NCG030251_COMPLETE FILE - HISTORICAL_20161230

PERMIT NO.
DOC TYPE
DOC DATE
STORMWATER DIVISION CODING SHEET
NCG PERMITS
/VCR
� HISTORICAL FILE
❑ MONITORING REPORTS
❑ �?ol cp t�; �j o
YYYYMMDD

PAT MCCRORY
Governor
i�
DONALD R. VAN DER VAART
Secretary
Energy, Mineral TRACY DAVIS
and Land Resources
ENVIRONMENTAL QUALITY Director
December 30, 2016
Watts Regulator
ATTN: Mark Kennard
100 Watts Road
Spindale, NC 28160
Subject: NPDES Stormwater Permit - Representative OutfalI Status Approval and Tiered
Sampling Relief
Permit No. NCG030251
Rutherford County
Dear Mr. Kennard:
Division of Energy, Minerals, and Land Resources (DEMLR) staff have reviewed your request
for representative outfall status at the subject facility. Based on a site visit and information
provided, the request has been approved and is effective with the next sampling event.
In accordance with 40 CFR § 122.21(g)(7), you are authorized to sample the outfall 002 as your
representative sample.
Please note: the permit still requires Qualitative Monitoring be performed at all outfalls,
regardless of representative status.
In addition, based on your extensive research to identify and document any background levels of
benchmark exceedances, and your efforts to remediate these background levels where possible,
you are hereby given relief from Tiered sampling. However, DEMLR maintains the right and
ability to revisit this determination if metals concentrations cause or contribute to water quality
standard violations in the receiving stream in the future.
Please append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit to
document that representative outfall status has been approved and that you have been given relief
from Tiered sampling until further notice. If changes in drainage areas, structures, processes,
storage practices, or other activities occur that significantly alter the basis of this approval,
representative outfall status may no longer be valid. You should either resume sampling at all -
outfalls, or reapply to this office for representative outfall status based on updated information.
If you have any questions or comments concerning this letter, please contact Darlene Kucken at
[phone] or [e-mail].
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
2090 US 70 Highway I Swannanoa, NC 28778-821 l
828 296 4500 T

Mark Kennard
December 30, 2016
Page 2 of 2
•
" Sincerely,
Darlene Kucken
Environmental Specialist
Land Quality Section
ec: Bethany Georgoulias([e-mail])
Matt Bramble ([e-mail])
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
2090 US 70 Highway I Swannanoa, NC 28778-8211
828 296 4500 T

Via Email
August 24, 2016
NC Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
2090 US 70 Highway
Swannanoa, NC 28778
Attn: Ms. Darlene Kucken
Re: Stormwater Background Sampling and
Representative Outfall Request
Watts Water Technologies
Spindale, NC
H&H Proiect No. WWT-004
Dear Darlene:
hart � hickman
d
SMARTER ENVIRONMENTAL SOLUTIONS
1.0 Introduction and Background
Hart & Hickman, PC (H&H) is providing this letter to summarize the results of stormwater
background metals sampling at the Watts Water Technologies (Watts) facility in Spindale, NC
(Figure 1). The Watts facility was recently in Tier 3 status for metals in accordance with NPDES
Stormwater Permit (NC-Gj- 000314 Samples from representative Stormwater Drainage Outfalls
001, 002, 004, and 006 for the Watts facility indicated levels of copper and zinc above NPDES
permit benchmarks for multiple sampling periods, putting the Watts facility under Tier 3 status
for zinc and/or copper at Outfalls 001, 002, 004, and 006.
Watts engaged H&H to evaluate the stormwater metal detections and to improve stormwater
management for the facility. H&H recommended three key action items which included the
placement of stormwater filter socks, addition of limestone riprap in high flow areas, and
improvement in the grass coverage density for soil surface stabilization. Watts implemented
these recommendations, and stormwater metal concentrations (copper, lead and zinc)
significantly decreased based on the October 2015 monthly sampling event, which represented
the first stormwater sampling event after these recommendations had been fully implemented.
2923 South Tryon Street, Suite 100 3334 Hillsborough Street
Charlotte, NC 28203 Raleigh, NC 27607 www.harthickman.com
704.586.0007 main 1 919.847.4241 main

Ms. Darlene Kucken
August 24, 2016
Page 2
These decreases were sustained in subsequent sampling events, though zinc and/or copper
continued to exceed NPDES permit benchmarks for Outfalls 001, 002, 004, and 006.
Based on these results and the common occurrence of these metals in stormwater, H&H
suspected background sources of these metals to be contributing to the collected stormwater
samples. Samples were collected from the roof and road runoff during a storm event on October
27, 2015. Relatively high levels of copper, lead, and zinc were found in these samples. These
results were reported to the North Carolina Division of Energy, Mineral and Land Resources
(NC DEMLR) by H&H in a letter dated November 24, 2015. Elevated metals were confirmed in
additional background samples collected November 18, 2015, as submitted with the Discharge
Monitoring Report (DMR) dated December 29, 2015.
On January 27, 2016, you visited the Watts site at Watts' request to evaluate NPDES permit
compliance. Though the inspection confirmed exceedances of copper and zinc at the sampled
outfalls, the inspector indicated that background sources may be influencing the outfalls, and
temporarily reduced tiered sampling to a semi-annual frequency. Additionally, the inspector
noted that outfall 2 is the only outfall representative of the Watts site without being impacted by
off -site background sources. The inspector requested additional background sampling to confirm
the initial sampling results. Two additional background sampling events were conducted on
April 1, 2016, and April 22, 2016. The results of the background sampling events are discussed
below.
2.0 Background Sampling Results
Watts collected background stormwater samples from two locations on the roof and two
locations on Watts Road, an adjacent road which partially drains into the Watts property
upgradient of Outfalls 001, 003, 004, 005, 006, and 007. These background sample locations
were sampled during four separate storm events, including samples on October 27, 2015,
November 18, 2015, April 1, 2016, and April 22, 2016. Direct rainfall samples were collected in
hart � hickman
SMARTER ENVIRONMENTAL SOLUTIONS
S:\AAA-Master Projects\Watts Water Technologies -WWRWWT•004 Quarterly Spindale NC�Background Metals letterlWatts Stor ater Backgromd.docx

Ms. Darlene Kucken
August 24, 2016
Page 3
addition to the other background samples for the two April 2016 sampling events. The data from
the background sampling and the four most recent outfall sampling events are presented in
Tables I and 2, respectively. The outfall data includes all data collected after the completion of
the stormwater management improvements were completed in October 2015. The data are
compared in Figure 2, which demonstrates higher metal concentrations in the background data
compared to outfall data. Sampling locations are indicated on Figure 1. Laboratory reports are
provided in Appendix A. Relatively high levels of copper (up to 0.438 mg/1), lead (up to 0.0692
mg/1), and zinc (up to 1.89 mg/1) were detected in the background samples, exceeding both
NPDES benchmark values and average outfall concentrations since the implementation of the
stormwater management improvements. Additional details on background sample results are
provided below.
2,1 Road Runoff Results
Outfalls 001, 002, 004, and 006 are currently being monitored for metal concentrations. Amongst
these outfalls, only Outfall 002 has a low probability of runoff from Watts Road contributing to
the collected stormwater sample. Furthermore, the lowest metal concentrations in outfall
samples were generally found in Outfall 002. As such, Watts Road was investigated as a
potential contributor to metals detected at the outfalls on -site. Two locations were selected to
sample runoff from Watts Road. Road Run Off— 01 DC was taken from the south side of Watts
Road across from the distribution center, near Outfall 007. Road Run Off — 02 DR was taken
from the south side of Watts Road across from the drains department of the Watts facility, near
Outfall 002. Copper (up to 0.438 mg/L) was found in every road runoff sample at concentrations
exceeding the NPDES permit benchmark. Zinc (up to 0.224 mg/L) was detected at
concentrations exceeding the NPDES permit benchmark in five of the eight background samples.
Lead (0.0524 mg/L) was also detected in the October 27, 2015 Road Run Off-02 sample at a
concentration exceeding the NPDES permit benchmark. These background samples indicate that
the runoff from Watts Road is contributing to the detected metal concentrations at the outfalls.
hart --a hickman
SMARTER ENVIRONMENTAL SOLUTIONS
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Ms. Darlene Kucken
August 24, 2016
Page 4
2.2 Roof Runoff Results
As buildings on -site take up a considerable portion of the overall area, the runoff from the
building roofs was sampled for metals. Two sampling points were selected to monitor the roof
runoff on -site. Both samples were collected from the roof of the drains department of the Watts
site. Roof Drain #1 Dock was collected from over the loading dock for the drains warehouse,
and Roof Drain #2 Evap was collected from over the out of service evaporator room within the
drains warehouse. The roof samples were found to contain copper (up to 0.221 mg/L), lead (up
to 0.0692 mg/L), and zinc (up to 1.89 mg/L). Copper was, found in every roof runoff sample at
concentrations exceeding the NPDES permit benchmark. Every roof runoff sample except the
Roof Drain #1 Dock sample collected on April 22, 2016 contained zinc at concentrations
exceeding the NPDES permit benchmark. Lead was detected above the NPDES permit
benchmark in every Roof Drain #2 Evap sample except on April 1, 2016 sampling event. The
April 1, 2016 Roof Drain #I Dock sample contained lead above the NPDES permit benchmark.
To identify the potential source of these metals in the roof runoff, Watts checked the coating
materials used on the roof, as well as the material of the roof, vents, and other structures. The
roof vents are galvanized, and the drains spouts are electroplated with a potential white metal.
These materials may be contributing to the metals detected in the runoff samples. Additionally,
Watts stated that a reflective white roof sealant known as Kool Seal has been used in select roof
locations. A study published in 2008 analyzed the potential for a variety of roofing materials,
including Kool Seal, to leach metals (Appendix B). It was reported that Kool Seal has the
potential to leach copper, lead, and zinc at low levels. In addition, storage trailers parked on -site
also have galvanized roofs and siding that may be contributing similarly to metals at the outfalls.
The roof runoff samples suggest that the roofs on -site are made of typical materials and are
contributing to the metal exeeedances at the outfalls for the Watts site.
hart .11 hickman
SMAMR ENVIRONMENTAL SOLUTIONS
SMAA.MaatarPMjCuUNWattsWater Technologies-WW71wWr-004Quarterly SpindaleN"ackgroundMetals Ietter\WattsStom aterBackground.doc%

Ms. Darlene Kucken
August 24, 2016
Page 5
2.3 Direct Rainfall Results
Two dir� ect raiifall samples were collected concurrent with the two background sampling events
in April 2016. The first rainfall sample was collected in close proximity to a galvanized fence,
which may have influenced the metal concentrations detected within the sample. This sample
was found to contain levels of zinc (2.27 mg/L) and copper (0.0176 mg/L). These concentrations
exceed NPDES benchmark values. As the zinc concentration is significantly greater than the
outfall concentrations, H&H believes that these data provide runoff data for the galvanized fence
rather than the direct rainfall. This supports the conclusion that the galvanized surfaces are
contributing zinc and copper to the stormwater onsite.
The second rainfall sample was taken from within a parking lot on -site, unaffected by runoff
from the galvanized fence. Even so, it was found to contain elevated levels of copper (0.158
mg/L) and zinc (0.35 mg/L). This supports the conclusion that background levels of copper and
zinc in rainfall are influencing the outfall concentrations.
3.0 Representative Outfall Status
The Watts facility currently monitors stormwater discharge visually at Outfalls 003, 005, and
007, and analytically at Outfalls 001, 002, 004, and 006. Outfalls 001, 004, and 006 collect
stormwater from on -site, as well as runoff from Watts Road. The road runoff has been shown to
contain metals at concentrations in excess of the NPDES permit benchmark. The contribution of
metals from the road affects the reported concentrations at the outfalls. Due to its isolation from
the Watts Road runoff, H&H believes that Outfall 002 is the most representative outfall for the
site. The use of Outfall 002 as the single representative outfall was suggested by you after your
site visit in January 2016.
Outfall 002 drains a portion of the main eastern building on the Watts site. Other than light
assembly, manufacturing no longer occurs on -site, and the primary activity is warehousing.
hart D hickman
SMARTER ENVIRONMENTAL SOLUTIONS
S:IAAA-Master Ptnjec Watts Watcr TcOhologies-WWI1WWT-004 Quanerly Spin4ltc NCll3ackWound Metals leuer5Walts Stcr atu 13wkground,docx

Ms. Darlene Kucken
August 24, 2016
Page 6
Warehouse operations are similar across the entire site such that a single outfall is representative.
The portion of the Watts facility which drains to Outfall 002 includes a portion of the building
roof, a parking area where galvanized roof trailers may be stored, and a loading dock. The
drainage basin for Outfall 002 is representative of the entire Watts facility. H&H is requesting
that DEMLR approve Outfall 002 as the single representative outfall for analytical monitoring.
A Representative Outfall Status Request Form is included as Appendix C. ✓
4.0 summary
The Watts facility has recently implemented improved stormwater management practices which
reduced the metals discharged at the outfalls on -site; however, the zinc and copper
concentrations still exceed the low NPDES permit benchmarks. In order to identify whether
background sources may be contributing to these elevated concentrations, multiple background
sampling events were conducted to investigate the influence of runoff from Watts Road, the roof
of buildings on -site, and direct rainfall. On average, the copper, lead, and zinc concentrations in
these background samples were greater than those recorded at the outfalls. Amongst the
background samples, the roof runoff showed the highest average metal concentrations. These
elevated concentrations may be due to the roof coating, runoff from galvanized vents, or
interaction with the metal roof drains. The presence of metals in the roof runoff supports the
conclusion that roofs on -site should be inspected annually to identify degraded materials and to
repair or resurface degraded areas, if any. The recommendation for annual roof inspections will
be incorporated into the SWPPP for the Watts facility.
With the recent improvement of stormwater management at the Watts facility resulting in
improved stormwater discharge quality, and the likelihood of current permit benchmark
exceedances to be caused by background sources rather than industrial activity, H&H on behalf
of Watts is respectfully requesting that the Spindale facility be placed under Tier I status.
Additionally, as Outfalls 001 and 006 are influenced by runoff from the railroad and Callahan
Koon Rd, and these outfalls, as well as Outfall 004 are influenced by runoff from Watts Rd,
40
hart p hickman
SMARTER ENVIRONMENTAL SOUMN5
S:4UA•Muter PmjcaskWatts Water Technologies - W WTiW h7*W Quaterly SpimWc NCUBackgmund Moak Ietta Watts Stut a:m Backgrounddocx

Ms. Darlene Kucken
August 24, 2016
Page 7
H&H on behalf of Watts is also respectfully requesting formal approval for Outfall 002 as the
single representative outfall for the Spindale facility.
We appreciate the opportunity to assist with this project. Should you have any questions or need
any additional information, please feel free to contact me.
Sincerely,
Hart & Hickman, PC
. J14e
Matt Bramblett, PE
Principal Engineer
Attachments
Cc: Mr. Mark Kennard, Watts (via email)
Mr. Howard Chu, Watts (via email)
Mr. Sean Sullivan, TS (via email)
hart � hickman
SMARTER ENVIRONMENTAL SOLUTIONS
S:W AA -Matta Pmiects\Watts Water Technologic$ - W WT%W Wr-OOA Q=erly Spindale NClBackground Moak IaterlWatts Stot ata BackgrouMAoex

Table 1
Background Stormwater Data
Watts Water Technologies
Sptndals, NC
H&H-lob_No. WylrT-004
Sample L"lon
Road Run OH-01 DC
Road Run ON-02 DR
Roof Drain #I Dock
Roof Drain 92 Evap
f Direct 1'
Rainfall #111
Direct I
Rainfall #21
Background
Averse
NPDES Permit
Date
10127/15 11/18/16 411116
4122116
10/27/15 11/18118 411116
4122116
10/27/15
11118/16 411116
412V16
1D127115
11118/16 411116
4122116
411116
4122116 1
10/27/15 to 411116
Benchmark
Units
m L
m9fl.
m 1L
m 1L
m A.
m IL
m 1L
m 1L
Metals 2D0.7
I
Co
0.008i 0.0161
O.Oi63
0.0126
D.�38 0.07}0
D,0}61
0.116
D.0120
0.0099
0.22}
0.010f
0205
0.107
O.ON2
0.160
0.0176 1
0.f58
0.093
0.007
Lead
<0.005 <0.005
<0.005
0.0067
0-0524 <0.005
c0.005
D.0064
<0.005
<0.005
0.0692
<0.005
0.05f2
0.0176
0.0227
0.0129
<0.005
0.0242
0.016
0.030
Zinc
0.0469 0.0961
0.0638
0.}}9
0.178 0A,"
0,0295
0.224
0.338
0.229
0.356
O.D469
1. ago
0.759
0.197
0.260
1 ZZ70 !
0.350
0,418
0.067
NOW
Data collected after two days with aplNdximatety 0.2 inches of rain per day
Nan•detect9 averaged at I R of the repartirg link
Bold and Italics Indicate exceed benchmark
Table 1, Page 1 of 1
n. a.ww«w,v,q.oeurw Wr rRae+osw-xwrxxwraw o,.R.^r,��+e+rrm,ae.�ww�a .rW ,�nne,c,w�.a ew ns.�
Hart Hirkneun. PC

Table 2
Outfall Stormwatar Data after Stormwater Improvements
Watts Water Technologies
Spinciale, NC
H&H Job No. WWT-004
Sample
Location
OU-001
OU-002
OU-004
OU-006
Outfall Average
NPDES Permit
Benchmark
Date
10127/20151
11AB120151 12124/2015
11812016
10/27/2015
1111812p15 1 12/22/2015
11&2016
1012V20151
11118120151 12/2212015
I 116/2016
10127/2015
1 1111&12D151 12122/2015
1 118/2016
Units
mq1L
1
mg1L
m
m L
mq1L
mqfL
Metals 200.7
Copoer
0.0722
0.0688
0.0500
0.0536
0.0059
0.0403
0.0069
OA248
0.0550
0.142
0.0H8
0.0655
0.0378
0.0674
0.0161
0.0472
0.050
0.007
Lead
0."'f
0.0092
-0.005
<0.005
�0.005
<0.005
<0.005
0.0072
<0.005
0.0207
-0.005
0.0058
�O.005
W.005
<0.005
�0.005
0.005
0.030
Zinc
0.0734 1
0.0443
1 0.0732
1 0.0360
0.02B7
1 0.0645
1 0.0134
1 0.0220
- 0.1960
1 0.220
1 0.0797
1 0.109
0.117
1 0.196
1 0.0669
1 0,113
0.091
0.067
Nate;
Non -detects averaged at 1 f2 of the repomng Erne
Bold and Itakcs Indicate exceed benchmark
awwy..oA...d...�...,•.�...�•.,.w,�ww,ma,�.M r.... vim... m,. r�a�-., w.. �..�`...+� ,.,. x table 2. Page 1 o1 I
o�.nern,e Han 6 Hickman, PC

TLY K
P-A A
MUM
me
W.1 11
AIN ki.,
w
.77
7'
1, 29,
4 of
. Xk
-0
-Ji

Figure 2
Metals Concentration in Stormwater
Watts Water Technologies
Spindale, NC
H$H Job No. WWT 004
0.450
0.400
r.
r �'r
0.350
vi
4
0.300
`
E
El Background Average
0 200
+ C] Outfall Average
"i
w1x '>..
0.150
0.100TL
t ''
0.050
0.000
Copper Lead
Zinc
Notes:
Outfall data collected on October 27, 2015, November 18, 2015, December 22, 2015, and January 8, 2016
Background data collected on October 27, 2015, November 18, 2015, April 1, 2016, and April 22, 2016

Roofing Materials' Contributions to Storm -Water
Runoff Pollution
Shirley E. Clark, P.E. D.WRE, M.ASCE'; Kelly A. Steele, A.M.ASCE2; Julia Spicher, A.M.ASCE3;
Christina Y. S. Siu4; Melinda M. Lalor5; Robert Pitt, P.E. D.WRE, M.ASCE6; and
Jason T. Kirby, A.M.ASCE7
Abstract: Development in sensitive watersheds continues to pose environmental problems for receiving waters. One contributor to this
lone -term pollution is building and other construction materials. However, the long-term effect of many building materials on the
environment has not been quantified due to limited testing of these materials prior to sales and installation. Laboratory "leach" testing of
commercially available roofing materials by this research group indicated that the potential for release (primarily nutrients, lighter
hydrocarbons, pesticides, and metals) is substantial. Testing of metals' release from aged roofing panels also has shown that the potential
for pollutant release still exists after 60 years. The data missing from a complete evaluation of many roofing materials is behavior over the
lifespan of the material, including the critical period of initial exposure. The 2 years of runoff data from a pilot -scale testing of these
materials indicated substantial concerns regarding zinc from uncoated galvanized metals and copper from treated woods in this early part
of the materials' lifespan. plus the potential for long-term nutrient releases in the runoff from several roofing types.
DOI: 10.1061/(ASCE)0733-9437(2008)134:5(638)
CE Database subject headings: Slormwater management. Water management: Runoff; Water pollution: Roofs; Leaching:
Construction materials.
Introduction
Urban runoff has been identified as a major contributor to the
degradation of many urban streams. rivers, and estuaries (Burton
and Pitt 2002, which includes an extensive literature review).
Using the Microtox acute toxicity testing procedure. Pitt et al.
(1995) investigated the toxicity of source -specific urban wet
. IAssistant Professor of Environmental Engineering, School of
Science, Engineering and Technology, Penn State Harrisburg, 777
W. Harrisburg Pike TL-105. Middletown, PA 17057 (corresponding
author). E-mail: [e-mail]
2Engineering Technician, Dawood, Inc., 2020 Good Hope Rd., Enola,
PA 17025: formerly, Project Engineer, Navarro and Wright Consulting
Engineers. Inc., 151 Reno Ave., New Cumberland, PA 17070. E-mail:
[e-mail]
3Environmental Engineer, Greeley and Hansen, Inc., 1818 Market
St., Ste. 3400. Philadelphia, PA 19103-3613. E-mail: jspicher@greeley-
hansen.com
4Research Scientist. School of Science, Engineering and Technology,
Penn State Harrisburg, 777 W. Harrisburg Pike TL-123, Middletown,
PA 17057. E-mail: [e-mail]
`Associate Dean. School of Engineering, Univ. of Alabama at
Birmingham, 1075 l3th St. S., Birmingham, AL 35294. E-mail: mlalor@
uab.edu
6Cudworth Professor of Urban Water Systems, Dept. of Civil,
Construction and Environmental Engineering. Univ. of Alabama.
Tuscaloosa, AL 35487-0205. E-mail: [e-mail]
Assistant Professor, Univ. of Alabama at Birmingham. 1075 13th St.
South, Room 140, Birmingham, AL 35294. E-mail: [e-mail]
Note. Discussion open until March I, 2009. Separate discussions must
be submitted for individual papers. The manuscript for this paper was
submitted for review and possible publication on June 28, 2007: approved
on January 28, 2008. This paper is part of the Journal of Irrigation and
Drainage Engineering, Vol. 134, No. 5. October 1. 2008. ©ASCE, ISSN
073 3-9437/2008/5-638-645/$25,00.
weather flows. Roofs, storage areas, streets, and loading docks
had the highest frequency of moderately toxic and highly toxic
runoff samples. Runoff from roofs and paved surfaces had the
greatest organic toxicant detection frequencies and the highest
levels of detected metals. Boller (1997) found roof runoff to con-
tain not only heavy metals, but polycyclic aromatic hydrocarbons
(PAHs) and organic halogens as well. In addition to the well
known component materials in roofing and pavements. seemingly
unrelated compounds have been added to improve performance
and durability. and these compounds could be the source of many
pollutants detected in the runoff.
Based on a review of the literature, other building materials of
concern included concrete, paints, and exposed wood/pressure
treated wood. A summary of the literature on concrete and asphalt
paving can be found in Clark et al. (2002). For paint, the concerns
reported were lead and other metals incorporated into the paint
itself (Davis and Burns 1999). In New Zealand, limits were
placed on the heavy metal content of paints applied to metal
construction materials, such as roofs, as an environmental barrier
(Kingette Mitchell Ltd. and Diffuse Sources Ltd. 2003). This use
of paint as an environmental barrier was. for example. a practice
that occurred on a site in the western United States to reduce the
zinc release from galvanized metal roofing.
A summary of the literature on roofing (both surface covers
and materials used as subbases such as treated wood) is presented
in Table 1. The older field studies in the table inferred the differ-
ences in roofing's pollutant contributions by analyzing runoff
from nearby roofs made from different materials, using small
areas where atmospheric contributions could be assumed to be
similar. Newer studies directly or indirectly measured atmo-
spheric contributions in order to isolate the materials' contribu-
tions. In addition to the research projects that reported runoff
concentrations, others investigated the effects of these materials
638/JOURNAL OF IRRIGATION AND DRAINAGE ENGINEERING ©ASCE/SEPTEMBER/OCTOBER 2008
Downloaded 13 May 2009 to 128.143.22,132. Redistribution subject to ASCE license or copyright: see http:flpubs.asce.orgfcopyrighl

Table 1. Roof Runoff Analysis —Literature Summary
Roof type Location
Polyester Duebendorf, Switzerland
MR
Flat gravel
Plywood w/ roof paper/tar Washington
Rusty gals. metal
C-
O
c
Z Old metal w/Al paint
b
Flat tar surface w/fibrous reflective A] paint
O
n New anodized Al
D
O Zinc -gals. Fe Dunedin City. New Zealand 560 µg/g 5.901 µglg 670 µg/g
n
Z
0
U Fe-Zn sheets Ile-Ife. Nigeria
X
D Concrete slate tiles
Z
> Asbestos cement sheets
m
m Aluminum sheets
Z
0
Z
m Cu panels Munich, Germany
m
m
z
0
® Galvanized metals (primarily Galvalume) Seattle. Wash.
+n
0
m CCA wood Florida
mUntreated wood
m
Note: Fraction of metal: D=dissolved, T=total; ND=not detected.
200-11.100
10-1,400 420-14,700 ND
Analytes
Cu
(µg/L)
Zn
(lug/L)
Pb
(µg/L)
Cd
(Kg /L)
As NH4 NO-
(µglL) PH (mom) (mglL)
6,817
2,076
510
3.1
1905
360
172
2.1
140
36
22
0.2
166T/128D
877T/9091,
IIT/ < SD
43
5.9
4.8
20T/2D
12.20OT/ I I,90OD
302T135D
4,1
1 1T/7D
1,98OT/ I,61 OD
I OTI < 5 D
5.9
25T/14D
297T/257D
IOT/51,
16T/7D
101"'/82D
15T/ <517
Reference
Boller (1997)
Goad (1993)
Brown and Peake (2006)
6.77 0A6 1.52 Adeniyi and Olabanji (2005)
7.45 0.05 3.34
7.09 0.06 2.26
6.68 0.05 6.18
0.7-7.0 Athanasiadis et al. (2006)
Tobiason et al. (2004)
1.200-1.800 Khan et al. (2006)
2-3
Downloaded 13 May 2009 to 128.143.22,132. Redistribution subject to ASCE license or copyright: see ht1p:11pubs.asce.orglcopyright

