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HomeMy WebLinkAboutNCS000235_COMPLIANCE_20170629_- STORMWATER-DIVISION-CODI NG-SHEET PERMIT NO. N LS 000a S DOC TYPE ❑ FINAL PERMIT ❑ MONITORING INFO ❑ APPLICATION �? COMPLIANCE ❑ OTHER DOC DATE ❑ 2 Ul 6 2 YYYYM M DD :1 Energy, Mineral & Land Resources ENVIRONMENTAL QUALITY John Myers, QC Manager Southern Resins, Inc. 3440 Denton Road Thomasville, NC 27360 June 29, 2017 Subject: Compliance Inspection I Spill Response Permit No. NCS 000235 Southern Resins, Inc. Davidson County Dear Mr. Myers: ROY COOPER Governor MICHAEL S. REGAN Secretary TRACY DAVIS Director On June 28, 2017 Glen White of the North Carolina Department of Environmental Quality; Department of Energy, Minerals, and Land Resources met with you (Quality Control Manager) and Bryce Young (Site Operations Manager) at the facility located at 3440 Denton Road, Thomasville, to conduct an inspection as part of the response procedures following a spill of sufficient volume to require reporting. This inspection consists of review of the Stormwater Pollution Prevention Plan, training, monitoring and spills records, emergency response and responsible party review as well as observation of the condition of the site with emphasis on areas of the May 26, 2017 spill. Your assistance with the inspection was greatly appreciated. Spill & Response: On May 26, 2017, Southern Resin, Inc. reported a spill of approximately 2500 gallons of formaldehyde and acetone based resin. On the day of the spill Shamrock Environmental had just arrived onsite for a scheduled clean -out of another reactor/tank and had all of their equipment onsite. At approximately 6:30 am an employee noticed that one of the reactors was leaking product from the hatch at the op of the ractor. Response was immediate. Shamrock Environmental, already on site to conduct other scheduled work, began work to control and clean-up. Major clean-up began at the reactor containment area and adjacent grassed area. One, Grate inlet was affected in the grassed area. That inlet drains directly to one of the detention ponds. The pond inlet was diked to prevent drainage from entering the pond and Shamrock began pumping out and flushing the inlet pipe. NCDEQ was immediately notified. Bonnie Ware, P.G., Hydrogeologist with NCDEQ took soil samples at the spill site and water samples from the ponds and downstream locations. At the time of this visit, results were not back but Mr. Myers said he would forward a copy as soon as available. This facility is fortunate that it has the detention pond system and that it does not drain directly into any waters of the state. Exceedance of formaldehyde and nitrogen continue and site is State ofKortrtCaroUna t FnviranmenralOuality I Energy. Mineral and Land Resources Winston-Salem Region a[ Of#ice t 450 Hanes ,1Ai1 Road, Suite 300 i Winston-Salem. NC 27103 33b 776 9800 currently operating in Tier II/Tier III response. Effluent flows into an unnamed tributary that drains to Hamby Creek. Hamby Creek is encumbered by fecal coliform contamination, unrelated to any activity conducted at this facility. Soils were removed from the grassy area of the spill. All soil removed remains in Shamrock waste containers with cover until test results are back on the soils. John Myers (Quality Control Manager) and Bryce Young (Site Operating Manager) have purchased specialty gate valves to be installed in the storm drain lines near pond inlets so they can be shut off quickly in the event of another spill. Operator error was found to be the cause of failure/spill. The operator forgot to tighten down the hatch bolts and once reaction began, the product began to spill out. Mr. Myers has documented the spill and response and is implementing new procedures and preventative measures to reduce the chance of a similar incident in the future. Permit: This facility holds Individual Stormwater Permit NCS 000235 to discharge stormwater from industrial activity associated with industrial processes under the National Pollutant Discharge Elimination System (NPDES). The permit became effective November 1, 2010 and expired on October 31, 2015. The facility remains covered under the expired permit until a new permit is issued. A copy of the current permit is required to be maintained