WQ0001077_Regional Office Historical File Pre 2018

PAT MCCROR'Y
C__
7A�kj­
GovernorD( L�VDER VAART
L] , � ' � L a= Secretary
Water Resources
S. JAY ZI11iIMERMAN .
ENS/IRONMENTAL OUALITY�. � � � � � - � � � � � '
Director
. , December 22; 2016
Innospec Performance Chemicals
P.O. Box'164
Salisbury, North Carolina 28159
Attention: Allen Robey; SHE Manager .
•
Subject: Surface Irrigation Permit Inspection Report
`Permit No. WQ0001077
Innospec-Spencer Plant.
Rowan County.
Dear Mr. Robey:.
Enclosed you will find the report for the compliance inspection -that was conducted on December 15th,
2016;for the referenced facility's treatment -and disposal system. The inspection included a review of: -
records, the residuals processing,storage areas and
the application sites: 1-would like to•thank.you and
Clay White for your time during the inspection-.
One note of consideration would be to paint;the monitoring wells for e'aseof location:
Data questions were_ adequately addressed during our meeting: The attached, report reflects compliance.
at thetime of inspection. The attached report should be self=explanatory; however,. should you have
questions, please contact Me. by phone [phone]) or email (edward:[e-mail]). .
Sincerely;
dward Watson' ,
`Hydrogeologist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Alf-,
Attachment(s): W.00001077 Inspection Report
.:':.CC: Clay White; Operations Manager, Innospec Active Chemical.(via
State of North Carolina I Environmental Quality. I.Water Resources I Water Quality. Region at Operations.
Mooresville Regional Office 1610 East Center Avenue;, Suite 301.1 MooresA1e,.North Carolina 28115
704 6631699 - - - - —

Compliance Inspection Report
Permit: WQ0001077 Effective: 08/17/16 Expiration: 07/31/21 Owner: Innospec Active Chemicals LLC
SOC: Effective: Expiration: Facility: Innospec Performance Chemicals -_Salisbury Facility
County: Rowan 500 Hinkle Ln
Region: Mooresville
Salisbury NC 28144
Contact Person: Allen Robey Title: Phone: [phone]
Directions to Facility:
From Salisbury, travel north on 1-85 to exit 81. At the top of the exit ramp turn left and cross over the highway. Turn right onto Hinkle
Lane. The plant entrance is at the end of the road (approx. 0.75 miles).
System Classifications: WW2, SI,
Primary 0RC: James Cloyd White Certification: 25861 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NCO023884 City of Salisbury - City of Salisbury WWTP
Inspection Date:' 12/15/2016 Entry Time: 01:30PM Exit Time: 03:30PM
Primary Inspector: Edward Watson Phone:
Secondary Inspector(s):

Permit: WQ0001077 Owner - Facility: Innospec Active Chemicals LLC
Inspection Date: 12115/2016 . Inspection Type • Compliance Evaluation _. Reason for visit: Routine
Inspection Summary:
On December 15, 2016, staff from the Mooresville -Regional Office,(MRO) of the DWR performed a Compliance Evaluation
inspection of the subject site. During the site visit, asecords review was performed. Laboratory analytical data and
operations records were in good older.
The permit was recently renewed and concerns from the last inspection have been addresed..
The visual alarm in the wet well will be addressed in a capital improvement project. However, the alarm system does work
well.
MW s were reviewed for general construction and identification. However, a detailed well completion review was not
performed as part of this inspection.
During the inspection, mention was made regarding system expansion that would increase discharge from the facility.
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Permit: WQ0001077 Owner - Facility:InnospecActive Chemicals LLC
Inspection Date: 12/15/2016 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Treatment Flow Measurement -Effluent
Is flowmeter operating properly?
Does flowmeter monitor continuously?
Does flowmeter record flow?
Does flowmeter appear to monitor accurately?
Yes No NA NE
❑ ❑ ❑
❑■❑❑
■❑❑.❑
Comment: The flow recorded for effluent is the total amount applied to all fields based on Dump run times.
The permitte has been advised not to include the flow that is directed to the City of Salisbury as
part of the total flow volume because it gives a false total flow volume that appear to exceed
permitted flow for the facility.
Treatment Flow Measurement -Influent Yes No NA NE
Is flowmeter calibrated annually? ❑ ❑ ❑
Is flowmeter operating properly? N❑ ❑ ❑
Does flowmeter monitor continuously? M ❑ ❑ ❑
Does flowmeter record flow? ❑ ■ ❑ ❑
Does flowmeter appear to monitor accurately? 0❑ ❑ ❑ .
Comment: The flow meter is properly working and calibration information was presented during the site visit
to indicate annual flow meter calibration. Flow is recorded manuully.
Treatment Flow Measurement -Water Use Records Yes No NA NE
Is water use metered? ❑ ❑ ❑
Are the daily average values properly calculated? ■ ❑ ❑ ❑
Comment: Information was provided during the site visit for the permitee to return to previous flow
calculations as the new system was creating numbers that could be mis-interpreted as being
Over limit for daily flow rates. .

6
Permit: WQ0001077 Owner - Facility: Innospec Active Chemicals LLC
Inspection Date: 12116/2016 Inspection -Type : Compliance Evaluation Reason for Visit: Routine
P
Treatment Influent Pump Station Yes No NA NE
Are SCADA/Telemetry available? ❑ ❑ 0 ❑
Are SCADA/Telemetry operational? ❑ ❑ ❑
Comment: The high water alarm was tested. The alarm light did not work. However, the audio alarm did
and redundant system worked as two calls were recieved during the testing of the alarm system.
We were informed during the inspection that a capital improvement project was being drawn up
to make improvements to the alarm system and the light issue would be corrected with the
capital improvement.
Type'
Reuse (Quality)
Activated Sludge Spray, HR
Activated Sludge Spray, LR
Single Family Spray, LR
Infiltration System
Recycle/Reuse
Activated .Sludge Drip, LR
Single Family Drip
Lagoon Spray, LR
01 -
Treatment Laaoons
Lagoon Type
Primary/Secondary
Influent structure
Banks/berms (seepage and erosion)
Vegetation (excessive vegetation on banks/berms)
Liner
Liner Type
Yes No NA NE
❑
Yes No NA NE
Aerated
Primary
■❑❑❑
❑❑❑■...
Apron, clay

Permit:. WQ0001077 Owner- Facility:lnnospec Active Chemicals LLC
Inspection Date: 12/15/2016 Inspection Type: Compliance Evaluation Reason for Visit:
Routine
01 -
Treatment Lagoons •
Yes No NA NE
Feet
Are increments clearly marked on gauge at adequate intervals?N
❑ .❑ ❑
Has the water level gauge been surveyed w/ respect to lowest point.on, dike? wall?
❑ 11110
No Evidence• of overflow0
❑ ❑ ❑
Acceptable colorN
❑ ❑ ❑
Floating mats
❑ N ❑ ❑
Excessive solids buildup
❑ 0 ❑ ❑
Aerators/mixers
❑ ❑ ❑
Effluent structure
❑ ❑ E ❑
Lagoon cover
❑ ❑ E❑
02 -
Treatment Lagoons
Yes No NA NE
Lagoon Type
Combination
aerated/mixed
Primary/Secondary
Secondary
Influent structure
❑ ❑ 0 ❑.
Banks/berms (seepage and erosion)
0 ❑ ❑ ❑
Vegetation (excessive vegetation on banks/berms)
❑ ❑ ❑
Liner .A
❑ ❑ ❑
Liner Type
Apron, clay
Baffles/curtains
❑ ❑ N ❑
Freeboard Marker
Required freeboard
2
Feet
Actual freeboard '
2
Feet
Are increments'clearly'marked on gauge at adequate intervals? :,:.;
❑ ❑ : .. .
Has the water level gauge been surve ed w/ r g y respect to lowest point on dike? walk
No Evidence of overflow
❑ •:� ❑ Ef

Permit: 'WQ0001077
Owner- Facility:InnospecActive Chemicals LLC
inspection Date: 12/15/2016
Inspection Type: Compliance Evaluation Reason for visit: Routine
02 -
Treatment Lagoons
Yes No NA NE
Floating mats
❑ ❑ ❑
Excessive solids buildup
❑ . ❑ ❑
Aerators/mixers
❑ ❑ ❑
Effluent structure
❑ ❑ 0 ❑
Lagoon cover
❑ ❑ ❑

PAT`M:CC,Q ;
'i:'"• _, a poi-ern�tr}
D,.()NAi�D R: VA�VA'Aii`
_.._._
__Wt2terResturces S. J,AY ZTMvIERMAN
ENVIRONMENTAL dUAL TY plrecFor
December 22,..206 -
Innospec Performance:Chemicals
P.O.-Box 164. - ,
_...
S:allsbury,North Garollha 28>15,5
Attention. Allen Robey,-SHE Manager.
Subject Surface Irrigation Permit.nspectlo;n Repo,rt;,
Permit No WQ000,1077 _�...;
Innospec -SOqqggrt Plant. "
Rgwan CountV<
DearMt..: RobeV
Enclosed you will find the report for the corrpflance inspection that was conducted; on December_15th;;
20M,for the referenced facilitV's'treatment,'and disposal system: `The 'inspection included a review of:
records;'the residuals processing, sto, •rage areas and'the applicatidn sites. 1-would :like to -,thank you ano'=
C(ay White for yourtime-.during:,the inspection;
One notebf consideratgn would be to palntthe moritoring=we(Is for ease of location:.
Data questions were adequately addressed; during'our meeting Th'eattached. reptirt'reflects ci m`pliance
at the time of inspection. The`:attached report'sh--' P& a self=explariatory':however,•stiould you have
q"ue,stlons,; pfease,contact me'by. pho"ner(704-2'35-2198), or email (etluvard:inr4 on@ncdenr gov}
I
�CIA-
1
Edward watso,n '
Hydrogeologist i
Mgore'svllle�fteglona1(ffice
-Water Quality Reglob al Operations Section
-Dlvlslon of Water Resources; NCDEQ. t v-
Attachment(s)- VWQ000;1077'lnspection Reportr
_. . i
CC CIaV:White,,0 ratio'ns'Manager Innos ec:Active Cherriical via _ email
."a
State of Ngdtt Carolina l Env_ironmental,(Zua1Ry l WaterResources I Water Quality'RagionaLOperations i
Mooresville Regional Office l,610,EasfCeotor_Avenue,, Suite 30;) I Mooresville Nordl enrbliga-
704,6631699`. --r_ ._::r

Compliance Inspection Report
Permit: WQ0001077 Effective: 08/17/16 Expiration: 07/31/21 Ownef : Innospec Active Chemicals LLC
SOC: Effective: Expiration: Facility: Innospec Performance Chemicals - Salisbury Facility
county: Rowan 500 Hinkle Ln
Region: Mooresville
Salisbury NC 28144
Contact Person: Allen Robey Title: Phone: [phone]
Directions to Facility:
From Salisbury, travel north on 1-85 to exit B1. At the top of the exit ramp turn left and cross over the highway. Turn right onto Hinkle
Lane. The plant entrance is at the end of the road (approx. 0.75 miles).
System Classifications: WW2, SI,
Primary 0RC: James Cloyd While Certification: 25861 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NCO023884 City of Salisbury - City of Salisbury WWTP
Inspection Date: 1211512016 EntryTime: 01:30PM
Primary Inspector: Edward Watson
Secondary Inspector(s):
Maria Schutte
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Irrigation
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Exit Time: 03:30PM
Phone:
Inspection Type: Compliance Evaluation
Treatment Flow Measurement -Effluent Treatment Flow Measurement -Influent Miscellaneous Questions
Treatment Flow Measurement -Water Treatment Record Keeping
Use Records
Treatment Lagoons End Use -Irrigation Treatment Influent Pump Station
Treatment Clarifiers Treatment Flow Measurement Storage
Wells
(See attachment summary)
Page: 1

Permit: WQ0001077 Owner - Facility: innospec Active Chemicals LLC
Inspection Date: 12/15/2016 Inspection Type :Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On December 16, 2016, staff from the Mooresville Regional Office,(MRO) of the DWR performed a Compliance Evaluation
inspection of the subject site. During the site visit, a records review was performed. Laboratory analytical data and
operations records were in good order,
The permit was recently renewed and concerns from the last inspection have been addresed.
The visual alarm in the wet well will be addressed in a capital improvement project. However, the alarm system does work
well.
MWs were reviewed for general construction and identification. However, a detailed well completion review was not
performed as part of this inspection.
During the inspection, mention was made regarding system expansion that would increase discharge from the facility.
Page: 2

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Permit: WQ0001077 Owner - Pacility:lnnospec Active Chemicals LLC
Inspection Date: 12/1512016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Record Keeping
Yea No NA NE
Do effluent concentrations exceed GW standards?
❑ ❑ ❑
Are annual soil reports available?
M ❑ ❑ ❑
# Are PAN records required?
❑ ❑ ❑
# Did last soil report indicate a need for lime?
❑ 0 ❑ ❑
If so, has it been applied?
❑ ❑ M ❑
Are operational logs present?
0 ❑ ❑ ❑
Are lab sheets available for review?
❑ ❑ ❑
Do lab sheets support data reported on NDMR?
M ❑ ❑ ❑
Do lab sheets support data reported on GW-59s?
0 ❑ ❑ ❑
Are Operational and Maintenance records present?
0 ❑ ❑ ❑
Were Operational and Maintenance records complete?
❑ ❑ ❑
Has permittee been free of public complaints in last 12 months?
E ❑ ❑ ❑
Is a copy of the SOC readily available?
❑ ❑ M ❑
No treatment units bypassed since last inspection?
❑ ❑ ❑
Comment: No treatment units have been bypassed since the last inspection,
Treatment Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit? M ❑ ❑ ❑
Do all treatment units appear to be operational? (if no, note below.) 0 ❑ ❑ ❑
Comment: The treatment is consistant with the permitted use.
Treatment Clarifiers Yes No NA NE
Are the weirs level? 0 ❑ ❑ ❑
Are the weirs free of solids and algae? 0 ❑ ❑ ❑
Is the scum removal system operational? ❑ ❑ ❑ M
Is the scum removal system accessible? ❑ ❑ ❑
Is the sludge blanket at an acceptable level? ❑ ❑ ❑
Is the effluent from the clarifier free of excessive solids? 0 ❑ ❑ ❑
Comment: Rocculant is added after aeration to drop out solids before the pre-treated effluent is sent to
Salisbury.
Treatment Flow Measurement -Effluent Yes No NA NE
Is flowmeter calibrated annually? 0 ❑ ❑ ❑
Page: 4

Permit: WQ0001077 Owner - Facility: Innospec Active Chemicals LLC
Inspection Date: 12/1512016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Treatment Flow Measurement -Effluent Yes No NA NE
Is flowmeter operating properly? 0 ❑ ❑ ❑
Does flowmeter monitor continuously? M ❑ ❑ ❑
Does flowmeter record flow? ❑ 0 ❑ ❑
Does flowmeter appear to monitor accurately? ❑ ❑ ❑
Comment: The flow recorded for effluent is the total amount applied to all fields based on pump run times.
The permitte has been advised not to include the flow that is directed to the City of Salisbury as
part of the total flow volume because it giyes!a false total flow volume that appear to exceed
permitted flow for the facility.
Treatment Flow Measurement -Influent Yes No NA NE
Is flowmeter calibrated annually? 0 ❑ ❑ ❑
Is flowmeter operating properly? M ❑ ❑ ❑
Does flowmeter monitor continuously? 0 ❑ ❑ ❑
Does flowmeter record flow? ❑ M❑ ❑
Does flowmeter appear to monitor accurately? i ❑ ❑ ❑
Comment: The flow meter is properly working and calibration information was presented during the site visit
to indicate annual flow meter calibration. Flow is recorded manuully._
Treatment Flow Measurement -Water Use Records Yes No NA NE
Is wafer use metered? 0 ❑ ❑ ❑
Are the daily average values properly calculated? M ❑ ❑ ❑
Comment: Information was provided during the site visit for the permitee to return to previous flow
calculations as the new system was creating numbers that could be mis-interpreted as being
over limit for daily flow rates.
Treatment Influent Pump Station
Yes No NA NE
Is the pump station free of bypass lines or structures?
❑ 0 ❑ ❑
Is the general housekeeping acceptable?
0 ❑ ❑ ❑
Are all pumps present?
0 ❑ ❑ ❑
Are all pumps operable?
0 ❑ ❑ ❑
Are floats/controls operable?
■ ❑ ❑ ❑
Are audio and visual alarms available?
M❑ ❑ ❑
Are audio and visual alarms operational?
■ ❑ ❑ ❑
# Are SCADA/Telemetry alarms required?
❑ 0 ❑ ❑
Page: 5

Permit: WQ0001077
Inspection Date: 12/15/2016
Owner - Facility:Innospec Active Chemicals LLC
Inspection Type : Compliance Evaluation Reason for Visit: Routine
Treatment Influent Pump Station Yes No NA NE
Are SCADA/Telemetry available? ❑ ❑ N ❑
Are SCADA/Telemetry operational? ❑ ❑ 0 []
Comment: The high water afarm was tested. The alarm liciht did not work. However, the audio alarm did
and redundant system worked as two calls were recieved durin-gthe testing of the alarm system.
We were informed during the inspectiow that a capital improvement project was being drawn up
to make improvements to the alarm system and the light issue would be corrected with the
capital improvement.
Type
Reuse (Quality)
Activated Sludge Spray, HR
Activated Sludge Spray, LR
Single Family Spray, LR
Infiltration System
Recycle/Reuse
Activated Sludge Drip, LR
Single Family Drip
Lagoon Spray, LR
01 -
Treatment Laaoons
Lagoon Type
Primary/Secondary
Influent structure
Banks/berms (seepage and erosion)
Vegetation (excessive vegetation on banks/berms)
Liner
Liner Type
Baffles/curtains
Freeboard Marker
Required freeboard
Actual freeboard
Yes No NA NE
EJ
Yes No'NA NE
Aerated
Primary
E ❑ ❑ ❑
■❑❑❑
E ❑ ❑ ❑
❑❑❑■
Apron, clay
❑❑■❑
2
Feet
2
Feet
Page: 6

Permit: WQ0001077 Owner - Facility:InnospecActive ChemicalsLLC
Inspection Date: 12/15/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
01 -
Treatment Lagoons Yes No NA NE
Are increments clearly marked on gauge at adequate intervals?
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall?
No Evidence of overflow
Acceptable color
Floating mats
Excessive solids buildup
Aerators/mixers
Effluent structure
Lagoon cover
02 -
Treatment Lagoons
Lagoon Type
Primary/Secondary
Influent structure
Banks/berms (seepage and erosion)
Vegetation (excessive vegetation on bankslberms)
Liner
Liner Type
Baffles/curtains
Freeboard Marker
Required freeboard
Actual freeboard
Are increments clearly marked on gauge at adequate intervals?
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall?
No Evidence of overflow
Feet
■❑❑❑
❑❑❑■
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑❑ME]
❑❑■❑
Yes No NA NE
Combination
aerated/mixed
Secondary
❑❑■❑
■❑❑❑
01100
❑ ❑ ❑
Apron, clay
❑ ❑ M ❑
■❑❑❑
2
Feet
2
Feet
■❑❑❑
❑❑❑■
❑■❑❑
Page: 7

Permit: WQ0001077 Owner - Facility: Innospec Active Chemicals LLC
Inspection Date: 1211512016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
02 -
Treatment Lagoons Yes No NA NE
Floating mats ❑ M ❑ ❑
Excessive solids buildup
Aerators/mixers
Effluent structure
Lagoon cover
Page: 8

ATTACHMENT A-.,.. LIMITATIONS ANDMONITORING REPUMEMENTS Permit'NumbemWQ0001,077 Version: 4-.0-
Prj 6.01 =WWTIF Industrial` EftimpOt Discharged; t'o the Sgli*ttyROWAO WIW,- V-10irm,11 COM
EFFLUENT-,.GBk,RA4L!TEItIST-ItS
EFFLUENTLIMITS:MONITOR
INdREQUIREMENTS!
PCs
CodeParamder.Description
Measure
'Monthly
Axes 'ge�,
I
Monthly'
"Oeometric,Mean
.- In
DailyMinimu
-Dadly,
-Maxinimm
K"suronlep
Fr9quency,Ty
eL
50050-
Flow, in conduit or thru-treAtment
GPD
Continumjs:
-Recoriiin&,
I, Please note -for the,p,trposes,of'thig.permit (�.ermiiNo.WQ0001077J;�the :66,660:-OPD'efauent pretreatment -lih-ift §hall n be Division -enfbrcco,snit, included
'-rws a MOO" to track the
kmGunt.pf'iAdustri4efflucat,disch4(gqd.tbtq;Sal q-RQwau.WWTP(PermifNoNQQDZn84)-
P , P1[002 --VWTFEfftu.ent
)gfftliENT 04"CTERISTICS C
EFFLUENT LIMITSN
Pc&
Cone
Parameter Description
Unim of
Measure .
monthly,
Aver age
;Monthly
"Geometric Mean.:
Daily
mimmunk
-Daily,Maximum
Measureme .
-- , -.1 -1 Measurement;
Frequency
Sample
Type
003110
,BQD,::5-Day`(20:T)
Mg/L
monthly
.01.02.7
Cadmium; (as.Cq)
IYI
Grab,
610341
Chromium, Total(ds e,-i)
'Monthly
Grab
'
.01042.
Copper, Total W4)
pp
Monthly
Grab
500%1'
Flow, -in: conductor thru treatineat•plant
.:rn#,L
Ispo
Continuous
Recording,
61' 51
1p0Total (as P6)-
'.
'Jng/t
Monthly
Grab
01007;
'Nickel;. Total (as Ni),
Monthly
:6rib
.06610
Nitogeft; Ammonia Total (as aN)mg/L
.Monthly '
c 4o
00625
Nitrq gep, K-je,Idab.1,.ToW (as -N)
mg/L
Monthly .
Grab
Nitrogen; Nitrate
�mgl
Monthly
Grab
00556,
Oil,&,Gteh§b
mg/1
1
Monthly
GrA-b
60340,.
'Oxygen,Demand Ched. (High Level)�,((OD)
-rng/L
Monthly'
.'Grab
00400
P.
rn94,
-
Weekly
;Grab
327-30
PhenolicsJ.661"Recoverable
'Monthly
;
Grib
,090
Pladt-.AvdifabliD'Nitt6gei' Coiiceritt.ad6if
lftig,/4
monthly
Groh
00530
Solids, Total S' I*13 6nd6d
MonthlyGrab
38260
S"urfactants--(M]13AS)
Ing/L
Grab.
.0092
_Z11
'ZiJac,T61Iad (as --
Monthly
drab
)YO6601071 VpTsi.p.44.0.
AttaPhmehtA
kagp 1 of I

- �.- ��j
-T - -
_
fr
ff.
r
--
VIC
/ f
(
BLDG I
1
r
' �
•:�.
i.
BLDG':3
j. f �' '
BLDG 2
EL 91-14 f
DTW 32 99
is
j
l'AG U<ONS
i
3 g,
LEGEND
_
'O',
dROUN!] WATER MONITORING' WELLS:
j
PIEZOMETER',
-- — — —
REVIEW BQUNOARY'
COMPLIANCE, 86UN0414Y
.''
EL
ELEVATION (FT)
��y!_�•r---�
D,TW
17EPTH-TO' WATER (�'T�
Author
Drarilnq
Layers
Dcte
T{tlq -
Spr m -
l �. o
ay rrt atl n S ste
WATERS EDGE ENV-_ tONMENTAI , LI C`
ahl
o� aea-Foz
$ 2:0
Delall Map for First Plaid
Job No
R'V45
Revisidn'
�guce
Scole
Projgct
` Fineiex Inc. "
r
845,07
2-
1 120'.
_. Rowan Coun North Carolina

A . TTAC I HWNT B­ APPROVED LAND AppucAnw srms AND LuffrATIONs
Innospec Active- Chemicals,,.LLC —Innospec Performance Chemic2ils ..� Salisbury Facility
I'etrmtt-Number- WQ9961077 Versidd: 4.,Q
IRRIGATION AREA INF 4MA-TJON:
APP1,10, T-A IWLI119I1 ATJOr0i­
Field
OWper
-County:
Latitude
Longitude
Net
Acreage
Doininant
Parameter-
)joprly'.
Rate
Yearly
Max
Units
Jnnospec Active Chemicals, 4,LC
Rowan
'35,7077030
78-0.39854,00
4.00
_SbilSeries
Cecil sandyclay.
'0 1284 �Nbn,Disdharge A00licationRate,
WQ09'—,'Planit Available Nitrogen —10ading,
0'25
28.16
-360
Inches
lbslac/yr
2 1 -1
Innospec Active Chemicals, LLG
Rowan
35,699600
464036650
1.14
Enon.fine.sandil
Discha±ggAppli 01284—Norf�i6n'Rafe
WQOql— lilant Avai1`able',NiJirogcn — Loaaing,
0.25
;26k
300:
inches
lbs/ac/yr
2-2,
Innospec Active Chemicals i LLG
Rowan
35.6994010
­90AW082°
0.92,
Enon fine -sand
01284— Npp-DisqhargP Application Rate
*Q09 --Plant Available Nitrogen Loading,,
-
0.25,
2610
'30a
inches
lhs(dc/yr'
2-4
Innospec Active Chemicals, LL C
Rowan
35.69 9 7521
-90A02859p
1.44,
Enon fine sepo
0 12M -- Npn7-Discharge. Application'Rate
WQ — Plant ,AX�-itableNitrogen —L-,poding,
0,25,
26-0 -
1-99
inches
kbs14clyr
%-5�
Innospec Active Chemicals, LCC
Rowan
35�699,474'
.0.4 64'
005
1.09%
Enonflnc sand'
0 1284— Non-Discharge,-Applicatfon Rate.
Nitrogen
WQ0 —.Plant-lant,Ayail01e,,Niiro — Loading
0.25
26.0
300,,,
inch ' es
lbslac�yr
2-6:
Innospec Active Chemicals_LLO
Rowan
35,.700015�
=804031200
1,62
EnonJine sand
011284— Non-DischargeAp�lidatibnRate
WQ09.—.Plant Available Nitrogen —,Loading.
025�
216.0
3 00'
inches
lbs/*yr
Totals
I., 'Eachiirrigation4eld.shaill, not exceed an,annual loading1mit ofb.45 the of Cadmium,per, acre per year..
I,- Each irrigation fieIdshall not exceed, thefqllowii g.curnwatNe metal loadings. l ascd, crithe fields Cation ,EXq4pge Capacity ((;E-(,).-,I
L-1FETIMEWADINGSILDSIAC)
PARAMETER
CEC,< 5
CEC15__ 15
UEC >15
Lead
500
10,00
20010
Zinc -
250
500.
1 t000
Copper'
125
250
500
Nickel
125
250
500,
WQ0001077 Version 4.0 Page 1 of I

.�� � � ' i
i t:

170'dhec
Healthy People. Mea t1 y Cammm igm
November 02, 2016
DAVID C COYLE
TERRA RENEWAL SERVICES INC
EAST REGION ENVIRONMENTAL OFFICE
PO BOX 1746
WATKINSVILLE GA 30677
RE: LOA-004638
TERRA RENEWAL SERVICES INC
ADDITIONAL RESIDUAL SOURCE FROM INNOSPEC INC
ND0082741: Kershaw and Lee Counties
ND0086479: Chesterfield, Darlington and Marlboro Counties
Dear Mr, Coyle:
On September 30, 2016, the Department received and reviewed your request for residuals from
Innospec Inc in Salisbury, NC as an addition source for land application. Innospec is primarily engaged in
the manufacturing of raw materials for the personal care industry. These raw materials are used in the
production of shampoos, body washes, beauty bars, conditioners and lotions. The residuals to be land
applied are derived from the clean-up of a batch reactor and boil outs between batches. The estimated
volume to be land applied from this facility is approximately 50 dry tons (780,000 gallons) per year.
The residuals are beneficial as a soil amendment for agricultural operations. Based on the analysis of
these. residuals -there is no indication that -the materials would be considered a hazardous waste or
would contain significant amounts of harmful 'Materials if applied at agronomic rates. Therefore, the
above referenced source is acceptable to the Department for land application on the approved sites
listed in your permits.
If you have any questions, please contact me at 803-898-4236 or amickbmPdhec.sc.gov.
Sincerely,
Byron M Amick
Industrial Wastewater Permitting Section
Water. Facilities Permitting Division .
cc via e-mail: Leigh W Plummer, PEE DEE REGION BEHS FLORENCE
Keith Lane, PEE DEE REGION BEHS SUMTER
BOW/WPC Enforcement
S.C. Department of Health and Environmental Control
2600 Bull Street, Columbia, SC 29201 [phone] www.scdhec,gov

reaac.
TERRA RENEWAL WASTEWATER RESIDUALS SERVICE AGREEMENT
Innospac Adve Chemicals, LLC I 'feria Reneeal
("Custamei'- Legal Business Name) By. 41
Innospac Performance Cherrficals
Print: `
(Assumed Betsitsesti NNa/mr or [1B—/�AG
Bay (siRnl: ---Cat/-L'r„' 47atc: aS i ` [:mail: �� Fw-• tilUOl���, +Y(t i'Cd12''
Prim; Allen Robey t•ddieni:—q� mwln� 4��
Date: 1{ . Enim). [e-mail] C'" " '—'�� �� °� �
Addirss• 500 Hinkle Lana Phtwuc: j-3 iy_ ti2({0 t-�:
Salisbury, NC 26144
704-633-8026 e _ 704-633-3746
1. This Watsteevuler Residuals Service Agreement and all exhibit(s) (""Agreemcat') is made between Customer and Terra Rtnc%vl Services, Inc C-mn Customer appoints
TRS as Customer's Lxcluszve provider of traasporlabon. storage, land applicalim, disposal fart record-koepingrrcporung services for Customer's non-haardous wasteuml r
resubtah that ere suitable for processing or land uppl►cauon ("Residuals") at the rates and for the Customer location(s) set forth an Exhibit A.
2. THE will provide Residuals bowling service to Custamee at the li queawy set Rath on Ex)ubit A. and if no" speeirsed, upon Customer's reasonable vv?ltten request It
service k required prior to the scheduled Requency, Customer is solely responsible for notifying IRS that sevia is necessary. TRS will matte z reasonable alfon to
provide senrce as soon as pmeiie dde. TRS shalt have reasonable accears to Customer's locations at all reasonable times. TRS will provide the service in o timely and
wo>rktmnnitke man= and according to standard indusuy practices. If Customter believes that IRS's perflirmance is defective. Customer shall notify TRS in writing within
10 days of the eisimed defective ssrvice. If IRS agrees in its reasonable discretion that if did not properly provide service, then IRS will repeat performuce of the service.
This limited w2rrsnty eonstitates Customer's sole remedy. TRS ditclabns an other remedies and warranties, express or implied, hnc)tidlag the Implied warranties
of mercchanubl)ity and fitness fbr n particular purpose: Notwithstanding wo"Ing herein to the contrar); in no event shall TRS he Rable to Customer for any
indirect, (ntidental, special, or consequential damages, whether arldng or alleged In breach of contmet or viarranty, negligence, strict ItabWW, tort, at othertahe,
o en if TR.S it. advised of the paulbllity of such damages. These Ilmttattens ofllfbIl[tJ eoaslitate an essential part orthis Agreement.
3. This Agreement shall �,vm nwnax upon eneeution of rho last signature above and expire 36 wombs o Fier the rim service, which shall mast mcur until iRS has completed all
analysis and the Residuals have been approved and permmed for the disposal methods by the permitting eg mcies. After expirations of the it" or mry succeedarg tens, this
Agreement aunnranticalip rancws feu additional 12 month teams mdcss either patty notifies the other in wramg by Certified Mail mot less than 60 days prior to dhe expiration
of dic than -current term of its mteast not to renew. If lama or regulations are adopted thin ndwerstly affect'IRS's
parties shall negotiate to modify the Agreement accord' . If die of service. nt urn 30 Cuwmnensad the
tingly parties esrmat reach a resolution. TR.S racy laminate this Agreement upon 3D days' written mintscs
Should either party be in material breach of this Agre ememand fail to care such broach within 30 days after receipt of written notice. the non•breachiag patty wary temsinate
this Agreed but only with regard to those Imativas when: the material breach shams uncured.
4. Cusuater shall pay the service charges on Fxhibit A. net 14 days with a fw ancce charge of 1.5% per month on all outstanding invoices. Service charges shall be aubject to a
diesel Ibel surcharge and CPl adjustment es set forth on Exhibit A In the event of Customer's nonpayment of an invoice ear oiha beach of ibis Agremmtt, IRS shall have
the right to terminate this Agreement or, without termimatiag, suspend soviet i mql Customer cures its branch and is currant on its, account (listener agrees to pay IRS all
costs of collccrfem ine�red)ry 7RS, Inaludimg wuhaut ltmturtiori, calla chum agehtcy lees, al101ieys' fees, raid court otistr Duo M v"tirns in colkction, processing, and
disposal costs, TRS may increase fhe service ebfrgn at any dine upon Prior wrhwn notice, Customer will have la days to reject the increase in writing, whereupon TRS
shall have the right m immaiiately tominate this AgreeMen t or continue service at the sane lies, subject to TRS's conbrming light to terminate at any time thereAer. if
Customer fails to do so, this Agrecotent sltill be automatically antcn&d to reflect such inctseaw. IRS has. rho right to set off tiny amounts that Customer owes to TRS against
any amounts that may be payable by TRS to Customer..
i. Customer wwra ms tba Ilia Residuals orc noubarardous, suitable for land application or processing and repteseolative orsamples provided to iRS for analysis. Customa
shall include to other constituents in the Residuals without the prior written approval of TRS, winch array be withheld at MI's sole discretian. Title to all Residuals that is
not Rather processed by IRS shall remain with Customer at all tiroas. Customer tcban be solely responsible Ibr the torhtcut turd mekcsgs of the Residuals, and tbstatno wall
cxcwiw its best efforts to ensure that no trash, comirs>maaats, or unacceptable materml will he included in any loads. IRS "I charge Cummmer for any costs that result
from re opt of any unacceptable malcrfals. Customer shall be solely responsible fbr any and all liabilities, damallft wears, fines, or pctWliesof or firm any third parties or
regulatory agencies relating to the content of makeop of, or title to the Residuals. rustaner shall Indemnify. defead, and hold hahmle ss TRS from all liabilities. damages,
costs, and expanses (including reasonable attorneys' fees) resulting lion or ansing out of (a) Customer's breach of this Agreement, (b) Cuslocraws negligence er
recklessness; and (c) perftmna ice by 7RS hereunder except to die extent such liabilities, daronges, costa aldror expaases we found by a Foal Judgment of o court of
curnxMett jurisdiction to have resulted from M's negligence
6. Fisch party shall be responsible for obtaining the necessary permits and Rppmvals for its obligations set forth in this A Each
in awning the other party in ob ainuig the nactsary approvals or permits. TRS will be responsible for obtaining sam d party s to masof the cdopentc
�s 8 P uaY � emallyses of the Residuals.
IRS will pay for the lob analyses and will invoice Customer Rer this mnotml, payment net 14 days.
7. To the extent TRS places storage nmks or other equipment at Cusomer's Iocation(s), all equipment TRS Ramishes to Customer shall remain the property of TRS.
Customer Shall; (a) keep the equipment hie fhim all cricumbrances and chums; (b) not remove equipment ailbout TRS's prior written consent; (a) be liable for all
damage, loss, or tmauthtwized removal of equipment; and (d) maintain the equipment in goad, operable condition and return it to IRS in the some condition upon
termination or expiration. reasonable wear trod leer excepted. Customer shall be resprarisihle for any costs a%ocimed with the insialledon, maintenance and
removal of such equipment.
R. lius Agreemem and all other documents and mftuinatem (whether written, oral, ekctraaarc, or otherwise) that TRS provides to Customer mating to this Agaecnem to the
senses pro coded (-Confidential information') is eonfidemial and pna{rietM to TRS. Customer agrees to maintain all ('onfldeatml )nfimnatson in strict confidence and
shall not duckue Confidential Infrommiaa. This Agreem m constitutes the Matte agreement between IRS and Customer, supersedes all prior agreements for due subject
matter hereof. and can only. be modified in uniting signed by both parties. This Agreement shall be bmdrng upon and muse to the benefit of each
nssi ces, pamnal re tatives, and 1 Y and its successors.
gn ptewt ttcquuecs, but (lutotihcr stall mot be released of its obligations unless TRS egrets in writing. TRS expressly limtuts acceptance of
this Agreement to the terms herein. and all courses of dealing Rod performance, usnp oftrade, and verbal agreemens non reduced to writing signed by txnb parties sban not
be binding upon die parties. By s4ning Ihts Agmetaacm. Customer hereby appomt% TRS as its agent for the limited purpose of excLaiting any required manifests, logs, or
other dectmrems relating to the services provided hereunder. The Customer signs tory above is inaborized to sign this Agreement

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IfIt
TERRA
rene,wa6
September 15, 2016
Byron M. Amick
Industrial Wastewater Permitting Section
Water Facilities Permit Division
Bureau of Water
South Carolina Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
P.Q. Box 1746
Wcd�insvil'1e,: GA 3C677
phone [phone]
RE: Request for Addition of Residuals Source Facility to SCDHEC Land App Permit No. ND0086479
and Permit No. ND0082741
Dear Mr. Amick,
Terra Renewal Services, Inc (TRS) respectfully requests the addition of the following industrial
residuals generating facility to the SCDHEC Land Application Permits listed above:
Name:
Innospec Inc.
Address:
500 Service Rd 1-85
Salisbury, NC 28144
Contact:
Allen Robey; SHE Manager
Phone:
[phone]
This facility is primarily engaged in the manufacturing of raw materials for the personal care
industry. The products are utilized by other industrial facilities to produce shampoos, body
washes, beauty bars, conditioners, and lotions. The source of the residuals is derived from the
clean-up of a batch reactor (i.e. waste activated sludge) and boil outs between batches. The SIC
Code for this facility is 2843. These are the materials to be land applied and are beneficial as a
soil amendment for agricultural operations when managed properly. Based on laboratory
analysis, there is no indication that the product would contain significant amounts of harmful
materials if applied, based on agronomic rates or be classified as a hazardous material. A copy of
an analysis for the material is provided as an attachment for your review.
TRS manages sufficient resources to land apply the residuals from this facility at agronomic rates
based on the guidelines of the existing permit. The estimated volume of residuals to be land
applied from this facility is approximately 50 dry tons (780,000 gallons) per year based on the
analysis provided.
Thank you for your assistance with this matter. If you have any questions, concerns, or require
additional data, you can contact me at [phone] or david.covle(a)terrarenewal.com. Please
send response to the following address at my attention:
Sincerely,
Ems- �-
David C. Coyle
Regional Environmental Manager

PAT MCCRORY
WN
Water Resources
ENVIRONMENTAL QUALITY
Innospec Performance Chemicals
P.O. Box 164
Salisbury, North Carolina 28159
Attention: Allen Robey, SHE Manager
Dear Mr. Robey:
rovemor
ONAY D :�W DER VAART
Secrelary
S. JAY ZIMMERMAN
d Director
January 11, 201�
Subject: Surface Irrigation Permit Inspection Report
Permit No. WQ0001077
Innospec — Spencer Plant
Rowan County
Staff of the Mooresville Regional Office conducted a compliance inspection on December
14th, 2015 as part of the permitting renewal process for the referenced facility. Questions
about the renewal may be directed. to David. SchlobohmCa_ncdenr.gov, with our permitting
staff in- Raleigh.
The inspection included a review of: records, the residuals processing and storage areas
and the .application sites. I would like to thank,you and Clay White.for your time during.
this site visit. -
The attached report reflects compliance at the time of inspection and should be self-
explanatory; however, should you have questions, please: contact me by phone:(704-235-
2184),or email ([e-mail]).
Sincerely, d
Maria Schutte, Environmental Specialist.
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ .
Attachment(s): WQ0009077Inspection Report
CC: Clay White, Operations Manager, Innospec Active Chemicals (Email)
State of North Carolina ( Environmental Quality. I Water Resources I Water Quality Regional Operations
Mooresville Regional Office) 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704 663 1699

State of North Carolina Department of Environmental Quality
Division of Water Resources
i
Pat McCrory, Governor
Donald R. van der Vaart, Secretary
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: Innospec Performance Chemicals County: Rowan
Permit No.:- W00001077 Issued: 6/27/2007 Expiration: 5/31/2016
Permittee Contact: Allen Robev (SHE Manager) Telephone No.: 104-633-8028
Contact & Facility ORC: Clay White Cert #SI 28828 Telephone No.: 704-639-7926
Email: [e-mail]
B/U ORC Name: Tim Mauldin Cert # SI 29214 Telephone No.: 704-633-8028
Reason for Inspection
_XROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System X Spray Irrigation Sludge Other
Inspection Date(s): December 14, 2015
Inspection Summary: (additional comments maybe included on attached pages)
This inspection was conducted in conjunction with the permit renewal. The treatment and application
systems appeared well maintained and to be operating in accordance with permit requirements at the time of
inspection.. The records and supporting data were in excellent order. This facility was last visited on March
.17, 2015 and comments noted during that visit were quickly addressed.
Please note:
The permit is. currently in the renewal process, as noted in the cover letter you may contact
David.Sehlobohm(amcdenr.gov directly with your renewal questions.
• The MRO should be informed of any changes to the contact information noted above.
Is a follow-up inspection necessary _yes X no
Inspector(s): Maria Schutte - Environmental Specialist; Ori Tuvia -,Engineer
Telephone No.: 704-663-1699 . Fax No.: 704-663-6040
Date of Inspection: December 14a', 2015

Surface Irrigation Inspection
WQ0001077 Innospec - Rowan County
pg. 2
Type
Activated Sludge Spray, low rate
Activated Sludge Drip, low rate
X Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational? If no, note below.
Influent Pump Station
Y All pumps present, operational Bypass structure present
Y Bar screen, maintained Free of excessive debris
Bars evenly spaced Bars excessively corroded
Back-up power
Flow Measurement — Influent
Y Is flowmeter calibrated annually?
Y . Is flowmeter operating properly?
Y Does flowmeter .operate continuously?
*N Does_ flowmeter record flow? This meter needs to be read manually.
Y Does flowmeter appear to monitor accurately?
Comments: * Per our conversations: Currently the total inflow to the system includes the pre-treatment
portion offlow sent to the City ofSalisbury and the remainder, which is either irrigated or held (stored) in
the plant. The recorded e f uent flow is the total daily volume applied to all fields:
Flow Measurement _ Water -Use Records
Y Is water use metered?
Y Are the daily average values properly calculated?
Disinfection NA
Is the system working? Is the system properly maintained?
Tablets Gas Liquid UV
If tablets, proper size? - Present in Cylinder(s)?
If gas/liquid, does cylinder/tank storage seem safe?
If bulbs, are replacement bulbs on hand?
- Is contact chamber free of sludge, solids and growth?
Flow Measurement— Effluent
Y Is the flowmeter calibrated annually?
Y Is the flowmeter operating properly?
Y Does the flowmeter monitor continuously? The PPI #2 flowmeter measures flow sent to the City of
Salisbury. The remainder is either sent to irrigation 'or_diverted back to plant, where it is stored until land
applied. Distribution events to the fields are based on time and pump rates.
Y Does the flowmeter appear to monitor accurately?
Effluent Storage Effluent can be sent to the fields for irrigation or diverted back to aeration basin 92
until land ap 1p ied.