on receiving waters and biota. Bailey et al. (1999) investigated
the toxicity to juvenile rainbow trout of runoff from British Co-
lumbia sawmills and found that much of the toxicity may have
been a result of divalent cations, in particular, zinc from galva-
nized roofs. Other sources of toxicity included tannins and lignins
from the woods. Lebow el al. (1999) tested chromated-copper-
arsenate (CCA) treated wood in seawater and deionized water and
found that the steady-state release rate of copper was much
greater in seawater than in deionized water (vice versa for ar-
senic). Seawater testing may be indicative of material behavior
when exposed to salt -laced rainwater in the winter.
Slormwater runoff in a ditch water near pentachlorophenol
(PCP) treated utility poles had chlorophenol concentrations 1.8
time,.,, the 96-h LC50 (lethal concentration for 50% of the salmonid
test organisms) (Stranks 1976). As These studies showed. preser-
vative release during storms from CCA and other preserved
woods was sufficiently high to be implicated in these toxicity
studies. These materials, therefore, have to be of concern in the
environment since they are used as subbase for roofing, as eaves
or, in the case of cedar, as a roofing material itself.
Wallinder el al. (2007) and Van Asschc et al. (2003) modeled
worldwide copper and zinc runoff rates, respectively, based on
runoff rates and concentrations reported in the literature. in addi-
tion to laboratory testing on degradation. These results, in com-
bination with the runoff concentrations reported in Table 1,
indicated that roofing has the potential to be a significant pollutant
source in the urban environment, where roofing covers a suhstan-
Iial fraction of the landscape.
What cannot be determined from the prior roofing runoff stud-
ies and the Table 1 results is the contribution to toxicity and
runoff pollutant concentrations from the various roofing materials
themselves versus contributions from atmospheric deposition.
The literature very strongly suggests that these materials contrib-
ute to increased runoff pollutant concentrations. This is evident
especially when nearby roofs of different compositions produce
vastly different runoff concentrations. To address the concerns
about pollutant release in the field from common construction
materials, laboratory "leaching" studies (Pitt et al. 1999; Clark
2000) were performed. The results indicated that the potential
existed for many construction materials to release pollutants into
the environment. Concerns about the .environmental impacts of
roofing led to the development of newer materials. However,
these newer materials do not have readily available results show-
ing both their short-term and long-term pollutant contributions to
urban runoff.
This ongoing research project examined a variety of roofing
materials (including subbase materials such as treated and un-
treated woods and roofing felts, which may be exposed both dur-
ing roof installation and after damage to the roof) to determine
their long-term pollutant release after typical installation and ex-
posure to the weather. The goal was to develop a better under-
standing of how aging and exposure processes impacted the
temporal release of pollutants to runoff which, eventually, should
translate into a model of pollutant release over the material's life
cycle.
Methodology
This research consisted of two parts: (1) a laboratory leaching
study of test coupons (including a simulated runoff event on aged
roofing sections, described below); and (2) a 2-year (to date),
pilot -scale field study in Pennsylvania. The project focused on
roofing and subbase materials commonly used in the roofing in-
dustry. The categories of materials investigated during the
laboratory -scale survey included the following:
I. Roofing materials (galvanized metal, asphalt tar shingles,
cedar shingles. plastic/vinyl/fiberglass roofing panels. fake
slate roofing, and roofing sealers); and
2, Woods [one (2 X 4) treated with CCA, another (2 X 4) with
an alternative waterproofing compound (modified copper
combination), and one untreated wood].
The materials, with two exceptions, were purchased from Lowes
Home Improvement Stores in Birmingham, Ala., for the labora-
tory studies, and in Harrisburg. Pa., for.the field studies. The aged
metal roofing panels (---60 years old), used in laboratory studies
only, were obtained from a barn in Lancaster County, Pa. One
panel 'was on the roof for the entire time and was rusted. The
second panel was stored in the barn as a replacement and still had
its paint intact. Besides the paint, which likely contained lead, it
was unknown whether the panels were subjected to other coating
treatments like zinc oxide. The appearance of the panels was
similar to galvanized metal. The results from testing these older
materials guided the experimental design for the field studies,
particularly in terms of monitoring program length,
Laboratory "Leaching" Studies
The laboratory tests were performed in 2002 using a modified
toxicity characteristic leaching procedure (TCLP) test. This test
simulated the exposure of a material or waste to acidic environ-
mental conditions. The two modifications to the USEPA-
prescribed test were the weight of material (approximately
100-200 g) and the length of exposure [48 It for these tests, using
Leachant Solution 1—the more aggressive, lower pH leachani.
The pH of Leachant I was approximately 0.5 pH units lower than
the acidic rainwater measured at the Penn State Harrisburg (PSH)
site]. The resulting leachate for each material (triplicate samples
for each material) was analyzed for the following constituents:
pH, conductivity, chemical oxygen demand (COD). semivolatile
organics, pesticides, heavy metals, major cations. and nutrients.
The analytical methodologies were described in Clark et al.
(2005) and conformed to methods outlined by EPA or Standard
Methods (APHA 1995). The aged roofing panels were analyzed in
2004 using the "leaching" protocols described above, as well as
being subjected to a synthetic rainfall applied with a spray bottle
over the surface of the material. The formula for the simulated
rainwater was from Davis and Bums (1999). The runoff and the
original rainwater were analyzed using EPA Method 2009, with
the rainwater concentrations subtracted from the runoff results to
obtain the contributions from the materials themselves. For these
panels, heavy metals were the only pollutants of interest.
Pilot -Scale Field Testing
Two sites in the eastern United States were selected for the field
tests based on climatic differences: the southern site was al the
University of Alabama -Birmingham (UAB), while the ntid-
Allantic site was al PSH. 'These two sites occur in two EPA rain-
fall zones (PSH: Zone 1: UAB: Zone 3) and Iwo different rainfall
pH zones (from USGS data. PSH: 4.3-4.5: UAB: >4.8). The
roofing materials (whole panels: 1.22 m X 2.44 m, shingles at-
tached in sheet rows as prescribed by the manufacturer) were
attached to A frames, with slopes similar to those used in residen-
tial pitched roofs (Fig. l shows the test setup at PSH). Construc-
tion was completed and testing began at PSH in the summer of
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Fig. 1. Roofing setup at PSH field site
2005. At UAB, roofing panels and frames were reconstructed in
the spring of 2007 as a result of prior hurricane damage. The test
panels were placed on each campus in areas with no overhead
canopy to obstruct rainfall onto the panels. Installation techniques
and fasteners, including spacing of fasteners, matched those used
by roofers to the maximum extent practicable. The panels were
left covered until just before the first monitored rain event. The
field results portion of this paper focused on the PSH site data
since the UAB evaluation recently was restarted. For the PSH
site, samples were collected for every storm for the first 2 months,
with periodic sampling thereafter.
The field testing evaluated (he following materials (manufac-
turer information provided where available from the store):
• Plexiglass (as a control to quantify and background subtract
atmospheric deposition);
• Plytanium plywood [untreated and pressure -treated (CCA)];
• Severe -weather pressure treated/water sealed planks;
• Cedar shakes:
• Roofing felt/tar paper-30 lb. (United Roofing Mfg.):
• Asphalt fiberglass shingles (Supreme Owens Corning 3-tab
[25-year limited warranty] treated for 10-year algae resis-
tance):
• Rubberized roofing material (similar to the layer on a built-up
roof);
• Galvanized aluminum, corrugated;
• 55% aluminum -zinc alloy coated steel (Galvalunlc)—
prepainted:
• Asphalt impregnated organic fiber panel (Ondura 2002), cor-
rugated; and
• Polyvinyl chloride panel, corrugated.
Analytes included pH (including periodic direct measurement of
rainfall by pH meter in beaker of rainfall collected during a storm
the pH was measured as soon as sufficient rainwater was col-
lected to submerge the probe lip), specific conductance, COD,
nutrients. and heavy metals. These parameters were analyzed
using the methods described in Clark ct al. (2005). except for
metals which were analyzed. after nitric -acid digestion, by graph-
ite furnace/atomic absorption spectropholonletry (GFAA)
(Perkin -Ebner Zeeman 5100. Perkin-Elmer) in accordance with
EPA Method 200.9,
Results and Discussion
Laboratory "Leaching" and Simulated Runoff Tests
The results from the modified TCLP test were used to indicate if
a pollutant "existed" in the material, and whether, over time. it
might be released to the environment. The organic data indicated
very little potential contributions of specific semivolatile organics
(highest leachate concentration=315 µg/L of bis(2-ethylhexyl)
phthalate, a common plasticizer, in roofing felt). The lack of el-
evated bis(2-ethylhexyl) phthalate concentrations in other
samples indicated that this result likely was not due to environ-
mental contamination of the samples, but to dissolution of the felt
paper in the leachant solution.
For the nutrients and metals, all samples were run in triplicate
and the resulls averaged after background subtraction of the initial
leachant solution concentration. These results are shown in Table
2. Even though each subsample was cut from the same intact
panel of material, the heterogeneity of Elie materials themselves
was reflected in the high variability seen in the data (in many
cases, coefficients of variation were 2.0 or greater). Therefore,
these comparisons were not made based on absolute values of the
median concentration, but on general observations made from the
data. The results from the nutrient testing showed release of ni-
trate and phosphate to the leachate, especially of phosphate from
the galvanized metal. A review of hot -dip and cold galvanizing
process information available online from several manufacturers
indicated that phosphorus may be an ingredient in some binders
and some wash solutions. The metals' results also showed that
significant potential exists for metals to be leached from these
materials as they degrade. This was expected for certain materi-
als, such as the galvanized metal, the shingles, the treated wood.
and several sealers that listed one or more metals as ingredients
since certain metals were added as a protective coating or impreg-
nated in the exposed surface of the material. Table 2 results high-
light the reservoir of pollutants potentially available for release
during storm events.
The leach testing indicated the "size" of the pollutant reservoir
in new materials, but did not address the potential of aged roofing
to release pollutants. Two aged (60+year old), painted metal roof-
ing panels were evaluated using,both leach testing and simulated
rainfall. One panel was exposed to the atmosphere since installa-
tion and was rusted across approximately 75% of the surface area,
while the other was an intact replacement panel. The panels were
subjected to the following tests: (1) a dissolution test in which an
approximate 100 g piece of the panel was submerged in concen-
trated nitric acid; (2) a leaching test (approximately 100 g) similar
to the previously discussed laboratory work; and (3) a simulated
rain exposure lest. While these exact material formulations cur-
rently may not be available, these results were used to develop the
field testing plan and to determine if an "end date" may exist in
the pollutant release.
The lead results showed (hat releases from the aged panels
were between 0.01 and 1 glkg for (he dissolution and leaching
tests (not shown). Prior to testing, it was thought that lead would
result mostly from what was likely lead paint. However, the test-
ing on the bare metal (the nonrusted portion) showed lead con-
centrations equivalent to that of the. painted metal, indicating two
potential causes: (1) lead was a component of the metal roofing
panel itself; or (2) lead was deposited on the bare metal surface
and "contaminated" the bare roofing. Unlike copper and iron, lead
also was released from the material during "rain."
The results for zinc are shown in Fig. 2 as a comparison be-
tween the results in the "leach" tests described above and simu-
lated rain. The 2002 leach test results were designated as
"pristine" panels since they were purchased less than I month
before testing. The results indicated that substantial quantities
were released from the material during both the dissolution and
leaching tests. It also was apparent that "raining" on the material
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Table 2. Laboratory Leaching of Building Materials°
Material
PO,
(rng/kg)
NO3
(mg/kg)
NH,-N
(mg/l g)
COD
(mg/kg)
CU
(mg/kg)
Pb
(mg/kg)
Zn
(mg/kg)
Fe
(mg/kg)
Asphalt tar shingles
29.4 (0.5)
1.52 (0.4)
0.83 (0.8)
2,698 (0.4)
0.66 (l.l)
0.34 (0.5)
1.22 (0.3)
46.7 (0.2)
Roofing felt
44.6 (0.245)
4.2 (1.7)
108 (0.9)
26,367 (0.9)
0.026 (2.4)
0.11 (0.2)
0(0.05)
1.87 (0A)
Ondura red vinyl roofing
0 (na)b
2.44 (2.4)
1.44 (0.4)
13.161 (0.6)
0 (na)h
0 (na)h
0 (na)b
0 (na)b
Fiberglass roofing
0.86 (l.7)
0 (na)b
0 (na)h
0(0.9)
0.017 (2.0)
0.005 (4,2)
0.53 (0.9)
0 (na)b
White plastic roofing
0 (na)b
099 (1.7)
0 (na)b
6.942 (0.5)
0.076 (0.4)
0 (na)h
1.42 (0.0
2 (0.7)
Cedar roofing shingles
1.23 (1.0)
0 (na)b
0(0.7)
18.852 (0.6)
0.033 (l.l)
0,11 (0.4)
0.64 (1.2)
1.64 (0.3)
Galvanized metal roofing
53.8 (1,2)
58.4 (0.3)
12A (0.2)
20,471 (0.1)
0.44 (0.5)
0.16 (1.2)
16.500 (0.03)
9,400 (0.4)
Galvanized metal roofing (replicate)
30.8 (1.5)
nab (na)b
t ,14 (0.7)
0 (0.3)
0 (0.09)
1.61 (0.3)
11,900 (0.01)
3,300 (0.4)
Waterproofed wood
0 (na)b
9.12 (0.2)
0 (na)b
0 (0.5)
161 (0.2)
0,29 (0.3)
3,72 (0.8)
3.22 (3,1)
Pressure treated wool
62.2 (0.06)
6.47 (0.2)
0.38 (0.8)
53,002 (0.2)
191 (0.05)
0 (na)h
1.35 (0,02)
2.69 (0.5)
Fake slate roofing shingle
0.07 (1.7)
2.71 (0.4)
0 (na)b
0(0.3)
0.2 (0.1)
0,42 (0.07)
1.81 (0.3)
20.1 (l.l)
Leak stopper rubberized roof patch
0.05 (1,7)
9.43 (0.5)
0 (na)b
726 (15.4)
0.13 (0.5)
3.78 (0.8)
2.61 (0.9)
2.25 (1.0)
Koo] seal acrylic patching cement
21.6 (1.7)
0 (na)h
0 (na)b
2,297 (1.2)
0.15 (1.4)
0.65 (0.9)
2.94 (1.5)
229 (0.9)
Gardner Wet-R-Dri roofing patch
203 (0.6)
0 (na)b
0 (na)b
0 (2.7)
0(11.1)
0,094 (1.3)
0 (na)b
1.39 (5,1)
Silver dollar aluminum roof coating
0 (na)b
nab (na)b
nab (na)b
21,520 (1.1)
1.14 (1.0)
0.3 (6.1)
0 (na)b
151 (0.5)
'Table value equals average concentration [coefficient of variation (std, dev./avg.) in parenthesis].
hna=not available. Coefficient of variation cannot be calculated because none of the triplicate samples was indistinguishable from the background
(material contribution was zero),
caused zinc to be released to the environment, although the mag-
nitudc of the release was >2 log less Ihan the release from dis-
solution and leaching. While these results were not comparable
directly since they were not from the same manufacturer and
batch, they were indicative of the zinc reservoir that may be avail-
able for release into the environment under the right conditions in
the order of several grams per kilogram of roofing panel. Com-
paratively, the lead. copper, and cadmium releases were 2-4 or-
ders of magnitude less than zinc's releases.
Pilot -Scale Field Tests
The laboratory resting showed that these materials had a reservoir
of pollutants that could be released if conditions were right. How-
ever, in order to perform these tests, the materials had to be cut
to fit the test vessels. This cutting potentially exposed sublayers
that would not be exposed during the material's normal life. The
concern was that the cuts, in the aggressive environment of the
testing, were the source of the pollutants and that the results
would not be easily translatable to the field. Since both the PSH
and UAB sites were in area,. of the United States with acid rain,
these sites were considered ideal for studying the long-term be-
havior of inlacl panels (installed according to manufacturer in-
structions). Because of the destruction of the UAB lest site during
a hurricane and its recent rebuilding, this paper focused on the
PSH results.
Approximately 2 years of field monitoring occurred at PSH.
The results are shown in Figs. 3-6 for four pollutants of interest:
nitrate. reactive phosphorus, copper, and zinc, respectively. These
results have been background corrected using the concentrations
from the plexiglass control panel. Results were not included in
this paper for pH, specific conductance, total nitrogen, total
phosphorus, ammonia, and lead for every material_ Since this
testing occurred well after lead phaseout from gasoline, lead
concentrations from the materials, after background correction.
were approximately 0 mg/L. pH for all materials were below
neutral. with runoff pHs measuring between 5 and 6.5 for all
materials except the cedar shakes (consistently approximately
4.5-5 ).
For the nutrients and copper graphs, only the results from the
treated woods and cedar shakes were incorporated. For zinc, only
the galvanized metal and aluminum -zinc alloy coated steel were
plotted. These materials were selected for each of these graphs
because of the nature of the material -woods composed of nutri-
ents in cells, and copper used as a preservative. Galvanized metal
and the alloy coated steel both advertised zinc in the product. In
addition, the daily rainfall, as reported by the National Weather
Service for the Harrisburg International Airport, was included as a
hyetograph on each figure. The airport monitoring location is
across Pennsylvania State Route 230 from the test site (within
0.5 km of the test site).
To confirm that the site was subjected to acid rain, periodic
monitoring of rainfall pH was conducted. The rainfall pH varied
1e+6
1e+5
Y 1t3+4
E
e 1e+3
N
Pristine = 2002 pumbase
Aged - 60+ years
Rx - Replicate number
xgaCr o�6af
fe -v
�Qav�
�mL
P
9°a
P
Fig. 2. Zinc in galvanized metals -comparison of new and aged
materials
642 / JOURNAL OF IRRIGATION AND DRAINAGE ENGINEERING © ASCE / SEPTEMBER/OCTOBER 2008
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so
50
40
_ a Tl Mr =4
J
-9- MMM-d Wood
m 30
Z
20
II
I 1 h
I p
i /11 �1 14
0+
0
200 400 600
Age (days)
0 3D
25
100
20
E
2D0 g 15
� U
10
300
5
400 0
t300 0
Fig. 3. Nitrate runoff concentrations for wood products
between 3.7 and 6.0. depending on the portion of the storm mea-
sured. In addition, the panels were inspected periodically for vis-
ible degradation.
The field results showed that nutrient concentrations were el-
evated early in the materials' lives (Fig. 3 for nitrate as nitrogen.
and Fig, 4 for reactive phosphorus as phosphate). Figs. 3 and 4
focused on the wood -based materials only. The woods typically
had higher concentrations than the metal -based or vinyl -type
roofing for these pollutants. The metal, rubber, and vinyl con-
centrations (not shown) were closet to background levels with
periodic spikes in the runoff (rubberized roofing reactive phos-
phorus spike of 32 mg/L at approximately Day 60; galvanized
aluminum nitrate spike of 35 mg/L at Day 50). Similar trends
were seen for ammonia. total nitrogen, and total phosphorus. In
general, the highest concentrations of these nutrients were found
in the runoff from the wood products, and in the case of the
nitrate, the untreated wood. This was not surprising since the
untreated wood was the first wood product to show visible deg-
radation (a split in the wood), exposing the underlayers to the
atmosphere. In addition, since these were wood products, the deg-
radation of cells and the release of nutrients from the cell mass
would be anticipated. Because these periodic spikes occurred
throughout the 2-year observation period, including winter, and
the control data were subtracted from the results before data
50
40
A
O
a
m 3D
p�
L
20
a
.z
10
D:
0
200 400 600
Age (days)
0
t too
E
200 c
3DO
400
80o
Fig. 5. Copper runoff concentrations for wood products (Note:
all values above 5 mg1L are estimated concentrations because
substantial dilution of the sample was needed to be within range of
the analytical method)
analysis. These spikes were not believed to be due to wash -on/
blow -on of fertilizer or grass cuttings, but instead, resulted from
the materials themselves. In addition, several of these spikes
could be correlated to additional visible material degradation (i.e.,
splitting of the wood).
Good (1993) found that dissolved metals' concentrations and
toxicity remained high in roof runoff samples. especially from
rusty galvanized metal roofs during first flush and several hours
after the rain started, indicating metal leaching continued through-
out the events. Figs. 5 and 6 highlight the results for copper and
zinc. As noted in the caption, many of the earlier samples from
the treated woods had copper concentrations that were very high
(upper analytical limit=.5 mg/L; concentrations above 5 mglL
were measured using substantial dilution and are estimates only).
Lead and arsenic concentrations were near background levels.
indicating minimal concerns. This was contrary to the results seen
by Khan et a1. (2006). who noted elevated concentrations of ar-
senic from treated wood decks. For copper, preliminary results
showed that releases were substantially higher than expected for
many materials. Rubberized roofing had the highest Cu conccn-
60
0
so
too 40
E 30
U
200 C R
0
tY 20
300 10
0
400
0 200 400 600 800
Age (days)
Fig. 4. Reactive phosphorus runoff concentrations for wood products
I
0
Coated Steel
nized Metal 100
E
E
` 200 �
I .R
t1
, 30D
v
40D
0 20D 400 GOD 800
Age (days)
Fig. 6. Zinc runoff concentrations for galvanized metal and
aluminum -zinc alloy coated steel
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tration of the metal. rubber. and vinyl materials (data not shown),
<70 µglL at [lay 50. The remaining materials from this group
showed concentrations near background levels and less than
20 µg/L. Runoff concentrations of copper for the two treated
wood panels (Fig. 5) exceeded 5 mg/L for the first 9 months of
exposure. Only after 270 days postinstallation did the copper con-
centrations from these woods approach the analytical range of the
instrumentation. These results indicated that copper continued to
be released from these wood products and at levels high enough
to exceed the aquatic life criteria and that this release likely was
not due to an excess surface coating that would wash off in the
first few storms post installation.
The literature showed that zinc from traditional unpainted or
uncoated hot -dip galvanized steel could be an environmental
concern. Fig. 6 compares the zinc runoff concentrations from a
traditional galvanized panel and from Galvalume, a prepainted
aluminum -zinc alloy coating on steel. The results showed that
the zinc runoff concentration was 5-30 mg/L throughout the first
2 years of monitoring for the traditional galvanized metal panel,
while the prepainied aluminum -zinc alloy panel was less than
250 µg/L, more than Iwo orders of magnitude less. Whether the
reduction in zinc runoff concentration was due to the painting/
coating on the material or due to a different formulation/
application method for the protective coating cannot be dcler-
mined from these data.
The laboratory -scale research showed that there could be sig-
nificant potential for pollutants (especially nutrients and metals)
to be released from common roofing materials. However, the
laboratory activities did not mimic the cyclic wet -dry weathering
(including rainfall, ultraviolet radiation, temperature, etc.) to
which these materials are exposed over the course of their
10-50 year life span. Therefore, to better predict the pollutant
release over a material's installed lifetime, field testing was
started in August 2005 and continues to date. The ongoing field
tests confirmed several of the results seen in the laboratory. Met-
als, such as copper and zinc, still were being released from ttta-
lerials well after any short-term protective coatings should have
washed off, indicating that measurable quantities of pollutants
may continue to be released in art acid rain environment through-
out the material's useful life. This contradicts prior assumptions
that releases tended to stabilize to negligible levels over a prod-
uct's lifespan. Given the large quantity of these materials installed
in the environment, the overall contribution may be significant
and deserves further investigation.
Conclusions
The laboratory leaching results showed that traditional galvanized
metal roofing contributed the greatest concentrations of many of
the pollutants of interest —specific conductance. cations, metals
(particularly zinc), and nutrients. In addition, the.metals' analyses
showed that the pressure treated and waterproofed wood contrib-
uted substantial copper loads. The potential for nutrient release
exists in many of these materials, such as from -the galvanized
metal (potentially as a result of phosphate washes and binders
used in the material's preparation) and wood products due to
natural degradation. Tests conducted in the laboratory on the aged
roofing panels suggested that this pollutant release may occur for
an extended period of time. The laboratory testing results were
limited because they were single tests of a material (which had
been precu(, exposing edges and the underlying structure) and
were performed under very aggressive conditions. Their results
were used to decide whether further investigation through a long-
term field study was warranted. The 2 years of field testing that
began in August 2005 documented low-level, long-term releases
of many pollutants from these materials.
These results indicated that investigation of the potential envi-
ronmental impact of roofing should be encouraged prior to the
material entering the market. In addition, stormwater modeling
and management should not ignore roofing when assessing
sources of pollutants. Roofs do not simply collect atmospheric
deposition and transport it to the drainage system. They also may,
.depending on the material's composition and ability to degrade
and release pollutants, be a significant source of pollutants in
urban runoff. These results, in combination with those generated
from the UAB lest site, will be used to develop models that ac-
count for the environmental and material characteristics [hat in-
nucnee the degradation and release. patterns seen in this study and
others.
Acknowledgments
The writers would like to acknowledge the contributions of three
undergraduate students at UAB—Blaine Collier, Amanda Lowry,
and Bridget Shealy, and one graduate and two undergraduate
students at PSH--Brad Mikula, Jim Elligson, and Christopher
Roenning. In addition, the writers would like to express their
appreciation to the following funding sources: Alabama Water
Resources Research Institute and the Penn State Harrisburg
Graduate Council Faculty Research Grants Committee.
References
Adeniyi, 1. F., and Olabanji, I. 0. (2005). '"rhe physicochemical and
bacteriological quality of rainwater collected over different roofing
materials in Ile-Ife, southwestern [Nigeria." Chem. Ecol., 21(3),
149-166.
American Public Health Association (APHA). (1995), Standard rnelhods
for the eeantinalian of water and wastewater, 19th Ed., American
Water Works Association. Water Pollution Control Federation. Wash-
ington, D.C.
Athansiadis, K.. Helmreich. B., and Wilderer, P. A. (2006). "Infiltration
of a copper roof runoff through artificial barriers." Water Sci. Tech-
noL, 54(6-7), 281-289.
Bailey, H. C., Elphick, J. R., Potter, A., and Zak, B. (1999). "Zinc tox-
icity in stormwater runoff from sawmills in British Columbia." lister
Res., 33(11), 2721-2725,
Boller, M. (1997). "Tracking heavy metals reveals sustainability deficits
of urban drainage systems." Water Sci. Technol., 35(9), 77-87.
Brown, J. N., and Peake, B. M. (2006). "Sources of heavy metals and
polycyclic aromatic hydrocarbons in urban stormwater runoff." Sci.
Total Eimiron., 359(1-3), 145-155.
Burton, G. A., Jr., and Pitt, R. (2002). Stortrnrater effects handbook:
A tool hat fitr watershed managers, scientists, mid engineers, CRC,
Boca Raton, Fla.
Clark, S. E. (2000). "Urban stormwater filtration: Optimization of design
parameters and a pilot -scale evaluation." Ph.D. dissertation, Univ. of
Alabama at Birmingham, Birmingham, Ala,
Clark, S. E., Lalor. M. M., and Pitt. R. (2005). "Wet -weather pollu-
tion from commonly -used building materials." Proc., World Environ-
mental and Water Resources Congress (CD-ROM), ASCE/EWRI,
Reston, Va.
Clark, S. E., Pitt, R., and Field. R. (2002). "Wet -weather pollution pre-
vention by product substitution." Proc., United Engineering Conf. on
Linking Slonmr'arer BMP Designs and Petfirnnance ro Receiving
644 / JOURNAL OF IRRIGATION AND DRAINAGE ENGINEERING 0 ASCE / SEPTEMBER/OCTOBER 2008
Downloaded 13 May 2009 to 128.143.22.132. Redistribution subject to ASCE license or copyright; see http://pubs.asce.orgtcopyright

Weiler Impacts, ASCE, Reston, Va., 266-283.
Davis, A„ and Burns, M. (1999). "Evaluation of lead concentration in
runoff From painted structures." Water Res., 33(13), 2949-2958,
Good, J. C. (1993). "Roof runoff as a diffuse source of metals and aquatic
toxicity in siormwater." Water Sri. Technal., 28(3-5), 317-321.
Khan, B. I„ Solo-Gabriele, H. M., Townsend, T. G., and Cai, Y. (2006).
"Release of arsenic to the environment from CCA-treated wood. I:
Leaching and speciation during service." Environ. Sci. Technol.. 40,
988-993.
Kingette Mitchell Ltd., and Diffuse Sources Ltd. (2003), A sludgy of roof
runoff qualii), in Auckland New Zealand: lngtlicatiwrs for slormwater
nrrnragenrenf, Takapuna, Auckland, New Zealand.
Lebow, S. T.,Foster, D. O., and Lebow, P. K. (1999). "Release of copper,
chromium, and arsenic from treated southern pine exposed in sea-
water and freshwater," For. Procl. J., 49(7), 80-89.
Ondura. (2002). Ondura(9 has if all over other roofing. Fredericksburg,
Va.
Pitt, R., Field, R., Lalor, M., and Brown, M. (1995). "Urban stormwaler
toxic pollutants: assessment, Sources and treatability." Wafer Environ.
Res., 67(3). 260-275.
Pitt, R., Robertson, B., Barron, P., Ayyoubi, A., and Clark, S. (1999).
Store water runoff treatment of crilical areas: The nrulrichainbered
treatment trail (MC77), EPA 600/R-99/017. U.S. Environmental Pro-
tection Agency, Water Supply and Water Resources Division, National
Risk Management Laboratory, Cincinnati.
Stranks, D. W. (1976). "Wood preservatives: Their depletion as fungi-
cides and fate in the environment." Canadian Forest Sen-ire 7eclvri-
cal Rep. No. 10, Ottawa, Canada.
Tobiason. S. (2004). "Stormwater metals removal by media filtration:
Field assessment case ,study." Proc., Watershed 2004 Conf. Proc.,
(CD-ROM), Water Environment Federation, Alexandria. Va.
Van Assche, F., Regoli, L., and Cook, M, (2003). "Atmospheric zinc
run-off in a general perspective of diffuse zinc emissions to surface
waters: Experience of" the EU zinc risk assessment." Korrosionsinsri-
netet Rap. No. 109E, 159-167.
Wallinder, 1. O., Bahar, B., Leygraf. C., and Tidblad. J. (2007). "Model-
ling and mapping of copper runoff for Europe." J. Environ. Monit— 9,
66-73,
JOURNAL OF IRRIGATION AND DRAINAGE ENGINEERING ® ASCE / SEPTEMBER/OCTOBER 2008/645
Downloaded 13 May 2009 to 128.143.22.132. Redistribution subject to ASCE license or copyright; see httpalpubs.asce.orgrcopyright

Kucken, Darlene
From: Georgoulias, Bethany.
Sent: Wednesday, February 03, 2016 12:41 PM
To: Pickle, Ken
Cc: Kucken, Darlene
Subject: RE: NtG030251 - Tier Three Issues
Thanks, Ken. I didn't even make the connection that it had been the same site. -Bg
Bethany Georgoulias •
Environmental Engineer
Stormwater Permitting Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
[e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N.-Salisbury Street, Raleigh, NC 27604 (location)
Website: http://portal.ncdenr.org,/web/Ir/stormwater
-,>'"Nothiing Compares--,-�
Email correspondence to and from this address is subject to the
!North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Wednesday, February 03, 2016 12:38 PM
To: Georgoulias, Bethany<bethany,[e-mail]>; Kucken, Darlene <[e-mail]>
Subject: FW: NCG030251 - Tier Three Issues
Bethany, thanks for copying me on the email string on Watts Regulator, 5pindole.

Darlene,
FYI: See below my report on what may have been the initial conversation with their Mr.Chu last week. Just more background to help with your decision on this
site. I advised Mr. Chu to contact ARO.
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
:` Nothing Compares-,%,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Tuesday, January 26, 2016 1:39 PM
To: Georgoulias, Bethany<[e-mail]>; Bennett, Bradley <bradley.bennettRncdenr.Rov>
Subject: RE: NCG030251 -Tier Three Issues
BBBG:
I followed up on this one and spoke voice -to -voice with Mr. Chu. BIMS reminds me it was Watts Regulator in Spindale. I think Mr. Chu sits somewhere in
Yankeeland with Watts corporate.
A couple of questions rolled together, iirc. The facility is mostly an off -site warehouse and distribution center for product from other Watts facilities. So, would
they even need to continue under NCGO3, since no manufacturing activity takes place?

However, also: He reported that there is some assembly of valve parts into final product that takes place. 1 relayed our perspective that the presence of the
manufacturing activity calls into question whether the facility is an off -site warehouse only, and so we would not rescind the permit. Continuation under NCGu3
may be indicated.
I think we left it at that; with the expectation that if Mr. Chu wants us to consider rescission of the permit he will put together a description of the site activities
for our evaluation. I also noted that the next step in any permit rescission process would be an inspection by the ARO to confirm that rescission is appropriate.
The facility also used to be a brass foundry in the mid 1990's, although the Google aerial appears to show a pretty clean site, now. He reports continuing hits on
Cu and Zn. I advised that given the background of the site, I would not default to the conclusion that the Cu and Zn are from un-impacted site soils. More
substantial evidence would be necessary to reach a conclusion that the metal hits are environmental background results.
- -1 think that's all there was to his call - - - .
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
i'Nothing Compares,.., •
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Georgoulias, Bethany
Sent: Tuesday, January 26, 2016 12:33 PM
To: Bennett, Bradley <[e-mail]>; Pickle, Ken <[e-mail]>
Subject: RE: NCG030251 -Tier Three Issues

Oh gosh, I haven't had a chance to follow up on this. Ken, did you? I think I lost sight of it with the schedule upheaval I've had the last week. I can try to get to
this later this week if it still needs attention.
Bg
Bethany Georgoulias
Environmental Engineer
Stormwater Permitting Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany.geor og [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Strcct, Raleigh, NC 27604 (location)
Website: http://portal.nedenr.orglweb/Ir/stormwater
Nothing Compares.,,_,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley
Sent: Thursday, January 14, 2016 3:32 PM
To: Pickle, Ken <[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: NCG030251 - Tier Three Issues
Hey Guys,
Could one of you contact Howard Chu. He called and wants to set up a meeting to discuss their tier 3 response. His number is [phone].
Bradley Bennett
Stormwater Permitting Program Phone: [phone]

NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: brad ley. bennett ncdenr. ov
Raleigh, NC 27699-1612 Web: http://portal.ncdenr.00/web/Ir/stormwater
Email correspondence to and from this address may be subject to public records taws
i
i

Kucken, Darlene
From: Kucken, Darlene
Sent: Wednesday, November 30, 2016 3:02 PM
To: Bethany Georgoulias ([e-mail]); Laura Alexander ([e-mail])
Subject: FW: Watts-Spindale Stormwater Background Sampling and Representative Outfall Request
Attachments: Watts Spindale BG and RO Report.pdf; DEQ Letter Feb 201.6.pdf
Bethany and Laura,
This is a very thorough and interesting report done for Watts Water Technologies. I had responded to a request to assess this site related to their Tiered
sampling and for a possible ROS for the facility late last year. I communicated with y'all about my inspection and sent them a letter saying they should
temporarily continue sampling all outfails but on a quarterly basis. As noted at the time and in this report, they had already installed some BMPs, they were
sampling for background levels, and direct rainfall. They had also researched that the coating materials used on many flat roofs in the area has metals leaching
qualities.
They did continue their research and the outcome well documents they are heavily impacted by background inputs, including a road, railroad, and other
industrial roofs with the coating materials.
I believe that they should receive ROS for the one outfall 002, which is the only outfall that is directly related to their facility. This is my recommendation.
I'm just checking in with y'all to let me know if you have any problem with this recommendation. Do I send a letter to this effect? Do you need to send it? Can I
tell them by email that they can expect to get the ROS?
I also think they should not have to continue the Tiered sampling due to the high background levels of Cu, Zn and Pb coming to the facility. Are you ok with this*
Thanks for your input!
Darlene Kucken - [e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
`-A Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: Matt Bramblett[[e-mail]
Sent: Wednesday, August 24, 2016 1:54 PM
To: Kucken, Darlene <[e-mail]>
Cc: Kennard, Mark A. <[e-mail]>; Sullivan, Sean M. <[e-mail]>; Chu, Howard H.
<[e-mail]>
Subject: Watts-Spindale Stormwater Background Sampling and Representative Outfall Request
Darlene,
On behalf of Watts Water Technologies, please find the attached stormwater background sampling letter and Representative Outfall Request for the Watts s
facility in Spindale. l have attached the letter report in PDF format and also a copy of your letter from February 2016 regarding this site.
I look forward to receiving your response.
Thanks,
Matt
Matt Bramblett, PE, Principal
Hart & Hickman, PC 12923 South Tryon Street, Suite 100 1 Charlotte, NC 28203
Direct 704-887-4620 1 Mobile [phone] Main 704-586-0007
www.harthickman.com
hart � hickman
W-VUEB Et1V4 "'Alfa" SC1Yt10Nt

Energy, Mineral
and Land Resources
E N V tRONMENTAL QUALITY
February 3, 2016
Watts Regulator
ATTN: Mark Kennard
100 Watts Road
Spindale, NC 28160
SUBJECT: NPDES Stormwater Permit Compliance Inspection
Watts Regulator
Permit No: NCG030251
Rutherford County
Dear Mr. Kennard:
PAT MCCRORY
Gnvernrw
DONALD R. VAN DER VAART
I r—ary
TRACY DAVIS
Director
This letter is in follow-up to the NPDES Stormwater Permit Compliance Inspection conducted on January 27, 2016.
The facility was found to be in non-compliance with permit NCG 180003.
Enclosed is a copy of the Compliance Inspection Report, which contains additional observations and comments for
your reference. Please note the summary on page 2 of this report and in particular note the recommendations. You
will note that you are being given relief from Tier 11I sampling at this time but you are required to conduct additional
sampling. After the additional sampling of the roof, road runoff and rainfall event is conducted, and the
documentation as noted in item #2, please contact me for further assessment of the potential for requesting
Representative Outfall Status.
If I can be of any further assistance, please contact me at (828) 2964500.
Sincerely,
Darlene Kucken
Environmental Specialist
Land Quality Section
Enclosure: Compliance Inspection Report
Stale of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
2090 US 70 Highway I Swannanoa, NC 28778-8211
829 296 45N T

Compliance Inspection Report
Permit: NCG030251 Effective: 11/01/12 Expiration: 10/31/17 Owner : Watts Regulator
SOC: Effective: Expiration: Facility: Watts Regulator
County: Rutherford 100 Watts Rd
Region: Asheville
Spindale NC 28160
Contact Person: Mark Kennard Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 01/27/2016 Entry Time: 10:30AM Exit Time: 12:30PM
Primary inspector: Darlene J Kucken Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

permit: NCG180003 Owner - Facility: Westrock Converting Company
Inspection Date: 01/26/2016 Inspection Type : Compliance Evaluation 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 Slormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment: Facility manager needs to continue to conduct semi-annual gualititative monitoring.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: Documentation of analvtical monitoirnq was not on site. Continue to provide aril ;maintain
documentation of analytical monitoring
Yes No NA NE
■❑❑❑
0 ❑ ❑ ❑
® ❑ ❑ ❑
❑❑■❑
❑❑■❑
E ❑ ❑ ❑
■❑❑❑
■❑❑❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
■❑❑❑
■❑❑❑
■❑❑❑
Yes No NA NE
■❑❑❑
Yes Ng_RA NE
❑ N ❑ ❑
❑ ❑ ❑
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ N ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it property documented by the Division? ❑ ❑ © ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ® ❑
Comment: A name change form needs to be filled out to get the current permit in the current facility name.
A cope of the actual permit was not on site. Alan Hooper was directed to obtain these
documents and Laura Alexander of the Raleigh Central Office Stormwater Program staff
0aura.alexander0)ncdenr.gov) will assist
Page: 3

Kucken, Darlene
From: Pickle, Ken
Sent: Wednesday, February 03, 2016 12:38 PM
To: Georgoulias, Bethany; Kucken, Darlene
Subject: FW: NCG030251 - Tier Three Issues
Bethany, thanks for copying me on the email string on Watts Regulator, Spindale.
Darlene,
FYI: See below my report on what may have been the initial conversation with their Mr.Chu last week. Just more
background to help with your decision on this site. I advised Mr. Chu to contact ARQ.
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
ri"": Compares,..:_
AA
IMLOM
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent:G7uesday, January 26; 2016 1:39 PM
Ta:'Geor oulias Bethany <bethan eor oulias@ncdenr. ov>• Bennett, Bradley <bradle bennett@ncdenr. ov>
g Y Y•g � g Y Y• g
Subject: RE: NCG030251 -Tier Three Issues
BBBG
I followed up on this one and spoke voice -to -voice with Mr: Chu. BIMS reminds me it was Watts Regulator in Spindale
think Mr. Chu sits somewhere in Yankeeland with Watts corporate. _.
A couple of questions rolled together, iirc. The facility is mostly an off -site warehouse and distribution center for
product from other Watts facilities. So, would they even need to continue under NCG03, since no manufacturing activity
takes place?
However, also: He reported that there is some assembly of valve parts into final product that takes place. I relayed our
perspective that the presence of the manufacturing activity calls into question whether the facility is ;.In off -site
warehouse only, and so we would not rescind the permit. Continuation under NCG03 may be indicatr d.
1

