 0 0 0 o 0 0 b o o p O p o p p c7 0
O A p Sri o0 00 00 C A 4 r: r-i 06 lD 0 LD 0 0 N O ri 0 O O 0 H to 0o r-
CA N r-i CA � d' r•i r� r-1 CA ct 0 to 0 CA co � 0a V]CA r- r- 00 m VT Vl lD In
_ M r� m cT m N N N H m N N 'd' H 1-1 O N N N H rn
CA
U O M
rC ZLn 4A m r- w m N ;-n m o CA N d' m dt H 00 H r-i m w r i ri -4 N O d' m
f M rl� ct m lD w o0 0 LD g 0 r I E` n o in rn oo rn -i r� en 1p tD r-i en rn
0. oo w t w w ,6 to r-- r, r, r� r� r ww w lD w w r, LD w lD w r- r, w
Q a T
L Z 4+
+- M
N O
r0
d � N
f0 r� W 00 Ln N r-� N c-i �# W N c-1 H w m N cD lD �t m r� no m 00 Ln
Eu 0 0 -1 o r-i O N c-1 ri O r-r N r 1 N r I O O ri O p ri N r[ e-A r i O O
O
++ O
U
C
3 ro
V lD CA r, m w w m N cI N 00 r- m m N N N 00 6) D1 ri H m 00 N m
LL. dt rn r 4 m r- d � r- CA Ln r- 00 cD r` LA r� m m i Ql q 00 0) � m
— p 0 0 r{ 0 0 0 -1 0 0 0 0 r-i O CD p 0 0 0 0 ri 1-1 0 0 0 0
Q o 0 0 0 0 0 0 0 0 0 0 0 0 r� n 0 0 0 0 0 0 0 0 0 0 0 0 0
0 in Ln Ln u7 lD C71 lD lD CD lD `n CD n r- r`
r4 -4 r4 r ] ri c I lD c i H H H H -4 H H `� r i n H -4 r 1 -1 r A — r I
A `� O O 0 0 0 ri O O CS `� O O 0 0 0 0 0 p 0 O 0 0 0 0 `� O
o N N CV O O O 0 N N p p N
N N rV tV _ N N N N ry N N N N N \ \ N N N N N N N N _
0o rn u1 \ \ � \ \ \ \ \ \ \ p, \ � \ � � � \ \ o
Q s i +n cD 0o m m CA cr m vq ct m 0 t-
oo m N N rH N � N m r� N r I r 1 \ ` `� N m N N N rA 00 vi
00 O �-i N N to cD \ \ a0 \ r i N N o0 co
m 00 m c-1 r i r I N m QD r` a) r 1 A c-I r f an d Ln lD r, ri

LA
O J N 00 00 N d Lfi to to In sn 00 0 ri 00 r 00 Ln o CJ
� p_,a o Ln 00 Ol 4 m Q1 Ln N N I.n %* In Na) ro Ln N 00 00 �
u1 E c1 N N L6 m ri V1 C7 6 Ln m ci lD w i O N N c-r N M
O
.0
a
c
i� o o 0 o o o as Ln ri , to o ri m m o0 0`°0 n rn ca'n m Ln a Ln
� o m
o an t-, en ri ri o m 0o
O N E r-, Ln oo 0 m w Ln lD r-i 1-i m m r oo m 01
z
in -j 0 0 0 0 0 o o o m -1 o C? o 0 o o 0 o o o 0
V) tsp rn Iri --t 0 oo N <t cD 6 6 co m oo m m r` w Ln oo N of
H 0 0 1. d' r-f 11 N Ln wm r-i r-i d d ww
A = 0 0 0 0 0 0 0 0 0 o 0 0 o 0 0 o 0 0 0 o v
pq 00 N 14 4 lD m r-" En 6 N N Ln 'I ri Ql N w LD 00
N N ul N lQ 00 rq r-i d r-1 0
U m in m m . N N Ln 'y N lzr Ln r- ri m N cl Ln
H zzt m to r� 0 tV Ol -i Co N N €" �t Ln o N N
00 r` n r� lD c-4 0 0 tD Ln Ol Ln d: d: d. CD N lA ri ri G
CL i` 1-, r, r` r, r- r-- r- r�, r-� w n r- r- r- w oo r, Ln Ln n
in
c w
d ri 'n N N to m iD r-i m Ln m to r- r`
o c5 0 , 4 o N N r I r i o r-i ri O N 0 m rn
m
0
3 m
Q 0 N m m m m Ln Ln 0) r� m L1 ;n Ln in m Ln m r-i cl
Ii O r� N r-i ri m lD W m m cii w w 0 lD W m H m cr Ct coo O O O O O o Ca 0 ci 0 0 0 0 0 o N N
o 0 o o o 0 0 0 0 O C7 O O C7 0 0 0
o
F-
+% r, oo wm w 00 00 cc w00 °° m 0) rn rn rn
r-1 r-i r-i c^i ri ri r-I c-[ ri � i ri Ql ri ci ci m Ql r-I —4 a
A 0 0 0 0 0 0 0 0 0 0 0 0 0 0 D o o hA
N N N N N N N N N N N N N N
\ \ \ \ \ \ \ \ \ \ \ N \ \ \ N N
Q tD m m 0o N d' oo i!} lD \ r-I ri Lo al� \ m m >
N \ N N N r-i N ri ri r-i `l r-i ri r-i N u'1 N N
E Q N \ \ \ \ \ \ \ \ 0 r\^i r\-1 \ \ \ t DD \ \ Q
m r-I r-i r-i N m �t Ln m Ol N N m
i!f