Surface Irrigation Inspection pg. 3
WQ0001077 Innospec - Rowan County
Aeration Basins
Check any/all that apply
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
N Vegetation (is there excessive vegetation on the lagoon bank
NE Clay liner (if visible, is it intact) = unable to view well with foam and aeration
NA Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
Y Staff gauge (clearly marked)
N Evidence of overflow (vegetation discolored or laying down/broken)
.N Unusuaf color (very black, textile colors)
Y Foam (are a.ntifoam agents .used)
N Floating mats (sludge, plants, inorganics)
NA Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent. structure (free of obstructions, easily accessible)
Comments: This industrial facility processes products with surfactants so the WWTP often has foam
Residuals
Storage/treatment _Y
Comment: NE- during this inspection. Historically Wallace Farms was the contractor for disposal of the
sZud�e.
Disposal (final end use)
*Y Is the application equipment present and operational?
N Is application equipment in need repair?
NE Spray heads. calibrated this past year?
.Y Are cover crops the type.specified in permit? Permit is not speci ac just states suitable vegetative cover.
N Is cover crop in need of improvement?
N Signs of runoff? N Signs of ponding? N Signs of drift?
Y Are buffers adequate?
**Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields? .
NA Are restrictions for use of these areas specified?
Y Is permit being followed?
*Y Is site access restricted in accordance with.permit?
Comments: * The spray equipment was not running at the time of this visit but spray heads viewed were
intact and appeared well maintained. As noted in previous inspection reports Zone #3 infield 42 is not
being utilized. This is a gated access facility; however, there are no fences s ecjfically around the
application fields.. The application flelds appeared very well maintained
"The drip irrigation equipment is cumbersome to move around the field, but it is recommended that the
equipment be rotated (perhaps annually — the time frame is open for discussion) to take advantage of the
entire permitted application area and the rotation be documented in the maintenance logs

�r Surface Irrigation Inspection.
l WQ0001077 Innospec - Rowan County
pg. 4
Recordkeeping
Y Is permit available upon request?
*Y .Are flow rates less. than permitted flow?
Y Are monitoring reports present: NDMR Y NDAR Y
Y Are operational logs present? Y Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are all samples analyzed for the required parameters?
*.*Y Is field parameter certification required?
N Are there any 21, GW quality violations?
Y Are annual soil reports available?
Y Is the operation and maintenance manual. present? Complete?
N Has DWR received any complaints regarding the facility in the last 12 months?
Comments:
(permitted up to 60, 000 gpd). The remainder is the true effluent volume which does not appear to have
exceeded the 18, 000 gpd limit. The NDMRs occasional show days when the total flow exceeds 78 000 gpd
(the permit maximum), but the permittee has been able to show the elevated rates are Op call due to
reduced flow the day prior combined with large rain events and/or a delayed meter reading (der ormed
manuall
** A field parameter certification.is required. Per conversation with Mr Robey and Mr. White the
previous concerns expressed about the pH meter calibration method and instrument used have been
addressed.
Groundwater Monitoring
Y Does the permit require monitoring wells? If so,
Y Are the monitoring wells properly installed- according to the permit?
Y Are the wells properly identified?
*N Are the wells damaged?
Comments: * Not all monitoring wells were viewed during this inspection but those that were qp eared
well 'maintained.
Additional Comments:
in:

.:x .
Water Resources
ENVIRONMENTAL QUALITY
January 11, 2015
Innospec Performance Chemicals
P.O. Box 164
Spencer, North Carolina 28159
Attention: Allen Robey, SHE Manager
PAT MCCRORY
Governor
DONALD .R. VAN DER VAA:RT
Secretary
S. JAY ZIMMERMAN
Director
Subject: Surface Irrigation Permit Inspection Report
Permit No. WQ0001077
Innospec — Spencer Plant
Rowan County
Dear Mr. Robey:
Staff of the Mooresville Regional Office conducted a compliance inspection on December
14th, 2015 as part of the permitting renewal process for the referenced facility. Questions
about the renewal may be directed to David. SchlobohmCc)_ncdenr.gov, with our permitting
staff in Raleigh.
The inspection included a review of: records, the residuals processing and storage areas
and the application sites. I would like to thank you and Clay White for your time during
this site visit.
The attached report reflects compliance at the time of inspection and should be self-
explanatory; however, should you have questions, please.contact me by phone (704-235-
2184) or email ([e-mail]).
Sincerely,
Maria Schulte, Environmental Specialist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachment(s): WQ00010771nspection Report
CC: Clay White, Operations Manager, Innospec Active Chemicals (Email)
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional.0perations
Mooresville Regional Office) 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
vne Fin troo

State of North Carolina Department of Environmental Quality
Division of Water Resources
Pat McCrory, Governor
Donald R. van der Vaart, Secretary
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: Innospec Performance Chemicals
Permit No.: WQ0001077
Permittee Contact: Allen Robey (SHE Manager)
Contact & Facility ORC: Clay White Cert #SI 28828
Email: [e-mail]
B/U ORC Name: Tim Mauldin Cert # SI 29214
County: Rowan
Issued: 6/27/2007 Expiration: 5/31/2016
Telephone No.: 704-633-8028
Telephone No.: 704-639-7920
Telephone No.: 704-633-8028
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System X Spray Irrigation Sludge Other
Inspection Date(s): December 14, 2015
Inspection Summary: (additional comments may be included on attached pages)
This inspection was conducted in conjunction with the permit renewal. The treatment and application
systems appeared well maintained and to be operating in accordance with permit requirements at the time of
inspection. The -records and supporting data were in excellent order. This facility was last visited on March
17, 2015 and comments noted during that visit were quickly addressed.
Please note:
• The permit is currently in the renewal process, as noted in the cover letter you may contact
David.Schlobohm(iDncdenr.gov directly with your renewal questions.
• The MRO should be informed of any changes to the contact information noted above.
Is a follow-up inspection necessary _yes X no
Inspector(s): Maria Schulte - Environmental Specialist; Ori Tuvia - En ineer .
Telephone No.: 704-663-1699 . Fax No.: 704-663-6040
Date of Inspection: December 14th, 2015

Surface Irrigation Inspection
WQ0001077 Innospec.- Rowan County
pg. 2
Type
Activated Sludge Spray, low rate
Activated Sludge Drip, low rate
X Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational? If no, note below.
Influent Pumn Station
Y All pumps present, operational Bypass structure present
Y Bar screen, maintained Free of excessive debris
Bars evenly spaced Bars excessively corroded
Back-up power
Flow Measurement — Influent
Y Is flowmeter calibrated annually?
Y Is flowmeter operating properly?
Y Does flowmeter operate continuously?
*N Does flowmeter record flow? This meter needs to be read manually.
Y Does flowmeter appear to monitor accurately?
Comments: * Per our conversations: Currently the total inflow to the system includes the pre-treatment
portion offlow sent to the City of Salisbury and the remainder, which is either irrigated or held (stored) in
the plant The recorded effluent flow is the total daily volume applied to all fields.
Flow Measurement —Water-Use Records
Y Is water use metered?
Y Are the daily average values properly calculated?
Disinfection NA
Is the system working? Is the system properly maintained?
Tablets Gas Liquid UV
If tablets, proper size? Present in Cylinder(s)?
If gas/liquid, does cylinder/tank storage seem safe?
If bulbs, are replacement bulbs on hand?
Is contact chamber free of sludge, solids and growth?
Flow Measurement — Effluent
Y Is the_ flowmeter calibrated annually?
Y Is the flowmeter operating properly?
Y Does the flowmeter monitor continuously? The PPI #2 flowmeter measures flow sent to the City of
Salisbury. The remainder is either sent to irrigation or diverted back to plant, where it is stored until land
applied. Distribution events to the fields are based on time and pump rates.
Y Does the flowmeter appear to monitor accurately?
Effluent Storage Effluent can be sent to the fields for irrigation or diverted back to aeration basin 42
until land applied.

Surface Irrigation Inspection
WQ0001077 Innospec - Rowan County
Aeration Basins
Check any/all that apply
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
N Vegetation (is there excessive vegetation on the lagoon bank
NE Clay liner (if visible, is it intact) — unable to view well with foam and aeration
NA Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
Y Staff gauge (clearly marked)
N Evidence of overflow (vegetation discolored or laying down/broken)
N Unusual color (very black, textile colors)
Y Foam (are antifoam agents used)
N Floating mats (sludge, plants, inorganics)
NA Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
pg. 3
Comments: This industrial facility processes products with surfactants, so the WWTP often has foam.
Residuals
Storage/treatment Y
Comment: NE- during this inspection. Historically Wallace Farms was the contractor for disposal of the
sludgy
Disposal (final end use)
*Y Is the application equipment present and operational?
N Is application equipment in need repair?
NE Spray heads calibrated this past year?
Y Are cover crops the type specified in permit? Permit is not Weci is just states suitable vegetative cover.
N Is cover crop in need of improvement?
N Signs of runoff? N Signs of ponding? N Signs of drift?.
Y Are buffers adequate?
**Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
NA Are restrictions for use of these areas specified?
Y Is permit being followed?
*Y Is site access restricted in accordance with permit?
Comments: * The sprayquipment was not running at the time of this visit, but spray heads viewed were
intact and appeared well maintained. As noted in previous inspection reports, Zone 43 in field #2 is not
being utilized. This is a gated accessfacility; however, there are no fences specifically around the
pplication fields. The application fields appeared verb well maintained.
**The drip irrigation equipment is cumbersome to move around the field, but it is recommended that the
equipment be rotated (perhaps annually — the time frame is open for discussion) to take advantage of the
entire permitted application area and the rotation'be documented in the maintenance logs.

Surface Irrigation Inspection
WQ0001077 Innospec - Rowan County
pg. 4
Recordkeepinst
Y Is permit available upon request?
*Y Are flow rates less than permitted flow?
Y Are monitoring reports present: NDMR Y NDAR Y
Y Are. operational logs present? Y Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are all samples analyzed for the required parameters?
**Y Is field parameter certification required?
N Are there any 2L GW quality violations?
Y Are annual soil reports available?
Y Is the operation and maintenance manual present? Complete?
N Has DWR received any complaints regarding the facility in the last 12 months?
Comments: * The reported flow volumes currently include the volume sent to the City of Salisbury
(permitted yp to 60, 000 gpd). The remainder is the true effluent volume, which does not appear to have
exceeded the 18, 000 gpd limit. The NDMRs occasional show days when the total {low exceeds 78, 000 gpd
(the permit maximum), but the permittee has been able to show the elevated rates are typically due to
reduced flow the day prior combined with large rain events, and/or a delayed meter reading (performe
manuall .
* * A field parameter certification is required. Per conversation with, Mr. Robey and Mr. White, the
previous concerns expressed about the pH meter calibration method and instrument used have been
addressed.
Groundwater Monitoring
Y Does the permit require monitoring wells? If so,
Y Are the monitoring wells properly installed according to the permit?
Y Are the wells properly identified?
*N Are the wells damaged?
Comments: * Not all monitoring wells were viewed durin this is inspection, but those that were appeared
well maintained.
Additional Comments:
Production volume at the facility is expected to increase significantly over the next few years. Please
contact staff at the Mooresville Regional Office (704-663-1699) or permitting staff at the Central Office in
Raleigh (littp.11portal.ncdenr.org/web/wo/aps/lau/staft) to discuss your permit prior to increases in volume
and/or plant upgrades, as it is likely that a permit modification will be required.

Permit: WQ0001077
SOC:
County: Rowan
Region: Mooresville
Compliance Inspection Report
Effective: 07/12/13 Expiration: 05/31/16 owner: Innospec Active Chemicals LLC
Effective: Expiration: Facility: Innospec Performance Chemicals - Salisbury Facility
500 Hinkle Ln
Salisbury NC 28144
Contact Person: Allen Robey Title: Phone: [phone]
Directions to Facility:
From Salisbury, travel north on 1-85 to exit 81. At the top of the exit ramp turn left and cross over the highway. Turn right onto Hinkle
Lane. The plant entrance is at the end of the road (approx. 0.75 miles).
System Classifications: WW2, SI,
Primary ORC: James Cloyd White Certification: 25861 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0023884 City of Salisbury - City of Salisbury WWTP
Inspection Date: 12/14/2015 Entry Time: 12:57PM
Primary Inspector: Maria Schulte
Secondary Inspector(s):
Ori A Tuvia
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Irrigation
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Exit Time: 03:OOPM
Phone: [phone]
Inspection. Type: Compliance Evaluation
Treatment Flow Measurement -Effluent Treatment Flow Measurement -Influent Miscellaneous Questions
Treatment Flow Measurement -Water Treatment Record Keeping
Use Records
Treatment Lagoons .End Use -Irrigation Treatment Influent Pump Station
Treatment Clarifiers Treatment Flow Measurement Storage
Wells
(See attachment summary)
Page: 1

9
I
Permit: wQ0001077 Owner-Facility:Innospec Active Chemicals LLC
Inspection Date: 12/14/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This inspection was conducted as part of the permit renewal. The facility was recently visited in March of 2015 and
comments noted during that inspection were quickly addressed. The permittee appears to do a good job maintaining the
plant, fields, wells and their records. Per our conversation, the plant production (surfactants) is expected to grow
significantly or the next 5+ years; at which time, they will likely have to increase flow to Salisbury and perhaps do some
plant upgrades - either of which will require a permit modification.
Page: 2

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Permit: WQ0001077 Owner - Facility: Innospec Active Chemicals LLC
Inspection Date: 12/14/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Record Keeping
Yes No NA NE
Is effluent sampled for same parameters as GW?
0 ❑ ❑ ❑
Do effluent concentrations exceed GW standards?
❑ ❑ ❑
Are annual soil reports available?
❑ ❑ ❑
# Are PAN records required?
❑ ❑ ❑
# Did last soil report indicate a need for lime?
❑ 0 ❑ ❑
If so, has it been applied?
❑ ❑ 0 ❑
Are operational logs present?
0 ❑ ❑ ❑
Are lab sheets available for review?
E ❑ ❑ ❑
Do -lab sheets support data reported on NDMR?
0 ❑ ❑ ❑
Do lab sheets support data reported on GW-59s?
0 ❑ ❑ ❑
Are Operational and Maintenance records present?
E ❑ ❑ ❑
Were Operational and Maintenance records complete?
0 ❑ ❑ ❑
Has permittee been free of public complaints in last 12 months?
❑ ❑ ❑
Is a copy of the SOC readily available?
❑ ❑ N ❑
No treatment units bypassed since last inspection?
❑ 0 ❑ ❑
Comment: Most days are within flow limits. There is an occasional outlier, which can typically
be explained
by I wflows on previous day with rain events or a delay in reading the flowmeter.
MWs may not be located at the compliance boundary to adequately assess 2L violations. The
MRO is requesting w/ this renewal that Review & Compliance boundaries be established and
maps submitted: however, additional MWs may not be required at this time.
The most recent soils had been collected in Julv 2015, permittees had forgotten to retrieve from
website and were to look into that. The previous soil reports appeared okay - I do not recall the
2014 report requiring lime. Their effleunt pH is typically neutral.
Treatment Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit? E ❑ ❑ ❑
Do all treatment units appear to be operational? (if no, note below) ❑ ❑ ❑
Comment:
Treatment Clarifiers
Are the weirs level?
Are the weirs free of solids and algae?
Is the scum removal system operational?
Is the scum removal system accessible?.
Yes No NA NE
❑ ❑ ❑
❑ ❑ ❑
❑❑❑■
❑❑❑■
Page: 4

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Permit: WQ0001077 Owner - Facility:InnospecActive Chemicals LLC
Inspection Date: 12/14/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
01 -
Treatment Lagoons Yes No NA NE
Required freeboard 2
Feet
Actual freeboard
2.5
Feet
Are increments clearly marked on gauge at adequate intervals? _
❑ ❑ ❑
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall?
❑ ❑ ❑
No Evidence of overflow
❑ N ❑ ❑
Acceptable color
❑ ❑ ❑
Floating mats
❑ ❑ ❑
Excessive solids buildup
❑ ❑ ❑
Aerators/mixers
0 ❑ ❑ ❑
Effluent structure
❑ ❑ E ❑
Lagoon cover
❑ ❑ ❑
02 -
Treatment Lagoons
Yes No NA NE
Lagoon Type'
Combination
aerated/mixed
Primary/Secondary
Secondary
Influent structure
N ❑ ❑ ❑
Banks/berms (seepage and erosion)
❑ ❑ ❑
Vegetation (excessive vegetation on banks/berms)
❑ 0 ❑ ❑
Liner
❑ ❑ ❑
Liner Type
Full, concrete
Baffles/curtains
❑ ❑ ❑
Freeboard Marker
N ❑ ❑ ❑
Required freeboard
2
Feet
Actual freeboard
2.5
Feet
Are increments clearly marked on gauge at adequate intervals?
0 ❑ ❑ ❑
Page: 7

Permit: WQ0001077 Owner- Facility: Innospec Active Chemicals LLC
Inspection Date: 12/14/2015 Inspection Type : Compliance Evaluation Reason for Visit: Routine
02 -
Treatment Laqoons
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall?
No Evidence of overflow
Acceptable color
Floating mats
Excessive solids buildup
Aerators/mixers
Effluent structure
Lagoon cover
CONV000060
Abandonment
Temporary abandonment completed such that well cannot be accessed without use of tools?
Permanently abandonment completed in accordance with applicable rules?
Well abandonment comments
Comment:
CONV000060
Casing
Type
Depth (ft b.l.$)
Weight/thickness
Height (A.L.S)
Comment:
CONV000060
Development
Turbidity
Comment:
(Decimal range, e.g. 15.5 to 25.5 ft)
CONV000060
Disinfection
Disinfection in compliance with standards?
Describe disinfection if observed
Yes No NA NE
❑ ❑ ❑
❑ M ❑ ❑
■❑❑❑
❑ M ❑ ❑
❑❑❑■
!❑❑❑
❑ ❑ ❑
❑ ❑ M ❑
Yes No NA NE
❑ ❑ ❑ ❑
Yes No NA NE
Yes No NA NE
Yes No NA NE
❑ ❑ ❑ ❑
Page: 8

Permit: WQ0001077 Owner - Facility: Innospec Active Chemicals LLC
Inspection Date: 12/14/2015 Inspection Type : Compliance Evaluation Reason for Visit: Routine
CONV000060
Disinfection
Comment:
CONV000060
Fluids/Additives
Type
Comment:
CONV000060
Grout
Type
Thickness
Depth (Decimal range, e.g. 15.5 to 25.5 ft)
Comment:
CONV000060
GW-1/30 Construction Record
Well construction/abandonment record submitted?
Comment:
CONV000060
ID Plate
ID Plate present & properly completed?
Well Contractor indicated on ID Plate?
Comment:
CONV000060
Location
Distance from septic tank & drainfield (feet)
Distance from other waste disposal/collection (feet)
Comment
Distance from other pollution source (feet)
Comment
Is well location subject to flooding?
Minimum distance to property boundary (ft)
Comment: No is the correct answer. Some MWs were viewed for maintenance condition only!
Yes No NA NE
Yes No NA NE
Yes No NA NE
Yes No NA NE
❑ ❑ ❑ ❑
Yes No NA NE
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
Yes No NA NE
❑ N ❑ ❑
Page: 9

Permit: WQ0001077 ' - Owner - Facility: Innospec Active Chemicals LLC
Inspection Date: 12/14/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
CONV000060
Pump Installation
Yes No NA NE
Pump Contractor ID plate present? ❑ ❑ ❑ ❑
Date pump installed
Pump installation violations, if any
Comment:
CONV000060
Sampling
INFLUENT (water source) lab sample ID #
EFFLUENT (injected fluid) lab sample ID #
Comment: some MWs were viewed for maintenance condition only!
CONV000060
Screens
Screened or Open Borehole Completion?
Screened/open borehole interval (ft b.l.$)
Comment:
CONV000060
System Operation
Describe inconsistencies between application and observed operation/construction
some MWs were viewed for maintenance condition only!
Comment: some MWs were viewed for maintenance condition only!
CONV000060
Wellhead Completion
Access port present?
Spigot present?
Comment:
Suction Line meets standards?
Tee Get). meets standards?
If naturally flowing well, is flow valved?
Vent meets standards?
Watertight pipe entry meets standards?
Well Entry meets standards?
Pitless adaptor (if used) meets standards?
Well enclosure meets standards?
Yes No NA NE
Yes No NA NE
Yes No NA NE
Yes No NA NE
❑. ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ El,
Page: 10

60
Permit: WQ0001077 Owner - Facility: Innospec Active Chemicals LLC
Inspection Date: 12/14/2015 Inspection Type : Compliance Evaluation Reason_forVsit: Routine
CONV000060
Wellhead Completion
Infuent (water source) sampling port present and labeled?
Effluent (injected fluid) sampling port present and labeled?
r
Yes No NA NE
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
Page: 11

;�-"
Page 1 of 2
Google Maps 610 East Center Avenue, Mooresville, NC Drive 29.4 miles, 36 min
to 500 Sry Road 1- 85, Salisbury, NC 28144
Map data ©2015 Google 2 mi L
610 E Center Ave
Mooresville, NC 28115
Take N Magnolia St to Culp St
mi)
t 1. Head east on E Center Ave toward
Evergreen St
mi
+1 2. Turn left onto N Magnolia St
mi
1+ 3. Turn right onto E Iredell Ave
._._._.—_---- —_ _—_ _..377 ft
47 4. Turn left onto Culp St
mi)
Follow NC-152 and 1-85 N to Sry Rd 1- 85 in
Salisbury
2-mirr(2-7.9 mi)
r 5. Turn right onto NC-152/N Main St
Continue to follow NC-152
2.0 mi
FA

Page 2 of 2
6.
Slight right onto NC-150 E/NC-152 E
mi
f
7.
Turn right onto NC-152 E
12.0 mi
°t%
41
8.
Turn left onto US-29 N
t
9.
Continue straight onto US-29 Connector
N
-----
----- -- — -- —
—�.2 mi
10.
Merge onto 1-85 N
mi
11.
Take exit 81 toward Spencer
__.......
mi
41
12.
Turn left onto Long Ferry Rd
------- _ ________---0.2
mi
r► 13. Turn right at the 2nd cross street
onto Sry Rd 1- 85
Destination will be on the left
mi)
500 Sry Road 1- 85
Salisbury, NO 28144
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.
11) 11 A 41n1 C

R
Va
NCDENIt
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
April 10, 2015
Innospec Performance Chemicals
P.O. Box 164
Salisbury, North Carolina 28159
Attention: Clay White, _Operations Manager
Dear Mr. White:
Donald van der Vaart
Secretary
Subject: Surface Irrigation Permit Inspection Report
Permit No. WQ0001077
Innospec — Spencer Plant
Rowan County
°.Enclosed you will find the report for the compliance inspection that was conducted on March
17th, 2015 for the referenced facility's treatment and disposal system. The inspection
included a review of: records, the residuals processing and storage areas and the
application sites. I would like to thank you and your staff for your time during the inspection.
Per conversation and email recent freeboard concerns from weather conditions have been
addressed and freeboard levels are again > 2 feet. In addition, data questions were
adequately addressed during our meeting or in subsequent email; however, there are a
couple of points worth noting to maintain program compliance: .
• Address effluent pH meter calibration concern noted under the Recordkeeping
comments section on pg. 4 of the report.
• The permit expiration date is May 31, 2016. Per permit requirements, a
renewal application is due within 180 days of expiration.
The attached report should be self-explanatory; however, should you have questions,
please contact me by phone [phone]) or email (maria.schutteAncdenr. ov).
Sincerely,
Maria Schutte, Environmental Specialist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
Attachment(s): WQ0601077 Inspection Report
CC: Allen Robey, SHE Manager, Innospec Active Chemicals (Email)
Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Phone: [phone] Fax: [phone]Customer Service 1-877-623-6748
Internet: www.ncdenr.gov
An Enual Oonortunity 1 Affirmative Action Emolover— Made in Dart by recycled Daoer

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Resources
Pat McCrory, Governor
Donald van der Vaart, Secretary
ITZ;K
A4i 0
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: Innospec Performance Chemicals
Permit No.: W00001077
Permittee Contact: Allen Robey (SHE Manager)
Contact & Facility ORC: Clay White Cert #SI 28828
Email: claw innospecinc.com
B/U ORC Name: Tim Mauldin Cert # SI 29214
Reason for Inspection
County: Rowan
Issued: 6/27/2007 'Expiration: 5/31/2016
Telephone No.: 704-633-8028
Telephone No.: 704-639-7920
Telephone No.: 704-633-8028
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System X Spray Irrigation Sludge Other
Inspection Date(s): March 17, 2015
Inspection Summary: (additional comments may be included on attached pages)
This inspection was conducted in -part as a response to recent self -reporting of weather related freeboard
issues, and included residuals processing, storage, end -use and a records review. Freeboard issues were
adequately addressed and lagoon levels were > 2ft, the treatment system appeared to be operating properly
and the disposal fields appeared to be in excellent condition, at the time of inspection.
Data records were found to be in very good order. The MRO had a couple of data related questions which
were either addressed at the meeting or via follow-up email. The MRO is communicating with Central
Office (CO) in Raleigh to clarify a continuing flow reporting question.
Please note:
• —The MRO has some concerns aboutthe effluent pH -measurement. __The meter calibration—c oes
not meet method requirements. Please see the Recordkeening comments section on pg. 4 for a
more detailed explanation.
• The permit expiration date is May 31st, 2016. A renewal application is due 180 days prior to
expiration and may be found at: http://portal.nedenr.orghveb/wa/aps/lau/applications. Please
contact me with any questions about this permit or the renewal.
• The MRO should be informed of any changes to the contact information noted above.
Is a follow-up inspection necessary _yes X no
Inspector(s): Maria Schutte - Environmental Specialist
Telephone No.: 704-663-1699 Fax No.: 704-663-6040
Date of Inspection: March 17th, 2015

Surface Irrigation Inspection
WQ0001077 Innospec - Rowan County
pg. 2
Tvpe
Activated Sludge Spray, low rate
Activated Sludge Drip, low rate
X Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Influent Pump Station
Y All pumps present, operational
Y Bar screen, maintained
Bars evenly spaced
Back-up power
Bypass structure present
Free of excessive debris
Bars excessively corroded
Flow Measurement — Influent
Y Is flowmeter calibrated annually?
Y Is flowmeter operating properly?
Y Does flowmeter operate continuously?
*N Does flowmeter record flow? It appears that this meter needs to be read manually.
Y Does flowmeter appear to monitor accurately?
Comments: * Currentlythe he inflow to the system includes the pre-treatment portion flow sent to the City
o Salisbury. The present reporting system does not allow for the reporting of more than one flowratelday.
MRO staff recommends the permittee continue reportin as they have, until the MRO and Central Office staff
can address the issue.
Flow Measurement — Water -Use Records
Y Is water use metered?
Y Are the daily average values properly calculated?
Disinfection NA
Is the system working? Is the system properly maintained?
Tablets Gas Liquid LTV
If tablets, proper size? Present in Cylinder(s)?
- - - -- -If -gas/liquid;-d-oes cylinder/tank-storage seem safe?-- -------------------------- .- - - ---- - - - -
If bulbs, are replacement bulbs on hand?
Is contact chamber free of sludge, solids and growth?
Flow Measurement — Effluent
Y Is the flowmeter calibrated annually?
Y Is the flowmeter operating properly?
Y Does the flowmeter monitor continuously? The PPI 92 flowmeter measures flow sent to the QU of
Salisburv. The remainder is diverted back to Lagoon 42. where it is stored until land annlied. Distribution
events to the fields are based on time and pump rates.
Y Does the flowmeter appear to monitor accurately?

Surface Irrigation Inspection pg. 3
WQ0001077 Innospec - Rowan County
Effluent Storage Effluent is stored in aeration basin #2 until land applied.
Aeration Basins
Check any/all that apply
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
N Vegetation (is there excessive vegetation on the lagoon bank
NE Clay liner (if visible, is it intact) — unable to view well with foam and aeration
NA Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
Y Staff gauge (clearly marked)
N Evidence of overflow (vegetation discolored or laying down/broken)
N Unusual color (very black, textile colors)
Y Foam (are antifoam agents used)
N Floating mats (sludge, plants, inorganics)
NA Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Comments: This industrial facility processes products with surfactants, so the WWTP often has foam.
Residuals
storage/treatment Y
Comment: NE- during this inspection. Historically Wallace Farms was the contractor for disposal of the
sludge.
Disposal (final end use)
*Y Is the application equipment present and operational?
N Is application equipment in need repair?
NE Spray heads calibrated this past year?
Y Are cover crops the type specified in permit? Permit is not specific iust states suitable vegetative cover.
N Is cover crop in need of improvement?
N Signs of runoff? N Signs of ponding? N Signs of drift?
Y Are buffers adequate?
*Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
NA Are restrictions for use of these areas specified?
- -Y--Is permit being followed? - --- - -- - - -
*Y Is site access restricted in accordance with permit?
Comments: * The spray equipment was not running at the time of this visit, but spray heads viewed were
intact and appeared well maintained. As noted in previous inspection reports, Zone #3 in field #2 is not
being utilized. This is a gated accessfacility; however, there are no fences speci acally around the
application fields. The application fields appeared very well maintained.

Surface Irrigation Inspection
WQ0001077 Innospec - Rowan County
pg. 4
Recordkeeping
Y Is permit available upon request?
*Y Are flow rates less than permitted flow?
Y Are monitoring reports present: NDMR Y NDAR Y
Y Are operational logs present? Y Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are all samples analyzed for the required parameters?
**NE Is field parameter certification required?
N Are there any 2L GW quality violations?
Y Are annual soil reports available?
Y Is the operation and maintenance manual present? Complete?
N Has DWR received any complaints regarding the facility in the last 12 months?
Comments: * ' The reported flow volumes currently include the volume sent to the City of Salisbury
(permitted up to 60, 000 gpd). The remainder is the true effluent volume, which does not appear to have
exceeded the 18, 000 gpd limit. The MRO noted a day when the total {low exceeded 78, 000 gpd (the permit
maximum), and the permittee was able to show the elevated rate was due to reduced flow the de prior
combined with a > 2in rain event.
** Per the last inspection report, a field parameter certif cation is required. At the time of this inspection,
effluent pH readings were being analyzed on the in-house lab meter used for the production process, which
calibrates with 4&7 buffers, but does not check a third. -MRO staff recommended the ORC or BU-ORC
check a third std buffer- with their effluent pH measurements for validation; however, if they are maintaining
a NC field certification, then they should be analyziLzg pH with that same field meter and calibrating in
accordance with the proper procedure.
Groundwater Monitoring
Y Does the permit require monitoring wells? If so,
Y Are the monitoring wells properly installed according to the permit?
Y Are the wells properly identified?
*N Are the wells damaged?
Comments: * Not all monitoring wells were viewed during this inspection, but those that were appeared
well maintained.

Schutte, Maria
From: Allen Robey <[e-mail]>
Sent: Monday, March 16, 2015 11:28 AM
To: Schutte, Maria
Cc: Clay White
Subject: RE: Innospec Salisbury SI permit No. WQ0001077 freeboard
Hard hat, safety glasses, and steel toed boots. We have all of this available if you need.
Allen Robey
SHE Manager
Innospec Performance Chemicals
High Point Office: [phone]
Salisbury Office: [phone]
Mobile: [phone]
From: Schutte, Maria [mailto:maria.schutte(d)ncdenr.aov]
Sent: March 16, 2015 11:27 AM
To: Allen Robey
Cc: Clay White
Subject: RE: Innospec Salisbury SI permit No. WQ0001077 freeboard
Allen,
That is good news. Thank You for the update and I look forward to meeting you as well. I should have. asked earlier, but
what safety equipment is required at your facility?
Maria
From: Allen Robey [mailto:Allen.Robey0innospecinc.com]
Sent: Monday, March 16, 2015 9:46 AM
To: Schutte, Maria
Cc: Vic Jameson; Jerry Putnam; Clay White; Richard Blaisdell
Subject: RE: Innospec Salisbury SI permit No. WQ0001077 freeboard
Maria, I wanted to let you know that we are now above our freeboard limit at 2'4". We plan on continuing to bypass
sending water to the City until this Wednesday when we will cease the bypass and begin discharging treated water to
the City. We look forward to meeting you tomorrow.
Regards,
Allen Robey
SHE Manager
Innospec Performance Chemicals
High Point Office: [phone]
Salisbury Office: [phone]
Mobile: [phone]

From: Allen Robey
Sent: March 09, 2015 1:35 PM
To: maria.schutte(a)ncdenr.gov
Cc: Vic Jameson; Jerry Putnam; Clay White; Richard Blaisdell
Subject: RE: Innospec Salisbury SI permit No. WQ0001077 freeboard
Maria, in follow up to our phone conversation this morning, we are currently at 11" of freeboard. Innospec has taken
proactive measures in anticipation of the upcoming rain events. We have rented approximately 60,000 gallons of
storage; these tanks are currently being filled. This should give us approximately 6 more inches of freeboard. This
water will be sent back through the treatment system once we gain freeboard. In addition, the City of Salisbury/Rowan
Utilities has given us a temporary interim permit good for 30 days that allows an increase in the TSS we can send them
from 75 pounds per day to 300 pounds per day. A copy of the revised sections of the permit is attached for
reference. Please let me know if you have any questions or need additional information.
' Allen Robey
SHE Manager
Innospec Performance Chemicals
High Point Office: [phone]
Salisbury Office: [phone]
Mobile: [phone]
From: Clay White
Sent: February 20, 2015 10:37 AM
To: maria.schutteC�ncdenr.gov
Cc: Allen Robey; Vic Jameson; Jerry Putnam
Subject: Innospec Salisbury SI permit No. WQ0001077 freeboard
Maria, following up from phone call this morning. Freeboard in our aerated lagoons has dropped below our permit limit
of two feet.
As of this morning our freeboard level is 1'10". Due to freezing temperatures we are not able to maintain waste water
flow to the city or discharge to spray fields.
We are experiencing issues with our chemical feed lines freezing up attributed to insulation problems and cold weather.
Insulation issues around the chemical feed lines is being addressed by repairing a failed heat trace line and by installing
an electrically heated blanket on a chemical feed tote. We expect to be discharging tomorrow afternoon when the
weather warms up. Please let us know if you have any -questions or need additional information.
Regards,
Clay White
Operations Coordinator / Facility ORC
Innospec Performance Chemicals
Tel: [phone]
Mobile: [phone]
Fax: [phone]

,01
A 4 0 W
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Charles Wakild, P.E. John E. Skvarla, III
Governor Division of Water Quality Secretary
June 6, 2013
Innospec Active Chemicals
Post Office Box 164
Spencer, North Carolina 28159
Attention: Clay White, Operations Manager
RE: Surface Irrigation Inspection Report
Spencer Plant
Permit No. WQ0001077
Rowan County, N.C.
Dear Mr. White:
Enclosed you will find the report for the annual compliance inspection that was conducted on
May 22, 2013. The treatment and disposal system appeared to be operating satisfactorily.
As noted in the report, the maximum permitted flow to the City of Salisbury has been increased
to 60,000 gpd. In order to avoid compliance problems, a permit modification should be
requested for this matter as well as the permittee name change so that the permit reflects the
current situation. You should submit your request to:
Jon Risgaard, Land Application Unit Supervisor
NCDENR/DWQ
Mail Service Center 1636
Raleigh, NC 27699-1636
Should you have any questions, feel free to call me at 704/235-2183 or contact me via email at:
[e-mail].
Sincerely,
Peggy Finley
Environmental Specialist
Enclosure: Inspection Report
Cc: Allen Robey, SHE Manager, Innospec Active Chemicals —sent electronically
MAF/innospec inspection rpt 5-22-13
Nne
orthCarohi
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] a�Ja�uraja j
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterquality.org f/ V l[V

4
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Pat McCrory, Governor
John E. Skvarla, III, Secretary
Charles Wakild, P.E., Director
A10"?W'A
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
Owner: Innospec Performance Chemicals
Permit # W00001077
Issuance Date: 6/27/07
Permittee Contact: Clay White
ORC Name: Clay White Cert #28828
Email address: [e-mail]
Backup ORC Name: Tim Mauldin Cert #29214
County: Rowan
Project Name: Innospec
Expiration Date: 5/31/16
Telephone No.: 704/639-7920
Tel. No.: 704/633-8028
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Summary: (additional comments may be included on attached pages)
The treatment and disposal system appeared to be operating in compliance with the permit.
The irrigation fields appeared to be in good condition. Recordkeeping was complete and in
good order.
Maintaining the required freeboard in the lagoons presents a challenge at times but the ORC
monitors the situation closely.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Environmental Specialist; David Hill, Sr. Environmental Tech
Tel. No. 704/235-2183 Fax No. 704/663-6040 704/235-2186
Date of Inspection: 5/22/13

!k_�
W
Surface Irrigation
Permit #WQ0001077
Type
Activated Sludge Spray, low rate
Activated Sludge Drip, low rate
_X_ Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Comment:
Influent DumD station
X All pumps present, operational Bypass structure present
X Bar screen, maintained Free of excessive debris
Bars evenly spaced Bars excessively corroded
Back-up power
Flow Measurement — Influent
_X_ Is flowmeter calibrated annually?
_ X_ Is flowmeter operating properly?
_ X_ Does flowmeter operate continuously?
_ X_ Does flowmeter record flow?
X _ Does flowmeter appear to monitor accurately?
Flow Measurement — Water -Use Records
Is water use metered?
Are the daily average values properly calculated?
Page 2
Disinfection NA
Is the system working? Is the system properly maintained?
Tablets Gas Liquid UV
If tablets, proper size? Present in Cylinder(s)?
If gas/liquid, does cylinder/tank storage seem safe?
If bulbs, are replacement bulbs on hand?
Is contact chamber free of sludge, solids and growth?
Flow Measurement — Effluent
_Y_ Is the flowmeter calibrated annually?
_ Y_ Is the flowmeter operating properly?
Y _ Does the flowmeter monitor continuously?
Y Does the flowmeter appear to monitor accurately?

.*
Surface Irrigation
Permit #WQ0001077
Page 3
Aeration Basins
Check any/all that apply
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N _ Vegetation (is there excessive vegetation on the lagoon bank
Y _ Clay liner (if visible, is it intact)
Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
_Y Staff gauge (clearly marked)
_N Evidence of overflow (vegetation discolored or laying down/broken)
Unusual color (very black, textile colors)
Y Foam (are antifoam agents used)
Floating mats (sludge, plants, inorganics)
NA Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Residuals
storage/treatment _Y
Comment: Wallace Farms is still the contractor for disposal of the.sludge.
Disposal (final end use)
Y Is the application equipment present and operational?
_N_ Is application equipment in need repair?
_N_ Spray heads calibrated this past year?
_Y_ Are cover crops the type specified in permit?
_N_ Is cover crop in need of improvement?
_N_ Signs of runoff? _N_ Signs of ponding? N Signs of drift?
Y Are buffers adequate?
Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
NA Are restrictions for use of these areas specified?
Y Is site access restricted in accordance with permit?
Comments: The fields appear to be in good condition. *Zone #3 in sprayfield #2 is not utilized.

Surface Irrigation Page 4
Permit #WQ0001077
Recordkeeping
Y Is permit available upon request?
_N*_ Are flow rates less than permitted under current DWQ permit?
Y Are monitoring reports present: NDMR _ NDAR
Y Are operational logs present? _Y Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
_Y_ Are all samples analyzed for the required parameters?
_Y_ Is field parameter certification required?
_N_ Are there any 2L GW quality violations?
Y Are annual soil reports available?
Y_ Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: * Approved maximum flows to the City of Salisbury's sewer system were
increased to 60,000 gpd last year. Monthly PAN calculations were available for review.
Groundwater Monitoring
Y Does the permit require monitoring wells? If so,
Y are the monitoring wells properly installed according to the permit?
_Y_ are the wells properly identified?
_N_ are the wells damaged?