•
I think we left it at that; with the expectation that if Mr. Chu wants us to consider rescission of the permit he will put
together a description of the site activities for our evaluation. f also noted that the next step in any permit rescission
process would be an inspection by the ARO to confirm that rescission is appropriate.
The facility also used to be a brass foundry in the mid 1990's, although the Google aerial appears to show a pretty clean
site, now. He reports continuing hits on Cu and Zn. I advised that given the background of the site, I would not default
to the conclusion that the Cu and Zn are from un-impacted site soils. More substantial evidence would be necessary to
reach a conclusion that the metal hits are environmental background results.
- - I think that's ail there was to his toll ---
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. pickleq ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
--Nothing Compares -,,.-
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Georgoulias, Bethany
Sent: Tuesday, January 26, 2016 12:33 PM
To: Bennett, Bradley <[e-mail]>; Pickle, Ken <[e-mail]>
Subject: RE: NCG030251 -Tier Three Issues
Oh gosh, I haven't had a chance to follow up on this. Ken, did you? I think I lost sight of it with the schedule upheaval
I've had the last week. I can try to get to this later this week if it still needs attention.
Bg
Bethany Georgoulias
Environmental Engineer
Stormwater Permitting Program, Division of Energy, Mineral, and Land Resources
N.C. Department of' Environniental Quality
919 807 6372 office
bethany.georgou I ias@ncdenr
1612 Mail Service Center. Raleigh: NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http_://portal.ncdenr.org/web/ir/storinwater

1, Nothing Compares_-,�.._
Email correspondence to and from this address is subject to the
Nodh Carolina Public Records Law and may be disclosed to third parties,
From: Bennett, Bradley
Sent: Thursday, January 14, 2016 3:32 PM
To: Pickle, Ken <[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: NCG030251 - Tier Three Issues
Hey Guys,
Could one of you contact Howard Chu. He called and wants to set up a meeting to discuss their tier 3 response. His
number is [phone].
BB
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1612 Web: http:llportal,ncdenr.org/weblldstormwater
Email correspondence to and from this address may be subject to public records laws
3

l . 'L
Kucken, Darlene
From: Georgoulias, Bethany
Sent: Tuesday, February 02, 2016 12:46 PM
To: Kucken, Darlene
Cc: Bennett, Bradley; Pickle, Ken
Subject: RE: Watts Water Technologies - NCG 030251
Follow Up Flag: Follow up
Flag Status: Flagged
Darlene,
I still agree with my original preliminary conclusion last week — that the evidence points towards most sources
(roads/tracks) being beyond their control, If you confirmed no Zn impairment information for that segment, we don't
have much in the way of ambient stream sampling results to factor in here. But, some things to consider:
One of the big questions here is what to do about the outfalls that include road run-off. Is there any way for them to
sample something before that runoff mixes with their industrial site? Or do the other three outfalls even drain any of
the areas where industrial activity occurs or materials are stored here? If they do, is there a good case for
Representative Outfall Status here that makes sense? (That is not always the easy answer, though, unfortunately.)
If they think they are seeing Zn levels influenced by the whitener put on their roof, it sounds like at least one of the
outfalls drains that, and presumably it is industrial activity. That 1.89 mg/I of Zn concentration is...wow, big. And if
other roofs in the area use it, are those roofs draining onto their property too? Or onto the road runoff they
sampled? Have they sampled that same roof drain again to confirm concentrations that high are coming from there? Is
it possible that whitener stripped zinc from the roof material itself?
It sounds like they've implemented some very good things at their site that have helped. But if they are seeing
consistent Zn results that high from the roof drain, that's potentially a major source, and they may need to investigate
that further. I might take a balanced approach, considering it's a roof that other facilities nearby have too. Consider
allowing them to drop back to semi-annual sampling at their outfalls, on the basis of the other items you outlined (road
influence, etc.), but advising more samples of that roof drain. Ask them to follow up after (2-3 more?). How often is it
necessary for them to whiten their roof? Have they investigated an alternative for next time, or is it necessary to apply
this chemica[ at all if it introduces such a dramatic spike in metals concentrations? If they determine it is the roof
whitener application, how can they address this issue specifically in their SPPP to the most practical extent? We don't
expect them to buy a new roof, but they should be aware if that much zinc is coming off of it ... uitimately this is part of
their industrial property and covered by this permit.
At the end of the day, it's up to ARO how to handle this, so you can decide whether to ask them for more or not. You've
gotten several of these under your belt, and your experience is something we can really count on_ Thanks so much for
all the efforts you've put into working with this and other facilities under permits like the NCG03.
Best,
Bethany
From: Kucken, Darlene
Sent: Tuesday, February 02, 2016 10:17 AM
To: Georgoulias, Bethany<[e-mail]>
Subject: RE: Watts Water Technologies - NCG 030251

0
Hi Bethany,
I'm going on vacation from Feb 10-28 and it would be nice to get this letter out before I leave. I'm not trying to be pushy
here, but I'm trying to get a lot done before I vacate and I want to be able to schedule the priorities.
Darlene Kucken - [e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
`A, Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: Georgoulias, Bethany
Sent: Friday, January 29, 2016 11:25 AM
To: Kucken, Darlene <darlene.kucken@ncdenr,gov>
Subject: RE: Watts Water Technologies - NCG 030251
Hi Darlene,
I will look at this a little more thoroughly next week, but it sounds like you are leaning in the same direction we would.
Be sure to check the receiving waters to see if there are any problems with these metals (documented, anyway... maybe
the stream was never sampled). I'm working on a permit right now that discharges to a segment impaired for copper. A
copper or zinc impairment might affect our decision on what to do next. it's easy to forget to cover that base — but it's
one of the caveats to the "we should relieve their monitoring if it's just their roof" scenario; the permittee is still
responsible for that source, and we need to factor in water quality information. At first glance, though, the evidence
seems to point to other background sources out of their control as well.
I'll get back to you on this early next week.
Thanks!
Bethany
13ethany Geurgoulias '
Frivironmtntal Digirieer
StorniNvater Permitting Program. Division of Energy. Mineral. and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany geor�,,oulias rr nedenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://portal.ncdenr.orp/web/Ir/storm water

0
K! ''Nath9ng Comperes ..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Kucken, Darlene
Sent: Friday, January 29, 2016 11:06 AM
To: Georgoulias, Bethany<[e-mail]>
Subject: Watts Water Technologies - NCG 030251
I received a request to conduct an inspection at the Watts Water Technologies facility in Spindale, Rutherford
County. The facility is currently under Tier III sampling for Cu and Zn at OF 1,2 and 4 and Cu at OF 6. Given their high
sample results, they brought in Hart Hickman environmental solutions firm out of Charlotte to help them figure out how
to reduce these elevated levels. They provided me with a thorough report of their analysis. Here's the summary:
1. The facility has 3 operation sections: warehouse, recovery (recycling region) and a very small and yjn light
assembly (basically they put two parts together with nuts and bolts).
2. They have implemented 3 key items: stormwater filter socks, adding rip rap in all eroding areas, improving grass
coverage density for soil stabilization, and internal policies of sweeping daily in the small area of assembly.
3. Metal concentrations decreased as a result of these efforts, but still remain above the benchmark levels. They
have conducted two samplings since the implementation of these items but results are only available for one of
these events. The other one will be available soon.
4. They added sampling of road runoff ( Cu=.438 mg/L and Zn=.178 mg/L) and directly from the roof drains
(Cu=.205 mg/L and Zn=1.89 mg/L and .338 mg/L at another drain).
5. Outfalls in this same sampling showed Cu= .072, .005,.055, .037 and Zn=.073, .028, .196 and .117
6. Complicating factors:
a. OF002 is really the only outfall that is only related to the facility. Test results from this outfall were
Cu=.0059 and Zn=.0287 (well below benchmarks).
b. The other outfalls are heavily impacted by the railroad tracks and Watts Rd runoff. I don't think that OFs
1, 4, or 6 are representative of the facility at all. OF 4 is runoff from Watts Rd and OFs 1 and 6 are runoff
from the railroad tracks and Callahan Koon Rd.
C. This facility was a textile production facility for a long time, but this production ended about 18 years
ago. There could be residual effects?
d. The whitening material used on the roof (sort of a paint) may be a source. This covering was recently
put on the roof. With research efforts, they found a study showing this material may have a Zn
component. Many buildings in this area have used this product on their roofs, so there could be a
background influence. You can see this in the test results noted above.
I can provide you with this report and the results. But after inspecting the interior and exterior conditions of this facility
as it's currently operating, I think they have done what they can do to address the metals levels (reportedly they spent
about $60,000 on items in 42) and that only OF 2 represents runoff from any processing areas. I believe their sample
results are heavily influenced by background levels and inputs:
I told them to keep doing what they're doing until they hear back from me. 5o I will wait to hear from you as to what
else you need and how to proceed.
Thanks for your guidance.

0
0 ­-1
Darlene Kucken - Darlene.Kucken([e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
`�j Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
4

Kucken, Darlene
From: Kucken, Darlene
Sent: Friday, January 29, 2016 11:06 AM
To: Georgoulias, Bethany
Subject: Watts Water Technologies - NCG 030251
I received a request to conduct an inspection at the Watts Water Technologies facility in Spindale, Rutherford
County: The facility is currently under Tier III sampling for Cu and Zn at OF 1,2 and 4 and Cu at OF 6. Given their high
sample results, they brought in Hart Hickman environmental solutions firm out of Charlotte to help them figure out how
to reduce these elevated levels. They provided me with a thorough report of their analysis. Here's the summary:
1. The facility has 3 operation sections: warehouse, recovery (recycling region) and a very small and very light
assembly (basically they put two parts together with nuts and baps).
2. They have implemented 3 key items: stormwater filter socks, adding rip rap in all eroding areas, improving grass
coverage density for soil stabilization, and internal policies of sweeping daily in the small area of assembly.
3. Metal concentrations decreased as a result of these efforts, but still remain above the benchmark levels. They
have conducted two samplings since the implementation of these items but results are only available for one of
these events. The other one will be available soon.
4. They added sampling of road runoff ( Cu=.438 mg/L and Zn=.178 mg/L) and directly from the roof drains
(Cu=.205 mg/L and Zn=1.89 mg/L and .338 mg/L at another drain).
S. Outfalls in this same sampling showed Cu= .072, .005,,055, .037 and Zn=.073, .028, .196 and .117
6. Complicating factors:
a. OF002 is really the only outfall that is only related to the facility. Test results from this outfall were
Cu=.0059 and Zn=.0287 (well below benchmarks).
b. The other outfalls are heavily impacted by the railroad tracks and Watts Rd runoff. I don't think that OFs
1, 4, or 6 are representative of the facility at all. OF 4 is runoff from Watts Rd and OFs 1 and 6 are runoff
from the railroad tracks and Callahan Koon Rd.
c. This facility was a textile production facility for a long time, but this production ended about 18 years
ago. There could be residual effects?
d. The whitening material used on the roof (sort of a paint) may be a source. This covering was recently
put on the roof, With research efforts, they found a study showing this material may have a Zn
component. Many buildings in this area have used this product on their roofs, so there could be a
background influence. You can see this in the test results noted above.
I can provide you with this report and the results. But after inspecting the interior and exterior conditions of this facility
as it's currently operating, I think they have done what they can do to address the metals levels (reportedly they spent
about $60,000 on items in #2) and that only OF 2 represents runoff from any processing areas. I believe their sample
results are heavily influenced by background levels and inputs.
I told them to keep doing what they're doing until they hear back from me. So I will wait to hear from you as to what
else you need and how to proceed.
Thanks for your guidance.
Darlene Kucken - [e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway

Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
d-, Go Green? Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.

Pickle, Ken
From:
Pickle, Ken
Sent:
Tuesday, January 19, 2016 3:27 PM
To:
Bennett, Bradley
Cc:
Aiken, Stan E
Subject:
RE: NCG030251 - Tier Three Issues
Thanks, Bradley,
Talked with Howard Chu. Watts Water Technologv. about their facility in Spindale (Rutherford Countv). NCG0302S1.
• Howard is in Boston, Ma., and works incorporate environmental. The Spindale facility is now in Tier 3 based
on copper and zinc exceedances. It does not appear that they contacted ARO as per the text of NCG03: they
contacted RCO. Stan: I provided the phone number and names at ARO for his contact.
• He reports that they are mainly a warehouse, but some assembly of valves takes place on site. The site used to
be a brass foundry, but the foundry closed down in the mid-90s. Google aerial photo appears to show a
relatively clean site.
• Using Bart Hickman as consultants. They have some 'background' sampling to augment the permit sampling in
support of a hypothesis that it's in the soils, or otherwise part of the background conditions. I advised we are
typically very cautious on our response to Cu and Zn exceedances because sometimes it could indeed be in the
soils. However, I also advised that since the facility was a brass foundry, we would expect some substantial
amount of evidence before dismissing the possibility of industrial materials being the source.
• I advised we have instituted new, higher benchmarks for Cu and Zn since this general permit was issued in 2012.
• He requested a meeting. I advised our procedure is to first engage the RO in order to have the benefit of a
recent site inspection. He will call Stan in ARO (Rutherford County) to request a site visit. i offered that we in
RCO will of course respond to any subsequent request to meet, but we would prefer it after ARO has been on
site.
• He wants to investigate re-classifying the site as an off -site warehouse. I advised that we would look at the
actual on -site activity, and I noted that the presence of Cu and Zn exceedances can't be addressed by switching
permits so that he no longer has to test for them (as per NCG08). I also advised that the assembly of valves
could make it difficult for us to conclude that this is a transportation activity rather than a metal manufacturing
activity. We did not speak to the potential that an off -site warehouse might not be captured by the NPDES reps
at all, although that could be another outcome, depending on actual on -site activities.
• He wants to discuss the next steps in Tier 3. Presumably leading to an endpoint satisfactory to all. I advised that
after ARO has been on site, RCO would be happy to participate in that discussion, if invited by either ARO or the
permittee. J
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
[e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Y
:7

N
Nothing Compares--.,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley
Sent: Tuesday, January 19, 2016 2:26 PM
To: Pickle, Ken <[e-mail]>; Georgoulias, Bethany <[e-mail]>; Randall, Mike
<[e-mail]>
Subject: RE: NCG030251 -Tier Three Issues
Ken,
Just to clarify. This is the one I talked to, but I think this is different from the one Mike and Bethany Talked with. That
was a Goodrich facility I think.
BB
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: brad ley. ben netta_ncdenr.gov
Raleigh. NC 27699-1612 Web: http:/lportal.ncdenr.org/webAristormwater
Email correspondence to and from this address may be subject to public records laws
From: Pickle, Ken
Sent: Tuesday, January 19, 20161:39 PM
To: Bennett, Bradley <bradle [e-mail]>; Georgoulias, Bethany <[e-mail]_>;
Randall, Mike <[e-mail]>
Subject: RE: NCG030251- Tier Three Issues
Is this the contact we spoke about in staff meeting?
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. pickle@. ncdenr.pov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
-5�'Nothing Compares--%.-

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley
Sent: Thursday, January 14, 2016 3:32 PM
To: Pickle, Ken <ken.picklePncdenr.gov>; Georgoulias, Bethany<[e-mail]>
Subject: NCGO3O251 -Tier Three Issues
Hey Guys,
Could one of you contact Howard Chu. He called and wants to set up a meeting to discuss their tier 3 response. His
number is [phone].
BB
Bradley Bennett
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources
1612 Mail Service Center j
Raleigh, NC 27699-1612
Phone: [phone]
Fax: [phone]
Email: bradley.bennett(@ncdenr.gov
Web: http:llportal.ncdenr.org/web/Irlstormwater
Email correspondence to and from this address may be subject to public records laws

INWATM
A Watts Water Technologies Company
December 29, 2015
615 Chestnut Street • North Andover. MA • 01845-6098 • Tel. [phone] • Fax: [phone]
BY CERTIFIED MAIL — RETURN RECEIPT REQUESTED
Central Records
Division of Energy, Mineral and Land Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
(; t\je0
GENTRA `C �
pVVR SEC
Re: Discharge Monitoring Report and Notice of Compliance Status
Watts Regulator, 100 Watts Road, Spindale, North Carolina 0
Certificate of Coveray-c Number NCG030251
0-
To Whom It May Concern:
In accordance with certificate of coverage referenced above and requirements of general
permit number NCG030000 ("General Permit"), please find enclosed discharge monitoring
report ("DMR") for monitoring year 3, period 2, monthly monitoring (November 2015)
regarding Watts Regulator ("Watts") facility at 100 Watts Road in Spindale, North Carolina
(`'Facility"). Consistent with the February 3, 2010, Approval of Representative Outfall Status,
Watts obtained quantitative data for samples from outfalls 001, 002, 004, and 006. Based on the
results reflected in the enclosed November 2015 DMR, these outfalls remain in Tier III status. In
addition to required outfall sampling, Watts obtained samples for pH from outfalls 003, 005, and
007. Those data are also reflected in the enclosed DMR.t
Upon receiving July 2015 sampling results, Watts engaged environmental consulting firm
of Hart & Hickman ("H&H") to develop additional best management practices (BMP") for the
Facility. In order to evaluate effectiveness of those BMPs — and to determine the cause of the
recent zinc and copper benchmark exceedences — on October 27, 2015, the Facility sampled
outfalls 001, 002, 004 and 006 as well as four background locations. 2 A letter report from H&H,
describing the results of that effort, was enclosed with Watts' October 2015 DMR, and an
additional copy is enclosed with this correspondence. The Facility then re -sampled the four
background locations identified in H&H's letter report during the November 2015 sampling
event, and those results are consistent with the previous results.3
In summary, available data indicate that copper and zinc present in the Facility's storrn
water discharge likely originates from "non -industrial" sources — either the Facility's roof (which
' As documented in the June 2015 DMR, pH of precipitation in and around Spindale is commonly below the
benchmark range in the General Permit. Watts will continue to collect "neat" precipitation samples, analyze those
samples for pH, and include the summarized results in each DMR. in accordance with footnote 1 of Table 3 in the
General Permit.
2 Consistent with the February 3, 2010 Approval of Representative Outfall Status, the Facility did not sample
outfalls 003, 005, or 007.
3 The enclosed lab report contains data for samples taken at locations identified as Road Run Off -01 and -02 as
well as Roof Drain #1 and #2, which are the same background sampling points discussed in H&H's letter report.
Watts Regulator Company
Since 1674
watls.com

is not exposed to industrial operations) or the roadway adjacent to the Facility's storm water
outfalls. The results also suggest that the Facility's additional BMPs will resolve previous
exceedences of the lead benchmark.
As mentioned in my previous correspondence, I respectfully request to schedule a
meeting with representatives of the Division of Energy, Mineral and Land Resources to discuss
the results of a storm water compliance audit performed by AECOM and Watts' efforts to
implement additional BMPs at the Facility. Please contact me at your earliest convenience at
[phone] to arrange a date and time.
Sincerely,
Howard H. Chu
Director, Environment, Health and Safety
Watts Water Technologies, Inc.
Enclosures
cc: Central Records, Division of Water Quality

e
aceAnalytrcal
~rpaw.'abs.com
November 30, 2015
Mark Kennard
Watts Water Technologies
815 Pickens Street
Chesnee, SC 29323
RE: Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Dear Mark Kennard:
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Enclosed are the analytical results for sample(s) received by the laboratory on November 19, 2015.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Nicole Gasiorowski
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 17

aceAnalytical
W".pacerabs.aaar
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville. NC 28078
[phone]
CERTIFICATIONS
Project: WATTS SPINDALE STCRMWATER
Pace Project No.: 92276912
Charlotte Certification IDs
9800 Kincey Ave, Ste 100, Huntersville, NC 28078
Florida/NELAP Certification #: E87627
North Carolina Drinking Water Certification #: 37706
Kentucky UST Certification #: 84
North Carolina Field Services Certification #: 5342
West Virginia Certificafion #: 357
North Carolina Wastewater Certification #: 12
Virginia[VELAP Certification #: 460221
South Carolina Certification #: 99006001
Asheville Certification IDs
2225 Riverside Drive, Asheville, NC 28804
Florida/NELAP Certification #: E87548
Massachusetts Certification #_ M-NC030
North Carolina Drinking Water Certification #: 37712
North Carolina Wastewater Certification #: 40
South Carolina Certification #: 99030001
West Virginia Certification #: 356
Virginia[VELAP Cerbfication #: 460222
REPORT OF LABORATORY ANALYSIS
This report Shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 2 of 17

Pace Analytical Services, Inc.
aceAnalytlCal a 9600 Kincey Ave. Suite 100
Huntersville, NC 28078
wwwpacelab&=M [phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Sample: OU-001 Lab ID: 92276912001 Collected: 11/18/15 07:05 Received: 11/19/15 10:15 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 1664E
Total Petroleum Hydrocarbons
ND mg1L
5.0
1
11/24/15 10:44
200.7 MET ICP
Analytical Method: EPA200.7 Preparation
Method: EPA200.7
Copper
68.8 ug1L
5.0
1 11/23/15 20:30
11/25115 00:09 7440-50-8
Lead
9.2 ug1L
5.0
1 11123115 20:30
11/25/15 00:09 7439-92-1
Zinc
44.3 ug1L
10.0
1 11f2311520:30
IM511500:09 7440.66-6
25400 Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
22.5 mg/L
3.8
1
11/20115 11:56
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/30/2015 02:20 PM without the written consent of Pace Analytical Services, Inc.. Page 3 of 17

Pace Analytical Services, Inc.
® 9800 KinceyAve. Suite
aceAnalytr"cal
Huntersville, NC 28078
www pacWabs.com [phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALE STORMWATER
Pace Project No,: 92276912
Sample: OU-002 Lab ID: 92276912002 Collected: 11/18/15 07:12 Received: 11/19/15 10:15 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 16648
Total Petroleum Hydrocarbons
ND mg1L
5.0
1
11/24/15 10:44
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation
Method: EPA 200.7
Copper
40.3 ug1L
5.0
1 11/23115 20:30
11/25/15 00:17 7440-50-8
Lead
ND ug/L
5.0
1 11/23/15 20:30
11/25/15 00:17 7439-92-1
Zinc
64.5 ug1L
10.0
1 11/23115 20:30
11/25/15 00:17 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
16.3 mg/L
7.1
1
11/20/15 11:56 D6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in lull,
Date: 11 /30/2015 02:20 PM without the written consent of Pace Analytical Services, Inc.. Page 4 of 17

Pace Analytical Services, Inc.
IacieAnalytical 0 seoo Kinsey Ave. Suite 100
Huntersville, NC 28078
www.pacstabs.com (704 )875-9092
ANALYTICAL RESULTS
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Sample: OU-004 Lab ID: 92276912003 Collected: 11/18/15 07:21 Received: 11/19/15 10:15 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 1664B
Total Petroleum Hydrocarbons
ND mg/L
5.0
1
11/24/15 10:45
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation
Method: EPA 200.7
Copper
142 ug/L
5.0
1 11/23/15 20:30
11 /25/15 00:21 7440-50-8
Lead
20.7 ug/L
5.0
1 11/2311520:30
11/2511500:21 7439-92-1
Zinc
220 ug/L
10.0
1 11/23/1520:30
11/25/1500:21 7440�6-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
30.8 mg/L
4.2
1
11/20/15 11:57
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/30/2015 02:20 PM without the written consent of Pace Analytical Services, Inc.. Page 5 of 17

(�55'c 6 A nalytical
wwwpacefebs.cw
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Sample: OU-006 Lab ID: 92276912004 Collected: 11/18/15 07:32 Received: 11/19/15 10:15 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 1664E
Total Petroleum Hydrocarbons
ND mg1L
5.0
1
11/24/15 10:45
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
67.4 ug/L
5.0
1 11/23115 20:30
11/25/15 00:24 7440-50-8
Lead
ND uglL
5.0
1 11/23/15 20:30
11/25/15 00:24 7439-92-1
Zinc
196 ug/L
10.0
1 11/23/15 20:30
11/25/15 00:24 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
ND mg/L
4.2
1
11/20/15 11:57
REPORT OF LABORATORY ANALYSIS
This reporl shall not be reproduced, except in full.
Date: 11/30/2015 0220 PM without the written consent of Pace Analytical Services, Inc.. Page 6 of 17

e
aceAnalyllcal
www.pacelabs.=n
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Nuntersville, NC 28078
[phone]
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Sample: ROAD RUN OFF-01 DC Lab ID: 92276912005 Collected: 11/18/15 08:10 Received: 11/19/15 10:15 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper 16.4 uglL 5.0 1 11 /23115 20:30 11/25/15 00:36 7440-50-8
Lead ND ug1L 5.0 1 11/23/15 20:30 1i125115 00:36 7439-92-1
Zinc 96.4 uglL 10.0 1 11/23/15 20:30 11/25/15 00:36 7440-66-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11 /30/2015 02:20 PM without the written consent of Pace Analytical Services, Inc..
Page 7 of 17

aceAnalytrcal
* wP4*a6s.=R
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersvitle, NC 28078
[phone]
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Sample: ROAD RUN OFF-02 DR LabID: 92276912006 Collected: 11118115 08:15 Received: 11/19/15 10:15 Matrix: Water
Parameters Results Units Report limit DF Prepared Analyzed CAS No. Qua[
200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper 71.0 ug1L 5.0 1 11/23/15 20:30 11/25/15 00:39 7440-50-8
Lead ND ug1L 5.0 1 11/23/15 20:30 11/25/15 00:39 7439-92-1
Zinc 69.8 ug1L 10.0 1 11123/15 20:30 11/25/15 00:39 7440-�56-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/30/2015 02:20 PM without the written consent of Pace Analytical Services, Inc.. Page 8 of 17

aceAnalytical 01
wwwpaC8h*5.=n
ANALYTICAL RESULTS
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Sample: ROOF DRAIN #1 DOCK
Lab ID: 92-276912007
Collected: 11/18115 08:25
Received: 11/19/15 10:15 Matrix: Water
Parameters
Results Units
Report Limit DF
Prepared
Analyzed
CAS No. Qual
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
9.9 ug/L
5.0 1
11/23/15 20:30
11/25/15 00:42
7440-50-8
Lead
ND ug1L
5.0 1
11/23/15 20:30
11/25/15 00:42
7439-92-1
Zinc
229 ug/L
10.0 1
11/23/15 20:30
11/25/15 00:42
744046-6
Date: 11/30/2015 02:20 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
I
Page 9 of 17

e
(�55'&e Ana lyticaI
~parelabs.c=
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Sample: ROOF DRAIN #2 EVAP Lab ID: 92276912008 Collected: 11/18/15 08:30 Received: 11/19/15 10:15 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper 107 ug/L 5.0 1 11/23/15 20:30 11/25/15 00:45 7440-50-8
Lead 47.6 ug/L 5.0 1 11/23/15 20:30 11/25/15 00:45 7439-92-1
Zinc 759 ug1L 10.0 1 11/23/15 20:30 11/25/15 00:45 7440-66-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/30/2015 02:20 PM without the written consent of Pace Analytical Services, Inc..
Page 10 of 17

lacieAnalyfical"
rww.pawabs.com
QUALITY CONTROL DATA
Project: WATTS SPINDALE STORMWATER
Pace Project No,: 92276912
QC Batch: GCSV123323 Analysis Method: EPA 1664E
QC Batch Method: EPA 1664B Analysis Description: 1664 SGT-HEM, TPH
Associated Lab Samples: 92276912001, 92276912002, 92276912003, 92276912004
METHOD BLANK: 1613786 Matrix: Water
Associated Lab Samples: 92276912001, 92276912002, 92276912003, 92276912004
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Total Petroleum Hydrocarbons mg1L ND 5.0 11/24/15 10:28
Pace Analytical Services, Inc.
9800KinceyAve. Suite100
Huntersville, NC 28078
[phone]
LABORATORY CONTROL SAMPLE:
1613787
Spike LCS
LCS
% Rec
Parameter
Units
Cone. Result
% Rec
Limits
Qualifiers
Total Petroleum Hydrocarbons
mg1L
20 15.5
78
64-132
MATRIX SPIKE SAMPLE:
1613788
92275825001 Spike
MS
MS
%Rec
Parameter
Units
Result Conc.
Result
% Rec
Limits Qualifiers
Total Petroleum Hydrocarbons
mg/L
ND 20
17.3
86
64-132
Results presented on this page are in the units indicated by the 'Units- column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/30/2015 02:20 PM without the written consent of Pace Analytical Services, Inc.. Page 11 of 17

e
aceAnalyflcal
wwwpacelabs.mn
QUALITY CONTROL DATA
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Pace Analytical Services, Inc.
9800 K'ncey Ave. Suite 100
Huntersville, NC 28078
[phone]
QC Batch: MPRPI20101
Analysis Method: EPA 200.7
QC Batch Method: EPA 200.7
Analysis Description: 200.7 MET
Associated Lab Samples: 92276912001, 92276912002,
92276912003, 92276912004, 92276912005, 92276912006, 92276912007,
92276912008
METHOD BLANK: 1613593
Matrix: Water
Associated Lab Samples: 92276912001, 92276912002,
92276912003, 92276912004, 92276912005, 92276912006, 92276912007,
92276912008
Blank Reporting
Parameter Units
Result Limit Analyzed Qualifiers
Copper ug/L
ND 5.0 11/25/15 00:02
Lead ug1L
ND 5.0 11/25/15 00:02
Zinc ug1L
ND 10.0 11/25/15 00:02
LABORATORY CONTROL SAMPLE:
1613594
Spike
LCS LCS % Roc
Parameter
Units
Cone.
Result % Rec Limits Qualifiers
Copper
ug1L
500
476 95 85-115
Lead
uglL
500
471 94 85-115
Zinc
uglL
500
478 96 85-115
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1613595
MS
92276912001 Spike
Parameter Units Result Conc.
Copper uglL 68.8 500
Lead uglL 9.2 500
Zinc uglL 44.3 500
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1613597
MS
92276695001 Spike
Parameter Units Result Cone.
Copper uglL ND 500
Lead uglL ND 500
Zinc uglL ND 500
1613596
MSD
Spike
MS
MSD
MS
MSD
% Rec
Cone.
Result
Result
% Rec
% Rec
Limits
RPD
500
537
530
94
92
70-130
1
500
468
464
92
91
70-130
1
500
509
504
93
92
70-130
1
1613596
MSD
Spike
MS
MSD
MS
MSD
% Rec
Cone.
Result
Result
% Rec
% Rec
Limits
RPD
500
498
495
98
97
70-130
1
500
407
409
81
81
70-130
0
500
479
, 471
91
89
70-130
2
Results presented on this page are In the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11 /30/2015 02:20 PM without the written consent of Pace Analytical Services, Inc..
Qual
Qual
Page 12 of 17

aceAnalyfical
www.pacalabs.com
QUALITY CONTROL DATA
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
QC Batch: WET141531 Analysis Method: SM 2540D
QC Batch Method: SM 2540D Analysis Description: 2540D Total Suspended Solids
Associated Lab Samples: 92276912001, 92276912002, 92276912003, 92276912004
METHOD BLANK: 1611897 Matrix: Water
Associated Lab Samples: 92276912001, 92276912002, 92276912003, 92276912004
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Total Suspended Solids mg1L ND 2.5 11/20/15 11:54
Pace Analytical Services, Inc,
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
LABORATORY CONTROL SAMPLE:
1611898
Spike LCS LCS
% Rec
Parameter
Units
Conc. Result % Rec
Limits Qualifiers
Total Suspended Solids
mg/L
250 228 91
90-110
SAMPLE DUPLICATE: 1611899
92276978001 Dup
Parameter
Units
Result Result RPD
Qualifiers
Total Suspended Solids
mg/L
164 176
7 D6
SAMPLE DUPLICATE: 1611900
92276912002 Dup
Parameter Units Result Result RPD Qualifiers
Total Suspended Solids mglL 16.3 21.7 29 D6
Results presented on this page are in the units Indicated by the "Units" column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11 /30/2015 02:20 PM without the written consent of Pace Analytical Services. Inc.. Page 13 of 17

aceAnalytical
wwrv.pacelabs.own
QUALIFIERS
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
DEFINITIONS
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MOL -Adjusted Method Detection Limit.
PQL - Practical Quantitation Limit.
RL -Reporting Limit.
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
S - Surrogate
1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate) '
MS(D) - Matrix Spike (Duplicate)
OUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected. .
Acid preservation may not be appropriate for 2 Chloroethylvinyl ether, Styrene, and Vinyl chloride.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis of Acrolein and Acrylonitrile by EPA
Method 8200.
N-Nitrosod iphenyla mine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI -The NELAC Institute.
ANALYTE QUALIFIERS
D6 The relative percent difference (RPD) between the sample and sample duplicate exceeded laboratory control limits.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/30/2015 02:20 PM without the written consent of Pace Analytical Services, Inc.. Page 14 of 17

aceAnalytrcal
www pacalabs.com
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project: WATTS SPINDALE STORMWATER
Pace Project No.: 92276912
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
Lab ID Sample ID CIC Batch Method OC Batch Analytical Method
92276912001
OU-001
EPA 16648
GCSV123323
92276912002
OU-002
EPA 1664B
GCSV123323
92276912003
OU-004
EPA 16648
GCSV123323
92276912004
OU-006
EPA 1664E
GCSV123323
92276912001
OU-001
EPA 200.7
MPRP120101
EPA 200.7
92276912002
OU-002
EPA 200.7
MPRP120101
EPA 200.7
92276912003
OU-004
EPA 200.7
MPRP120101
EPA 200.7
92276912004
OU-006
EPA 200.7
MPRP120101
EPA 200.7
92276912005
ROAD RUN OFF-01 DC
EPA 200.7
MPRP120101
EPA 200.7
92276912006
ROAD RUN OFF-02 DR
EPA 200.7
MPRP120101
EPA 200.7
92276912007
ROOF DRAIN #1DOCK
EPA 200.7
MPRP120101
EPA 200.7
92276912008
ROOF DRAIN 92 EVAP
EPA 200.7
MPRP120101
EPA 200.7
92276912001
OU-001
SM 2540D
WET14153i
92276912002
OU-002
SM 2540D
WET141531
92276912003
OU-004
SM 2540D
WET141531
92276912004
OU-006
SM 2540D
WET141531
Date: 11/30/2015 02:20 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Analytical
Batch
ICP118128
ICP118128
ICP118128
ICP118128
ICP118128
ICP118128
ICP118128
ICP118128
Page 15 of 17