) ui
2 \ \ q f / $ q
wE O a a o d 66 /
�
k ¥ & m C4 » \ o m
« m » e @ m @
L 0 E d d e o e \ e d
z
c -
. f G m © ® @ 0 LU
�
o � e w m & & a r R
E v w v v v v , \
.§ %
RbA q % \ CD
LU
%
u E v v v % \ vlzzr
M 2 *
uLn
o
�
CL 7 q / m / m \ 2
c - a e R a 5 & # m
-
@ k
' ƒ » w & m w m m I
E ixu e & w w d 6 m m
o / k
� e d
u
E
» m �
G m n w # # e « m
O § \ q / / \ q \ �
2 / L o d d d o 0 0 /
® � d
\ 0 / 0 / \
o \ £
& & � � �
n m . . .
4 � . . . k
\ u \ m w ® »

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 001
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating SuspendedSolids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/ No : Yes/No Yes/No
Light
12/22/2015 None 3 2 2 No No No
Brown
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Light None 2 2 1 No No No
Brown
7/23/2019 Light Gray None 2 2 1 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 002
The scale for Clarity, Floating Solids,and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating SuspendedSolids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
12/22/2015 Light None 1 1 1 No No No
Brown
6/23/2016 LightNone 1 1 1 No No No
Brown
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 2 1 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 003
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Floating Suspended
"Samplee Color Odor Clarity Solids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/No
8/8/2015 Gray None 3 2 2 No No No
8/31/2015 LightNone 2 1 1 No No No
Brawn
9/25/2015 Light Gray None 2 2 1 No No No
10/28/2015 LightNone 2 1 1 No No No
Brown
11/19/2015 Light Gray None 2 1 1 No No No
12/25/2015 Gray None 3 2 2 No No No
2/4/2016 Light Gray None 2 2 1 No No No
2/16/2016 Light Gray None 2 2 1 No No No
312812019 Light Gray None 2 2 1 No No No
5/3/2016 Light Gray None 2 2 1 No No No
6/7/2016 Light Gray None 2 2 1 No No No
6/23/2016 Light None 2 2 1 No No No
Brown
7/19/2016 LightBrown None 1 1 1 No No No
8/8/2016 Clear None 1 2 2 No No No
9/19/2016 Clear None 1 1 1 No No No
11/4/2016 Light Gray None 1 1 1 No No No
11/14/2016 Light Gray None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
1/23/2017 Light Gray None 1 1 1 No No No
2/8/2017 Gray None 3 1 1 No No No
3/31/2017 Light Gray None 2 2 1 No No No
4/24/2017 Clear None 1 1 1 No No No
5/23/2017 Clear None 1 1 1 Na No No

Sample Date Color Odor Clarity Floating Suspended SolidsSolids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/No Yes/ No Yes/ No
6/20/2017 LightBrown None 2 2 2 No No No
7/17/2017 LightBrown None 3 1 2 No No No
8/8/2017 LightBrown None 2 3 1 No No No
10/10/2017 Light BrownNone 2 1 1 No No No
10/29/2017 Clear None 1 1 1 No No No
12/6/2017 Brown None 4 1 4 No No No
1/23/2018 LightBrown None 2 1 1 No No No
1/23/2018 LightBrown None 2 1 1 No No No
2/28/2018 LightBrown None 2 2 1 No No No
3/12/2018 Clear None 2 1 1 No No No
4/24/2018 Clear None 1 1 1 No No No
5/18/2018 LightBrown None 2 1 1 No No No
9/15/2018 Light Gray None 2 2 2 No No No
9/16/2018 Clear None 1 1 1 No No No
10/11/2018 LightBrown None 2 2 2 No No No
11/15/2018 Light Gray None 2 2 2 No No No
1/4/2019 Clear None 1 2 1 No No No
2/11/2019 LightBrown None 2 1 1 No No No
2/11/2019 LightBrown None 2 1 1 No No No
3/26/2019 Light Gray None 2 1 1 No No No
4/9/2019 LightBrown None 2 1 1 No No No
6/5/2019 LightBrown None 2 3 2 No No No
7/23/2019 Light Gray None 2 2 2 No No No
7/23/2019 Light Gray None 2 2 2 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 004
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating Suspended solidsSolids Foam? Oil Sheen? Eroslo0
(1-5) (1-5) (1-5) Yes/No Yes/No Yes/ No
12/22/2015 Clear None 1 1 1 No No No
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 1 1 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 007
The scale for Clarity, Floating Solids,and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Floating Suspended
"Samplee Color Odor Clarity Solids Solids Foam? Oil Sheen? Erosion?
(1-5) (1-5) (1-5) Yes/ No Yes/ No Yes/No
12/22/2015 Clear None 2 1 1 1 No No No
6/23/2016 Clear None 2 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 2 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Light Gray None 2 2 1 No No No