with the Stormwater Pollution Prevention Plan (SPPP) documents. The permit was available for review at the time of inspection. Records/Reports: This facility was required to develop and maintain a (Stormwater Pollution Prevention Plan) SPPP in accordance with Part H, Section A of the permit. The facility has developed a SPPP. Training and spills records are current and maintained. Monitoring has been performed as per the permit. Rainfall records are recorded daily at Pond 3 Outfall. Weekly inspections are conducted at each of the containment areas and samples are taken before any contained area can be discharged. No deficiencies found. Facility Site Review: This facility manufactures the main ingredient for making Elmer's School Glue and makes the resin used to make the fiberglass fiber used in air filters. The facility has several containment areas that contain tanks and vats used in production processes. Many of the facilities are new and added within the past year. The plant has three (3) stormwater ponds. They are designed to function in series. Stormwater drains to Pond 1, then into Pond 2, then Pond 3 before it discharges through two (2) pipes that outlet to Hamby Creek. Effluent Receiving Waters: Effluent from this facility drains to Hamby Creek, class "C" waters of the Yadkin Pee Dee River Basin. State of North Carolina I Environmental Qual ty I Energy. Minerat and Land Resources Winston-Salem Regionai Office 1 450 Hanes Mill Road, 5uitc 300 1 'Winston-Salem. NC 27103 33b Th 9800 y 'Self -Monitoring Program: The permit requires qualitative and analytical monitoring be conducted twice annually unless a Tiered response is triggered. The facility is currently operating in Tier IUTier III response due to consecutive parameter exceedance for Formaldehyde and Nitrogen. This facility was very well maintained and stormwater records were well documented and current. The facility followed proper reporting, response and documenting procedures during and after the reported spill. Soouthern Resins was found to be compliant with requirements of its industrial stormwater permit. If you have questions or need additional information, please contact Glen White at (336) 776-9660. Sincerely, Matthew E. Gantt, P.E. Regional Engineer Land Quality Section Winston-Salem Regional Office Enclosures: Inspection Report cc: File Copy Division of Energy, Mineral and Land Resources (WSRO) State cat tiorth Carolina Enviroornental Qualtty 1 Energy, A4incral and Land Rescxarcc:s Winston-Sa!ern Regionai Office 1450 Hares A4i11 Read. S€rite 300 [ Winston-Salem NC 27103 336,176 9800 i' Permit: NCS000235 SOC: County: Davidson Region: Winston-Salem Contact Person: Allen Grubb Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Compliance Inspection Report Effective: 11/01/10 Expiration: 10/31/15 Owner: Southern Resin Inc Effective: Expiration: Facility: Southern Resin Incorporated 3440 Denton Rd Title. Operations Mgr. Inspection Date: 06/28/2017 Entry Time: 10:OOAM Primary Inspector: Glen White Secondary tnspector(s): Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant ❑ Not Compfiant Question Areas: 0 Storm Water (See attachment summary) Certification: Thomasville NC 27360 Phone: 336-475-1348 Phone: Exit Time: 11:30AM Phone: 336-776-9800 Inspection Type: Spill/Emergency Response Page: 1 Permit: NCS000235 owner - Facility: Southern Resin Inc inspection Date: 06/28/2017 Inspection Type: Spill/Emergency Response Reason for Visit: Routine Inspection Summary: This inspection was conducted as part of NCDEQ's response following a spill of an estimated 2500 gallons of formaldehyde and acetone based resin. On the date of the spill, Shamrock had just arrived on site to clean out one of the tanks as scheduled and had all of their equipment ready for use. At approximately 6.30am on 5/26/17 an employee noticed that one of the reactors was leaking product from the hatch at the top of reactor. Response was immediate. Shamrock Environmental, already on site to conduct other scheduled work, began work to control and dean -up. Major clean-up began at on the reactors containment area and adjacent grassed area. one grate inlet was affected in the grassed area. That inlet drains directly to one of the detention ponds. That ponds inlet was diked to prevent drainage from