-14
Finley, Peggy
From: Clay White [[e-mail]]
Sent: Wednesday, June 26, 2013 8:55 AM
To: Finley, Peggy
Cc: Allen Robey
Subject: RE: Innospec freeboard
Thanks Peggy, It has been a pleasure working with you.
Best wishes for a great retirement!
afr Clay White
Operations Coordinator
Innospec Performance Chemicals
Tel: [phone]
Mobile: [phone]
Fax: [phone]
From: Finley, Peggy [mailto:[e-mail]]
Sent: Wednesday, June 26, 2013 8:51 AM
To: Clay White
Cc: Allen Robey; Hill, David A
Subject: RE: Innospec freeboard
Good. I understand though that the weather predictions are for a wet summer. Good luck.
I'm glad that the company is thinking about increasing treatment capacity. It may be a matter that will need to be
addressed sooner than later if y'all continue to be challenged with the freeboard issue. It will likely be a topic of
discussion during next year's inspection. David is going to be the point of contact for you. You can reach him at
704/235-2186 or at [e-mail].
Peggy
From: Clay White[mailto:[e-mail]
Sent: Tuesday, June 25, 2013 5:14 PM
To: Finley, Peggy
Cc: Allen Robey
Subject: Innospec freeboard
Peggy, we are now back to 2' of freeboard in our aeration basins.
Regards,

' Clay White
Operations Coordinator
Innospec Performance Chemicals
Tel: [phone]
Mobile: [phone]
Fax: [phone]

11T
", • .,�
In compliance with the provisions of North Carolina General Statute 143-215.1, any applicable Federal categorical pretreatment
regulations, all other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the City of Salisbury Utilities Ordinance; the following industry, hereafter referred to by name or as the pernvttee:
SIC Coale: 2843
40 CFR Category: N/A
Facili Location: 775 Hackett Street
Mailing Address: P.O. BOX 164
Salisb North Carolina 28159-0164
Contact & Phone: Mr. Allen Robey, SIZE Manager — 704-633-8028
Alternate Contact & Phone: Mr. Jerry Putnam, Operations Manager — 704-639-7904
is hereby authorized to discharge wastewater from the facility located at the above listed address into the sanitary sewer collection system
and the Grant Creek and Town Creek Wastewater Treatment Trains of the Salisbury -Rowan Utilities listed below:
Name of City Facility:
SALISBURY-ROWAN
Name of Treatment Train
Grant Creek Treatment Train WWTP
NPOES Number:
NCO023884
Treatment Facility Location
1915 Grubby Ferry Rd.
Salisbury S encer), N.C. 28144-1248
This permit and the authorization to discharge shall become effective at midnight on:
November 1, 2011
This permit and the authorization to discharge shall e- xpire at midnight on:
October 31, 20:
Date: - &LTO 2 & , 2011
SIU CODE: [PC
1
c
so—ng Basinger
Environmental Services Manager
Permit P#0038
Page 1 of 17

Section 1. 1UF Basic Information:
General information on the discharger, the receiving POTW, the POTW's NPDES permit number, the effective date and expiration
date of this permit,and the SIU's SIC code and Federal category, if applicable, can be found on the cover page of this document
Section 2. "Modification Historv:
Effective Date Renewal or Modification Description of changes over nredous iUP
I1/01/10 New Changed from a local SIU to SIU
11/01111 Modification New permit format. Added state language
for Part II General Conditions (2) Reporting;
decreased due date for permit renewal applications
and notificaton of process changes from 190 to 90
days; added Slug/Spill chart to Special Conditions;
decreased POTW monitoring frequency from 1/6 to
1/12; revised Part I Specific Conditions (9)(a)
Monitoring by the Permittee (Self-Mouitoring);
updated Part III Special Conditions (4); added Part III
Special Conditions (5) Certified Laboratory Analysis;
changed Part I Special Conditions (10)(A)(3) from 0.5
hours to 1.0 hour; updated Part I Specific Conditions
(8)(e&1) Definitions; increased pH range from 6-9 s.u.
to 6-10 s u.; approval to discharge a new process:
Pureact SFS to the pretreatment system; increased
permit limits for SOD, COD, Zn, and Chromium;
removed monitoring requirements for Silver; removed
maximum monthly average flow permit limit; updated
Description of SIU's Pretreatment System Units;
added monitoring requirement for Phenols at 116.
Section 3. Authorization to Discharge:
a) The permittee is hereby authorized to discharge wastewater in accordance with the effluent limitations, monitoring requirements,
and all other conditions set forth in this Industrial User Pretreatment Permit (IUP) into the sewer collection system and Grant Creek
or Town Creek Wastewater Treatment Train Facility identified on the cover page of this permit.
b) The permittee is hereby authorized to continue operation of and discharge wastewater from the following treatment or
pretreatment facilities. These facilities must correspond to the units listed on both the application and inspection forms. The
following treatment or pretreatment facilities as described in the permittee's application for this discharge permit:
DESCRIPTION OF SIU's PRETREATMENT SYSTEM UNITS
1. Influent flow measurement 8. Secondary clarification with chemical
2. Bar Screen precipitation
3. Biological treatment activated sludge 4. Effluent lift station
4. 8000 gallon sludge tank 10. Effluent flow measurement at sewer discharge
5. Flow equalization 11. Spill protection throughout facility
6. Defoamer
7. Neutralization
c) The permittee is hereby authorized to, if required by the Environmental Services Division of Salisbury -Rowan Utilities, and after
receiving Authorization to Construct (A to C), construct and operate additional pretreatment units as needed to meet the effluent
limitations described in this permit.
SIU CODE: IPC Permit #0038
Page 2 of 17

Section 4. Descripition of IUP Discharges:
Pipe 41 Discharge Point
Pipe 01 is located in the sump directly between the effluent side of the biological lagoons. The sump is encased in a vault
and has a metal lid. Treated effluent from clarifier is piped into sump then pumped to main server line. Effluent is an
intermittent process discharge from the manufacture of surfactants and emollients for personal care industry and
surfactants for emulsion polymerization. IU has capability of discharging treated unclarified wastewater to spray irrigation
fields as an alternative to sewer discharge.
Section 5. Schematic of Monitoring Locations:
The facility schematic and description of monitoring location(s) given below must show enough detail such that someone unfamiliar
with the facility could readily fund and identify the monitoring location(s) and connection to the sewer. include and identify all
regulated pipes. The location)of the above discharge point(s) is shown in the diagram below:
Flow from Piant
,- Influent Weir with bar Screen
Aeration Lagoon Capacity
250,000/gal
Aeration Lagoon Capacity
25000/gal
00000
100 gallon manhole poly
aluminum chloride feed
Sample Point
To POTW 71
I Lift Station I
SIU CODE: L
250 gallon Roe tank
polymer/caustic feed
l0,000 gall., ci.,irier
Permit #0038
Page 3 of 17

WAstewater piping diagram
E
g
StU CODE: [PC Permit #0038
Page 4 of 17

y 1 t0,4Dti3ey
1 �
n
rnw
SIU CODE: [PC
LsIle drainage map
� ash; a,� W'•v'_..—_....,a.-,._._
STORACt
f
Permit 90038
Page 5 of 17

Section 6: Effluent Limits and Monitoring Requirements:
EFFLUENT LIMITS TABLE I - Pipe #01
W WTP 'Treatment Train:
POTW:
Grant Creek Treatment Train
Salisbury -Rowan
SILT name:
Innospec Active Chemicals
POTS' NPDES #:
NCO023884
Permit #:
0038
Effective Date:
November 1, 2011
Pipe #:
#01
Expiration Date:
October 31, 2012
40 CFR #:
THE LIMITS IN TMS TABLE ARE: N/A '
1)Limits for the Entire Permit Period_ X
2)Interim Limits for Period #1:
3)Interim Limits for Period #2:
)Final Limits
' DISCI3ARGE FLOW
LIMITS
Daily Maximum
Monthly Avg.
0.060 MGD
ii
1, pH Limit - The pH of this discharge, identified by the pipe number indicated above, shall be within the range of 6.00 to
10.00 standard units at all times.
2. Temperature Limit - The temperature of the discharge, identified by the pipe number stated above, shall be less than
65.5 degrees C. at all times.
3. pH and Temperature shall be measured at the discharge site on a grab sample, and each shall be measured
immediately upon collection of the grab sample.
Limited Parameter
and
Units
Daily
Maximum
Limit
Monthly
Average
Limit
Industry
Monitoring
Frequency
POTW
Monitoring
Frequency
Sample
Collection
Method
Flow, MGD
0.060
*Daily
1/12
Discharge Flow Meter
pH, s.u. (1,3)
2/6
1/12
Grab
Temperature, Celsius (2,3)
216
1,12
Grab
BOD, lblday
550
216
1/12
Corposite
COD, lb/day
1100
2/6
1/12
Composite
TSS, lb/day
75
216
1/12
Composite
TKN, lb/day
15
2/6
1/12
Composite
Ammonia, mg/1
Monitor
1/6
1/12
Composite
Chloride, mg/i
Monitor
1/6
1/12
Composite
Cyanide, mg/l
0.010
216
1112
Grab
Total Nitrite + Nitrate, mg/1
Monitor
2/6
1112
Composite
Total Phosphorus, mg/l
Monitor
1/6
1/12
Composite
Mercury, mg/l 4
Monitor
116
1/12
Composite
Total Cadmium, lb/day
0,005
216
1/12
Composite
Total Chromium, lb/day
0,008
2/6
1/12
Composite
Total Copper, lb/day
0.025
2/6
1112
Composite
Total Lead, lb/day
0.005
2/6
1112
Composite
Total Nickel, lb/day
0.015
2/6
1/12
Composite
Total zinc, lb/day
0.500
2/6
1112
Composite
Phenols, mg/L
Monitor
1/6
1112
Grab
**Where shall be no discharge of floating solids or visible foam in other than trace amounts.
4 Monitor per Special Conditions in Part III of this permit.
51U CODE: LC Permit 00038
Page 6of17

Section 7. Semi -Annual Reports - Requirements for Industrial Dischargers:
The permittee, whether subject to Federal categorical standards or not (40 CFR 403.12 (e) &: 40 CFR 403.12 (h)], shalI submit Semi -
Annual Reports covering the months of JanuM through June, and the months of July through December,
The report for the period of
January through June shall be postmarked no later than July 10tb, The report for July through December shall be postmarked no later
than January 10th, and must contain the following information listed below.
A. Non -Categorical Dischargers shall submit:
(1) A description of the nature, concentration, and flow rate for any new or previously unreported discharge containing any substance
limited by this permit or prohibited by the Salisbury Utilities Ordinance.
(2) The results of any monitoring in excess of that required by this permit, if the results were determined by a North Carolina
certified laboratory. (See paragraph 6, "Additional Monitoring by Permittee," below.) Monitoring results obtained from a laboratory
not certified by the state of North Carolina must also be reported, but the wording "Non -certified results" must be clearly indicated on
each page of data submitted.
(3) A written description of any change or modification to the permittee`s pretreatment process equipment that has not previously
been submitted in writing.
(4) A report of any increase or decrease in average water consurnption of more than ten percent of the amount consumed during the
previous semi-annual report period.
(5) A report of any change in production rate that amounted to more than ten percent of the rate during the previous semi-annual
report period.
(6) A report containing a description of any unreported modification of manufacturing facilities that has occurred since the last serni-
annual report, if that modification had the potential of affecting any wastewater discharged by the permittee. (See also the
requirements of Part JI., General Conditions, Paragraph #25, "Reports of Changed Conditions.")
(7) Copies of Material Safety Data Sheets not previously submitted for any substance present on the permittee's prenuses during the
period covered by the report, if that substance contains pollutants limited by this permit or prohibited by the Salisbury Utilities
Ordinance.
(8) At least once during the six-month period covered by each semi-annual report, a letter, calibration certificate, or similar
documentation signed by a qualified professional who has the ability to calibrate the perinittee's discharge flow monitoring
equipment to design accuracy specifications. The documentation submitted shall also indicate whether any adjustment was required
to bring the flow measurement system within specifications,
B. Categorical Dischargers: In addition to the above reporting requirements for non -categorical dischargers, the permittee whose
process is subject to Federal categorical production -based limits shall keep records of average daily production rates for that
categorical process. The pernrittee shall include a summary of average production rates in each semi-annual report. The average
production rate that is reported shall be based on the past two six-month compliance periods. The months on which the permittee
bases the average production rates must be clearly noted on the production report.
Section 8. .Definitions
In accordance with the City of Salisbury Utilities Ordinance and other authority, the following definitions apply:
- General Definitions —
In addition to the definitions in the City of Sallshury Sever Use Ordinance the folio wing definitions and requirements apply.
a. The "Ci" when referred to in the text of this permit shall mean the Environmental Services Division of Salisbury -Rowan
Utilities.
b. "Daily" shall mean any day or any part of a day during which the permittee's process operates or on which a wastewater discharge
occurs.
S1U CODE: IPC Permit #0038
Page 7 of 17

c. A " grrab sample," for monitoring requirements, shall mean a single "dip and take" sample, not exceeding fifteen minutes total
collection time, taken at a representative point in the discharge stream.
d. A "commsite sample," for monitoring requirements, shall mean the daily collection of a minimum of one grab sample per hour for
each hour of discharge during the entire discharge period of 24 hours.
e. A "daily average" shall mean the sum of all values obtained for a parameter in any twenty-four hour period divided by the number
of results for that parameter from analysis of samples collected during that twenty-four hour period.
f. A "daily maximum" shall mean the largest numerical result obtained for a parameter in any twenty-four hour period from analysis .
of samples collected during that twenty-four hour period.
g. A "four -clay average" for a parameter shall mean the average value obtained for a parameter from a nvnffiwm of four individual
composite samples collected within the same calendar month.
h. A "monthly averatle" shall mean the sum of all values obtained for a parameter in a calendar month, divided by the number of
results for that parameter in that calendar month.
i. A "sampling event" shall mean the collection of a grab or composite sample at the discharge point(s) described in Part I. A. of this
permit and the proper preservation of those samples during and after collection.
j. A "monitoringevent" vent" shall mean a sampling event, followed by proper analysis of the samples collected within the regulated
holding time, completion of required chain -of -custody, IDMR forms, and other documentation, and filing with the Environmental
Services Division the required analytical reports by the applicable deadline Reference General Conditions Part 2b.
k. "TTO" or "Total Toxic Organics" shall mean the sum of the concentrations of the toxic organic compounds listed in 40 CFR
43TI I (e) that apply to the permitteds process discharge.
1. "Toxicity" shall mean the qualitative characteristic of a discharge which is measured by the bioassay procedure currently approved
by the State of North Carolina which uses live Ceriodaphnia to indicate the presence or absence of toxic substances in wastewater
discharges.
in. "Priority Pollutants" shall mean those organic chemicals, metals, and other substances defined in the Federal Register 40 CFR Part
122, Appendix D.
n. The "Semi -Annual Report Periods" shall mean the intervals of January through June, and July through December of each year.
o, The terms "Sewer Use Ordinance" or "Utilities Ordinance" shall mean the most recent revision of those parts of the City of
Salisbury's Utilities Ordinance which regulate discharges to the City of Salisbury collection system, particularly Chapter 25, Article
YII, Sewer Use Regulations.
p. A "slue,, or "slug discharge" is any discharge of a non -routine, episodic nature, including but not limited to an accidental spill or a
non -customary batch discharge.
q. A "three-day average" for a parameter shall mean the average value obtained for a'parameter from a minimum of three individual
composite samples collected within the same calendar month.
- Definitions of Monitoring Frequency -
A monitoring frequency of 1/12 when applied to monitoring of SIU's by the Environmental Services Division shall mean a minimum
of one monitoring event during a calendar year.
Monitoring frequency for industrial dischargers is designated as a fraction of each semi-annual report period. The fractional
designations used in this permit shall have the following meanings when applied to self -monitoring by SIU's.
1. 1/6 Shall mean one monitoring event during January or February and one monitoring event during July or August.
2. 2/6 Shall mean one monitoring event during each calendar month of January, February, July, and August.
3. 3/6 Shall mean one monitoring event during each calendar month of January, February, March, July, August,
SIU CODE: 1PC Permit #0038
Page 8of17

and September.
4.4/6 Shall mean one monitoring event during each calendar month of January, February, March, April, July,
August, September, and October.
5.5/6 Shall mean one monitoring event during every calendar month except the months of June and December.
6.6/6 Shall mean one monitoring event during every calendar month.
7. 1112 Shall mean one monitoring event during each calendar year, with that monitoring event being completed
during one of the following months: January, February, March, July, August, or September.
Section 9. Monitoring by the Permittee (Self -Monitoring)
Each permittee shall monitor its discharge(s) at the frequency stated earlier in this pennies "TABLE OF DISCHARGE LIMITS,"
except that the permittee may elect to monitor more often than required herein,
(a) To determine compliance with the Daily Maximum limits and/or the Monthly Average Limits of this permit, the permittee shall
conduct at least one monitoring event for each limited parameter during each calendar month as indicated by the required monitoring
frequency.
(b) The permittee, if so required by 40 CFR 433.10 et. seq., or if required by any other Federal, State, or City regulation or
requirement; shall monitor for Total Toxic Organics. If required to monitor, the permittee shall monitor or shall submit certification
for TTO as required in the applicable Federal regulation.
Section 1 Q. Flow Measurement and Reporting Requirements:
Dischargers subject to Federal categorical mass -based effluent limits, production -based effluent limits, or Combined Wastestream
Formula effluent limits must install and maintain appropriate discharge flow measurement devices utilizing methods consistent with
approved scientific practices to insure the accuracy and reliability of measurements of the volume of all discharges which are
required to be monitored by this permit. Dischargers not otherwise required to install such discharge flow measurement devices, may
be required by the Environmental Services Division to install the devices if, in their judgment, such devices are necessary.
A. Measurement Frequency and Reyortine
1. The flow measurement frequency for each discharge point. regulated by this permit is continuous.
2. The total discharge volume from the beginning to the end of each composite sampling event shall be recorded in
gallons per day or million gallons per day and shall be reported to Environmental Services in those units along with
the analytical data from the sampling event. A State -approved Indirect Discharge Monitoring Report (IDMR) form
shall also be submitted for each sampling event. The flow recorded during the sampling event shall be converted to
thousands of gallons.per day, and shell be indicated in those units on the IDMR form.
3. During every calendar month, the permittee shall maintain a log of readings from the totalizer of each discharge
flowmeter. The permittee shall record a totalizer entry for each day of the month that a discharge occurred. For any
day during which a totalizer reading did not increase, a notation shall be made on the log indicating the reason there
was no change. Daily totalizer readings shall be recorded at 24 hour intervals, within +/- 1.0 hours of a regular time
established by the permitee.
4. The permittee shall submit to Environmental Services no later than the 5th of each month, copies of all totalizer logs
compiled during the previous month. Each monthly log submitted must clearly show the meter manufacturer's name,
the serial number of the device, the original date of installation, the units of flow (gallons, cubic feet, etc.), and the
factor by which the difference in consecutive totalizer readings must be multiplied to obtain the actual volume
discharged. Logs may be faxed or emailed to the Pretreatment Program Coordinator
5, Permittee shall also show on each monthly log, a calculation of (a) The total flow from the first day of each month
through the first day of the following month, and (b) The total flow for each 24 hour period. The calculated flow
must be converted by the permittee to units of *alt loos or million alg lons as appropriate.
SIU CODE: IPC Permit #0038
Page 9 of 17

* - In the event that the monitoring cannot be completed in the stated months because of circumstances such as no discharge
during the particular month, an II?MR should be submitted with "NO (DISCHARGE". If possible, monitoring should be
completed in one of the remaining months.
B. Alternate Flow Measurement Method
The flow discharged by any permittee not required to maintain a discharge flow metering system shall be considered equal to 100%
of the pernnittee's total water consumption if measured by devices maintained by the Salisbury -Rowan Utilities, except that:
If permittee demonstrates that a constant ratio exists between total wastewater volume discharged and total water
consumed, the Environmental Services Division of Salisbury -Rowan Utilities may, at its discretion, allow the
permittee to calculate total discharge flow from total consumption based on the that ratio, which must be periodically
re-established to the satisfaction of Environmental Services.
2. If the permittee demonstrates to the satisfaction of the Environmental Services that a significant fraction ofwater
consumption is routinely retained in a product and is not discharged to the sewer system, then the Environmental
Services Division of Salisbury -Rowan Utilities may, at its discretion, allow for the fraction of water consumption,
which is retained in the product.
3. If an allowance is made for discharge flow as described in paragraph 1 or 2, above, the resulting adjusted discharge
flow shall be used only for compliance with mass limits of this permit, if present herein.
C. Calibration of Flow Measurement Devices
Each permittee required to measure discharge flow must consistently maintain such equipment in operating condition and within
design accuracy specifications. Calibration shall be performed at least once during each semi-annual report period as stated in section
7.A.(8), preceding.
SIU CODE: IPC Pem-dt #0038
Page 10 of 17

Section 1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge. All
samples shall be taken at the monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is
diluted by any other wastestream, body of water, or substance. Monitoring points shall not be changed without notification to, and
approval by, the permit issuing authority.
Section 2. Reporting
a) Monitoring results obtained by the permittee shall be summarized and reported on Indirect Discharge Monitoring Report Forms
(IDMR), postmarked no later than the last calendar day following the month in which the samples were taken. If no discharge
occurs during a calendar month in which a sampling event was to have occurred, an IDMR form with the phrase "no discharge"
shall be submitted for that month. Copies of these and all other reports required herein shall be submitted to the following
address:
Salisbury -Rowan Utilities
Environmental Services Division
Pretreatment Program Coordinator
1915 Grubb Ferry Road
Salisbury, N.C. 29144-1248
b) If the sampling performed by the permittee indicates a violation, the permittee shall notify Environmental Services within 24
hours of becoming aware of the violation. The permittee shall also repeat the sampling and analysis and submit the results of the
repeat analysis to Environmental Services within 30 days after becoming aware of the violation.
Section 3. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with the techniques prescribed in 40 CFR Part 136
and amendments thereto unless specified otherwise in the monitoring conditions of this permit. In addition, the test procedure
shall be conducted utilizing recognized techniques that will produce the lowest practical detection limit for each analyte and
sample matrix:
Section 4. Additional TN1onitor n1 by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more frequently than required by this permit, using
approved analytical methods as specified above, the results of such monitoring shall be submitted to the Environmental Services
Division. The Environmental Services Division may require more frequent monitoring, or the monitoring of other pollutants not
required in this permit by written notification.
Section 5. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the City of
Salisbury Utilities Urdivance and is grounds for possible enforcement action.
Section 6. Duty to Mitjgate - Prevention of Adverse Impact
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit, which has a
reasonable likelihood of adversely affecting human health, the POTW, the waters receiving the POW's discharge, or the
environment.
Section 7. facilities Operation, Bypass
The pennittee shall at all times maintain in good working order and operate as efficiently as possible, all control facilities or
systems installed or used by the permittee to achieve compliance with the terms and conditions of this permit. Bypass of treatment
SIU CODE: 2,C Permit #0038
Page l 1 of 17

facilities is prohibited except when approved in advance by the Environmental Services Division of Salisbury -Rowan Utilities.
Bypass approval shall be given only when such bypass is in compliance with 40 CFR 403.17.
Section S. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters shall be disposed
of in a manner such as to prevent any pollutants from such materials from entering the sewer system. The permittee is responsible
for assuring its compliance with any requirements regarding the generation, treatment, storage, and/or disposal of "Hazardous
waste" as defined under the Federal Resource Conservation and Recovery Act.
Section 4. UnEet Conditions
An "upset" means an exceptional incident in which there is an unintentional and temporary noncompliance with the effluent
limitations of this permit because of factors beyond the reasonable control of the permittee. An upset does not include
noncompliance to the extent caused by operational error, improperly designed or inadequate treatment facilities, tack of
preventative maintenance, or careless or improper operations.
An upset may constitute an affirmative defense for action brought for the noncompliance. The perniittee has, the burden of proof
to provide evidence and demonstrate that none of the factors specifically listed above were responsible for the noncompliance.
Section 10. Right of Entry
The permittee shall allow the staff of the State of North Carolina Department of Environment, Health, and Natural Resources,
Division of Water Quality, the Regional Administrator of the Environmental Protection Agency, the Environmental Services
Division of Salisbury -Rowan Utilities and/or their authorized representatives, upon the presentation of credentials:
a) To enter upon the permittee's premises where a real or potential discharge is located or in which records are required to be kept
under the terms and conditions of this permit; and
b) At reasonable times to have access to and copy records required to be kept under the terms and conditions of this permit; to
inspect any monitoring equipment or monitoring method required in this permit; and to sample any discharge of pollutants.
Section 11. Availability of Records and iRetrorts
The permittee shall retain records of all monitoring information, including all calibration and maintenance records as well as
copies of reports and information used to complete the application for this permit for at least three years. All records that pertain
to matters that are subject to any type of enforcement action shall be retained and preserved by the permittee until all enforcement
activities have concluded and all periods of limitation with respect to any and all appeals have expired. ,
These, and any other records and data maintained by the permittee which provide information related to the operation of the
permittee's pretreatment system or which may influence the quality of the permittee's discharge, shall be made available by the
permittee during inspections by the Environmental Services Division; the Department of Environment, Health, and Natural
Resources; and by the Environmental Protection Agency.
Except for data determined to be confidential under the Utilities Ordinance, all reports prepared in accordance with the temns of
this permit shall be available for public inspection at the Environmental Services Division Office. As required by the Utilities
Ordinance, effluent data shall not be considered confidential.
Section 12. Duty to Provide Information
The permittee shall furnish to the Environmental Services Manager or his or her designees, within a reasonable time, any
information which the Environmental Services Manager, his or her designee, or the Division of Water Quality may request to
determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with
this permit. The permittee shall also furnish, upon request, copies of records that are required to be kept by this permit.
Section 13. Signatory Requirements
All reports or information submitted pursuant to the requirements of this permit must be signed and certified by the Authorized
Representative as defined under the Sewer Use Ordinance. If the designation of an Authorized Representative is no longer
accurate because a different individual or position has responsibility for the overall operation of the facility, or overall
responsibility for environmental matters for the company, a new authorization satisfying the requirements of this section must be
SIU CODE: IPC Permit -40038
Page 12 of 17

submitted to Environmental Services Division Manager prior to or together with any reports to be signed by an authorized
representative'.
Section 14. Toxic Pollutants
If a toxic effluent standard or prohibition (including any schedule of compliance specified in such effluent standard or
prohibition) is established under Section 307(a) of the Federal Clean Water Act for a toxic pollutant which is present in the
discharge and such standard or prohibition is more stringent than any limitation for such pollutant in this permit, this permit may
be revised or modified in accordance with the toxic effluent standard or prohibition and the permittee so notified.
Section 15. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil or -criminal penalties for noncompliance.
Section 16 Federal and/or State Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any
responsibilities, liabilities, or penalties established pursuant to any applicable Federal and/or State law or regulation.
Section 17. Penalties
The City of Salisbury Utilities Ordinance provides that any person who violates a permit condition is subject to a civil penalty,
The maximum amount of each civil penalty is specified in the most recent revision of the Utilities Ordinance, and may range up
to $25,000.00 for each day that a violation exists.
Under state law, (NCGS 143-215.613), under certain circumstances it is a crime to•violate terms, conditions, or requirements of
pretreatment permits. It is a crime to knowingly matte any false statement, representation, or certification in any record or other
document submitted or required to be maintained under this permit, including monitoring reports or reports of compliance or
noncompliance. These crimes are enforced at the prosecutorial discretion of the local District Attorney.
Section 18. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted
activity to maintain compliance with the conditions of the permit.
Section 19. Transferability
This permit shall not be reassigned or transferred or sold to a new owner, new user, different premises, or a new or changed
operation without approval of the Environmental Services Division of Salisbury -Rowan Utilities.
Section 20. Property Rights
This permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it
authorize any injury to private property or any invasion of personal rights, nor any infringement of Federal, State or local laws or
regulations,
Section 21. Severability
The provisions of this permit are severable and, if any provision of this permit or the application of any provision of this permit to
any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this permit shall
not be affected thereby.
Section 22. Permit Modification, Revocation, Termination
This permit may be modified, revoked and reissued or terminated with cause in accordance to the requirements of the City of
Salisbury Utilities Ordinance and North Carolina General Statute or implementing regulations.
Section 23. Re -Application for Permit Renewal
The perrnittee is responsible for filing an application for re -issuance of this permit at least 90 days prior to its expiration date.
SIU CODE; 1PG Permit #0038
Page 13of17

Section 24. Dilution Prohibition
The permittee shall not increase the use of potable or process water or in any other way attempt to dilute the discharge as a partial
or complete substitute for adequate treatment to achieve compliance with the limitations contained in this. permit.
Section 25. Reports of Chanced Conditions
The permittee shall give notice to the Environmental Services Division of any planned significant changes to the permittee's
operations or system., which might alter the nature, quality, or volume of its wastewater at Ieast 90 days before the change. The
permittee shall not begin the changes until receiving written approval from Environmental Services Division. Also see Part III,
Special Conditions below for additional reporting requirements for spill/slug issues.
Significant changes my include but are not limited to
(a) Increases or decrease to production
(b) Increases in discharge of previously reported pollutants;
(c) Discharge of pollutants not previously reported to the Environmental Services Division;
(d) New or changed product lines
(e) New or changed manufacturing processes andlor chemicals; or
(f) New changed customers.
Section 26, Construction
No construction of pretreatment facilities or additions thereto shall be begun until Final Plans and Specifications have been
submitted to the Environmental Services Division, and written approval and an Authorization to Construct (A to C) have been
issued.
Section 27. Reopgner
This permit shall be modified or, alternatively, revoked and reissued to comply with any applicable effluent standard or limitation
for the control of any pollutant shown to contribute to toxicity of the W WTP effluent or any pollutant that is otherwise limited by
the POTW discharge permit. The permit as modified or reissued under this paragraph may also contain any other requirements of
State or Federal pretreatment regulations then applicable.
Section 28. Categorical Reonener
This permit shall be modified, or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitation
issued or approved under Sections 302(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) of the Clean Water Act, if the effluent standard
or limitation so issued or approved;
a) Contains different conditions or is otherwise more stringent than any effluent limitation in this permit; or
b) Controls any pollutant not limited in this permit.
The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable.
Section 29. General Prohibitive :Standards
The permittee shall comply with the general prohibitive discharge standards in 40 CFR 403.5 (a) and (b) of the Federal
pretreatment regulations.
Section 30. Rerrorts of Potential Problems
The permittee shall notify the Environmental Services Division immediately by telephone of all discharges that could cause
problems to the POTW, including any slug loadings as defined by 40 CFR 403.5 (b). The permittee shall provide protection from
accidental and slug discharges of prohibited materials and other substances regulated by this permit. The permittee shall also
notify the POTW which it's facility discharges to and Environmental Services Division immediately of any changes at its facility
affecting the potential for spills and other accidental discharge, discharge of a non -routine, episodic nature, a non -customary batch
discharge, or a slug load as defined in the Sewer Use Ordinance. If the permittee experiences such a discharge, the permittee shall
inform the Environmental Services Division immediately upon the first awareness of the commencement of the discharge.
Notification shall include location of the discharge, type of waste, concentration, and volume - if known - and corrective actions
SIU CODE: IPC Permit #0038
Page 14 of 17

taken by the permittee. A written follow-up report thereof shall be filed by the permittee within five (5) days, unless waived by
the Environmental Services Division.
Additionally, the permittee in the event of the release of a slug discharge which may present a hazard to the public, to municipal
employees, or which may do harm to the collection system, treatment facilities or the treatment process, the discharger must
notify by telephone immediately the following persons or agencies until the accidental spill has been reported:
o City of Salisbury Fire Department 704-638-5351
o Environmental Services Division, Pretreatment }[Department, 704-638-5375, (8:00am4:30pm)
o Water / Sewer Maintenance & Construction Division
(Emergencies affecting water or sewer service.) 704-638-5339
o Grant Creek Treatment Train* (24 hr.- 7 days/wk) 704-638-5374
o Town Creek Treatment Train * (24 hr.- 7 days/wk) 704-638-5377
*[Notify the municipal treatment train plant Operator in Charge at the facility into which you are permitted
to discharge. That information is available on the cover page of this permit.)
Such notification will not relieve the permittee from any liability, which may be incurred as a result of the discharge, but failure to
notify shall be a violation of this permit and subject to enforcement action, including revocation or termination of this permit.
Section 3l. Siggatory Requirements
All reports or information submitted to fulfill the requirements of this permit must be signed and certified by a ranking and duly -
authorized agent of the permittee.
The following certification statement must be included as an integral part of each report listed above under "Signatory
Requirements" and must be signed by the perrnittee's authorized agent:
" T certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance,with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.
Based on my inquiry of the person or persons directly responsible for gathering the information, the information submitted is, to
the best of my.knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting
false information, including the possibility of fine and imprisonment for snowing violations.
(Signature)
SlU CODE: 1PC
(Title)
(Date)
Permit 40038
Page 15 of 17

P i} li I t a
Section 1. Required Slug Control Plan:
The permittee shall provide protection from accidental discharges of prohibited materials or other substances regulated by this
permit. The pernvttee is hereby notified that he shall develop, submit, obtain Environmental Services Division approval
of, and implement a written Slug Control Plan within 90 days of the effective date of this permit.
Descri Lion of Measure, Activity, Plan, etc.
Required Completion/ Implementation Date
1, Implementation of current and updated Slug/Spill
Continuous
Control Plan upon POTW approval
2. Review and update Slug/Spill Control Plan to assure
Annual update (based on calendar year)
continuous effectiveness
To be submitted to POTW for approval within 30 days
of revision date.
The plan submitted shall include the following measures as necessary to assure protection of the POTW from slug loads: the
construction of containment dikes around pretreatment units, around process units containing liquids, and chemical storage areas;
the rerouting of floor drains in manufacturing areas to a holding area located upstream of the discharge to the pretreatment unit;
and the plugging of floor drains in chemical storage areas, and in other areas as needed to protect the PO"111V.
The permittee shall provide updates to the Environmental Services Division as required by Part II Section 30 of this permit.
Modifications to the measures shall be approved by Environmental Services prior to installation/ implementation, If a measure
fails, Environmental Services shall be notified within 24 hours.
Section 2. Total Mercurv:
Beginning October 1, 2006, test method Std. Method 3112B or EPA 245.1 may be used for mercury monitoring, Laboratories
must be North Carolina certified and able to reach a minimum quantitation level of 0.2 pg/l.
If any monitoring indicates total mercury present in the permittee's discharge at a concentration exceeding 0.2 pg/l, the permittee
shall, within ten calendar days of becoming aware of that exceedance, collect and analyze an additional total mercury sample
from the same discharge point where the exceedance occurred.
For reporting purposes, the permittee shall treat each exceedance as though it were a violation of a discharge limit, and shall
report each exceedance as stated elsewhere in this permit.
Every effort should be made by the permittee to find the source of mercury in their effluent by looking at raw materials, waste
practices, etc. This pernut may be re -opened by the Environmental Services Division to impose a numerical limit for total
mercury.
Section 3. Conditions Affecting WWTP Performance:
Should pollutants discharged by the perrrdttee contribute to a degradation of the performance of the Salisbury -Rowan Utilities'
treatment facilities, the Environmental Services may require the permittee to conduct a treatability study for the suspect
pollutant(s). In addition, the Environmental Services may reopen and modify this permit as necessary to further regulate any
pollutants causing such degradation of performance.
Section 4. ]Flow Measurement Requirements
The perrnittee shall maintain appropriate discharge flow measurement devices and methods consistent with approved scientific
practices to ensure the accuracy and reliability of measurements of the volume of monitored discharges. Devices installed shall be
continuous recording flow meter capable of measuring flows with a maximum deviation of less than 10% from true discharge
rates throughout the range of expected discharge volumes. The devices shall be installed, calibrated, and maintained to ensure
accuracy. The meter shall be calibrated every six months. Modifications to the flow metering equipment shall be approved by the
SIU CODE: IPC Permit #4038
Page 16 of 17

Control Authority prior to installation_ If a required flow measurement device fails, the Control Authority shall be notified within
24 hours. The permittee has 72 hours to return to compliance (and report total water consumption in the interim).
Section 5. Certified Laboratory Analysis
Pollutant analysis shall be performed by a North Carolina Division of Water Quality Certified Laboratory that is certified in the
analysis of the pollutant in wastewater.
SIU CODE: IPC Permit #0038
Page 17 of 17

;RF,
October 22, 2010
Mr. Allen Robey
lnnospec Active Chemicals
P.O. BOX 164
Spencer, N.C. 28159-0164
Subject: New SIU Pretreatment Permit #0038
Dear Mr. Robey,
You will find enclosed pretreatment discharge permit #0038 for the Innospec Active Chemical, on 775 Hackett
Street, Rowan County. Please read the enclosed permit in its entirety and note the effective date of November 01,
2010,
If any requirements contained in this permit are unacceptable, you have the right to an adjudicatory hearing upon
written request within thirty (30) days following receipt of this letter. Unless such demand is made, the provisions
of the enclosed permit shall be final and binding.
If you have questions regarding conditions of this permit or related matters, please do not hesitate to contact me or
Sonja Basinger at [phone].
SincereI
e
Cheryl D. Douglas
Pretreatment Program Coordinator
Enclosure
cc:1PC file
DWQ - Pretreatment
1915 Grubb Ferry Road
Salisbury. NC 28144
Salisbury -Rowan Utilities Telephone [phone]
Environmental Services Division Fax [phone]

y
PERMIT
INDUSTRIAL USER PRETREATMENT PERMIT TO DISCHARGE WASTEWATER
UNDER THE CITY OF SALISBURY INDUSTRIAL PRETREATMENT PROGRAM
In compfiance with the provisions of North Carolina General Statute 143-215.1, any applicable Federal categorical
pretreatment regulations, all other lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the City of Salisbury Utilities Ordinance, the following industry, hereafter
referred to by name or as the permittee:
Pe ; 1=ospec Active Chemicals
SIC Code: 2843
40 CFR Category: NIA
Facilt Location: 775 Hackett Street
Mailing Address: P.O. BOX 164
Salisbury, North Carolina 28159-0164
Contact & Phone: Mr. Allen Robey, SHE Manager — 704-633-8028
Alternate Contact & Phone: Mr. Jerry Putman, Operations Manager — 704-639-7904
is hereby authorized to discharge wastewater from the facility located at the above listed address into the sanitary sewer
collection system and the Grant Creek and Town Creek Wastewater Treatment Trains of the Salisbury -Rowan Utilities
listed below:
Name of City Facility:
SALISBURY-ROWAN
Marne of Treatment Train
Grant Creels Treatment Train WWI?
NPDES Number:
NCO023894
Treatment Facility Location
1915 Grubby Ferry Rd.
Salisb (Spencer), N.C. 28144-1248
This permit and the authorization to discharge shall become effective at midnight on:
November 01, 2a10
This penrut and the authorisation to discharge shall eM a at midnight on:
November 01, 2011
Date: I d / 2- .2010
riy+•
So " Basinger
Manager, Environmental Services
SILT CODE: IPC Permit 90038
Page 1 of 15

Specific Conditions
1. IUP Basic Information:
General information on the discharger, the receiving POTW, the POTW s NPDES permit number, the effective date
and expiration date of this permit,and the SIU's SIC code and Federal category, if applicable, can be found on the cover
page of this document
2. IUP Modification History:
Effective (Date Renewal or Modification (Description of changes over previous IUP
11/01/10 New Changed from a local SIU to SIU
3. Authorization to Discharge;
a) The permittee is hereby authorized to discharge wastewater in accordance with the effluent limitations, monitoring
requirements, and all other conditions set forth in this Industrial User Pretreatment Permit QUP) into the sewer
collection system and Grant Creek or Town Creek Wastewater Treatment Train Facility identified on the cover page of
this permit.
b) The permittee is hereby authorized to continue operation of and discharge wastewater from the following treatment
or pretreatment facilities. These facilities must correspond to the units listed on both the application and inspection
forms. The following treatment or pretreatment facilities as described in the permittee's application for this discharge
permit:
DESCRIPTION OF SI U° s PRETREATMENT SYSTEM UNITS
1. Influent flow measurerment 17. Secondary Clarification with Chemical
2. Biological treatment activated sludge pe4itation
3. Flow Equalization j S. Effluent lift station
4. Screens 9. Effluent flow measurement at Sewer
5. Neutralization discharge
6. Spill Protection
c) The permittee is hereby authorized to. if required by the Environmental Services Division of Salisbury -Rowan
Utilities, and after receiving Authorization to Construct (A to C), construct and operate additional pretreatment units as
needed to meet the effluent limitations described in this permit.
SIU CODE: ]PC Pennit #0033
Page 2 of 15

4. Description of IUP Discharges:
11 Pipe 01 Discharge Point 11
Pipe 01 is located in the sump directly between the effluent side, of the biological lagoons. The
sump is encased in a vault and has a metal lid. Treated effluent from clarifier is piped into sump
then pumped to main sewer line. Effluent is an intermittent process discharge from the manufacture
of surfactants and emollients for personal care industry and surfactants for emulsion
polymerisation. IU has capability of discharging treated unclarified wastewater to spray irrigation
fields as an alternative to sewer discharge.
5. Schematic of Monitoring Locations:
The facility schematic and description of monitoring location(s) given below must show enough detail such that
someone unfamiliar with the facility could readily find and identify the monitoring location(s) and connection to the
sewer. Include and identify all regulated pipes. The location)of the above discharge point(s) is shown in the diagram
below:
Aeration Lagoon Capacity
250.QW/g2r
100 gnuon manhole J
Ferric chloride feed f
I Flow Diverter I
14
Aerators
I SamDlc Point I
To POTW �®
I Lift Station I
STU CODF: IPC
Flow from Plant
Influent Weir with bar Screen
Aeration Lagoon capacity
250,000/g2l
250 gallon Me tank
l polymer/caustic feed
10,000 gallon clarifier
Permit #0038
Page 3 of 15

Section 6: Effluent Limits and Monitoring Requirements:
EFFLUENT LIMITS TABLE I - Pipe #01
WWTP Treatment Train:
POTW:
Grant Creek Treatment Train
Salisbury -Rowan
SIU Name:
Innospec Active Chemicals
POTW NPDES #:
NCO023884
Permit #:
0038
Effective Date:
November 01, 2010
Pipe #:
#01
Expiration Date:
November 01, 2011
40 CFR #
THE LIMITS IN THIS TABLE ARE: N/A
])Limits for the Entire Permit Period. X
2)lnterim Limits for Period #1:
3)1mcrim Limits for Period #2:
4)Final Limits
DISCHARGE FLOW
LIMITS
daily Maximum
Maximum Monthly Avg.
0.060 MGD
0.050 MGD
1. pH Limit - The pH of this discharge, identified by the pipe number indicated above, shall be within the range of 6.00 to
9.00 standard units at all times.
2. Temperature Limit - The temperature of the discharge, idenfrfied by the pipe number stated above, shall be less than
65.5 degrees C. at all times.
3. pH and Temperature shall be measured at the discharge site on a grab sample, and each shall be measured
immediately upon collection of the grab sample. s ! L( C1c
Limited Parameter
and
Units
Daily
Maximum
Limit
Maximum
Monthly
Average
Limit
- --Indust
Monitoring
Frequency
POTW
Monitoring
Frequency
Sample
Collection
Method
Flow, MGD
0,060
0.050
*Daily
1/6
POTW each sampling event
BOD, lb/day
275
--
2/6
1/6
Composite
COD, lb/day
600
--
216
1/6
Composite
TSS, lb/day
75
- -
2/6
1/6
Composite
TKN, lb/day
I5
--
216
1/6
Composite
Ammonia, mg/l
Monitor
--
1/6
1/6
Composite
Chloride, mg/l
Monitor
—
1/6
1/6
Composite
Cyanide, mgll
0,010
—
2/6
1/6
Grab
Total NiUrite+Nitrate, mg/1
Monitor
—
216
1/6
Composite
Total Phosphorus, mg/l
Monitor
—
l/6
1/6
Composite
Mereury, mg/l 46
Monitor
—
1/6
1/6
Composite
Total Cadmium, lb/day
0.005
—
2/6
I/6
Composite
Total Chromium, lb/day
0.005
—
2/6
1/6
Composite
Total Copper, lb/day
0.025
--
2/6
1/6
Composite
Total Lead, lb/day
0.005
--
2/6
1/6
Composite
Total Nickel, lb/day
0.015
--
2/6
1/6
Composite
Total Silver, lb/day
Monitor
--
1/6
1/6
Composite
Total Zinc, lb/day
0.210
--
2/6
1/6
Composite
**There shall be no discharge of floating solids or visible foam in other than trace amounts.
4 Monitor per Special Conditions in Part III of this permit.
SIU CODE: IPC Permit #0038
Page 4 of 15

Section 7_ Semi -Annual Reports - Requirements for Industrial Dischargers:
The permittee, whether subject to Federal categorical standards or not (40 CFR 403.12 (e) & 40 CFR 403.12 (h)1, shall
submit Semi -Annual Reports covering the monQls of January through June, and the months of July through December.
The report for the period of January through June shall be postmarked no later than July 10th The report for July
through December shall be postmarked no later than January 10th, and must contain the following information listed
below.
A. Non -Categorical Dischargers shall submit:
(1) A description of the nature, concentration, and flow rate for any new or previously unreported discharge containing
any substance limited by this permit or prohibited by the Salisbury Utilities Ordinance.
(2) The results of any monitoring in excess of that required by this permit, if the results were determined by a North
Carolina certified laboratory. (See paragraph 6, "Additional Monitoring by Permittee," below.) Monitoring results
obtained from a laboratory not certified by the state of North Carolina must also be reported, but the wording "Non -
certified results" must be clearly indicated on each page of data submitted.
(3) A written description of any change or modification to the permittee's pretreatment process.equipment that has not
previously been submitted in writing.
(4) A report of any increase or decrease in average water consumption of more than ten percent of the amount
consumed during the previous semi-annual report period
(5) A report of any change in production rate that amounted to more than ten percent of the rate during the previous
semi=annual report period.
(6) A report containing a description of any unreported modification of manufacturing facilities that has occurred since
the last semi-annual report, if that modification had the potential of affecting any wastewater discharged by the
permittee. (See also the requirements of Part II., General Conditions, Paragraph 425, "Reports of Changed
Conditions.")
() Copies of Material Safety Data Sheets not previously submitted for any substance present on the permittee's
premises during the period covered by the report, if that substance contains pollutants limited by this permit or
prohibited by the Salisbury Utilities Ordinance.
(8) At least once during the six-month period covered by each semi-annual report, a letter, calibration certificate. or
similar documentation signed by a qualified professional who has the ability to calibrate the permitteds discharge flow
monitoring equipment to design accuracy specifications. The documentation submitted shall also indicate whether any
adjustment was required to bring the flow measurement system within specifications.
13. Categorical Dischargers: In addition to the above reporting requirements for non -categorical dischargers, the pern-duee
whose process is subject to Federal categorical production -based limits shall keep records of average daily production
rates for that categorical process. The permittee shall include a summary of average production rates in each semi-
annual report The average production rate that is reported shall be based on the past two six-month compliance
periods. The months on which the permittee bases the average production rates must be clearly noted on the production
report
A. Definitions
In accordance with the City of Salisbury Utilities Ordinance and other authority, the following definitions apply:
SI1J CODE: 11?C Permit 90038
Page 5 of 15

