NCS000582_Fact sheet binder_20230706

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 6/30/2023
Permit Number NCS000582
Owner/Facility Name Ennis Flint, Inc./Ennis Flint High Point Facility
SIC AICS Code/Category 2821 /Plastic Materials and Resins
Basin Name/Sub-basin number Yadkin Pee Dee/03-07-07
Receiving Stream/HUC UT to Kennedy Mill Creek/030401030203
Stream Classification/Stream Segment C/ 12-119-7-2
Is the stream impaired on 303 d list]? No
Any TMDLs? No
Any threatened and/or endangered species? No
Any compliance concerns? See Section 2 below
Any perinit mods since lastpermit? No
New expiration date 7/31/2028
Comments on Draft Permit? See Section 6(below)
Section 1. Facility Activities and Process:
Ennis Flint High Point Facility is a latex resin manufacturing facility for road markings. The facility
manufactures resin products for incorporation into paint products for in-house distribution. Per
information in the permit file history, production of latex resin involves applying an initiator
(ammonium persulfate) and heat to a monomer methylmethacrylate (MMA) and butyl-acrylate (BA),
along with minor chemicals, inside a reactor tank. Any spills that occur in the production area will
collect to a central floor drain and drain to the AST containment berm. Onsite there is a
production/manufacturing room, storage room for drums of methacrylic acid(MAA), and storage of
nonflammable raw materials. Seven (7) ASTs are used for bulk storage of MMA and BA, the pre-
emulsion process, an overflow AST for runaway reactions, and two (2) ASTs used for temporary storage
of finished latex resin.
In February 2020 there was a reduction in the percent of aqua ammonia(reduced from 29%to 19%). Per
the December 2022 inspection report, the valve on the stormwater pond was damaged and the facility
planned to increase the size of the pond (trees were cut around the pond at the time of inspection).
Outfall SW001:
Drainage area consists of the manufacturing and office building, loading bays, eleven (11)ASTs, IBC
totes, 55-gallon drums, 700-gallon below-ground vault, containment pad, dumpsters,pallet storage
areas,undeveloped land, and a stormwater pond. Potential pollutants include MMA, MAA, BA, and
ammonium hydroxide.
Additional outfalls:
There is sheet flow from forested area onsite that goes directly to Kennedy Mill Creek.
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
Page 1 of 5

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
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 November 2022, benchmarks exceeded for:
o TSS Ix
o COD 2x
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 November 2022. Quantitative sampling included pH, TSS, BOD, COD,
and ammonia nitrogen.
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 is a table of the
proposed monitoring for each outfall at the Ennis-Flint High Point 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
Non-Polar Oil &Grease Quarterly monitoring
Page 2 of 5

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
Ammonia Nitrogen BASIS: Potential pollutant from drainage area
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
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:
Page 3 of 5

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 m /L BPJ; Based on Secondary Treatment Regulation(40 CFR
g 133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Ammonia Nitrogen At 7.5 s.u. pH and summer(26°C) temperature from
(summer)
5.6 mg/L Wasteload Allocation document for the coastal plain region
worst-case scenario
Ammonia Nitrogen At 7.5 s.u. pH and winter(14°C) temperature from Wasteload
(winter)
15 mg/L Allocation document for the coastal plain region(worst-case
scenario
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
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.
Page 4 of 5

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
• 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: 3/20/2023
• Initial contact with Regional Office: 3/20/2023
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 5/25/2023
• Final permit sent for supervisor signature: 6/30/2023
Section 7. Comments received on draft permit:
• None
Page 5 of 5

Young, Brianna A
From: Schwendeman, Timothy M <[e-mail]>
Sent: Friday, July 7, 2023 3:38 PM
To: Young, Brianna A
Cc: Krahn, Randy W; Johnson, Sarah A
Subject: RE: [External] FW: <EXT>Issued NPDES Permit NCS000582
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.
Received...thank you!
From:Young, Brianna A<[e-mail]>
Sent: Friday,July 7, 2023 3:35 PM
To: Schwendeman,Timothy M
Cc: Krahn, Randy W;Johnson, Sarah A
Subject: RE: [External] FW: <EXT>Issued NPDES Permit NCS000582
Good afternoon,
Attached is the issued NPDES stormwater permit for THE Ennis-Flint High Point Facility (NCS000582). Please respond to
this email confirming that you received the attached document,were able to open and view the document, and have
saved/printed a copy for your records.
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)
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.
From: Schwendeman,Timothy M <[e-mail]>
Sent: Friday,July 7, 2023 3:33 PM
To:Young, Brianna A<[e-mail]>
1