entering the pond and Shamrock began pumping out and flushing the inlet pipe. NCDEQ was notified. Bonnie Ware, P.G. , Hydrogeologist with NCDEQ took soil samples at the spill site and water samples from the ponds and downstream. At the time of this visit, results were not back but Mr. Myers said he would forward a copy as soon as available. This facility is fortunate that it has the detention ponds and that it does not drain directly into an waters of the state. Exceedance of formaldehyde'and nitrite continue and site is currently operating in Tier llfrierlll response. Effluent flows into an unnamed tributary that drains to Hamby Creek. Hamby Creek is encumbered by fecal coliform contamination, unrelated to any activity conducted at this site. Soils were removed from the grassy area of the spill. All soil removed remains in Shamrock waste containers with cover until test results are back on soils. John Myers (Quality Control Manager) and Bryce Young (Site Operations Manager) have purchased specialty gate valves to be installed in the storm drain lines near pond inlets so they can be shut off quickly in the event of another spill. Operator Error was found to be the cause of the failure/spill. The operator forgot to tighten down the bolts on the hatch and once reaction began, the product began to spill out. Mr, Myers has documented the spill and response and is implementing new procedures and preventative measures to reduce the likelihood of a similar incident in the future. Page: 2 �T permit NCS000235 Owner - Facility: Southem Resin Inc Inspection Data: 06128/2017 Inspection Type: SpilVEmergency Response Reason for Visit: Routine Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan? # Does the Plan include a General Location (USGS) map? # Does the Plan include a "Narrative Description of Practices"? # Does the Plan include a detailed site map including outfall locations and drainage areas? # Does the Plan include a list of significant spills occurring during the past 3 years? # Has the facility evaluated feasible alternatives to current practices? # Does the facility provide all necessary secondary containment? # Does the Plan include a BMP summary? # Does the Plan include a Spill Prevention and Response Plan (SPRP)? # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? # Does the facility provide and document Employee Training? # Does the Plan include a list of Responsible Party(s)? # Is the Plan reviewed and updated annually? # Does the Plan include a Stormwater Facility Inspection Program? Has the Stormwater Pollution Prevention Plan been implemented? Yes No NA NE ■❑❑❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Cl ❑ ❑ ❑ ❑ ❑ ❑ M ❑ ❑ ❑ ❑ ❑ ❑ M ❑ ❑ ❑ M ❑ ❑ ❑ ❑ ❑ ❑ M ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Comment: Mr. Myers has done a good bb of maintaining the SPPP and keeping an updated record of spills, spills response, employee training, facility inspections and maintenance Iotas_ Qualitative Monitorin Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑ Comment: Monitoring conducted as permit requires. Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Yes No NA NE ■❑❑❑ ❑ ❑ N ❑ Comment: Monitoring conducted monthly under Tier IIITierill response for exceedance of formaldehvde and nitrogen. This is an old superfund site and contamination likely remains. Permit and OUtfails Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? E ❑ ❑ ❑ # Were all outfalls observed during the inspection? E ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ E ❑ # Has the facility evaluated all illicit (non Stormwater) discharges? 0 ❑ ❑ ❑ Comment: Spill response prompted inspection. Facility has one outfall, through two 15" HDPE_storm pipes outfalling from one of the ponds. Page: 3 iF a Energy, Mineral & Land Resources ENVIRONMENIAL QUALITY John Myers, QC Manager Southern Resins, Inc. 3440 Denton Road Thomasville, NC 27360 Z"o oo PAT McCRORY C,nvermu DONALD R. VAN DER VAART Secrvary October 17, 2016 TRACY DAVIS Dim -for Subject- Compliance Evaluation Inspection Permit No. NCS 000235 Southern Resins — Thomasville Davidson County Dear Mr. Myers: On October 12, 2016 Glen White of the North Carolina Department of Environmental Quality; Department of Energy, Minerals, and Land Resources met with you at the facility