- general Definitions —
In adMon to the definitions in the Qy of Salisbury Sewer Use Ordinance the follarssing defanitions and
requirements apply:
a. The "Q11" when referred to in the text of this permit sball mean the Environmental Services Division of Salisbury.
Rowan Utilities.
b. "Daily" shall mean any day or any part of a day during which the permittee's process operates or on which a
wastewater discharge occurs.
c. A "Upb samRle." for monitoring requirements, shall mean a single "dip and take" sample, not exceeding fifteen
minutes total collection time, taken at a representative point in the discharge stream.
d. A "composite sample." for monitoring requirements, shall mean the daily collection of a minimum of one grab
sample per hour for each hour of discharge during the entire discharge period of 24 hours.
e. A "daily average" shall mean the sum of all values obtained for a parameter in any twenty-four hour period ending at
midnight local time, divided by the number of results for that parameter from analysis of samples collected during that
twenty-four hour period.
f. A "daily rnaxtirntrrrl" shall mean the largest numerical insult obtained for a parameter in any twenty-four hour period
ending at midnight local time, from analysis of samples collected during that twenty-four hour period
g. A "four -day average" for a parameter shall mean the average value obtained for a parameter from a minimum of four
individual composite samples collected within the same calendar month.
h. A "monthly average" shall mead the sum of all values obtained for a parameter in a calendar month, divided by the
number of results for that parameter in that calendar month
i. A "sampling event" shall mean the collection of a grab or composite sample at the discharge point(s) described in
Part I. A of this permit and the proper preservation of those samples during and after collection..
j. A "moni ' event" shall mean a sampling event, followed by proper analysis of the samples collected witldn the
regulated holding time, completion of required chain -of -custody, IDMR forms, and other documentation, and filing
with the Environmental Services Division the required analytical reports by the applicable deadline Reference General
Conditions Part 2b.
k. '"TTO" or "Total Toxic Organics" shall mean the sum of the concentrations of the toxic organic compounds listed in
40 ZFR 433.11 (e) that apply to the permitteds process discharge.
1. "Toxicity" shall mean the qualitative characteristic of a discharge which is measured by the bioassay procedure
currently approved by the State of North Carolina which uses live Ceriodaphnia to indicate the presence or absence of
toxic substances in wastewater discharges.
m. "Priority Pollutants" shall mean those organic chemicals, metals, and other substances defined in the Federal
Register 40 CFR Part 122, Appendix D.
n. The "Semi -Annual Report Periods" shall mean the intervals of January through June, and July through December of
each year.
o. The terms "Sewer Use Ordinance" or "Utilities Ordinance" shall mean the most recent revision of those parts of the
City of Salisbury's Utilities Ordinance which regulate discharges to the City of Salisbury collection system, particularly
Chapter 25, Article VII, Sewer Uve Regulations.
p. A "stu " or "slug discharge" is any discharge of a non -routine, episodic nature, including but not limited to an
accidental spill or a non -customary batch discharge.
q. A "three-day average" for a parameter shall mean the average value obtained for a parameter from a minimum of
three individual composite samples collected within the same calendar month.
SIU CODE: 1PC Permit #0038
Page 6 of 15

- Definitions of Monitoring Frequency -
A monitoring frequency of 1/6 when applied to morrftoring of SW's by the Environmental Service shall mean a
minimum of one monitoring event during the months of January through June and one monitoring event during the
months of July through December.
Monitorinz fratuency for industrial dischargers is designated as a fraction of each semi-annual report period. The
fractional designations used in this permit shall have the following meanings when applied to self -monitoring by Slus.
1. 1/6 Shall mean one monitoring event during January or February and one monitoring event during July or August
2. 2/6 Shall mean one monitoring event during each calendar month of January, February, July, and August_
3. 316 Shall mean one monitoring event during each calendar month of January, February, March, July, August,
and September.
4, 4/6 Shall mean one monitoring event during each calendar month of January, February, March, April, July,
August, September, and October.
5.5/6 Shall mean one monitoring event during every calendar month except the months of June and December.
6, 616 Shall mean one monitoring event during every calendar month.
7. 1/12 Shall mean one monitoring event during each calendar year, with that monitoring event being completed
during one of the following months: January, .February, March, July, August, or Septerber. *
9. Monitoring by the Permittee (Self-Monitoringa)
Each permittee shall monitor its discharge(s) at the frequency stated earlier in this pen-nit's "TABLE OF DISCHARGE
LIMITS," except that the permittee may elect to monitor more often than required herein.
(a) To determine compliance with the Daily Maximum limits of this permit, the permittee shall conduct at least one
monitoring event for each limited parameter during each calendar month as indicated by the required monitoring
frequency. A Perrnittee subject to a Maximum Monthly Average limit of this permit shall conduct at least four
individual monitoring events for those parameters each calendar month at the indicated monthly frequency.
(b) The permittee, if so required by 40 CFR 433.10 et. seq., or if required by any other Federal, State, or City regulation
or requirement, shall monitor for Total Toxic Or¢anics. If required to monitor, the permittee shall monitor or shall
submit certification for TTO as required in the applicable Federal regulation.
10. Flow Measurement and Reporting Requirements:
Dischargers subject to Federal categorical mass -based effluent limits, production -based effluent limii_s, or Combined
Wastestream Formula effluent limits must install and maintain appropriate discharge flow measurement devices
utilizirig methods consistent with approved scientific practices to insure the accuracy and reliability of measurements of
the volume of all discharges which are required to be monitored by this permit. Dischargers not otherwise required to
install such discharge flow measurement devices, may be required by the Environmental Services Division to instatl the
devices if, in their judgment, such devices are necessary.
A. Measuremen_t_Frequency and Re rung
1. The flow measurement frequency for each discharge point regulated by this permit is continuous.
2. The total discharge volume from the beginning to the end of each composite sampling event shall be recorded in
gallons per day or million gallons per day and shall be reported to Environmental Services in those units along with
the analytical data from the sampling event A State -approved Indirect Discharge Monitoring Report (IDMR) form
shall also be submitted for each sampling event. The flow recorded during the sampling event shall be converted to
thousands of gallons per day, and shall be indicated in those units on the IDMR form,
SIU CODI?: PAC Permit #0038
Page 7 of 15

3. During every calendar month, the petmittee shall maintain a Iog of readings from the totalizer of each discharge
flow -meter. The permittce small record a totalizer entry for each day of the month that a discharge occurred. For any
day during which a totalizer reading did not increase, a notation shall be made on the log indicating the reason there
was no change, Daily totalizer readings shall be recorded at 24 hour intervals, within +/- 0.5 !touts of a regular time
established by the permitee.
4. The permittee shall submit to Environmental Services no later than the 5th of each month, copies of all totalizer logs
compiled during the previous month Each monthly log submitted must clearly show the meter manufacturces name
the serial number of the device, the original date of installation, the units of flow (gallons, cubic feet, etc.), and the
factor by which the difference in consecutive totalizer readings must be multiplied to obtain the actual volume
discharged. Logs may be fazed into 704-638-8476 and followed with a bard copy.
5. permittee shall also show on each monthly log, a calculation of. (a) The total flow from the first day of each month
through the first day of the following month, and (b) The total flow for each 24 hour period. The calculated flow
must be converted by the permittee to units of gallons or million gallons as appropriate.
* - In the event that the monitoring cannot be completed in the stated months because of circuinstances such as
no discharge during the particular month, an EDAM should be submitted with "MO DISCHARGE". If possible,
monitoring should be completed in one of the remaining months.
B. Alternate Flow Measurement Method
The flow discharged by any permittee not required to maintain a discharge flow teetering system shall be considered
equal to 1001/6 of the permitteds total water consumption if measured by devices maintained by the Salisbury -Rowan
Utilities, except that:
If permittee demonstrates that a constant ratio exists between total wastewater volume discharged and total water
consumed, the Environmental Services Division of Salisbury -Rowan Utilities may, at its discretion, allow the
permittee to calculate total discharge flow from total consumption based on the that ratio, which must be periodically
re-established to the satisfaction of Environmental Services.
If the permittee demonstrates to the satisfaction of the Environmental Services that a significant fraction of water
consumption is routinely retained in a product and is not discharged to the sewer system, then the Environmental
Services Division of Salisbury -Rowan Utilities may, at its discretion, allow for the fraction of water consumption,
which is retained in the product
If an allowance is made for discharge flow as described in paragraph I or 2, above, the resulting adjusted discharge
flow shall be used only for compliance with mass limits of this permit, ifpresent herein.
C. Calibration of Flow Measurement Devices
Each permitter required to measure discharge flow must consistently maintain such equipment in operating condition
and within design accuracy specifications. Calibration shall be performed at least once during each semi-annual report
period as stated in section TA. (8), preceding.
SIU COD]]: IPC Permit #0038
Page 8 of 15

1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored
discharge. All samples shall be taken at the monitoring points specified in this permit and, unless otherwise specified,
before the effluentjoins or is diluted by any other wastestream, body of water, or substance. Monitoring points shall not
be changed without notification to. and approval by, the permit issuing authority.
2. Reporting
a) Monitoring results obtained by the permittee shall be summarized and reported on Indirect Discharge Monitoring
Report Forms (IDMR.), postmarked no later than forty-five calendar days after the sampling date. If no discharge
occurs during a calendar month in which a sampling event was to have occurred, an IDMR form with the phrase "no
discharge" shall be submitted for that month Copies of these and all other reports required herein shall be submitted
to the following address:
Salisbury -Rowan Utilities
Environmental Services Division
Pretreatment Program Coordinator
1915 Grubb Ferry road
Salisbury, N.C. 28144-1248
b) If any monitoring performed by the permittee indicates a violation of any limit in this permit, the permittee shall
verbally notify the Environmental Services Division within 24 hours after becoming aware of the initial violation,
and shall at that time provide the analytical results from that monitoring event to the division. In addition, the
permittee shall, within five calendar days of becoming aware of the initial violation, conduct a monitoring event for
that parameter(s) within 30 days. If the results from the repeat monitoring event indicate a permit violation, the
permittee shall again verbally notify the Environmental Services Division within 24 hours of becoming aware of the
results. Whether a violation exists or not, the permittec shall report all results of permit -required monitoring to the
Environmental Services Division in writing no later than 45 days after the end of each monitoring event
3. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with the techniques prescribers in 40
CFR Part 136 and amendments thereto unless specified otherwise in the monitoring conditions of this permit_ In
addition, the test procedure shall be conducted utilizing recognized techniques that will produce the lowest practical
detection limit for each analyte and sample matrix.
4. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more frequently than required by this
permit, using approved analytical methods as specified above, the results of such monitoring shall be submitted to
the Environmental Services Division. The Environmental Services Division may require more frequent monitoring,
or the monitoring of other pollutants not required in this permit by written notification.
5. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of
the City of Salisbury Utilities Ordinance and is grounds for possible enforcement action.
6. Duty to Mitigate - Prevention of Adverse Impact
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit, which
has a reasonable likelihood of adversely affecting human health, the POTW, the waters receiving the POTW's
discharge. or the environment.
SIU CODE: 111C Permit 0038
Page 9 of 15

7. Facilities OReration, Bypass
The permittee shall at all times maintain in good working order and operate as efficiently as possible, all control
facilities or systems installed or used by the permittee to achieve compliance with the terms and conditions of this
permit Bypass of treatment facilities is prohibited except when approved in advance by the Environmental Services
Division of Salisbury -Rowan Utilities. Bypass approval shall be given only when such by is in compliance with
40 CFR 403.1:7.
S. Removed Substances
Solids, sludges, Filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be disposed of in a manner such as to prevent any pollutants from such materials from entering the sewer
system. The permittee is responsible for assuring its compliance with any requirements regarding the generation,
treatment, storage, and/or disposal of "Hazardous waste" as defined under the Federal Resource Conservation and
Recovery Act.
9. Upset Conditions
An "upset" means an exceptional incident in which there is an unintentional and temporary noncompliance with the
effluent limitations of this permit because of factors beyond the reasonable control of the permittee. An upset does
not include noncompliance to the extent caused by operational error, improperly designed or inadequate treatment
facilities, lack of preventative maintenance, or careless or improper operations.
An upset may constitute an affirmative defense for action brought for the noncompliance. The permittee has the
burden of proof to provide evidence and demonstrate that none of the factors specifically listed above were
responsible for the noncompliance.
10. Right of Entry
The permittee shall allow the staff' of the State of North Carolina Department of Environment, Health, and Natural
Resources, Division of Water Quality, the Regional Administrator of the Environmental Protection Agency, the
Environmental Services Division of Salisbury -Rowan Utilities and/or their authorized representatives, upon the
presentation of credentials:
a) To enter upon the permittee's premises where a real or potential discharge is located or in which records are
required to be kept under the terms and conditions of this permit; and
b) At reasonable times to have. access to and copy records required to be kept under the terms and conditions of this
permit; to inspect any monitoring equipment or monitoring method required in this permit; and to sample any
discharge of pollutants.
11. Availability of Records and Reports
The permittee shall retain records of all monitoring information, including all calibration and maintenance records as
well as copies of reports and information used to complete the application for this permit for at least three years. All
records that pertain to matters that are subject to any type of enforcement action shall be retained and preserved by
the permittee until all enforcement activities have concluded and all periods of limitation with respect to any and all
appeals have expired.
These, and any other records and data maintained by the permittee which provide information related to the
operation of the permittee's pretreatment system or which may influence the quality of the permittee's discharge,
shall be made available by the permittee during inspections by the Environmental Services Division; the Department
of Environment, Health, and Natural Resources; and by the Environmental Protection Agency.
Except for data determined to be confidential under the Utilities Ordinance, all reports prepared in accordance with
the terms of this permit shall be available for public inspection at the Environmental Services Division Office. As
required by the Utilities Ordinance, effluent data shall not be considered confidential.
SIU CODE: rPC Permit #0038
Page 10 of 15

12. Duty to Provide Information
The perniince shall furnish to the Environmental Services Manager or his or her designees, within a reasonable time,
any information which the Environmental Services Manager, his or her designee, or the Division of Water Quality
may request to determine whether cause exists for modifying revoking and reissuing, or terminating this permit or
to determine compliance with this permit. The permittee shall also furnish, upon request, copies of records that are
required to be kept by this permit.
13, Signatory Requirements
All reports or information submitted pursuant to the requirements of this permit must be signed and certified by the
Authorized Representative as defined under the Sewer Use Ordinance. If the designation of an Authorized
Representative is no longer accurate because a different individual or position has responsibility for the overall
operation of the facility, or overall responsibility for environmental matters for the company, a new authori7.ation
satisfying the requirements of this section must be submitted to Environmental Services Division Manager prior to
or together with any reports to be signed by an authorized representative.
14. Toxic Pollutants
If a toxic effluent standard or prohibition (including any schedule of compliance specified in such effluent standard
or prohibition) is established under Section 307(a) of the Federal Clean Water Act for a toxic pollutant which is
present in the discharge and such standard or prohibition is more stringent than any limitation for such pollutant in
this permit, this permit may be revised or modified in accordance with the toxic effluent standard or prohibition and
the permittee so notified.
I5. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance.
16. Federal and/or State Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permince from
any responsibilities, liabilities, or penalties established pursuant to any applicable Federal and/or State law or
regulation.
17. Penalties
The City of Salisbury Utilities Ordinance provides that any person who violates a permit condition is subject to a
civil penalty. The maximum amount of each civil penally is specified in the most recent revision of the Utilities
Ordinanm and may range up to $25,000.00 for each day that a violation exists.
Under state law. (NCGS 143-215.58), under certain circumstances it is a crime to violate terms, conditions, or
requirements of pretreatment permits. It is a crime to knowingly make any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit. including
monitoring reports or reports of compliance or noncompliance. These crimes are enforced at the prosecutorial
discretion of the local District Attorney.
18. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce
the permitted activity to maintain compliance with the conditions of the permit.
I9, Transferability
This permit shall not be reassigned or transferred or sold to a new owner, new user, different premises, or a new or
changed operation without approval of the Environmental Services Division of Salisbury -Rowan Utilities.
S1U COI)I : 111C Permit #0038
Page I I'of 11

20. Property Rights
This permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor
does it authorize any injury to private property or any invasion of personal rights, nor any infringement of Federal,
Slate or local laws or regulations.
21. Severability
The provisions of this permit are severable and, if any provision of this permit or the application of any provision of
this permit to any circumstance is held invalid, the application of such provision to other circumstances and the
remainder of this permit shall not be affected thereby.
22. Permit Modification, Revocation, Termination
This permit may be modified, revoked and reissued or terminated with cause in accordance to the requirements of
the City of Salisbury Utilities Ordinance and North Carolina General Statute or implementing regulations.
23. Re -Application for Permit Renewal
The permittee is responsible for filing an application for re -issuance of this permit at least 180 days prior to its
expiration date.
24. Dilution Prohibition
The permittce shall not increase the use of potable or process water or in any other way attempt to dilute the
discharge as a partial or complete substitute for adequate treatment to achieve compliance with the limitations
contained in this permit.
25. Bg rts of Changed Conditions
The permittec shall give notice to the Environmental Services Division of any planned significant changes to the
permiace's operations or system, which night alter the nature, quality, or volume of its wastewater at least 180 days
before the change. The pernuttee shall not begin the changes until receiving written approval from Environmental
Services Division. Also see Part III, Special Conditions below for additional reporting requirements for spill/slug
issues.
Significant changes my include but are not limited to
(a) Increases or decrease to production
(b) Increases in discharge of previously reported pollutants;
(c) Discharge of pollutants not previously reported to the Environmental Services Division;
(d) New or changed product lines
(e) New or changed manufacturing processes and/or chemicals; or
(f) New changed customers.
26. Construction
No construction of pretreatment facilities or additions thereto shall be begun until Final Plans and Specifications
have been submitted to the Environmental Services Division, and written approval, and an Authorization to
Construct (A to C) have been issued.
27.Reopener
This permit shall be modified or, alternatively, revoked and reissued to comply witli any applicable effluent standard
or limitation for the control of any pollutant shown to contribute to toxicity of the W WTP effluent or any pollutant
chat is otherwise limited by the POTW discharge permit The permit as modified or reissued under this paragraph
may also contain any other requirements of State or Federal pretreatment regulations then applicable.
SI11 CODE: IPC Permit #0038
Page 12 of 15

28. Categorical Reonener
This permit shall be modified, or alternatively, revoked and reissued, to comply with any applicable effluent
standard or linutation issued or approved under Sections 302(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) of the Clean
Water Act, if the effluent standard or limitation so issued or approved:
a) Contains different conditions or is otherwise more stringent than any effluent limitation in this permit; or
b) Controls any pollutant not limited in this permit.
Tlie permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then
applicable.
29. General Prohibitive Standards
The permittee shall comply with the general prohibitive discharge standards in 40 CFR 403.5 (a) and (b) of the
Federal pretreatment regulations.
30. Reports of Potential Problems
The permittee shall notify the Environmental Services Division immediately by telephone of all discharges that
could cause problems to the POTW, including any slug4oadings as defined by 40 CFR 403.5 (b). The permittee
shall provide protection from accidental and slug discharges of prohibited materials and other substances regulated
by this permit. The permittee shall also notify the POTW which it's facility discharges to and Environmental
Services Division immediately of any changes at its facility affecting the potential for spills and other accidental
discharge, discharge of a non -routine, episodic nature, a non -customary batch discharge, or a slug load as defined in
the Sewer Use Ordinance. if the permittee experiences such a discharge, the perrtrittee shall inform the
Environmental Services Division immediately upon the first awareness of the commencement of the discharge.
Notification shall include location of the discharge, type of waste, concentration, and volume - if known - and
corrective actions taken by the permittee. A written follow-up report thereof shall be filed by the permittee within
five (5) days, unless waived by the Environmental Services Division.
Additionally, the permittee in the event of the release of a slug discharge which may present a hazard to the public;
to municipal employees, or which may do harm to the collection system, treatment facilities or the treatment
process, the discharger must notify by telephone immediately the following persons or agencies until the accidental
spill has been reported:
o City of Salisbury Fire Department 638-5351
,,v Environmental Services Division, Pretreatment Office,
704-638 5375, (7:30am 4:30prn)
o Water ! Sewer Maintenance & Construction Division
(Emergencies affecting water or sewer service) 704-638-5339
o Grant Creek Treatment Train* (24 hr.- 7 dayslwk) 704-638-5374
o Town Creek Treatment Train * (24 hr.- 7 dayslwk) 704-638-5377
*(Notify the municipal treatment train plant Operator in Charge at the facility into which you
are permitted to discharge. That information is available on the cover page of this permit. j
Such notification will not relieve the permittee from any liability, which may be incurred as a result of the discharge,
but failure to notify shall be a violation of this permit and subject to enforcement action, including revocation or
termination of this permit.
SIU CODE: 1PC Permit 40038
Page 13 or 15

3 f. Signatory Requirements
All reports or information submitted to fulfill the requirements of this permit must be signed and certified by a
ranking and duly -authorized agent of the permittec.
The following certification statement must be included as an integral part of each report listed above ender
"Signatory Requirements" and must be signed by the permittee's authorized agent:
"I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations.
(Signature)
(Title)
(Date)
5IU CODE: IPC Permit #t0038
Page 14 of 15

I. Required Slug Control Plan:
The permittec shall provide protection from accidental discharges of prohibited materials or other substances
regulated by this permit. The permittee is hereby notilded that he shall develop, submit, obtain Environmental
Services Division approval of, and implement a written Slug Control Plan within 90 days of the effective date
of this permit.
Any permittee who has previously submitted a spill / slug control plan must review the plan at least once during
every calendar year to assure its continuing effectiveness. If changes are necessary, the plan must be modified and
resubmitted to the Environmental Services Division within 90 days of the date the plan is initially reviewed by the
industry.
The plan submitted shall include the following measures as necessary to assure protection of the City's wastewater
treatment facilities from slug loads: the construction of containment dikes around pretreatment units, around process
units containing liquids, and chemical storage areas; the rerouting of floor drains in manufacturing areas to a holding
area located upstream of the discharge to the pretreatment unit; and the plugging of floor drains in chemical storage
areas, and in other areas as needed to protect the Salisbury -Rowan Utilities treatment system.
2. Total Mercurv:
Beginning October 1, 2006, test method Sid. Method 3112B or EPA 245.1 may be used for mercury monitoring.
Laboratories must be North Carolina certified and able to reach a minimum quantitation Ievel of 0.2 pg/1.
If any monitoring indicates total mercury present in the permittee's discharge at a concentration exceeding 0.2 pg/l,
the permittee shall, within ten calendar days of becoming aware of that exceedance, collect and analyze an
additional total mercury sample from the same discharge point where the exceedance occurred.
For reporting purposes, the permittee shall treat each exceedancc as though it were a violation of a discharge limit
and shall report each exceedanee as stated elsewhere in this permit
Every effort should be made by the permitter to find the source of mercury in their effluent by looking at raw
materials, waste practices, etc. This permit may be re -opened by the Environmental Services Division to impose a
numerical limit for total mercury.
3. Conditions Affecting WWTP Performance:
Should pollutants discharged by the permittee contribute to a degradation of the performance of the Salisbury -
Rowan Utilities' treatment facilities, the Environmental Services may require the permittec to conduct a treatability
study for the suspect pollutant(s). In addition, the Environmental Services may reopen and modify this permit as
necessary to further regulate any pollutants causing such degradation of performance.
4. Flow Measurement Requirements
The permitter shall maintain appropriate discharge flow measurement devices and methods consistent with approved
scientific practices to ensure the accuracy and reliability of measurements of the volume of monitored discharges. Deices
installed shall be continuous recording flow meter capable of measuring flows with a maximum deviation of less than 10%
from true discharge rates throughout the range of expected discharge volumes. The devices shall be installed, calibrated.
and maintained to ensure accuracy. The meter shall be calibrated every six months. Modifications to the flow metering
equipment shall be approved by the Control Authority prior to installation. If a required flow measurement device fails, the
Control Authority shall be notified within 24 hours.
SIU CODF,: IPC Permit #0038
Page 15 of 15

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Finley, Peggy
From: Clay White [[e-mail]]
Sent: Friday, July 27, 2012 1:12 PM
To: Finley, Peggy
Cc: Allen Robey; Timothy Mauldin; Mark Heimberger; Jerry Putnam
Subject: v-notch plate for influent wastewater meter
Peggy, to confirm my call to you today; Tim Mauldin has identified that the v-notch plate for our influent wastewater
meter is not holding water up to the bottom of the v-notch.
• With water leaking by the v-notch plate the meter does not accurately record the influent flow rate.
• We will need to lower pond levels to be able to identify leak area(s) and seal the v-notch plate/ brackets.
• The influent flow will be estimated until the influent meter system is functioning properly.
• Influent flow will be estimated based on freeboard levels effluent amounts and rain fall.
• Meter calibration to follow system repairs.
• Updates to follow
Best regards,
P' Clay White
Operations Coordinator
Innospec Active Chemicals U.S. Co.
Tel: [phone]
Mobile: [phone]
Fax: [phone]

Beverly Eaves Perdue
Governor
"LE
ATA. Fi
NCDENR
North Carolina Department of Environment and Natural Resources
Charles Wakild, P.E.
Division of Water Quality
Innospec Active Chemicals
Post Office Box 164
Spencer, North Carolina 28159
Attention: Clay White, Operations Manager
Dear Mr. White:
Dee Freeman
Secretary
May 7, 2012
RE: Surface Irrigation Inspection Report
Spencer Plant
Permit No. WQ0001077
Rowan County, N.C.
Enclosed you will find the report for the annual compliance inspection that was conducted on
May 2, 2012. The treatment and disposal system appears to be in compliance with the permit.
Should you have any questions, feel free to call me at 704/235-2183 or contact me via email at:
[e-mail].
Sincerely,
Peggy Finley
Environmental Specialist
Enclosure: Inspection Report
Cc: Allen Robey, SHE Manager, Innospec Active Chemicals, POB 164, Spencer
MAF/innospec inspection rpt 5-2-12
NorthCarol/ii
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] Natu1,Q /[l
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1 877-623 6748 Internet: www.ncwaterquality.org l V

}
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly Eaves Purdue, Governor
Dee Freeman, Secretary
Charles Wakild, P.E., Director
00
Orin
�_ A-r
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION.
GENERAL INFORMATION
Owner: Innospec Performance Chemicals
Permit # WQ0001077
Issuance Date: 6/27/07
Permittee Contact: Clay White
ORC Name: Clay White Cert #28828
Email address: [e-mail]
Backup ORC Name: Tim Mauldin Cert #29214
County: Rowan
Project Name: Innospec
Expiration Date: 5/31/16
Telephone No.: 704/639-7920
Tel. No.: 704/633-8028
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Summary: (additional comments may be included on attached pages)
The treatment and disposal system appear to be operating satisfactorily. The irrigation fields
appeared to be in very good condition. Recordkeeping is complete and in good order. No
compliance issues.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 5/2/12

r
A
Surface Irrigation
Permit #WQ00
Type
Activated Sludge Spray, low rate
Activated Sludge Drip, low rate
X Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Influent pump station
X All pumps present, operational
X Bar screen, maintained
Bars evenly spaced
Back-up power
Bypass structure present
—Y—Free of excessive debris
Bars excessively corroded
Flow Measurement — Influent
_X_ Is flowmeter calibrated annually?
_ X_ Is flowmeter operating properly?
_ X_ Does flowmeter operate continuously?
_ X_ Does flowmeter record flow?
X _ Does flowmeter appear to monitor accurately?
Flow Measurement — Water -Use Records
Is water use metered?
Are the daily average values properly calculated?
Page 2
Disinfection NA
Is the system working? Is the system properly maintained?
Tablets Gas Liquid UV
If tablets, proper size? Present in Cylinder(s)?
If gas/liquid, does cylinder/tank storage seem safe?
If bulbs, are replacement bulbs on hand?
Is contact chamber free of sludge, solids and growth?
Flow Measurement — Effluent
Y Is the flowmeter calibrated annually?
_ Y_ Is the flowmeter operating properly?
_Y _ Does the flowmeter monitor continuously?
Y_ Does the flowmeter appear to monitor accurately?

ti.
Surface Irrigation
Permit #WQ0001077
Page 3
Aeration Basins
Check any/all that apply
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N _ Vegetation (is there excessive vegetation on the lagoon bank
Y _ Liner (if visible, is it intact)
Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
_Y Staff gauge (clearly marked)
_N Evidence of overflow (vegetation discolored or laying down/broken)
Unusual color (very black, textile colors)
Y Foam (are antifoam agents used)
Floating mats (sludge, plants, inorganics)
Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Comment:
Residuals
storage/treatment Y Comment: Wallace Farms is still the contractor.
Disposal (final end use)
Y Is the application equipment present and operational?
_N_ Is application equipment in need repair?
_N_ Spray heads calibrated this past year?
Y Are cover crops the type specified in permit?
_N_ Is cover crop in need of improvement?
_N_ Signs of runoff? _N_ Signs of ponding? N Signs of drift?
Y Are buffers adequate?
Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
NA Are restrictions for use of these areas specified?
Y Is site access restricted in accordance with permit?
Comments: The fields appear to be in very good condition.

r
Surface Irrigation
Permit #WQ0001077
Page 4
Recordkeeping
Y Is permit available upon request?
Y_ Are flow rates less than permitted flow?
Y Are monitoring reports present: NDMR _ NDAR
Y Are operational logs present? _Y_ Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are all samples analyzed for the required parameters?
_Y* Is field parameter certification required?
_N_ Are there any 2L GW quality violations?
Y Are annual soil reports available?
Y_ Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: *The facility has a current DWQ field certification.
Groundwater Monitoring
Y Does the permit require monitoring wells? If so,
_Y_ are the monitoring wells properly installed according to the permit?
_Y_ are the wells properly identified?
_N_ are the wells damaged?

Beverly Eaves Perdue
Governor
AFILE
FgC®ENR
North. Carolina Department of Environment and Natural Resources
Coleen H. Sullins
Division of Water Quality
Innospec Active Chemicals
Post Office Box 164
Spencer, North Carolina 28159
Attention: Clay White, Operations Manager
Dear Mr. White:
Dee Freeman
Secretary
March 31, 2011
RE: Surface Irrigation Inspection Report
Spencer Plant
Permit No. WQ0001077
Rowan County, N.C.
Enclosed you will find the report for the annual compliance inspection that was conducted on
March 22, 2011. The treatment and disposal system appears to be in compliance with the
permit.
As a result of additional action by the North Carolina legislature, the expiration date for your
permit has been extended to November 30, 2016. Please submit your renewal application at
least six months prior to the new expiration date.
Should you have any questions, feel free to call me at 704/235-2183 or contact me via email at:
[e-mail].
Sincerely,
Peggy Finley
Environmental Specialist.
Enclosure: Inspection Report
Cc: Allen Robey, SHE Manager, Innospec Active Chemicals, POB 164, Spencer
MAF/innospec inspection rpt 3-22-11
Nne
orthCarohi
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] �%tlll'Qlll
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterquality.org

State of North Carolina
Department of Environment
and Natural Resources
Division of water Quality
Beverly Eaves Purdue, Governor
Dee Freeman, Secretary
Coleen H. Sullins, Director
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
Owner: Innospec'Performance Chemicals
Permit # WQ0001077
Issuance Date: 6/27/07
Permittee Contact: Clay White
ORC Name: Clay White Cert #28828
Email address: [e-mail]
Backup ORC Name: Tim Mauldin Cert #29214
County: Rowan
Project Name: Innospec
Expiration Date: 5/31/16
Telephone No.: 704/639-7920
Tel. No.: 704/633-8028
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Summary: (additional comments may be included on attached pages)
The treatment and disposal system appear to be operating in compliance with the permit.
The irrigation fields appeared to be in good condition. Recordkeeping is complete and in
good order.
As a result of increases in manufacturing output, the company is still investigating an
expansion of the surface irrigation system. The City of Salisbury has granted an increase in
flow that can be discharged to the municipal sewer.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Environmental Specialist; Maria Schutte, Sr. Environmental Tech
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 3/22/11

Surface Irrigation
Permit #WQ00
Type
Activated Sludge Spray, low rate
Activated Sludge Drip, low rate
_X_ Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Comment:
Influent pump station
X All pumps present, operational
X Bar screen, maintained
Bars evenly spaced
Back-up power
Bypass structure present
—Y—Free of excessive debris
Bars excessively corroded
Flow Measurement — Influent
X Is flowmeter calibrated annually?
_ X_ Is flowmeter operating properly?
_ X_ Does flowmeter operate continuously?
_ X_ Does flowmeter record flow?
X Does flowmeter appear to monitor accurately?
Flow Measurement — Water -Use Records
Is water use metered?
Are the daily average values properly calculated?
Page 2
Disinfection NA
_ Is the system working? Is the system properly -maintained?
Tablets Gas Liquid UV
If tablets, proper size? Present in Cylinder(s)?
If gas/liquid, does cylinder/tank storage seem safe?
If bulbs, are replacement bulbs on hand?
Is contact chamber free of sludge, solids and growth?
Flow Measurement — Effluent
Y Is the flowmeter calibrated annually?
_ Y_ Is the flowmeter operating properly?
Y _ Does the flowmeter monitor continuously?
Y Does the flowmeter appear to monitor accurately?
Comments: Flowmeter was replaced very recently.

4
Surface Irrigation Page 3
Permit #WQ0001077
Aeration Basins
Check any/all that apply
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N _ Vegetation (is there excessive vegetation on the lagoon bank
Y _ Liner (if visible, is it intact)
Baffles/curtains (in need of repair)
Y* Freeboard (>2 feet from overtopping)
_Y Staff gauge ( clearly marked)
_N Evidence of overflow (vegetation discolored or laying down/broken)
Unusual color (very black, textile colors)
Y Foam (are antifoam agents used)
Floating mats (sludge, plants, inorganics)
Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Comment: Liquid levels have been drawn done in the basins in order to repair a leaking pipe.
This would be an opportune time to remove solids buildup.
Residuals
storage/treatment Y Comment: Wallace Farms is still the contractor.
Disposal (final end use)
Y Is the application equipment present and operational?
_N_ Is application equipment in need repair?
_N_ Spray heads calibrated this past year?
Y Are cover crops the type specified in permit?
_N_ Is cover crop in need of improvement?
_N_ Signs of runoff? _N_ Signs of ponding? N Signs of drift?
Y Are buffers adequate?
Y * Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
NA Are restrictions for use of these areas specified?
Y Is site access restricted in accordance with permit?
Comments: The fields appear to be in very good condition. Zone #3 in sprayfield #2 has not
received applications in quite a while.

Surface Irrigation
Permit #WQ0001077
Page 4
Recordkeeping
Y Is permit available upon request?
Y*_ Are flow rates less than permitted flow?
Y Are monitoring reports present: NDMR _ NDAR
Y Are operational logs present? _Y Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are all samples analyzed for the required parameters?
_Y_ Is field parameter certification required?
_N_ Are there any 2L GW quality violations?
Y Are annual soil reports available?
Y_ Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: * Approved flows to the City of Salisbury's sewer system were recently increased
to 60,000 gpd max. Monthly PAN calculations were available for review.
Groundwater Monitoring
Y Does the permit require monitoring wells? If so,
_Y_ are the monitoring wells properly installed according to the permit?
Y are the wells properly identified?
N are the wells damaged?

Finley, Peggy
From: Clay White [[e-mail]]
Sent: Friday, March 18, 2011 11:07 AM
To: Finley, Peggy
Cc: Allen Robey; Jerry Putnam
Subject: Innospec, Spencer Flow Meter
Peggy, our new effluent flow meter was installed and successfully started up yesterday afternoon by Endress and
Hauser.
Our freeboard is now 4' 3".
Regards,
Clay White
Operations Coordinator
Innospec Active Chemicals U.S. Co.
Tel: [phone]
Mobile: [phone]
Fax: [phone]

Finley, Peggy
From: Clay White [[e-mail]]
Sent: Friday, February 25, 2011 3:14 PM
To: Finley, Peggy
Cc: Allen Robey; Jerry Putnam
Subject: Innospec Waste Water system
Peggy, per our conversation, the following summarizes our issue and our corrective actions:
1. We have found a small leak in a flange in the line that gravity feeds from the ponds to the flocculation tank.
2. The leak is contained in a manner to prevent ground contamination and we are pumping any accumulated
water back to the wastewater system.
3. In order to repair the leak, we need to drain the ponds down at least 24" from current levels. This will take
approximately 25 days at best flow rates.
4. Once the levels are down, we can plug the discharge pipe of the pond and make the repair. There is no valve
between the leak and the discharge pipe of the lagoons, so a plug must be used to isolate the line.
5. The water leaving the ponds is continuing to go through the flocculation tank and clarifier, so we do not
anticipate this issue to cause us to violate any permit limits.
I will contact you once we get to the point where we can plug the line and make the repair. If you have any questions,
please don't hesitate to call me.
Regards,
it$* Clay White
Operations Coordinator
Innospec Active Chemicals U.S. Co.
Tel: [phone]
Mobile: [phone]
Fax: [phone]

Beverly Eaves Perdue
Governor
NCDENR
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins
Division of Water Quality
Innospec Performance Chemicals
Post Office Box 164
Spencer, North Carolina 28159
Attention: Clay White, Operations Manager
Dear Mr. White:
Dee Freeman
Secretary
April 20, 2010
RE: Surface Irrigation Inspection Report
Spencer Plant
Permit No. WQ0001077
Rowan County, N.C.
Enclosed you will find the report for the annual compliance inspection that I conducted on April
15, 2010. The treatment and disposal system appears to be in compliance with the permit.
As a result of passage of SL 2009-406, the expiration date for your permit has been extended to
November 30, 2015. Please submit your renewal application at least six months prior to the
new expiration date.
Sincerely,
Peggy Finley
Environmental Specialist
Enclosure: Inspection Report
MAF/innospec inspection rpt 4-15-10
NoRhCarohi
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office. Phone: [phone] Fax: [phone] J��u1,R"l
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterquality.org (/ V

L
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly Eaves Purdue, Governor
Dee Freeman, Secretary
Coleen H. Sullins, Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
Owner: Innospec Performance Chemicals
Permit # WQ0001077
Issuance Date: 6/27/07
Permittee Contact: Clay White
ORC Name: Clay White Cert #28828
Email address: [e-mail]
Backup ORC Name: Tim Mauldin Cert #29214
County: Rowan
Project Name: Innospec
Expiration Date: 5/31/15
Telephone No.: 704/639-7920
Telephone No.: same
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Summary: (additional comments may be included on attached pages)
The treatment and disposal system appear to be operating in compliance with the permit.
The irrigation fields appeared to be in good condition. Recordkeeping is complete and in
good. order.
As a result in changes in manufacturing output, the company is investigating expansion of the
wastewater system. The City of Salisbury has been approached about increasing the flow
discharged to the municipal sewer. A modification of the non -discharge permit may also be
requested in the future.
Is a follow-up inspection necessary yes
Inspector Name/Title: Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 4/15/10
X no

A
Surface Irrigation
Permit #WQ00
Type
Activated Sludge Spray, low rate
Activated Sludge Drip, low rate
_X_ Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
N Do all treatment units appear -to be operational. If no, note below.
Comment:
Influent pump station
X All pumps present, operational
X Bar screen, maintained
Bars evenly spaced
Back-up power
Flow Measurement — Influent
_X_ Is flowmeter calibrated annually?
_ X_ Is flowmeter operating properly?
_ X_ Does flowmeter operate continuously?
Does flowmeter record flow?
X _ Does flowmeter appear to monitor accurately?
Bypass structure present
Free of excessive debris
Bars excessively corroded
Flow Measurement — Water -Use Records
Is water use metered?
Are the daily average values properly calculated?
Page 2
Disinfection NA
Is the system working? Is the system properly maintained?
Tablets Gas Liquid _Y_ UV
If tablets, proper size? Present in Cylinder(s)?
If gas/liquid, does cylinder/tank storage seem safe?
If bulbs, are replacement bulbs on hand?
Is contact chamber free of sludge, solids and growth?
Flow Measurement — Effluent
_Y_ Is the flowmeter calibrated annually?
_ Y_ Is the flowmeter operating properly?
_Y _ Does the flowmeter monitor continuously?
Y Does the flowmeter appear to monitor accurately?

Surface irrigation
Permit #WQ0001077
Effluent Storaqe
Page 3
X LAGOON SEPTIC TANK(s) ABOVE GROUND TANK OTHER
Number of months storage _1" Spill control plan on site
Above ground tank Aerated Mixed
In ground tank Aerated Mixed
Storage Lagoons
Check any/all that apply
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N _ Vegetation (is there excessive vegetation on the lagoon bank
_Y _ Liner (if visible, is it intact)
Baffles/curtains (in need of repair)
Y* Freeboard (>2 feet from overtopping)
—Y—Staff gauge ( clearly marked)
—N—Evidence of overflow (vegetation discolored or laying down/broken)
Unusual color (very black, textile colors)
Y Foam (are antifoam agents used) -
Y Floating mats (sludge, plants, inorganics)
Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Comment: Two foot of freeboard is currently present. Evidence of previous freeboard
incursion is still apparent from past excessive rainfall events.
Residuals
storage/treatment _Y Comment: Wallace Farms is still the contractor.
Disposal (final end use)
Y Is the application equipment present and operational?
_N_ Is application equipment in need repair?
_N_ Spray heads calibrated this past year?
Y Are cover crops the type specified in permit?
_N_ Is cover crop in need of improvement?
_N Signs of runoff? _N_ Signs of ponding? N Signs of drift?
Y Are buffers adequate?
Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
NA Are restrictions for use of these areas specified?
Y Is site access restricted in accordance with permit?
Comments: The fields appear to be in very good condition

r
Surface Irrigation
Permit #WQ0001077
Page 4
RecordiCeeping
Y Is permit available upon request?
Y_ Are flow rates less than permitted flow?
Y Are monitoring reports present: NDMR _ NDAR
Y Are operational logs present? _Y_ Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are all samples analyzed for the required parameters?
_Y_ Is field parameter certification required?
_N_ Are there any 2L GW quality violations?
Y Are annual soil reports available?
Y Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: Monthly PAN calculations were available for review.
Groundwater Monitoring
_Y_ Does the permit require monitoring wells? If so,
Y are the monitoring wells properly installed according to the permit?
_Y_ are the wells properly identified?
_N_ are the wells damaged?