Cc: Krahn, Randy W<[e-mail]>;Johnson, Sarah A<[e-mail]>
Subject: [External] FW: <EXT>Issued NPDES Permit NCS000582
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.
Brianna,
We are good with transmitting the documents via email. Have a good weekend!
Thank you,
Tim
From: Krahn, Randy W<[e-mail]>
Sent: Friday,July 7, 2023 10:36 AM
To: Schwendeman,Timothy M
Cc:Johnson, Sarah A
Subject: RE: <EXT>Issued NPDES Permit NCS000582
I'm good with it.
Randy Krahn
Plant Manager
Traffic Solutions HPT
PPG
201 Old Thomasville Rd.
High Point, NC 27260
T: 336-308-3843
M: 336-239-6377
E:[e-mail]
F
From: Schwendeman,Timothy M <[e-mail]>
Sent: Friday,July 7, 2023 10:29 AM
To: Krahn, Randy W
Cc:Johnson, Sarah A
Subject: FW: <EXT>Issued NPDES Permit NCS000582
Randy
I have no issues with it. However, I think you as the responsible official for the site has to respond. If you could just let
her know on the original email.
-Tim
From:Young, Brianna A<[e-mail]>
Sent: Friday,July 7, 2023 8:49 AM
To: Krahn, Randy W
Cc:Schwendeman,Timothy M;Johnson, Sarah A
Subject: <EXT>Issued NPDES Permit NCS000582
CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
2

Good morning,
In order to provide more convenience, control, and security to our permittees and assist them in processing their
transactions,the Division of Energy, Mineral, and Land Resources, is currently transitioning towards electronic
correspondence.This will hopefully provide more efficient service to our permittees and other partners and will allow us
to more effectively process and track documents. We are writing to ask you for your approval of the transmittal of
documents related to your permitting and related activities with the Division in an electronic format. Documents will be
emailed to the appropriate contact person(s) in your organization in a PDF format.
Please respond to me through email with verification that transmittal of your documents in an electronic manner is
acceptable to you. If you have any questions, please feel free to contact me.
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)
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.
3

Greensboro News Record
Advertising Affidavit Account Number
4023100
Date
May 28, 2023
NC DEMUR STORMWATER PERMITTING
PROGRAM
1612 MAIL SERVICE CENTER
RALEIGH,NC 27699-1612
PO Number Order Category Description
0000836421 Legal Notices NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION INTENTTO ISSUE
Publisher of the
Greensboro News Record
Before the undersigned,a Notary Public duly commissioned,qualified,and authorized by
law to administer oaths,personally appeared the Publisher's Representative who by being
duly sworn deposes and says:that he/she is authorized to make this affidavit and sworn
statement;that the notice or other legal advertisement,a copy of which is attached hereto,
was published in the Greensboro News Record on the following dates:
05/2812023
and that the said newspaper in which such notice,paper document,or legal advertisement
was published,was at the time of each and every such publication,a newspaper meeting all
the requirements and qualifications of Section 1.597 of the General Statutes of North
�j Carolina.
�ate�Pco9 Billing Rep a entati�e�.
�M\"ReO\°VIN Sworn to and subscribed before me the 28th ay o May,2023
0
(Notary Public)
State of Virginia Kimberly Kay Harris
County of Hanover NOTARY PUBLIG
My commission expires: rommonwealih of Virginia
�o.356753
commission Exp.Jan.31,2025
THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU

NORTH CAROLINA ENVIRONMENTAL
MANAGEMENT COMMISSION INTENT TO ISSUE
NPDES STORMWATER DISCHARGE PERMITS
The North Carolina Environmental Management Commission proposes to
issue NPDES stormwater discharge permit(s)to the person(s)listed be-
low.Public comment or abjection to the draft permits is invited. Written
comments regarding the proposed permit will be accepted until 30 days
after the publish date of this notice and considered in the final determina-
tion regarding permit issuance and permit provisions.The Director of the
NC Division of Energy,Mineral,and Land Resources(DEMLR)may hold a
public hearing should there be a significant degree of public interest.
Please mail comments and/or Information requests to DEMLR at 1612
Mail Service Center,Raleigh,NC 27699-1612.
-Ennis Flint,Inc.[201 Old Thomasville Road,High Point,NC 272601 has re-
quested renewal of permit NCS000582 for the Ennis Flint High Point Facili-
ty in Guilford County.This facility discharges to an unnamed tributary to
Kennedy Mill Creek in the Yadkin-Pee Dee River Basin.
Interested persons may visit DEMLR at 512 N.Salisbury Street Raleigh,
NC 27604 to review information on file.Additional information an NPDES
permits and this notice may be found on our website:
https✓/deq.nc.gov/about/divisions/energy-mineral-and-land-resources/s
tormwater/stormwater-prograMstormwater-public-notices,or by con-
tacting Brianna Young at brianna.young®ncderingov or 919-707-3647.