located at 3440 Denton Road, Thomasville, to conduct a compliance inspection per the Industrial Stormwater Permit requirements. Inspection consists of review of the Stormwater Pollution Prevention Plan, training, monitoring and spills records as well as observation of the general condition of the site, the outfalls and any possible exposures to downstream stormwater. Your assistance with the inspection was greatly appreciated. Permit: This facility holds Individual Stormwater Permit NCS 000235 to discharge stormwater from industrial activity associated with industrial processes under the National Pollutant Discharge Elimination System (NPDES). The permit became effective November 1, 2010 and expires on October 31, 2015. The facility remains covered under the expired permit until a new permit is issued. A copy of the current permit is required to be maintained with the Stormwater Pollution Prevention Plan (SPPP) documents. The permit was available for review at the time of inspection. Records/Reports: This facility was required to develop and maintain a (Stormwater Pollution Prevention Plan) SPPP in accordance with Part II, Section A of the permit. The facility has developed a SPPP. Training and spills records are current and maintained. Monitoring has been performed as per the permit. Rainfall records are recorded daily at Pond 3 Outfall. Weekly inspections are conducted at each of the containment areas and samples are taken before any contained area can be discharged. No deficiencies found. si'euR t�€ the r tPf L rrJlina I Elrvironmcntal Quality I Energy, Mineral and Lar?rl Resources tNinston Salem kegianal €�f{ice 1450 Hanes Mill Road, Suite 300 [ Winsion-Salem, NC 27103 3750 i IG <?800 Facility Site Review: This facility manufactures the main ingredient for making Elmer's School Glue and makes the resin used to make the fiberglass fiber used in air filters. The facility has several containment areas that contain tanks and vats used in production processes. Many of the facilities are new and added within the past year. The plant has three (3) stormwater ponds. They are designed to function in series. Stormwater drains to Pond 1, then into Pond 2, then Pond 3 before it discharges through two (2) pipes that outlet to Hamby Creek. Effluent Receiving Waters: Effluent from this facility drains to Hamby Creek, class "C" waters of the Yadkin Pee Dee River Basin. Self -Monitoring Program: The permit requires qualitative and analytical monitoring be conducted twice annually unless a Tiered Response is triggered. The facility is currently operating in Tier II Response due to consecutive parameter exceedance for Formaldehyde and Nitrogen. This facility was very well maintained and stormwater records were well documented and current. The facility was found to be compliant with requirements of its industrial stormwater permit. If you have questions or need additional information, please contact Glen White at (336) 776-9660. Sincerely, Matthew E. Gantt, P.E. Regional Engineer Land Quality Section Winston-Salem Regional Office Enclosures: Inspection Report cc: File Copy Division of Energy, Mineral and Land Resources (WSRO) Stab of North Carolina 1 Environmental Quality I Energy, Mineral and Land Resources Winston-Salem Regional Qffice 1450 (lanes Mil( Road Suite 300 I Winston-Salem NC 27103 336 776 9800 ill Permit: NCS000235 SOC: County: Davidson Region: Winston-Salem Contact Person: Allen Grubb Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative($): Related Permits: Compliance _Inspection Report Effective: 11/01/10 Expiration: 10/31/15 owner-: Southern Resin Inc Effective: Expiration: Facility: Southern Resin Incorporated 3440 Denton Rd Title: Operations Mgr. Inspection Date: 1011212016 Entry Time: 1 t:30AM Primary Inspector: Glen White Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant Not Compliant Question Areas: Storm Water (See attachment summary) - Certification: Thomasville NC 27360 Phone: 336-475-1348 Phone: Exit Time: 12:30PM Phone: 336-776-9800 Inspection Type: Compliance Evaluation Page: 1 Permit NCS000235 Owner - Facility: Southern Resin Inc Inspection Date: 10112t2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: (See Compliance Letter) Page: 2 r • ' Permit: NCS000235 Owner - Facility: Southem Resin Inc Inspection Data: 1011212016 Inspection Type: Compliance Evaluation Reason for Visit: Routine Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? E ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ 110 ❑ Comment: Analyticai monitoring being conducted monithly in Tier II Response due to consecutive exceedance of Formaldehyde and Nitrogen. Continue to monitor monthly until three consecutive sambles result within threshold. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? M ❑ ❑ ❑ # Were all outfalls observed during the inspection? E ❑ ❑ ❑ # If the facility has representative outfall status, is it property documented by the Division? ❑ ❑ ® ❑ # Has the facility evaluated all illicit (non stormwater) discharges? N ❑ ❑ ❑ Comment: No deficiencies. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? i ❑ ❑ ❑ Comment: Conduct Monitorinq per permit. Stormwater Pollution Prevention Plan Yes No NA_bIrz Does the site have a Stormwater Pollution Prevention Plan? E ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? 0 ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ® ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? E ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? E ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? E ❑ ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? E ❑ ❑ ❑ # Does the facility provide and document Employee Training? 0 ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? E ❑ ❑ ❑ # Is the Plan reviewed and updated annually? E ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? E ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑ Page: 3 Permit NCS000235 Owner - Facility: Southern Resin Inc Inspectlon Date: 10112/2015 Inspection Type : Compliance Evaluation Reason for Via It: Routine Stormwater Pollution Prevention Plan Yes No NA NE Comment: All records complete. Training conducted annually. Currently in Tier 11 for consecutive exceedance of Formaldehyde and Nitrogen. Monitoring as required. Weekly site inspections conducted throughout the facility. Well documented. No deficiencies. Page: 4 Appendix F Southern Resin, Inc. Thomasville, North Carolina PREVENTIVE MAINTENANCE INSPECTION FORM Associated with sampling on 9/27/2016 Date/Time of Shift Team Member Area Inspected & Corrective - Problem Observed Action Inspection 9/29/2016 1st John Myers 1170 Dyke area - Is clean and free of trash ' and buckets t 9/29/2016 1st John Myers 500 Dyke area - Is being cleaned. Old dried material being chiseled out 9/29/2016 1st John Myers Coron Dyke area - No issues 9/29/2016 1st John Myers Product pump No issues 9/29/2016 1st John Myers Truck lot No issues 9/29/2016 1st John Myers Truck Scale a No issues 9/29/2016 1st John Myers Tote Storage No issues 9/29/2016 1st John Myers Shop Area and ditch to Ponds Ditch clear 9/29/2016 1st John Myers Wastewater handling area- No spills 9/29/2016 1st John Myers ketone loading area - Clean. Buckets closed 9/29/2016 1st John Myers Urea blowing area No spilled matieral AmrKWA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary August 18, 2010 Mr. Alien Grubb, Operations Manager Southern Resin, Inc. 3440 Denton Drive Thomasville, NC 27360 Subject: Compliance Evaluation Inspection Certificate of Coverage #NCS000235 Southern Resin, Inc. Davidson County Dear Mr. Grubb: A Compliance Evaluation Inspection was performed at Southern Resin in Thomasville, North Carolina on July 22, 2010 by Jenifer Carter of the Winston-Salem Regional Office. You were present for the inspection. The purpose of the inspections was to review compliance with the National Pollutant Discharge Elimination System (1VPDES) Individual Stormwater Permit. The following are the findings from the subject inspection: • A Stormwater Pollution Prevention Plan (SPPP) has been developed and properly implemented. • Qualitative monitoring has been conducted as required and recorded in accordance with permit requirements at one (1) stormwater outfall. Analytical monitoring has been conducted as required and recorded in accordance with permit requirements at one (1) stormwater outfall. Exceedences of benchmark values for formaldehyde and nitrate f nitrite nitrogen as well as corrective actions taken were well -documented. Exceedences continue to be a problem and investigations and further corrective