BEST MANAGEMENT PRACTICES (BMPs)
AVOCA, LLC
Stormwater Permit No. NCS000134
BMP 1 - Containment Berms: Avoca, LLC has spill containment berms installed
around each of its fuel, solvent, and other processing tanks. These berms are large enough
to hold the total capacity of at least one of the contained tanks plus a minimum of 10%.
The following is a listing of the containment areas and their locations:
1) Fuel Oil Storage and Unloading, West of Building 1001-2
2) Gasoline Storage and Unloading, South of Building 1002-4
3) Emergency Generator Fuel Storage,Near Cooling Tower
4) Emergency Generator Fuel Storage, South of Building 1001-I ,
5) Hazardous Waste Storage, Building 1003-5
b) Tank Farm, South of 1001-1
7) Tank Farm, Not of Building 1001-1
8) Tank Farm, West of Building 1003-2
9) Unloading Station, South of Building 1001-2
10) Sclareol Reetystallization& Storage tanks, Building 1003-10
11)Chemical Storage, 1003-7
12) Botanical Extraction Process & Storage tanks,North of Building 1001-11
13) Biomass Extraction Process & Storage tanks, Building 1004-2
14)Limited Use Generator, South of Building 1004-1
15)Sclareolide and Sclareol Recrystallization storage tanks,Building 1005-1
BMP 2 - Weekly monitoring of all areas listed in BMP 1: Monitoring includes
inspection of equipment and tanks within containments as well as all areas of the facility.
The operational status of the processes, housekeeping and cleanliness, condition of
equipment and tanks, and notification of spills and leaks are noted as well as any
corrective actions taken.
BMP 3 - Annual monitoring of the areas listed in BMP 1: Monitoring includes in
depth inspection of equipment and tanks within containments as well as all areas of the
facility. Parameters of inspection include: housekeeping and cleanliness, operating
condition of equipment, evidence of spills and/or leaks, stormwater conveyance (i.e.
condition of valves, flow channels, etc,.,), erosion evidence, actions required to remedy
any problems, and the date the problem was resolved.
BMP 4 - Monitor berm contents: Avoca, LLC keeps its spill containment berth drains
closed and locked. All pumps and valves are capped when not in use. The berths are
either drained by the boiler operator or pumped to Avoca's Tertiary Lagoon. All rain

water is inspected before it is drained to determine if there it has oil sheen or other
contaminates. In the case of a spill, the berms can be pumped out with a suction tanker or
either directly pumped to Avoca's Waste Water Treatment facility. The spilled liquid can
be either treated and disposed of or reused.
BMP 5 -Hazardous waste storage: All hazardous waste is stored in a concrete dike area
with a protective roof covering the containment. There are signs stating that hazardous
waste is to be stored in this area only.
BMP 6 - Analytical Monitoring: Analytical monitoring of stormwater runoff is
performed as stated in Stormwater Permit No. NCS000134. Analytical monitoring of
outfalls 9001, #003, and 4004 is performed quarterly and outfall#003 is monitored
monthly. The temperature and pH are recorded at the time of sampling. The samples are
put on ice and sent to Environmental 1 located in Greenville,NC where they are analyzed
for Nitrogen, Phosphorous, Total Suspended Solids, COD, and pH. The analytical
monitoring results are kept at Avoca, LLC and sent to NCDENR within 30 days of
receiving the results from Environmental 1.
BMP 7 - Qualitative Monitoring: Qualitative monitoring of Stormwater Runoff is
performed as stated in Stormwater Permit No. NCS000134. Qualitative monitoring of
outfalls #001, #002, #003, #004, #006, and 4007 is performed twice annually. Outfall
#005 is not monitored under the stormwater permit as it is covered under a separate
NPDES permit. The qualitative results are kept on file at Avoca, LLC.
BMP S - Training: Training of all Avoca, Incorporated personnel occurs annually.
Employees are trained in the safe handling of chemicals, spill prevention of chemicals,
location of shutoff valves, who to contact in case of a spill, location of containment
equipment, and operation and maintenance of containment equipment.
BMP 9--Spill Clean-Up: Hazardous waste clean-up and major Spills are handled be an
outside contractor. AVOCA, LLC has a contract with Inco, Inc, located in Rocky Mount,
NC to handle all it's major spill incidents.
BMP 10 --Covered Waste: All waste drums for scrap metal are to be covered. A tarp is
used to cover the scrap metal container which is used to store crushed drums at Avoca,
LLC.

2019 Notice of Significant Changes at the Avoca, LLC Facility
Stormwater Permit No. NCS000134
Addition of Building 1005-1:
Building 1005-1 was constructed in January 2017 for the expanded operation of
Sclareol Reciystallization{SFG} and Sclareolide. Building 1005-1 operates in the same
manner with the same materials as buildings 1001-1 and 1003-10 have for many ycais.
The sle purpose of this building was to allow for more production of the SFG and
Sclareolide products. All tanks, vessels, materials, etc. are covered and surrounded by
berms that meet all requirements. Building 1005-1 is inspected at the same frequency as
all other buildings listed in the BMPs.
All prior material handling and storage practices are currently in effect at Avoca,
LLC. The major Raw Materials handled at the facility also remain the same as in the past
.notification.
Avoca, LLC. always strives to maintain a healthy environment and to prevent
pollution of the land, air, and water of the surrounding area. Avoca, LLC. understands the
importance of maintaining a natural, unpolluted environment and makes certain that its
actions in no way have adverse effects on the surrounding ecosystems. Avoca, LLC. also
realizes the importance of maintaining a safe workplace and strives to always meet all
OSHA and other general safety guidelines. Avoca, LLC. will continue its policy of
maintaining the condition of the environment and safety of its facility through proper
management of its processes and through the training of its employees to meet the criteria
set forth to sustain a healthy, safe workplace and environment.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources-Stormwater Permitting
Facility Name: N10QAvaY — me", v.l ,,
Permit Number CS.
Location Address tAl Njo �wir,nn
County. .
I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel property gather and evaluate the information required by the SPPP
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations "
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CE RTIT ICATION.
Signature Date
Print or-WnayKe of person signing above Title
SPPP Certification 10/13