Compliance Inspection Report
Permit:NCS000582 Effective: 09/01/15 Expiration: 08/31/20 Owner: Ennis Flint
SOC: Effective: Expiration: Facility: Ennis Flint
County: Guilford 201 Old Thomasville Rd
Region: Winston-Salem
High Point NC 27260
Contact Person:Jennifer Williams Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 04/20/2023 Entry Time 09:45AM Exit Time: 11:45AM
Primary Inspector:Lily C Kay Phone: [phone]
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: NCS000582 Owner-Facility:Ennis Flint
Inspection Date: 04/20/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This inspection was conducted in conjunction with the renewal of the NPDES permit. The facility appeared well operated
and maintained with most of the necessary documentation. If you have questions, contact me at [e-mail] or by
phone at(704)235-2137.
Page 2 of 3

Permit: NCS000582 Owner-Facility:Ennis Flint
Inspection Date: 04/20/2023 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: The Stormwater Pollution Prevention Plan (SWPPP) and related documentation was complete
except the employee training documentation. The facility is developing a stormwater training
program.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment: Qualitative monitoring records were available and complete.
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: Analytical monitoring records were available and complete and all results were below the
benchmark limitations.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ ❑ 0 ❑
Comment: The facility has one outfall from a stormwater pond and the valve is damaged. The facility
plans to increase the size of the pond and trees were cut around the pond at the time of
inspection.
Page 3 of 3

Young, Brianna A
From: Schwendeman, Timothy M <[e-mail]>
Sent: Tuesday, May 23, 2023 1:46 PM
To: Young, Brianna A
Cc: Krahn, Randy W; Johnson, Sarah A
Subject: [External] RE: <EXT>FW: Ennis Flint High Point Facility (NCS000582)
Attachments: NPDES Stormwater Permit Contact Update Request.pdf; High Point Analytical Data
Summary.xlsx; Best Management Practices Summary - Ennis-Flint High Point.docx
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.
Brianna,
Please see responses in red below. We have also updated the permit/billing/facility contact information as seen
in the confirmation attached.
Please let me know if you have any further questions/concerns.
Regards,
Tim
Tim Schwendeman
Regional Environmental Manager-Southeast
PPG Corporate Environmental Affairs
M: [phone]
Email: tschwende man(c�ppg.com
ppg.com
• Description of industrial activity occurring onsite;
o The facility manufactures resin products for incorporation into paint products for in-house distribution.
• Confirmation on the number of outfalls and associated coordinates;
0 1 outfall (Outfall-001)
o Latitude: 35.933876' & Longitude: -80.030011'
• Description of industrial activity in each drainage area;
o Manufacturing/Office building: an approximately 10,900 square foot building; contains office space,
warehouse/storage space for raw materials, a warm raw materials storage room, and houses all
manufacturing processes; minor hydraulic fluid changes for forklifts are also completed inside of the
building.
o Aboveground Storage Tanks (ASTs): located west of the manufacturing/office building; a total of eleven
ASTs are located on site,which store raw materials and finished goods;the ASTs are located within the
two concrete floored/walled containment berms.
o Outbuilding/shelter: an approximately 400-square foot shelter; used for the storage of Suppressor 2218
foam control agent.
i

o A stormwater retention pond is located to the west of the main facility structures.The retention pond is
the receiving point for all stormwater catchments located around the main facility structures described
above and contains one outfall location (Outfall-001).
• SIC (NAICS) code;
o Standard Industry Classification (SIC) Code 2821 (Plastic Materials and Resins)
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
o Attached
• Verification that the information in the renewal application is still complete and correct; and
o Some contact information (attached). Updated Best Management Practices (attached).
• An explanation of any operational changes since the renewal application was submitted.
o No changes
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 (Updated)
• Permit contact: Permit Contact Update Request Form(Updated)
• Facility contact: Permit Contact Update Request Form(Updated)
• 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 (No outstanding payments)
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
2

Physical address: 512 North Salisbury Street, Raleigh, NC 27604
D E "7'�`
IQ 10�
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.
3

DEQ-) NPDES Stormwater
Request
NPDES Permit Enter your NPDES stormwater permit number or Certificate of Coverage(COC)number.
Number* NCS000582
Begins with NCS,NCG,or NCGNE(no exposure)
Facility Name* Ennis Flint
(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)
Q Permit Contact Update
Q Billing Contact Update
Q 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
Sarah Johnson
E-mail Address* [e-mail]
Phone No.* 336-308-3994
Mailing Address* 201 Old Thomasville Rd, High Point, NC 27260
Physical Address If different than mailing address
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
Randy Krahn
E-mail Address* [e-mail]
Phone No.* 336-308-3843

Mailing Address* 201 Old Thomasville Rd, High Point, NC 27260
Physical Address If different than mailing address
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
Randy Krahn
E-mail Address* [e-mail]
Phone No.* 336-308-3843
Mailing Address* 201 Old Thomasville Rd, High Point, NC 27260
Physical Address If different than mailing address
Add another facility contact if needed by clicking the'Add'button below
Submitter's Name* Please enter your FIRST and LAST name
Tim Schwendeman
Phone Number* Please enter your phone number
216-210-9827
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*
�f>c /1re'.t�ill�P�fc�.Il
Date 5/22/2023
Questions? Contact [e-mail].