actions are ongoing. When your permit is renewed, please note new required procedures for dealing with benchmark exceedences. It was noted that pH samples were most likely measured outside the required 15-minuted holding time, though the contract lab never notified the facility of that fact, and the permit does not mention the requirement. Clarification will be provided when the permit is renewed. One option is to use on -site pH monitoring equipment, though the industry would need to obtain field parameter certification. prior to doing so. Visit http://PortaLiiedestr.org/weblwgllableertlfield for more information on obtaining field parameter certification. �© • Manifests for removal of strip water, process water and process sludge wer�vailabl for review. -�0 &_�? • There were no residuals from spills or leaks obsered on the ground, nor in or near surface waters. ("Loalo��tl' + Evidence of rodent damage to the dam of the pond near the outfall was observed. Woody vegetation should be removed and controlled for, and significant damage should be repaired in order to prevent the dam from being breached, releasing pond water directly to the stream below the outfall. • A second undocumented outfall was observed during the inspection that only receives stormwater from some of the roof drains. It was agreed that the pipe directing the stormwater to this outfall would be capped and the flow redirected in order to drain the roofs to other documented outfall. continued on reverse... North Carolina Division of water Quality, Winston-Salem Regional Office Location: 585 Waughtown St Winston-Salem, North Carolina 27107 One Phone: 336-771-5000 l FAX: 336-771-46301 Customer Service: 1-877.623-6748 North C aro tin a Internet: www.ncwaterquaiity.org ;Vaturally An Equal Opportunity 1 Affirmative Action Employer ` The Division greatly appreciates your efforts to maintain compliance. You should be receiving a draft version of your permit soon, as part of the renewal process. Please take the time to read it carefully as there will be changes. Should you have any questions, please contact Jenifer Carter at (336) 771-4957. Sincerely, Steve W. Tedder Surface Water Regional Supervisor Winston-Salem Regional Office Division of Water Quality cc: SRO=Files SWP — Central Files NPS ACO Unit Mr. Mike Waddey, P.E. (Engineering Solutions, Inc; 131 Lonetree Cir; Advance, NC 27006) 05/10/2810 10:07 336-99E0526 P & ^ L-ABOR-ATORIES P'GE 02/03 RESEARCh & ANA[YACAL LAbORAM ES, INC. Analytical/Process Consultations Southern Resin Date Sample Collected = OS/19/3.0 3440 Denton Road Date Sample Received 05/19/10 Thomasville, NC 27360 Date Sample Analyzed 05/19/10 -----A P.nal-yses Performed by DW -AR -KL -TP Lab sample Number -------------------- 674176 Parameter Storet 4 Results Formaldehyde (71880) •�- 3 _ 19 mg/_ Ua� fA�I/}1 6y f � COD -HIGH (00340) --- so mg/1 , /�Ic:A t 9a7 mG%� NH-3-N (00610). 0.92-7 mgfl /QC,)), TKN (00625) 7.40 mg/1 0,o2 NO2+NO3 (00630) 0.540 mg/l PH (00400) To Li>s 5-93 std. Units -------------------- Clients Sarnple Sazzrce OUTFAU. Numae;' Time Collected (,Hzs) 1230 I RESEARCh & ANA1yTICA1 LAbORATORIES, INC. Analytical/Process Consultations Soutbern_Resin Dat..e.Sample Collected 11/13/09 3440 Denton Road Date Sample Received 11/13/09 Thomasville, NC 27360 Date Sample Analyzed 11/13/09 Attn: BOBBY HILL Date of Report 11/23/09 ---Analyses Performed by AR -KL Lab Sample Number --------------------- 660844 Parameter Storet # Results Formaldehyde (71880) COD -HIGH (00340) 88 mg/1 NH-3-N (00610) 0.295 mg/1 TKN (00625) 6.51 mg/1 NO2+NO3 (00630) 1.29 mg/1 pH {00400) '6.49 std. Units Clients Sample Source Number Time Collected (Firs) k -------------------- DISCHARGE PIPE 1300 P 0. Box 473 • 105 Short Street • Kernersville, North Carolina 27284 • 336-996-2841 • Fax 336-958-0326 www..