Compliance Inspection Report
Permit:NCS000134 Effective: 07/01/15 Expiration: 06/30/20 Owner: Avoca LLC
SOC: Effective: Expiration: Facility: Avoca-Merry Hill WWTP
County: Bertie 841 Avoca Farm Rd
Region: Washington
Merry Hill NC 27957
Contact Person:Brian Conner Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 03/22/2023 Entry Time 09:OOAM Exit Time: 10:30AM
Primary Inspector:William J Moore Phone: [phone] Ext.264
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000134 Owner-Facility:Avoca LLC
Inspection Date: 03/22/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Site inspection conducted 03/22/23 at Avoca Farms located at 841 Avoca Farm Rd in Merry Hill, NC. Met with Mr. Brian
Conner, Environmental Mgr, [[e-mail]] - [phone]. This is an existing sage processing plant
operating under an individual sw permit NCS000134. The facility has a fully implemented SP3 plan; BMPs and monitoring
activities appear to be in good order, with the exception of sw outfall 003.
The following discussion/observations were made during the inspection:
1)The facility added an expansion project in 2016 that included a new building &concrete loading ramp. This expansion
area drains to an existing natural vegetated low area in close proximity to their existing sw outfall 002. This should be
designated as a new outfall and evaluated for representative outfall status (ROS)with their existing outfalls 001 &002.
2)The sage receiving/storage building and surrounding area drains to their designated sw outfall 003. This outfall has
consistently over time exceeded benchmark values for COD &TSS; and to a lesser extent pH,Total Nitrogen and
Phosphorus. The primary BMP for this area is removal of spilled product&sweeping; however, based on past exceedances
of BM values, this BMP does not appear to be sufficient, especially during peak times. We discussed a few alternative
BMPs, inculding filters in the nearby catch basin and use of a mechanical sweeper. The facility should evaluate&consider
additional BMPs for this process area.
3) No problems were observed at outfalls 004, 005, 006, & 007. Outfall 007 might be considered a representative outfall for
the other(3)outfalls. The facility should evaluate &consider ROS.
It is recommended that the permit be reissued with quarterly monitoring requiremnts. Based on their history of BM
exceedances (more than 4 exceedances during the permit cycle)the facility should continue monitoring under the Tier 3
response and proivde a written plan of action for sw outfall 003.
Page 2 of 3

Permit: NCS000134 Owner-Facility:Avoca LLC
Inspection Date: 03/22/2023 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 (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 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? 0 ❑ ❑ ❑
Comment: Facility will re-evaluate designted sw outfalls & may request updated ROS.
Page 3 of 3

3/7/23, 11:21 AM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Limited Liability Company
Legal Name
Avoca LLC
Prev Legal Name
Avoca, Inc.
Information
Sosld: 0665567
Status: Current-Active O
Date Formed: 10/16/2017
Citizenship: Domestic
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: CT Corporation System
Addresses
Reg Office Reg Mailing Principal Office
160 Mine Lake Ct Ste 200 160 Mine Lake Ct Ste 200 841 Avoca Farm Road
Raleigh, NC 27615 Raleigh, NC 27615 Merry Hill, NC 27957
Mailing
P.O. BOX 3665
DUBLIN, OH 43016
Company Officials
All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20.
Secretary Chief Financial Officer Assistant Secretary President
Babatunde Awodiran Brian Bunch WILLIAM J DAVIS Augustinus Gerritsen
P.O. BOX 3665 PO BOX 3665 P.O. BOX 3665 PO BOX 3665
https://www.sosnc.gov/online_services/Search/Business_Registration_profile?ld=l 3667170 1/2

3/7/23, 11:21 AM North Carolina Secretary of State Search Results
DUBLIN OH 43016 DUBLIN OH 43016 DUBLIN OH 43016 DUBLIN OH 43016
Assistant Secretary Assistant Treasurer Vice President Vice President
JOHN A HAMM KEVIN D HIGGINS ROBIN E LAMPKIN DONALD E MEYER
P.O BOX 3665 P.O. BOX 3665 PO BOX 3665 P.O. BOX 3665
DUBLIN OH 43016 DUBLIN OH 43016 DUBLIN OH 43016 DUBLIN OH 43016
Vice President Vice President
Matthew K Spence WILLIAM C WHITAKER
P.O. BOX 3665 P.O. BOX 3665
DUBLIN OH 43016 DUBLIN OH 43016
https://www.sosnc.gov/online_services/Search/Business_Registration_profile?ld=l3667170 2/2