Ennis-Flint(High Point Facility)
Permit Number: NCS000582
Outfal I: 001
Sample Date
Parameter 3/6/2018 10/10/2018 2/20/2019 7/23/2019 1/7/2020 9/25/2020 1/25/2021 11/22/2021 6/14/2022 11/15/2022 Benchmark
TSS(mg/L) 84.5 36.3 8.5 20.8 36.5 138 5.14 7.4 18.8 50 100
BOD(mg/L) 7.6 1.85 <2.0 9.7 2.3 7.7 4.7 4.7 14.0 5.56 30
COD(mg/L) 101 16.7 25.4 29.4 16.2 26.9 47.2 20.2 42.5 <20.0 120
Ammonia as Nitrogen(mg/L) <0.1 0.258 <0.1 0.262 0.183 <0.250 <0.250 <0.250 1.67 0.333 8.4
pH(SU) 1 7.8 1 7.8 1 7.8 1 8.0 1 7.9 1 7.2 1 8 1 7.7 1 7.3 1 7.5 1 6-8

Best Management Practices Summary
Facility Area/Process Structural orBNoPn-Structural Implementation Schedule
Aboveground Storage Tanks Secondary containment Currently in place
structures or curbs/limit
offloading during rainfall events
/routine inspection of ASTs
Intermediate Bulk Container Secondary containment Currently in place
Tote Storage Shelter structures or curbs/maintain
open materials transfer routes
Warm Raw Materials Storage Secondary containment Currently in place
Room structures or curbs/maintain
open materials transfer routes
Production Room Secondary containment Currently in place
structures or curbs/prohibit
bulk storage of hazardous
materials
Warehouse Maintain open materials Currently in place
transfer routes
Eastern Loading Bays Covered overhangs to limit Currently in place
exposure to stormwater
Hazardous Material Transfer Maintain forklift operator Currently in place
Routes training programs/maintain
SPRP and spill response
materials
Outdoor Dumpsters Restrict hazardous Currently in place
chemicals/substances/powdered
solids
Outdoor Pallet Storage Area Restrict outdoor storage to Currently in place
clean pallets only
All site areas General good housekeeping Currently in place
practices
Aboveground Storage Tanks
A table containing information related to AST usage and construction is provided in Section 1.2. BMPs
currently being practiced include secondary containment structures(concrete floor/berm walls) around all
ASTs,as well as a secondary containment structure utilized by the tanker trucks during offloading of bulk
liquids. The ASTs and associated transfer piping will be visually inspected on a routine basis for cracks,

bulging,pitting,rust/corrosion,loose fittings,or any other physical defects which could contribute to a
release. The concrete secondary containment structures will be routinely inspected for signs of cracking,
spills/leaks, or drainage issues. Signs are present designating this as a hazardous material storage area.
Post Addition Shelter
A shelter for post additions,which contain any post addition raw materials,is located south of the ASTs.
The shelter is constructed with a concrete floor and a secondary containment structure consisting of a
concrete containment curb. The post additions are pumped from the shelter to the appropriate tank. BMPs
in place include the inspection of the overhead piping for signs of deterioration and damage. The concrete
secondary containment structure will be routinely inspected for signs of cracking, spills/leaks, or drainage
issues..
Warm Raw Materials Storage Room
A description of the warm raw materials storage room is provided in Section 1.3. BMPs include a
secondary containment structure (concrete berm)to contain any potential spills or leaks which may occur.
Loading bays with covered overhangs,located along the eastern side of the main building,will be utilized
during delivery/offloading of the raw materials stored in this room in order to limit their potential for
exposure to stormwater during rainfall events. Raw materials are transported between the warm raw
materials storage room and the production room via forklift on an as-need basis. The concrete secondary
containment structure will be routinely inspected for signs of cracking, spills/leaks, or drainage issues.
Signs are present designating this as a hazardous material storage area.
Production Room
A description of the production room is provided in Section 1.3.As with the warm raw materials storage
room,the production room also contains a secondary containment structure (concrete berm)to contain
spills/leaks. The materials transfer route between the production room and adjacent warm raw materials
storage room should be maintained free of clutter at all times to prevent spills associated with forklift
operation. The concrete secondary containment structure will be routinely inspected for signs of cracking,
spills/leaks, or drainage issues.
Warehouse
Located east of the production and warm raw materials storage rooms,this area of the facility is used for
storage of various other hazardous and non-hazardous materials used in the production process (see table
in Section 1.3). The raw materials are packaged in a combination of 55-gallon drums and paper sacks, and
are stored on pallet racks/shelving along the perimeter of the room. Materials are transferred to the