NCDENR Py
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Division of Water Quality Secretary
April 15, 2009
Innospec Performance Chemicals
Post Office Box 164
Spencer, North Carolina 28159
Attention: Clay White, Operations Manager
RE: Surface Irrigation Inspection Report
Permit No. WQ0001077
Rowan County, N.C.
Dear Mr. White:
Enclosed you will find the report for the annual compliance inspection that I conducted on March
31, 2009. While the treatment system was not in operation on the day of the inspection, the
facility is essentially in compliance.
Enclosed you will also find a copy of the permit name/ownership change form. Please update
the information for the signing official and return it to the Mail Service Center address on the
reverse side.
Sincerely,
Peggy Finley
Environmental Specialist
Enclosures
MAF/innospec inspection rpt 3-31-09
One
Xitmhalli
hCaroli�
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] Caroh
610 East CenterAvenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterquality.org

f
A
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly Eaves Purdue, Governor
Dee Freeman, Secretary
Coleen H. Sullins, Director
e��
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
Owner: Innospec Performance Chemicals County: Rowan
Permit # WQ0001077 Project Name: Innospec
Issuance Date: 6/27/07 Expiration Date: 5/31/12
Permittee Contact: Clay White Telephone No.: 704/639-7920
ORC Name: Clay White Cert #28828 Telephone No.: same
Email address: [e-mail]
Backup ORC Name: Tim Mauldin Cert #29214
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Summary: (additional comments may be included on attached pa_-ges)
There have been no changes in the manufacturing process at this facility. The treatment
plant was not in operation but was awaiting repair at the time of the inspection. The irrigation
fields appeared to be in good condition.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 3/31/09

Surface Irrigation Page 3
Permit #W00001077
Effluent Storaae
X LAGOON SEPTIC TANK(s) ABOVE GROUND TANK OTHER
Number of months storage _1 Spill control plan on site
Above ground tank Aerated Mixed
In ground tank Aerated Mixed
Storage Lagoons
Check any/all that apply
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N _ Vegetation (is there excessive vegetation on the lagoon bank
_Y _ Liner (if visible, is it intact)
Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
_Y Staff gauge ( clearly marked)
_N Evidence of overflow (vegetation discolored or laying down/broken)
Unusual color (very black, textile colors)
Y Foam (are, antifoam agents used)
Floating mats (sludge, plants, inorganics)
Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Residuals
storage/treatment Y Comment: Wallace Farms is still the contractor.
Disposal (final end use)
Y Is the application equipment present and operational?
_N_ Is application equipment in need repair?
Spray heads calibrated this past year?
_Y_ Are cover crops the type specified in permit?
N Is cover crop in need of improvement?
_N_ Signs of runoff?
_N_ Signs of ponding?
Y Are buffers adequate?
Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
_ Are restrictions. for use of these areas specified?
N Is there evidence of runoff or drift?
Y Is site access restricted in accordance with permit?
Comments: The fields appear to be in very good condition

Michael F. Easley, Governor
William G. Ross Jr., Secretary
f � 0 IPT
h Carolina Department of Environment and Natural Resources
Colleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION SECTION
May 23, 2008
Innospec, Inc.
PO Box 164
775 Hackett Street
Spencer, North Carolina 28159
Attention: Kirby Atwood, HSE Compliance Manager .
RE: Spray Irrigation Inspection Report
Permit No. WQ0001077
Rowan County, N.C.
Dear Mr. Atwood:
Enclosed you will find the report for the inspection that I conducted on May 20, 2008. The treatment and
disposal system is operating satisfactorily at this time. However, the flow into the plant has exceeded the
permitted monthly average of 18,000 gallons per day for the past several months. In order to become
compliant with your permit, you must submit an application for a permit modification and request that the flow
threshold be increased. You will need to include an engineering evaluation demonstrating that the plant can
accommodate the proposed flow or you must provide a plan for expansion of the treatment facilities. This
evaluation must be signed and sealed by a professional engineer.
Please feel free to contact me via phone [phone]) or email at: peggy.finley(nncmail.net if you have any
questions.
Sincerely,
P ejyPinIe
Y
Environmental Specialist
Enclosure: Inspection Report
Cc: Clay White — Innospec w/enclosure
David Goodrich — APS Land Application Unit, Raleigh
MAF/surface irrig/innospec inspect rpt 5-20-08
NorthCarolina
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] i
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org i/ V atut,Q [[//y

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Colleen H. Sullins, Director
I I Tk4
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
City/Town/Owner: Innospec, Inc.
Permit # WQ 0001077
Issuance Date: 6/27/07
Permittee Contact: Emmett K. Atwood
ORC Name: Kirby Atwood
Backup ORC: Clay White
County: Rowan
Expiration Date: 5/31/08
Telephone No. 704/639-7919
Telephone No. 704/639-7920
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System X Spray Irrigation Sludge Other
Inspection Summary: (additional comments may be included on attached pages)
The treatment plant is operating satisfactorily, however average monthly flow has exceeded
the permit limit of 18,000 gpd over the last several months. Both application areas appearto
be in excellent condition. Records and documentation are organized and up-to-date.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 FAX [phone]
Date of Inspection: 5/20/08

Spray Irrigation
Permit #W00001077-
Type
Activated Sludge Spray, low rate
Activated Sludge Spray, high rate
Activated Sludge Drip, low rate
X Lagoon Spray, low rate
Reuse (Golf Courses)
Recycle /Reuse
Single Family Spray, low rate
Single Family Drip
Infiltration System
Other
Treatment
Page 2
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Comments: The permitted average monthly inflow (18,000 gpd) has been exceeded for
the last six months.
Treatment & Storage Lagoons (one 252,536 gal. and one 247,156 gal.)
Primary (check any/all that apply)
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N Vegetation (is there excessive vegetation on the lagoon bank
_Y_ Liner (if visible, is it intact)
_NA_ Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
Y Staff gauge (clearly marked)
_N_ Evidence of overflow (vegetation discolored or laying down/broken)
_N_ Unusual color (very black, textile colors)
Y Foam (are antifoam agents used)
_N Floating mats (sludge, plants, inorganics)
N_ Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Influent numn station
Y all pumps present, operational Bypass structure present
Y Bar screen, maintained —Y—Free of excessive debris
—Y—Bars evenly spaced —N—Bars excessively corroded
_N _Back-up power

IN
A
Spray Irrigation Page 3
WQ0001077
Flow Measurement - Influent '
_Y_ Is flowmeter calibrated annually?
Y Is flowmeter operating properly?
_Y_ Does flowmeter operate continuously?
_ Does flowmeter record flow?
Y Does flowmeter appear to monitor accurately?
Clarifiers
—Y—weirs level —Y—scum rack operational —Y—easily accessible
Filters NIA
media present air scour operational clear well free of solids
Disinfection NA
Is the system working? Is the system properly maintained?
Flow Measurement - Effluent
_Y_ Is flowmeter calibrated annually?
_Y_ Is the flowmeter operating properly?
_Y_ Does the flowmeter monitor continuously?
Y_ Does the flowmeter appear to monitor accurately?
Effluent Storage
Spill control plan on site Y
Residuals
Storage/treatment — Sludge is removed from 8,000 gal capacity tank approximately every two
weeks by Wallace Farms of Huntersville.
Disposal (final end use)
_N_ Is application equipment in need repair?
_Y_ Are buffers adequate?
_Y_ Are cover crops the type specified in permit?
_N_ Is cover crop in need of improvement?
_N_ Signs of runoff?
_N_ Signs of ponding?
Y Is the acreage specified in the permit being utilized?
Y Is the application equipment present and operational?
N Are there any limiting slopes in disposal fields?
Y Are restrictions for use of these areas specified?
Y Is permit being followed?
N Is there evidence of runoff or drift?
Y Are monitoring wells called for in permit present?
Y Is site access restricted in accordance with permit?
Comments: Application fields appear to be in excellent condition

F
Spray Irrigation
WQ0001077
page 4
Recordkeeping
Y Is permit available upon request?
Y Are monitoring reports present: NDMR X NDAR X
Y Are operational logs present?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are annual soil reports available?
Y Are operation and maintenance records present? Complete? Y_
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: A copy of the soil fertility analysis will be forwarded to the regional office
when available. The annual loading report documents PAN calculation for each of the
application zones. The 2007 report was available for review.

i I N.
2007 Annual Loading Report
Field #1(4 acres)
Discharge Volume: 1,135,200 gallons
gallons
PAN: 54.50 lbs./acre
Lead:.018 lbs./acre
Zinc: 2.63 lbs./acre
Copper:.164 lbs. /acre
Nickel:.093 lbs./acre
Cadmium:. 003 lbs. /acre
Field #2-Zone 2 (.9163 acre)
Discharge Volume: 428,194 gallons
PAN: 88.80 lbs./acre
Lead:.029 lbs./acre
Zinc: 4.32 lbs./acre
Copper: .2701bs. /acre
Nickel: .154 lbs./acre
Cadmium:.005 lbs./acre
Field #2-Zone 5 (1.092 acre)
Discharge Volume: 522,192 gallons
PAN: 91.22 lbs./acre
Lead:.029 lbs./acre
Zinc: 4.36 lbs./acre
Copper: .2751bs. /acre
Nickel:.155 lbs./acre
Cadmium:.005 lbs./acre
•
I (III osec )-
performance chemicals
Field #2-Zone 1 (1.135 acres)
Discharge Volume: 536,616
PAN: 89.29 lbs./acre
Lead:.029 lbs./acre
Zinc: 4.33 lbs./acre
Copper:.272 lbs. /acre
Nickel:.154 lbs. /acre
Cadmium:.005 lbs./acre
Field #2-Zone 4 (1.435 acre)
Discharge Volume: 686,224 gallons
PAN: 91.22 lbs./acre
Lead: .0291bs./acre
Zinc: 4.36 lbs./acre
Copper:.275 lbs./acre
Nickel:.155 lbs./acre
Cadmium. .0051bs./acre
Field #2-Zone 6 (1.617 acre)
Discharge Volume: 382,278 gallons
PAN: 44.65 lbs./acre
Lead:.015 lbs./acre
Zinc: 2.17 lbs./acre
Copper: .13 6 lbs. /acre
Nickel:.077 lbs./acre
Cadmium:.003 lbs./acre
". Innospec Performance Chemicals U.S. Co
PO Box 164, Spencer
North Carolina 28159
Tel: [phone]
Fax: [phone]
www.innospecinc.com

Sprayfieid Voium' Al
13200
6168
4979
7798
5934
4394
A tied' ;
F# 1
F# 2-1
F# 2-2
F# 2-4
F# 2-5
F# 2-6
Jan
0
6168
4979
7798
5934
4394
2
Feb
26400
12336
9958
15596
11868
8788
3
March
39600
18504
9958
23394
17802
13182
7
April
92400
43176
34853
54586
41538
30758
12
May
145200
74016
59748
93576
71208
52728
6
June
79200
37008
29874
46788
35604
26364
8
July
105600
49344
39832
62384
47472
35152
13
August
171600
80184
64727
101374
771421
57122
10
Set
132000
61680
49790
77980
593401
43940
10
Oct
132000
61680
49790
77980
59340
43940
9
Nov
118800
55512
44811
70182
53406
39546
Dec
92400
37008
29874
54586
41538
26364
Total Per; tone
; I135200
536616
=" '428194,
s86224
5'221 �2
382278:
Annual Total
W: 6907Q4
Pan Formula
TKN
INH3
IMR Const
0.5 Const
IN03NO2
181
0.51
0.31
0.51
37.1
42.6
L. 'EFF SAMPLE RESULT§,ia(mj4)
Pan, _
Lead
Zinc '
Co ` er`
Nicker:}
Cadmiun
Jan
9.48
0.0033
0.22
0.05
0.01
0.001
Feb
4.13
0.0028
0.26
0.05
0.0095
0.0012
March
10.575
0.0036
0.29
0.05
0.012
0.0012
April
39.04
0.007
0.2
0.05
0.021
0.0016
May
23
0.0059
0.49
0.055
0.02
0.0013
June
5.27
0.006
0.29
0.05
0.023
0.001
July
6.023
0.0058
0.046
0.05
0.023
0.001
August
24.316
0.012
0.35
0.05
0.02
0.0016
Sept
30.54
0.007
3.89
0.05
0.103
0.0014
Oct
27.046
0.0074
2.28
0.09
0.0561
0.0011
Nov
16
0.0087
1.6
0.18
0.0751
0.002
Dec
42.6
0.0064
0.65
0.055
0.017
0.001

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Oct
0.0012
0.0006
0.0005
0.0007
0.0005
0.0004
Nov
0.0020
0.0009
0.0007
0.0012
0.0009
0.0007
Dec
0.0008
0.0003
0.0002
0.0005
0.0003
0.0002
Total
0.0128
0.0060
. 0.0048
0.0077
0.0059
0.0043
Per Acre
1 0.00321
0.00531
0.00531
0.00541
0.0054
0.0027

�) Cn fl* MRO
State of North Carolina
a Environment
d Natural Resources c''�
Division of Water Quality DEC
James B. Hunt, Jr., Governor��El a� [�:;t�,�u&,"L-,n mrnrmD
Bill Holman, Secretary NORTH CAROLINA DEPARTMENT OF
Kerr T. Stevens, Director
�� gro'if`; ENVIRONMENT AND NATURAL RESOURCES
CERTIFIED MAIL.
RETURN RECEIPT REQUESTED
Mr. Emmet Atwood
Finetex, Inc.
PO Box 164
Spencer, NC 28159
November 22, 2000
C`
SUBJECT: Assessment of Civil Penalties for Violation(s) of NCGS 143-215.1
Finetex, Inc.
Rowan County
File No. PC 00-024
Dear Mr. Atwood:
This office has reviewed your pleadings and related correspondence regarding the above -
captioned civil penalty assessment. After careful review, our office has determined that there is
sufficient justification to drop. the enforcement case (File No. PC 00-013) and penalties in the
amount of $3690.79 against Finetex, Inc.
If you have any questions regarding this matter, please contact Jeff Poupart at (919) 733-
5083, ext. 527.
Sincerely,
3-a-
Kerr T. Stevens
cc: Mooresville Regional Office
Enforcement File
Mailing Address: Telephone [phone] Location:
1617 Mail Service Center Fax [phone] N. Salisbury St.
Raleigh, North Carolina 27699-1617 State Courier #52-01-01 Raleigh, NC 27699-1617
An Equal Opportunity /Affirmative Action Employer
50% recycled / 10% post -consumer paper
httpJ/`h20. enr.state. nc. us

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
CERTIFIED MAIL.
RETURN RECEIPT REQUESTED
Emmet Atwood
Fintex, Inc.
PO Box 164
Spencer, NC 28159
Dear Mr. Adams:
1 � •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
November 22, 2000
SUBJECT: Assessment of Civil Penalties
for Violation of 143-215
Rowan County
File No. PC 00-079
This letter transmits notice of a civil penalty assessed against Finetex, Inc in the amount
of $2690.79 including $ 690.79 in investigative costs. Attached is a copy of the assessment
document -explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the
Secretary of the Department of Environment and Natural Resources. Any continuing violation(s)
may be the subject of a new enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of
Environment and Natural Resources (do not include waiver fonn).
Payment of the penalty will not foreclose further enforcement action for
any continuing or new violation(s).
Mailing Address: Telephone [phone]
1617 Mail Service Center Fax [phone]
Raleigh, North Carolina 27699-1617 State Courier #52-01-01
An Equal Opportunity /Affirmative Action Employer
50% recycled / 10% post -consumer paper
http://`h2o.enr.state.nc.us
Location:
512 N. Salisbury St.
Raleigh, NC 27699-1617

Please submit payment to the attention of:
Mr. Steve Lewis
NCDENR
DWQ
1617 Mail Service' Center
Raleigh, North. Carolina 27699-1617
no
2. Submit a written request for remission or mitigation including a detailed
justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure for
contesting the accuracy of any of the statements contained in the assessment
letter. Because a remission request forecloses the option of an administrative
hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in
dispute. You must execute and return to this office the attached waiver and
stipulation form and a detailed statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 14313-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting
from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
Mr. Steve Lewis -
NCDENR
DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1671
N'
Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must
request an administrative hearing. This request must be in the form of a written
petition to the Office of Administrative Hearings and must conform to Chapter
150B of the North Carolina General Statutes. You must file your original petition
with the:

Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
AND
Mail or hand -deliver a Copy of the petition to:
Mr. Dan McLawhorn
NCDENR
Office of General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
Failure to exercise one of the options above within thirty days, as evidenced by a date
stamp (not a postmark) indicating when we received your response, will result in this matter
being referred to the Attorney General's Office with a request to initiate a civil action to collect
the penalty. Please be advised that additional assessments may be levied for future violations
which occur after the review period of this assessment.
If you have any questions, please contact Mr. Steve Lewis at [phone], ext. 539 or
Mr. Jeff Poupart at [phone], ext. 527.
Sincerely,
Kerr T. Stevens
ATTACHMENTS
cc: Regional Supervisor w/, attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
Public Information Officer w/ attachments

STATE OF NORTH CAROLINA
COUNTY OF ROWAN
IN THE MATTER OF: )
FINETEX )
FOR VIOLATIONS OF PERMIT)
NO. WQ0001077 AND )
NCGS 143-215.1 )
FOR FAILING TO PROPERLY )
OPERATE AND MAINTAIN )
SPRAY IRRIGATION SYSTEM )
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
File No. PC 00-079
FINDINGS AND DECISION
AND ASSESSMENT
OF CIVIL PENALTY
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources, I, Kerr T. Stevens, Director of the Division of Water
Quality (DWQ), make the following:
I. FINDINGS OF FACT:
A.' Finetex is an incorporated business organized and existing under the laws of the
State of North Carolina. -
B. On April 20, 1998, DWQ issued Water Quality Permit No. WQ0001077 to
Finetex which allows the treatment and spray irrigation of industrial wastewater
on two permitted sites located in Rowan County, North Carolina.
C. Said permit contains the following relevant conditions:
• Part I, Condition 7.b states The following buffers shall be maintained: 150 feet
between wetted area and property lines.
• Part II, Condition 3 states that a suitable vegetative cover shall be maintained.
D. On September 30, 1999, and October 1, 1999, DWQ staff from the Mooresville
Regional Office observed poor operating conditions at the wastewater treatment
facility's 6 acre spray irrigation field.

E. Staff observed the following violations of permit WQ0001077
1. Runoff was entering into the eastern property buffer and hydrology indicators
suggest that runoff has consistently flowed off the spray field and into the
buffer area.
2. Several areas of the spray field were without suitable vegetative cover.
F. A Notice of Violation concerning the above mentioned violations was sent to
Finetex by DWQ's Mooresville Regional Office on October 25, 1999.
G. The cost to the State of the enforcement procedures in this matter totaled $690.79.
Based upon the above Findings of Fact, I make the following:
H. , CONCLUSIONS OF LAW:
A. Finetex is a "person" within the meaning of G.S.143-215.6A pursuant to G.S. 143-
212(4).
B. The disposal system cited in Findings of Fact B. above falls within the definition
of same at G.S. 143-213(10) or G.S. 143-213(17).
C. A permit is required for the construction and operation of a treatment works and
disposal system the pursuant to G.S. 143-215. 1 (a)(2).
D. Finetex violated Part I Condition 7 (b) of DWQ Permit No. WQ0001077 by
failing maintain a 150 foot buffer between wetted area and property line.
E. Finetex violated, Part II Condition 3 of DWQ Permit No. WQ0001077 by failing
to maintain a suitable vegetative cover crop.
F Finetex may be assessed civil penalties in this matter pursuant to G.S. 143-
215.6A(a)(2), which provides that a civil penalty of not more than twenty five
thousand dollars per violation may be assessed against a person who is required
but fails to act in accordance with the terms , conditions or requirements of a
permit required by G.S. 143-215.1.
G. The State's enforcement costs in this matter may be assessed against Finetex
pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282. I (b)(8).

H. The Director, Division of Water Quality, pursuant to delegation provided by G.S.
143- 15.6A(h), has the authority to assess civil penalties in this matter.
III. DECISION:
Accordingly, Finetex is hereby assessed a civil penalty of:
$ `o O o for violating Condition number. I.7 (b) of Permit No.
WQ 0001077 by not maintaining a 150 foot buffer between
wetted area and property line.
$ `' 0 0 o for violating Condition No. II .3 of Permit No.
WQ 0001077 by not maintaining a suitable vegetative
cover crop.
$ 2 , oy TOTAL CIVIL PENALTY, which is 10 percent of
the maximum penalty authorized by G.S. 143-215.6A.
$ 690.79 Enforcement costs
$T o .'1 ti TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.
V-22— oo
�ena
(Date) Kerr T. Stevens, Director
Division of Water Quality

G. 4
State of North Carolina
Department of Environment �•v
and Natural Resources 1
Division of Water Quality
James B. Hunt, Jr., Governor NCDENR
Bill Holman, Secretary NORTH CAROLINA DEPARTMENT OF
Kerr T. Stevens, Director ENVIRONMENT AND NATURAL RESOURCES
f�
October 31, 2000 � ft
CERTIFIED MAIL NOV
RETURN RECEIPT REQUESTED 2000
4009OF l 1
tl l ;f pa n1A�611u1�j'
Emmet Atwood f7D0t1ED~JB&1:F IIF C9�iQC ����2,
Fintex, Inc.
PO Box' 164
Spencer, NC 28159
SUBJECT: Assessment of Civil Penalties
,for Violation of 143-215
Rowan County
File No. PC 00-024
Dear Mr. Atwood:
This letter transmits notice of a civil penalty assessed against Finetex, Inc in the amount
of $3690.79 including $690.79 in investigative costs. Attached is a copy of the assessment
document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the
Secretary of the Department of Environment and Natural Resources. Any continuing violation(s)
may be the subject of a new enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
Submit payment of the penalty:
Payment should be made directly to the order of the Department of
Environment and Natural Resources (do not include waiver form).
Payment of the penalty will not foreclose further enforcement action for
any continuing or new violation(s).
Mailing Address: Telephone [phone]
1617 Mail Service Center Fax [phone]
Raleigh, North Carolina 27699-1617 State Courier #52-01-01
An Equal Opportunity /Affirmative Action Employer
50% recycled / 10% post -consumer paper
http://h2o.enr.state.itc.us
Location:
512 N. Salisbury St.
Raleigh, NC 27699-1617

Please submit payment to the attention of
Mr. Steve Lewis
NCDENR
DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
X
2. Submit a written request for remission or mitigation including a detailed
justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure for
contesting the accuracy of any of the statements contained in the assessment
letter. Because a remission request forecloses the option of an administrative
hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in
dispute. You must execute and return to this office the attached waiver and
stipulation form and a detailed statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting
from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penaltie"s for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
Mr. Steve Lewis
NCDENR
DWQ
1617 Mail Service Center.
Raleigh, North Carolina 27699-1671
OR
Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must
request an administrative hearing. This request must be in the form of a written
petition to the Office of Administrative Hearings and must conform to Chapter
150B of the North Carolina General Statutes. You must file your original petition
with the:

Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
AND
Mail or hand -deliver a Copy of the petition to:
Mr. Dan McLawhom
NCDENR
Office of General Counsel.
1601 Mail Service Center
Raleigh, NC 27699-1601
Failure to exercise one of the options above within thirty days, as evidenced by a date
stamp (not a postmark) indicating when we received your response, will result in this matter
being referred to the Attorney General's Office with a request to initiate a civil action to collect
the penalty. Please be advised that additional assessments may be levied for future violations
which occur after the review period of this assessment.
If you have any questions, please contact Mr. Steve Lewis at [phone], ext. 539 or
Mr. Jeff Poupart at [phone], ext. 527.
Sincerely,
Kerr T. Stevens
ATTACHMENTS
cc: Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
Public Information Officer w/ attachments

I
STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
COUNTY OF ROWAN
IN THE MATTER OF: )
FINETEX, INC. )
FOR VIOLATIONS OF PERMIT)
NO. WQ0001077 AND )
NCGS 143-215.1 )
FOR FAILING TO PROPERLY )
OPERATE AND MAINTAIN )
SPRAY IRRIGATION SYSTEM)
File No. PC 00-024
FINDINGS AND DECISION
AND ASSESSMENT
OF CIVIL PENALTY
Acting pursuant to delegation provided, by the Secretary of the Department of
Environment and Natural Resources, I, Kerr T. Stevens, Director of the Division of Water
Quality (DWQ), make the following:
I. FINDINGS OF FACT:
A. Finetex, Inc. is an incorporated business organized and existing under the laws of
the State of North Carolina.
B. -On April 20, 1998, DWQ issued Water Quality Permit No. WQ0001077 to
Finetex, Inc. which allows the treatment and spray irrigation of industrial
wastewater on two permitted sites located in Rowan County, North Carolina.
C. Said permit contains the following relevant conditions:
• Part I, Condition 7.b states The following buffers shall be maintained: 150 feet
between wetted area and property lines.
• Part 11, Condition 1 states that the facilities shall be properly operated and maintained
at all times.
• Part II, Condition 3 states that a suitable vegetative cover shall be maintained
D. On September 30, 1999, and October'l, 1999, DWQ staff from the Mooresville

Regional Office observed poor operating conditions at the wastewater treatment
facility and at the 6 acre spray irrigation field.
E. Staff observed the following violations of permit WQ0001077
1. Runoff was entering into the eastern property buffer and hydrology indicators
suggest that runoff has consistently flowed off the spray field and into the
buffer area.
2. The facility was not operated and maintained properly. The clarifer,
flocculation tank and polymer feed system were not in operation.
3. Several areas of the spray field were without suitable vegetative cover.
F. A Notice of Violation concerning the above mentioned violations was sent to
Finetex, Inc. by DWQ's Mooresville Regional Office on October 25, 1999.
G. The cost to the State of the enforcement procedures in this matter totaled $690.79.
Based upon the above Findings of Fact, I make the following:
H. ' CONCLUSIONS OF LAW:
A. Finetex, Inc. is a "person" within the meaning of G.S.143-215.6A pursuant to G.S.
143-212(4).
B. The disposal system cited in Findings of Fact B. above falls within the definition
of same at G.S. 143-213(10) or G.S. 143-213(17).
C. A permit is required for the construction and operation of a treatment works and
disposal system the pursuant to G.S. 143-215.1(a)(2).
D. Finetex violated Part I Condition 7 (b) of DWQ Permit No. WQ0001077 by
failing maintain a 150foot buffer between wetted area and property line.
E. Finetex violated, Part H Condition 1 of DWQ Permit No. WQ0001077 by
failing to properly operate and maintain a non -discharge spray irrigation system.
F. Finetex violated, Part H Condition 3 of DWQ Permit No. WQ0001077 by failing

G Finetex may be assessed civil penalties in this matter pursuant to G.S. 143-
215.6A(a)(2), which provides that a civil penalty of not more than twenty five
thousand dollars per violation may be assessed against a person who is required
but fails to act in accordance with the terms , conditions or requirements of a
permit required by G.S. 143-215.1.
H. The State's enforcement costs in this matter may be assessed against Finetex
pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282. 1 (b)(8).
I. The Director, Division of Water Quality, pursuant to delegation provided by G.S.
143- 15.6A(h), has the authority to assess civil penalties in this matter.
III. DECISION:
Accordingly, Finetex is hereby assessed a civil penalty of:
$ o b for violating Condition number. I.7 (b) of Permit No.
WQ 0001077 by not maintaining a 150 foot buffer between
wetted area and property line.
for violating Condition No. II .1 (b) of Permit No
WQ 0001077 by not properly operating and maintaining the
$ 4 O o a for violating Condition No. 11.3 of Permit No.
WQ 0001077 by not maintaining a suitable vegetative
cover crop.
$ 3, o 0 o TOTAL CIVIL PENALTY, which is \o percent of
the maximum penalty authorized by G.S. 143-215.6A.
$ 690.79 Enforcement costs
$ 3Z TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;

(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.
(Date) Kerr T. Stevens, Director
Division of Water Quality

JAM ES. B HUNTJR
YyGOVERNOR
{` MEMORANDUM TO:
t
_'%BILL HOLMAN FROM:
t�lq � �L
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES b
Jeffrey Poupart
n
D: Rex Gleason `
DIVISION OF WATER QUALITY
MOORESVILLE REGIONAL OFFICE
June 13, 2000
PREPARED BY: Ellen Huffinan Z`�
SUBJECT: Recommendation for Enforcement
Violation of NCGS 143-215.1
DWQ Permit No. WQ0001077
Finetex Incorporated
Non -Discharge Spray Facility
Rowan County, North Carolina
Attached is an enforcement recommendation report concerning a violation of the
subject Permit and General Statute. Since this Office did not have a shell document from
which to develop the attached Findings and Decision (F&D), a similar type F&D was
modified to fit the specific violation. Such being the case, it may be appropriate to
coordinate the review of this recommendation with the Attorney General's Office.
Additional supporting material (including digital photographs on disks) are included with
this enforcement recommendation request.
The violation for which this enforcement recommendation is being submitted is the
result of Finetex's miss -management of the subject spray facility.
The attached material should be self-explanatory; however, if you have any questions,
please contact Mrs. Ellen Huffman or me.
Attachment
ebh
h\enf
A41
wFF1X.s ,.,
0 1 0
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 28115
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

Summary
Finetex is currently permitted to operate an 18,000-gallon per day spray irrigation
treatment facility. This facility includes a manual screen bar, clarifier, flocculation tank with
mixer, a polymer feed system, dual 115,000 gallon aeration basins in series with mechanical
aerators and lined with stone and clay, an 8,000 gallon effluent holding tank, a pump station with
dual 120 GPM irrigation pumps, a 20,000 storage tank, a 4-acre spray irrigation field, and seven
37,000-square foot irrigation zones.
Finetex had submitted an application to expand existing aeration basins (lagoons) to
improve treatment efficiency of their existing facility. A site visit by Charley Schwartz (9/30/99)
and follow up -site visit by Ellen Huffman and Charley Schwartz (10/l/99) confirmed serious
problems with the spray field (photos in file at MRO). The MRO staff- report (attached) details
the conditions and permit violations found at the facility. A Notice of Violation was issued 10-
25-99.
Chronology of Events/Correspondence
Timeline of events
Sept. 30, 1999 and October 1, 1999 - Site visits and initial investigation by Charley Schwartz,
Env. Engineer I, & Ellen Huffinan, Env. Technician V, MRO
October 12, 1999 — Permit Staff Report and Recommendations sent to Raleigh.
October 25, 1999 - NOV and notice for Finetex to stop applying to (all zones of) field 2.
November 1999 - Finetex meets with DWQ (at MRO) regarding violations.
December 1999 — Finetex (via MacConnell and Assoc.) hires Tony C. Jacobs and Associates
to perform a soil and site evaluation.
December 28, 1999 — Site visit at field 92 with Tony Jacobs. Recommendations discussed.
Site improvements started.
February 8, 2000 — Meeting at Finetex. Attendees: Robert Scala, Vice President, Finetex; Jack
Heath, Plant Engineer, Finetex; Tony Bolton, Operations Manager, Finetex; Gary MacConnell,
MacConnell & Associates; Tony Jacobs, Soil Scientist, Jacobs & Associates, Inc.; Ellen
Huffman, DENR-WQ, MRO. Soil evaluation report prepared by Tony Jacobs and site
rehabilitation recommendations were discussed. A field visit concluded that work was done to
repair and improve conditions at field #2. Rehabilitation activities included:
• Zone 3 of field #2 was taken out of service until rehabilitation plan completed
• Regrading and filling of depressions
• Reseeding program established

Page 2
• Preparation of Standard Operating Procedures (SOP) manual for irrigation
procedures, including pre -irrigation checklist
• Removal of gravel driveway from zone 5 of field 2
March 15, 2000 — Meeting at Finetex. Discussion related to:
• Permit status and memo for moving of electrical lines
• Continued field improvements
• A review of Soil Scientist report
• Review of SOP for spray application
CHECKLIST FOR PERMIT VIOLATIONS
1. A copy of the Permit is attached.
2. The violator is Finetex Incorporated.
Mr. Robert H. Scala, Vice -President
P.O. Box 164
Spencer, NC 28159
3'. This enforcement does not include effluent limit violations. It involves violations of
non -discharge DWQ Permit conditions and N.C. General Statute 143-215.1.
Permit # WQ0001077 (see attached)
• Violation of permit condition "I.6"
• Violation of permit condition "1.7.b"
• Violation of permit condition "II.2"
• Violation of permit condition "II.3"
• Violation of permit condition "I1.4"
• Violation of permit condition "II.5"
• Violation of permit condition "11.7"
• Violation of permit condition "II.10"
• Violation of permit condition "IV.2"
• Violation of permit condition "V.2"
4. Copies of all correspondence are attached..
5. There are no chain -of -custody samples.

6. The violations are not due to a power failure.
Page 3
7. Are violations chronic and/or due to a single operational upset?
The violations appear to be chronic, and not due to a single operational upset.
8. Were any specific notifications submitted concerning noncompliance?
A NOV/NRE was sent on October 25, 1999, which set forth the Permit and NCGS
violations, and advised that an enforcement recommendation would be prepared.
9. Cost of the investigation:
27 hours by Ellen Huffman for investigation
and preparation of enforcement report at
$20.08/hour.=$542.16
1 hour by D. Rex Gleason for supervisory review
at $37.70/hour = 37.70
1 hour for clerical processing at $10.93/hour = 10.93
AdministrativeCost for processing report = 100.00
Total $690.79

CIVIL PENALTY ASSESSMENT FACTORS FOR WATER QUALITY CASES
CASE NAME: Finetex
ASSESSMENT FACTORS:
A. CAUSE OF THE VIOLATION(S)
The violations are the result of Finetex's improper following of permit conditions including poor
operation of spray field #2 resulting in poor field conditions. These conditions include:
• the by-pass of untreated wastewater of the treatment facilities (clarifier by-pass)
• improper buffer conditions which appeared to cause runoff to enter into the eastern property
buffer. Hydrology indicators suggest that runoff has consistantly flowed off the spray filed
and into the buffer area.
• poor field conditions barren of vegetation and/or inundated with standing wastewater.
• areas of the spray field were without suitable vegetative cover.
• records indicating application of wastewater to the irrigation field during inclement weather
on multiple occasions.
• wastewater runoff from the spray field.
• records indicating exceedances of a cumulative loading rate of 29.12 inches over any twelve
month period or at an instananeous rate not to exceed 0.25 inches per hour on the seven,
37,000 square foot spray irrigation sites.
• tire ruts and other evidence of compaction were observed in several areas of the field.
• missing groundwater sampling data for Volatile Organic Compounds (VOC) required to be
collected every November.
• no formal inspection log.
B. THE DEGREE AND EXTENT OF HARM CAUSED BY THE VIOLATION(S)
There was no permanent harm to the environment documented as a result of the poor
operations of spray field 2. There was runoff observed at the time of investigation and
the field had evidence of over application in excessive amounts.
C. DURATION OF THE VIOLATIONS)
The violations began sometime on or after September 28, 1998 and ended on October
1, 1999.

Page 2
D. EFFECT OF VIOLATION(S) ON WATER, PUBLIC HEALTH AND FISH OR
WILDLIFE,
There is no documented effect on water, public health, fish or wildlife as a result of
the violations.
E. EFFECTIVENESS OF ANY PREVENTIVE OR RESPONSIVE MEASURE
TAKEN BY THE VIOLATOR
After receiving the NOV with notice to cease use of field #2, Finetex immediately
suspended use of field #2 and hired McConnell and As consultant engineers, to
advise them on correcting the problem. Jacobs Environmental was contracted to advise
Finetex on repair recommendations, to re -calculate field loading capacities, and to
recommend changes in operational proceedures and best management practices for the
type of spray system.
F. COST OF RECTIFYING THE DAMAGE OR INFORMATION THAT
WOULD BE NEEDED TO DETERMINE THE COST, SUCH AS PROCESS
RATES, CLEAN UP COSTS
Finetex responded quickly by repairing and improving field 2 to re -instate the field
into the existing spray treatment system.
G. THE ALLEGED VIOLATOR'S PREVIOUS RECORD OF COMPLIANCE OR
NONCOMPLIANCE
Finetex has not been assessed prior penalties for violations of their non -discharge
permit.
H. MITIGATING, AGGRAVATING FACTORS, IF ANY
It should be noted that Finetex, upon realization of the systems operational failure,
promptly retained the expertise needed to re-evaluate the spray system and repair field
#2 to working conditions as well as rewriting Standard Operating Procedures and sending
more personnel to Operator Certification training. In addition, Finetex plans to monitor
the newly renovated system and continue to make operational improvements as needed.

Putting Ideas to Work!
asi# 38670 item# Z 13

STATE OF NORTH CAROLINA
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROWAN
IN THE MATTER OF: )
FINETEX )
FOR VIOLATIONS OF PERMIT)
NO. WQ0001077 AND )
NCGS 143-215.1 )
FOR FAILING TO PROPERLY )
OPERATE AND MAINTAIN )
SPRAY IRRIGATION SYSTEM)
File No. PC
FINDINGS AND DECISION
AND ASSESSMENT
OF CIVIL PENALTY .
Acting pursuant to North Carolina General Statute (G.S.) 143-215.6A, I, Kerr T. S�t phans
Director of the Division of Water Quality (DWQ), of the North Carolina Department" of
Environment and Natural Resources, make the following:
I. FINDINGS OF FACT:
A. Finetex is an incorporated business organized and existing under the laws of the State
of North Carolina.
B. On April 20, 1998, DWQ issued Water Quality Permit No. WQ0001077 to Finetex
which allows the treatment and spray irrigation of industrial wastewater on two
permitted sites located in Rowan County, North Carolina.
C. On September 30, 1999, and October 1, 1999, DWQ staff from the Mooresville
Regional Office observed poor operating conditions at the wastewater treatment
facility and at the 6 acre spray irrigation field.
D. Said permit contains the following relevl nt conditions:
• Part I, Condition 6 states the by-pass of untreated wastewater of the treatment facilities
is prohibited. Bypass of equipment is considered a bypass of the treatment facilities.
• Part I, Condition 7.b states The following buffers shall be maintained: 150 feet between
wetted area and property lines. Runoff appeared to enter into the eastern property buffer
and hydrology indicators suggest that runoff has consistantly flowed off the spray filed
and into the buffer area.

Finetex
Findings and Decisions
Page 2
• Part II condition 1 states that the facilities should be maintained at all times. The facility
did not appear to be operated and maintained properly. The spray field was in poor
condition and many areas were barren of vegetation and/or inundated with standing
wastewater.
Part II condition 3 states that a suitable vegetative cover shall be maintained. Several
areas of the spray field were without suitable vegetative cover.
• Part H condition 4 states that irrigation shall not be performed during inclement weather
or when ground is in a condition that will cause runoff. Based on application records,
Finetex applied wastewater to the irrigation field during inclement weather on multiple
occasions.
• Part II condition 5 states that adequate measures shall be taken to prevent wastewater
runoff from the spray field.
• Part II condition 7 states that the application rate shall not exceed a cumulative loading
rate of 29.12 inches over any twelve month period or at an instananeous rate not to
exceed 0.25 inches per hour on the seven, 37,000 square foot spray irrigation sites.
• Part II condition 10 states that no traffic or equipment shall be allowed on the disposal
area except while installation occurs or while normal maintenance is being performed.
Tire ruts and other evidence of compaction were observed in several areas of the field.
• Part IV condition 2 states that the existing monitoring wells shall be sampled for Volatile
Organic Compounds (VOC) every November. The November 8, 1998 groundwater
quality sampling and analyses report submitted to the Division's Groundwater Section
did not contain the laboratory analytical results for the VOC analysis.
• Part V condition 2 states that the Penn ittee or his designee shall inspect the wastewater
treatment and disposal facilities to prevent malfunctions and deterioration; operator errors
and discharges which may cause or lead to the release of wastes to the environment.
While Finetex possesses a form documenting equipment repair activities, an inspection
log was not available.
E. A notice of Violation concerning the above mentioned violations was sent to Finetex
by DWQ's Mooresville Regional Office on October 25, 1999.
F. The cost to the State of the enforcement procedures in this matter totaled $690.79.

Finetex
Findings and Decisions
Page 3
Based upon the above Findings of Fact, I make the following:
H. CONCLUSIONS OF LAW:
A. Finetex is a "person" within the meaning of G.S.143-215.6A pursuant to G.S. 143-
212(4).
B. The disposal system cited in Findings of Fact B. above falls within the definition of
same at G.S. 143-213(10) or G.S. 143-213(17).
C. A permit is required for the disposal of wastewater pursuant to G.S. 143-215.1(a)(9)
and Part VI, Condition No. 4 of DWQ Permit No. WQ0001077.
D. Finetex violated G.S. 143-215. 1 (a)(9) and Part VI, Condition No. 4 of DWQ Permit
No. WQ0001077 by failing to properly operate and maintain a non -discharge spray
irrigation system.
E. Finetex may be assessed civil penalties in this matter pursuant to G.S. 143-
215.6A(a)(2), which provides that a civil penalty of not more than twenty five
thousand dollars per violation maybe assessed against a person who is required but
fails to apply for or to secure a permit required by G.S. 143-215.1(a)(9).
F. The State's enforcement costs in this matter may be assessed against Finetex pursuant
to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
G. The Director, Division of Water Quality, pursuant to delegation provided by G.S.
143- 15.6A(h), has the authority to assess civil penalties in this matter.
III. DECISION:
Accordingly, Finetex is hereby assessed a civil penalty of:
$ for failing to perform to permit standards as required by G.S.
143-215. 1 (a)(9) and Parts I.6 of DWQ Permit No. WQ0001077
for the spray irrigation treatment and disposal of wastewater by
bypassing a primary clarifier.

Finetex
Findings and Decisions
Page 4
for failing to 5erform to permit standar as required by G.S.
143-215.1(a)anTParts I.7.b of DWQ Permit No. WQ0001077
for the spray irrigation treatment and disposal of wastewater by
allowing irrigated wastewater to enter the 100 foot buffer
between the spray field and the property line.
for failing to perform to permit standards as required by G.S.
143-215. 1 (a)(9) and Part III of DWQ Permit No. WQ0001077
for the spray irrigation treatment and disposal of wastewater by
failing to maintain facilities.
$ for failing to perform to permit standards as required by G.S.
143-215. 1 (a)(9) and Part II.3 of DWQ Permit No. WQ0001077
for the spray irrigation treatment and disposal of wastewater by
failing to maintain a suitable vegetative cover.
$ for failing to perform to permit standards as required by G.S.
143-215. 1 (a)(9) and Parts II.4 of DWQ Permit No.
WQ0001077 for the spray irrigation treatment and disposal of
wastewater by applying to spray irrigation field during or
shortly after inclement weather events.
E19
for failing to perform to permit standards as required by G.S.
143-215.1(a)(9) and Parts II.5 of DWQ Permit No.
WQ0001077 for the spray irrigation treatment and disposal of
wastewater by allowing wastewater to runoff from the
application area.
for failing to perform to permit standards as required by G.S.
143-215. 1 (a)(9) and Part II.7 of DWQ Permit No. WQ0001077
for the spray irrigation treatment and disposal of wastewater by
operating pumping rates above the design rate of the system (as
described in the 1997 permit application).
$ for failing to perform to permit standards as required by G.S.
143-215. 1 (a)(9) and Part II.10 of DWQ Permit No.
WQ0001077 for the spray irrigation treatment and disposal of
wastewater by allowing soil impacting and rutting to occur in
the 'irrigation area.