-andaisbs,com RESEARCh & ANA[yTICAI LAbORATORIES, INC. Analytical/Process Consultations Southern Resin Date Sample Collected 06/16/09 1510 Denton Road Date Sample Received 06/16/09 Thomasville, NC 27360 Date Sample Analyzed 06/16/09 Attn: Ray Simmons Date of Report 07/13/09 Analyses Performed by AR -KL -DD -DW LabL Sample' 13umber ----------------- 648453 ------------------------------------------------------- Parameter Storet # Results TKN (00625) 3.74 mg/1 BOD-5 (00310) 4.11 mg/1 COD -HIGH (00340) 18 mg/l Formaldehyde (71880) �2mg NH-3-N (00610) 0.464 mg/l NO-2-N (00615) 0.326 mg/1 a� NO-3-N (00620) 0.445 mg/1 -- --­ -------------- Clients Sample Source #2 SMALL LAKE •Nurtrber Time Collected (Hrs) 1120 P.O. Box 473 • 106 Short Street • Kernersville, North Carolina 27284 • 336-996-2841 • Fax 336-996-0325 www.randalabs.com 06/13/2008 12:57 33G--9960326 R & A LABORATORIES PAGE 02/03 RESEARCH & ANAlyTICAI LABORATORIES,, INC. Analytical/Process ConsuttationS ♦�� 5 n"tiL �00 00 Ch 40 4 NC #34 s T, do ATip�' Southern Resin Date Sample collected 05/29/08 1510 Denton Road Date Sample Received 05/29/08 Thomasville, NC 27360 Date Sample Analyzed _ 05/29/08 Attn: Alan Grubb Date of Report 06/13/08 Analyses Performed by DW -KP -KL -TD Lab Sample Number -------------------- 618220 Parameter Storet Results Formaldehyde (71880) 7.�m�/l COD -HIGH (00340) 71.0 mg/l NH- 3-N (00610) 4.32 mg/l TKN (006�5) 8.10 mg/l NO2+NO3 (00630) �� ,0.516 mg/1 ✓J PH (004001 7.01 Std. Units vl -------------------- Clients Sample Source LOWER POND Number Time ColJ,ected (Hrs) 1100 PC, , Box 473 • 108i Short Street . KCrnersville, North 09rn(ina 272S4 • 335-996-2049 - Fax 336-996-0326 www.randalabs.com - 12i25Z2006 15 : 50 RLb&_ Mt_ f - - ----- REsFARch & ANA[yTICA[ _ `• ' �`• LAbORATORIE_$ INC • ,.ems— w. r NC #34, • ; Anahjt si/Process Consultations '; ? Southern Resin Date Sample Collected 11/16/06 3440 Denton Road Date Sample Received 11/16/06 Thomasville, NC 27360 Date Sample Analyzed : 11/16/06 Attn: Allen Grubb Date of Report 12/04/06 Analyses Performed by DW -JK -MC -DW -TD Lab Sample Number -------------------- 576261 ---.�-....�---------=•^-� �.. --�...-=====a==-�---'-----------a-'a----=====�x�=ate=== Pazameter Storet # Results Formaldehyde (71880) 5.34 mg/1 COD -LOW (00340) 40.0 mg/l NH- 3-N (00610) 6.19 mg/1 . TKN (0062S) 12.0 mg/l NO2tNO3 (00630) E-5 mg/1' PH (00400) 7.29 Std- Units - Clients Sample Source DISCHARGE PIPEAT �,•� Number BACK OF POND Time Collected (Hrs) 1240 RCL Box 473 - 106 Short Street • Kerneraville. North Carolina 27284 • 226-996-2841 • Fax 336-995-0326 www.researchandanalydcal.com RESEARCh & ANA1Y TICA1 LABORATORIES, INC. Analytical/Process Consultations Sr-nt er:. Resin - "Date 'Sa-, le ,,lid—: A 11/30i 05 _ - 3-40 Dei�ten Road Date Sample Received 11/30/05 Thomasville, NC 27360 Date Sample Analyzed 11/30/05 Attn: Doug Stewart Date of Report 12/08/05 Analyses Performed by DW -JK -IBC Lab Sample Number -------------------- 5491558 Parameter Storet # Results Formaldehyde (71880) 7.45 mg/� COD -HIGH (00340) 38 mg/l NH-3 V (00610) 7.47 mg/1 TKN (00625) mg/1 --_-- _ - NO2+NO3_ — (00_630) -144..9 \ l cJ3 ma/17�1 Clients Sample Source POND ON RIGHT AT Number DISCHARGE PIPE Time Collected (Frs) 1445 P.D. Box 473 • 106 Short Street • Kernersville. North Carolina 27284 • 336-996-2841 ,• Fax 336-996-0326 www. resea rch a n da n e lyti c e!_c om RESEARCH & ANA1YTiCA[ LABORATORIES, INC. AnalyticaVProcess Consuftations cc NC#34 z� �= - r • 'Il�Zj, AIA+lrr�lr»►�� Southern Resin Date Samp.7_P Collected : 06/04/04 1510 Denton Road Date Sample Received : 06/04/04 Thomasville, NC 27360 Date Sample Analyzed 06/04/04 Attn: Doug Stewart Date of Report 06/11/04 Analyses Performed by SW -DW Lab Sample Number -------------------- 506294 Parameter Storet # Results COD -LOW (00335) 73 mg/1 Formaldehyde (71880) 7.54 I Clients Sample Source Number Time Collected (Hrs) -------------------- A 1145 P.Q. Box 473 - 106 Short Street - Kernersville, North Carolina 27284 - 336-996-2841 - Fax 336-996-032S ti. RESEARCh & ANAIyTICAI LAbORATO&S, INC. Analytical/Process Consultations Southern Resin 1510 Denton Road Thomasville, NC 27360 Attn: Kevin Conway Date Sample Collected Date Sample Received Date Sample Analyzed Date of Report Analyses Performed by 04/11/03 04/11/03 04/11/03 04/24/03 SW Lab Sample Number -------------------- 474310 -------------------------------------------------------------------------------- ------------------------------------------------------------------------------- Parameter Storet # ��Reesults Formaldehyde (71880) �4.74 mg/l COD -LOW (00335) 65 mg/l Clients Sample Source Number Time Collected (Hrs) PO, Box 473 • 106 Short Street • Kernersville. North Carolina 27284 • 336-996-2841 • Fax 336-996-0326