production room via forklift as they are needed. The materials transfer route between the warehouse and
production room should be maintained free of clutter at all times to prevent spills associated with forklift
operation. Signs are present designating this as a hazardous material storage area.
A floor drain is located in the central portion of the warehouse room and will contain any spills that may
occur within the warehouse area. The drain is plumbed directly to a belowground 700-gallon capacity
steel-walled holding vault located west of the manufacturing building and north of the ASTs. The steel
vault was verified to be the direct and only discharge point of the warehouse floor drain through use of a
plumbing inspection camera in June 2014.
Eastern Loading Bays
Two loading bays with covered overhangs are located along the eastern side of the facility. All raw
materials that are stored in non-bulk quantities will be delivered to the site and offloaded at the covered
loading bays. Covered overhangs limit the potential for materials to be exposed to stormwater during the
delivery/unloading process.
Hazardous Material Routes
Exposure of contaminants to rainfall and stormwater could occur in this process if forklift mishaps result
in spills or releases of materials.A summary of potential BMPs to minimize the potential for exposures of
contaminants to stormwater is provided as follows.
• Forklift operator training: all facility employees who operate forklifts are trained in the proper
and safe procedures for such operation.
• Spill response: the facility SPRP includes procedures for prompt response to material and waste
spills/releases, should they occur. Spill and release cleanup equipment is staged at various facility
locations for rapid and convenient access,as documented in the SPRP.
• Minimize outdoor transfers of materials/wastes during rainfall events: facility personnel involved
in material/waste transfers are instructed to avoid such transfers during rainfall events whenever
possible. If transfers are necessary during rainfall events,personnel should utilize loading bays
with covered overhangs for loading and offloading materials.
Outdoor Dumpsters
Two dumpsters are located outdoors near the northwest corner of the manufacturing/office building. An
open 30-cubic yard capacity dumpster is used for disposal of general facility wastes,while an 8-cubic

yard capacity covered dumpster is used for cardboard recycling. Hazardous chemicals, substances,and
powdered solids are expressly prohibited from disposal in the dumpster.. The dumpsters should be
routinely inspected for the presence of cracks,holes,or other damages which could result in the wastes
being exposed to stormwater.
Outdoor Pallet Storage
Damaged and unused pallets are stored outdoors in an uncovered location near the northwest corner of the
manufacturing/office building,adjacent to the waste dumpsters. Pallets should not be stored outdoors in
an uncovered location unless the pallets are clean and completely free of raw materials. Any damaged
pallets showing signs of staining from raw materials should be either stored indoors, or thoroughly
cleaned prior to transporting them to the outdoor storage area.
No other facility features have been observed which could potentially generate adverse stormwater
exposures.

3/20/23,2:17 PM 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
Ennis-Flint, Inc.
Information
Sosld: 1646895
Status: Current-Active O
Date Formed: 12/31/2017
Citizenship: Domestic
Fiscal Month: December
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: Corporation Service Company
Addresses
https://www.sosnc.gov/onIine_services/search/Business_Registration_ResuIts 1/2

3/20/23,2:17 PM North Carolina Secretary of State Search Results
Reg Office Reg Mailing Mailing
2626 Glenwood Ave Ste 550 2626 Glenwood Ave Ste 550 4161 Piedmont Parkway Suite 370
Raleigh, NC 27608 Raleigh, NC 27608 Greensboro, NC 27410
Principal Office
4161 Piedmont Parkway Suite 370
Greensboro, NC 27410
Off icers
President Secretary
Edward Baiden Laura Greer
4161 Piedmont Parkway Suite 370 4161 Piedmont Parkway, Suite 370
Greensboro NC 27410 Greensboro NC 27410
Vice President Treasurer
Brice Hester John A Jankowski
4161 Piedmont Parkway Suite 370 4161 Piedmont Parkway, Suite 370
, Greensboro NC 27410 Greensboro NC 27410
Stock
Class: Common
Shares: 1000
Par Value 0.001
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2