Document Name:
Document Revised: November 17, 2015
ZAnalytical-
Sam le Condition U on Recei t SCUR
Pa e 1 of 2"
Document Number:
Issuing Authority:
F-CHR-CS-003-rev.16.1
Pace Huntersville Quality Office
Client Name. ';z n i� { uJu I Q L d r 5 ` Page 2 of 2 Is for Internal Use Only
Courier: ❑ Fed Er❑ UP USP❑ Cher❑ CommerciO Pace Other O tlon2l - = `:
Custody Seal on CoolerlBox Present: ❑ yes ❑ no Seals Intact: 0 yes ❑ no
Prg1 pue Date ' :;
t
Packing Material: ❑ Bubble Wrap ❑ Bubble Bags,2] None ❑ Other
Thermometer Used: IR Gun T1505 Type of Ice: We / Blue None Samples en ice, cooling process has begun
Temp Correction Factor No Correction
Corrected Cooler Temp.:]. • C
biological Tissue is Frozen: Yes NoA�
Oate and Initials of person examining
l/
contents: i 1
J-
Temp should be above freezing to 6°C
Comments:
Chain of Custody Present:
C3 rS ONO
❑NIA
1,
Chain of Custody Filled Out:
i;1Ys ❑No
❑NIA
2•
Chain of Custody Relinquished:
j2r5 vs ON,
❑N1A
3.
Sampler Name & Signature on COC:
OYes ©No
❑NIA
4.
Samples Arrived within Hold Time:
X1Yes ©No
❑NIA
5.
Short Hold Time Analysis <72hr :
❑Yes
❑NIA
6.-
Rush Turn Around Time Requested:
.�fp3No
Dyes No
❑NIA
7.
Sufficient Volume:
❑Ye'�s El No
❑NIA
8.
Correct.Containers Used:
0-Yes ONO
❑NIA
9.
-Pace Containers Used:
lJ Yes ONO
❑NIA
Containers Intact:
❑Y ONO
❑NIA
10.
Filtered volume received for Dissolved tests
tf s ONO
❑NIA
11.
Sample Labels match COC:
'Eves [:]No
❑NIA
12.
r
-Includes dateltime/lD/Ana1 sis Matrix:
W
All contalners needing preservation have been checked.
pYes ONO
❑NIA
13.
All containers needing preservation are found to be in
❑ ONO
❑N1A
compliance with EPA recommendation.
exceptions: VOA, co[iform, TOC, O&G, WI•DRO (water)
❑Yes O No
Samples checked for dechlorination:
g es ONO
❑NIA
14,
Heads ace In VOA Vials (>bmm :
❑Yes ONO
❑NIA
16.
Trip Blank; Present:
❑Yes ONO
FJN1A
16.
Trip Blank
❑Yes
Custody Seals Present
ONO
©NIA
Pace Trip Blank Lot # (if purchased):
Client notification/ Resolution: Field Data Required? Y 1 N
Person Contacted: Date/Time:
Comments/ Resolution:
SCURF Review: WMDate: I_[(-�25 I
SRF Review: IDate: 1l�ZI
Note: Whenever there Is a discrepancy affecting North Carolina compliance
samples, a copy of this form will be sent to the North Carolina DEHNR
Certification Office (i.e out of hold, Incorrect preservative, out of temp,
Incorrect containers)
WOB :J2276912

;P i CHAIN -OF -CUSTODY 1 Analytical Request Document
r The Chain-of-Cuslody is a LEGAL DOCUMENT. All relevant fields must be completer) accurately_
Section A Section B Section C
�i�r "_
Required Client information_ Required Project Information: tnvoice Informalion: fYl[1Y'�G . �!!ri Y1 u1Y(v [..� ,'..[-�/ J Page: 1 Of 1
Company: Watts Waler Technologies Repon To Mark Kennard Atlemon'. nlnlhe_
Address, 100 Welts Rd Coory To Company Namo:t.1A 1.1h A}O ir`S
Spindale, NC 28160
Addhoss: Jop &jA=
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Email: y^ya W
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Phone: 6_8-tjLff 3CPLY IPSK
Project Name: Slarmwetrr eti}t} u (x%
Pace Project Managor. nicale. asiorowski@,pacelabs cam,
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XVIWATM
/ ff } 1,-5,
A Watts Wafer Technologies Company 815 Chestnut Sueet • north Andover, MA • 01845-6098 • Tel. [phone] • Fax: [phone]
November 24, 2015
BY CERTIFIED MAIL — RETURN RECEIPT REQUESTED RECEIVED
Central Records DEC 0 1 2015
Division of Energy, Mineral and Land Resources CENTRAL FILES
1617 Mail Service Center ©WR SECTION
Raleigh, NC 27699-1617
Re: Discharge Monitoring Report and Notice of Compliance Status
Watts Regulator, 100 Watts Road, Spindale, North Carolir6f 4
Certificate of Coverage Number NCG030251
Z e
To Whom It May Concern:
In accordance with certificate of coverage referenced above and requirements of general permit
number NCG030000 ("General Permit"), please find enclosed discharge monitoring report ("DMR") for
monitoring year 3, period 2, monthly monitoring (October 2015) regarding Watts Regulator ("Watts")
facility at 100 Watts Road in Spindale, North Carolina ("Facility"). Due to the number of consecutive
precipitation events at the Facility during October 2015, Watts was unable to obtain a sample during a
measurable storm event that was preceded by at least 72 hours without precipitation and, consequently,
the DMR indicates "No Flow" for the October 2015 monitoring period.
Nonetheless, in order to continue evaluating the additional best management practices ("BMP")
utilized at the Facility and to determine the cause of the recent zinc and copper benchmark exceedences,
on October 27, 2015, the Facility sampled outfalls 001, 002, 004 and 006 as well as four background
locations.[ A letter report describing the results of that effort from the consulting firm Hart & Hickman is
enclosed. In summary, the data indicate that copper and zinc present in storm water discharge from the
Facility likely originates from "non -industrial" sources — either the Facility's roof (which is not exposed
to industrial operations) or roadway adjacent to the Facility's storm water outfalls. The data also suggest
that the Facility's additional BMPs will resolve the recent exceedences of the lead benchmark.
As mentioned in my previous correspondence, I respectfully request to schedule a meeting with
representatives of the Division of Energy, Mineral and Land Resources to discuss the results of a storm
water compliance audit performed by AECOM and Watts' efforts to implement additional BMPs at the
Facility. Please contact me at your earliest convenience at [phone] to arrange a date and time.
Sincerely,
/� 61
Howard H. Chu
Director, Environment, Health and Safety
Watts Water Technologies, Inc.
Enclosures
cc: Central Records, Division of Water Quality
1 Consistent with the February 3, 2010 Approval of Representative Outfall Status, the Facility did not sample
outfalls 003, 005 or 007.
Watts Regulator Company Since 1874 watts.com

hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
Via Email
November 24, 2015
Watts Water Technologies
100 Watts Road
Spindale, NC 28160
Attn: Mr. Mark Kennard
Re: Stormwater Background Sampling
Watts Water Technologies
Spindale, NC
H&H Proiect No. WWT-004
Dear Mark:
Per your request, Hart & Hickman, PC (H&H) is providing this letter to summarize the results of
stormwater background sampling at the Watts Water Technologies (Watts) facility in Spindale,
NC. Consistent with the February 3, 2010 Approval of Representative Outfall Status, Watts
obtains quantitative data for samples from outfalls 001, 002, 004 and 006. Upon receiving the
results of the July 2015 sampling, Watts engaged Hart & Hickman ("H&H") to evaluate the
stormwater metal detections and to improve stormwater management for the facility. H&H
recommended three key action items which included placement of stormwater filter socks, addition
of limestone riprap in high flow areas, and improvement in the grass coverage density for soil
surface stabilization. Watts implemented these recommendations, and stormwater metal
concentrations significantly decreased based on the September 2015 monthly sampling event.
The lead concentrations detected in the outfall samples in September 2015 were below the
benchmark value. However, based on the low benchmark values for copper and zinc, these metal
concentrations continue to exceed benchmark values as reported in the September 2015
DMR. Outfalls 001, 002, 004, and 006 are in Tier III status for copper and/or zinc. Monthly
2923 South Tryon Street, Suite 100 3334 Hillsborough Street
Charlotte, NC 28203 Raleigh, NC 27607 www.harthickman.com
704.586.0007 main 919,847.4241 main

Mr. Mark Kennard
November 24, 2015
Page 2
monitoring data continues to be used to evaluate the effectiveness of stormwater improvements
and the need for further improvements.
Because stormwater metal concentrations have been reduced to low levels with only copper and
zinc exceeding benchmarks, H&H suspected that background sources of copper and zinc may be
contributing to the detections at the stormwater outfalls. Two background sources were
investigated by sampling conducted by Watts in October 2015: I. roadside stormwater runoff
from Watts Road because stormwater outfalls receive such water and 2. roof drain runoff from
the warehouse building. It is noted that the roof has metal decking and a whitish coating. The
roof surface is generally clean and in good condition.
In that Watts is proactively addressing the stormwater metals concern, background and stormwater
discharge outfall samples were collected on October 27, 2015, although the prior rainfall resulted
in sampling under conditions that were not ideal. Approximately 0.2 inches of rain fell on the two
days prior to the stormwater sample collection based on precipitation data at a nearby reporting
station (Rutherfordton 2.6 WSW). Even though this rain event was not considered to be a
qualifying event for completing a monthly DMR, H&H considers these data to be relevant to
evaluating the stormwater conditions at this site.
H&H has summarized the stormwater sample background and outfall data collected on October
27, 2015 in Table 1, and laboratory reports are also attached. Relatively high levels of copper (up
to 0.438 mg/1), lead (up to 0.0524 mg/I), and zinc (up to 1.89 mg/1) were detected in both the road
runoff and roof background samples. Detected metal concentrations in the background samples
exceed the benchmark values. To compare the background data to the outfall results in a broad
sense, H&H calculated average values for the four outfalls and average values for the four
background samples. On average, the background concentrations for each metal significantly
exceed the outfall metal concentrations. H&H understands that a second round of background and
outfall metals data were collected in November, These data will be useful to confirm the October
results.
Ad
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
S WAA-Master ProltmMatts Water Technolopp - % W RWA'T-004 Quarterly Spindale NOWalts Slvml Ater Backgsound.cl c

Mr. Mark Kennard
November 24, 2015
Page 3
We appreciate the opportunity to assist with this project. Should you have any questions or need
any additional information, please feel free to contact me.
Sincerely,
Hart & Hickman, PC
Matt Brarnblett, PE
Principal Engineer
Attachment
Cc: Mr. Howard Chu, Watts (via email)
Mr. Sean Sullivan, TS (via email)
Id
hart hickman
SMARTER ENVIRONMENTAL SOLLMONS
SIAAA-NI=cr Projecs\Watss Wale Technologes - R'WTRu'W7-no4 Quarterly Spindale NC%Wans Szormuater 8achground_doe.

Table 1
Background Stormwater Data
Watts Water Technologies
Spindale, NC
H&H Job No. WWT-004
Background
Road Run
Road Run
Roof Drain
Roof Drain
Outfall
Average
Sample Location
Off-01 DC
Off-02 DR
#1 Dock
#2 Evap
OU-001
OU 002
OU-DD4
OU-006
Average
Various
NPDES
Sources
Permit
Benchmark
Date
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
Units
mg1L
mg/L
mg1L
mg1L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Metals (200.7)
Copper
0.0081
0,438
0.012
0.205
0.0722
0.0059
0.055
0,0378
0.043
0.166
0.007
Lead
<0.005
0.0524
<0.005
0.0512
0.0074
<0.005
<0.005
<0.005
0.004
0.028
0.030
Zinc
0.0469
0,178
0.338
1.89
0.0734
0.0287
0.196
0.117
0.104
0.613
0.067
Note:
Data collected after two days with approArnately 0.2 inches of rain per day
Non -detects averaged at 112 of the reporting limit
Bold and Italics indicate exceed benchmark
Table 2 (Page 1 of 1)
F31e. SUM�Wcta PmrecwWaln Weer Te[Mokgies-WaN11tM1HJf-ooa O�e�ronv `�^�� NC{BeckpvwE5W r{a Sc�
D*010MIS hurt & Hickman, PC

aceAnalytical e
www.pacalabs.com
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 2807E
[phone]
November 09, 2015
Mark Kennard
Watts Water Technologies
815 Pickens Street
Chesnee, SC 29323
RE: Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Dear Mark Kennard:
Enclosed are the analytical results for sample(s) received by the laboratory on October 28, 2015.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Nicole Gasiorowski
[e-mail]
Project Manager
Enclosures
�i Nkc
TNI
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 13

m
aceAnalytical
wwwp000kbs.com
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
(704) 87 5-9092
Project: WATTS SPINDALE SW
Pace Project No: 92273668
Charlotte Certification IDs
9800 KinceyAve, Ste 100, Huntersville, NC 28078
North Carolina Drinking Water Certification #: 37706
North Carolina Field Services Certification #: 5342
North Carolina Wastewater Certification #: 12
South Carolina Certification #: 99006001
Asheville Certification IDs
2225 Riverside Drive, Asheville, NC 28804
Florida/NELAP Certification #: E87648
Massachusetts Certification #: M-NCO30
North Carolina Drinking Water Certification #: 37712
CERTIFICATIONS
Florida/NELAP Certification #: E87627
Kentucky UST Certification #: 84
West Virginia Certification #: 357
Virginia/VELAP Certification #: 460221
North Carolina Wastewater Certification #: 40
South Carolina Certification #: 99030001
West Virginia Certification #: 356
VirginiafVELAP Certification #: 460222
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 2 of 13

�IaceAnalytical'-
( rwrw.pacelaba aom
I
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9B00 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Sample: OU-001 Lab ID: 92273668001 Collected: 10/27/15 09:25 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Total Petroleum Hydrocarbons
200.7 MET ICP
Copper
Lead
Zinc
2540D Total Suspended Solids
Total Suspended Solids
U
Date: 11/09/2015 04:34 PM
Analytical Method: EPA 1664B
ND mg/L
5.0 1
11/04/15 08:33
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
72.2 ug/L
5.0 1 10/29/15 20:00
11/02/15 19:52 7440-50-8
7.4 ug1L
5.0 1 10/29/15 20:00
11/02/15 19:52 7439-92-1
73.4 ug/L
10.0 1 10129115 20'00
11103/15 22:01 7440-66-6
Analytical Method: SM 2540D
66.1 mg/L
2.6 1
101291151012
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 3 of 13

aceAnalytical
www.pmwbs.com
Pace Analytical Services, Inc.
9600 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Sample: OU-002 Lab ID: 92273668002 Collected: 10/27115 09:35 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 16648
Total Petroleum Hydrocarbons
ND mg/L
5.0
1
11/04/15 08:33
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
5.9 ug/L
5.0
1 10/29/15 20:00
11/02/15 19:55 7440-50-8
Lead
ND ug/L
5.0
1 10/29/15 20:00
11/02/15 19:55 7439-92-1
Zinc
28.7 ug/L
10.0
1 10/29/15 20:00
11103/15 22:04 7440-6S-6
2640D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
ND mg/L
3.1
1
10f29/15 10:13
REPORT OF LABORATORY ANALYSIS
This report $hail not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written Consent of Pace Analytical Services, Inc..
Page 4 of 13

aceAnalyiical
cmw.Pw&6soom
Pace Analylical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Sample. Ott-004 Lab ID: 92273668003 Collected: 10/27/15 09:45 Received: 10128/15 11:30 Matrix: Water
Parameters Results Units Report Limit OF Prepared Analyzed CAS No. Qual
1664 5GT-HEM, TPH
Analytical Method: EPA 1664B
Total Petroleum Hydrocarbons
NO mg/L
5.0 1
11/041150&34
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation
Method: EPA 200.7
Copper
55.0 uglL
5.0 1 10129/1520-00
11/0211519:58 7440-50-8
Lead
N❑ ug1L
5.0 1 10/29/15 20:00
11/02/15 19:58 7439.92-1
Zinc
196 ug1L
10.0 1 10/29/15 20:00
11/03/15 22:16 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
4A mg/L
2.9 1
10/29/15 10:13
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc..
Page 5 of 13

aceAnalytical "
www.pacWabs.com
Pace Analytical Services, Inc.
9B00 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Sample: QU-006 Lab ID: 92273668004 Collected: 10/27/15 09:55 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 1664E
Total Petroleum Hydrocarbons
ND mg/L
5.0
1
11 /04/15 08:34
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
37.8 ugIL
5.0
1 10/29/15 20:00
11/02/15 20:01 7440-50-8
Lead
ND ug1L
5.0
1 10/29/15 20:00
11/02/15 20:01 7439-92-1
Zinc
117 ugIL
10.0
1 10/29/15 20:00
11/03/15 22:19 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
3.5 mg/L
3.1
1
10/29/15 10:13
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 1110912015 04:34 PM without the written consent of Pace Analytical Services. Inc.. Page 6 of 13

aceAnalytical •
www.pecelabs.com
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 25078
[phone]
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
QC Batch: GCSV123097 Analysis Method: EPA 1664E
QC Batch Method: EPA 1664B Analysis Description: 1664 SGT-HEM, TPH
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
METHOD BLANK: 1598176 Matrix: Water
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Total Petroleum Hydrocarbons mg/L ND 5.0 11/04/15 08:22
LABORATORY CONTROL SAMPLE: 1598177
Spike LCS LCS % Rec
Parameter Units Conc. Result % Rec Limits Qualifiers
Total Petroleum Hydrocarbons mg1L 20 14.5 72 64-132
MATRIX SPIKE SAMPLE: 1598178
92273784002 Spike MS MS % Rec
Parameter Units Result Conc. Result % Rec Limits Qualifiers
Total Petroleum Hydrocarbons mg/L ND 20 16A 80 64-132
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 7 of 13

aoAnalytical
www.pawabs.aom
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pare Project No.: 92273668
QC Batch: MPRP/19925 Analysis Method: EPA 200.7
QC Batch Method: EPA200.7 Analysis Description: 200.7 MET
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
METHOD BLANK: 1595294 Matrix: Water
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
Blank Reporting
Parameter Units Result Limit Analyzed
Copper uglL ND 5.0 11/0511516:28
Lead ug/L ND 5.0 1110511516:28
Zinc ug1L ND 10.0 11105/1516:28
Qualifiers
LABORATORY CONTROL SAMPLE:
1595295
Spike
LCS LCS % Rec
Parameter
Units
Cone.
Result % Rec Limits Qualifiers
Copper
ug1L
500
504 101 85-115
Lead
ug/L
500
493 99 85-115
Zinc
ug1L
500
485 97 85-115
MATRIX SPIKE & MATRIX SPIKE DUPLICATE:
1595298
1595299
MS
MSD
92273665001
Spike
Spike
MS
MSD
MS
MSD
% Rec
Parameter Units
Result
Cone.
Conc,
Result
Result
% Rec
% Rec
Limits
RPD Qual
Copper ug1L
8.1
500
500
480
470
94
92
70-130
2
Lead ug/L
ND
500
500
475
473
94
94
70-130
0
Zinc ug1L
46.9
500
500
495
486
90
88
70-130
2
Results presented on this page are In the units indicated by the "units' column except where an alternate unit Is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 8 of 13

aceAnalytical
www.pacelabs.mm
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
QC Batch: WET141108 Analysis Method: SM 2540D
QC Batch Method: SM 2540D Analysis Description: 2540D Total Suspended Solids
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
METHOD BLANK: 1594264 Matrix: Water
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Total Suspended Solids mg1L ND 2.5 10/29/15 10:09
LABORATORY CONTROL SAMPLE: 1594265
Spike LCS LCS % Rec
Parameter Units Conc. Result % Rec Limits Qualifiers
Total Suspended Solids mg1L 250 250 100 90-110
SAMPLE DUPLICATE: 1594266
92273613003 Dup
Parameter Units Result Result RPD Qualifiers
Total Suspended Solids mg/L 31.0 33.0 6 D6
SAMPLE DUPLICATE: 1594267
92273669003 Dup
Parameter Units Result Result RPD Qualifiers
Total Suspended Solids mg1L ND ND
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc- Page 9 of 13

(�IaceAnalytical
www.pacekiUcom
QUALIFIERS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
DEFINITIONS
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL -Adjusted Method Detection Limit.
POL - Practical Quantitation Limit.
RL - Reporting Limit.
S - Surrogate
1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
Acid preservation may not be appropriate for 2 Chloroethylvinyl ether, Styrene, and Vinyl chloride.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis ofAcrolein and Acrylonitrile by EPA
Method 8260.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI - The NELAC Institute.
ANALYTE QUALIFIERS
D6 The relative percent difference (RPD) between the sample and sample duplicate exceeded laboratory control limits.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 10 of 13

aceAnalyticalo
wwwpacelabs.cam
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersvilie, NC 28078
[phone]
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project:
Pace Project No.:
WATTS SPINDALE SW
92273668
Analytical
Lab ID
Sample ID
QC Batch Method
QC Batch
Analytical Method
Batch
92273668001
OU-001
EPA 1664B
GCSVI23097
92273668002
OU-002
EPA 16648
GCSV123097
92273668003
OU-004
EPA 1664E
GCSVJ23097
92273668004
OU-006
EPA 1664E
GCSV123097
92273668001
OU-001
EPA 200.7
MPRP119925
EPA 2003
1CPl17967
92273668002
OU-002
EPA 200.7
MPRP/19925
EPA 200.7
ICP117967
92273668003
OU-004
EPA 200.7
MPRP119925
EPA 2003
ICPl17967
92273668004
OU-006
EPA 200.7
MPRP/19925
EPA 200.7
ICP117967
92273668001
QU-001
SM 2540D
WET141108
92273668002
OU-002
SM 2540D
WET141108
92273668003
OU-004
SM 2540D
WET141108
92273668004
OU-006
SM 2540D
WET141108
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11I0912015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 11 of 13

, ceklalytrcal- Sample Condition Upon Receipt (SCUR) Page 1 of 2"
Document Number: issuing Authority:
F-CHR-CS-003-rev.16 Pace Huntersville Quality Office
Client Name: v/ 6+44 (,,r,,
Page 2 of 2 is for Internal Use Only
Courier: ❑ Fed E0---U'Po U5P❑ ClierD CommerciEl Pace Other
Custody Seal on Cooler/Box Present: ❑�ubbfee
❑ /-� ❑ y ❑ Proj=t,DueDake:-4Y+1:
no Seals intact: es no
Packing Material: ❑ Bubble Wrap ❑ Bags ❑ None ❑ Other
Thermometer Used: IR Gun T 4©2 Type of Ice:ce)t
Blue None amples on ice, cooling process has begun
Tema Correction Factor T14 No Correction
Corrected Cooler Temp.: 'C
Biological Tissue is Frozen: Yes No IA
9
Date and Initials of person examining
contents: r� �!1'�'•�S
Temp should be above freezing to M
Comments:
Chain of Custody Present:
E<s PNo
❑NIA
1.
Chain of Custody Filled Out:
es No
❑NIA
2.
Chain of Custody Relinquished:
es o
❑NIA
3.
Sampler Name & Signature on COC:
es gNo
❑NIA
4,
Samples Arrived within Hold Time:
gles ❑No
NIA
5.
Short Hold Time Analysis (<72hr):
Dyes 2<1
gMA
g.
Rush Turn Around Time Requested:
Dyes
❑NIA
7,
Sufficient Volume:
0<11S'pw
❑NIA
g,
Correct Containers Used:
©Yes P1t�❑NIA
9.
-Pace Containers Used:
11 es COIN
❑NIA
Containers Intact:
0-yeUNo
❑NtA
io.
Filtered volume received for Dissolved tests
Dyes ❑L
ONK
11.
Sample Labels match COC:
es ❑No
❑NIA
12.
-Includes dateltime/ID/Analysis Matrix:
All containers needing preservation have been checked.
D es ONo
❑NIA
13.
All containers needing preservation are found to be in
es ON,
❑N!A
compliance with EPA recommendation.
��
exceptions: VOA, coliform, TOG, O&G, WI-DRO (water)
� se/D—N
--1
Samples checked for dechlorination:
Dyes ❑No
DNI
14.
Headspace in VOA Vials ( >6mm):
❑Yes ❑No
0 A
1 S.
Trip Blank Present:
Oyes ©No
nNIA
i6
Trip Blank Custody Seals Present
❑Yes ©No
Pace Trip Blank Lot # if purchased):_
Client Notification! Resolution:
Person Contacted:
Comments! Resolution:
Date/Time:
SCURF Review: IV IN L-1 I Date: I JV-
SRF Review: M 0ate:
Note: Whenever there is a discrepancy affecting North Carolina compliance
samples, a copy of this form will be sent to the North Carolina DEHNR
Certification Office ( Le out of hold, incorrect preservative, out of temp,
incorrect containers)
Field Data Required?
Place label here
Y / N
W0#:92273668
1111110 1111111
92273668
Page 12 of 13

CHAIN -OF -CUSTODY 1 Analytical Request Document
r'' �•�- The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Section A Section B Section C
Required Client Information: Required Project Information: Invoice Infermatiow Pago ; 1 Of 1
Company; watts water Technotopies Report To: 4,.� R N.vs; Attontion: PAa KeV-)U4P_b
Addrass: too watts Rd Copy To: S1R9j(% C�"t'�ny ►' FlA �,[L. JVDL..i,G/
"Male. NC 28160
41Ail!M. Uf C1 . GG
Adclress: %Do W,, />✓ c_ Z 6
""-r �'-Elt;'C =ram. utato ru:
Email', t MA (/,+V � Q (Q/
pwthasa Order A:
Pace Quote:
Pfrono: Zg. y Fen
Project Name: S star W4 V W Le 5
Pace Project Manager." hit0I& asiorDWski ,paceiabs.com,
Slate l Location •.; :� =" �`r;"W
Requested Due Dale: .5
Project K:
Pace Profilo #: 7136 -
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ace Analytical
www.pacelab&com
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
November 10, 2015
Mark Kennard
Watts Water Technologies
815 Pickens Street
Chesnee, SC 29323
RE: Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Dear Mark Kennard:
Enclosed are the analytical results for sample(s) received by the laboratory on October 28, 2015.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Nicole Gasiorowski
[e-mail]
Project Manager
Enclosures
pCCRFO
TNI
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in Full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 11

,�aceAnalyfical
www.pacelabs.com
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Asheville Certification IDS
2225 Riverside Drive, Asheville, NC 28804
Florida/NELAP Certification #: E87648
Massachusetts Certification #: M-NC030
North Carolina Drinking Water Certification #: 37712
CERTIFICATIONS
North Carolina Wastewater Certification #: 40
South Carolina Certification #: 99030001
West Virginia Certification #: 356
VirginiaNELAP Certification #: 460222
REPORT OF LABORATORY ANALYSIS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
This reporl shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 2 of 11

aceAnalytical "
www.pamlabs.com
Pace Analytical Services, Inc.
9800 Khcey Ave. Suite 100
Huntersville, NC 28078
[phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Sample: ROAD RUN OFF-01 DC Lab ID: 92273665001 Collected: 10/27/15 10:25 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper 8.1 ug/L 5.0 1 10/29/15 20:00 11/02/15 19:24 7440-50-8
Lead ND ug/L 5.0 1 10/29/15 20:00 11/02/15 19:24 7439-92-1
Zinc 46.9 ug/L 10.0 1 10/29/15 20:00 11/03/15 21:43 7440-66-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc..
Page 3 of t i

aceAnalytical
www.peratabs.com
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 26078
[phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Sample: ROAD RUN OFF-02 DR
Lab ID: 92273665002
Collected: 10127/15 10:30
Received: 10/28/15 11:30 Matrix: Water
Parameters
Results Units
Report Limit DF
Prepared
Analyzed
CAS No. Qual
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
438 ug/L
5.0 1
10/29/15 20:00
11/02/15 19:42
7440-50-8
Lead
52.4 ug1L
5.0 1
10/29/15 20:00
11/02/15 19:42
7439-92-1
Zinc
178 ug1L
10.0 1
10/29/15 20:00
11/03/15 21:51
7440-66-6
Date: 11/10/2015 10:54 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 4 of 11

e
,��aceAnalytical
www Wcaiabscnm
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Sample: ROOF DRAIN #1 DOCK
Lab ID: 92273665003
Collected: 10/27/15 10:05
Received: 10/28/15 11:30 Matrix: Water
Parameters
Results Units
Report Limit DF
Prepared
Analyzed
CAS No. Qual
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
12.0 ug1L
5.0 1
10/29/15 20:00
11/02/15 19:46
7440-50-8
Lead
ND ug1L
5.0 1
10/29/15 20:00
11/02/15 19:46
7439-92-1
Zinc
338 ug1L
10.0 1
10/29/15 20:00
11/03/15 21:54
7440-66-6
REPORT OF LABORATORY ANALYSIS
This report Shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc..
Page 5 of 11

,�axAnalytical"
www.pacelabs.com
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Sample: ROOF DRAIN #2 EVAP Lab ID: 92273665004 Collected: 10/27/15 10:10 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No, Qual
200.7 MET 1CP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper 205 ug/L 5-0 1 10/29/15 20:00 11/02/15 19:49 7440-50-8
Lead 51.2 ug/L 5.0 1 10/29/15 20:00 11/02/15 19:49 7439-92-1
Zinc 1890 uglL 10.0 1 10/29/15 20:00 11/03/15 21:57 7440-66-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc..
Page 6 of 11

aceAnalytical'
www.pacelaAaoom
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
QC Batch: MPRP119925
Analysis Method: EPA 200.7
QC Batch Method: EPA 200.7
Analysis Description: 200.7 MET
Associated Lab Samples: 92273665001, 92273665002,
92273665003, 92273665004
METHOD BLANK: 1595294
Matrix: Water
Associated Lab Samples: 92273665001, 92273665002,
92273665003, 92273665004
Blank Reporting
Parameter
Units
Result Limit
Analyzed Qualifiers
Copper
ug1L
NO 5.0
11/0511516:28
Lead
ug1L
ND 5.0
11/0511516:28
Zinc
ug1L
NO 10.0
1110511516:28
LABORATORY CONTROL SAMPLE:
1595295
Spike LCS
LCS % Rec
Parameter
Units
Conc. Result
% Rec Limits Qualifiers
Copper
uglL
500 504
101 85-115
Lead
ug1L
500 493
99 85-115
Zinc
ug1L
500 485
97 85-115
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1595298 1595299
MS MSD
92273665001
Spike Spike MS
MSD MS MSD
% Rec
Parameter
Units Result
Conc. Conc. Result
Result % Rec % Rec
Limits RPD Qual
Copper
ug1L 8.1
500 500 480
470 94 92
70-130 2
Lead
uglL NO
500 500 475
473 94 94
70-130 0
Zinc
ug1L 46.9
500 500 495
486 90 88
70-130 2
Results presented on this page are in the units indicated by the "Units' column except where an alternate unit is presented to the right of the result
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc.. Page 7 of 11

aceAnalyfrcal
www.pecafabs.com
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Nuntersville, NC 28078
[phone]
QUALIFIERS
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
I93=Idla11111[$]Z&I
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL -Adjusted Method Detection Limit.
PQL - Practical Quantitation Limit.
RL - Reporting Limit.
S - Surrogate
1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
Acid preservation may not be appropriate for 2 Chloroethylvinyl ether, Styrene, and Vinyl chloride.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis of Acrolein and Acrylonitrile by EPA
Method 8260. .
N-Nitrosodiphenyla mine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI -The NELAC Institute.
WORKORDER QUALIFIERS
WO: 92273665
[1] Report revised to remove full analyte list from sample -001. Only Cu, Pb, Zn were requested. Samples -002 through -OD4
had correct list.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc.. Page 8 of 11

aceAnalytical
wwwpnwabs.com
Pace Analytical Services, Inc-
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Analytical
Lab ID
Sample ID
OC Batch Method
QC Batch
Analytical Method
Batch
92273665001
ROAD RUN OFF-01 DC
EPA 2001
MPRPl19925
EPA 200.7
ICP117967
92273665002
ROAD RUN OFF-02 DR
EPA 200.7
MPRP/19925
EPA 200.7
ICP117967
92273665003
ROOF DRAIN #1 DOCK
EPA 200.7
MPRP119925
EPA 2007
ICP117967
92273665004
ROOF DRAIN #2 EVAP
EPA 2001
MPRP119925
EPA 200.7
ICP117967
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc.. Page 9 of 11

.�ceArk?iyt'icaf-
Sample Condition Upon Receil
Document Number:
F-CHR-CS-003-rev.16
1 of 2"
Issuing Authority:
Pace Huntersville Quality Office
Client Name._ met �h 4-5 L�-4r ). 4f • Page 2 of 2 is for Internal Use Only
Courier: [] Fed E)o UPET USP[] Clier❑ CommerciQ Pace Other 0" tioiiai��- w =
Custody Sea[ on Cooler/Box Present: ❑ yes ❑ no ❑ ❑ PrOj :Dire"=Datev
Seals intact: yes no _ zY;s
Packing Material: ❑ Bubble Wrap ❑ Bubble Bags None ❑ Other
Thermometer Used: IR Gun T 402 ' Type of Ice: Eet Blue None amples on Ice; cooling process has begun
Temp Correction Factor T1402 No Correction
Corrected Cooler Temp.: 'C
Biological Tissue is Frozen: Yes No
g
Date and Initials of person examinI
contents:('
Temp should be above freezing to 60C
Comments:
Chain of Custody Present:
es
❑NIA
1.
Chain of Custody Filled Out:
❑ es ❑
❑N/A
2.
Chain of Custody Relinquished:
❑ es ❑No
❑NIA
3.
Sampler Name $ Signature on COC:
es ❑No
❑N!A
4.
Samples Arrived within Hold Time:
Dyes ❑No
❑NIA
5.
Short Hold Time Analysis (<72hr):
Dyes
IA
6.
Rush Turn Around Time Requested:
Dyes
❑NIA
7.
Sufficient Volume:
❑ es PWo
❑NIA
8.
Correct Containers Used:
es No
❑NIA
9.
-Pace Containers Used:
es No
❑NIA
Containers intact:
ErYLs ❑No
❑MIA
t0.
Filtered volume received for Dissolved tests
❑Yes ❑No
❑ OA
11.
Sample Labels match COC:
es ❑Na
❑NrA
12.
-includes dateltime/lDlAnalysis Matrix: f i✓K
All containers needing preservation have been checked.
es �
❑NIA
13.
All containers needing preservation are found to be in
Yes D
❑NIA
compliance with EPA recommendation.
exceptions: VOA, cofiform, TOG, 06G, WI-oRO (water)
Dyes Quo
Samples checked for dechlorination:
Dyes ❑No
N/A
Headspace in VOA Vials ( >6mm):
Dyes ❑No
0141A
l�
Trip Blank Present:
Dyes ❑No
13NrA
Trip Blank Custody Seals Present
❑Yes ❑No
❑ !A
Pace Trip Blank Lot # (if purchased):
Client Notiffcationf Resolution: Field Data Required? Y f N
Person Contacted:
Comments/ Resolution:
Date[Time:
SCURF Review: ij'j[ Date: 0-27-' W0# . 92273665
SRF Review: ( gate: l)
Note: Whenever there is a discrepancy affecting North Carolina compliance
samples, a copy of this form will be sent to the North Carolina DEHNR 92273665
Certification Office ( i.e out of hold, incorrect preservative, out of temp, ,duel available)
incorrect containers)
Page 10 of 11