Finetex
Findings and Decisions
Page 5
$ for of the six (6) failures to monitor as required by G.S. 143-
215. 1 (a)(9) and Part IV.2 of DWQ Permit No. WQ0001077 for
volatile organic compounds analysis in November 1999.
for failing to perform to permit standards as required by G.S.
143-215. 1 (a)(9) and Part V.2 of DWQ Permit No. WQ0001077
for the spray irrigation treatment and disposal of wastewater by
not keeping an adequate inspection log.
TOTAL CIVIL PENALTY, which is percent of the
maximum penalty authorized by G.S. 143-215.6A.
$ 690.79 Enforcement costs
$ TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
(Date) Kerr T. Stevens, Director
Division of Water Quality

Af•
State of North Carolina
Department of Environment
and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
William E. Holman, Secretary
Certified Mail
Return Receipt Requested
Finetex, Incorporated
Post Office Box 164
Spencer, North Carolina 28159
Attention: Mr. Emmett K. Atwood
Dear Mr. Atwood:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT ANo NATURAL RESOURCES
DIVISION OF WATER QUALITY
October 25, 1999
Subject: Notice of Violation and Recommendation for Enforcement
Permit No. WQ0001077 and NCGS 143-215.1
Finetex, Inc., 775 Hackett Street
Spencer, Rowan County
Finetex, Incorporated (Finetex) was issued Permit No. WQ0001077, effective April 20, 1998,
for the continued operation of a 18,000 GPD spray irrigation and disposal facility. Based upon site
visits conducted by personnel from this Office on September 30th and October 1st 1999, the Division has
reason to believe that you are responsible for activities resulting in noncompliance with North Carolina
Law and the subject Permit. In particular, the following violations of the existing permit conditions
were observed:
Violation of Permit Condition "I.1." — This Office's file does not contain a certification from
a professional engineer (PE) certifying that the drip field facility was installed in accordance with -the
permit, the approved plans and specifications. The facility did not appear to be constructed in
accordance with the application specifications. In particular, the wastewater distribution system in the
application was designed at a pump rate of 30 gpm, while 60 gpm pumps were installed at the facility.
In addition, some of the drip lines were placed on semi -impervious to impervious surfaces such as the
gravel driveway. You should be aware that Permit Condition "VI. 1." states, "The permit shall become
voidable unless the facilities are constructed in accordance with the conditions of this permit, the
approved plans and specifications, and other supporting data."
Violation of Permit Condition 4. — During the site visit on September 30th DWQ staff
observed that the clarifier, the flocculation tank and the polymer feed system were not in operation.
During a subsequent phone conversation, Mr. Atwood stated that the clarifier and flocculation
equipment were not utilized if the wastewater were to be disposed of through irrigation. The permit
was issued with the understanding that this equipment would be utilized in the treatment of the
wastewater prior to irrigation. Not operating this equipment is considered a bypass of the treatment
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

s.
Finetex. Inc. - NOV October 25 1999 Page 2 of 3
facilities and is prohibited by the permit. In addition, a small stream of cloudy wastewater was
observed flowing from an earthen berm located at the western corner of the aeration basins. The stream
flowed approximately 50 feet before infiltrating into the soil. Watermarks around the stream indicate
that the flow was greater prior to the site visit. Wastewater may be bypassing the treatment system
through holes or other imperfections in the earthen liner enclosing the aeration basins.
Violation of Permit Condition IT 7. b)" — During the September 30t' site visit, DWQ
personnel observed a mixture of stormwater and wastewater flowing off of the easternmost drip
irrigation field. The runoff appeared to enter into the eastern property buffer. Hydrology indicators in
the area, suggest that runoff has consistently flowed off of the drip field and into the buffer area.
Violation of Permit Condition "II. 1." - The facility did not appear to be operated and
maintained properly. The drip irrigation field was in poor condition. Many areas were barren of
vegetation and/or inundated with standing water. Several drip lines were observed to be overlapping
(should be 31 feet apart). The sample results of the treatment system effluent report wastewater
constituent concentrations in excess of the achievable limits specified in part "V. 14." of the July 1997
drip irrigation system application. In addition, the clarifier and flocculation units were not in operation.
Violation of Permit Condition I'll. 3." — Several areas within the drip irrigation fields were
without suitable vegetative cover.
Violation of Permit Condition I'll. 4." — Based on the application records submitted by
Finetex to this Office, Finetex has applied to the irrigation fields during inclement weather on multiple
occasions. From May through August 1999, Finetex applied to at least one irrigation field during 20 of
the 28 working days in which precipitation was reported. Mr. Atwood stated that the drip field had .
received wastewater during similar circumstances prior to this Office's September 30'' site visit. The
condition of the drip field observed during the September 30`h site visit was indicative of irrigation
during inclement weather.
Violation of Permit. Condition "II.5." — Runoff was observed on September 30'' from the
easternmost application field of the drip irrigation system.
Violation of Permit Condition I'll. 7." — Drip lines that are not separated by 31 feet or are
operated at pumping rates above the design rate of the drip irrigation system (as described in the 1997
application for the drip fields) may exceed the application rate of 0.25 inches per hour.
Comment regarding Permit Condition I'll. 10." — While equipment is allowed on the
application fields during maintenance activities, the permittee should be careful when operating the
equipment in order to avoid compaction of the soils that may retard and reduce the infiltration rates of
the soils in the application fields. Several tire ruts and -other evidence of compaction were observed in
the drip irrigation fields.
Violation of Permit Condition "IV. 2." — The November 1998 groundwater quality sampling
and analysis report submitted to the Division's Groundwater Section did not contain the laboratory
analytical results for the volatile organic compounds analysis.

Finetex Inc - NOV October 25 1999 Page 3 of 3
Violation of Permit Condition "V. 2." — The permittee does not appear to be adequately
inspecting the wastewater treatment facilities. While Finetex possessed a form documenting equipment
repair activities, an adequate inspection log was not available. Finetex should be inspecting the
irrigation fields as well as the equipment. Finetex should begin keeping an inspection log that at a
minimum includes: the date and time of inspections; any observations made (field wet, pools of water,
etc.); all maintenance activities (mowing, pipe moving, parts, etc.); and any additional corrective
actions. The logs must be maintained for three years.
At this time, this Office is considering recommending enforcement for the violations described
in this Notice. North Carolina General Statute (NCGS) 143-215.6A provides for a civil penalty
assessment of not more than twenty-five thousand dollars ($25,000) per violation, per day against any
person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to NCGS 143-215.1.
It is requested that you respond to this Notice in writing by November 5, 1999. Your response
should document any comments you may have regarding the violations cited in this Notice; any
corrective actions to prevent any similar conditions, and anticipated dates to complete the necessary
corrective actions. Your response will be considered prior to this Office's recommendation for
enforcement and will be included in any enforcement recommendation packages. You should not apply
to the new drip field until the PE certification for the as -built specifications has been forwarded to the
Division, the field has been rehabilitated, the Division has re -inspected the facilities, and the Division
has provided written authorization that you may resume irrigation to the field.
If you have any questions regarding this matter, please contact Mr. Charley Schwartz or me at
[phone].
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachments: October 12, 1999 MRO Staff Report for proposed Aeration Basin Expansion
April 20, 1998 Spray Irrigation Permit
cc: Non -Discharge Compliance & Enforcement Unit
Bob Cheek, Groundwater Section, Central Office
AMn-,Huffinan
hAFineEnf.doc
CMS

1
t State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Linda Diane Long, Regional Manager
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
DEHNR
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 24, 1995
Finetex, Inc.
Post Office Box 164
Spencer, North Carolina 28159
Attention: Anthony F. Bolton, Dept. Manager
RE: Notice of Violation of Permit Conditions
Permit N2 WQ0001077/GW93148
Rowan County, N.C.
Dear Mr. Bolton:
A review of the subject permit and your November 7, 1994
compliance monitoring data indicates that you are in violation of
the following permit conditions:
Permit Condition N° IV 2 by failing to analyze the sample
from MW-2 for total organic carbon (TOC); and
Permit Condition N4 IV 3 by failing, upon detection of.
volatile organic compounds (VOCs) in all three wells, to run
EPA Methods 604 and 611 to detect other organic compounds
which may be present.
You are requested to submit the required analysis for TOC
and VOC, as well as a clarification as to which method of
analysis is being used to measure VOC, within 60 days of receipt
of this letter or an.explanation of why you cannot comply. It
should be noted that the violations cited above and any
additional documented violations could result in the initiation
of an enforcement action by this Office in accordance with
General Statute 143.215.6A, which provides for a $10,000
assessment of civil penalties for each violation. Each day that
the violations continue may be considered a separate violation.
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

-,SENIDER: ..
'y • Complete items 1 and/or 2 for additional services..
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I also Wish to receive the
Print your name and address on the reverse of this form so that we can following Services (for an extra
d'letutl4this card to you. fee):
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Attach this form to the front of the mailpiece, or on the back
does not permit.
if space 1. ❑ Addressee's Address
tWrite "Return Receipt Requested" on the mailpiece below the article number.
` • The Return Receipt will show to whom the article was delivered 2 ❑Restricted Delivery
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and the date
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o 3. Article Addressed to:
Consult postmaster for fee.
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Finetex, Inc.
January 24, 1995
Page Two
Should you have any questions concerning this Notice,
contact Peggy Finley at [phone], ext. 235.
Sincerely,
. 1 h Overcas , P.E.
Re onal Supervisor
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh
MAF/sc

=;JAME§KB'2 HUNT JR
r.•
'..GE' R.. aV� es;
; ,BILY.�.HOLMAN"
DIRECTOR{
rye::
ORANDUM TO:
FROM:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
MOORESVILLE REGIONAL OFFICE
WATER QUALITY SECTION
May 22, 2000
Jeffrey Poupart
D. Rex Gleason
Ellen Huffman
Recommendation for Enforcement
Violation of NCGS 143-215.1
DWQ Permit No. WQ0001077
Finetex Incorporated
Non -Discharge Spray Facility
Rowan County, North Carolina
Attached is an enforcement recommendation report concerning a violation of the
)ject Permit and General Statute. Since this Office did not have a shell document from
ich to develop the attached Findings and Decision (F&D), a similar type F&D was modified
fit the specific violation. Such being the case, it may be appropriate to coordinate the
,iew of this recommendation with the Attorney General's Office. Additional supporting
aerial, including digital photographs on disks, are included with this enforcement
;ommendation request.
The violation for which this enforcement recommendation is being submitted is the
result of Finetex mis-management of the subject spray facility.
The attached material should be self-explanatory; however, if you have any questions,
please contact Mr. Parker or me.
Attachment
ebh
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919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 28115
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER SO% RECYCLED/10% POST -CONSUMER PAPER

Pagel
Summary
Finetex had submitted an application to expand existing aeration basins (lagoons) to
improve treatment efficiency of their existing facility. A site visit by Charley Schwartz.
(9/30/99) and follow up -site visit by Ellen Huffman and Charley Schwartz (10/l/99)
confirmed serious problems with the spray field (photos in file at MRO). The MRO staff -
report (attached) details the conditions and permit violations found at the facility. A NOV
was issued 10-25-99.
Chronology of Events/Correspondence
Timeline of events
Sept. 30, 1999 and October 1, 1999 - Site visits and initial investigation by Charley
Schwartz, Env. Engineer I, & Ellen Huffman, Env. Technician V, MRO
October 12, 1999 — Permit Staff Report and Recommendations sent to Raleigh.
October 25, 1999 - NOV and notice for Finetex to stop applying to (all zones of) field 2.
November 1999 - Finetex meets with DWQ (at MRO) regarding violations.
December 1999 — Finetex (via MacConnell and Assoc.) hires Tony C. Jacobs and
Associates to perform a soil and site evaluation.
December 28, 1999 — site visit at field #2 with Tony Jacobs. Recommendations
discussed. Site improvements started.
February 8, 2000 — meeting at Finetex. Attendees: Robert Scala, Vice President, Finetex;
Jack Heath, Plant Engineer, Finetex; Tony Bolton, Operations Manager, Finetex; Gary
MacConnell, MacConnell & Associates; Tony Jacobs, Soil Scientist, Jacobs & Associates,
Inc.; Ellen Huffinan, DENR-WQ, MRO. Review of Soil Evaluation by Tony Jacobs and site
rehabilitation recommendations was discussed. Field visit concludes that work was done to
repair and improve conditions at field #2. Rehabilitation activities included:
• Zone 3 of field #2 is taken out of service until rehabilitation plan completed
• Regrading and filling of depressions
• Reseeding program established
• Preparation of Standard Operating Procedures (SOP) manual for irrigation
procedures, including pre -irrigation checklist
• Removal of gravel driveway from zone 5

Page 2
March 15, 2000 — Meeting at Finetex. Discussion related to:
Permit status and memo for moving of electrical lines
Continued field improvements
Soil Scientist report complete
Review of SOP for spray application
CHECKLIST FOR PERMIT VIOLATIONS
1. A copy of the Permit is attached.
2. The violator is Finetex Incorporated.
Mr. Robert H. Scala, Vice -President
P.O. Box 164
Spencer, NC 28159
3. This enforcement does not include effluent limit violations. It involves a violation
of a Non -Discharge DWQ Permit conditions and N.C. General Statute 143-215.1.
4. Permit # WQ0001077
• Violation of permit condition "I.6"
• Violation of permit condition "I.7.b"
• Violation of permit condition "II.2"
• Violation of permit condition "II.3"
• Violation of permit condition "II.4"
• Violation of permit condition "II.5"
• Violation of permit condition "II.7"
• Violation of permit condition "II.10"
• Violation of permit condition "IV.2"
• Violation of permit condition "V.2"
4. Copies of all correspondence are attached.
5. There are no chain -of -custody .samples.
6. The violation is not due to a power failure or by-pass of any treatment facility.
7. Are violation(s) chronic and/or due to a single operational upset?
The violation is not considered to be chronic. The violation appears to be isolated.

Page 3
8. Were any specific notifications submitted concerning noncompliance?
A NOV/NRE was sent on October 25, 1999, which documented the Permit and
NCGS violation, and advised that an enforcement recommendation would be
prepared.
9. Cost of the investigation:
27 hours by Ellen Huffinan for investigation
and preparation of enforcement report at
$20.08/hour.=$542.16
1 hour by D. Rex Gleason for supervisory review
at $37.70/hour = 37.70
1 hour for clerical processing at $10.93/hour = 10.93
Administrative Cost for processing report = 100.00
Total $690.79
CIVIL PENALTY ASSESSMENT FACTORS FOR WATER QUALITY CASES
CASE NAME: Finetex
ASSESSMENT FACTORS:
A. CAUSE OF THE VIOLATION(S)
The violation is the result of Finetex poor operation of spray field 2
B. THE DEGREE AND EXTENT OF HARM CAUSED BY THE
VIOLATION(S)
There was no harm to the environment documented as a result of the poor operations
of spray field 2. There was runoff observed at the time of investigation and field had
evidence of over application in excessive amounts.
C. DURATION OF THE VIOLATIONS)
The violation occurred sometime on or after September 28, 1998 and ended on
October 1, 1999.
D. EFFECT OF VIOLATION(S) ON WATER, PUBLIC HEALTH AND FISH
OR WILDLIFE

There is no documented effect on water, public health, fish or wildlife as a result
of the violation
E. EFFECTIVENESS OF ANY PREVENTIVE OR RESPONSIVE MEASURE
TAKEN BY THE VIOLATOR
After receiving the NOV with notice to cease using field #2, Finetex immediately
suspended use of field #2 and hired McConnell and Associates to advise them on
repairing the problem. Jacobs Environmental was contracted to advise Finetex on
repair recommendations, re -calculate field loading capacities, and recommend
changes in operational proceedures and best management practices for the type of
spray system. There was no other responsive measures taken since there was no
evidence that a water quality violation or any other negative effect on the
environment had occurred.
F. COST OF RECTIFYING THE DAMAGE OR INFORMATION THAT
WOULD BE NEEDED TO DETERMINE THE COST, SUCH AS
PROCESS RATES, CLEAN UP COSTS
Finetex has responded quickly by repairing and improving field 2 to re -instate the
field into the existing spray treatment system.
G. THE ALLEGED VIOLATOR'S PREVIOUS RECORD OF COMPLIANCE
OR NONCOMPLIANCE
Finetex has not been assessed any other penalties for violations of their non -
discharge permit.
H. MITIGATING, AGGRAVATING FACTORS, IF ANY
It should be considered that Finetex, upon realization of the systems operational
failure, promptly hired the experience needed to completely re-evaluate the spray
system and repair field #2 to working condition as well as rewriting Standard
Operating Procedures and sending more personnel to State Certification training. In
addition, finetex plans to monitor the newly renovated system and continue to make
operational improvements as needed.

STATE OF NORTH CAROLINA
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROWAN
IN THE MATTER OF: )
FINETEX )
FOR VIOLATIONS OF PERMIT)
NO. WQ0001077 AND )
NCGS 143-215.1 )
FOR FAILING TO PROPERLY )
OPERATE AND MAINTAIN )
SPRAY IRRIGATION SYSTEM)
File No. PC
FINDINGS AND DECISION
AND ASSESSMENT
OF CIVIL PENALTY
Acting pursuant to North Carolina General Statute (G.S.) 143-215.6A, I, A. Preston
Howard, Jr., P.E., Director of the Division of Water Quality (DWQ), of the North
Carolina Department of Environment and Natural Resources, make the following:
I. FINDINGS OF FACT:
A. Finetex is an incorporated business organized and existing under the laws of the
State of North Carolina.
B. On April 20, 1998, DWQ issued Water Quality Permit No. WQ00031077 to
Finetex which allows the treatment and spray irrigation of industrial wastewater
on two permitted sites located in Rowan County, North Carolina.
C. On September 30, 1999, DWQ staff from the Mooresville Regional Office
observed poor operating conditions at the wastewater treatment facility and at the
6 acre drip/spray irrigation field.
D. Said permit contains the following relevant conditions:
Part I, Condition 6 states the by-pass of untreated wastewater of the treatment
facilities is prohibited. Bypass of equipment is considered a bypass of the treatment
facilities.
• Part I, Condition 7.b states The following buffers shall be maintained: 150 feet
between wetted area and property lines. Runoff appeared to enter into the eastern
property buffer and Hydrology indicators suggest that runoff has consistantly flowed
off the spray filed and into the buffer area.

• Part II condition 1 states that the facilities should be maintained at all times. The
facility did not appear to be operated and maintained properly. The Spray filed was
in poor condition and many areas were barren of vegetation and/or inundated with
standing wastewater.
• Part II condition 3 states that A suitable vegetative cover shall be maintained. Several
areas of the spray field were without suitable vegetative cover.
• Part II condition 4 states that Irrigation shall not be performed during inclement
weather or Owhen ground is in a condition that will cause runoff. Based on
application records, Finetex has applied to the irrigation fields during inclement
weather on multiple occasions.
• Part II condition 5 states that adequate measures shall be taken to prevent wastewater
runoff from the spray field.
• Part II condition 7 states that the application rate shall not exceed a cumulative
loading rate of 29.12 inches over any twelve month period at an instananeous rate not
to exceed 0.25 inches per hour on the 7, 37,000 square foot spray irrigation sites.
• Part II condition 10 states No traffic or equipment shall be allowed on the disposal
area except while installization occurs or while normal maintenance is being
performed. Tire ruts and other evidence of compaction were observed inseveral areas
of the field.
• Part IV condition 2 states that the existing monitoring wells shall be sampled for
Volatile Organic Compounds (VOC) every November. The November 8, 1998
groundwater quality sampling and analyses report submitted to the Divisions
Groundwater Section did not contain the laboratory analytical results for the VOC
analysis.
• Part V condition 2 states that the Permittee or his designee shall inspect the
wastewater treatment and disposal facilities to prevent malfunctions and
deterioration, operator errors and discharges which may cause or lead to the release
of wastes to the environment. While Finetex posses a form documenting equipment
repair activities, an adequate inspection log was not available.
E. A notice of Violation concerning the above mentioned violations was sent to
Finetex by DWQ's Mooresville Regional Office on October 25, 1999.
F. The cost to the State of the enforcement procedures in this matter totaled $690.79.

Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Finetex is a "person" within the meaning of G.S.143-215.6A pursuant to G.S.
143-212(4).
B. The disposal system cited in Findings of Fact B. above falls within the definition
of same at G.S. 143-213(10) or G.S. 143-213(17).
C. A permit is required for the disposal of wastewater pursuant to G.S. 143-
215. 1 (a)(9) and Part VI, Condition No. 4 of DWQ Permit No. WQ0001077.
D. Finetex violated G.S. 143 -215. 1 (a)(9) and Part VI, Condition No. 4 of DWQ
Permit No. WQ0001077 by failing to properly operate and maintain a non -
discharge spray irrigation system.
E. Finetex may be assessed civil penalties in this matter pursuant to G.S. 143-
215.6A(a)(2), which provides that a civil penalty of not more than ten thousand
dollars per violation may be assessed against a person who is required but fails to
apply for or to secure a permit required by G.S. 143-215.1(a)(9).
F. The State's enforcement costs in this matter may be assessed against Finetex
pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
G. The Director, Division of Water Quality, pursuant to delegation provided for by
G.S. 143- 15.6A(h), has the authority to assess civil penalties in this matter.
III. DECISION:
Accordingly, Finetex is hereby assessed a civil penalty of:
$ for failing to perform to permit stipards as required by
G.S. 143-215. 1 (a)(9) and Parts I,II,IV,V,VI, of DWQ
Permit No. WQ0001077 for the spray irrigation treatment
and disposal of wastewater.
TOTAL CIVIL PENALTY, which is percent of
the maximum penalty authorized by G.S. 143-215.6A.
$ 690.79 Enforcement costs
$ TOTAL AMOUNT DUE

As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.143B-282.I(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory
authority; and
(8) The cost to the State of the enforcement procedures.
(Date) Kerr Stevens, Director
Division of Water Quality

Fintex
Subject: Fintex
Date: Tue, 21 Dec 1999 10:12:55 -0500
From: Barbara Christian <[e-mail]>
Organization: NC DENR - Mooresville Regional Office
To: "Peggy.Finley" <[e-mail]>
Hi Peggy,
I just got a phone report from Jack Heath at Fintex that their
upgradient MW results show chloroform at 4 ug/l. They'll send in the
results. Jack's number is [phone], but you don't need to call.
be
Barbara Christian <[e-mail]>
NC DENR - Mooresville
Div. of Water Quality - Ground Water Section
1 of 1 12/21/99 10:23 AM

+ HOV 22 199 09:50PM FIHTEX LAB
Finetex Inc.
Date _I — 22 -9 2
Number of pages including cover sheet
To:
Phone
Fix Phono
CC:
d
From;
P.1
PO ®tax 164
Spenser, NO 28189
Kirby Atwood
Phone 704633 - 8028
Fax Phon® 704 637 - 9112

f �NOV 22 ' 99 09 : 51PM FINTEX LAIC 8476236406 P • 2
. iy _ 02
Ellen Huffman - November 22, 1999
NCDENR Division of Water Quality`
Mooresville Regional Office
919 N. Main Street
Mooresville, NC 281.15
Dear Ellen.
Enclosed are attachments_frorn our Plaints Engineer, Mr. Jack Heath, and our
Compliance Coordinator, Mr- 'TJxbY Atwood, These attachments sum
anariae our
activities -since receiving the NOV :dated 10/25/99. `Mr. Heath and 1�Tr, mriz Atwood
rcpra Ont near in house Specialists and have 'SRrilmarized our continuing efforts to
upgrade irrigation Field #2,
While .we feel we are in full Compliance the NOV, we are iwith our pexmlt and respectfully disagree waxh
nterested iu continuing .to upgrade all our operations where ever
possible. To"this end we extend this.sumtrnary update letter $s an invitation to ve
your staff TO inspect our facilities:at the earliest possible time. Y and
-sincerel
6,6 ''L
Bob "Scala
Vice President
Ir INC, pQ UM 81G.-nLV1wr1Rn PAM nW JERMi17402 ;01) zg7-4M F%Z, (M1) 79t.M58
EU NE• 164, SPENOM.1yoRT ! CAROLMA 88188 _tom -M FAX, i704MM746

NOV 22 '99 03:51PM FINTEY, LAB P.3
To: Ellin Huffman November 22,1999
NCDENR Division of Water Quality
.Mooresville Rwgioznal Ojfce
From: Jack Heath
Kirby Atwood
Finetex Inc.
PO Box 164
Speilcer, NC 28159
Subject: Fdllow Up Response to October 25tb NOV
Effen,
We are sending this letter as a f011Ow W to our November 3rd response to the
October 25th NOV,
We believe that we were operating within the conditions of our permit prior to
and after -your October 1 visit. Your visit has resulted in additional improvements being
made to the sprayfields and their operations, Herc are the changes that have taken place.
• Sprayfields 1, 2, 4, and 5 have had holes and depressions filled in where water could m P,vU'�
collect. We used 4 loads of top soil for the 4.aeres involved.
• B'escue and rye grass seed has been applied to all five s ra telds to augment the tree A-
;
P Yf �� �'�
vegetative cover.
• Sprayfield 3 (eastern most sprayffeld) has been taken out of service, 'This sprayfield
is downgrade from the other four sprayfields. Stonnwater rumoff causes additional
A ?=r�r � D hydraulic joading,
The gr$vel area on the sprayfieid has been relocated to a more appropriate location.
• Wastewater operations have beau changed to prevent septic conditions in the 20,000
gallon. storagetank on the sprayfields. Wastewater will be transferred in the morning
and discharged the same day prier to septic conditions taking place,
+� Wastewater opexator has been instructed to rake the field. as needed following �_ ,�? .".. 4`
WA stewater application to assist in the percolation process and prevent surface _ k ` `r" r"
.:%
slanrliing.
Daily maintenance log has been expanded to include additional information.
6 MacConnell and Associate performed and independent'audit of.the -facility.to assist
Finctex in ways to improve the wastewater operation.and facilities.
FINE= INC., P O BOX 216, ELY=OD PARIC, ;GW 1ER= 07407 [phone] FAX: (201) .797-6558
P.Q BOX 194, SPENCER, NORTH CMOLINA 28,89 (704) 63H028 FAX [phone]

i' , ~" NOV 22 '99 03:51PM FINTEX LAB
P.4
We continue to improve our wastewater facilities and operations to discharge the
best quality of wastewater, Here are the planned improvements to be made at Finetex to
improve our wastewater duality.
• Expansion of the aeration basins to reduce BOD and TSS levels, (Application
pending)
• :Annual application of rye grass seed will be done -each fall to give additional
vegetative cover to the sprayfields duriag the winter months.
• An annual audit will be done by MaeConnell and Associates at our wastewater
facilities to look for ways to improve operations, technology, and maintain fullest
compliance.
+ S a e pr yfi ld operator will continue to have dirt and seed.available to address small low
areas that might create a water collection area.
• NOW:* hose will be added to the discharge lines to help maxiuuze distribution of
the wastewater and prevent surface
skinning by utilizing greater surface area of the
sprayfield.
• Sprayfield 5 will be installed using the materials from sprayfield 3, 6 is located in a
better application area, with more forest for vegetative cover,
The "npravements.made will increase the quality our wastewater and improve the
operations of our faoilities. We would Appreciate the opportunity to show you these
changes in.a-follow up inspection.
T you, ,
k-Ieath,'Plant Engineer
ce: Roger Porter
Bob :Scala
Tony,Bolton
M$'I'SX INC., P-0. BOX 216, ELMWOOD PARK, NEW
Klrb twood, Compliance Coordinator
07407 (201) 707 46$ F
RU BOX 164, SPENCER, NORTH X: CAROLINA28.159 C704) 633-8028 .FA(04) 6 3(3046787-6658

�NOV 22 ' 99 q3: 51PM FINTEX C42( 8476236406 P. 2 P - 02
Ellen Huffman
NCI)BNR Division of Water. Quality .
Mooresville Regional office
919 N. Main Street
Mooresville, NC 28115
Bear Ellen,
November 22, 1999
Enclosed are attachmeats fro n our Plants Engineer, Mr..paak Reath, and our
Cornpli moe Coordinator, Mr. Kirby Atwood. Theca attachments summarize
activities since receiving the NOV did 10/25/99. mr. Heath and � �wo twoo our
represent our in house Specialists and Dave summarized our continuing to
Upgrade Irrigation Field #2,
While -we feel we are in fu11 compliance with our permit and respectfully disagree Wit.':
the NOV, we are interested itt cOntinuin to upgrade pgrade all our uperatlons where ever - t
possible, To this end we extend this summary update letter as an invitation to ou and '
your scoff to inspect our facilities at the earliest possible time. Y
Sincerel
AV6- t~e
Bob Scala
VIM President
r INS, PQ, 11OX21s, SLMWOOD PAW NEW jMET07401
AX
P-OL BOX 184, WX'VQPR. NO OLDIA 20168 (741) W29 FAX' 4) 746 �M58

NOV 22 '99 03:51PM FINTEX LAB
P.3
To: Ellen Huffinan November 22, 1999
NCDENR Division of Water Quality
Mooresville Regional Office
From: Tack Meath
Kirby Atwood
Finetex Inc.
PO Box 164
spencer, NC 28159
Subject: Follow CJp Response to October 25th NOV
,Ellen,
We Are sending this letter as a follow up to our November 3rd response to the
October 25th NOV,
We believe that we were operating within the conditions Of our permit prior to
and after your October I visit. your visit has resulted in additional iiliprovements being
made to the sprayfields and their operations. Dery are the 011allges that have taken place.
• Sprayfleids 1, 2, 4, and. 5 have had holes and depressions filled in where water could
collect. We used 4 loads Of top soil for the 4 acres involved.
• Fescue and rye grass seed has been applied to all five sprayfields to augment the tree
vegetative cover.
® Sprayfield 3 (eastern most sprayfield) has been taken out of service, This sprayfield
is downgrade froin the other four sprayfields. Stcrnmwat©r runoff causes additional
hydraulic; loading,
• The gravel area on the sprayfield has been relocated to it more appropriato location.
Wastewater operations have been changed to prevent septic conditions in the 20,000
gallon. storage tank on the sprayfields. Wastewater will be transferred in the morning
rggand discharged the he same day prior to septic conditions taking place,
"'WU.k ��F>•7419�'�'9V-ti:aA.a.u.a.6.... 4•._.....9. _ _ _ _ —__-_ _
�v��dw��e�;r•app��tC�tttorl'to-�,s�st=izi=tl2e-.per�dlatibia_pi�d��s.at�plpr.��i�i�,t-saii��,ee `"�
Daily maintenance log has been expanded to include additional information.
• MacConnell and Associate performed and independent audit of the facility to assist Finctex in ways to improve the wastcwatcr operation and facilities.
FINETEX INC., P.O BOX 216, ELMWOOD p. c, NE 1�t�� 07407 (201) 7e7-4686 X:
[phone]
I't.� FAX; BOX 164, SPENCER,1Vd�1i' H CARQIjNA 28189 (704) 63"028 FAX [phone]

NOV 22 '99 03:51PM FINTEX LAB
P.4
We continue to improve our wast0water facilities and Operations to discharge the
best qual ty of wastewater, Isere are the planned improvements to be made at �'inetex to
improve Our wastewater quality.
• Expansion Of the aeration basins to .reduce 134D and TSS levels, (Application
pending)
Annual application of rye grass seed will be done each fall to give additional
vegetative cover to the sprayfields during the winter months.
• An annual audit will be done by MacConnell and Associates at our wastewater
facilities to look .for ways to improve operations, technology, and maintain fullest
compliance.
• Sprayfield Operator will continue to have dirt and sced available to address small low
areas that might create a water collection area.
• New flex hose will be added to the discharge lines to help Maximize distribution of
the wastewater and prevent surface skinning by utilizing greater surface area Oi'the
sprayfield.
• Sprayfield 6 will be installed using the materials from sprayfield 3, .6 is located in a
better application area with more forest for vegetative cover.
The inmpravetnents made will increase the quality our wastewater and improve the
operations of oUr facilities. WO would appreciate the opportunity to show you these changes in a follow up inspection.
T You,'
ck Heath, Plant Engineer
cc: roger porter
Bob Scala
Tony, Dolton
irb twood, Compliance Coordinator
FINETEX INC., P.O. BOX 216, ELMWOOD PARK, NEW JERSEY 07407 (20:1) 797-4686 FAX: (a01 797-
P,U BOX 164, SPENkaraM AUNTu COpT) ;GS;
ma
as 169 [phone] M: (Y04)

FINETEX, INC.
RESPONSE TO N.O.V.
November 3, 1999

State of North Carolina
Department of Environment
and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
William E. Holman, Secretary
Certified Mail
Return Receipt Requested
Finetex, Incorporated
Post Office Box 164
Spencer, North Carolina 28159
Attention: Mr. Emmett K. Atwood
Dear Mr. Atwood:
NCDENR
NORTH CAROUNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
October 25, 1999
Subject: Notice of Violation and Recommendation for Enforcement
Permit No. WQ0001077 and NCGS 143-215.1
Finetex, Inc., 775 Hackett Street
Spencer, Rowan County
Finetex, Incorporated (Finetex) was issued Permit No. WQ0001077, effective April 20, 1998,
for the continued operation of a 18,000 GPD spray irrigation and disposal facility.. Based upon site _
visits conducted by personnel from this Office on September 30`h and October Is' 1999, the Division has
reason to believe that you are responsible for activities resulting in noncompliance with North Carolina
Law and the subject Permit. In particular, the following violations of the existing permit conditions
were observed:
Violation of Permit Condition "I. I." — This Office's file does not contain a certification from
a professional engineer (PE) certifying that the drip field facility was installed in accordance with the
permit, the approved plans and specifications. The facility did not appear to be constructed in
accordance with the application specifications. In particular, the wastewater distribution system in the
application was designed at a pump rate of 30 gpm, while 60 gpm pumps were installed at the facility.
In addition, some of the drip lines were placed on semi -impervious to impervious surfaces such as the
gravel driveway. You should be aware that Permit Condition "VI. L" states, "The permit shall become
voidable unless the facilities are constructed in accordance with the conditions of this permit, the
approved plans and specifications, and other supporting data."
Violation of Permit Condition "I.6." — During the site visit on September 30th DWQ staff
observed that the clarifier, the flocculation tank and the polymer feed system were not in operation.
During a subsequent phone conversation, Mr. Atwood stated that the clarifier and flocculation
equipment were not utilized if the wastewater were to be disposed of through irrigation. The permit
was issued with the understanding that this equipment would be utilized in the treatment of the
wastewater prior to irrigation. Not operating this equipment is considered a bypass of the treatment
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

Finetex Inc - NOV October 25 1999 Page 2 of 3
.`� facilities and is prohibited by the permit. In addition, a small stream of cloudy wastewater was
observed flowing from an earthen berm located at the western corner of the aeration basins. The stream
flowed approximately 50 feet before infiltrating into the soil. Watermarks around the stream indicate
_ - that the flow was greater prior to the site visit. Wastewater may be bypassing the treatment system
through holes or other imperfections in the earthen liner enclosing the aeration basins.
Violation of Permit Condition "I.7. b)" - During the September 30`h site visit, DWQ
personnel observed a mixture of stormwater and wastewater flowing off of the easternmost drip
irrigation field. The runoff appeared to enter into the eastern property buffer. Hydrology indicators in
the area, suggest that runoff has consistently flowed off of the drip field and into the buffer area.
Violation of Permit Condition "II. L" - The facility did riot appear to be operated and
maintained properly. The drip irrigation field was in poor condition. Many areas were barren of
vegetation and/or inundated with standing water. Several drip lines were observed to be overlapping
(should be 31 feet apart). The sample results of the treatment system effluent report wastewater
constituent concentrations in excess of the achievable limits specified in part 'IV. 14. " of the July 1997
drip irrigation system application. In addition, the clarifier and flocculation units were not in operation.
Violation of Permit Condition "II.3." - Several areas within the drip irrigation fields were
without suitable vegetative cover.
Violation of Permit Condition I'll. 4." - Based on the application records.submitted by
Finetex to this Office, Finetex has applied to the irrigation fields during inclement weather on multiple
occasions. From May through August 1999, Finetex applied to at least one irrigation field during 20 of
the 28 working days in which precipitation was reported. Mr. Atwood stated that the drip field had
received wastewater during similar circumstances prior to this Office's September 3&- site visit. The -
condition of the drip field observed during the September 30'' site visit was indicative of irrigation
during inclement weather.
Violation of Permit Condition "II.S." - Runoff was observed on September 30t' from the
easternmost application field of the drip irrigation system.
Violation of Permit Condition "U. 7." - Drip lines that are not separated by 31 feet or are
operated at pumping rates above the design rate of the drip irrigation system (as described in the 1997
application for the drip fields) may exceed the application rate of 0.25 inches per hour.
Comment regarding Permit Condition "II.10." - While equipment is allowed on the
application fields during maintenance activities, the permittee should be careful when operating the
equipment in order to avoid compaction of the soils that may retard and reduce the infiltration rates of
the soils in the application fields. Several tire ruts and other evidence of compaction were observed in
the drip irrigation fields.
Violation of Permit Condition "IV. 2 " - The November 1998 groundwater quality sampling
and analysis report submitted to the Division's Groundwater Section did not contain the laboratory
analytical results for the volatile organic compounds analysis.

A
Finetex, Inc. - NOV October 25, 1999 Page 3 of 3
Violation of Permit Condition "V. 2." — The permittee does not appear to be adequately
inspecting the wastewater treatment facilities. While Finetex possessed a form documenting equipment
repair activities, an adequate inspection log was not available. Finetex should be inspecting the
irrigation fields as well as the equipment. Finetex should begin keeping an inspection log that at a
minimum includes: the date and time of inspections; any observations made (field wet, pools of water,
etc.); all maintenance activities (mowing, pipe moving, parts, etc.); and any additional corrective
actions. The logs must be maintained for three years.
At this time, this Office is considering recommending enforcement for the violations described
in this Notice. North Carolina General Statute (NCGS) 143-215.6A provides for a civil penalty
assessment of not more than twenty-five thousand dollars ($25,000) per violation, per day against any
person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to NCGS 143-215.1.
It is requested that you respond to this Notice in writing by November 5, 1999. Your response
should document any comments you may have regarding the violations cited in this Notice, any
corrective actions to prevent any similar conditions, and:anticipated dates to complete the necessary
corrective actions. Your response will be considered prior to this Office's recommendation for
enforcement and will be included in any enforcement recommendation packages. You should not apply
to the new drip field until the PE certification for the as -built specifications has been forwarded to the
Division, the field has been rehabilitated, the Division has re -inspected the facilities, and the Division
has provided written authorization that you may resume irrigation to the field.
If you have any questions regarding this matter, please contact Mr. Charley Schwartz or me at
[phone]. _
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachments: October 12, 1999 MRO Staff Report for proposed Aeration Basin Expansion
April 20, 1998 Spray Irrigation Permit
cc: Non -Discharge Compliance & Enforcement Unit
Bob Cheek, Groundwater Section, Central Office
Ellen Huffman
hAFineEnf.doc
CMS

November 3, 1999
To: Rex Gleason
Water Quality Regional Supervisor
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
From: Bob Scala
Finetex, Inc.
P.O. Box 164
Spencer, NC 28159
[phone]
Subject: Response to Notice of Violation dated October 25, 1999.
Dear Mr. Rex Gleason,
_ This letter responds to the Notice of Violation dated October 25, 1999 (the "NOV"). I note that Finetex
had previously applied to the Division of Water Quality ("DWQ") for a modification to Permit No.
WQ0001077 to expand its two aeration basins. The September 30 inspection was conducted in response
to this application for modification.
Finetex, in continuous operation since 1949, operates our key manufacturing facility in North
Carolina. Our recent Spencer employment taps into the North Carolina Piedmont region and
while modest, provides about 40 high paying jobs. We remain committed to good relations
with our employees, customers, and all Regulatory Agencies. This includes full compliance
with State Permits and Regulations. We take the 10/25/99 Notice of Violation very seriously.
MMARY RESPONSE
Finetex has three outlets for its trlefe ste ater: Irrigation Field #1 (in operation since 1976),
Irrigation Field #2 (in operation since and for the extended rain events, the City of Spencer. The
clarifier and its related systems are used for pretreatmen prior to discharge into Silencer's WWTP.
These systems have been designed and constructed with the knowledge of the DWQ to allow Finetex's
growth and to ascertain compliance under all conditions. The systems are operated according to permit
terms and DWQ regulations.
The NOV has several factual errors. The as -built certification from our professional engineer was
u mitted n or about May 19, 1998 (See enclosed copy of certification by Gary R. MacConnell, P.E.
dated May 19, 1998). Finetex does not apply residual wastewater during precipitation events (See
mtiJ ONth 5r" ` NOT iN VFPCE PL5 `
FINETEX INC., P.O. BOX 216, ELMWOOD PARK, NEW JERSEY 07407 [phone] FAX: [phone]
P.O. BOX 164, SPENCER, NORTH CAROLINA 28159 [phone] FAX: [phone]

TNIS ul°LA�t lNt, r�I
Finetex Inc. 11/3/99 P
g• 2 (of 5 )
enclosed affidavit from Kirby Atwood). The November 1998 groundwater analysis was performed and
_ submitted by letter dated December 30, 1998, from Kirby Atwood to the Groundwater Section of the
Division of Water Quality in Raleigh (See enclosed December 30, 1998, letter and supporting data
SI I, cE���� ��na
sheets). � pz� rF
wsrr
In addition to the factual errors, the NOV failed to acknowledge that significant precipitation ev is
�)
documented in our DMR for September, had occurred immediately prior to the inspection. We believe
that some of the observations have been erroneously attributed to runoff of wastewater, when in fact the
runoff was entirely storm water. 4—m5 • IWIJoTO SI(,N WiMviT iN 21s60DS 'ro Pik ONGS rFrv(t�� inFJ2adPrb'�t
7MT ?1V)'DFf: whl `�FNng&tY'. srGRi`f wkTF�
Irrigation field #2 was constructed (1997) in a young forest with flexible distri -rff i�gtlIT kfticoor
proper maintenance and best field utilization. Construction tree removal and t, t°R TI+E uR rtfo
ground level sunlight negatively impact the grass vegetative cover. Substantia. Files bcsI6� ck evLoo,,j Ide
since State certification inspection with continued improvement tf cm Nn Il. ` To NsVl$� %, �, oc o �tY
5viTN6tE fop (-h ,61S r wc— IN is
The independent engineer's assessment of Finetex's wastewater treatment and ; �c RFSvus 6F 4E5(U v
pertinent affidavit are attached and presented as part of our response. C�tCVlik Ij ruDIMM A
ADDInorhv Dr51,,p ChtCs
DETAILED RESPONSE akc vN "th,
Violation of Permit Condition "I.1."
- The Professional Engineer's Certification certifying the irrigation field installation was sent to Randy
Kepler of the DWQ Non -Discharge Permitting department. It was mailed in May 1998 by Gary
MacConnell P.E. of MacConnell and Associates. A copy of the Certification is attached. A separate
copy was recently mailed to Mr. Schwartz at the Mooresville office.
The pumps were not changed. Pump curves show that 30 GPM pumps will discharge 60 GPM at our
field pressure conditions. Original construction included meters to control total discharge. The meters ri"Ur
automatically stop flow to each field to provide accurate measurement resulting in full compliance with "l
(�rq� State loading limitations. The pump change was noted during certification State inspection prior to Ft(,j �rf-
I pv- Ai
service and th totai-discharge remains in accordance to permit regulations— ^� "�, ` v0
Gravel irrigation lmeas are no longer ine areas use. We believe percolation does existin graveled surfaces
LIDVJ;�
jA receiving the NOV, discontinued its use. Other acceptable adjacent distrib
available. ar
F Co�RSF T�t�
Finetex has reason to believe we constructed and operated in accordance to the permit. 71WJ6S WcouK sk`
`V���t �ZNE
to fti BV* FAIT 45� � UF_ NOT RArP_ IS ,K't kJYe'
Violation of Permit Condition 11I.6."
- Non operation of clarifier, flocculation and polymer systems: Irrigation Field #1 has been in service
since 1975 and since 1982 under permit #3600-R. The clarifier, flocculant and polymer systems were
constructed in 1994 as pretreatment for discharge to the City of Spencer during significant precipitation
L�r events or period f extended wet irrigation fields allowing greater flexibility. Spray field #2 was
constructed in 1997 nd allowed for multiple irrigation locations and increased capacity. Pre -treating
the waste throu h ari icafion, occu ation and polymer feed for irrigation field application we feel is
inordinate)relative to the use of irrigation fields.
y
wtCNou—% sNtS GGTvtPItiENT oN-uNF TK} Is UTTt� p1£C(AHISr1
io Rrs�pvr_ 5vsP6N�Ffl SOLADS. 015T-091 ( 5AMPLE5 5gow '�t►i
t-ttb(-1 -TS5 (CvV,-°5. 5005 wiLt I)J I Ctoc
5Pf MC' tN Soit y '����eE INr(t.h2�1(o�l t-kT -
{♦t61FEi�'1SS LFvr 5 nfi G1�JtC'Kf- TG1lF W U06 5010. �SSF101h(
To t�i U•IC�'r55 v> �, ors ft%[00 k5 Posst$CF FoI�1 Frrtti Ai'�i►!

tip I9(30 -TLa- D juJ� �- C� SMhU 1-a SHayEL 5eoor too« 09StKvFp co( f
t1,jyF "( p D'-FfN v,5,FAtFD kmiz tojl VI51r
o,,,, LoNb AJWinetex, Inc. 11/3/99 Pg. 3 (of 5)
i f�; 1�"�5 w�J NV� �N•t�� `t
- There is_small seepage of wastewater from the aeration pond. We are well aware of the seepage and
monitor it The seepage is intermittent, dependent on aeration basin operations and varies between zero
and 5 gallons per hour. It originates on the side of our western basin and seeps down slope. At low
seepage rate, the seepage evaporates leavin water -marks. At the seepage rate of about 5 GPH, it travels
approximately 6 f et were it is collected in and du . It is then returned to the aeration basin
with a small u p purr', To our knowledge, no untreated wastewater has left our property from this
source. We desire to address this concern properly and plan to- act accordingly when the basin is empty
during aeration basin expansion. The application for modification of the permit to allow the expansion of
the aeration basin is intended to address this issue, so it is somewhat ironic that we were cited for
violation as a result.
Finetex believes that no diversion or bypass has occurred. Finetex believes that the permitted equipment
is being properly operated as envisioned at the time of issuance of Permit No. WQ00010077.
Violation of Permit Condition "I.7.b"
Sto a and waste water draining off the irrigation fields: The Finetex facility experience a one
a[�« inch rain event"Sept. 28th. Early the morning of Sept. 30th we experienced a second heavy rain event.
r Copies of the September Non Discharge Waste Water Monitoring Report are attached. Typically, either
such event alone can generate appreciable storm water runoff. As part of the inspection Mr. Charley
Schwartz of DWQ and Mr. Kirby Atwood of Finetex together walked the entire perimeter of the
irrigation fields 'There was no standing or flowing water in the_buffer areas. inetex believes the heavy
rain events may have caused the "hydrology indicators" and possibly give the appearance of flow from
the irrigation field. Finetex has reason to believe wastewater did not enter the buffer areas. To further
alleviate chances of water leaving the irrigation area, additional rye seed has been applied to the soil for
further improved absorption and to retard storm water flow.
Finetex believes rain event runoff caused "hydrology,, indicators" and waste water did not penetrate
�gt- k Wh5 �Zv RAW—, FCA(,6GD So Nor- CPMAIN ,-d-c"W
buffer zones. RvN�rF , _ Akejr wA5 EAST G DPW UY95 't D of
THICK wooD v��a,7Arlo,v — cc�t+� roN► tRn corro,� cr— �.vvrr
Violation of Permit Condition "II.1." d BvFFJ�R oIRIrvL suasE�z� r vr5rr-9t1NeFF WAS uC% Rj}/y/ °`'}7f�
- The irrigation lines (hoses) are flexible for the purpose of moving to maximize distribution within their
operating zone. They are also moved for maintenance purposes (mowing) but may overlap until
replaced (approximately 31 feet apart) prior to subsequent irrigation.
- Primary vegetative cover is forest with work ways between the trees for inspection and movement of
the irrigation drip lines. As a new irrigation field, grass grows poorly with limited sunlight beneath
established trees. Over the course of 2 years, young vegetative cover has improved since original State
inspection and we continue to work establishing improved grass vegetative cover between trees.
`Standing water observed was caused by the rain events of Sept. 28th and early morning of the 30th.
- Waste water constituent concentrations: Finetex produces waste that is fully biologically degradable.
Constituent concentrations will improve when the expanded aeration basins are complete. Finetex has
applied to the State for aeration basin expansion. �I�� te�e�toWE tF (cLw tt FUe.-T"K +Toom W 5rkv10h,
- Clarifier, flocculation and polymer system function is reported in our response to Violation of Permit
Condition "I.6." detailed above.
Finetex believes we have operated the systems in accordance to permit conditions.