PIEDMONT 6003-145 Chapel Hill Rd.
27607
GEOLOGIC Raleigh, -9532
%NN P:919-854-97p0 F:919-8549532
SMART EARTH SOLUTIONS wwwr.piedmontgeologic.com
October 30,2020
Ms. Suzanne McCoy
Stormwater Program Assistant
DEMLR—Stormwater Program
North Carolina Department of Environmental Quality
1612 Mail Service Center
Raleigh,NC 27699-1612
RE: NPDES Stormwater Individual Permit Renewal(NCS000582)
Ennis-Flint High Point Facility
201 Old Thomasville Road,High Point,NC
Dear Ms.McCoy:
Enclosed are the NPDES stormwater individual permit renewal forms and associated supporting
information for the Ennis-Flint facility referenced above. As indicated in an October 29,2020 email from
Mr.Jonathan Murphrey(Piedmont Geologic)to Ms.Bethany Georgoulias(Environmental Engineer,
DEMLR—Stormwater Program),Ennis-Flint inadvertently allowed coverage of the referenced permit to
elapse without renewal(the permit expired on August 31,2020). In accordance with Ms. Georgoulias'
instructions,Piedmont Geologic(on behalf of Ennis-Flint)is submitting the requisite permit-renewal forms
and supporting information to ensure continued coverage under the permit.
If you have any questions or would like any additional information,please do not hesitate to call.
Sincerely:
J&na&avwD. Murphrvy
Jonathan D.Murphrey,P.G.
Staff Geologist
cc: Jennifer Williams,Ennis-Flint
Dena Vandenberg,Ennis-Flint
Attachments

Permit Coverage
Renewal Application Form
National Pollutant Discharge 'Elimination System NP NC Permit Number
Environm cn rof
Stormwater Individual Permit S ooassz
Qlrality
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 which permit correspondence will be mailed
Owner/Organization Name: Ennis-Flint
Owner Contact: Jennifer Williams
Mailing Address: 4161 Piedmont Parkway,Suite 370
Greensboro,NC 27410
Phone Number: [phone]
Fax Number: [phone]
E-mail address: [e-mail]
Facility Information
Facility Name: Ennis-Flint High Point
Facility Physical Address: 201 Old Thomasville Road
High Point,INC 27260
Facility Contact: Randy Krahn
Mailing Address: 201 Old Thomasville Road
High Point,NC 27260
Phone Number: [phone]
Fax Number:
E-mail address: [e-mail]
Permit Information
Permit Contact: Jennifer Williams
Mailing Address: 4161 Piedmont Parkway,Suite 370
Greensboro,NC 27410
Phone Number: [phone]
Fax Number: [phone]
E-mail address: [e-mail]
Discharge Information_
Receiving Stream: Kennedy Mill Creek
Stream Class: C
Basin: Yadkin
Sub-Basin:
Number of Outfalls: 1
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit, Attached a
separate sheet if necessary.
No significant changes to facility operations,materials storagelhandling practices,or types of raw materials used at the facility.A small grassed area north of the building entrance was paved,
creating a small increase in site impervious surface area.With respect to raw materials used on site,there was a reduction in the percentage of aqua ammonia(reduced from 29%to 19%ammonia)
beginning in February 2020.
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is tru complete anq
Signature accurate.
Date 10f30r20
nnifer Williams EHS Manager-Safety
Print or type name of person signing above Title
DEMLR- Stormwater Program
Please return this completed application form Dept, of Environmental Quality
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Scanned with Cant c nner

ST
ORMWATER POLLUTION PREVENTION PLAN
F1 .......... DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources— Stormwafer Program
Facility Name:
Ennis-Flint High Polnl
Permit Number: NCS000582
Location Address: 201 Old Thomasville Road
High Point.NC 27260
County: Guilford
"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 10130120
Vu---jr
nifer Williams EHS Manager•Safety
Print or type name of person signing above Title
SPPP certifIcation 10113
Scanned with CamScanner

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
J W 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.
J W 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.
J W 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.
J W 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.
JW 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.
J W 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)

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FIGURE 1
SITE AREA MAP
ENNIS-FLINT
201 Old Thomasville Road, High Point, NC

N
IF
Stormwater basin V, cck
IBC tote
Stormwater
t staging area catchments
Manufacturing/
office building
Stormwater ditch/piping IAl
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' Outfall-001
Witt,' Loading bay
= Raw material ASTs
Bermed containment pad for with secondary
raw materials offloading containment structures
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Ave
100 200 300 400 500 feet FIGURE SITE MAP
PIEDMONT
GEOLOGIC Ennis-Flint
Data Source:High resolution orthoimagery,NC Orthoimagery Program,2018. 201 Old Thomasville Road
SMART EARTH SOLUTIONS Note:Site property boundary approximate;obtained from
Guilford County GIS. High Point,NC 27260

N
A-17
S
17
Stormwater basin
w.
.4v IBC tote
Stormwater
staging area catchments
' Manufacturing/
office building
Stormwater in ditch/p ip g ''' < ° Impervious
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Outfall-001 --
f s r
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_ Raw material ASTs
Bermed containment pad for with secondary
raw materials offloading containment structures
e
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0 100 200 300 400 500 feet FIGURE 3
PIEDMONT IMPERVIOUS SURFACES
GEOLOGIC Ennis-Flint
Data Source:High resolution orthoimagery,NC Orthoimagery Program,2018. 201 Old Thomasville Road
SMART EARTH SOLUTIONS Note:Site property boundary approximate;obtained from
Guilford County GIS. High Point,NC 27260