3/7/23, 11:22 AM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Business Corporation
Legal Name
Ashland Inc.
Information
Sosld: 2509916
Status: Current-Active O
Date Formed: 10/21/2022
Citizenship: Foreign
State of Incorporation: DE
Fiscal Month: December
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: CT Corporation System
Addresses
Reg Office Reg Mailing Mailing
160 Mine Lake Ct Ste 200 160 Mine Lake Ct Ste 200 8145 Blazer Drive
Raleigh, NC 27615 Raleigh, NC 27615 Wilmington, DE 19808
Principal Office
8145 Blazer Drive
Wilmington, DE 19808
Officers
Stock
https://www.sosnc.gov/onl ine_services/Search/Business_Registration_profile?ld=20144272 1/1

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete: P t!"WE D
(Do not submit the site Stormwater Pollution Prevention Plan) „I 2019
Initials DENR-LAND QUALITY
STORMWATER PERMITTING
1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas,process areas and
loading and unloading areas), drainage structures,drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
YhC. 2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
thr1 3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
i?)M C. 4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned,please include
information on these BMP's.
Qn"�— 5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
BMc. 6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility(Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

Permit Coverage
© � Renewal Application Form NPDES Permit Number
NCDENR National Pollutant Discharge Elimination System NCS C0013
Stormwater Individual Permit
Please provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to whi h erm/t correspondence will be mailed
Owner/Organization Name: 1Nv0!Lg6 LLL AC'0" L1..C,
Owner Contact: V * h
Mailing Address: p. . 910-A %144
Kevvl 1J L 2-I9 S`1
Phone Number: (.252� Lion
Fax Number: US2 4 2-
E-mail address: Qut\ $. QeXr't S2rn @ O'sV\ a-V\A
Facility Information
Facility Name: I-NJ 0 C4 f--o-V r- of
Facility Physical Address: 93%m R'Joc-w Fo.vw, Road
\
evylA L 2-195
Facility Contact: r'-d,••% O ylnev
Mailing Address: .O. Q.)oX k7A
Mevr µ 1% QL '2.1g5`l
Phone Number: LA(U.-2.13
Fax Number: y$Z V010Z2_
E-mail address: by df%. COYnntN Q, 0,$,n\OL-4. LOB
Permit Information
Permit Contact: %1r,Cty. (,or\neV-
Mailing Address: P.O. Ox \-Ic1
#Mcy,r "',; k 10C. 2'IaS-1
Phone Number: L-m-1) 4b'2^- 2133
Fax Number: C2S2 402-01027
E-mail address: bV"ta.,, . CO v.n&- @' aaS r . tow,
Discharge Information
Receiving Stream: ScukrnpY\ Creep
Stream Class: SW
Basin: :yC.v ih
Sub-Basin: O LI
Number of Outfalls: IS
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
'6%;1d;.w 1.10. 1 ooS-1 Ujus Cov,sirVckeej ��, Ja»•~4 U\71 . 7h,S b";ld."A oM.vAcs
L.\� 4Z Su_•r,e. SClarco\:de &"A SFG mDcra}to.,s aS alas
%oat"ac \00 \003-\0 -\hc.. ,,„1d:ow a.-VI AS vcssev dwc, Cow,g\eket„ covevcd
ay'd es.c.\asecd w;'1n Vevr,s,
CERTIFICATION
I certify that I am f 4ihi ormation contained in the application and that to the best of my knowledge and belief
such information i tr
Signature Date
<'
Print or type name of person signing above Title
SW Individual Permit Coverage Renewal
Please return this completed application form Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

s
..• r oy fJ `' A SURVEY AND PUT FOR
AWl'rI
sraWNc sraevwATER M+94cEMErir ca+rrnMs
MERRY HILL TOWNSHIP — BVME COUNTY— NORM CAROUNA
\\U UU SGLE 1-60' NOVDMBER 20, 2Of2
,.��""�_ X=w
r
..mow r �S^w.r • r
V a va Ise
5�„r+ s, r •p6 �
� 5 r ■
11:40—
/J � 5 5 �� 5� �� � w•
O
»n 0
„r O
81.0�• 1a05-1

Avoca, Inc. Storm Water Analytical Monitoring Results
Permit No. NCS000134
Outfall #: 001
Sample Date Total Flow Total Rainfall pH COD TSS Total Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
12/22/2015 0.052 0.7 7.68 65.0 127.0 14.40 2.78
6/23/2016 0.155 2.1 7.17 51.0 142.0 2.77 0.51
12/19/2016 0.088 1.2 7.14 86.0 23.0 3.31 0.86
6/20/2017 0.096 1.3 6.79 49.0 41.0 2.31 0.77
1/23/2018 0.015 0.2 7.64 496.0 125.0 12.40 4.02
1/4/2019 0.022 0.3 7.51 142.0 105.0 1.90 0.56
7/23/2019 0.273 3.7 4.97 61.0 123.0 4.45 0.70
Average 0.100142857 1.357142857 6.99 135.7 98.0 5.93 1.46