P CHAIN -OF -CUSTODY 1 Analytical Request Document
�'` - .w •.- The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must he completed accurately.
Section A Section B Section C
Required Client Information: Required Project Information: Invoice Information: Page : 1 Of 1
Company: Watts Water Technologies Repon To; Mark Kennard Atlenlion'. MAgK W1UAJjAD
Address: 100 Watts Rd Copy To: W0 W40-0 V Company Name: 6j,4 4 TM
S indals,NC28160
jfoWgR�.G 2J fn/ �p
Address: f00 yJ AV�
ii_" ':tL Reolittory Agency ?'r' �:t•.'i ":j
Email;fy)gr eyo-A SG1 r.CoM
Purchase Order#:
Pace Quote:
Phone: i^ 99 8 117ax
Project Name: er J,JA f.pj!2 _e LJ
Pace Project Manager nicole, [e-mail].
State ! Location —
,Requested Rue Date:
Project #:
Pace Profile it: 7136-3
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k
hart 'wom hickman
SMARTER. ENVIRONMENTAL SOLUTIONS
Via Email
November 24, 2015
Watts Water Technologies
100 Watts Road
Spindale, NC 28160
Attn: Mr. Mark Kennard
Re: Stormwater Background Sampling
Watts Water Technologies
Spindale, NC
H&H Project No. WWT-004
Dear Mark:
Per your request, Hart & Hickman, PC (H&H) is providing this letter to summarize the results of
stormwater background sampling at the Watts Water Technologies (Watts) facility in Spindale,
NC. Consistent with the February 3, 2010 Approval of Representative Outfall Status, Watts
obtains quantitative data for samples from outfalls 001, 002, 004 and 006. Upon receiving the
results of the July 2015 sampling, Watts engaged Hart & Hickman ("H&H") to evaluate the
stormwater metal detections and to improve stormwater management for the facility. H&H
recommended three key action items which included placement of stormwater filter socks, addition
of limestone riprap in high flow areas, and improvement in the grass coverage density for soil
surface stabilization. Watts implemented these recommendations, and stormwater metal
concentrations significantly decreased based on the September 201 S monthly sampling event.
The lead concentrations detected in the outfall samples in September 2015 were below the
benchmark value. However, based on the low benchmark values for copper and zinc, these metal
concentrations continue to exceed benchmark values as reported in the September 2015
DMR. Outfalls 001, 002, 004, and 006 are in Tier III status for copper and/or zinc. Monthly
2923 South Tryon Street, Suite 100 ! 3334 Hillsborough Street
Charlotte, NC 28203 IIj Raleigh, NC 27607 www.harthickman.com
704.586.0007 main 919.847.4241 main

Mr. Mark Kennard
November 24, 2015
Page 2
monitoring data continues to be used to evaluate the effectiveness of stormwater improvements
and the need for further improvements.
Because stormwater metal concentrations have been reduced to low levels with only copper and
zinc exceeding benchmarks, H&H suspected that background sources of copper and zinc may be
contributing to the detections at the stormwater outfalls. Two background sources were
investigated by sampling conducted by Watts in October 2015: 1. roadside stormwater runoff
from Watts Road because stormwater outfalls receive such water and 2. roof drain runoff from
the warehouse building. It is noted that the roof has metal decking and a whitish coating. The
roof surface is generally clean and in good condition.
In that Watts is proactively addressing the stormwater metals concern, background and stormwater
discharge outfall samples were collected on October 27, 2015, although the prior rainfall resulted
in sampling under conditions that were not ideal. Approximately 0.2 inches of rain fell on the two
days prior to the stormwater sample collection based on precipitation data at a nearby reporting
station (Rutherfordton 2.6 WSW). Even though this rain event was not considered to be a
qualifying event for completing a monthly DMR, H&H considers these data to be relevant to
evaluating the stormwater conditions at this site.
H&H has summarized the stormwater sample background and outfall data collected on October
27, 2015 in Table 1, and laboratory reports are also attached. Relatively high levels of copper (up
to 0.438 mg/1), lead (up to 0.0524 mg/1), and zinc (up to 1.84 mg/1) were detected in both the road
runoff and roof background samples. Detected metal concentrations in the background samples
exceed the benchmark values. To compare the background data to the outfall results in a broad
sense, H&H calculated average values for the four outfalls and average values for the four
background samples. On average, the background concentrations for each metal significantly
exceed the outfall metal concentrations. H&H understands that a second round of background and
outfall metals data were collected in November. These data will be useful to confirm the October
results.
hart ` hickman
SMARTER ENVIRONMENTAL SOLUTIONS
S.tAAA-Master Projacts\Wans Water Techmlogies - W WT%W\MT-ON Quwtffly Spindale NC1Watts Stot ate 6ackground.docn

Mr. Mark Kennard
November 24, 2015
Page 3
We appreciate the opportunity to assist with this project. Should you have any questions or need
any additional information, please feel free to contact me.
Sincerely,
Hart & Hickman, PC
Matt Bramblett, PE
Principal Engineer
Attachment
Cc. Mr. Howard Chu, Watts (via email)
Mr. Sean Sullivan, TS (via email)
is
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
SAAAA-Master Prgjects%Watts Water Technologies - WIATMAT-QUS Quarterly SpinrW c \Mwaus stormwaier Background_docx

Tabfe 1
Background Stormwater Data
Watts Water Technologies
Spindale, NC
H&H Job No. WWT-004
Background
Sample Location
Road Run
Road Run
Roof Drain
Roof Drain
OU 001
OU-002
OU-004
OU-006
Outfall
Average
NPDES
ON-01 DC
Off-02 DR
#1 Dock
#2 Evap
Average
Various
Sources
permit
Benchmark
Date
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
Units
mg1L
mg/L
mg/L,
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Metals (200.7)
Copper
0.0081
0.438
0.012
0.205
0.0722
0.0059
0.055
0.0378
0.043
0.166
0.007
Lead
<0.005
0.0524
<0.005
0.0512
OA074
<0.005
<0.005
<0.005
0.004
0.028
0.030
Zinc
0.0469
0.178
0.338
1.89
0.0734
0.0287
0.196
0.117
0.104
0.613
0.067
Nate:
Data collected after two days with approximately 0.2 inches of rain per day
Non-delects averaged at 112 of the reporting limit
Bold and Italics indicate exceed benchmark
Table 2 (Page 1 of 1)
F9e: B.V4U•AYaur WyetlaYWem Wabr TeWwlopea•WWrIWWi-0a OuxlerlV SpirltlYl NC�Hx�rOuntl SW %I�BtlI
wc-++rzwxols Hart & Hickman. PC

aoAnalytical
*"pacelabs.=n
November 09, 2015
Mark Kennard
Watts Water Technologies
815 Pickens Street
Chesnee, SC 29323
RE: Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Dear Mark Kennard:
Pace Analytical services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Enclosed are the analytical results for sample(s) received by the laboratory on October 28, 2015.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TN standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
r�
Nicole Gasiorowski
nicole.gas lorowski@pacelabs .corn
Project Manager
Enclosures
ptcx�o
TNI
4BdRA�
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 13

Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Nuntersville, NC 28078
(�55'cieAnalytical"
wwwpo Wabs•com
[phone]
CERTIFICATIONS
Project: WAFTS SPINDALE SW
Pace Project No.: 92273668
Charlotte Certification IDs
9800 KinceyAve. Ste 100, Huntersville, NC 28078
Florida/NELAP Certification #: E87627
North Carolina Drinking Water Certification #: 37706
Kentucky UST Certification #: 84
North Carolina Field Services Certification #: 5342
West Virginia Certification #: 357
North Carolina Wastewater Certification #: 12
VirginiatVELAP Certification #: 460221
South Carolina Certification #: 99006001
Asheville Certification IDs
2225 Riverside Drive, Asheville, NC 28804
North Carolina Wastewater Certification #: 40
Florida/NELAP Certification #: E87648
South Carolina Certification #: 99030001
Massachusetts Cer0ficadon #: M-NC030
West Virginia Certification #: 356
North Carolina Drinking Water Certification #: 37712
Virginia[VELAP Certification #: 460222
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 2 of 13

lacieAnalytical"
www.pacefabs.c=
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Sample: OU-001 Lab ID: 92273668001 Collected: 10127/15 09:25 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 1664B
Total Petroleum Hydrocarbons
ND mg/L
5.0
1
11/04/15 08:33
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation
Method: EPA 200.7
Copper
72.2 ug1L
5.0
1 10/29/15 20:00
11/02/15 19:52 7440-50-8
Lead
7.4 ug1L
5.0
1 10/29/15 20:00
11/02/15 19:52 7439-92-1
Zinc
73.4 ug1L
10.0
1 10/29/15 20:00
11/03/15 22:01 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
55.1 mg/L
2.6
1
10/29/15 10:12
Date: 11/0912015 04:34 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 3 of 13

acMnalytrcal
www.parwabs.cwn
ANALYTICAL RESULTS
Project: WATTS SPIN DALE SW
Pace Project No.: 92273668
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Sample: OU-002 Lab ID: 92273668002 Collected: 10/27/15 09:35 Received: 10128115 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 16648
Total Petroleum Hydrocarbons
ND mglL
5.0
1
11 /04115 08:33
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
5.9 ug1L
5.0
1 10/29/15 20:00
11 /02115 19:55 7440-50-8
Lead
ND ug/L
5.0
1 10/29/15 20:00
11/02/15 19:55 7439-92-1
Zinc
28.7 ug1L
10.0
1 10/29/15 20:00
11 /03115 22:04 7440f6-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
ND mg/L
3.1
1
10/29/15 10:13
Date: 11/09/2015 04:34 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 4 of 13

laneAnalytical.
wwwpacalabs.corn
ANALYTICAL RESULTS
Pace Analytical Seryices, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Sample: OU-004 Lab ID: 92273668003 Collected: 10/27/15 09A5 Received: 10128/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT HEM, TPH
Analytical Method: EPA 1664B
Total Petroleum Hydrocarbons
ND mglL
5.0 1
11/04/15 08:34
200.7 MET ICP
Analytical Method: EPA200.7 Preparation
Method: EPA200.7
Copper
55.0 uglL
5.0 1 10/29/15 20:00
11/02/15 19:58 7440-50-8
Lead
ND uglL
5.0 1 10/29/15 20:00
11/02/15 19:58 7439-92-1
Zinc
196 ug1L
10.0 1 10/29/15 20:00
11/03/15 22:16 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
4.4 mglL
2.9 1
10/29/15 10:13
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 5 of 13

Pace Analytical Services, Inc.
aceAnalytr<cal o 9800 Kincey Ave. Suite 100
Nuntersville, NC 28078
www.pacelabs.co n
[phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Sample: OU-006 Lab ID: 92273668004 Collected: 10/27/15 09:55 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 1664B
Total Petroleum Hydrocarbons
ND mg1L
5.0
1
11/04/15 08:34
200.7 MET ICP
Analytical Method: EPA200.7 Preparation Method: EPA200.7
Copper
37.8 ug/L
5.0
1 10/29/15 20:00
11/02/15 20:01 7440-50-8
Lead
ND ug/L
5.0
1 10129/15 20:00
11/02/15 20:01 7439-92-1
Zinc
117 ug/L
10.0
1 10/29/15 20:00
11/03/15 22:19 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
3.5 mglL
3.1
1
10/29/15 10:13
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11 /09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 6 of 13

aceAnalytical
www.pacelabs.c=
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
QC Batch: GCSV/23097 Analysis Method: EPA 1664B
QC Batch Method: EPA 1664E Analysis Description: 1664 SGT-HEM, TPH
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
METHOD BLANK: 1598176
Matrix: Water
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273666004
Blank Repotting
Parameter
Units
Result Limit
Analyzed Qualifiers
Total Petroleum Hydrocarbons
mg/L
ND 5.0
11/04/15 08:22
LABORATORY CONTROL SAMPLE:
1598177
Spike LCS
LCS % Rec
Parameter
Units
Conc. Result
% Rec Limits Qualifiers
Total Petroleum Hydrocarbons
mg/L
20 14.5
72 64-132
MATRIX SPIKE SAMPLE: 1598178
92273784002 Spike MS MS % Rec
Parameter units Result Conc. Result % Rec Limits Qualifiers
Total Petroleum Hydrocarbons mg/L N❑ 20 16.1 80 64-132
Results presented on this page are In the units Indicated by the "Units" column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 7 of 13

(�5acieAnalyficalo
wwwpacWfabs.t o n
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
QC Batch: MPRP119925 Analysis Method: EPA 200.7
QC Batch Method: EPA 200.7 Analysis Description: 200.7 MET
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
METHOD BLANK: 1695294
Matrix: Water
Associated Lab Samples:
92273668001, 92273668002, 92273668003, 92273668004
Blank Reporting
Parameter
Units
Result Limit
Analyzed Qualifiers
Copper
uglL
ND 5.0
11/0511516:28
Lead
ug/L
ND 5.0
11/05/1516:28
Zinc
ug/L
ND 10.0
11/0511516:28
Pace Analytical Services, Inc,
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
LABORATORY CONTROL SAMPLE:
1595295
Spike
LCS LCS % Rec
Parameter
Units
Cone.
Result % Rec Limits Qualifiers
Copper
ug1L
500
504 101 85-115
Lead
ug1L
500
493 99 85-115
Zinc
ug/L
500
485 97 85-115
MATRIX SPIKE & MATRIX SPIKE DUPLICATE:
1595298
1595299
MS
MSD
92273665001
Spike
Spike
MS
MSD
MS
MSD
% Rec
Parameter Units
Result
Cone.
Cone.
Result
Result
% Rec
% Rec
Limits
RPD Qual
Copper ug1L
8.1
500
500
480
470
94
92
70-130
2
Lead uglL
ND
500
500
475
473
94
94
70-130
0
Zinc ug1L
46.9
500
500
495
486
90
88
70-130
2
Results presented on this page are in the units Indicated by the "Units" column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 8 of 13

aceAnalytical.
www.pacelabs.t om
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
QC Batch: WET141108 Analysis Method: SM 2540D
QC Batch Method: SM 2540D Analysls Description: 2540D Total Suspended Solids
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
METHOD BLANK: 1594264 Matrix: Water
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Total Suspended Solids mg1L NO 2.5 10/29/15 10:09
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersvitle, NC 28078
[phone]
LABORATORY CONTROL SAMPLE:
1594265
Spike
LCS LCS
% Rec
Parameter
Units
Conc.
Result % Rec
Limits Qualifiers
Total Suspended Solids
mg1L
250
250 100
90-ii0
SAMPLE DUPLICATE: 1594266
92273613003
Dup
Parameter
Units
Result
Result RPD
Qualifiers
Total Suspended Solids
mglL
31.0
33.0
6 D6
SAMPLE DUPLICATE: 1594267
92273669003
Dup
Parameter
Units
Result
Result RPD
Qualifiers
Total Suspended Solids
mg1L
ND
ND
Ftesutts presented on this page are In the units indicated by the'Units' column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 9 of 13

aceAnalytical
wAW Pacalatux=
QUALIFIERS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
DEFINITIONS
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL - Adjusted Method Detection Limit.
PQL - Practical Quandtation Limit.
RL-Reporting Limit.
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
S - Surrogate
1,2-Diphenyihydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is
a combined concentration,
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
Acid preservation may not be appropriate for 2 Chioroethylvinyl ether, Styrene, and Vinyl chloride.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis ofAcrolein and Acrylonitrile by EPA
Method 8260.
N- Nitrosodiphenyla mine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TN -The NELAC Institute.
ANALYTE QUALIFIERS
D6 The relative percent difference (RPD) between the sample and sample duplicate exceeded laboratory control limits.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 10 of 13

aceAnalytJcal.
wwwpacetabs-C=
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Lab ID Sample ID QC Batch Method QC Batch Analytical Method
92273668001
OU-001
EPA 1664B
GCSVl23097
92273668002
OU-002
EPA 1664B
GCSV123097
92273668003
OU-004
EPA 1664E
GCSV123097
92273668004
OU-006
EPA 1664E
GCSV123097
92273668001
OU-001
EPA 200.7
MPRP119925
EPA 200.7
92273668002
OU-002
EPA 200.7
MPRP119925
EPA 200.7
92273668003
OU-004
EPA 200.7
MPRP/19925
EPA 200.7
92273668004
OU-006
EPA 200.7
MPRP/19925
EPA 200.7
92273668001
01.11-001
SM 2540D
WET141108
92273668002
OU-002
SM 2540D
WET141108
92273668003
OU-004
SM 2540D
WET/41108
92273668004
OU-006
SM 2540D
WET141108
Date: 11/09/201504:34 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Analytical
Batch
ICP117967
ICP117967
ICP117967
I C P117967
Page 11 of 13

1
I
f� aceArialytical+
d
uocumenc rvame:
Sample Condition Upon Receil
Document Number:
F-i HR-CS-003-rov.16
LJt,UU1 I Val R r%C V MMU-1VIGy 1U, by ram+
SCUR Page 1 of 2'
Issuing Authority:
Pace Huntersville Quality Office
Client Name: Page 2 of 2 is for Internal Use Only
Courier: El Fed E0__U­P0 USPCI Clier❑ Commerci Pace Other `�-7'
Y ❑Zbblee
❑ /-- P(6)�`Diie; Date �' ` tV.
Custody Seal on Cooler/Box Present: no Seals intact: ❑ yes ❑ no
Packing Material: ❑ Bubble Wrap ❑Bags ❑ None ❑ Other
Thermometer Used: lR Gun V2No
' Type of Ice:6e)t Blue None ample, on ice, cooling process has begun
Temo Correction Factor T14Correction
Corrected CnolerTemP.: C
Biological Tissue Is Frozen: Yes Na !A
9
Date and Initials of person examining
contents: c%) e �d-dY'•.rS
Temp should be above freezing to VC
Comments:
Chain of Custody Present:
J2'ie�sQNo
❑NIA
1.
Chain of Custody Filled Out:
Q< No
❑NIA
2.
Chain of Custody Relinquished:
es
❑NIA
3,
Sam ler Name & Signature on COC:
91es 2D
❑NIA
4.
Samples Arrived within Hold Time:
Oles ❑Na
PNIA
$.
Short Hold Time Analysis <72hr :
o
PWA
$,
Rush Turn Around Time Requested:
—Dyes
Dyes
❑NIA
7.
Sufficient Volume:
C] es
❑NIA
g.
Correct Containers Used:
Cl esEll k6"❑NIA
9.
-Pace Containers Used:
❑ es ONO
❑NIA
Containers Intact:
s C]No
❑NIA
it).
Filtered volume received for Dissolved tests
Dyes ❑L
❑N
11.
Sample Labels match COG:
es ❑No
❑NIA
12.
-Includes date/time/ID/Analysis Matrix:
All containers needing preservation have been checked.
D eY s ❑No
ONIA
13.
All containers needing preservation are found to be in
es ❑No
❑NIA
compliance with EPA recommendation.
exceptions: VOA, coliform, TOC, obG. WI-DRO (water)
COY sl ONO
�
Samples checked for dechlorination:
Dyes ❑No
DN<
14.
Headspace in VOA Vials ( >Bmm):
©Yes ONO
O rA
15.
Trip Blank Present:
Dyes ONO
❑
16
Trip Blank Custody Seals Present
Oyes ONO
NIA
Pace Trip Blank Lot # (if purchased):
Client Notification/ Resolution:
Person Contacted: Date/Time:
Comments! Resolution:
SCURF Review: `�l� '1 Date: I 10-IT
SRF Review: 0 M( Date:
Note: Whenever there is a discrepancy affecting North Carolina compliance
samples, a copy of this form will be sent to the North Carolina DEHNR
Certification Office ( i.e out of hold, incorrect preservative, out of temp,
incorrect containers)
Field Data Required? Y 1 N
Place label here
WO#:92273668
92273668
Page 12 of 13

�° arrarrr� CHAIN -OF -CUSTODY 1 Analytical Request Document
.M••- The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Sectian A Sectian B sectfan c
Required client Worm allao: Requfred Project Information: tnvolce tnfarmatlon: Page : t Of T
Gompwrir- watts water TechwfoRies Report To: attention �/
Addrwss: 1100walts Rd Copy To: y v CornPnny e3ama: �,/!} t.J f110LGi(�l
Spaidalo.14C251SD
1104.0014W.CNU fo t.0
Address:/4ay/p p3j,!� G 2
- r R utero nc
Email: RK CZMM— 4/*n4A 7r9— cM
Purchase Order p:
Pace Quote:
Phone: 2-6. rf Far
PmJect Nome_ s eler A Nti J —al"ScJ
Pace Project Manger. nicoie. slorowski pacalabs.mm.
- = sure 7 Lopelan
_ "
Requested Due Date. $
Project A:
Pace Profile e: 7136- 2,
unsted
Iyals
Filtered
(YIN)-
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Pam 1 P
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SAMPLE ID 0,"'°'°
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START
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f-
One Character per box. mp• WP
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Sample Ids must 6c unique
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TIME-�T
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SAMPLER NAIVE AND SIGNATURE 71.-'� . t e ='. i c"i } e ,`" y.=C -, .: 4• ••.
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PRINT Name of SAMPLER:
MARK !�n✓n.>Ar4,l�
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SIGNATURE of SAMPLER: !
DATE Signed:
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man

aceAnalytical
~pacalaft=n
November 10, 2015
Mark Kennard
Watts Water Technologies
815 Pickens Street
Chesnee, SC 29323
RE: Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Dear Mark Kennard:
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 2907E
(704)e75-9092
Enclosed are the analytical results for sample(s) received by the laboratory on October 28, 2015.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TN I standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Nicole Gasiorowski
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the wriCen consent of Pace Anaiytical Services, inc.,
Page 1 of 11

ace Analytical
*"Pacarab$-=
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Asheville Certification Ids
2225 Riverside Drive, Asheville, NC 28804
Florida/NELAP Certification #: E87648
Massachusetts Certification #: M-NC030
North Carolina Drinking Water Certification #: 37712
CERTIFICATIONS
North Carolina Wastewater Certification #: 40
South Carolina Certification #: 99030001
West Virginia Certification #: 356
VirginiatVELAP Certification #: 460222
REPORT OF LABORATORY ANALYSIS
Pace Anatytical Services, tnc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
This report shall not be reproduced, except in full,
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Page 2 of 11

ac,Mnaiytical
wwwpatelabs.rcm
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Nuntersville, NC 28078
[phone]
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Sample: ROAD RUN OFF-01 DC Lab ID: 92273665001 Collected: 10/27/15 10:25 Received: IW28115 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper 8.1 ug/L 5.0 1 10/29/15 20:00 11/02115 1914 7440-50-8
Lead ND ug1L 5.0 1 10/29/15 20:00 11102/15 19:24 7439-92-1
Zinc 46.9 uglL 10.0 1 10/29/15 20:00 11/03/15 21743 7440-06-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11 /10/2016 10:54 AM without the written consent of Pace Analytical Services, Inc..
Page 3 of 11

aceAnalytical
www.pacalabs.com
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Pate Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Sample: ROAD RUN OFF-02 DR
Lab ID: 92273665002
Collected: 10/27/15 10:30
Received: 10128/15 11:30 Matrix: Water
Parameters
Results Units
Report Limit OF
Prepared
Analyzed
CAS No. Qual
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
438 ug1L
5.0 1
10/29/15 20:00
11/02/15 19:42
7440-50-8
Lead
52.4 ug/L
5.0 1
10/29/15 20:00
11/02/15 19:42
7439-92-1
Zinc
178 ug/L
10.0 1
10/29/15 20:00
11/03/15 21:51
7440-66-6
Date: I V10/2015 10:54 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
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Page 4 of 11

aceAnayicaf.
wwwpaca)abs.com
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Nuntersville, NC 28078
[phone]
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Sample: ROOF DRAIN #1 DOCK Lab ID: 92273665003 Collected: 10127/15 10:05 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper 12.0 uglL 5.0 1 10/29/15 20:00 11/02/15 19:46 7440-50-8
Lead NO ug/L 5.0 1 10/29/15 20:00 11/02115 19:46 7439.92-1
Zinc 338 ug/L 10.0 1 10I29/15 20:00 11/03/15 21:54 7440-W6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in hull,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc..
Page 5 of 11

aceAnalyiical.
ww+w.pacelabs.com
ANALYTICAL RESULTS
Pace AnelyticaI Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Sample: ROOF DRAIN #2 EVAP Lab ID: 92273665004 Collected: 10/27/15 10:10 Received: 10/28115 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No, Qual
200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper 205 uglL 5.0 1 10/29/15 20:00 11/02/15 19:49 7440.50-8
Lead 51.2 uglL 5.0 1 10129/15 20:00 11/02/15 19:49 7439-92-1
Zinc 1890 uglL 10.0 1 10/29115 20:00 11103/15 21:57 7440-66-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc..
Page 6 of 11

aceAnaVica1 *
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QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No-: 92273665
QC Batch: MPRP119925 Analysis Method: EPA 200.7
QC Batch Method: EPA 200.7 Analysis Description: 200.7 MET
Associated Lab Samples: 9227366500i, 92273665002, 92273665003, 92273665004
METHOD BLANK: 1595294 Matrix: Water
Associated Lab Samples: 92273665001, 92273665002, 92273665003, 92273665004
Blank Reporting
Parameter Units Result Limit Analyzed
Copper uglL ND 5.0 11/05/1516:28
Lead ug1L ND 5.0 1110511516:28
Zinc uglL ND 10.0 11/05/1516:28
Qualifiers
Pace Analytical Services, Inc.
98M Kincey Ave. Suite 100
Huniersville, NC 28078
[phone]
LABORATORY CONTROL SAMPLE:
1595295
Spike LCS LCS
% Rec
Parameter
Units
Conc- Result % Rec
Limits Qualifiers
Copper
ug1L
500 504 101
85-115
Lead
uglL
500 493 99
85-115
Zinc
uglL
500 485 97
85-115
MATRIX SPIKE & MATRIX SPIKE DUPLICATE:
1595298
1595299
MS
MSD
92273665001
Spike
Spike
MS
MSD
MS
MSD
% Rec
Parameter Units
Result
Conc.
Conc.
Result
Result
% Rec
% Rec
Limits
RPD Qual
Copper ug1L
8.1
500
500
480
470
94
92
70-130
2
Lead ug1L
ND
500
500
475
473
94
94
70-130
0
Zinc ug1L
46.9
500
500
495
486
90
88
70-130
2
Results presented on this page are in the units Indkated by the "Units" column except where an alternate unit b presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc,.
Page 7 of 11

aceAnalytical"'
www.pecefabscom
QUALIFIERS
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
DEFINITIONS
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL - Adjusted Method Detection Limit.
PQL - Practical Quantitation Limit.
RL - Reporting Limit.
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
S - Surrogate
1,2-Diphenyihydrazine decomposes to and cannot be separated from Azobenzene using Method 8270_ The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
Acid preservation may not be appropriate for 2 Chloroethylvinyl ether, Styrene, and Vinyl chloride.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis of Acrolein and Acrylonitrile by EPA
Method 8260.
N-Nitrosodiphenyla mine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI - The NELAC Institute_
WORKORDER QUALIFIERS
WO: 92273665
III Report revised to remove full analyte list from sample -001. Only Cu, Pb, Zn were requested_ Samples -002 through -004
had correct list.
REPORT OF LABORATORY ANALYSIS
This report shall not he reproduced, except in full,
Date: 11110/201510:54 AM without the written consent of Pace Analytical Services, Inc.. Page 8 of 11

alceAnalytical "
www.peceJabs.c=
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite t DO
Huntersville, NC 28078
[phone]
Project:
Pace Project No,:
WATTS SPINDALE SW
92273665
Analytical
Lab ID
Sample ID
QC Batch Method
OC Batch
Analytical Method
Batch
92273665001
ROAD RUN OFF-01 DC
EPA 200.7
MPRP119925
EPA 200.7
ICP117967
92273665002
ROAD RUN OFF-02 DR
EPA 200.7
MPRPl19925
EPA 200.7
ICP117967
92273665003
ROOF DRAIN #1 DOCK
EPA 200.7
MPRP119925
EPA 200.7
ICP117967
92273665004
ROOF DRAIN #2 EVAP
EPA 200.7
MPRP119925
EPA 200.7
ICP117967
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11 /10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc.. Page 9 of 111

tJocurnent imame: uut:uiuCrrt r1CVIDGU. w113y 1u'
acer naokal• Sample Condition Upon Receipt (SCUR) Page i of 2*
Document Number: Issuing Authority:
F-CHR-CS-003-rev.16 Pace Huntersville Quality Mice
Client dame: W4i + -h5 i 4, �- Qr _ • Page 2 of 2 is for Internal Use Only
Courier: ❑ Fed E:❑ UPUSP ❑Ciier❑ Commerci❑ Pace Other
Custody Seat on Cooler/Box Present: ❑ yes ❑ no Seats intact: ❑ yes ❑ no _ . r.,l.Y� �• �_:,•, -_;,, .
Packing Material: ❑ Bubble Wrap ❑ Bubble Bags Er None ❑ Other
Thermometer Used: IR Gun T 402 1 Type of ice: et Blue None ampies on ice, cooling process has begun
Temn Correction Factor T1402 No Correction
Biological Tissue is Frozen: Yes No Date and Initials of person examining._
g
Corrected Cooler Temp.:C
contents:_
Temp should be above freezing to VC
Comments:
Chain of Custody Present:
es
©NIA
1.
Chain of Custody Filled Out:
es O_uar
ONIA
2.
Chairs of Custody Relinquished:
es ❑No
❑NIA
3.
Sampler Name & Signature on COC:
s ❑No
ONIA
4.
Samples Arrived within Hold Time:
15yea ON,
❑NIA
5.
Short Hold Time Analysis (<72hr):
Dyes
NIA
6.
Rush Turn Around Time Re Nested:
Dyes
❑NfA
7.
Sufficient Volume:
❑ es QWO
❑NIA
8.
Correct Containers Used:
❑NIA
8.
-Pace Containers Used:
ENo
es No
❑NIA
Containers Intact:
ElYeS ❑NG
❑NIA
110
Filtered volume received for Dissolved tests
❑Yes ONO
❑ A
11.
Sample Labels match COC:
s ❑No
❑NfA
12.
- -Includes datettimeliDlAnat sis Matrix:
K—
All containers needing preservation have been checked.
0 es �
❑NIA
13:
All containers needing preservation are found to be in
Yes NO
❑NIA
compliance with EPA recommendation.
�
,�
exceptions; VOA, coliform, TOG, O&G, W-DRO (water
1
❑Yea L1No
Samples checked for dechlorinalion:
❑Yes ONO
06
Headspace in VOA Vials >6mm):
Dyes ONO
©IA
Trip Blank Present:
Dyes ❑No
l3f 1
Trip Blank Custody Seals Present
❑Yes ONO
❑ IA
Pace Trip Blank Lot # (if purchased):
Client Notification! Resolution: Field Data Required? Y I N
Person Contacted: Date/Time:
Comments/ Resolution:
ti
SCURF Review: t1y(-7 Data: 140# : 92273665
SRF Review: r41 Dale. 6
Note: Whenever there is a discrepancy affecting North Carolina compliance Ill I`ly t` tI 11 Illf
samples, a copy of this form will be sent to the North Carolina DEHNR 92273665
Certification Office ( i.e out of hold, incorrect preservative, out of temp,
Incorrect containers) Et, �u nacret available}
Page 10 of 1 t

CHAIN -OF -CUSTODY I Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Section A Section S Section C
Required Ghent 1Momfetlon•. Required Project tarommtion, Irreoice hdonnabon; Page : 1 Of
canPaM: Wags water Tecnnofopies Report To: Mark Kennard Alfammw �Jw1AR(:
Ackkass: too watt,Ra Copy To: 00&jARo cJ COMP2PyName:4JA A Zn oL.00-1425�
s indale. Nc 28160
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Phone: . of 7- g Fax
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Pace Project Manager: Mode. 3kxuwS$ Isbs.com.
Stale I Location
Requested Due Date;
Prood 0:
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A Watts Water Technologies Company 815 Chestnut Street • North Andover, MA • 01845-6098 • Tel. [phone] • Fax: [phone]
301330 WN101038 3111AIHS
Stanley Aiken SM 9 AON
Regional Engineer
Asheville Regional Office
N.C. Department of Environmental Quality (13A d
2090 U.S. Highway 70
Swannanoa, NC 28778
Ike: Notification of Tier III Status under General Permit for Discharges of Stormwater
Associated with Metal Fabrication Facilities
Dear Mr. Aiken:
In accordance with Part II.13 of the general permit for discharges of Stormwater associated
with metal fabrication facilities (the "General Permit"), this letter serves as notification that
analytical results from the September 2015 storm water sampling caused entry into Tier III status
for Watts Water Technologies' ("Watts") facility located at 100 Watts Road in Spindale, North
Carolina (the "Facility") as indicated below:
• Outfall 1 —Copper
• Outfall 2 — Copper
• Outfall 4 — Copper and Zinc
• Outfall 6 — Copper
Over the past several months, Watts has implemented a number of additional best
management practices at the Facility to reduce the presence of metals in its stormwater
discharge. As Watts is committed to environmental stewardship, please contact me at your
convenience to set-up meeting to discuss this matter.
Sincerely,
(L/— -
//-3 i5
Howard Chu
Director, Environment, Health and Safety
Watts Water Technologies
815 Chestnut St.
North Andover, MA 01845
978-689-6070
Watts Regulator Company Since 1874 watts.com

h9 5`[Eh
4 1%jjWATM
WATER TECHNOLOGIES
815 Chestnut Street • North Andover, MA • 01845-6098
V
71VN F3I71110.7
�,.------�---- -- - --- ---------
3Nf1031100 lY G10��SS3HOOY NUMML 3N1 AO
1140ltl 3Nl Ol 3d013AN3 AO d011V N3xOLLS 33Yld
R cdved
4 Nov - 6 2015 .
Land Quality Section
Asheville
SrJAILEY 14IKCN
gAS PN-
ffi�PITMEV BOWIES
_: 02 1 P $ 006.736
00031 97255 NOV 03 2015
MAILED FROM ZIP CODE 01 845
x9cG rolqA L �NCa 11VEE9
V1 L i, l E610A14t-
2 oT 0 %j I7N y 70