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Stormwater basin C'eek
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Outfall-001
Stormwater flow Stormwater
7:� A OWL direction drainage basin w
boundary
.r. In 'i A14
Eugene Ave
100 200 300 400 500 feet FIGURE 4
PIEDMONT
STORMWATER DRAINAGE
BASINS&FLOW DIRECTIONS
GEOLOGIC Ennis-Flint
Data Source:High resolution orthoimagery,NC Orthoimagery Program,2018. 201 Old Thomasville Road
SMART EARTH SOLUTIONS Note:Site property boundary approximate;obtained from
Guilford County GIS. High Point,NC 27260

Summary of Analytical Monitoring Results-Outfall 001
Ennis-Flint High Point Facility
201 Old Thomasville Road,High Point,NC
NPDES Stormwater Individual Permit NCS000582
Sample TSS BOD COD Ammonia as pH
Date (mg/L) (mg/L) (mg/L) Nitrogen(mg/L) (SU)
12/22/2015 42.0 <3.33 17.1 <0.250 8.0
6/28/2016 112 105 590 4.38 8.8
10/7/2016 36.5 16.9 115 1.54 7.5
5/23/2017 22.7 <10 223 1.54 8.1
12/20/2017 31.3 7.9 72.8 0.324 7.5
3/6/2018 84.5 7.6 101 <0.100 7.8
10/10/2018 36.3 1.85 16.7 0.258 7.8
2/20/2019 8.5 <2.0 25.4 <0.100 7.8
7/23/2019 20.8 9.7 29.4 0.262 8.0
1/7/2020 36.5 2.3 16.2 0.183 7.9
9/25/2020 1 138 1 7.7 1 26.9 1 <0.250 1 7.2
Permit Benchmark 1 100 30 120 8.4 6.0-8.0
TSS=Total suspended solids.
BOD=Biochemical oxygen demand
COD=Chemical oxygen demand
SU=Standard units

Summary of Qualitative Monitoring Results-Outfall 001
Ennis-Flint High Point Facility
201 Old Thomasville Road,High Point,NC
NPDES Stormwater Individual Permit NCS000582
Sample Color Odor Clarity Floating Solids Suspended Solids Foam Oil Sheen Erosion or
Date (1) (2) (3) Present? Present? Deposition?
12/22/2015 Light brown None 1 1 1 No No No
6/28/2016 Light brown None 1 1 1 No No No
10/7/2016 Light brown None 1 1 1 No No No
5/23/2017 Light brown None 3 2 2 No No No
12/20/2017 Light brown None 1 1 2 No No No
3/6/2018 Light brown None 3 2 2 No No No
10/10/2018 Light brown None 1 1 1 No No No
2/20/2019 Light brown None 3 1 2 No No No
7/23/2019 Light brown None 1 1 1 No No No
1/7/2020 Light brown None 1 1 1 No No No
9/25/2020 Light brown None 2 1 2 No No No
(1)Rating on a scale of 1 to 5,where 1 is clear and 5 is very cloudy.
(2)Rating on a scale of 1 to 5,where 1 is no solids and 5 is the surface is covered with floating solids.
(3)Rating on a scale of 1 to 5,where 1 is no solids and 5 is extremely muddy.

Ennis-Flint High Point Facility
Summary of Best Management Practices
Best Management Practices Summary
Facility Area/Process Structural orBNoPn-Structural Implementation Schedule
Aboveground Storage Tanks Secondary containment Currently in place
structures or curbs/limit
offloading during rainfall events
/routine inspection of ASTs
Intermediate Bulk Container Secondary containment Currently in place
Tote Storage Shelter structures or curbs/maintain
open materials transfer routes
Flammable Materials Storage Secondary containment Currently in place
Room structures or curbs/maintain
open materials transfer routes
Production Room Secondary containment Currently in place
structures or curbs/prohibit
bulk storage of hazardous
materials
Warehouse Maintain open materials Currently in place
transfer routes
Eastern Loading Bays Covered overhangs to limit Currently in place
exposure to stormwater
Hazardous Material Transfer Maintain forklift operator Currently in place
Routes training programs/maintain
SPRP and spill response
materials
Outdoor Dumpsters Fully enclosed and covered Currently in place
Outdoor Pallet Storage Area Restrict outdoor storage to Currently in place
clean pallets only
All site areas General good housekeeping Currently in place
practices
Aboveground Storage Tanks
BMPs currently being implemented include secondary containment structures (concrete floor/berm walls)
around all ASTs,as well as a secondary containment structure utilized by the tanker trucks during
offloading of bulk MMA and BA. The ASTs and associated transfer piping will be visually inspected on
a routine basis for cracks,bulging,pitting,rust/corrosion, loose fittings, or any other physical defects
which could contribute to a release. The concrete secondary containment structures will be routinely