Finetex Inc. 11/3/99 Pg. 4 (of 5)
Violation of Permit Condition "II.3."
- Suitable vegetative cover: forest is our primary vegetative cover. Grass is grown to assist water
consumption in areas that sunlight permits. Original 1997 construction left the field with significant
heavy equipment (bulldozer) ruts and areas void of vegetative cover. Ruts have been restored and
vegetative cover between trees improved. We continue to cultivate new grass and continue to make
significant progress in the low light conditions among the trees. Additional rye grass seed has recently
been applied.
Finetex believes we have operated in accordance to permit conditions and continues efforts to establish
secondary grass vegetative cover beneath the trees.
7 5 w►� i
Violation of Permit Condition " II.4." L�� ��55t(��u�TA
- Records do reflect days of both rain events and irrigation. Existing DMR forms do not allow forgo DAi
morning and afternoon record entries for either rain events or irrigation resulting in the potential q `1k' f I
LID L9
appearance of coinciding irrigation and rain events when in fact the two may have been separate. It isotr:t��°�
possible, for example, to irrigate in the morning and experience an afternoon rain event. It is also LOG o
possible to experience a light rain event and subsequently irrigate when no standing water is present.
Su i occurrence might be interpreted as non-compliance when in fact it reflects limitations of the
currently required DMR form.
- We do not at anytime irrigate during rain events. Irrigation after a light rain does occur but only after
verifying the absence of standing water.
Finetex does not irrigate during a rain event nor after a rain event when standing water is present and has
reasons to believe we operate in accordance to Permit regulations.
Tyr
Violation of Permit Condition "II.S." a� �\) tR�u� `t� 0 `DDt-� _( `Key`( �(P-�I fWUNTO -AIM QEi IP" ci
�or�DD cv-SIrE .�- w�a �+-vSHb� aF� DUr?►Ny `r3o QAI�
- Finetex did not irrigate any forested irrigation fields Sept. 30th. Observed runoff was from rain events.
Finetex believes we have operated the irrigation system in accordance to permit regulations.
Violation of Permit Condition "II.7."
- The irrigation lines are flexible and moved for mowing maintenance. The lines are returned to correct
orientation within their zone prior to subsequent irrigation. Irrigation flow rate is metered. The
application rate of .25 inches has not been exceeded.
Finetex has reason to believe we have not exceeded the permit limitation of .25 inches and operate in
accordance to the Permit.
Comment regarding Permit Condition "II.10."
- Mowing equipment is used for vegetation maintenance. Supplies of dirt are obtainable to repair any tire�
ruts from mowing maintenance. 5tmftl t(ACINL�tRT otj Uts t5 Afj tcgevN 'rz tthctNc hikr op 5!1uFr-NF-m( -wMitf
jqE, F(Lk WZT (5 PsRijF1)9Le 'WE u)uWtY1NG SO(L MAY PTHAW tNP£L'MfW6tF - 111'Y
NDD[tloN�,- KT S00ULD �;E T[CLED (Wo Tf}E- PVT5 To J?zw VP Apy comphfteb stir
Violation of Permit Condition 11IV.2."
- The referred to analysis was performed for the November 1998 sampling period and was reported.
Finetex's Mr. Kirby Atwood phoned Linda Love of the Mooresville Regional Office to report two
detectable results during VOC sampling. Styrene was detected in two monitoring well samples. Finetex
`v[et�itot' �DpEQ vi=o� coNj�t��-t1ot� •.,�f 6w sTt�-r CtEi,�� Fwo,��� n��)
d��/c�✓�� GLJS1c<e, /22-G�.r�.•ap%' A/'

vu(rM
,7 NI'
- -r A

Finetex Inc. 11/3/99 Pg. 5 (of 5)
neither produces nor uses styrene now or at anytime in the past. Additional analysis was performed and
reported. That analysis reflected no detectable VOC results. Documentation is attached. The operator
was instructed in careful sampling procedures.
Finetex has complied with the permit conditions.
Violation of Permit Condition "V.2"
- The maintenance log used by Finetex requires the operator to walk and inspect the irrigation lines on
each field used. The entire fields and related equipment are checked. The log has space to check off
conditions and instructions to report problems. With DWQ staff s observation, Finetex has expanded the
log to include additional descriptions, observations, time of inspection, and comment sections. A copy of
the new form is attached.
RESPONSE CONCLUSION
Finetex is a second -generation family owned and managed business. We are proud of our relations with
customers, employees and government regulatory agencies. We believe we have operated our facilities
in compliance with all conditions of Permit No. WQ0001077. Our company strives to comply with
permit and regulatory requirements, and, where it is environmentally beneficial and economically
feasible, to surpass those requirements. Since further improvements are always possible, I welcome you
and your staffs questions and suggestions. We encourage your visitation to review and inspect our
facilities again at the earliest possible date and look forward to State re authorization to re - activate
Irrigation Field #2.
If possible, I would like to personally be present for the future re inspection and to that end and if
possible, would like to request a prearranged inspection date.
Our offices look forward to you earliest possible response.
Re Itful! l
i
Robert H. Scala
Vice president
cc: Michael Allen, PE - MacConnell & Associates
Bob Cheek, Ground Water section, Central Office
Ellen Huffman
Charley Schwartz
Kirby Atwood - Compliance Coordinator, Finetex
Jack Heath - Plant Engineer, Finetex
Gary MacConnell - President, MacConnell & Associates
Roger Porter - President, Finetex
Tony Bolton — Operations Manager, Finetex

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FRUM : MacConnelI & Associates, P.C. PHONE NO. 919 319 6510 Nov. 03 1999 12:13PM P3
�f 7o RFL't 0 IFED co TtNF7FX
5i1dQtb DiSl'F4iiR RS7ftValloT i�
cR E vNTIL rirt,D 'f•�('AsU-D, i
tl V?:nL A%ITy{oQ►ZES
almost a week (sinm Wednesday, October 2 during our investigation. Based upon our
- engineering evaluation, the owing is a list or recommendations for contin>ied proper operation
and. maintenance of the Finetcx ,wastewater treatment and disposal facility:
• proceed with the aeration- basin expansion project as soon as the permit is issued While
expansionn-of the basins is underway, tho corm of the dike experiencing. seepage should be
excavated, and recompacted in accordance with the project specifications . The soil should
be excavated, the slopes should be benched and appropriate fill material should be. placed
and.recompacted in. accordance with the project specifications. This should elintinate any
seepage through the embankment.
It should be noted that the aeration basin expansion project will have a profound effect on
operation of the wastewater treatment plant and disposal facility. The expansion will
of the basin will be re
provide two feet of fieeboard, the site upstream regraded to dive .rt
stormwater runoff from the wcccss road and other upstream cress underneath the access
road and away from -the_ aeration basins, longer detention times will be provided producing
a higher quality effluent for land application and the area of concern due to seepage
through the .ennban�ent will be repaired_ ..
• jJntil such. time as the seepage repair has been made, the sump for collecting the seepage
should continue to be used.. The seepage raze has been estimated at a maximum of only 3
gallons per hour and. sbould infiltrate the soil at this rate. however, during vain events, the
runoff .which collects in this .sump should be pumped back into the aeration basins. From
site observations, it is obvious that the channels in the access road near the seepage area
have been created by stomawaier runoff flowing down the access road. This was very
obvious, today because of the �ff continuing to flow down this channel towards the
sump upon our inspection.
• The disposal fields should be continue to be upgraded. A continuing program for
improving the site has been underway since canpletion of the .flood irrigation project._
The desire is to create a site with a. unitbrm grak no depressions which allow for ponding
of effluent and gwzn hater, and a good. vegetative cover for assirnilation of the wastewater
enieet. Since the inspection on September 3®, a great deal of work has 9m* been
per%rmed to improve the site. Many ofthe.major depressions on fields 1, 2,4 and 5.have
already been.filled with topsoil and grass seed has been planted_ For better germination of
the grass .seed, some type of mulch (straw, .etc). should be. placed on these areas. This .will
provide. adequate moisture for germination and. prevent stormwater runoff Rom. washing
I
way the grass seed.. This program should be continued until the site maintains a.uniform
grade which. does not pond after rain events.
During the inspection, it was noted that field number 3. is in the most need of repair.
There are many low -spots which collect water and. contain marginal vegeta&e cover.
This field is downstream of a large stormwater drainage area and also from irrigation fields
1, 2 and 4. Therefore, opificant hydraulic loading may be occurring on this field from
stormwater runoff and to a much smaller Wait, possibly irrigation water from fields 1, 2
and 4. Fmctex to have two options in this situation.. Extensive fiend repeats can be
undertakes to obtain a uniform slope and to improve the vegetative cover oa field 3.

FFL M MacConnell & Associates, P.C. PHONE NO. : 919 319 6510 Nov. 03 1999 12:14PM P4
Otherwise, fields 6 and 7 (previously perrnitted) - can be constructed for long term use and
Held 3 can, be used as a backup held. This mould require an engiaeces cuti5cation prior
to u nation of fields 6 and 7. 'Theselwo . fields bavc good vegetative cover established,
�s main fairly uniform slopes and have a smaller upstream drainage area as compared to
fief 3.
• The "berms" of construction debris should be removed from the disposal fields. These.
berms create somewhat of a dam, impounding storrnwater runofffi� upstream areas.
These ponded areas are too saturated to allow for infiltration of the effluent into the. soil.Upon removal of the. berms and creation of a uniform grade, the stormwater will be able
continue to flow downstream and offthe site.,
• The drip lines w1 ich appear to be ovedspping should be 'cut off just downstream of their
ast lirrigation orifice .Inspection of these lines. indicates that for approx mately. the last 15
feet of these fines there are no irrigation orifices. To eliminate the appearance that these.
lines are. irrigating these areas with twice,- as much effluent, the lines should be shortened to
their last orifice and'capped with the misting gate valves at the ends of these lines;
• The irrigation lines which cross over a gravel surface should be removed from use.. Gravel
surfaces will escperience lower permeability rates than the surrounding soil _. urfam.
Therefore,. inigatien rates being applied to the soil surfaces may cause .runoff from the.
gravel surfaces. 'Removal of these lines will not .result in. an roar AUPeous application rate.
in excess -of those recommended by . the . soiil sciewast. However. reroutingthem to
adjacent areas will :provide better: distribution at a lower rate throughout the field.
• No change in the dgsing rages of the disposal fields should be made. Upon observation of
the system; it appears as.though less than 1/4. inch per hour of irrigation is talang place.
The dosingunps i�ngate the fields at a rate of 60 .gallons per minute (GPM): These
fields have an. offec&e area of.35,000 square feet .(per 1997 application package) per
field. Since the fields are .dosed individually, they receive .the entire 60 GPM. Yn _ one hour
of irrigation, aWoik ately 3,600 gallons are'does over the 35,000 square foot 4Tes. This
results in an instantaneous. inigation rate of 0.16S inches per hour. This rate is much
lower than the acceptable instantaneous irrigation rate as determined by the soil scientist..
If you have.any questions about this evaluation please. feel free to contact Rick Moore or me at
(919).4 1-1239.
Sincerely.
kWe3D.- Allen, P.E_lanagec
cc: Mr. Ricbard. A. Moore; EIT., MacUnnell. & Associates,-P.C.
Mr, Jack.death Fkateu, Inc.
Mr. Kirby Atwood, Fmetex, Inc.

AFFIDAVIT OF KIRBY ATWOOD
State of North Carolina
County of Rowan
ss:
KIRBY ATWOOD, being first duly sworn, deposes and states as
follows:
1. My name is Kirby Atwood. I am of legal age to make this
Affidavit. I have personal knowledge of all of the facts stated in this Affidavit,
and I am competent to testify to the truth of said facts.
2. I am employed as Compliance Coordinator by Finetex, Inc. I have
held this position for one and one-half years. In this position I am responsible for
compliance for environmental laws, regulations and permits at the Finetex
manufacturing facility in Spencer, N. C. in Rowan County.
Cis 1
3. On September 30, 1999, I accompanied Mr. Ghade&Schwartz on
an inspection of the Finetex irrigation application facilities.
4. No application of waste was made to the irrigation ap lication
.gPLjP&VvP I1A0 is r 0 hCkT
fields on September 30, 1999. ro pt��X gurNor- 571"fJnr
DPAP RaD 3
5. Among my duties is the responsibility of deciding when and where
to apply residual wastewater to the irrigation application fields, or, in the
alternative, to route the residual wastewater to the wastewater treatment plant of
the Town of Spencer.

6. I have never authorized the application of residual wastewater to
the irrigation fields during a precipitation event. To the best of my knowledge
_ and belief, residual wastewater have never been applied to irrigation application
fields during a precipitation event.
\NL loll
� I f
T*t\T' oN� +w
oY I wS�7
ou R1oQ 'o 0
7. Prior to authorizing the application or residual wastewater to ��e�� S z,.*AR
d �o ojAett D 50 via
irrigation application fields, I ersonall determine the condition of the field. I do F LL�
not, nor have I ever, authorize app ication of residual wastewater to irrigation
application fields if there is water standing on the field.
8. There have been occasions during the summer of 1999 when I
authorized the application of residual wastewater to irrigation application fields
on the same day that a precipitation event occurred. To the best of my knowledge
and belief, in every one of those instances, the irrigation application of residual
wastewater occurred prior to the initiation of the precipitation event, or after the
conclusion of alight precipitation event after all standing water had drained from,
or had infiltrated into, the irrigation application field.
9. The drip lines used on the irrigation application fields are flexible.
One reason for the use of flexible drip lines was to allow workers in the irrigation
application fields to move the lines for the purpose of maintenance. I do not, nor
have I ever, authorize application of residual wastewater to irrigation application
fields if the drip lines are not properly separated. To the best of my knowledge e so'& KAol-s °a��E orl
and belief, the flexible drip lines have always been restored to their proper
separation prior to the delivery of the residual wastewater to the lines.
F To'D 4,,,A *NE, � wlts Plz�viou5c , jNNWW of 'WC SBf'�l�FTt�� fZEQv�RERG�vT
loci
RGtNT
To i; ovr l� THE Dtflb�kc� �SSoelkr6� wj Y�}C� IN�rA� ��R1�ITer'rICh��oa �r�'k�LF

10. On December 1998, I personally reported to Linda Love of the
Mooresville Regional Office of the Department of Environmental and Natural
Resources, by telephone, that styrene had been detected in two separate
monitoring well samples collected on November 17, 1998. At my direction,
additional samples were taken on December 14, 1998, from the two monitoring
wells. The latter samples showed no detectable VOCs. Subsequent investigation
indicated that the styrene concentrations were caused by inadvertent
contamination of the samples.
Further affiant sayeth not.
Sworn to and subscribed to before me this the
day of November, 1999.
I OFFICIAL SEAL
Notary Public Notoy Pqr.�,,. ram, Carob„
My Commission Expires. 62 IS ow
My Commission Expires

FROM : MacConnelI & Associates, P.C.
PHONE NO. : 919 319 6510 Oct. 28 1999 09:42AM P2
Sri Vs-1 v-/Lv
Permit No. WQ0001077
April20, 1998
ENGINEER'S CERTIFICATION
Partial Final
1, Gary c MacConn.el l , as a duly registered Professional Engineer in the State of
North Carolina, having been authorized to observe (periodically, weekly, full tithe) the construction of the
project
Finetex Incorporated, spencer Facility
Wastewater Spray. r.r. ga zon Spencer Rowan County
P4ect Nmne Locadon and Cosa*
for the Permittce hereby *at, to the bast of my abilities, due care and diligence was used in the
observation of the constro- od nn, -such that the conmuction was observed tobe built within substantial
compliance andintsarffWs ireations, and other supporting materials.
Si ature Registration No. �: M 71'tM
S.
SEAL
Date a ., a i®a- _ r= 17069
April 17, 1998- ConstrM o dan of a 20,000 gall two 30 GPM iaeigatio2a rwiffip z FTnd mvw 37,000 _
squaw foot iesagation zones
Please rote the following changes and modifications from the
approved plans:..
1. orientation of building and piping are changed to accomodate pow,
2. `fliaaensions of -tank are different from plan,.. capacity is the same
3: Automatic (PLC) controls were not installed. System is operated
manually.
4. Fields 6 & 7 were not installed.
5. For one field the pump operated at 54 gaizons 0 22.pri.

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------------

North Carolina Department of Natural
Resources. &Community Development
James B. Hunt, Jr.; Governor Joseph W. Grimsley, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT June 30,' 1982
Mr. Anthony F. Bolton, Operations Manager
Finetex,Incorporated
P. 0.•Box 164
Spencer, North Carolina 28159
SUBJECT: Permit No. 3600-R
Finetex;Incorporated
Non-Discharging:Wastewater Treatment
System with Spray Irrigation
Rowan County
Dear Mr. Bolton:
In accordance with your letter request for permit renewal received
February 8, 1982, we are forwarding herewith Permit No. 3600-R, dated
June 30,' 1982, to Finetex, Incorporated for the operation'of
the subject non -discharging industrial wastewater treatment system with
final.disposal of treated wastewater by spray irrigation.
Ths•permit shall be effective from the date of issuance until July 31,
1985, and shall be subject to the conditions and limitations as specified
therein, and shall void Permit No.. 3600 dated June 17, 1975.
If any parts, requirements, or limitations contained in this permit are
unacceptable.to you,.you have the right to an adjudicatory.hearing before a
hearing officer upon written demand to the Director within thirty (30) days
following receipt of this permit, identifying the specific issues to be
contended. Unless such demand is made, this permit shall be final and
binding.
One (1) set of approved plans and specifications is being forwarded
to you. If you have any questions or need additional information
concerning this matter, please contact Mr. A. R. Hagstrom, telephone
number 919/733-7120..—�.
Sincerely yours,
.�.
Robert F. He
Director
cc: Rowan County Health Department
Mr. W. Lee Fleming, Jr.
Mr. Richard Peace
Mooresville Regional Office Manager
P. 0. Box 276B7 Raleigh, N. C. 27611-7687

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
RALEIGH
P E R M I T
For the Discharge of Sewage, Industrial Wastes, or Other Wastes
In accordance with the provisions
Statutes of -North Carolina as amended,
Regulations
of Article.21 of Chapter 143, General
and other applicable Laws, Rules, and
PERMISSION IS HEREBY GRANTED TO
Finetex, Incorporated
Rowan County
FOR THE
continued operation of a 5,000 GPD industrial wastewater treatment system
with final disposal of treated wastewater by spray irrigation consisting of
.approxzmately.360-lineal feet of 8-inch gravity sewers, an influent screen-
ing structure, dual 115,000 gallon mechanically aerated basins, a 8000
gallon holding tank, a lift station with dual 120 GPM spray irrigation
pumps, approximately.1500 lineal feet of 6-3'L'nch force main, a 120 GPM sprink-
ler system with pipes, nozzles, controls, valves, flow measuring and record=
ing equipment, and appurtenances with a spray field of approximately 4.0
acres to serve Finetex, Incorporated with no discharge of either wastewater
or liquid sludge to the surface waters of the State,
pursuant to the letter. of request for permit renewal received February 8,
1982, and in conformity with the project plans, specifications, and other
supporting data, subsequently filed and approved by the Department of
Natural,.Resources and Community Development and considered a part of this
permit.
This Permit shall be effective from the date of issuance until July 31,
1985, and shall be subject to the following specified conditions and limita-
tions and shall void Permit No. 3600 dated June 17, 1975:
1. This permit shall become voidable unless the facilities continue to be
operated in accordance with the approved plans, specifications and other
supporting data.
2. This permit is effective only with respect to the nature and volume of
wastes described in the application and other supporting data.
3. The facilities shall be properly maintained and operated at all times.
4. This permit is not transferable.

r
r
Permit No. 3600-R
Page Two
5. This permit -shall become voidable in the event of failure of the
soil to adequately absorb the wastes, and may.be rescinded unless the
facilities are installed, maintained and operated in a manner which
will protect the assigned water quality standards of the surface
waters, and prevent any contamination of the ground water which will
render them unsatisfactory for normal use.
6. In the event.the facilities fail to perform satisfactorily, the
Permittee shall take such immediate corrective action as may be
required by this Department.
7. Solids, sludges, or other pollutants removed,or resulting from the
wastewater treatment process shall be contained and disposed of in
such a manner as to prevent any contamination of the surface or
ground waters of the State.
8. The Permittee shall employ a certified wastewater treatment plant
operator in responsible charge of the wastewater 'treatment facilities.
Such operator must hold a certificate of the grade at least equivalent
to the classification assigned to the wastewater treatment facilities
by the Certification Commission.
9. :Diversion or bypassing of the untreated wastewater from the land
application facilities is prohibited.
10. Monitoring wells shall be.constructed and sampling schedules and
monitored.parameters arranged.as.required by the Division of
Environmental Management.
11. A suitable year round. vegetative cover shall be.maintained.
12. The Permittee, at least six (6) months prior to the expiration of
this Permit, shall request its extension. Upon.receipt of the request,
the Commission will review the adequacy of the facilities described
therein, and if indicated, will extend the Permit for such period
of time and under such conditions and limitations as it may deem.
13. A minimum buffer. zone of 400 feet shall. be maintained between the
wetted spray -field and residential units.
14. No root or leaf crops for public consumption shall be raised on the
sites.
15. All spraying of treated wastewater must be done within the designated
and protected spray irrigation fields as indicated on the approved
engineering plans.
16. Application rates shall not exceed a maximum irrigation rate of
.25 inches/hour or an average of 0.55 inches/acre/week of wastewater,
uniformly applied so as to avoid runoff, ponding, or erosion.
17. The issuance of this permit shall not relieve Finetex, Incorporated

r
t
r Permit No. 3600-R
Page Three
18. In the event odor problems. occur, immediate action, including- further
pretreatment such as may be required by'this Division, shall be
taken by the Permittee.
19. Wastewater shall not be applied during inclement weather or until
24 hours following.a rainfall event of 1/2-inch or greater in 24
hours.
20. Accurate records shall be maintained as to the amount of wastewater
applied to the land on the disposal site. These records shall be
made available to this Division upon request.
21. An operation: and maintenance manual shall be drafted by Finetex,
Incorporated and submitted to the,Mooresville Regional Office for
I
their review and approval.
J-.-. jc•Y nzrs-/G�Yi C�c7� �4 %i5.���P. t e n ��-� �'•'-�'
Permit .issued this. the 30th of June, 1982..
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Robert F. Helms Director
Division.of Env ronmental Management
By Authority of the Environmental Management Commission
Permit No. 3600-R

NON DISCHARGE WASTEWATER MONITORING REPORT Page -L of
.. PERMIT NUMBER: W CQ 0 OO 1077 MONTH: SC io+embe(- YEAR:
FACILITY NAME: }' A_e+@.y LnL. CLASS: _ COUNTY: IecWc,.r1
50050
Daily Rate
Sampled at the Point Prior to irrigation or disc ar e to rotarydistnbutor
Enter arameta code above name and units below
D
a
Opal
Arrival
Operator
ORC
(Flow)
into
t
Time 2400
Time On
on
Treatment
e
Clock
Site
Site?
System
HRS
YIN
MGD
11
Grab
OPERATOR IN RESPONSIBLE CHARGE (ORC) Em m d+ GRADE _�� PHONE
CHECK BOX IF ORC HAS CHANGED ❑
CERTIFIED LABORATORIES (1) e gk Rr►�et . C nC. (2)
PERSON(S) COLLECTING .SAMPLES 7 a tk cc'V' e i Ern Me" "+ hfWOOC;'
Mail ORIGINAL and TWO COPIES to:
ATTN: COMPLIANCE GROUP
DIV. OF ENVIRONMENTAL MGT. X_ t;t
DEHNR (SIGNATURE OF OPERATOR IN RSC GE)
P.O. BOX 29535 BY THIS SIGNATURE, I CERTIFR PORT IS ACCURATE
RALEIGH, NC 27626.053E AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
NOMR-1.1 (7194)

NON DISCHARGE APPLICATION REPORT Page of
SPRAY IRRIGATION FIELDS
There are two application fields per page. Use addiSonal pages as needed.
PERMIT NUMBER: WQ COD % 07 7 MONTH: S 'i er)� �o �� YEAR:
FACILITY NAME: 1- n �e _ TeX Zn C . COU TY:
Formulae
Daily Loading (inches): - (Volume Applied (pl►oxa) a 0.1316 (c*ie (iedgallmo) x 12 (irclkw[m)I / (Am Sp vW (aces) x QJ60 (square (ecda=
Moximum Handy Luading (( )' - Daily faadiat @x1m) I rrime"pwd (odnmo) 160 (aimxesAmtr)( 'Mandtly Loading (inches) >• Sum o(Doily losdiap (iocEa)
12 Manth Flouin6 Tool pnches): = Sum o(Ws mondrs)Nandd Mmthly Losdop0„d�) .. Y poi (ioehn) aad pn:via® 11 muaeh's
Aveeage Wmhly Lording (inch-); . (Momhly loading (iochedmoath)/Number of days in rbe asomb (dryslpmmh)i x 7 (days)
Spray Irrigation Operator in Responsible Charge (ORC): Em me--4 K r A-�W oO J' If, Phone: rz%41 1.3 3 -OOD�LC6
ORC Certification Number: a33 5.5
Mail ORIGINAL and TWO COPIES to:
ATTN: Non -Discharge Compliance Unit
DENR
Division of Water Ouality
P.O. BOX 29535
RALEIGH, NC 27626-535
X
lmylk& aw2� a. —
(SIGNATURE OF OPERATOR IN RESPONSIB ARGE)
BY THIS SIGNATURE. I CERTIFY THAT THIS PORT IS ACCURATE AND COMPLETE
TO THE BEST OF MY KNOWLEDGE.
NDAR (2/98)

NON DISCHARGE APPLICATION REPORT Page _,Z of t-II
SPRAY IRRIGATION FIELDS
There are two application fields per page. Use additional pages as needed.
PERMIT NUMBER: W Q C G o b11 MONTH: el"I `j E<- YEAR:
FACILITY NAME: �t �-} e�- Z,^ C COUNTY: (� Ln L > ck n
Formulas
... :..Daily Fading (inches)- [Volume Applied (gallon) a 0.1336 (ahie feet/gallon) a 12 (iftxhestfaot)I / [Area Spmyd (acres) s 43.560 (square rcn/aae)1
Maximum Hourly Loading (inches)'- Daily Loading (mclrs) / ITime brigdod (minutej) / 60 (miouidhar)1
. .-... Mtnlddy Loading (inches) aSwo ofDady lnadinia(
I Momh Floaling Total (inchw): -Sum of this mooth's Monthly Loading (inches) and pmviow I I mooWs uxhes)
... Y LoadisgaGndaea)
Average; wcsliiy Loading (Inches):. IMamMy Ada: (inChe✓pwa)a) f Numhad days in the mach (dayilmwh)) s 7 (daystaink)
Spray Irrigation Operator In Responsible Charge (ORC): E M r,n.e±± c phone pr l _� da�
ORC Certification Number: 2 3 3 5 1
Mail ORIGINAL and TWO COPIES to:
ATTN: Non-Dlscharge Compliance Unit
DENR
Division of Water Quality
P.O. BOX 2.9535
RALEIGH, NC 27626-535
X
(SIGNATURE OF OPERATOR IN RESPONSIBLE C GE)
BY THIS SIGNATURE, I CERTFY THAT THIS REPORT IS ACCURATE AND COMPLETE
TO THE BEST OF MY KNOWLEDGE.
NDAR (2/98)

NON DISCHARGE APPUCATION REPORT Page 4 of u
SPRAY IRRIGATION FIELDS
!There are two application fields per page. Use additional pages as needed.
PERMIT NUMBER: QQQ 1 0-7'7 MONTH:
FACILITY NAME: �� �',) ( YEAR: ( �
- - � � e-{-p y` =n C COUNTY:
Rowe, n
Formulefa
.. .Daily Loading (inches) _ [Volume Applied (galkKn) x 0.1376 (cubic feer/gallon) x 12 (Incha1f0m)1 f IAm Strayed (oats) x 47,560 (Squat fcafaae)I
Maximum Hourly Loading (inches), = Daily Loading (incha) I Dime brigtled (mkwlcs) 160 (mimm=fbmr))
::�Monlhly Loading (inches) . Sum of Daily laadiap (iod�a)
:. 12 Mdnlh F7padng TbtaL (inches); = Sum of dda mm s Mamhly Loading (iocbm) and om
pmvious 11 mh'a Mmhly Laadmp(k�)
Average Weekly loading (inches) = IMmuhly lording (ioehcsfmmmh) I plumber of days in on mmuh (days/mmb)) x 7 (daySheck)
Spray Irrigation Operator in Responsible Charge (ORC): EMme-e 4' K /`tTa x� �I r.
Phone(
ORC Certification Number: 33S's
Mail ORIGINAL and TWO COPIES to:
ATTN: Non -Discharge Compliance Unit
DENR
Division of Water Quality
P.O. BOX 29535
RALEIGH, NC 27626-535
X
(SIGNATURE OF OPERATOR IN RESPONSIBLE CHA 1
BY THIS SIGNATURE, I CERTIFY THAT THIS REPOR IS ACCURATE AND COMPLETE
TO THE BEST OF LAY KNOWLEDGE.
NDAR an8)

00,
- Next Day Express Mail
December 30,1998
To: Division of Water Quality-Groundwt?Te: Sion
PO Box 29578
Raleigh, NC 27626-0578
Y.
P
From: Ruby Atwood, Compliance Coordinator
Finetex Inc.
PO Box 164
Spencer, NC 28159
Sir,
a
I am submitting this letter as instructed by the Mooresville Regional Office. Two _
of our monitoring wells had detectable VOC results. As required by our re.-mit we
contacted the regional offs a for instructions. Linda Lava was the contact in Moores%M&
We were directed to send this letter informing you.of the results with the GW-59 forms.
The results from MW-1 were .98 ug/i of gymne and MW-3 had 3.1 u&4 of
styrene also. The other monitoring well on the field did not report any styrene. We have
not had any detectable readings in the past for styrene. I investigated the use of styrene at
our fatwU-:g-. 7-Me investigation has shown that styrene is not used presently or at any time
during the pastor We puffed additional samples .o confirm the test results. The testing
results will be sent to your attention as soon zr me in ormation arrives. Please contact me
at [phone] with any questions or C=Cr—M .
Thank you,
- Atwood
F2MM INC., P.Q sox 216, MMWOOD PARL,1! M JERSEY 07407 (201) TM-M FAX 01) M-6M

Type or Use a ball-point pen and press firmly. PERMIT NUMBER: (REQUIRED)
Non -Discharge �"r n est:b 1 0%%
;ility Name M-+" Tele NPDES.
Address IS
TYPE OF DISPOSAL OPERATION BEING MONITORED
County (REQUIRED) Lagoon Septic Tank/Draln Field
ill Location
ill Identification Number i Well Depth Ft. --k/— spray Field Subsurface Low -Pressure
ill Diameter —Sample (Screened) Interval Ft. To Ft. anPiping (LPP)
• Land Application of Sludge
pth to Water Level eft. below measuring point (before sampling) other
iasurlhg point is• ' ft. above land surfaceRotary Distributor
Ilons of water pumped/bailed before sampling ®®
ild Analysis: pH &� Specific Conductance uMhos Temp. °C Odor �: ( Appearance Clear
to Sample Collected 11 11? 1g5t Date Lab Sample Analyze+ 11 1 a O! q
N�
3oratory Name Certification No.
,MPLES FOR METALS WER COLLECTED UNFILTERED AND FIELD ACIDIFIED _AYES NO
)®• mg/I
)liform: MF Fecal /100ml
Alform: MF Total /100ml
ite: Use MPN method for highly turbid samples)
ssolved Solids: Total �20$ . C mg/i
l (when analyzed) units
)C mg/l
iloride mg/I
senic mg/I
ease and Oils mg/I
3rdness: Total mg/I
ienol mg/I
Mate mg/I
)ecific Conductance __ uMhos
)tal Ammonia mg/I
64 as N mg/I
Nitrite (NO2) as N
mg/I
Nitrate (NO3) as N
mg/I
Phosphorus: Total as P
mg/i
Al - Aluminum
mg/I
mg/I
Ba - Barium j
Ca - Calcium
mg/I
Cd - Cadmium
mg/I
Chromium: Total
mg/I
Cu - Copper
mg/I
Fe - Iron
Hg - Mercury
mg/I
K - Potassium
mg/I
mg/I
Mg - Magnesium
mg/I
Mn - Manganese
Na - Sodium
mg/I
CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
ature of Permittee (or Authorized Agent*)
12- - I - if
Date
NI - Nickel
i`I
mg/I
mg/I
Pb - Lead
Zn - Zinc
mg/I
Pesticides/Herbicides
(Specify Compounds)
Ug/i
ug/I
ug/I
Other (Specify Compounds and
Concentration units)
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
Ee back for Instructions.
bmlt blue and yellow copies only to address above.1
►N-59 REV. 8/96

Order # B8-11-408
Page 3
12102198 15:38
TEST RESULTS BY SAMPLE
Sample Description: MW-1
Lab No: 0IB
Test Description: ®DCs by GC/MS
Method: EPA 8260B Test Code: 8260AW
_ Collected: 11/17/98 13:30
PARAMETER RESULT
PQL
0
Acetone
BDL
20
U
67-64-1
Acrolein
BDL
20
U
107-02-8
Acrylonitrile
BDL
10
U
17-13-1
Allyl chloride(3Cbloropropene)
BDL
2
s1
107-05-1
Benzene
BDL
I
U
71- 43 -2
Bromobenzene
BDL
I
U
108-86-1
= Bromochloromethane
BDL
I
U
74-97-5
Bromodichloromethane
BDL
1
U
75-27-4
Bromoform
BDL
1
U
75-25-2
Bromometbane
BDL
1
U
'
74-83-9
2-Butanone(Methylethyl ketone)
BDL
10
U
78-93-3
n-Butyl benzene
BDL
I
U
104-51-8
sec -Butyl benzene
BDL
I
U
135-98-8
tert-Butyl benzene
BDL
I
0
98-06-6
Carbon disulfide
BDL
2
_U
75-15-0
Carbon tetrachloride
BDL
Z
U
56-23-5
Chloroacetonitrile
BDL
50
U
107-14-2
Chlorobenzene
BDL
I
U
108-90-7
1-Chlorobutane
BDL
2
U
109-69-3
Cbloroethane
BDL
1
U
75-00-3
Chloroform
67-66-3
Chloromethane
BDL
1
U
74-88-4
2-Chlorotoluene
BDL
1
U

osNer 8 BB-11-408
Page 4
12102198 15:39 TEST RESULTS BY SAMPLE
Sample Description: MN-1
Lab No: DID
Test Description: VDC9 by GC/MS
Method: EPA
8260B Test Code: 8260AN
Collected: 21/17/98 13:30
95-49-8
4-Chlorotoluene
BDL
1
U
106-43-4
1,2-Dibromo-3-chloropropane
BDL
2
U
96-12-8
Dibromocbloromethane
BDL
1
U
124-49-1
1,2-Dibrcooethane
BDL
1
U
206-93-4
Dibramomethane
BDL
1
U
74-95-3
1,3-Dichlorobenzene
BDL
I
U
542-73-1
1,2-Dichlorobenzene
BDL
I
U
95-50-1
1,4-Dichlorobenzene
BDL
I
U
106-46-7
trans-1,4-Dichloro-2-butene
BDL
2
U
110-57-6
Dichlorodifluoramethane CFC-12
BDL
1
U
75-71-8
1,1-Dichloroethane
BDL
I
U
_ 75-34-3
1,2-Dichloroethane
BDL
1
U
107-06-2
cis-1,2-Dichloroethene BDL
1
U
156-59-2
tram-1,2-Dichloroethene
BDL
I
U
156-60-5
1,1-Dichloroethene
BDL
1
O
75-35-4
1,1-Dichloropropanone
BDL
50
U
513-80-2
1,3-Dichloropropane BDL
I
U
242-28-9
1,2-Dichloropropane
BDL
I
U
78-87-5
2,2-Dichloropropane
BDL
5
U
= 590-20-7
1,I-Dichloropropene
BDL
2
U
563-58-6
cis-1,3-Dichloropropene
BDL
I
U
542-75-6
trans-1,3-Dichloropropene
BDL
I
U
542-75-6
Diethyl ether (Ethyl ether)
BDL
2
U
60-29-7
Ethylbenzene
BDL
1
U
100-41-4

Order # B8-11-408 Page 5
12/02/98 15:38 TEST RESULTS BY SAMPLE
Sample Description: MW-1 Lab No: O1B
Test Description: VOCs by GC/MS Method: EPA 8260B Test Code: 8260AW
Collected: 11/17/90 13:30
Hexachlorobutadiene
BDL
I
U
87-69-3
Ethyl methacrylate
BDL
10
U
97-63-2
2-Hexanone
BDL
I0
U
591-78-6
Hexachloroethane
BDL
10
U
67-72-1
Zsobutyl Alcohol
BDL
1
U
78-63-1
Zsopropylbenzene
BDL
I
U
98-82-8
p-Isopropyl toluene
BDL
I
U
99-87-6
Methacrylonitrile
BDL
20
U
126-98-7
Methyl acrylate
BDL
10
v
96-33-3
Methyl iodide (Iodomethane)
BDL
2
U
74-88-4
Methyl methacrylate
BDL
10
U
80-62-6
Methyl tert-butyl ether
(MTBE)
BDL
1
U
1634-04-4
4-Methyl-2-pentanone (MZBR)
BDL
10
U .
108-10-1
Methylene chloride
BDL
5
U
75-09-2
Naphthalene
BDL
5
U
91-20-33
Nitrobenzene
BDL
50
U
98-95-3
2-Hitropropane
BDL
50
V
79-46-9
Pentachloroethane
BDL
50
U
76-01-7
Propionitrile
BDL
50
U
107-12-0
a-Propylbenzene
BDL
z
U
103-65-1
Styrene
0.98
1
Z
100-42-5
1,1,1,2-Tetrachloroethane
BDL
I
U
630-20-6
1,1,2,2,-Tetrachloroethane
BDL
I
U
79-34-5
Tetrachloroethene
BDL
1
U
127-19-4
Tetrahydrofuran (THF)
BDL
2
U

Order # BB-11-408 Page 6
12/02/98 15:38 TEST RESULTS BY SAMPLE
Sample Description: MW-I Lab No: VIB
Test Description: VOCS by GC/MS Method: EPA 8260B Test Code: 8260AW
Collected: 11/17/98 13:30
109-99-9
Toluene
BDL
I
U
108-68-3
,1,2,3-Trichlorobenzene
BDL
I
U
87-61-6
1,2,4-Trichlorobenzene
BDL
I
U
120-82-1
1,1,2,-Trichloroethane
BDL
I
U
72-55-6
1,1,2-Trichloroethane
BDL
I
U
79-00-5
Trichloroethane
BDL
I
U
79-02-6
2,2,3-Trichloropropane
BDL
I
U
96-19-4
2,2,4-Trimethylbenzene
BDL
I
U
95-63-6
2,3,5-Trimethylbenzene
BDL
2
U
95-47-6
Trichlorofluoromethane
CFC-I1
BDL
I
U
75-69-4
Vinyl Chloride
BDL
I
U
75-01-4
Total Xylenes
BDL
I
U
2330-20-7
p-Dioxane
BDL
25
U
123-91-1
Vinyl Acetate
BDL
2
U
Isopropyl ether
BDL
2
U
SURROGATE
tRECOVERY
LIMITS
Dibromofluoromethane
97
82
-
136
1,2-Dichloroethane-d4
91
82
-
I30
Toluene-d8
99
84
-
119
4-Bromofluorobenzene
95
94
-
121
Notes and Definitions for this Report:
DATE RUN 11125198
ANALYST JLS
INSTRUMENT 5971E
FILE ID
CONC FACTOR 2
UNITS as/L

Type or use a ball-point pen ana press tirmiy. PERMIT NUMBER: (REQUIRED)
lity Name + X'AS Non -Discharge MI Q UG� (Oi -7
Address bN NPDES
Saf nC&C ,N.C. a%155 CountTYPE
OREDIPOSAL.OPERATION BEING MONITORED
Lagoon
Septic TanIdDraln Field
Identification Number a Well Depth d7 Ft. ✓ Spray Field Subsurface Low -Pressure
Diameter ')Q" Sample (Screened) Interval Ft. To Ft. p Piping (LPP)
h to Water Level P'r 9" ft. below measuring point (before sampling) Land Application of Sludge
curing point is 1 ft. above land surface RotOther
Rotary Distributor
ms of water pumped/bailed before sampling 17Af tU
Analysis: pH 7.3 Specific Conductance uMhos Temp. °C Odor Appearance c-e-
Sample Collected Date Lab Sample Analyzed I ��� 9 Certification No. 7
iratory Name
PLIES FOR METALS 1101ERE COdLECTED UNFILTERED AND FIELD ACIDIFIED _-YES NO
mg/I
form: MF Fecal
/100ml
form: MF Total
/100ml
: Use MPN method for highly turbid samples)
iolved Solids: Total 1A9 .0
mg/I
'when analyzed)
units
E'.1 %
mg/I
)ride
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;nic
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ase and Oils
mg/I
mess: Total
mg/I
nol
mg/I
ate
mg/I
cific Conductance
uMhos
it Ammonia
mg/I
I as N
mg/I
Nitrite (NO2) as N
mg/I
Nitrate (NO3) as N
mg/I
Phosphorus: Total as P
mg/I
All - Aluminum
mg/I
Ba - Barium
mg/I
Ca - Calcium
mg/I
Cd - Cadmium
mg/l
Chromium: Total
mg/I
Cu - Copper
mg/I
Fe - Iron , Iso
mg/I
Hg - Mercury
mg/I
K - Potassium
mg/I
Mg - Magnesium
mg/I
Mn - Manganese
mg/I
Na - Sodium
mg/I
RTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
iz-7-9ty
I e of Permittee (bAuthorized Agent') Date
59 REV. 8/96
Ni - Nickel mg/I
Pb - Lead ®1 a mg/I
Zn - Zinc mg/I
Pesticides/Herbicides
(Specify Compounds)
ug/I
ug/I
ug/I
Other (Specify Compounds and
Concentration units)
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
• See back for Instructions.
•" Submit blue and yellow copies only to address above.