Avoca, Inc. Storm Water Analytical Monitoring Results
Permit No. NCS000134
Outfall #: 003
"Sample Total Date Total Flow Total Rainfall pH COD TSS Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
8/8/2015 0.046 0.7 8.59 64.0 3.6 4.73 0.65
8/31/2015 0.039 0.6 6.73 725.0 36.0 17.35 6.74
9/25/2015 0.117 1.8 4.47 4228.0 68.0 23.73 7.68
10/28/2015 0.033 0.5 6.96 318.0 18.0 1.72 1.04
11/19/2015 0.078 1.2 6.63 498.0 134.0 11.22 2.86
12/25/2015 0.046 0.7 6.62 1149.0 90.0 43.66 5.98
2/4/2016 0.143 2.2 6.85 344.0 102.0 5.53 1.59
2/16/2016 0.072 1.1 7.03 217.0 273.0 5.76 1.31
3/28/2019 0.091 1.4 7.60 271.0 19.0 6.17 2.10
5/3/2016 0.052 0.8 7.09 218.0 57.0 6.10 1.56
6/7/2016 0.078 1.2 7.02 196.0 169.0 5.21 1.24
6/23/2016 0.137 2.1 7.14 340.0 233.0 5.15 1.44
7/19/2016 0.065 1 6.73 206.0 9.7 7.54 0.94
8/8/2016 0.13 2 7.74 95.0 77.0 1.75 0.67
9/19/2016 0.072 1.1 8.01 2800.0 49.0 3.94 0.71
11/4/2016 0.052 0.8 6.58 240.0 19.0 6.45 2.70
11/14/2016 0.02 0.3 6.91 482.0 34.0 12.25 0.98
12/19/2016 0.078 1.2 6.81 95.0 28.0 8.79 2.03
1/23/2017 0.039 0.6 6.93 171.0 21.0 3.81 2.47
2/8/2017 0.039 0.6 7.16 1770.0 353.0 35.80 12.76
3/31/2017 0.091 1.4 6.71 1080.0 153.0 18.36 20.46
4/24/2017 0.15 2.3 6.51 59.0 5.2 7.67 0.64
5/23/2017 0.111 1.7 6.61 250.0 7.4 5.23 2.60
6/20/2017 0.085 1.3 6.62 251.0 48.0 6.41 2.24
7/17/2017 0.098 1.5 7.10 276.0 57.0 6.52 2.63
8/8/2017 0.052 0.8 7.54 168.0 20.0 4.76 15.48
10/10/2017 0.033 0.5 6.93 957.0 59.0 19.72 8.76

"Sample Totalate Total Flow Total Rainfall pH COD TSS Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
10/29/2017 0.072 1.1 7.81 328.0 19.0 7.15 4.02
12/6/2017 0.023 0.35 7.70 522.0 115.0 15.86 4.58
1/23/2018 0.013 0.2 7.71 351.0 101.0 8.51 2.88
1/23/2018 0.013 0.2 7.71 324.0 100.0 10.57 2.92
2/28/2019 0.033 0.5 7.64 266.0 48.0 9.16 5.44
3/12/2018 0.065 1 7.13 283.0 42.0 6.00 3.35
4/24/2018 0.085 1.3 7.06 217.0 14.0 5.31 1.95
5/18/2018 0.039 0.6 7.07 515.0 46.0 6.13 5.55
9/15/2018 0.137 2.1 7.60 26.0 6.9 1.09 0.25
9/16/2018 0.13 2 7.52 28.0 6.1 1.08 0.25
10/11/2018 0.065 1 6.99 442.0 26.0 14.86 5.58
11/15/2018 0.065 1 7.51 462.0 133.0 12.14 3.40
1/4/2019 0.02 0.3 7.46 61.0 58.0 3.07 1.54
2/11/2019 0.065 1 7.42 595.0 83.0 16.94 6.21
2/11/2019 0.065 1 7.42 701.0 93.0 16.69 5.91
3/26/2019 0.033 0.5 6.67 41.0 17.0 3.03 0.38
4/9/2019 0.15 2.3 8.24 179.0 18.0 7.05 2.57
6/5/2019 0.039 0.6 7.65 392.0 45.0 11.05 2.28
7/23/2019 0.241 3.7 5.10 276.0 48.0 8.05 1.85
7/23/2019 0.241 3.7 5.12 416.0 82.0 13.01 2.80
Average 1 0.08 1.19 7.07 508.4 69.0 9.83 3.70

Avoca, Inc. Storm Water Analytical Monitoring Results
Permit No. NCS000134
Outfall #: 004
Total
Sample Date Total Flow Total Rainfall pH COD TSS Phosphorus
Nitrogen
Million Gal. Inches mg/L mg/L mg/L mg/L
12/22/2015 0.013 0.7 6.64 <20 <2.8 0.57 <0.04
6/23/2016 0.039 2.1 6.82 <20 6.80 0.72 0.07
12/19/2016 0.022 1.2 7.02 <20 < 2.7 0.15 0.18
6/20/2017 0.024 1.3 6.95 20.00 < 2.6 0.52 0.08
1/23/2018 0.004 0.2 7.76 24.00 < 3.1 1.57 0.14
1/4/2019 0.006 0.3 7.39 < 20 < 2.6 < 0.51 0.06
7/23/2019 0.069 3.7 4.87 24.00 12.00 1.90 0.10
Average 1 0.188405797 0.189189189 1.36345 #VALUE! #VALUE! 0.3 #VALUE!