Table 1
Background Stormwater Data
Watts Water Technologies
Spindale, NC
H&H Job No. WWT-004
Background
Road Run
Road Run
Roof Drain
Roof Drain
Outfall
Average
Sample Location
OU 001
OU 002
OU 004
OU-006
NPDES
Off-01 DC
Off-02 DR
#1 Dock
#2 Evap
Average
Various
Sources
Permit
Benchmark
Date
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
10/27/15
Units
mglL
mglL
mg1L
mglL
mglL
mglL
mglL
mg/L
mg1L
mglL
mglL
Metals (200.7)
Copper
0.0081
0.436
0.012
0.205
0.0722
0.0059
0.055
0.0378
0.043
0.166
0.007
Lead
<0.005
0.0524
<0.005
0.0512
0.0074
<0.005
<0 005
<0 005
0 004
0 028
0 030
Zinc
00469
0.178
0.338
1.89
0.0734
0.0287
0.196
0.117
0.104
0.613
0 067
Note
Data collected after two days with approximately 0.2 inches of rain per day
Non -detects averaged at 112 of the reporting limit
Bold and Italics indicate exceed benchmark
Tabfe 2 {page 1 of 1}
fY S%W-M� rRopchlWat}a 1W., Ter -ogR WW YWW4MQunt fSpv .NC1,H-kg,—d SW,Is Sal
D"immsos5 flart& Riefimurr, PC
0
•

0

• • • 0

Via Email
November 23, 2015
Watts Water Technologies
100 Watts Road
Spindale, NC 28160
Attn: Mr. Mark Kennard
Re: Stormwater Background Sampling
Watts Water Technologies
Spindale, NC
H&H Project No. WWT-004
Dear Mark:
hart '� hickman
SMARTER ENVIRONMENTAL SOLUTIONS
FILE
Per your request, Hart & Hickman, PC (H&H) is providing this letter to summarize the results of
stormwater background sampling at the Watts Water Technologies (Watts) facility in Spindale,
NC. Consistent with the February 3, 2010 Approval of Representative Outfall Status, Watts
obtains quantitative data for samples from outfalls 001, 002, 004 and 006. Upon receiving the
results of the July 2015 sampling, Watts engaged Hart & Hickman ("H&H") to evaluate the
stormwater metal detections and to improve stormwater management for the facility. H&H
recommended three key action items which included placement of stormwater filter socks, addition
of limestone riprap in high flow areas, and improvement in the grass coverage density for soil
surface stabilization. Watts implemented these recommendations, and stormwater metal
concentrations significantly decreased based on the September 2015 monthly sampling event.
The lead concentrations detected in the outfall samples in September 2015 were below the
benchmark value. However, based on the low benchmark values for copper and zinc, these metal
concentrations continue to exceed benchmark values as reported in the September 2015 DMR. Site
outfal I number, 2, and 4 are now in Tier III status for copper and zinc. land outfall number 6 is
2923 South Tryon Street, Suite 100 3334 Hillsborough Street
Charlotte, NC 28203 Raleigh, NC 27607 www.harthickman.com
704.586.D007 main 1 919-847,4241 main

Mr. Mark Kennard
November 23, 2015
Page 2
in Tier III status for copper. Monthly monitoring data continues to be used to evaluate the
effectiveness of stormwater improvements and the need for further improvements.
Because stormwater metal concentrations have been reduced to low levels with only copper and
zinc exceeding benchmarks, H&H suspected that background sources of copper and zinc may be
contributing to the detections at the stormwater outfalls. Two background sources were
investigated by sampling conducted by Watts in October 2015: 1. roadside stormwater runoff
from Watts Road because stormwater outfalls receive such water and 2. roof drain runoff from
the warehouse building. 1t is noted that the roof has metal decking and a whitish coating. The
roof surface is generally clean and in good condition.
In that Watts is proactively addressing the stormwater metals concern, background and stormwater
discharge outfall samples were collected on October 27, 2015, although the prior rainfall resulted
in sampling under conditions that were not ideal. Approximately 0.2 inches of rain fell on the two
days prior to the stormwater sample collection based on precipitation data at a nearby reporting
station (Rutherfordton 2.6 WSW). Even though this rain event was not considered to be a
qualifying event for completing a monthly DMR, H&H considers these data to be relevant to
evaluating the stormwater conditions at this site.
H&H has summarized the stormwater sample background and outfall data collected on October
27, 2015 in Table 1, and laboratory reports are also attached. Relatively high levels of copper (up
to 0.438 mg/1), lead (up to 0.0524 mg/1), and zinc (up to 1.89 mg/1) were detected in both the road
runoff and roof background samples. Detected metal concentrations in the background samples
exceed the benchmark values. To compare the background data to the outfall results in a broad
sense, H&H calculated average values for the four outfalls and average values for the four
background samples. On average, the background concentrations for each metal significantly
exceed the outfal I metal concentrations. H&H understands that a second round of background and
outfall metals data were collected in November. These data will be useful to confirm the October
results.
Id
hart hickman
SMARTER ENVIRONMENTAL SOLUTU MS
5 %AAA -Master ProjeMMaas Water Te hnolagus - WW %W WT-064 Quanerly Spui"e NC\Watrs SlD mw ter Ba kgrvmd.dmc

M 0
Mr. Mark Kennard
November 23. 2015
Page 3
We appreciate the opportunity to assist with this project. Should you have any questions or need
any additional information, please feel free to contact me.
Sincerely,
Hurt & Hickman, PC
Matt Bramblett, PE
Principal Engineer
Attachment
Cc: Mr. Howard Chu, Watts (via email)
Mr. Sean Sullivan, TS (via email)
Ad
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
SMAA-Mwe, projeculu'am Water Technologies - WW"nWLU'T-DW Quanedy Spindale NClWans Scormwwer Background docz

M
(�Iacmnalyfi'cal'
*WWpbcai &own
November 09, 2015
Mark Kennard
Watts Water Technologies
815 Pickens Street
Chesnee, SC 29323
RE: Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Dear Mark Kennard:
iPace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Enclosed are the analytical results for sample(s) received by the laboratory on October 28, 2015.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Nicole Gasiorowski
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 13

0
acMnalytical
www.pecdebacam
CERTIFICATIONS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
. Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 2BD78
[phone]
Charlotte Certification IDs
9800 Kincey Ave. Ste 100, Huntersville, NC 28078
Flonda/NELAP Certification #: E87627
North Carolina Drinking Water Certification #: 37706
Kentucky UST Certification #: 84
North Carolina Field Services Certification #: 5342
West Virginia Certification #: 357
North Carolina Wastewater Certification #: 12
VirginiaNELAP Certification* 460221
South Carolina Certification #: 99006001
Asheville Certification IDs
2225 Riverside Drive, Asheville, NC 28804 North Carolina Wastewater Certification #: 40
FloridarNELAP Certification #: E87648 South Carolina Certification #; 99030001
Massachusetts Certification #: M-NC030 West Virginia Certification #: 356
North Carolina Drinking Water Certification #: 37712 VirginiaNELAP Certification #: 460222
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except In full,
without the written consent of Pace Analytical Services, Inc.. Page 2 of 13

Pace Analytical Services, Inc.
aee�naica0 9800 Kincey Ave. Suite 100
Nuntersville, NC 28U78
wwwPacakcam (704)8759092
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Sample: OU-001 Lab ID: 92273668001 Collected: 10/27/15 09:25 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. 4ual
1664 SGT HEM, TPH
Analytical Method: EPA 16646
Total Petroleum Hydrocarbons
ND mg1L
5,0 1
11/04/15 08:33
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
72.2 ug1L
6.0 1 10129/15 20:00
11102/15 19:52 7440-50-8
Lead
7.4 ug1L
5.0 1 10/29/15 20:00
11/02/15 19:52 7439-92-1
Zinc
73.4 ug1L
10.0 1 10/29/15 20:00
11/03/15 22:01 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
55.1 mg1L
2.6 1
10129/15 10:12
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11 /09/2015 04:34 PM without the written consent of Pace Analytical Services, inc.,
Page 3 of 13

aceAnalytical
wwwPocelms.mm
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
Pace Analytical Services, Inc.
9800 Kincey Ave_ Suite 100
HuntersVile, NC 28078
(704)M-9092
Sample: OU-002 Lab lD: 92273668002 Collected: 10/27/15 09:35 Received: 10128/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Total Petroleum Hydrocarbons
200.7 MET ICP
Copper
Lead
Zinc
2640D Total Suspended Sollds
Total Suspended Solids
Date- 11/09/2015 04:34 PM
Analytical Method: EPA 1664B
NO mg1L
5.0
1
11/04/15 08733
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
5.9 ug1L
5.0
1 10/29/15 20:00
11102f15 19:55 7440-50-8
NO uglL
5.0
1 10129115 20:00
11/02/15 19:55 7439.92-1
28.7 ug1L
10.0
1 10129/15 20:00
11/03/15 22:04 7440-66-6
Analytical Method: SM 2540D
ND mglL
3.1
1
1012911510:13
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, inc.
Page 4 of 13

Pace Analytical Services, Inc.
acEAnalytical • 9800 iCincey Ave. Suite 100
Hurl:en:ville, NC 2$078
wwwpecelabs.mm [phone]
ANALYTICAL, RESULTS
Project: WATTS SPINDALE SW
Pace Project No.-. 92273668
Sample: OU-004 Lab t0: 92273668003 Collected: 10/27/15 09:45 Received: 10/28/15 11:30 Matrix: Waler
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method: EPA 1664B
Total Petroleum Hydrocarbons
ND mg1L
5.0
1
11/04/15 08:34
200-7 MET iCP
Analytical Method: EPA 200.7 Preparation
Method: EPA 200.7
Copper
55.0 ug/L
5.0
1 10/29/15 20:00
11/02/15 19:58 7440-50-8
Lead
ND ug/L
5.0
1 10/29/15 20:00
11/02/15 19:58 7439-92.1
Zinc
196 ug1L
10.0
1 10/29/15 20:00
11/03/15 22:16 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
4.4 mg/L
2.9
1
10/29/15 10:13
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.
Page 5 of 13

Pace Analytical Services, Inc.
C�na
?Mal�cal
i�
inney Ave. Suite
9800 K100
Hunlersville, NC 2a078078
xwwperalacs mm
[phone]
ANALYTICAL RESULTS
Project: WATTS SPiNDALE SW
Pace Project No_: 92273668
Sample: OU-006
Lab ID: 92273668004 Collected: 10/27/15 09:55
Received:
10/28/15 11:30 Matrix: Water
Parameters
Results Units Report Limit DF
Prepared
Analyzed CAS No. Qual
1664 SGT HEM, TPH
Analytical Method: EPA 1664B
Total Petroleum Hydrocarbons
ND mg/L
5,0 1
11/04/15 08:34
200.7 MET 1CP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
37.8 ug1L
5.0 1 10/29/15 20:00
11/02115 20:01 7440-50-8
Lead
ND uglL
5.0 1 10/29115 20:00
11/02/15 20701 7439-92-1
Zinc
117 uglL
10.0 1 10/29/15 20:00
11/03/15 22:19 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
3.6 mglL
3.1 1
10/29/15 10:13
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc. Page 6 of 13

Pace Analytical Services, Inc.
aeeARalytical 980o i(incey Ave. Suite 100
Huntemville, NC 20D78
www.pacelabs.com [phone]
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No-: 92273668
QC Batch: GCSV123097 Analysis Method: EPA 1664B
QC Batch Method: EPA 1664E Analysis Description: 1664 SGT-HEM, TPH
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
METHOD BLANK: 1598176
Matrix: Water
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 9227$668004
Blank Reporting
Parameter
Units
Result Limit
Analyzed Qualifiers
Total Petroleum Hydrocarbons
mg1L
N❑ 5.0
11/04/15 08:22
LABORATORY CONTROL SAMPLE:
1598177
Spike LCS
LCS % Rec
Parameter
Units
Conc. Result
% Rec Limits Qualifiers
Total Petroleum Hydrocarbons
mg/L
20 14.5
72 64-132
MATRIX SPIKE SAMPLE: 1598178
92273784002 Spike MS MS % Rec
Parameter Units Result Conc. Result % Rec Limits Qualifiers
Total Petroleum Hydrocarbons mg/l_ ND 20 16.1 80 64-132
Results presented on this page are in the units Indicated by the "knits" column except where an alternate unit Is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 1110912015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 7 of 13

eeAnalyiica!`
wwwpacdahs.com
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No-: 92273668
QC Batch: MPRP119925 Analysis Method: EPA200.7
QC Batch Method: EPA 2007 Analysis Description: 200.7 MET
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 92273668004
METHOD BLANK: 1595294
Matrix: Water
Associated Lab Samples:
92273668001, 92273668002, 92273668003, 92273668004
Blank Reporting
Parameter
Units
Result Limit
Analyzed Qualifiers
Copper
uglL
ND 5.0
11/05/1516:28
Lead
ug1L
ND 5.0
1110511516:28
Zinc
ug1L
ND 10.0
11/05/1516:28
Pace Analytical Services, Inc.
9800 Kinsey Ave. Suite 100
Huntersville, NC 28078
[phone]
LABORATORY CONTROL SAMPLE:
1595295
Spike
LCS LCS % Rec
Parameter
Units
Conc-
Result % Ree Limits Qualifiers
Copper
uglL
500
504 101 85-115
Lead
uglL
500
493 99 85-115
Zinc
uglL
500
485 97 85-115
MATRIX SPIKE & MATRIX SPIKE DUPLICATE:
1595298
1595299
MS
MSD
92273665001
Spike
Spike
M5
MSD
MS
MSD
% Rec
Parameter Units
Result
Conc.
Conc.
Result
Result
% Rec
% Rec
Limits
RPD Qual
Capper uglL
81
500
500
480
470
94
92
70-130
2
Lead uglL
ND
500
500
475
473
94
94
70-130
0
Zinc uglL
46.9
500
500
495
486
90
88
70-130
2
Resutts presented on this page are in the units $ndicated by the "units" column except where an altemate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pats Analytical Services, Inc..
Page 8 of 13

Pace Analytical Services, Inc.
ace,rralytiea! 900o Kinsey Ave. Suite 300
Huntersville, NC 28078
www.pacefabs.com [phone]
QUALITY CONTROL DATA
Project: WATTS SPIN DALE SW
Pace Project No.: 92273668
OC Batch: WET141108
Analysis Method: SM 2540D
OC Batch Method: SM 2540D
Analysis Description: 2540D Total Suspended Solids
Associated Lab Samples: 92273668001, 92273668002,
92273668003, 92273668004
METHOD BLANK: 1694254
Matrix: Water
Associated Lab Samples: 92273668001, 92273668002, 92273668003, 9227366B004
Blank Reporting
Parameter
Units
Result Limit Analyzed Qualifiers
Total Suspended Solids
mg1L
ND 2.5 10/29/15 10:09
LABORATORY CONTROL SAMPLE: 1594265
Spike LCS LCS % Rec
Parameter
Units
Conc. Result % Rec Limits Qualifiers
Total Suspended Solids
mg/L
250 250 100 90-110
SAMPLE DUPLICATE: 1594266
92273613003 Dup
Parameter
Units
Result Result RPD Qualifiers
Total Suspended Solids
mg/L
31.0 33.0 6 D6
SAMPLE DUPLICATE: 1594267
92273669003 Dup
Parameter
Units
Result Result RPD Qualifiers
Total Suspended Solids
mg1L
NO NO
Results presented on this page are in the units Indicated by the "Units" column except where an alternate unit Is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc..
Page 9 of 13

13c,eAnalytical
wrwpMblaBaeom
QUALIFIERS
Project: WATTS SPINDALE SW
Pace Project No.: 92273668
DEFINITIONS
. Pace Analyticai Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
(704)87s-9092
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL-Adjusted Method Detection Limit.
POL - Practical Quantitation Limit.
RL - Reporting Limit.
S - Surrogate
1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
Acid preservation may not be appropriate for 2 Chloroethylvinyl ether, Styrene, and Vinyl chloride.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis of Acrolein and Acrylonitrile by EPA
Method 8260.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI - The NELAC Institute.
ANALYTE QUALIFIERS
D6 The relative percent difference (RPD) between the sample and sample duplicate exceeded laboratory control limits
REPORTOF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/09/2015 04:34 PM without the written consent of Pace Analytical Services, Inc.. Page 10 of 13

aceAnalytical
www.pvcoabs.com
. Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project:
Pace Project No.:
WATTS SPINDALE SW
92273668
Analytical
Lab IQ
Sample ID
QC Batch Method
QC Batch
Analytical Method
Batch
92273668001
OU-001
EPA 1664B
GCSV/23097
92273668002
OU•002
EPA 1664E
GCSV/23097
92273668003
011.1•004
EPA 1664B
GCSV/23097
92273668004
OU-006
EPA 1684E
GCSV/23097
92273668001
OU•001
EPA 200.7
MPRP119925
EPA 200.7
ICP/17967
92273668002
OU-002
EPA 200.7
MPRP/19925
EPA 200.7
ICP/17967
92273668003
OU-004
EPA 200.7
MPRP/19925
EPA 200.7
1CP/17967
92273668004
OU•006
EPA 200.7
MPRP/19925
EPA200.7
ICP117967
92273668001
OU•001
SM 2540D
WET/41108
92273668002
OU-002
SM 2540D
WET141108
92273668003
OU-004
SM 25400
WET/41108
92273668D04
OU-006
SM 2540D
WET/41108
Date: 11109/2015 04:34 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 11 of 13

uocument ivame.
ele Condition Upon Recell
Document Number:
F-CHR-CS-003-rev.16
JLJ�:iJI I IGI It r1CY I a cu. IVIClj�
1 iV, F-v ry
Page of 2'
Issuing Authority:
Pace Huntersville Quality Office
Client Name: G` Page 2 of 2 Is for Internal Use Only
Courier: ❑ Fed E UP❑ USP❑ Clier❑ CommerciLl Pace Other Optional
CustodySeal on CoolerJBox Present: ❑ ye ❑ Proj. Due Dote,, `
no Seals intact: ❑ yes ❑ no
Proj. N3rrie:
Packing Material: ❑ Bubble Wrap 0ubble Bags ❑ None ❑ Other
Thermometer Used: IR Gun TC402 Type of Ice: etBlue None amptes on ice, cooling process has begun
Tem Corre ion Factor T14Correction
R Correction
y
Corrected Cooler Temp.: 'C
Biological Tissue is Frozen: Yes No IA
9
Date and Initials of person ex.4mining
contents:�� (a�.�S
nle"-
Temp should be above freezing to 6'C
Comments:
Chain of Custody Present:
es o
❑NIA
1.
Chain of Custody Filled Out:
es No
❑NIA
2.
Chain of Custody Relin wished:
es 1>0
El NIA
3.
Sampler Name & Signature on COC:
EXeS 1>0
❑N/A
4.
Samples Arrived within Hold Time:
es ❑No
DNIA
5.
Short Hold Time Analysis <72hr):
❑Yes o
gWA
6
Rush Turn Around Time Requested:
❑Yes
©NIA
T
Sufficient Volume:
Des
©NIA
g.
Correct Containers Used:
0 es xK'_❑NIA
9.
-Pace Containers Used:
❑Yes ❑No
❑N1A
Containers Intact
❑No
ONIA
10.
Filtered volume received for Dissolved tests
[-]Yes ❑ram
©,
11.
Sample Labels match COG:
D es ©No
❑NIA
12.
-Includes dateltimellD/Anal sis Matrix:
All containers needing preservation have been checked.
I3es ❑No
❑NIA
13•
All containers needing preservation are found to be in
es ❑No
❑NIA
compliance with EPA recommendation.
cly ❑No
exceptions: VOA, coliform. TOC, 0813, W-DRO (water)
9
Samples checked for dechtorination:
C-Yes ©No
©k
14.
Heads ace in VOA Vials ( >6mm):
❑Yes Elmo
IA
15.
Trip Blank Present:
❑Yes ©No
©
18
Trip Blank Custody Seals Present
❑Yes i]Nc
O NIA
Pace Trip Blank Lot # (ifpurchased):
Client Notification/ Resolution:
Person Contacted:
Comments! Resolution:
DateMme:
Field Data Required? Y 1 N
SCURF Reviewj NW4 Date: �}I L _LT Place label here
i
SRF Review: Date:,.+nVV� : 92273668
Note: Whenever there is a discrepancy affecting North Carolina compliance WW 7 68
samples, a copy of this form will be sent to the North Carolina DIzHNR � �� �� �� I Ij �� ��)
Certification Office ( i.e out of hold, incorrect preservative, out of (emp,
incorrect containers) 92273668 -
Page 12 of 13

CHAIN -OF -CUSTODY I Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT_ All relevant fields muss be completed accurately_
Section A Section a Section C
Required Client Information: Required Project Infomiatiorr: invoice Informatian: Page: 1 Of. 1
Company: Walls Water Technolofjes Report To: M,4RXoV4 Attention: t< A/
Address' 100 Watts Rd Copy To. V4Q WLI/ Company Narlle; J,/4 t..J r£J[• MALG61
5 indaie. NC 28160
4)*R . [JI U VV4175 r,, l , c-
Addresc /00 (e%} Jrl Z Q
' -
Elnad: /tj[ • g! lMV j
Purchaso Order 0:
Pace quote:
g5
Pr— 2-9- Y Fax
Project Nsrrrs: S aler jJa ill S
Para Prolecf Managar nicale. siomwski labs.com,
State I Location r '
Requested Due Date:
Project 0:
Pace Profile 0: 7136
r
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Anal
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Pace Analytical Services, Inc.
tic
EaClalytiGal0 9$00 Kincey Ave. Suite 100
Huntersville, NC 2ao79
awwpacdabs.com
[phone]
November 10, 2015
Maroc Kennard
Watts Water Technologies
815 Pickens Street
Chesnee, SC 29323
RE: Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Dear Mark Kennard:
Enclosed are the analytical results for sample(s) received by the laboratory on October 28, 2015.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Nicole Gasiorowski
[e-mail]
Project Manager
Enclosures
A
TNI
RA_�
REPORT OF LABORATORY ANALYSIS
This report shall not W reproduced, except in Full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 11

aceAnalylicai
rnrw.parelabtcam
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Pace Analytical Services, Inc.
9800 Korey Ave. Suite 100
Huntersville, NC 28078
[phone]
Asheville Certification Ids
2225 Riverside Drive, Asheville, NC 28804
FlondalNELAP Certification #: E87648
MaSSachusetts Certification #: M-NC030
North Carolina Drinking Water Certification #: 37712
CERTIFICATIONS
North Carolina Wastewater Certification #: 40
South Carolina Certification #: 99030001
West Virginia Certification #: 356
Urginia(VELAP Certification #: 460222
REPORT OF LABORATORY ANALYSIS
This report shall not be reprMuced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 2 of 11

i
acmnafytical�
..pacwaesmm
ANALYTICAL RESULTS
• Pace Analytical Services, Inc.
9800 KiriM Ave. Suite 100
Huntersville, NC 28078
[phone]
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Sample: ROAD RUN OFF-01 DC Lab ID: 92273665001 Collected: 10/27/15 10:25 Received: 10/28115 11:30 Matnx: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Capper 8.1 ug1L 5.0 1 10/29/15 20:00 11/02/15 19724 7440-50-8
Lead ND ug1L 5.0 1 10/2911520:00 1110211519:24 7439.92-1
Zinc 46.9 ug1L 10.0 1 10/29/15 20:00 11/03/15 21:43 7440-66-6
0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc,.
Page 3 of 11

aceAiaalytl'cal
wwwpaGaWa.cam
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No-: 92273665
• Pace Analytical Services, Inc.
9800 KinceyAve-Suite 100
Huntersville, NG 28078
[phone]
Sample: ROAD RUN OFF-02 OR tab ID: 92273665002 Collected: 10/27/15 10:30 Received: 10128/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET tCP Analytical Method: EPA 200.7 Preparation Method: EPA 2003
Copper 438 ug1L 5.0 1 10129/15 20:00 11/02/15 19A2 7440-60-8
Lead 52.4 ug1L 5.0 1 10129/1520:00 1110211519:42 7439-92-1
Zinc 178 ug1L 10.0 1 10/29/15 20:00 11/03/15 21:51 7440-66.6
Date: 11 / 10/2015 10:54 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 4 of 11

• • Pace Analytical Services, Inc.
1c?C6ft0Ca1" 9800 Kiney Ave. Suite 100
HuntersviEle, NC 28078
www.pacetam.ow [phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALF SW
Pace Project No.: 92273665
Sample: ROOF DRAIN #1 DOCK
Lab lD: 92273665003
Collected: 10/27115 10:05
Received: 10/28/15 11:30 Matrix: Water
Parameters
Results Units
Report Limit DF
Prepared
Analyzed
CAS No. Qual
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
12,D ug1L
5.0 1
10/29/15 20:00
11/02/15 19:46
7440-50-8
Lead
ND ug1L
5.0 1
10/29/15 20:00
11/02/15 19:46
7439-92-1
Zinc
338 ug/L
10.0 1
10{29115 20:00
11103115 21.54
7440-66-6
Date: 11/10/2015 10:54 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 5 of 11

. Pace Analytical Services, Inc.
0800 KinceyAve. Suite 100
aceAnalytieal Huntersvilie. NC 28078
"°' wpaodabsow [phone]
ANALYTICAL RESULTS
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
Sample: ROOF DRAIN #2 EVAP Lab ID: 92273665004 Collected: 10/27/15 10:10 Received: 10/28/15 11:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP Analytical Method: EPA200.7 Preparation Method: EPA200.7
Copper 205 ug/L 5.0 1 10/29/16 20:00 11/02/15 19A9 7440-50-8
Lead 51,2 ug1L 5.0 1 10129i1520:00 1110211519A9 7439.92-1
Zinc 1890 ugfL 10.0 1 10129/15 20:00 11/03(15 21:57 7440.66-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, inc..
Page 6 of 11

•
Pace Analytical Services, Inc.
aceAnalytr"cal a
9800 Kincey Ave. Suite100
Huntersville, NC 28078078
Mww,oe=tab&Wffl
[phone]
QUALITY CONTROL DATA
Project: WATTS SPINDALE SW
Pace Project No.: 92273665
QC Batch: MPRP119925
Analysis Method: EPA 200.7
QC Batch Method: EPA 200.7
Analysis Description: 200.7 MET
Associated Lab Samples: 92273665001, 92273665002,
92273665003, 92273665004
METHOD BLANK: 1595294
Matrix: Water ^
Associated Lab Samples: 92273665001, 92273665002,
92273665003, 92273665004
Blank Reporting
Parameter
Units
Result Limit Analyzed Qualifiers
Copper
uglL
ND 5.0 1110511516:28
Lead
ug1L
ND 5.0 1110511516:28
Zinc
ug1L
ND 10.0 1110511516:28
LABORATORY CONTROL SAMPLE:
1595295
Spike LCS LCS % Rec
Parameter
Units
Conc. Result % Rec Limits Qualifiers
Copper
ug/L
500 504 101 85-115
Lead
ug1L
500 493 99 85-115
Zinc
ug1L
500 485 97 85-115
MATRIX SPIKE 8 MATRIX SPIKE DUPLICATE:
1595298
1595299
MS
MSD
92273665001
Spike
Spike
MS
MSD
MS
MSD
% Rec
Parameter Units
Result
Cone.
Conc.
Result
Result
% Rec
% Rec
Limits
RPD Qual
Copper ug/L
8.1
500
500
480
470
94
92
70-130
2
Lead ug/L
ND
500
500
475
473
94
94
70-130
0
Zinc ug/L
46.9
500
500
495
486
90
88
70-130
2
Results presented on this page are in the unite indicated by the "Units" Column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11110/2015 10:54 AM without the written consent of Page Analytical Services, Inc.. Page 7 of 11

aceAnalytical
www.p&c0batwm
QUALIFIERS
Project: WATTS SPiNDALE SW
Pace Project No-: 92273665
DEFINITIONS
. Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 10o
Huntersville, NC 28078
[phone]
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL-Adjusted Method Detection Limit.
PQL - Practical Quantitation Limit-
RL - Reporting Limit.
S - Surrogate
1,2-Diphenythydrazine decomposes to and cannot be separated from Azobenzene using Method 8270, The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unfounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
Acid preservation may not be appropriate for 2 Chloroethylvinyl ether, Styrene, and Vinyl chloride.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis of Acrolein and Acrylonitrile by EPA
Method 8260.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI - The NELAC Institute.
WORKORDER QUALIFIERS
WO: 92273665
Ill Report revised to remove full analyte list from sample -001. Only Cu, Pb, Zn were requested. Samples -002 through -004
had correct list.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc.. Page 8 of 11

s
ace Analytical
www.pecalab&=n
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Pace Analytical Services, Inc.
9800 KinCey Ave. Suite 100
Hunlersville, NC 28070
[phone]
Project:
Pace Project No.:
WATTS SPINDALE SW
92273665
Analytical
Lab ID
Sample ID
QC Batch Method
QC Batch
Analytical Method
Batch
92273665001
ROAD RUN OFF-01 DC
EPA200.7
MPRPI19925
EPA200.7
ICPI17967
92273665002
ROAD RUN OFF-02 DR
EPA 2007
MPRPl19925
EPA 200.7
ICPI17967
92273665003
ROOF DRAIN #1 DOCK
EPA200.7
MPRPl19925
EPA200.7
ICP117967
S2273665004
ROOF DRAIN #2 EVAP
EPA200-7
MPRPf19925
EPA 200-7
ICP117967
REPORT OF LABORATORY ANALYSIS
This report Shall not be reproduced, except in full,
Date: 11/10/2015 10:54 AM without the written consent of Pace Analytical Services, Inc., Page 9 of 11

uocumen€ rvame:
22ceAwlyfiwl' le Condition U on Recei
Document Number:
' F-CHR-CS-003-rev.16
Ghent Name: �/-t k_er
Courier: ❑ Fed Er❑ UP ' USP❑ Clier❑ Commerci;] Pace Other_
Custody Seal on Cooler/Box Present: ❑ yes ❑ no Seals intact: ❑ yes
Packing Material: ❑ Bubble Wrap ❑ Bubble Bags None ❑ Other
Thermometer Used: IR Gun T 4O2 Type of Ice: oetBlue None
Toms) Correction Factor T1402 No Correction
luuuMGIR nwvlacu. wIay IV, &V I-
I` Page 1 of 2'
Issuing Authority:
Pace Huntersville Quality Office
Page 2 of 2 is for Internal Use Only
❑ no Proj Due,pate'.0 ,.
Proj j;Nanie: 's =
amples on ice, cooling process has begun
Corrected Cooler Temp.: •C
Temp should be above freezing to 6°C
Biological Tissue is Frozen: Yes Na
Comments:
Date and Initials of person examinln _
contents:_, �1(? ly�
Chain of Custody Present:
es
❑NIA
1.
Chain of Custody Filled Out:
EWes ❑
❑NIA
2.
Chain of Custody Relinquished:
es QNo
NIA
3.
Sampler Nance & Signature on COC:
es ❑No
❑NIA
4,
Samples Arrived within Hold Time:
Cries ❑No
❑NIA
g.
Short Hold Time Analysis a72hr :
Dyes
IA
6.
Rush Turn Around Time Requested-,
❑Yes
❑NIA
7.
Sufficient Volume:
❑ es QN6
❑NIA
8,
Correct Containers Used:
-Pace Containers Used:
No
;es,,2036
❑NIA
❑NIA
g,
Containers Intact:
" Yes ON"
❑NIA
10
Filtered volume received for Dissolved tests
Dyes ❑No
❑ IA
11.
Sample Labels match COC:
-Includes dateltime/ID/Anal sis Matrix:
s l-No
❑NIA
12.
All containers needing preservation have been checked.
All containers needing preservation are found to be in
compliance with EPA recommendation.
ezoepVons: VOA, cogform, TOC, O&G-1M-DRO (water)
es o ❑NIA
Yes ❑No ❑NIA
©Yes
13.
Samples Checked for dechlorinatien:
❑Yes ❑No
1A
Heads ace in VOA Vials ( >6mm):
Dyes ❑No
d 1A
Trip Blank Present:
Trip Blank Custody Seals Present
Pace Trip Blank Lot # (if purchased):
❑Yes ❑No
Dyes ❑No
13 1A
0141ZA
46,
Client Notification/ Resolution: Field Data Required? Y 1 N
Person Contacted: Date/Time:
Comments/ Resolution:
SCURF Review:1 ' Date: �f f 'L�-• 15 {
SRF Review: I A Date:��,�
Note: Whenever there Is a discrepancy affecting North Carolina compliance
samples, a copy of this form will be sent to the North Carolina DEHNR
Certification Office ( l.e out of hold, incorrect preservative, out of temp,
Incorrect containers)
W071 :92273665
1111111111111111111
92273565
13, rry vaoei available)
Page 10 of 11

CHAIN -OF -CUSTODY l Analytical Request Document
�..- The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Section A Section a Section C
Required Client Intomoation: Required Project hdomration: Invoke bdamation: Pa @ : 1 Of 1
Cerny: Watts Water T ies Report To: Mark Kennard Attention: yy�,Jy�
Address: 100Watts Rd- Copy Ta: 00 WA(LU U Company Name'r✓A A NO4-66I43'
S irTdalo, NC 28160
!1 a S./ .fD
s: lt70 W /UG 2B t'oD
.. RegReguMbn Agericy- -
Email:r*Qt% e w S u Can
Purchase Orderlk
Pace Quote:
Ph-w: 7_ 9tj $ Fox
Project Name: er Mf t:P1N 5LJ
Pace Project Manager. nicalo,9asior&m&M@pnceIabSLMM
Stater Location
Reciumted Due Date:
Project e:
Aare Profile e: 713s-3
Requested
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Ventaloro, Julie
From: Fulkerson, Mike ([e-mail]
Sent: Wednesday, September 10, 2014 8:29 AM
To: Ventaloro, Julie
Cc: Kennard, Mark A. ([e-mail])
Subject: Watts Regulator - Spindale Facility
Julie,
Thank you for the time yesterday to discuss the Watts Facility in Spindale. As requested, I have provided the correct site
contact as well as the name and title of the new responsible person for the site.
Communication for most matters:
Mark Kennard (Ovi -L La>A-q c4--
EHS - Watts Water Technologies 1,,4-- CA-,q t L(-
100 Watts Road, Spindale, NC 28160 6► ``
W [phone]
M [phone]
Responsible Person (f--(A Gt eq +)
Alice Gaulin, Facility Manager
As we discussed the site has made some internal changes which led them to not want to pursue the rescission of the
current NOI. URS will be assisting the site in collecting stormwater samples per their SWPPP in the near future.
Should you have any questions or need additional information please contact Mark or me at your convenience.
Thank you,
Mike Fulkerson, J.D. I Senior Environmental Scientist
URS Corporation -North Carolina
6000 Fairview Road, Suite 200
Charlotte, NC 28210
(Direct) 704.716.0768
(Main) 704.522,0330
(Cell) 704.746.7041
(Fax) 704.522.0063
[e-mail]
www.urs.com
This e-mail and any attachments contain URS Corporation confidential information that may be proprietary or privileged. If you
receive this message in error or are not the intended recipient, you should not retain, distribute, disclose or use any of this
information and you should destroy the e-mail and any attachments or copies.