Ennis-Flint High Point Facility
Summary of Best Management Practices
inspected for signs of cracking, spills/leaks, or drainage issues. Signs are present designating this as a
hazardous material storage area.
Intermediate Bulk Container Tote Storage Shelter
A storage shelter for IBC totes,which contain ammonium hydroxide, is located south of the ASTs. The
shelter is constructed with a concrete floor and a secondary containment structure consisting of a concrete
containment curb. The ammonium hydroxide is pumped from the totes to the production room via
overhead piping. BMPs in place include the inspection of the overhead piping for signs of deterioration
and damage. The concrete secondary containment structure will be routinely inspected for signs of
cracking, spills/leaks, or drainage issues. Signs are present designating this as a hazardous material
storage area.
Flammable Materials Storage Room
BMPs include a secondary containment structure(concrete berm)to contain any potential spills or leaks
which may occur. Loading bays with covered overhangs,located along the eastern side of the main
building,will be utilized during delivery/offloading of the raw materials stored in this room in order to
limit their potential for exposure to stormwater during rainfall events. Raw materials are transported
between the flammable materials storage room and the production room via forklift on an as-need basis.
The concrete secondary containment structure will be routinely inspected for signs of cracking,
spills/leaks, or drainage issues. Signs are present designating this as a hazardous material storage area.
Production Room
As with the flammable materials storage room,the production room also contains a secondary
containment structure(concrete berm)to contain spills/leaks. The materials transfer route between the
production room and adjacent flammable materials storage room should be maintained free of clutter at
all times to prevent spills associated with forklift operation. The concrete secondary containment
structure will be routinely inspected for signs of cracking, spills/leaks, or drainage issues.
Warehouse
Located west of the production and flammable materials storage rooms,this area of the facility is used for
storage of various other hazardous and non-hazardous materials used in the production process. The raw
materials are packaged in a combination of 55-gallon drums, 5-gallon pails, and paper sacks, and are
stored on pallet racks/shelving along the perimeter of the room. Materials are transferred to the
production room via forklift as they are needed. The materials transfer route between the warehouse and

Ennis-Flint High Point Facility
Summary of Best Management Practices
production room should be maintained free of clutter at all times to prevent spills associated with forklift
operation. Signs are present designating this as a hazardous material storage area.
A floor drain is located in the central portion of the warehouse room and will contain any spills that may
occur within the warehouse area. The drain is plumbed directly to a belowground 700-gallon capacity
steel-walled holding vault located west of the manufacturing building and north of the ASTs. The steel
vault was verified to be the direct and only discharge point of the warehouse floor drain through use of a
plumbing inspection camera in June 2014.
Eastern Loading Bays
Two loading bays with covered overhangs are located along the eastern side of the facility. All raw
materials that are stored in non-bulk quantities will be delivered to the site and offloaded at the covered
loading bays. Covered overhangs limit the potential for materials to be exposed to stormwater during the
delivery/unloading process.
Hazardous Material Routes
Exposure of contaminants to rainfall and stormwater could occur in this process if forklift mishaps result
in spills or releases of materials. A summary of potential BMPs to minimize the potential for exposures
of contaminants to stormwater is provided as follows.
• Forklift operator training: all facility employees who operate forklifts are trained in the proper
and safe procedures for such operation.
• Spill response: the facility SPRP includes procedures for prompt response to material and waste
spills/releases, should they occur. Spill and release cleanup equipment is staged at various
facility locations for rapid and convenient access, as documented in the SPRP.
• Minimize outdoor transfers of materials/wastes during rainfall events: facility personnel involved
in material/waste transfers are instructed to avoid such transfers during rainfall events whenever
possible. If transfers are necessary during rainfall events,personnel should utilize loading bays
with covered overhangs for loading and offloading materials.
Outdoor Dumpsters
Two covered dumpsters are located outdoors near the northwest corner of the manufacturing/office
building. A 30-cubic yard capacity dumpster is used for disposal of general facility wastes,while an 8-
cubic yard capacity dumpster is used for cardboard recycling. The dumpsters are fully covered such that

Ennis-Flint High Point Facility
Summary of Best Management Practices
they would not normally be exposed to stormwater. Loading of garbage to the dumpster should be
limited during rainfall events in order to prevent exposure to stormwater. The dumpsters should be
routinely inspected for the presence of cracks,holes, or other damages which could result in the wastes
being exposed to stormwater.
Outdoor Pallet Storage Area
Damaged and unused pallets are stored outdoors in an uncovered location near the northwest corner of the
manufacturing/office building, adjacent to the waste dumpsters. Pallets should not be stored outdoors in
an uncovered location unless the pallets are clean and completely free of raw materials. Any damaged
pallets showing signs of staining from raw materials should be either stored indoors, or thoroughly
cleaned prior to transporting them to the outdoor storage area.
No other facility features have been observed which could potentially generate adverse stormwater
exposures.