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 001
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating SuspendedFoam? Oil Sheen? Erosion?
Solids Solids
(1-5) (1-5) (1-5) Yes/ No Yes/ No Yes/ No
Light
12/22/2015 Brown None 3 2 2 No No No
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Light None 2 2 1 No No No
Brown
7/23/2019 Light Gray None 2 2 1 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 002
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Sample Date Color Odor Clarity Floating SuspendedFoam? Oil Sheen? Erosion?
Solids Solids
(1-5) (1-5) (1-5) Yes/ No Yes/ No Yes/ No
12/22/2015 Light None 1 1 1 No No No
Brown
6/23/2016 Light None 1 1 1 No No No
Brown
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 2 1 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 003
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Floating Suspended
Sample Date Color Odor Clarity Foam? Oil Sheen? Erosion?
Solids Solids
(1-5) (1-5) (1-5) Yes/ No Yes/ No Yes/ No
8/8/2015 Gray None 3 2 2 No No No
8/31/2015 Light None 2 1 1 No No No
Brown
9/25/2015 Light Gray None 2 2 1 No No No
10/28/2015 Light None 2 1 1 No No No
Brown
11/19/2015 Light Gray None 2 1 1 No No No
12/25/2015 Gray None 3 2 2 No No No
2/4/2016 Light Gray None 2 2 1 No No No
2/16/2016 Light Gray None 2 2 1 No No No
3/28/2019 Light Gray None 2 2 1 No No No
5/3/2016 Light Gray None 2 2 1 No No No
6/7/2016 Light Gray None 2 2 1 No No No
6/23/2016 Light None 2 2 1 No No No
Brown
7/19/2016 Light None 1 1 1 No No No
Brown
8/8/2016 Clear None 1 2 2 No No No
9/19/2016 Clear None 1 1 1 No No No
11/4/2016 Light Gray None 1 1 1 No No No
11/14/2016 Light Gray None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
1/23/2017 Light Gray. None 1 1 1 No No No
2/8/2017 Gray None 3 1 1 No No No
3/31/2017 Light Gray None 2 2 1 No No No
4/24/2017 Clear None 1 1 1 No No No
5/23/2017 1 Clear I None 1 1 1 No No No

Sample Date Color Odor Clarity Floating SuspendedFoam? Oil Sheen? Erosion?
Solids Solids
(1-5) (1-5) (1-5) Yes/ No Yes/ No Yes/ No
6/20/2017 Light None 2 2 2 No No No
Brown
7/17/2017 Light None 3 1 2 No No No
Brown
8/8/2017 Light None 2 3 1 No No No
Brown
10/10/2017 Light None 2 1 1 No No No
Brown
10/29/2017 Clear None 1 1 1 No No No
12/6/2017 Brown None 4 1 4 No No No
1/23/2018 Light None 2 1 1 No No No
Brown
1/23/2018 Light None 2 1 1 No No No
Brown
2/28/2018 LightBrown None 2 2 1 No No No
3/12/2018 Clear None 2 1 1 No No No
4/24/2018 Clear None 1 1 1 No No No
5/18/2018 Light None 2 1 1 No No No
Brown
9/15/2018 Light Gray None 2 2 2 No No No
9/16/2018 Clear None 1 1 1 No No No
10/11/2018 Light None 2 2 2 No No No
Brown
11/15/2018 Light Gray None 2 2 2 No No No
1/4/2019 Clear None 1 2 1 No No No
2/11/2019 Light None 2 1 1 No No No
Brown
2/11/2019 Light None 2 1 1 No No No
Brown
3/26/2019 Light Gray None 2 1 1 No No No
4/9/2019 Light None 2 1 1 No No No
Brown
6/5/2019 Light None 2 3 2 No No No
Brown
7/23/2019 Light Gray None 2 2 2 No No No
7/23/2019 Light Gray None 2 2 2 No No TNo7

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 004
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
Floating Suspended
"Samplee Color Odor Clarity Foam? Oil Sheen? Erosion?
Solids Solids
(1-5) (1-5) (1-5) Yes/ No Yes/ No Yes/ No
12/22/2015 Clear None 1 1 1 No No No
6/23/2016 Clear None 1 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 1 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Clear None 1 1 1 No No No

Avoca, Inc. Storm Water Visual Monitoring Results
Permit No. NCS000134
Outfall #: 007
The scale for Clarity, Floating Solids, and Suspended Solids is 1-5. 1 is very clear or none present to 5 is high
or covered.
SampleFloating Suspended Date Color Odor Clarity Foam? Oil Sheen? Erosion?
Solids Solids
(1-5) (1-5) (1-5) Yes/ No Yes/ No Yes/No
12/22/2015 Clear None 2 1 1 No No No
6/23/2016 Clear None 2 1 1 No No No
12/19/2016 Clear None 1 1 1 No No No
6/20/2017 Clear None 1 1 1 No No No
1/23/2018 Clear None 2 1 1 No No No
1/4/2019 Clear None 1 1 1 No No No
7/23/2019 Light Gray None 2 2 1 No No No