Ventaloro, Julie
From: Fulkerson, Mike (mike,[e-mail])
Sent: Monday, September 08, 2014 3:32 PM
To: Ventaloro, Julie
Subject: Notice of rescission for Watts Regulator - Spindale facility
Julie,
i apologize our phones got disconnected and you received half a message from me today. Our client Watts Regulator
has decided to not seek rescission for their Spindale facility and will be collecting samples to fulfill the requirements of
their stormwater permit and SWPPP. If you have time tomorrow or Wednesday I would like the opportunity to discuss
the site so 1 can make sure my client understands and satisfies that applicable regulatory requirements.
Thank you,
Mike Fulkerson, J.D. I Senior Environmental Scientist
URS Corporation -North Carolina
6000 Fairview Road, Suite 200
Charlotte, NC 28210
(Direct) 704.716.0768
(Main) 704.522.0330
(Cell) 704.746.7041
(Fax) 704.522.0063
mike,[e-mail]
www.urs.com
This e-mail and any attachments contain URS Corporation confidential information that may be proprietary or privileged, If you
receive this message in error or are not the intended recipient, you should not retain, distribute, disclose or use any of this
information and you should destroy the e-mail and any attachments or copies,

Aold � ,
� e
�Y,V; 19 / "

'a
Division of Water (duality i Surface Water Protection
National Pollutant Discharge Elimination System
NCDENR
RESCISSION REQUEST FORM
FOR AGENCY uSE ONLY
Date Received
Year
Month
Da
Please fill out and return this form if you no longer need to maintain your NPDE5 stormwater permit.
1) Enter the permit number to which this request applies:
Individual Permit (or) Certificate of Coverage
N I C S N I C I G 1 D L3.1 0 1 2 1 5 1 3
2) Owner/Facility Information: • Final correspondence will be mailed to the address noted below
Owner/Facility Name Watts Water Technologies =S indale
Facility Contact Mr. Mark Kennard, EHS Specialist
Street Address 100 Watts Road
City Spindale _ _ State NC ZIPCode h$ Q
County Rutherford E-mail Addresser
Telephone No. 828 447-3998 Fax: _(8281286-3892
31 Reason for rescission request (This is required information. Attach separate sheet if necessary):
❑ Facility closed or is closing on l.,4%1`1 All industrial activities have ceased such that no discharges of
stormwater are contaminated by exposure to industrial activities or materials.
❑ Facility sold Eo . ` " "a on _' If the facility will continue operations under the new owner it
may be more appropriate to request an ownership change to reissue to permit to the new owner.
® Other: The facility previously operated as a metal fabrication operation. Around 2010, the sfte
ceased operating and is now used for warehousing products made offsite. Due to the use change, the
appropriate SIC code that subjected the site to stormwater coverage is no longer applicable.
4) Certification:
I, as an authorized representative, hereby request rescission of coverage under the NPDES Stormwater Permit for the
subject facility. I am familiar with the information contained in this request and to the best of my knowledge and belief
such information is true, complete and accurate.
Signature _ ZZ& Date & - 6 - l q
?L/ KC�vAjgKo CNS &) .
Print or type name of person signing above Title
Please return this completed rescission request form to: SW NPDES Permit Coverage Rescission iDIWAQUAL
�
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 JUN4
1617 Mari Service Center, Raleigh, North C=Una 27699.1617
Location. 512 N. Salisbury St Raiegh, North Carolina 27W4 011e - >ti
Phone 91MG7-63001 FAX 919�_ 07-6492 %Customer Sere m 1-a77-823 6748 NorthC, amrX
Internet. mvw.r,4yrdterquaiity.org �%lll'ltl'11��f
An EQual OppD tarty 1 Affimi4n ACtW Employe+

Ventaloro Julie
From.
uentaioro, ,Julie
Sent:
Monday, July 21, 2014 9:12 AM
To:
I mark. ken na rd (Owa ttswater. corn'
Cc.
Alexander, Laura; Herbert, Laura C; Kucken, Darlene
Subject:
Rescission Request Stormwater Permit NCG030251.
Mr. Kennard,
It was nice talking with you earlier. As we discussed, we are going to hold open your request to rescind Stormwater
Permit No. NCG030251, Watts Water Technologies - Spindale. There are remaining industrial materials onsite that must
be removed before your permit can be rescinded. This includes a tank containing oil. I understand you will locate a
recycler for the oil and contact me once the materials have been removed.
Please let me know if you have any questions.
Thank you,
Julie Vencalorc
Storm vazer Permitting Program
NC Dirrision of'linergy,, Mineral, wid Land Resources
1612 Marl Service Center, Raleigh, NC 27699-1612
PhO!'t: [phone] Fax: [phone],194
Wel)site: trtfi�rlfwatersa��ywatershed.nc.e
E-mail correspondence to and farm Niis address may he subject to the North Carolina Public Records Low and may be discloser) to third
Parties.

Ventaloro, Julie
From:
Bennett, Bradley
Sent:
Tuesday, July 15, 2014 4:21 PM
To:
Pickle, Ken, Ventaloro, Julie
Cc.
Alexander, Laura
Subject:
FW: Message from "RNP0026733F34F1"
Attachments:
IMG 5705.JPG
Follow Up Flag:
Follow up
Flag Status,
Flagged
Ken, Julie
Take a look at the response below. Looks like maybe we should work to deny the rescission
and keep the permit in place. Julie - could you touch base with Darlene and make sure of
this and then work with Laura to get the response together.
Thanks
BB
Bradley Bennett
Stormwater Permitting Program Phone:
[phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email:
bradley..bennettoncdenr.eov_
Raleigh, NC 27699-1612 web:
htt ortal.ncdenr.or web lr stormwater
Email correspondence to and from this address may be subject to public records laws
-----Original Message -----
From: Alexander, Laura
Sent: Thursday, July 10, 2014 7:54 AM
To: Bennett, Bradley
Subject: FW: Message from "RNP0026733F34F1"
Good Morning Bradley!
I wanted to pass this information on to you! Let me know if there is something I can do to
help.
Thanks!
Laura
----- Original'Message-----
From: Kucken, Darlene
Sent: Wednesday, July 09, 2014 4:42 PM
To: Alexander, Laura
Cc: Herbert, Laura C
Subject: RE: Message from "RNP0026733F34FI"
f

i _ R
Hi Laura('s),
I went by this site on 7/7/14 to review the overall site conditions. I did not make an
appointment and set up an internal inspection. It does appear that the facility no longer
does production as there are shipping trucks pulling in and out to loading docks.
The one question I would ask of the facility contact is what the containers are for outside
(see attached photo). There are fluids in these containers and they are in secondary
containment. However, the secondary containment does not appear to get pumped out and there
is standing water several inches deep that is thick with slime and I'm not sure what else.
Let me know if you need anything else.
Darlene Kucken - [e-mail] North Carolina Dept. of Environment and Natural
Resources Asheville Regional office Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
P Go Greenl Print this email only when necessary. Thank you for helping NCDENR be
environmentally responsible.
-----Original Message -----
From: Herbert, Laura C
Sent: Wednesday, June 25, 2014 5:53 PM
Ta: Kucken, Darlene
Subject: FW: Message from "RNP0026733F34F1"
Darlene,
Please put this on your ride by list to see if the facility is indeed closed. Let Laurie
know what you find.
Thanks,
Laura
From: Alexander, Laura
Sent: Wednesday, June 25, 2014 2:23 PM
To: Herbert, Laura t
Cc: Alexander, Laura
Subject: FW: Message from "RNP0026733F34F1"
Good Afternoon Laura!
I received a rescission request for NCG030251, facility name is Watts Water Technologies -
5pindale. Please let me know when this is okay to rescind.
Thank youl
Laura Alexander
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
2

sr.
ON

Herbert, Laura C
From: Herbert, Laura C
Sent: Monday, January 06, 2014 12:11 PM
To: [e-mail]'
Cc: Stepp, Jonathan; Kucken, Darlene
Subject: Watts Regulator (NCG 030251) SIC 4225 General Warehouse and Storage
Jennifer,
Thank you for your inquiry regarding whether or not Watts Regulator (NCG030251) continues to need a general
stormwater permit for this site, now that manufacturing operations have ceased and this facility is being used as a
warehouse for inventory only. See guidance from our Ken Pickle in our Raleigh Central Office (below) and let us know if
you have any questions. As you can see, the answer to your question depends on the specifics of the current
warehousing operation. Please review the guidance below and let us know your conclusions.
Regards,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Ashevilie Regional Office
2090 U5 Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the `orth Carolina Public Records Low and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Pickle, Ken
Sent: Thursday, January 02, 2014 4:54 PM
To: Herbert, Laura C; Georgoulias, Bethany; Stepp, Jonathan
Cc: Bennett, Bradley
Subject: RE: SIC 4225 General Warehouse and Storage
Hi Laura,
Based on the limited amount i know now, i don't think they need our permit at this location, anymore. They should send
in a request to rescind the permit.
Warehousing is one of the more convoluted SIC codes we deal with. I always have to go back and re -read the source
materials to come to what I think is an answer.
OK so startinp with the federal rule for our program at 40 CFR 122.26 b 14 :
SIC 42 (except 4221-4225) is categorized as a Transportation sector industrial activity that requires a permit, if
they have vehicle maintenance activities. See 40 CFR 122.26(b)(14)(viii). There is really only one SIC code left
once you remove SIC 4221-4225, and that is SIC 4226, Special Warehousing. Things like Fur storage, Foreign
Trade Zone storage, Whiskey warehousing, and few others. I don't think this SIC fits, and so our federal rule

category (viii) doesn't fit, either, for the way these folks operate now. So, it looks like our General Permit NCG08
Transportation is not a fit.
• However, SIC 4221 —4225 are captured as industrial activities later on in the same section, under 40 CFR
122.26(b)(xi). So, if the consultant is correct as to the SIC code, they are still captured and a permit is required.
However, I'm not sure the consultant has it right wrt SIC 4225.
o A part of the SIC code framework is the idea that the coded businesses are more or less independent
commercial businesses, offering warehouse space to whoever will rent it. That doesn't sound like our
circumstance. This sounds like a inactive manufacturing facility that is now an internal company
depot. I think the critical aspect is probably whether or not they really have ceased all manufacturing at
this site.
o Also, I see that the listed businesses under SIC 4225 can be things like mini -warehouses and self -storage
warehouses.
The next resource I eo to is tvoically the 1992, 1993 two volume EPA Q&A document that came out when the NPDES
industrial stormwater program was initiated.
• Per 1992 Volume 1, Question 55, "Is an offsite warehouse associated with a regulated industrial faciiit
required to submit an application? No. As stated on page 48011 of the preamble to the November 16, 1990
rule, warehouses of either preassembly parts or finished products that are not located at an industrial facility
are not required to submit an application unless otherwise covered by the rule." The 'application' referred to
here is on application for a stormwater permit, which is the way the federal rule identifies who is covered by the
rule — those folks that have to submit an opplication.
So, consider the following possible cases, and our presumed response:
o Are they still doing some manufacturing at the 'warehouse'? Then they still need our permit.
o Is the warehouse co -located or adjacent to the parent company's manufacturing activity? Then they still
need our permit.
o Is this a commercial warehousing business? Then, strictly speaking, they may need our permit. And
maybe we would seek to retain our current permittee as the permit holder, since he might be in control
of the day-to-day operation at the site, whether he owns the warehouse, or not. But, I don't think this is
the case you have described.
o So, as I imagine the circumstances, it sounds to me like the 1992 EPA Q&A document speaks directly to
the circumstances and no permit is required.
Ken
Ken Pickle
Environmental Engineer
NCDENR ! DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]

Email: [e-mail]
Website: htto://portal.ncdenr.org/web/ir/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Herbert, Laura C
Sent: Thursday, January 02, 2014 3:29 PM
To: Georgouiias, Bethany; Pickle, Ken; Stepp, Jonathan
Subject: SIC 4225 General Warehouse and Storage
Bethany and Ken,
Just had a call from a consultant for Watts Regulator (NCG030251) in Rutherford County. They have changed their
operation and now fall under the SIC code 4225. The consultant indicated that this is all they do (storage of inventory)
do not see a general hermit requirement for this SIC but wanted to confirm with RCO. If a permit is not required, do
they just need to send in a letter requesting that their permit be rescinded with an explanation? The consultant also
asked if they needed an SPPP if they didn't have a permit. I told her we would encourage it, but that it would not be
required by us.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://Portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.

A
��
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P.S.
Governor Director
Mark Kennard
Watts Regulator
100 Watts Road
Spindale, NC 28160
April 30, 2013
John E. Skvada, III
Secretary
Subject: Permit Application Return
Permit NCG030000
Rutherford County
Your request for New Stormwater General Permit coverage received on April 8, 2013 is being returned due to:
❑ Check for $100.00 made payable to NCDENR is missing.
❑ Application is incomplete.
❑ Application package is missing the supporting documents,
❑ Missing copy of county map or USGS quad sheet with facility clearly marked.
VOther After discussions with you it appears that the facility is already covered under NCG030251
and this application is not needed. We are returning your NOI and your check for $100,
If you have any additional questions, please contact Bradley Bennett at 919-807-6378.
cc:
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Rafegh, !North Carolina 27604
Rhone: 9IM07-63001 FAX: [phone] Customer Service: 1-877-62M748
Intemet: www.ncwaterquality.org I
An Eqbal Opportunity 1 Aff rrnativa Action Employer
h_ loirthCarolina
,Naturall,�

IWWAM 815 CHESTNUT ST.
115783 NO. ANDOVER, MA 01845
NCDENR -
764-833
CHECK NUMBER
03/29/13 764833
INVOICE'DATE
-INVOICE NUMBER
VOUCHER NUMBER
GROSS AMOUNT
DISCOUNT
NET AMOUNT
03/22/13
NCG030000
1642122
100.00
0.00
100.00
TOTALS
100.00
0.0
100.00
tie 761.8331I' e.053 10156 L1:20799850683 291I'

�WA17W
WATER TECHNOLOGIE
S
R e g t r o I F a e i I I t y 100 Waits Road + Spindale, KC • 28160 • Tel. [phone] • Fax: [phone]
March 22, 2013
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
_ _ Subject__ NCG030000 Notice Of Intent_
Watts Regulator — Spindale Facility, 100 Watts Road, Spindale, NC ------
Dear Division of Water Quality,
Please find enclosed a check for $100 made payable to NCDENR and a completed Notice of
Intent for coverage under the North Carolina General Industrial Storm Water Permit
NCG050000 for the Watts Regulator Spindale Facility located in Spindale, North Carolina.
This Notice of Intent is being submitted by Mark Kennard on behalf of the Watts Regulator
Spindale Facility. Please call me at [phone] if you have any questions or if you need any
additional information.
Sine ely
Mark Kennard
Watts Water Technologies
Enclosures
Innovative Water Solutions Since 1874

Division of Water Quality / Surface Water
' •
Protection Section
NC®ENR
National Pollutant Discharge Elimination Svstem
'^. - GAcaw... C%JYJ EM or
FNvmNwl'rt N1n Naxx1.V . IY:.nA^l0
NCG030000
NOTICE OF INTENT
FOR AGENCY USE ONLY
Date Received
Year
tvlonth
Da
Certificate of Covers e
3
Check #�
Amours[
Pcruut Assi ned to
National Pollutant Discharge Elimination System application for coverage under General Permit
NCG030000:
STORMWATER DISCHARGES associated with activities classified as:
SIC (Standard Industrial Classification) 335 Rolling, Drawing, and Extruding of Nonferrous Metals
SIC 3398 Metal Heat Treating
SIC 34 Fabricated Metal Products
SIC 35 Industrial and Commercial Machinery
SIC 36 Electronic and Other Electrical Equipment
SIC 37 Transportation Equipment
SIC 38 Measuring, Analyzing, and Controlling Instruments
ZaFor questions, please contact the DWO Regional Office for your area. See page 4.
(Please print or type)
1) Mailing address of owner/operator (address to which all ermit correspondence will be mailed):
Name Watts Regulator
Street Address 100 Watts Road
City Spindale State NC ZIP Code 28160
Telephone No. 828 429-5452 Fax:
2) Location of facility producing discharge:
Facility Name Watts Regulator
Facility Contact Mark Kennard
Street Address 100 Watts Road -
City Spindale State NC ZIP Code 28160
County Rutherford County
Telephone No. 828 447-3998 Fax:
Email kennarma[Qawatts.com
3) Physical Location Information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). coming from US-74AIt W, take the Spindale exit. Turn right on Oakdale Road.
Travel for 112 mile on Oakdale Road. Turn right on Watts Road. Facility is on the left.
(A copy of a county map or USGS quad sheet with the facility clearly located must be submitted with this
4) Latitude 35' 21' 3.136"
Longitude -81° 54' 44.498"
(deg, min, sic)A P.R
Page 1 of 4
SWU-218-071408 Last revised 7/14/08

t
NCG030000 N.O.I.
5) This NPDES Permit Application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
a Existing
6) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility.
SIC Code: 3 4 9 4
7) Provide a brief narrative description of the types of industrial activities and products manufactured at
this facility: Brass Valve manufacturing
8) Discharge points 1 Receiving waters:
How many discharge points (ditches, pipes, channels, etc.) convey stormwater from the property? 7 outfalls
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility.stormwater
discharges end up in? Unnamed tdhutary of Brackett's Creek
Receiving water classification: ws-iv
Is this a 303(d) listed stream? No Has a TMDL been approved for this watershed? No
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm
sewer system (e.g. City of Raleigh municipal storm sewer).
9) Does this facility have any other NPDES permits?
✓❑ No
❑ Yes
If yes, list the permit numbers for all current NPDES permits for this facility: operates under General Permit NCGa30000.
10) Does this facility have any Non -Discharge permits (ex: recycle permit)?
❑✓ No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
11) Does this facility employ any best management practices for stormwater control?
❑ No
❑� Yes (Show any structural BMPs. on the site diagram.)
It yes, please briefly describe. All manufacturing and raw material storage is inside of the facility.
Waste minimization practices are in place at the facility.
12) Does this facility have a Stormwater Pollution Prevention Plan?
❑ No
El Yes
It yes, when was it implemented? zone
13) Are vehicle maintenance activities occurring at this facility?
❑� No ❑ Yes
14) Hazardous Waste:
a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
No ❑ Yes
Page 2of4
SWU-218-07140a Last revised 7114/08

NCG030000 N.O.I.
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of
hazardous waste? i
❑ No ❑ Yes
c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous.waste generated per month) of
hazardous waste?
ONo ❑ Yes
d) Is hazardous waste stored in the 100-year flood plain?
21 No ❑ Yes If yes, include information to demonstrate protection from flooding_
--- e)--If-you-answered.yes-to.questions.b. or-c., please. provide -the following information:_
Types) of waste:
How is material stored:
Where is material stored.
How many disposal shipments per year:
Name of transport / disposal vendor: _
Vendor address:
15) Certification:
North Carolina General Statute 143-215.6B (i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report,
plan, or other document filed or required to be maintained under this Article or a rule implementing this Article; or who
knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article; or
who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be
operated or maintained under this Article or rules of the commission implementing this Article shall be guilty of a Glass 2
misdemeanor which may include a fine not to exceed ion thousand dollars ($10,000).
I hereby request coverage under the referenced General Permit. 1 understand that coverage under this permit
will constitute the permit requirements for the discharge(s) and is enforceable in the same mariner as an
individual permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing: Marx Kennard
Title: EHS
Ald_4�1r_ 4Z 4 _/Z
(Signature of Applicant) (Date Signed)
This Notice of Intent must be accompanied by a check or money order for $100.00, made payable to:
NC©ENR
Page 3 of 4
swil-218-071408 Last revised 7/14/08

NCG030000 N.O.I.
Final Checklist
This application will be returned as incomplete unless all of the following items have been included:
.11
ff Check for $100 made payable to NCDENR.
L?" This completed application and all supporting documents.
Cg' A site diagram showing, at a minimum, (existing or proposed):
(a) outline of drainage areas, (b) stormwater management structures, (c) location of stormwater outfalls
corresponding to the drainage areas, (d) runoff conveyance features, (e) areas where materials are stored,
(f) impervious areas, (g) site property lines.
[� Copy of county map or USGS quad sheet with the location of the facility clearly marked on the map.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee coverage under the General Permit.
For questions, please contact the DWO Regional Office for your area.
DWQ Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office
... [phone]
Mooresville Office
... [phone]
Raleigh Office ........ [phone] {
Washington Office 946-6481
...(252)
Wilmington Office
... [phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 4 of 4
SWU-218-071408 Last revised 7114108

NC® NR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Watts Regulator
100 Watts Rd
Spindale, NC 28160
Dear Permittee:
Division of Water Quality
Charles Wakild, P. E.
Director
December 4, 2012
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Watts Regulator
COC Number NCG0302S1
Rutherford County
In response to your renewal application for continued coverage under stormwater General Permit NCG030000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCG030000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://portal.ncdenr.org/web/wq/ws(su/npdessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Ralegh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.acwaterquality.oro
An Equdi Opportunity l Affirmative Actr n Employer
NorthCzu•olina
Naturally

December 4, 2012
Page 2 of 2
Some of the changes include:
• Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections B, C: Failure to perform analytical Stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections B, C: A lower TSS benchmark of 50 mg/I for HOW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections B, C. The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections B, C. The term "Representative Storm Event" has been replaced by "Measurable Storm
Event." A measurable storm event is defined in the permit.
• Section D: If the permittee fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal re 4uest prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,
for Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files
Asheville Regional Office
V

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
D[VISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030251
STORM WATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Watts Regulator
is hereby authorized to discharge stormwater from a facility located at:
Watts Regulator
100 Watts Rd
Spindale
Rutherford County
to receiving waters designated as Stonecutter Creek, a class C waterbody in the Broad River
Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, 111, and IV of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 4thday of December, 2012,
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

iAV
4 ` • ' FILE'
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
February 3, 2010
Ken Ledoux
Watts Regulator
100 Watts Rd
Spindale, NC 28160
Division of Water Quality
Coleen H. Sullins
Director
Subject: NPDES Stormwater Permit - Representative Outfall Status Approval
Permit No. NCG030251
Watts Regulator
Rutherford County
Dear Mr. Ledoux:
Dee Freeman
Secretary
Division of Water Quality staff have reviewed your request for representative outfall status at the
subject facility. Based on a site visit and information provided, the request has been approved
and is effective with the next sampling event.
In accordance with 40 CFR § 122.21(g)(7), you are authorized to sample the outfalls as described
in the following table.
Representative Stormwater
Discharge Outfall (SDO)
SDOs Represented
001
001
002
002
004
003, 004, 005
006
006,007
Please note: the permit still requires Qualitative Monitoring be performed at all SDOS,
regardless of representative status.
Please remember that any actions you initiate in response to benchmark exceedances as directed
in the tiered response provisions of your permit must address all drainage areas represented by
the SDO, where appropriate.
Location: 2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www,nrwaterQuatity.org
An Fmral nnnnrtunity 1 Affirmative Ao;nn Emnlaver
One
NortliCardiha

we
Ken Ledoux
February 3, 2010
Page 2 of 2
Please append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit to
document that representative outfall status has been approved. If changes in drainage areas,
structures, processes, storage practices, or other activities occur that significantly alter the basis
of this approval, representative outfall status may no longer be valid. You should either resume
sampling at all SDOs, or reapply to this office for representative outfall status based on updated
information. if you have any questions or comments concerning this letter, please contact
Chuck Cranford at [phone] or [e-mail]
Sincerely,
Roger C. Edwards, Regional Supervisor
Surface Water Protection
Asheville Regional Office
cc: Regional Office Copy
Central Office/Stormwater Permitting Unit
Central Files

r
Regtrol Division
100 Watts Road • Spindale, North Carolina 28160
Telephone [phone] • Fox [phone]
January �. 2010
North Caroline Deparunent of Environment andNatural Resources
Division of"Water Quality
Stornilvater PeL-Mii'till-? Unit
512 N. Salisbury Street
Ralei�-h. North Carolina 27604
Attention: Mr. Bradley Bennett, Stormwater Unit Supervisor
RE: Representative Stormwater OutfallRequest
Watts- Rew=ulator—Spindale Facility
TOO !'Watts Drive
Spindale. North Carolina
General Permit No. NCG030000. Certificate of Coverage No. NCGO0251
Dear Mr. Bennett:
The purpose ofth is letter is to`petition the North Carolina Department of Environment and Natural Resources
("NC DEN R") for representative outfal I status for four outfalls at the referenced facility. This petition is bein�k)
submitted in accordance with Part [I] Section D.6 of the referenced permit.
The relcrenced facility has multiple discharge locations with substantially identical storrmvater discharges.
These storm waterdischarue locations(ontfalls) are required to be sampled under the referenced permit. The
Watts Rev'uiaror-Spindale Facility believes that OutfalIs001, 002, 004 and 006 are representative ofal I ofthe
stormwater outfalls at the facility. Descriptions of the drainage zones foeach outfall are included below-
1. Drainane Area #1 Outfall 001):
Proposed Representative Outfall
This drainage zone collects storm waterrunoff from the eastern endof the property, including drivetvaN
runoff. Storm water is directed into storm water catch basins and is piped to the drainage ditch along
Watts Road at Outfall 001. The discharge from Oufall 001 flows tinder Watts Road and into the unnamed
tributary ofBracketts Creek located to the southof the facility property,
Total Drainage Area:
,o Impervious:
% Pel'V[OUS:
I,.ongitude/Latitude of Outfall 001:
Nlarcrial Storav+e Areas:
Load lni=/Unload im, Areas:
Process Areas (inside building):
laud/Particulate Generating Equipment:
Waste 1-landlin,- Equipment_
105,800 ft'
75%
25%
350 217 02" N 81 ° 54' 39" W
None
Raw material loading and unloading
Brass valve production area
None
Empty drum storage

Mr. Bradlee Bennett
January 5, 2010
Pao
e 2
2. Drainaae Area #2 (Outfall 002):
Proposed Representative Outfall
This drainage zone collects storm water runoff from the central part of the Regtrot building, includitn�,:
driveway runoff. Storm water is directed into storm water catch basis and is piped to the drainage ditch
alone Watts Road at Outfall 002. The discharge from Outfall 002 flows under Watts Road and into the
unnamed tributary ofBrackctts Creek located to the southof the facility property.
Total Drainage Area:
% Impervious:
% Pervious:
Lon-itude/Latitude of Outfall 001:
Material Storage Areas:
Load ing/Utnloading Areas:
Process Areas (inside building):
DUst/Particulate Generating Equipment:
Waste Handling Equipment:
3. DrainaM Zone 43 (Outfall 003).-
--13,900 W
80%
20%
35021'01"N 81054'43"W
Two Waste oil tanks.
Two Hydraulic fluid tanks,
Waste oil loading. Hydraulic fled
Unloading. Raw Material loading and unloading
Brass valve production area
None
None
This drainage Zone collectsstontn water runoff front a snnallportion of the eastern side of the property,
including roof drainage and driveway runoff. Stoa'nt water is directed into stoma water catch basins and is
piped to the drainage ditch along Watts Road at Outfall 003. The dischar�g-cfronn Outfall 003 flo.vs under
Watts Road and into the unnamed tributary of Bracketts Creek located to the south of the facility property.
'total Drainage Area:
% Impervious:
% Pervious:
L0111Mtrrde/Latitude of Outfall 0M:
�1laterial Storatc Areas (all inside building)
Loading/Unloading Areas:
Process Areas (inside buildin�ty):
Waste Handling Equipment:
---18,800 W
90%
10%
35° 21' 01 " N 81 ° 54' 45" W
Raw materials storagc,
Raw materials unloading
Brass valve production area
Solid waste compactor and coveredroll off
4. Draina a Zone #4_(Outfall 004): Proposed Representative Outfall
(to represent 003, 004 &. 005)
']'his drainage zone collects stornn water runoff from a large portion of the eastern side of the property,
including roof drainage and driveway runoff. Storm water is directed into storm water catch basins and is
piped to the drainage ditch along Watts Roadat Outfall 004. The discharge from Outfall 004f1ows under
Watts Road and into the unnamed tributary of Bracketts Creek looted to the south ofthe facility property.
Total Drainage Area:---44,650 fe
% Impervious: 90%
% Pervious: 10%

Ow
* 0
Mr. Bradley Bennett
January 5.2010
Page 3
Longitude/Latitude of Outfall 003:
Material Storage Areas:
Loading/Unloading Areas:
Process Areas (inside building):
Waste Handling Equipment:
5. Drainalze Zone ##5 (Outfall 005):
350 21' 02" N 810 54' 48" W
Raw materials storage, empty drtni storage,
electrical transformers
Raw materials unloading, empty drum loading,
Brass valve production area and warehouse area
Solid waste compactor and eoveredroll off
This drainage zone collects storm water runoff from a sntalleentral portion of the property, including roof
drainage and driveway runoff. Stone water is directed into storm water catch basins and is piped to the
drainage ditch along Watts Roadat Outfall 005. The discharge from Outfall 005flows under Watts Road
and into the unnamed tributary of Bracketts Creek located to the south of the facility property.
Total Drainage Area:
% Impervious:
% Pervious:
Longitude/Latitude of Outfall 004:
Material Stora+llc Areas:
Loading/Unloading Areas:
Process Areas (inside building):
Waste Handling Equipment:
19,070 ft'
90%
10%
35021'02"N 81054'5i"W
Raw materials storage
Raw materials unloading
Warehouse area
None
6. Draina<(e Zone 46 (Outfall 006): Proposed Representative Oufall
(to represent 006 & 007)
This drainage zone collectsstorm water runoff from a largecentral portion of the property, including roof
drainage and driveway runoff. Storm watar is directed into storm water catch basins and is piped to the
drainage ditch along Watts Roadat Outfall 006. The discharge from Outfall 006flows under Watts Road
and into the unnamed tributary of Bracketts Creek located to the south of the facility imperty.
Total Drainage Area:
% Impervious:
% Pervious:
Longitude/Latitude of Outfall 005:
Material Storage Areas:
Loading/Unloading Areas:
Process Areas:
Waste Handling Equipment:
—177,050 fe
95%
5%
350 21' 03" N 81" 54' 55" W
Raw materials storage, plastic storage silos; used
oil containers (empty propane tank, sand
storage
Raw materials unloading, finished products
loading, plastic unloading, used oil loading, iuew
oil unloading
Plastics manufacturing area, warehorse area
Wood recycling containers metal recycling roll
off, molded process sand containers

40 4P
* 0
Mr. Bradley Bennett
January 5, 2010
Page 4
7. Drainage Zone 97 (Outfall 007):
This drainage zone collects storm water runoff front [lie western portion of the property, including roof
drainage and driveway runoff Storm water is directed into storm water catch basins and is piped to the
drainage ditch along Watts Roadat Outfall 007. The discharge from Outfall 007flows under Watts Road
and into the unnamed tributary of Bracketts Creek located to the south of tb facility property.
Total Drainage Area:
% Impervious:
% pervious:
Lon <gittide/Latittide of Outfall 006:
Material Storage Areas:
Loadin-/Unloading Areas:
Process Areas (inside building):
Waste Handling Equipment:
—37,730 ft'
80%
20%
350 21' 04" N 810 54" 59" W
Finished products storage
Finished products loading
Warehouse area
Solid waste compactor and covered rolloff
As can be seen above, OLItfalls 001, 002, 004 and 006 are representative of all of the site operations and of
the potential significant exposed materials at the faeility.With this letter; the Watts Regulator— Spindale
Facility respectfully requests that NC DENR grant representative Outfall status for Oitfalls 001, 002, 004
and 006, and that analytical sampling requiements be reduced to only these outfalls.
lfyou have any questions or require additional information lease contact me at828-286-8882,
Sincerely,
WATTS RF.GULA'rOR
Ken Ledoux
Safety & Environmental Manager