BEST MANAGEMENT PRACTICES (BMPs)
AVOCA, LLC
Stormwater Permit No. NCS000134
BMP 1 - Containment Berms: Avoca, LLC has spill containment berms installed
around each of its fuel, solvent, and other processing tanks. These berms are large enough
to hold the total capacity of at least one of the contained tanks plus a minimum of 10%.
The following is a listing of the containment areas and their locations:
1) Fuel Oil Storage and Unloading, West of Building 1001-2
2) Gasoline Storage and Unloading, South of Building 1002-4
3) Emergency Generator Fuel Storage,Near Cooling Tower
4) Emergency Generator Fuel Storage, South of Building 1001-1
5) Hazardous Waste Storage, Building 1003-5
6) Tank Farm, South of 1001-1
7) Tank Farm,North of Building 1001-1
8) Tank Farm, West of Building 1003-2
9) Unloading Station, South of Building 1001-2
10) Sclareol Recrystallization& Storage tanks, Building 1003-10
11)Chemical Storage, 1003-7
12) Botanical Extraction Process & Storage tanks,North of Building 1001-11
13) Biomass Extraction Process& Storage tanks, Building 1004-2
14)Limited Use Generator, South of Building 1004-1
15)Sclareolide and Sclareol Recrystallization storage tanks, Building 1005-1
BMP 2 -Weekly monitoring of all areas listed in BMP 1: Monitoring includes
inspection of equipment and tanks within containments as well as all areas of the facility.
The operational status of the processes,housekeeping and cleanliness, condition of
equipment and tanks, and notification of spills and leaks are noted as well as any
corrective actions taken.
BMP 3 -Annual monitoring of the areas listed in BMP 1: Monitoring includes in
depth inspection of equipment and tanks within containments as well as all areas of the
facility. Parameters of inspection include: housekeeping and cleanliness, operating
condition of equipment, evidence of spills and/or leaks, stormwater conveyance (i.e.
condition of valves, flow channels, etc...), erosion evidence, actions required to remedy
any problems, and the date the problem was resolved.
BMP 4 -Monitor berm contents: Avoca, LLC keeps its spill containment berm drains
closed and locked. All pumps and valves are capped when not in use. The berms are
either drained by the boiler operator or pumped to Avoca's Tertiary Lagoon. All rain

water is inspected before it is drained to determine if there it has oil sheen or other
contaminates. In the case of a spill,the berms can be pumped out with a suction tanker or
either directly pumped to Avoca's Waste Water Treatment facility. The spilled liquid can
be either treated and disposed of or reused.
BMP 5 -Hazardous waste storage: All hazardous waste is stored in a concrete dike area
with a protective roof covering the containment. There are signs stating that Hazardous
waste is to be stored in this area only.
BMP 6 -Analytical Monitoring: Analytical monitoring of stormwater runoff is
performed as stated in Stormwater Permit No.NCS000134. Analytical monitoring of
outfalls#001, #003, and#004 is performed quarterly and outfall#003 is monitored
monthly. The temperature and pH are recorded at the time of sampling. The samples are
put on ice and sent to Environmental 1 located in Greenville,NC where they are analyzed
for Nitrogen, Phosphorous, Total Suspended Solids, COD, and pH. The analytical
monitoring results are kept at Avoca, LLC and sent to NCDENR within 30 days of
receiving the results from Environmental 1.
BMP 7- Qualitative Monitoring: Qualitative monitoring of Stormwater Runoff is
performed as stated in Stormwater Permit No.NCS000134. Qualitative monitoring of
outfalls#001, #002, #003, #004, #006, and#007 is performed twice annually. Outfall
#005 is not monitored under the stormwater permit as it is covered under a separate
NPDES permit. The qualitative results are kept on file at Avoca, LLC.
BMP 8 -Training: Training of all Avoca, Incorporated personnel occurs annually.
Employees are trained in the safe handling of chemicals, spill prevention of chemicals,
location of shutoff valves, who to contact in case of a spill, location of containment
equipment, and operation and maintenance of containment equipment.
BMP 9—Spill Clean-Up: Hazardous waste clean-up and major Spills are handled be an
outside contractor. AVOCA, LLC has a contract with Inco, Inc, located in Rocky Mount,
NC to handle all it's major spill incidents.
BMP 10—Covered Waste: All waste drums for scrap metal are to be covered. A tarp is
used to cover the scrap metal container which is used to store crushed drums at Avoca,
LLC.

2019 Notice of Significant Changes at the Avoca, LLC Facility
Stormwater Permit No. NCS000134
Addition of Building 1005-1:
Building 1005-1 was constructed in January 2017 for the expanded operation of
Sclareol Recrystallization(SFG) and Sclareolide. Building 1005-1 operates in the same
manner with the same materials as buildings 1001-1 and 1003-10 have for many years.
The sle purpose of this building was to allow for more production of the SFG and
Sclareolide products. All tanks,vessels,materials, etc. are covered and surrounded by
berms that meet all requirements. Building 1005-1 is inspected at the same frequency as
all other buildings listed in the BMPs.
All prior material handling and storage practices are currently in effect at Avoca,
LLC. The major Raw Materials handled at the facility also remain the same as in the past
notification.
Avoca, LLC. always strives to maintain a healthy environment and to prevent
pollution of the land, air, and water of the surrounding area. Avoca, LLC. understands the
importance of maintaining a natural, unpolluted environment and makes certain that its
actions in no way have adverse effects on the surrounding ecosystems. Avoca, LLC. also
realizes the importance of maintaining a safe workplace and strives to always meet all
OSHA and other general safety guidelines. Avoca, LLC. will continue its policy of
maintaining the condition of the environment and safety of its facility through proper
management of its processes and through the training of its employees to meet the criteria
set forth to sustain a healthy, safe workplace and environment.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources-Stormwater Permitting
Facility Name: AVocckFCxvm e,— Mew uAI
Permit Number: WC,S QQ O12,
Location Address: $1A% OC4 5CLr n R0acl
M rvw NAZ%y0 2.14Sl
County: '
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date
Au U v' pY'C S1
Print or'Ywl�iayKe of person signing above Title
SPPP Certification 10/13