NCB N F I L r
North Carolina Department of Environment and Natural Resources � 4
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
December 17, 2009
Ken Ledoux
Watts Regulator
100 Watts Rd
Spindale, NC 28160
SUBJECT: NPDES Stormwater Permit Compliance Inspectionl
Watts Regulator
Permit No: NCG030251
Rutherford County
Dear Mr. Ledoux:
This letter is in follow-up to the NPDES Stormwater Permit Con-ipliarice Inspection conducted on
November 17, 2009. "1`he f�icility was found to be in conipliance with permit NCG030251.
Enclosed is a copy of the Compliance Inspection Report, which contains additional observations
and comments for your referetice.
Please contact me at [phone] or cliuck.crarnfordLabiedcf1r.ov , if I can be of any fbrtl}cr
assistance.
Sincerely,
Chuck Cranford
Environmental Specialist
Surface Water Protection
Enclosure
cc: Central Files
Asheville Files
Jimmy Summers URS (e-copy)
G_1WPDATAIDEMWQ\RutlierrordlStormwater Metals t4CG031WausRegttlator\CE!_12-16-09.doc
Location: 2090 U.S. Hipway 70 5wannanoa, North Carolina 28778
Phone: [phone] FAX: [phone] Ctistamer Service: 1-877.623-6748
Internet: www.numlerquality.org
, An Equal Upporlunity 1 AYrmative Auion Empicyer
One
NorthCar.�oli.na
,/Vaturally

ow
•0
Cornpliance inspection Report
Permit: NCG030251 Effective: 11/01/07 Expiration: 10/31/12 Owner: Watts Regulator
SOC: Effective: Expiration: Facility: %Plaits Regulator
County: Rutherford 100 Watts Rd
Region: Asheville
Spindale NC 28160
Contact Person: Ken Ledoux Title: Phone: [phone]
Ext.134
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 11/17/2009 Entry Time: 09:30 AM Exit Time: 11:45 AM
Primary Inspector: Chuck Cranford Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit inspection Type: Metal Fabrication Sformwater Discharge COC
Facility Status: ® Compliant E) NO Compliant
Question Areas:
NJ Storm Water
(See attachment summary)
Page, 1

se
Permit: NCGO30251 OWnor- Facility: Watts Regulator
Inspection Date: 11/17/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
DWQ staff was met on site by Ken LedOUX, Mike neck and Jeff Hodge of Watts and Jimmy Summers with URS
Corporation. A tour was conducted of the exterior of the facility, observing the stormwater conveyances, outfalls and site
conditions. During the visit, the SPPP manual was reviewed, operational activities and existing stormwater exposures
were discussed. The current status of the Tier 2 response sampling was discussed; including, the evidence that the
rainwater falling upon the property is less than 6.0 pH.
At the time of the inspection the site was found to be in compliance with the permit. The inspector noted that SPPP and
records were in good order. However, certain housekeeping and grounds maintenance practices needed improvement:
- oily materials at the tractor trailer unloading ramp
- compressor blowdown needed to be contained and disposed to a sanitary sewer
- upkeep around the lift truck gas station
- slope stabilization in several areas along the southside gates
Watts has satisfactorily pursued the required Tier 2 responses. Upon review and consideration of the outfall analytical
data, it is recommended that the current, monthly Tier 2 analytical sampling be reduced to only lead at outfalls 1 and 2_
However, if future benchmark exceedances occur requiring increased monitoring, standard Tier 2 sampling should be
followed.
Also, data indicate that ambient rainfall pH measures below 6.0. Therefore, current benchmark exceedances of pH do not
seem reflective of facility stormwater quality. Rainfall pH data should be collected concurrent with all sampling events to
document ambient conditions.
According to a review of outfalls, discharge areas and site conditions, it appears Representative Outfall Status could be
pursued.
Page: 2

r
Ow
0 •
Permit: NCG030251 Ownor - Facility: Watts Regulator
Inspection Date: 11/17/2009 Inspection Type: Compliance Evaluation Reasnn for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA u:_
Does the site have a Stormwater Pollution Prevention Plan? n n
;` Does the Plan include a Generaf Location (USGS) map?
13
l j
n
i I
9 Does the Plan include a "Narrative Description of Praciices"?
Ij
f-1
# Does the Plan include a detailed site map including cutfall locations and drainage areas?
1u
(_I
01
10
4 Does the Plan include a list of significant spills occurring during the past 3 years?
d
n
❑
U
# Has the facility evaluated feasible alternatives to current practices?
r;
n
n
# Does the facility provide all necessary secondary containment?
n
ri
rl
It Does the Plan include a BMP summary?
F1
n
f-1
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
E?
n
n
❑
It Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑
n
[I
It Does the facility provide and dacument Employee i raining?
❑
❑
n
# Does the Plan include a list of Responsible Party(s)?
1 7
n
0
# Is the Plan reviewed and updated annually?
EM
1-1
%,I
F1
# Does the Plan include a Stormwater Facility Inspection Program?
)
U
❑
11
Has the Stormwater Pollution Prevention Plan been implemented?
t t
' 7
n
r—I
Comment:
(qualitative Monitoring
Yes
No
NA
NE_
Has the facility conducted its Qualitative Monitoring semi-annually?
I=1
Comment:
Analytical Monitoring
Yes
No
NA
Ng
Has the facility conducted its Analytical monitoring?
®
n
In
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
10
n
❑
fn
Comment:
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
n
n
❑
# Were all outfalls observed during the inspection?
®
n
❑
❑
# If the facility has representative outfall status, is it properly documented by the Division?
n
n
®
❑
4 Has the facility evaluated all illicit (non stormwater) discharges?
n
n
❑
Comment:
Page: 3

Compliance Inspection Report
Permit: NCG030251 Effective: 11/01/07 Expiration: 10/31/12 Owner: Watts Regulator
SOC: Effective: Expiration: Facility: Watts Regulator
County: Rutherford 100 Watts Rd
Region: Asheville
Spindale NC 28160
Contact Person: Ken Ledoux Title: Phone: [phone]
Ext.134
Directions to Facility:
System Classifications:
Primary ORC: Certifications. Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 11/17/2009 Entry Time: 09:30 AM Exit Time: 11:45 AM
Primary Inspector: Chuck Cranford Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ■ Compliant 0 Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1

F
Permit: NCGO30251 Owner - Facility: Watts Regulator
Inspection Date: 11/17/2009 Inspection Type: Compliance Evaluation - Reason for Visit: Routine
Inspection Summary:
DWQ staff was met on site by Ken Ledoux, Mike Deck and Jeff Hodge of Watts and Jimmy Summers with URS
Corporation. A tour was conducted of the exterior of the facility, observing the stormwater conveyances, outfalls and site
conditions. During the visit, the SPPP manual was reviewed, operational activities and existing stormwater exposures
were discussed. The current status of the Tier 2 response sampling was discussed; including, the evidence that the
rainwater falling upon the property is less than 6.0 pH.
At the time of the inspection the site was found to be in compliance with the permit. The inspector noted that SPPP and
records were in good order. However, certain housekeeping and grounds maintenance practices needed improvement:
- oily materials at the tractor trailer unloading ramp
- compressor blowdown needed to be contained and disposed to a sanitary sewer
- upkeep around the lift truck gas station
- slope stabilization in several areas along the southside gates
Watts has satisfactorily pursued the required Tier 2 responses. Upon review and consideration of the outfail analytical
data, it is recommended that the current, monthly Tier 2 analytical sampling be reduced to only lead at outfalls 1 and 2.
However, if future benchmark exceedances occur requiring increased monitoring, standard Tier 2 sampling should be
followed.
Also, data indicate that ambient rainfall pH measures below 6.0. therefore, current benchmark exceedances of pH do not
seem reflective of facility stormwater quality. Rainfall pH data should be collected concurrent with all sampling events to
document ambient conditions.
According to a review of outfalls, discharge areas and site conditions, it appears Representative Outfall Status could be
pursued.
Page: 2

Permit: NCG030251 Owner - Facility: Watts Regulator
Inspection Date: 1111712009 Inspection Type: Compliance Evaluation
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?
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outfalls
# 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?
Comment:
Reason for Visit: Routine
Yes No NA NE
■nnn
■ ❑ 0 0
■ ❑ ❑ ❑
■❑00
le❑❑❑
■❑❑❑
■nnn
■❑❑❑
■ ❑ ❑ ❑
Yes No NA NE
■000
■❑❑❑
■❑❑❑
Page: 3

Georgoulias, Bethan
From: Cranford, Chuck
Sent: Tuesday, April 06, 2010 7:40 AM
To: Georgoulias, Bethany
Subject: RE: DMR info.
You have all correspondence.
Chuck Cranford -�[e-mail] North.Car6lina Dept. of Environment and Natural
Resources Asheville Regional Office Division of Water Quality - Surface Water Protection
Section 2090 U.S. 70 Highway Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the
North Carolina Public
Records Law and may be disclosed to third parties.
-----Original Message -----
From: Georgoulias, Bethany
Sent: Monday, April 05, 2010 9:50 PM
To: Cranford, Chuck
Subject: RE: DMR info.
Okay, thanks. Could you send us a copy of the correspondence to the
permittee about that?
Or was it just documented in the staff report?
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: http://portal.ncdenr.org/web/wq/ws/su
North Carolina Public
E-mail correspondence to and from this address may -be subject to the
Records Law and may be disclosed to third parties.
From: Cranford, Chuck
Sent: Monday, April 05, 2010 12:43 PM
To: Georgoulias, Bethany
Subject: RE: DMR info.
Hi Bethany -
Sorry, I took some extra time off last week.
Yes. The reduced sampling applies to the Tier II requirements only.
Otherwise, regular
semi-annual sampling requirements remain per the permit.
Be well,
1

.f Vq
Chuck
Chuck Cranford - [e-mail] North Carolina Dept. of Environment and Natural
Resources Asheville Regional Office Division of Water Quality - Surface Water Protection
Section 2090 U.S. 70 Highway Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
From: Georgoulias; Bethany
Sent: Tuesday, March 30, 2010 4:46 PM
To: Cranford, Chuck
Cc: Edwards, Roger
Subject:• RE: UMR info.
Thanks for the additional information, Chuck. I saw the ROS letter come in, actually - I
remember that.' Was the decision to'grant the permittee reduced sampling for those outfalls
documented in separate correspondence to the permittee, or just in the inspection report? To
clarify - that's just for monthly samples outside of regular semi-annual requirements?
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: http://portal.ncdenr.org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
From: Cranford, Chuck
Sent: Tuesday, March 30, 2010 4:39 PM
To: Georgoulias, Bethany
Cc: Edwards, Roger
Subject: RE: DMR info.
Hi Bethany:
Attached you will find correspondence from the ARO to the permittee.
After a site visit and review of the pertinent data by ARO staff, it was judged that reducing
the sampling requirements was appropriate.
Thanks for the heads up.
Chuck
Chuck Cranford - [e-mail] North Carolina Dept. of Environment and Natural
Resources Asheville Regional Office Division of Water Quality - Surface Water Protection
Section 2090 U.S. 70 Highway Swannanoa, NC 28778
Tel: [phone]
2

T10 - r
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
From: Georgoulias, Bethany
Sent: Tuesday, March 30, 2010 3:36 PM
To: Cranford, Chuck
Subject: DMR info.
Chuck,
I sust'entered the data for the attached DMR, and I noticed the footnotes on -the page.. They
say that you advised the permittee to only sample for the parameter that was exceeded'in Tier
2 sampling. That's not correct. The NCG03 permit (see p. 7 in Part II), in the Tier 2 box
says that the permittee must monitor *all* parameters as part of monthly sampling (even if
only one triggered the tier). Can you contact the permittee and advise them appropriately?
The reason we have them do this is so that we don't get a partial data set for some samples.
This is particularly critical for metals data, which can fluctuate in toxicity depending on
pH. Sampling for the whole suite also ensures that other clues and important data don't get
left out of the `big picture' while the permittee is trying to find a problem -or
correct/improve BMPs.
If you have any questions, just let me know.
Thanks,
Bg
Bethany Georgoulias
Environmental Engineer
NCDENR i DWQ I Stormwater Permitting Unit
1617.Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: http://portal.ncdenr.org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
3

.
I I �f3lQ
y
r
— U
I
my
µ
SITE MAP
FIGURE 2 -SITE N.4P
liy Cva cwta�a . +�� uawn
SiORN NAICft FK}L1 PR£VENT70er PLAN
REG
WATTS R it
NOP1H FJLJNA
SF'lNOALE. H CAEQ

Watts Regulator - Spindale, NC
,pH Sernofirrij Data
Sampling Date
Outfall 001
Outfall 002
Outfall 003
Outfall 004
Outfall 005
Outfall 006
Outfall 007
5115f2008
No Flow
5.90
5.90
600
6 10
660
: 6O
101812008
November 2008
580
No Flow
550
No Flow
F, �-r
• to
12/10/2008
6.60
5,70
1/2812009
5.96
5,64
February 2009
No Flow
No Flow
_
-�
3/14/2009
', i
6.34
6.23
—
--�
Wy 2009
No Flow
No Flow
June 2009
No Fiow
No Flow
July 2009
No FEow
No Flow
August 2009
No FEow
No Flow
September 2000
1�
No Flow
No Floe
October 2009
1 �, ,ki
1 594
600
6.19
628
6.13
6.06
Historical High pH = 6.60
Historical Low pH = 5.50
Average pH for All Testing = 6.12
NCDENR Communication History
DMR Submittal Cover Letter Dated 12-18-2008.
Called Brian Lowther on 1/15/2009 and documented via email to him.
DMR Submittal Cover Letter Dated 2118/2009
Lead Sampling Data
Sampling Date
Outfall 001
Outfall 002
Outfall 003
Outfall 004
Outfall 005
Outfall 006
Outfall 007
5i1512008
No Flow
0.1050
0.0349
00247
0.0386
00322
0.0123
101812008
0 C:C164
0,1220
001,-1
h
0,0201
Not Detected
Not Detected
November 2008
No Flow
12/10/2008
0-7340
1 /28/2009
00990
February 2009
No Flow
3/1412009
0.0836
00619
Not Detected
Not Detected
May 2009
No Flow
June 2009
No Flow
July 2009
No Flow
Au ust 2009
No Flow
Se temper 2009
No Flow
October 2009
003;SU
0.0186

0VW ••
February 18, 2009
Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Tier II Response Monthly Discharge Monitoring Report Submittal.
for January 2009
Watts Regulator — Spindale Facility, 100 Watts Drive, Spindale, NC
Storm Water Permit COC Number NCG030251
Dear Division of Water Quality,
Based on the analytical results for the Year.] -Period 1 and Period 2 samples for pH and
lead at Outfall 002 and pH at Outfall 003, the Watts Regulator-Spindale Facility
proceeded to the Tier 2 response actions required by the North Carolina General
Industrial Storm Water Permit NCG030000 under the referenced Storm Water Permit
Certificate of Coverage. Please find attached the original and one copy of the required
monthly Discharge Monitoring Report (DMR) for outfalls 002 and 003. This DMR is
being submitted by URS Corporation on behalf of Watts Regulator.
Please note that the average pH for all samples previously reported on the May 2008 and
October 2008 Discharge Monitoring Reports has been 5.97 which is below the lower
benchmark limit of the permit. The facility has performed the required Tier 1 and Tier I1
response investigations without having identified any industrial storm water exposure to
account for the low pH of the storm water at the facility outfalls.
As indicated in the cover letter that accompanied the December 2008 sampling; Watts
Regulator does continue to monitor the pH of"neat" samples of storm water at the
facility in order to determine if an acid rain condition exists in the area. "Teat" samples
are collected in clean plastic vessels that have been rinsed with distilled water prior to
being placed at the collection site on top of the building. Several "neat" storm water
samples have been evaluated since this practice began with the following results.
.:Date';-,.. __ "
Time of Da� ;
;Storm Water' f" .
12/10/2008
Morning
5.76
12/10/2008
Evening
5.81
12/11/2008
Morning
595 -
.12/15/2008
morning
4.74
01/29/2009
Morning
5.50

Watts Regulator - Spindale, NC
pH Sampling Data
Il:
• •
��
•11
• 1
•1
1 11 :
• 11
���
• 1
• • 1
• - -girt:
NONXNIM,NIIM
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`WNSO\.""♦
11
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`\�`,k,ON MSN&IONNIM`\\N"OWNR\\IMMON"
•• .� !1'
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• •
\"\"MORMI
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NCDFNR, Ccmmunication History
DMR Submittal Cover Letter Dated 12-18-2008.
Called Brian Lowther on 1/15/2009 and documented via email to him.
DMR Submittal Cover Letter Dated 2/18/2009
Lead Sampling Data
11:
. •
! 1 1
11 ••
1 1
11 :.
! 1
1 1
1 11:
1 11••
1 !
1 1 1
! 1
1 1 1
. �- - Men,
•- -•
' • • ' WITO '
" MININII`\♦
. .
\\`\`\`\"`\\"\\\01,00\\\�
`\%,ONNI 1%,%NO&IMO
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41

o�()� \N A r�Rp�
-7
❑ 'C
ROBERT E REVELS
WATTS REGULATOR
100 WATTS ROAD
SPINDALE, NC 28160
Dear Permittee:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Depart m f Environment and Natural Resources
August 23, 2002
Alan W. Klimek, P.E., Director
Division of Water Quality
AUIJ 6 9 -l?
Subject: NPDES Stormwater Permit Renewal
WATTS REGULATOR
COC Number NCG030251
Rutherford County
In response to your renewal application for continued coverage under general permit NCG030000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983.
The following information is included with your permit package:
* A new Certificate of Coverage
* A copy of General Stormwater Permit NCG030000
* A copy of the Analytical Monitoring Form (DMR)
* A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Bill Mills of the Central Office Stormwater
and General Permits Unit at [phone], ext. 548
Sincerely,
Bradley Bennett, Supervisor
Storrwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Asheville Regional Office
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7746

WATT Michael F. Easley, Governor
`O�� RQi✓ William G. Ross Jr., Secretary
North Carolina Departmee Environment and Natural Resources
r Gregory J. Thorpe, Ph.D.
"I Acting Director
0 Division of Water Quality
December 27. 2001 11
ROBERT E REVELS APR 1 0 2002
WATTS REGULATOR
100 WATTS RDLRA
-
SPINDALE, NC 28160
Subject: NPDES Stormwater Permit Renewal
WATTS REGULATOR
COC Number NCG030251
Rutherford County
Dear Permittee:
Your facility is currently covered for stormwater discharge under General Permit NCG030000. This permit expires
on August 31, 2002. The Division staff is currently in the process of rewriting this permit and is scheduled to have
the permit reissued by late summer of 2002. Once the permit is reissued, your facility would be eligible for
continued coverage under the reissued permit. 4
In order to assure your continued coverage under the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier. we are informing you in
advance that your permit will be expiring. Enclosed you will Find a General Permit Coverage Renewal
Application Form. The application must he completed and returned by March 4, 2002 in order to assure continued
coverage under the general permit.
Failure to request renewal within this time period may result in a civil assessment of at least $250.00. Larger
penalties may he assessed depending on the delinquency of the request. Discharge of stornwater from your facility
without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to $10,000 per day.
Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial
facilities in any of the 1 1 categories of "storm water discharges associated with industrial activity." (except
construction activities). if you feel your facility can certify a condition of "no exposure". i.e. the facilty industrial
materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional
information contact the Central Off ice Stormwater Staff member listed below or check the Stormwater & General
Permits Unit Wch Site at httpaHh2o.cnr.state.nc.us/su/stormwater.html
if the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed
Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will be notified when the
rescission process has been completed.
If you have any questions regarding the permit renewal procedures please contact !im Reid of the Asheville
Regional Office at 928-251-6208 or Bill Mills of the Central Office Stormwater Unit at [phone], ext. 548
Sincerely.
Bradley Bennett. Supervisor
Stormwa€er and General Permits Unit
cc: Central Files
Asheville Regional Office
®�L�
NCDENR
Jti
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699.1617 [phone] Customer Service
1-800-623-7748

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen B. Sullins Dee Freeman
Governor Director Secretary
March 20, 2009
Mr. Ken Ledoux
Watts Regulator Co.
100- Watts Drive
5pindale, NC 28160
Subject: General Permit No. NCG050000
Watts Regulator Co.
Watts Regulator — WATEC Facility
COC NCGO50378
Rutherford County
Dear Mr. Ledoux:
In accordance with your application for a discharge permit received on February 10, 2009,
we are forwarding herewith the subject certificate of coverage to discharge under the subject state
— NPDES general permit. This permit is issued pursuant to the requirements of North Carolina
General Statute 143-2I 5.1 and the Memorandum of Agreement between North Carolina and the
US Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except after notice to
the Division of Water Quality. The Division of Water Quality may require modification or
revocation and reissuance of the certificate of coverage. --
This permit does not affect the legal requirements to obtain other pennits which may be
required by the Division of Water Quality or pennits required by the Division of Land Resources,
Coastal Area Management Act or any other federal or local governmental permit that may be
required.
If you have any questions concerning this permit, please contact Brian Lowther at
telephone number [phone]
ORIGINAhIGNED BY
BETHANY GEORGOIAIAS
for Coieen H. Sullins
cc: Asheville Regional Office
Central Files
Stormwater Permitting Unit Files
Wetlands and Slorrnwater Branch One
1617 Mail Service Center, Raleigh, North GaroGna 27699.1617 NOrthCaroj na
!vacation: 512 N, Salisbury St. Raleigh, North Carolina 27604 �Q`�la�l"ll��l, f
Phone: 9IM07-63001 FAX: [phone] Customer Servlce: 1-877-623.674$ Li L
Internet: w Av.ncwaterquality.org

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG050000
CERTIFICATE OF COVERAGE No. NCG050318
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Watts Regulator Co.
is hereby authorized to discharge stormwater from a facility located at
Watts Regulator — WATEC Facility
1148 Withrow Road
Spindale
Rutherford County
to receiving waters designated as Bracketts Creek, a class C water in the Broad River Basin, in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth
in Parts 1,11, 111, IV, V, and VI of General Permit No. NCG050000 as attached.
This certificate of coverage shall become effective March 20, 2009.
This Certificate of Coverage small remain in.effect for the duration of the General Pen -nit.
Signed this 201h day of March, 2009. ORiG}At SIGNED BY
BETHANY GEORGOULIAS
for Coleen H. Sullins., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

LOCATION MAP:
y
0
NCGOS0378
MV Scale 1-29, 000
Watts Regulator
Watts Regulator - WATEC Facility
Latitude: 35° 20' S2" N
Longihxde: 810 54S4" W
County: Rutherford
Receiving Stream: Bracketts Creek
Stream lass: C
Sub -basin: 03-08-02 (Broad River Basin)
�1t' JJL� vw►'/� � 4;
Facility Location

W ATF Michael F. Easley, Governor
0�0F 9pG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
co 7
Alan W. Klimek, P.E., Director
`f Division of Water Quality
t� 'C
August 23, 2002
ROBERT E REVELS
WATTS REGULATOR
100 WATTS ROAD
SPINDALE, NC 28160
Subject: NPDES Stormwater Permit Renewal
WATTS REGULATOR
COC Number NCG030251
Rutherford County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG030000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983.
The following information is included with your permit package:
* A new Certificate of Coverage
* A copy of General Stormwater Permit NCG030000
* A copy of the Analytical Monitoring Form (DMR)
* A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance. order. judgment, or
decree.
If you have any questions regarding this permit package please contact Bill Mills of the Central Office Stormwater
and General Permits Unit at [phone], ext. 548
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Asheville Re(pional Office
v
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030251
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
WATTS REGULATOR
is hereby authorized to discharge stormwater from a facility located at
WATTS REGULATOR
100 WATTS RD
SPINDALE
RUTHERFORD COUNTY
to receiving waters designated as a UT to Stonecutter Creek, a class C stream, in the Broad River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, I1, 111,
IV, V. and VI of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective September 1, 2002.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day August 23, 2002.
for Alan W. Klimek, P.1_.. Director
Division of Water Quality
By Authority of the Environmental Management Commission

Michael F. Easley, Governor
William G. Ross Jr., Secretary
!North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D,
Acting Director
Division of Water Quality
December 27. 2001
ROBERT E REVELS
WATTS REGULATOR
100 WATTS RD
SPINDALE. NC 28160
Subject: NPDES Stormwater Permit Renewal
WATTS REGULATOR
COC Number NCG030251
Rutherford County
Dear Permitice:
Your facility is currently covered for stormwater discharge under General Permit NCG030000. This permit expires
on August 31. 2002. The Division staff is currently in the process of rewriting this permit and is scheduled to have
the permit reissued by late sutnnter of 2002, Once the permit is reissued, your facility would be eligible for
continued coverage under the reissued permit.
In order to assure your continued coverage under the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, we are informing you in
advance that your permit will be expiring. Enclosed you will find a General Permit Coverage Renewal
Application Form. The application must be completed and returned by March 4, 2002 in order to assure continued
coverage under the general permit.
Failure to request renewal within this time period may result in a civil assessment of at least $250.00, Larger
penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility
without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to $10,000 per day -
Please note that recent federal leeislation has extended the "no exposure exclusion" to all operators of industrial
facilities in any of the I I categories of "storm water discharges associated with industrial activity," (except
construction activities). If you feel your facility can certify a condition of "no exposure", i.e. the facilty industrial
materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional
information contact the Central Office Stormwater Staff member listed below or check the Stormwater & General
Permits Unit Web Site at hitp:Hh2o.enr.state.ne.us/su/stormwiter.htinI
If the subject stormwater discharge to waters of the state has been terminated. please complete the enclosed
Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will be notified when the
rescission process has been completed.
If you have any questions regarding the permit renewal procedures please contact Jim Reid of the Asheville
Regional Office at 828-251-6208 or Bill Mills of the Central Office Stormwater Unit at [phone], ext. 548
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Asheville Regional Office
G, A
NC©IENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-623-7748

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
ROBERT E. REVELS
WATTS REGULATOR
100 WATTS ROAD
SPINDALE, NC 28160
M1.57A
C)EHNF=1
September 24, 1997
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG03025 1
Rutherford County
Dear Permittee:
In response to your renewal application for continued coverage under the subject permit, the Division
of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit
is reissued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency
dated December 6, 1983.
The following information is included with your permit package:
■ A copy of the stormwater general permit.
m A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit. This form must be completed and returned to the Division within 30 days of receipt of
this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
■ Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program with outlines program components
and addresses frequently asked questions.
z A corrected Certificate of Coverage if you indicated a name or address change on the Renewal
Form returned to the Division.
Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water
Quality may require modification or revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater Group at telephone number [phone]
Sincerely,
fo A. Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

A
. ' r
NC®ENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
February 3, 2010
Ken Ledoux
Watts Regulator
100 Watts Rd
Spindale, ITC 28160
Division of Water Quality
Coleen H. Sullins
Director
a
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-n
m
a
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M
N
O
Subject: NPDES Stormwater Permit - Representative Outfall Status Approval
Permit No. NCG030251
Watts Regulator
Rutherford County
Dear Mr, Ledoux:
Division of Water Quality staff have reviewed your request for representative outfall status at the
subject facility. Based on a site visit and information provided, the request has been approved
and is effective with the next sampling event.
In accordance with 40 CFR § 122.2 1 (g)(7), you are authorized to sample the outfalls as described
in the following table.
Representative Stormwater
Discharge Outfall (SDO)
SDOs Represented
001
001
002
002
004
003, 004, 005
006
006,007
Please note: the permit still requires Qualitative Monitoring be performed at all SDOs,
regardless of representative status.
Please remember that 'any actions you initiate in response to benchmark exceedances as directed
in the tiered response provisions of your permit must address all drainage areas represented by
the SDO, where appropriate.
an
Location: 2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] l FAX: [phone] Customer Service: 1-877-623-6748
Intemet www.ncwatermuality.oM
An Fmil Onnnatirow ti Affirmative ktinn Fmnlnvnr
One

Ken Ledoux
February 3, 2010
Page 2 of 2
Please append this letter to youm r Storwater Pollution Prevention Plan (SPPP) or permit to
document that representative outfall status has been approved. If changes in drainage areas,
structures, processes, storage practices, or other activities occur that significantly alter the basis
of this approval, representative outfall status may no longer be valid. You should either resume
sampling at all SDOs, or reapply to this office for representative outfall status based on updated
information. If you have any questions or comments concerning this letter, please contact
Chuck Cranford at [phone] or [e-mail]
Sincerely,
r
Roger C. Edwards, Regional Supervisor
Surface Water Protection
Asheville Regional Office
cc: Regional Office Copy
Central Office/Stormwater Permitting Unit
Central Files

State of North Carolina
,. ;Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
October 22, 1993
Mr. Earl Culbertson
Watts Regulator
100 Watts Road
Spindale, NC 28160
Subject: General Permit No. NCG030000
Watts Regulator
COC NCG030251
Rutherford County
Dear Mr. Culbersson:
In accordance with your application for discharge permit received on December 14, 1992, we are
forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Environmental Management_ The Division of Environmental Management may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. Bill Mills at telephone number 919/733-
5083.
Sincerely,
Original Signed By
Coleen H. Sullins
A. Preston Howard, Jr., P. E.
cc: Asheville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE NO. NCG030251
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.I, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Watts Regulator 1 Regtrol - Wacasco
is hereby authorized to discharge stormwater from a facility located at
Watts Regulator / Regtrol - Wacasco
Watts Road
Spindale
Rutherford County
to receiving waters designated as an unnamed tributary to Stonecutter Creek in the Broad River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I,11,111
and IV of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective October 22, 1993.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day October 22, 1993.
Original Signed By
Coieen H. Sullins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

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Herbert, Laura C
From: Ventaloro, Julie
Sent: Tuesday, September 09, 2014 9:02 AM
To: Herbert, Laura C
Subject: Update on NCG0302SI Watts Water Technologies Spindale
Attachments: IMG_5705.JPG �S �
Laura, �� s
No action needed on your part. I just wanted to let ow that the permittee has changed their mind about
rescinding their permit NCG030251. They changing fro a warehousing operation to alight assembly operation.
They'll resume sampling to fulfill the requirements of th . stormwater permit and SWPPP.
Julie
-----Original Message -----
From: Bennett, Bradley
Sent: Tuesday, July 15, 2014 4:21 PM
To: Pickle, Ken; Ventaloro, Julie
Cc: Alexander, Laura
Subject: FW: Message from "RNP0026733F34F1"
Ken, Julie
Take a look at the response below. Looks like maybe we should work to deny the rescission and keep the permit in
place. Julie - could you touch base with Darlene and make sure of this and then work with Laura to get the response
together.
Thanks
M.
Bradley Bennett
Stormwater Permitting Program j Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1612 Web: http:/Iportal.ncdenr.org/web/lr/stormwater
Email correspondence to and from this address may be subject to public records laws
-----Original Message -----
From: Alexander, Laura
Sent: Thursday, July 10, 2014 7:54 AM
To: Bennett, Bradley
Subject: FW: Message from "RNP0026733F34F1"
Good Morning Bradley!
I wanted to pass this information on to you! Let me know if there is something I can do to help.
1

4
Thanks!
Laura
-----Original Message -----
From: Kucken, Darlene
Sent: Wednesday, July 09, 2014 4:42 PM
To: Alexander, Laura
Cc: Herbert, Laura C
Subject: RE: Message from "RNP0026733F34F1"
Hi Laura('s),
I went by this site on 7/7/14 to review the overall site conditions. I did not make an appointment and set up an internal
inspection. It does appear that the facility no longer does production as there are shipping trucks pulling in and out to
loading docks.
The one question I would ask of the facility contact is what the containers are for outside (see attached photo). There
are fluids in these containers and they are in secondary containment. However, the secondary containment does not
appear to get pumped out and there is standing water several inches deep that is thick with slime and I'm not sure what
else.
Let me know if you need anything else.
Darlene Kucken - Darlene. [e-mail] North Carolina Dept. of Environment and Natural Resources Asheville
Regional Office Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
P Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
-----Original Message -----
From: Herbert, Laura C
Sent: Wednesday, June 25, 2014 5:53 PM
To: Kucken, Darlene
Subject: FW: Message from "RNP0026733F34F1"
Darlene,
Please put this on your ride by list to see if the facility is indeed closed. Let Laurie know what you find.
Thanks,
Laura
From: Alexander, Laura
Sent: Wednesday, June 25, 2014 2:23 PM
To: Herbert, Laura C
2

Cc: Alexander, Laura
Subject: FW: Message from "RNP0026733F34F1"
Good Afternoon Laura!
I received a rescission request for NCG030251, facility name is Watts Water Technologies - Spindale, Please let me know
when this is okay to rescind.
Thank you!
Laura Alexander
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
[phone]

Kucken, Darlene
From:
Ventaloro, Julie
Sent:
Monday, July 21, 2014 9:12 AM
To:
[e-mail]
Cc:
Alexander, Laura; Herbert, Laura C; Kucken, Darlene
Subject:
Rescission Request 5tormwater Permit NCG030251
Mr. Kennard,
It was nice talking with you earlier. As we discussed, we are going to hold open your request to rescind 5tormwater
Permit No. NCG030251, Watts Water Technologies - Spindale. There are remaining industrial materials onsite that must
be removed before your permit can be rescinded. This includes a tank containing oil. I understand you will locate a
recycler for the oil and contact me once the materials have been removed.
Please let me know if you have any questions.
Thank you,
Julie Ventaloro
Storniwater Ptrmittin, prc��;ram
NC Division of Energy, Mineral, and I...and Resources
t6ra Mail Service Center, Raleigh, NC 27699-t6t2
Phow- (gig) 8o7-6370 Fax: (gig) Ro7-6491
Wcbsite: h : watersu watershed.ne. ov
!:-rnni1 corresPomlence to artd front this address rn7av he subject to the North Carolina Public Records Law and may he disclosed to third
parties_

I
AT -1—a 3n�51
Herbert, Laura C VJt S bja,4, �
From:
Kucken, Darlene
Sent:
Wednesday, July 09, 2014 4:42 PM
To:
Alexander, Laura
Cc:
Herbert, Laura C
Subject:
RE: Message from "RNP0026733F34F1"
Attachments:
IMG 5705.JPG
Hi Laura('s),
I went by this site on 7/7/14 to review the overall site conditions. I did not make an appointment and set up an internal
inspection. It does appear that the facility no longer does production as there are shipping trucks pulling in and out to
loading docks.
The one question I would ask of the facility contact is what the containers are for outside (see attached photo). There
are fluids in these containers and they are in secondary containment. However, the secondary containment does not
appear to get pumped out and there is standing water several inches deep that is thick with slime and I'm not sure what
else.
Let me know if you need anything else.
Darlene Kucken - [e-mail] North Carolina Dept. of Environment and Natural Resources Asheville
Regional Office Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
P Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
-----Original Message -----
From: Herbert, Laura C
Sent: Wednesday, June 25, 2014 5:53 PM
To: Kucken, Darlene
Subject: FW: Message from "RNP0026733F34F1"
Darlene,
Please put this on your ride by list to see if the facility is indeed closed. Let Laurie know what you find.
Thanks,
Laura
From: Alexander, Laura
Sent: Wednesday, June 25, 2014 2:23 PM
To: Herbert, Laura C
Cc: Alexander, Laura
1

r
ti
0 0
Subject: FW: Message from "RNP0026733F34F1"
Good Afternoon Laura!
I received a rescission request for NCG030251, facility name is Watts Water Technologies - Spindale. Please let me know
when this is okay to rescind.
Thank you!
Laura Alexander
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
[phone]

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Swannanoa, NC to E Main S Woogle Maps
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Goo�1emaps
Swannanoa, NC
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Directions to E Main St
48.2 mi — about 1 hour 8 mins
Save trees. Go green!
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1. Head east toward Asheville Rd/State Rd 2848
go 108 ft
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go 24.4 mi
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go;0.3 mi
tootal 25.4 mi.
7. Turn right at Ashworth Rd/State Rd 1168
go 0.9 mi
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11. Slight left at E Main St go 1.0 mi
Destination will be on the right total 48.2 mi
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These directions are for planning purposes only. You may find that construction projects, traffic, weather, or other events may cause
conditions to differ from the map results, and you should plan your route accordingly. You must obey all signs or notices regarding your
route.
Map data 02009 , Google
http://maps.google.com/maps?f d&source=s_d&saddr=swannanoa,+nc&daddr=35.3513... 11/17/2009