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Order # BB-11-408
Page 8
12102198 15:38 TEST RESULTS BY SAMPLE
Sample Description: MW-2
Lab No: 02B
Test Description: VOCz by GC/MS
Method: EPA 8260B Test Code: 8260AW
Collected: 11/17/99 13:55
95-49-8
4-Chlorotoluene
BDL
I
U
106-43-4
1,2-Dibromo-3-chloropropane
BDL
2
U
96-12-8
Dibromochloromethane
BDL
I
U
224-48-1
1,2-Dibromoethane
BDL
I
U
106-93-4
Dibromomethane
BDL
I
U
74-95-3
2,3-Dichlorobenzene
BDL
1
U
541-73-1
2,2-Dichlorobenzene
BDL
1
U
95-50-1
1,4-Dichlorobenzene
BDL
1
U
106-46-7
trans-1,4-Dichloro-2-butene
BDL
2
U
210-57-6
Dichlorodifluoromethane CFC-12
BDL
1
U
75-71-8
' 1,1-Dichloroethene
BDL
i
U
75-34-3
1,2-Dichloroethane
BDL
I
U
107-06-2
cis-1,2-Dichloroethene
BDL
I
U
256-59-2
trans-1,2-Dichloroethene
BDL
1
U
156-60-5
I,I-Dichloroethene
BDL
I
U
75-35-4
1,1-Dichloropropanone
BDL
50
U
513-88-2
1,3-Dichloropropane
BDL
I
U
242-28-9
1,2-Dichloropropane
BDL
1
U
78-67-5
2,2-Dich2oropropane
BDL
5
U
590-20-7
1,1-Dichloropropene
BDL
2
U'
563-58-6
cis-1,3-Dichloropropene
BDL
1
U
542-75-6
trans-1,3-Dichloropropene
BDL
1
U
542-75-6
Diethyl ether (Ethyl ether)
BDL
2
U
60-29-7
Ethylbenzene
BDL
I
U
100-42-4

Order ## BB-11-408
Page 9
12/02/98 15:38 TEST RBSULTS BY SAMPLE'
Sample Description: MW-2
Lab No: CS
Test Description: VOCs by GC/MS
Method: JCF]! 6260D Test Code: 8260AW
Collected: 11/17/90 13:55
Mexachlorobutadiene
BDL
1
U
87-68-3
Ethyl methacrylate
BDL
10
U
97-63-2
2-Mexanone
BDL
10
U
591-79-6
Mexachloroethane
BDL
10
U
67-72-1
Iscbutyl Alcohol
BDL
I
V
78-83-1
Iaopropylbenzene
BDL
I
U
98-82-8
p-Isopropyl toluene
BDL
I
U
99-87-6
Methacrylonitrile
BDL
20
U
126-96-7
Methyl acrylate
BDL
IO
U
96-33-3
Methyl iodide (Iodomethane)
BDL
2
U
74-88-4
Methyl methacrylate
BDL
10
U
80-62-6
Methyl tert-butyl ether (MTBB)
BDL
i
FT
1634-04-4
4-Methyl-2-pentanone (MIBK) BDL
10
V
I09-10-1
Methylene chloride
BDL
_ 5
U
75-09-2
Naphthalene
BDL
5
U
91-20-33
Nitrobenzene
BDL
50
U
98-95-3
2-Nitropropane
BDL
So
D
79-46-9
Pentachloroethane
BDL
SO
U
76-01-7
Propionitrile
BDL
50
U
107-12-0
n-Propylbenzene
BDL
i
SI
103-65-1
Styrene
BDL
I
U
100-42-5
1,1,1,2-Tetrachloroethane
BDL
I
U
630-20-6
1,1,2,2,-Tetrachlorcethane
BDL
i
U
79-34-5
Tetrachlorcethene
BDL
I
U
127-18-4
Tetrahydrofuran (TilF)
BDL
2
U

Order 9 88-11-408
Page 10
12102198 I5:36 TEST RESULTS BY SAMPLE
Sample Description: MW-2
Lab No: 02B
Test Description: VOCV by GC1J6
Method: EPA 8260B Test Code: 6260AW
Collected: 11/17/98 13:55
109-99-9
Toluene
BDL
I U
108-88-3
1,2,3-Trichlorobenzene
BDL
I U
87-61-6
1, 2,4 -Trichlorobenzene
BDL
I U
120-82-1
1,1,1,-Trichloroethane
BDL
I U
71-55-6
1,1,2-Trichloroethane
BDL
i _U
79-00-5
Trichlorcethene
BDL
I U
79-01-6
1,2,3-Trichloropropane
BDL
I V
96-I8-4
I,2,4-Trimethylbenzene
BDL
I U
95-63-6
1,3,5-Trimethylbenzene
BDL
I
95-47-6
Trichlorofluoromethane CFC-12
BDL
I U
75-69-4
Vinyl Chloride
BDL
I U
7S-02 -4
Total Xylenes
BDL
I p
1330-20-7
p-Dioxane
BDL
25 Z
123-91-1
Vinyl Acetate
BDL
2 U
Isopropyl ether
BDL
2 U
SURROGATE tRECOVBRY
LIMITS
Dibromofluoromethane 96
82 - 136
1,2-Dichlorcethane-d4 89
82 - 130
Toluene -dB I00
B4 - 129
4-Bromofluorobenzene 97
84 - 121
- Notes and Definitions for this Report:
DATE REIN 11/25/96
ANALYST JLS
INSTRUMWff S971B
FILE ID
CONC FACTOR
I
UNITS uo/L

Type or Use a ball-point pen and press tirmiy. PERMIT NUMBER: (REQUIRED)
cillty Name / ; Non -Discharge W & rtn�®1 0 7
Address PC k^ • Ii6w NPDES
r '� County Qo��� n TYPE OF DISpOSAL OPERATION BEING MONITORED
(REQUIRED)
all Location Lagoon Septic TanIdDrain Field
all Identification Number Well Depth Ft.
Spray Field Subsurface Low -Pressure
ADiameter 20"Sample (Screened) Interval Ft. TO Ft. —�
Piping (LPP)
�pth to Water Level "ft. below measuring point (before sampling) Land Application of Sludge
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ild Analysis: Specific Conductance uMhos Temp. °C Odor NeAppearances
to Sample Collected f f J a' gil
�� Date Lab Sample Analyzed ,y 15 2
aoratory Name Certification No. LJ 7
MPLES FOR METALS ERE COLLECTED UNFILTERED AND FIELD ACIDIFIED _ /AYES NO
)D
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/100ml
iliform: MF Total
/100ml
to: Use MPN method for highly turbid samples)
9solved Solids: Total 121.0 mg/I
I (when analyzed)
units
)C U , f a
mg/I
iloride
mg/I
senic
mg/I
ease and Oils
mg/I
irdness: Total
mg/I
ienol
mg/I
ilfate
mg/I
iecific Conductance
uMhos
tal Ammonia
mg/I
:N as N
mg/I
Nitrite (NO2) as N
mg/I
Nitrate (NOO as N
mg/I
Phosphorus: Total as P
mg/I
Al - Aluminum
mg/1
Ba -Barium
mg/I
Ca - Calcium
mg/I
Cd - Cadmium
mg/I
Chromium: Total
mg/I
Cu - Copper
mg/I
Fe - Iron a.l o
mg/I
Hg - Mercury
mg/I
K - Potassium
mg/I
Mg - Magnesium
mg/I
Mn - Manganese
mg/I
Na - Sodium
mg/1
Ni - Nickel
mg/I
Pb - Lead E . G f 0
mg/1
Zn - Zinc
mg/I
Pesticides/Herbicides
(Specify Compounds)
ug/I
ug/I
ug/1
Other (Specify Compounds and
Concentration units)
:ERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
of Permittee (or Authorized Agent*)
I PO ' See back for Instructions.
Date " Submit blue and yellow coples•only to address above.
REV. 8/96

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Order # B8-11-408
Page 12
22/02/98 15:38 TEST RESULTS BY SAMPLE
Sample Description: MW-3
Lab Mo: 03B
Test Description: flocs by Gc/KS
Method: EPA 8260B Test Code: 8260AM
Collected: 21/17/98 14:10
- 95-49-8
4-Chlorotoluene
BDL
1
U
106-43-4
1,2-Dibromo-3-chloropropane
BDL
2
U
96-22-8
Dibromochloromethane
BDL
2
D
124-48-1
1,2-Dibromoethane
BDL
1
U
206-93-4
Dibromomethane
BDL
1
D
74-95-3
2,3-Dichlorobenzene BDL
1
D
541-73-1
I,2-Dichlorobenzene
BDL
1
U
95-50-I
1,4-Dichlorobenzene
BDL
1
D
206-46-7
trans-1,4-Dichloro-2-buteue
BDL
2
D
110-57-6
Dichlorodifluoromethane CFC-12
BDL
1
D
75-71-8
I,I-Dichloroethane
BDL
1
D
75-34-3
_
1,2-Dichloroethane BDL
1
U
107-06-2
cis-1,2-Dich2oroethane
BDL
1
D
156-59-2
trans-2,2-Dichloroethane
BDL
I
U
156-60-5
I,I-Dichloroethene
BDL
1
D
75-35-4
1,1-Dichloropropanone
BDL
50
D
513-88-2
1,3-Dichloropropane
BDL
1
U
142-28-9
1,2-Dichloropropane
BDL
i
U
78-87-5
2,2-Dichloropropane BDL
5
U
' S90-20-7
1,1-Dich2oropropene
BDL
2
U
563-58-6
cis-1, 3 -Dichloropropene
BDL
1
U
542-75-6
trans-1,3-Dichloropropene
BDL
I
U
542-75-6
Diethyl ether (Ethyl ether)
BDL
2
U
60-29-7
Ethylbenzene BDL
1
U
100-42-4

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Order 0 BB-11-408
page 14
12102198 15:38
TEST RESULTS BY SAMPLE
Sample Description: MV-3
Lab Jib. 03B
Test Description: VOCs by
GC/MS
Method: EPA 8260B Test Code: 8260AN
' Collected: 21/17/99 14:10
109-99-9
Toluene
BDL
Z U
108-88-3
1,2,3-Trichlorobenzene
BDL
I U
87-61-6
1,2,4-Trichlcrobenzene
BDL
I U
120-82-1
1,1,1,-Trichloroethane
BDL
I U
71-SS-6
1,1,2-Tri.chloroethane
BDL
I U
79-00-5
Trichloroethene
BDL
1 D
79-01-6
1,2,3-Trichloropropane
BDL
1 U
96-18-4
_ 1,2,4-Trimethylbenzene
BDL
_I V
95-63-6
1,3,5-Trimethylbenzene
BDL
I
95-47-6
Trichlorofluoromethane
CFC-11
BDL
1 U
75-69-4
Vinyl Chloride
BDL
1
75-01-4
Total Xylenes
BDL
I U
I330-20-7
p-Dioxane
BDL
25 U
123-91-1
Vinyl Acetate
BDL
22 U
Isopropyl ether
BDL
2 U
SURROGATE
#RECOVERY
LIMITS
Dibromofluoromethane
97
82 - 136
1,2-Dich2orcethane-d4
89
82 - 130
7oluene-d8
100
84 - 1I9
4-8romofluorobenzene
94
84 - 121
Notes and Definitions for this Report:
DATE RUN 11/25/98
ANALYST JLS
ZNSTREWW 597ZB
FILE ID
CONC FACTOR 1
UNITS uaA

Type or use a
lWy Name +"� =elf
Address- O. 1- Q p L �+
..IA�
pen ana press tirmiy. PERMIT NUMBER: (REQUIRED)
Non -Discharge WGI DID 10?7
NPDES
_ County 4 TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
I Location C.P • Lagoon Septic Tank/Drain Field
I Identification Num er u Well Depth 2_Ft.
I Diameter 2 •r Sample (Screened) Interval2_ R. To _ 16 R. Spray Field Subsurface Low -Pressure
,th to Water Level ft. below measuringPiping (LPP)
point (before sampling) Land Application of Sludge
isuring point is - ft. above land surface
Rotary Distributor
Other
ons of water pumped/bailed before sampling
i Analysis: pH Specific Conductance uMhos Temp. °C Odor Appearance
i Sample Collected Date Lab Sample Analyzed
)ratory Name Certification No.
11PLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES NO
D
mg/I
form: MF Fecal
/100ml
form: MF Total
/100ml
: Use MPN method for highly turbid samples)
solved Solids: Total
mg/I
(when analyzed)
units
mg/I
bride
mg/I
onic
mg/I
ase and Oils
mg/l
mess: Total
mg/I
nol
mg/I
ate
mg/I
cific Conductance
LiMhos
it Ammonia
mg/I
as N
mg/I
Nitrite (NO2) as N
mg/I
Nitrate (NO3) as N
mg/I
Phosphorus: Total as P
mg/I
Al -Aluminum
mg/I
Ba - Barium
mg/I
Ca - Calcium
mg/I
Cd - Cadmium
mg/I
Chromium: Total
mg/I
Cu - Copper
mg/I
Fe - Iron
mg/I
Hg - Mercury
mg/I
K - Potassium
mg/I
Mg - Magnesium
mg/I
Mn - Manganese
mg/I
Na - Sodium
mg/I
RTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
12- 9 9®
ure of PermittAelthorized Agent*). Date
Ni.- Mckef-- mg/I
Pb - Lead mg/I
Zn - Zinc mg/I
Pesticides/Herbicides
(Specify Compounds)
ug/I
ug/I
ug/I
Other (Specify Compounds and
Concentration units)
1/Sl�l l wQs A C . .
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
' See back for Instructions.
" Submit blue and yellow copies only to address above.
i9 REV. 8/96

Type or Use a ball-point pen and press firmly. PERMIT Non-DisNUMBER: (RE®UIREQ) charge ®� I C*)% 7
411ty Name NPDESy�/ C'r•
Address 'e'- ®x TYPE OF DISPOSAL OPERATION BEING MONITORED
«(c . =� 1 1� County ®� n (REQUIRED)
II Location T LQn c rl --r Lagoon Septic Tank/Drain Field
II Identification Number, Well Depth t i Ft.
_v Spray Field Subsurface Low -Pressure
11 Diameters —Sample (Screened) Intervai--�;—>0 Ft. TO.5 Ft. Piping(LPP)
)th to Water Level ft. below measuring point (before sampling) Land Application of Sludge"
Other
asuring point is ft. above land surface Rotary Distributor
Ions of water pumped/bailed before sampling
Id Analysis: pH Specific Conductance uMhos Temp. °C Odor Appearance
e Sample Collected Date Lab Sample Analyzed_
oratory Name Certification No.
MPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES NO
)D
mg/i
Nitrite (NO2) as N.
,Mg/(...,...Ni. - NlckeI
mg/I
mg/l
liform: MF Fecal
liform: MF Total
/100ml
/100ml
Nitrate (NO3) as N
Phosphorus: Total as P
mg/I
mg/I
Pb - Lead
Zn - Zinc
mg/l
I®: uss MPN method for highly turbid samples)
;solved Solids: Total
mg/I
Al - Aluminum
Ba - Barium
mg/I
mg/i
Pesticides/Herbicides
(Specify Compounds)
(when analyzed)
units
Ca - Calcium
9/
mg/I
ug/I
ug/I
►C
loride
mg/I
mg/I
Cd - Cadmium
Chromium: Total
mg/I
ug/I
ienic
mg/I
Cu - Copper
mg/I
Other (Specify Compounds and
ease and Oils
mg/I
Fe - Iron
mg/I
mg/l
Concentration units)
wCQ 1 L °� "` 1
irdness: Total
mg/I
Hg - Mercury
g
enol
Ifate
mg/I
mg/I
K - Potassium
Mg - Magnesium
mg/I
ecific Conductance
uMhos
Mn - Manganese
mg/I
mg/l
tal Ammonia
mg/i
Na - Sodium
;N as N
mg/l
ERTIFY AT THIS REPORT IS TRUE AND ACCURATE.
Note:
Values should reflect dissolved and
colloidal concentrations. (see #3 on back]
See
back for Instructions.'lr
fnat of Permittee. (or Authorized Agent*)
Date
'* Submit blue and yellow copies only to address above.
if -`REV, 8/96

Type or Use a ball-point pen and press firmly. PERMIT NUMBER. (REQUIR I
Non-Dis
y e
flL`-f• DEScharge
NamNP
kddresSI&LI TYPE OF DISPOSAL OPERATION BEING MONITORED
/\ i
(REQUIRE®) Septic TanIdDrain Field
Lagoon
.in:auVIN SU Ft.
Jentification Number �__ Well Depth Spray Field Subsurface Low -Pressure
Piping (LPP)
)iameter V' Sample (Screened) Interval. Ft. To _Ft. Land Application of Sludge
to Water Level =ft• below measuring point (before sampling) Other
wing point is--ft• above land surface Rotary Distributor
is of water pumped/balled before sampling �•'S o prior ( Appearance_LLCI..r
Analysis: pH _LLSL—S ecifi Conductance %Date Lab Sample Analyze uMhos Temp.
if
sample Collected W
Certification No.
atoryName
ILES FOR METALS WERE C LLECTED UNFILTERED AND FIELD ACIDIFIED _.),/_YES NO
mg/I
Drm: MF Fecal
/100ml
Drm: MF Total
/100ml
Use MPN method for highly turbid samples)
Aved Solids: Total SrQ . 0 mg/I
nrhen analyzed)
�
mgll
ride
mg/I
nic
mg/I
ise and Oils
mg/I
Iness: Total
mg/I
iol
mg/
ate
g
;ific Conductance
uMhos
Ammonia
11
m /I
Nitrite (NO2) as N
mg/l
Nitrate (NO3) as N
mg/I
Phosphorus: Total as P
mg/I
Al - Aluminum
Ba - Barium
Ca - Calcium
mg/I
Cd - Cadmium
mg/I
mg�I
Chromium: Total
Cu - Copper
3•-_4 ISO
g
mg/I
Fe - Iron
Hg - Mercury
mg/mg/I
K - Potassium
mg/I
Mg - Magnesium
Mn - Manganese
mg/I
Na -Sodium
Ni - Nickel mg/I
Pb - Lead • ®1® mg/I
Zn - Zinc mg/1
Pesticides/Herbicides
(Specify Compounds)
Other (Specify Compounds and
Concentration units)
ug/I
ug/I
ug/I
as N g
RTIFY yIAT THIS REPORT IS TRUE AND ACCURATE. Note: -Values should reflect dissolved and
colloidal concentrations. (see #3 on back) `
Permittee (or Authorized Agent*)
' See back for Instructions. �•
Date ** Submit blue and yellow copies only to address above.
8/96

Order # B8-11-408
Page 15
22102198 25:38
TEST RESULTS BY SAMPLE
Sample Description: MW-6
Lab No: 04B
Test Description: VDCs by WINS
Method: SPA 8260E Test Code: 8260AW
Collected: 1111719B 11:I5
PARAMETER RESULT
PQL
Q
Acetone
BDL
20
U
67-64-1
Acrolein
BDL
20
U
207-02-8
Acrylonitrile
BDL
10
U
17-13-1
Allyl chloride(3Chloropropene)
BDL
2
D
107-05-1
Benzene
BDL
1
U
71-43-2
Bromobenzene
BDL
I
U
208-86-I
Bromochloromethane
BDL
I
U
74-97-5
Bromodichloromethane
BDL
I
U
75-27-4
Bromoform
BDL
I
U
75-25-2
Bromomethane
BDL
I
U
74-83-9
2-Butanone(Methylethyl ketone)
BDL
10
U
78-93-3
n-Butyl benzene
BDL
I
U
104-51-8
sec -Butyl benzene
BDL
I
O
235-98-8
tart -Butyl benzene
BDL
I
U
98-06-6
Carbon disulfide BDL
2
U
75-IS-0
Carbon tetrachloride
BDL
I
U
56-23-5
Chloroacetonitrile BDL
50
U
207-14-2
Chlorobenzene
BDL
i
U
108-90-7
i-Chlorobutane
BDL
2
U
109-69-3
Chloroethane
BDL
I
U
75-00-3
Chloroform
BDL
I
U
67-66-3
Chloromethane
BDL
I
U
74-88-4
2-Chlorotoluene
BDL
I
U

order 8 BB-11-408
Page 16
12102198 15:38 TEST RESULTS BY SAMPLE
Sample Description: MV-6
Lab No: 04B
Test Description: VOCz by GCIMS
Method: EPA 8260B Test Code: 8260AW
`. Collected: 11/17/98 11:15
95-49-8
4-Chlorotoluene
BDL
1
U
106-43-4
1,2-Dibromo-3-chloropropane
BDL
2
U
96-12-8
Dibromochloromethane
BDL
1
U
124-48-1
1,2-Dibromoethane
BDL
I
U
106-93-4
Dibromomethane
BDL
1
U
74-95-3
1,3-Dichlorobenzene
BDL
1
U
541-73-1
1,2-Dichlorobenzene
BDL
Z
U
'
95-50-1
1,4-Dichlorobenzene
BDL
1
U
106-46-7
Y
trans-1,4-Dichloro-2-butene
BDL
2
U
110-97-6
DichlorodifIuoromethane CFC-12
BDL
Z
U
75-71-8
1,1-Dichlorcethane
BDL
1
U
75-34-3
1,2-Dichloroethane
BDL
I
U
207-06-2
cis-1,2-Dichloroethene
BDL
1
U
156-59-2
trans-1,2-Dichloroethene
BDL
I
U
156-60-5
I,I-Dichlorcethene
BDL
1
U
75-35-4
2,1-Dichloropropanone
BDL
50
U
513-88-2
1,3-Dichloropropane
BDL
1
U
142-28-9
1,2-Dichloropropane
BDL
Z
U
78-87-5
2,2-Dichloropropene
BDL
5
U
590-20-7
1,1-Dichloropropene
BDL
2
U
563-58-6
cis-1,3-Dichloropropene
BDL
1
U
542-75-6
trans-1,3-Dichloropropene
BDL
I
U
542-75-6
Diethyl ether (Ethyl ether) BDL
2
U
60-29-7
Ethylbenzene
BDL
1
U
100-41-4

Order # B8-11-408
Page 17
12102198 I5:38 TEST RESULTS By SAMPLE
Sample Description: MM-6
Lab No:
04B
Teat Description: VOCs by GC/NS
Method: EPA 8260D Teat Code: 8260AW
-• Collected: 11/17/99 I1:15
Mexachlorobutadiene
19DL
i
s7
87-68-3
Ethyl methacrylate
BDL
10
U
97-63-2
2-Hexanone
BDL
10
U
591-78-6
Mexachloroethane
BDL
10
U
67-72-1
Isobutyl Alcohol
BDL
I
V
78-83-1
Isopropylbenzene
BDL
I
U
98-62-8
p-Isopropyl toluene
BDL
1
p
99-87-6
Methacryloni.trile
BDL
20
U
_- 126-98-7
Methyl acrylate
BDL
10
U
96-33-3
Methyl iodide (Iodometbane)
BDL
2
_U
74-88-4
Methyl methacrylate
BDL
10
U
80-62-6
Methyl tent -butyl ether (M EE)
BDL
I
U
1634-04-4
4-Methyl-2-pentanone (MIBX)
BDL
10
U
108-10-1
Methylene chloride
BDL
5
U
75-09-2
Naphthalene
BDL
5
U
91-20-33
Hitrobenzene
BDL
50
U
98-95-3
2-Nitropropane
BDL
50
V
79-46-9
Pettachloroethane 8DL
50
V
76-01-7
Propionitrile
BDL
• 1D7-12-0
n-Propylbenzene
BDL
o 1
U
103-65-I
Styrene
BDL
I
U
100-42-5
1,1,1,2-Tetrachloroethane
BDL
1
V
630-20-6
1,1,2,2,-Tetrachloroethane
BDL
��
U
79-34-5
Tetrachloroethane
BDL
- Z
U
127-18-4
Tetrahydrofuran (TFIF)
BDL
��
p

Order 8 B®-11-408
Page 18
12/02/98 15:38 TEST RESULTS BY SAMPLE
Sample Description: MW-6
Lab No: 04B
Test Description: VOCs by GC/MS
Method-- EPA 8260B Test Code: 8260A&l
Collected: 11117198 11:15
209-99-9
Toluene
BDL
1
U
108-88-3
1,2,3-Trichlorobenzene
BDL
I
U
87-61-6
1,2,4-Trichlorobenzene
BDL
1
U
a
120-82-1
1,1,1,-Trichloroethane
BDL
1
�f
71-55-6
1,1,2-Trichloroethane
BDL
1
U
79-00-5
Trichloroethene
BDL
1
U
79-01-6
1,2,3-Trichloropropane
BDL
1
�f
96-18-4
1,2,4-Trimethylbenzene
•�
BDL
1
U
95-63-6
1,3,5-Trimethylbenzene
BDL
1
U
95-47-6
TrichIorofluoromethane CFC-11
BDL
1
U
75-69-4
Vinyl Chloride
BDL
1
U
75-01-4
Total Xylenes
BDL
1
1330-20-7
p-Dioxane
BDL
25
U
e
123-91-1
Vinyl Acetate
BDL
2
U
Isopropyl ether
BDL
2
U
SURROGATE *RECOVERY
LIMITS
Dibromofluoromethane 96
82 -
136
1,2-Dichloroethane-d4 90
82 -
130
= Toluene-d8 99
84 - 119
4-Bromof2uorobenzene 97
84 -
121
Notes and Definition& for this agport:
DATE RUN i�1/25/98
ANALYST jLS
INSTRUMENT 5971E
FILE ID
CONC FACTOR
1
UNITS uv/L

Recordlle.
ody
NC
7(8278L)254JI'69
O Norcross. OA
O Chuloue.NC• 0 Frankfort KY 0 Marrlaville.NC
�70) 36t1.0636
(701) 392-116t (.iQ2) 223.0231 (919) 3�9699
1
CI Lumberton. NC
0 Lexington, SC 0 lldswon. CO 0 Maw• CIA
0 Orlando. FL
(910) 73"!90
[phone] (303) 65M97 (912) 737-0=11
(407111131.2560
Client:
project No.:
t REQUESTED PAILAbWERSPQ
Report Address:
Invoice Address:
?r
I nl
A ■ AslietrlllePIC
W
Cm Charla te. NC
C.,rica IrJ
CGY215cl
D w Denier. CO
At : t .
An :
a. LalnaU®rt. SC
O - Mc
Phone No.:
® _
Sampled Ely:.
M �
�
WOM
K s FrertNoat. KY
Fax No.,
?pa -7 — cl
P.O. Her
L a Lumberton. NC
M= Morrisville. NC
TURNAROUNDTIME
\
0 = Orlando, FL
O 24 Haws O 49 Hours
So Subcontracted
13 3 Days 0 10 Days Dale Needed:
Sample ID Date I Mme I r e I 111atris �—' REMARKS
wall MOM W-MMM,
WHO
!!�dlwLiel
COMMEIM:
Relinquished By a JL' ruse r Itaeei•ed ®r--r. Lf / ^
Relinquls�ed By: Darot nrar OMM ®C. Time
lime
Relinou. A Bv: Dra line Ri+ealwIll ®, Dale

Certified Mail -Return Receipt Requested
January 5, 1999
To: Division of Water Quality -Groundwater Section
PO Box 29578
Raleigh,. NC 27626-0578
From: Kirby Atwood, Compliance Coordinator
Finetex Inc. - Permit Number WQ0001077
PO Box 164
Spencer, NC 28159
Sir,
I am submitting this letter as a follow-up to my December 30th cover -letter =
submitted with our GW-59 monitoring well reports. The cover letter stated that we had
detectable amounts of styrene reported from our VOC analysis in two monitoring wells.
We do not presently use any styrene at our facility or at any time during the past. The
wells were re -sampled to confirm the VOC results. Results from the re -samples did not
have any'detectable styrene or any other VOC.
We believe that the original samples were contaminated during sampling or at the
laboratory and are not reflective of our groundwater quality. Please contact me at (704)
633-8028 ext. 209 with any questions or concerns.
Thank you,
Kirby Atwood
rrKTRTPx iNC__ P.O. Rox 216_ ELMwnnn PARK mm MRSEY 07407 f201) 797-4686 PAY. f2nn 747-A.FMA

SPECIALIZED ASSAYS, INC.
2960 Foster Creighton Dr.
P.O Box 40566
Nashville, 9N 37204-0566
Phone [phone]
.,TATESVILLE ANALYTICAL 6445
)ENA MYERS
=.22 COURT STREET
3TATESV I LLE, NC
7ro ject:
iro ject fame:
Samp I ea~:
ANA1_lrT I CAL_ RE=-PO-RT
Lab Number: 98-A161316
Sample ID: 03-1216-1
Sample Type: Ground eater
28677 Site ID:
Date Collected:
Time Collected:
Date Received: 12/17/98
Time Received: 9:00
bport Wan, oil
Aaalgte Result units U tit Unit Factor Date Tine Aaalgst Method Bitch
*UGLATILE DRCAN .3A
kc$tone
HD
ug/1
2
2
1
12f24/9D
17:41
J.Haleg
8m
3364
_
Benzene
NO
ug11
0.4
0.4
1
12/24/98
17:41
J.Haleg
no
3364
Brinobea ene
No
u111
2
2
1
12124198
17:41
J.Haleg
8260E
3364
Branach€arnetethane
NO
ugll
0.4
0.4
1
12124/98
17:41
J.Haleg
8260E
3364
Branofarn
No
ug11
0.4
0.4
1
IV24M.
17:41
J.Haleg
8260B
3364
_._ Branonethane
RD
ug11
2
2
1
12124198
17:41
J.Haleg
8260E
3364
"2-Butinese
NO
u1/1
2
2
1
12IM98
17:41
J.Haleg
MOD
3364
Wit►-Butglhenzeae
No
ugll
4.4
0.4
1
LVM98
17:41
J.Ha€eg
8260E
336
see-8utglbenzene
HD
u911
0.4
e.4
1
12/24/98
17:41
J.Halif
82608
3364'
t-Butglbenzene
Ho
ugfl
0.4
0.4
1
12/s4/98
17:41
J.Haleg
em
3364
Carbon disulfide
No
ug11
0.4
0.4
1 .
12/24/98
17:41
J.Haleg
8268E
3364
Carboa tetrachloride
go
u111
0.4
0.4
1
12124f98
17:41
J.Haleg
em
3364
Chlerobeezene
No
ugil
0.4
0.4
1
W24/98
17:41
J.H"
82608
3364
Chlaroethana
NO
ug11
0.4
0.4
1
IV24/98
17:41
J.Haleg
8268E
3364
2-4"bloro¢thglvinglether
8o
ug/l
0.4
0.4
1
12124/98
17:41
J.Haleg
820
3364
Chloroforn
RD
uq/1
0.4
8.4
1
W24M
17:41
J.Haleg
8260E
3364
Ch€orotsethana
RD
u9/1
0.4
0.4
1
12e74/98
17:41
J.Haleg
8260E
3364
2-Cblorotoluene
RD
ug11
0.4
4.4
1
12f24/98
17:41
J.Haleg
8260E
3364
4-Chloretaluene
RD
uq/1
0.4
0.4
1
12/24198
17:41
J.Haleg
82611E
3364
1,2-0ibrana-3-chlaropropane
RD
ug/1
2
2
1
12/24/98
17:41
J.Haleg
8260E
3364
Khronachloranethane
RD
11111
0.4
4.4
1
12/24/98
17:41
J.Haleg
8260E
3364
1,2-Dibrawc-thane
RD
ug/1
0.4
0.4
1
12f24198
17:41
J.Haleg
8268E
3364
Dibronanethane
RD
uq1€
0.4
0.4
1
12f24198
17:41
J.H"
82608
3364
. 1,2-0101orobeezene
RD
ugel
0.4
4.4
1
121".,
17:41
J.Haleg
82606
3364
1,3-Dieblorobeezene
RD
ugll
0.4
0.4
1
12/i4/98
17:41
J.Ha€eg
8260E
3364
1,4-01chlorrbenzetw
RD
u111
0.4
0.4
1
1=4/98
17:41
J.Haleq
BMD
3364
Diabiorodifl+toronethane
RD
u111
0.4
0.4
1
IVM90
17:41
J.Haleg
8260E
3364
1,1-01ehloraethana
No
ug11
0.4
0.4
1
12124/98
17:41
J.Haleg
82608
3364
1,2-oicbloraethane
RD
ug/1
0.4
0.4
1
12f24/98
17:41
J.Haleg
82608
3364
1r1 0LchlaraA.t 'he ne
RD
ugfl
0.4
0.4
1
12/24/98
17:41
J.Haleg
82608
3364
cis-1,2-Die"10roethene-
RD
u211
0.4
0.4
1
12124/9B
17:41
J.Ha3ey
8250E
3364
trans-1,2-oiaWroethene
HD
JVl
0.4
0.4
1
12/24/98
17:41
J.Haleg
8260E
3364
1,2-oiehlaraprapane
RD
ug/1
0.4
0.4
1
12M98
17:41
J.Haleg
8260E
3364
1,'roiehlarapropane
RD
ug11
0.4
0.4
1
IVM98
17:41
J.Haleg
8260E
3364
2,2-oieblar�prapar.e
RD
ug/l
0.4
0.4
1
12/24198
17:41
J.Haleg
8260E
3364
1,1-Dichlorraprouene
HIt
ug; l
4.4
0.4
1
12,12419E
17:41
J.Hzleg
8260B
3364
�.c -t 1-hinklnrrta7,rnD&P
RD
::erl
A 4
R 4
1
12I24/9ft
17-41
J-Halou
RUM
IlAd

SPECIALIZED ASSAYS, INC.
2960 Foster Geighton Dr.
E Q Box 40566
Nashville, TN 37204-0566
Phone [phone]
AN^L_YT I C ^L_
REPORT
Laboratory dumber: 96-AI61316
Sample ID: 03-1316-1
Page 2
fieport
Ouan
oil
pnalgte
Fesult
Anita
Unit
knit
factor
Date
Tine
pnalgst
rethod
Bitch
trans-1,13 �ishlar PMfeae
NO ------
Vill N
0.4
0.4
1
IVM98
17:41
J.Haleg
am
3364
3364
Ethglbenzene
RD
Vill
0.4
0.4
1
2MI98
17:41
J.Haleg
82608
3364
Herachlorohutadiene
RD
Vill
0.4
8.4
1
1
121.?4/98
12124198
17:41
17:41
J.Haleg
J.Haley
82608
82608
3364
2-Hexanoae
I-sopropglheftaeae
RD
RD
Vill,
will
2
0.4
2
0.4
1
12124/98
17:41
J.Hdey
82608
WA
4-I-aopropy1toluene
RD
ugll
0.4
0.4
1
1
12124/98
W24198
17:41
17:41
J.Haleg
J.Haleg
8260E
82608
3364
3364
4-11f?thy1-2-pentanone
RD
RD
ugll
Vill
2
2
2
2
1
W24/90
17:41
J.Haleg
82600
3364
Methylene chloride
RD
ugll
0.4
0.4
1
12124/98
17:4
J.Haleg
8260E
3364
naphthalene
n-Propylhenzene
RD
Vill
0.4
0.4
1
12124/98
17:41
J.Haleg
82608
3364
Styrene
RD
VIA
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IV24/98
17:41
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02608
3364
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J.Haleg
82608
3364
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17:41
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RD = Not detected at the report lint.
Surrogate 1. Recoverg target Range
VD►! Surrogate, i,i-uicfiiorceihane, M 12?. M. - 131.
VIM Surrogate, Toluene d8 102. 03. - 315.
V(i0 Surrogate, 44(rcnoFluorchenLene 106. 73. - 1#9.

SPECIALIZED ASSAYS, INC.
2960 Foster Creighton Dr.
P.O. Box 40566
Nashville. TN 37204-0566
Phone [phone]
^N^L.VTICr^LL RI=PMRT
Laboratory Number: 98—AI61316
Sample ID: 03-1216-1
Page 3
Report Approved By: Report Date: 12/31/98
Theadore J. Duello, Ph.D., Q.A. Officer
Michael H. Dunn, ".S., Technical, Director
Danny B. Hale, M. S. , Laboratory Director
Js3hnny A. {Mitchell, Dip. Technical Services
Laboratory Certification number: 387

SPECIALIZED ASSAYS, INC.
296o Foster Creighton Dr.
P. O. Box 40566
Nashville, IN 37204-0566
Phone [phone]
r ec :
er•:
Prhlt= L-V-rICAL RMPORT
6.443 Lab Number: 99-A161317
Sample ID: 03-1216-2
Sample Type: Ground water
Site ID:
Date ::ollected:
Time Collected:
Irate Received: 12/17/98
Time Received: 9:00
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SPECIALIZED ASSAYS, INC.
2960 Foster Creighton Dr.
P. O. Box 40566
Nashville. TN 37204-0566
Phone [phone]
^M^L-YT I Cr ^L- R MP OR T
Laboratory Number: 178-A161317
_ . Sample €€}: 03-1216-2
Page 2
Lit!Lt
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SPECIALIZED ASSAYS, INC.
2960 Foster Creighton Dr.
Nashville. TN 37204-0566
-
Laboratorg Number: 98—A161317
Sample II}: 03-1216-2
Fage 3
�eport Auproved SuReport Date: 12/31/98
Thecdore J. Duel-10, Ph.D., O.A. Officer
Michael ��. �unn. rf%.S., Technical Director
�asuy B. NuIe, MS., Laboratory Director
Johnn� A' Mitchell, Qir. Technical Services
Laboratorg Certification Number: 387

Client :''*', °
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SrATESVILLE ANALYTICAL
122 Couit Sheet' • .286 Box 228
�E f
s.:+..r> l�,
f :_ �'�
Stetesville,NC28687
87 2�4647
i
Address:
',
.
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•
Contact Person• .' ��
�p�
Phone . "` �:!•�•- L3 3-
a fAx iCA- . L -� lla
G`t[stod Record
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e Date)
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' •''
"•):.
Requlsitfoned
(Lab use on
Customer
ed
Preservative Matrix
�.
Parameters requestedaorenalgsls
>`
Arrival pH Analyzed
Tern . ed
ID a
sample ID # TI
a Da a
Lab use on r• e
IV
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Preservative Codes:
1. HNO3
2. HCI
3. NaOH
4. H2SO4
5 Na2 S2 04
6. Chemicals In containers, lab.
7. Chemicals in containers, client
8. Chemicals added upon receipt
9. Received on Ice, <•4.0"C
10. Samples delivered as soon as pulled
ii11. Samples chilled upon receipt
)12. Dchlop- '9d
/
Rhlinquished by: - 5 C� Sampled by:
Transported via:
Received by: Time/Date— 6 LO
Reliriqulshed by: TimelDate Holding times met:
•
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Non-compilahce work:
Lab Comments:

Operator Check Sheet for Preventative Maintenance
of Wastewater Operations Equipment (Complete Daily)
Date : Operator:
L 4 Acre Field No.1 Inspection and Operational Activities
Field No. 1(4 acres) Spray Time: Inspection of lines and spray heads at the
start of each use. Lines: Spray Heads : Time:
Inspection of field: Field maintenance performed:
II. .85 Acre Field No.1 through No. 5 Inspections and Operational Activities
Field No. 1 Amount Sprayed: All valves opened on field at the start of each .use. Valves
Opened, Flushed, Closed: All discharge openings in lines are spraying correctly:
Inspection of field: Field maintenance performed:
Time:
Field No. 2 Amount Sprayed: All valves opened on field at the start of each use. Valves
Opened, Flushed, Closed: All discharge openings in lines are spraying correctly:
Inspection of field: Field maintenance performed:
Time:
Field No. 3 Amount Sprayed : All valves opened on field at the start of each use. Valves
Opened, Flushed, Closed: All discharge openings in lines are spraying correctly
Inspection of field: Field maintenance performed:
Time:
Field No. 4 Amount Sprayed: All valves opened on field at the start of each use. Valves
Opened, Flushed, Closed: All discharge openings in lines are spraying correctly
Inspection of field: Field maintenance performed:
Time:
Field No. 5 Amount Sprayed : All valves opened on field at the start of each use. Valves
Opened, Flushed, Closed: All discharge openings in lines are spraying correctly:
Inspection of field: Field maintenance performed:
Time:
M. .85 Acre Field Related Equipment
-; Storage tank, pumps, and piping are in good working condition
VL Primary Effluent Discharge Equipment
Pumps and lines are in good working condition:
V. Wastewater Clarifier and Related Equipment
All pump motors, clarifier motor, and chemical feed pumps greased per quarter: Date Last
Greased :
Revised 11-1-99
ell',

State of North Carolina
Department of Environment
and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
William E. Holman, Secretary
Certified Mail
Return Receipt Requested
Finetex, Incorporated
Post Office Box 164
Spencer, North Carolina 28159
Attention: Mr. Emmett K. Atwood
Dear Mr. Atwood:
N CDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
October 25, 1999
Subject: Notice of Violation and Recommendation for Enforcement
Permit No. WQ0001077 and NCGS 143-215.1
Finetex, Inc., 775 Hackett Street
Spencer, Rowan County
Finetex, Incorporated (Finetex) was issued -Permit No. WQ0001077, effective April 20, 1998,
for the continued operation of a 18,000 GPD spray irrigation and disposal facility. Based upon site
visits conducted by personnel from this Office on September 30th and:October lst 1999, the Division has
reason to believe that you are responsible for activities resulting in noncompliance with North Carolina
Law and the subject Permit. In particular, the following violations of the existing permit conditions
were observed:
Violation of Permit Condition "I. I." — This Office's file does not contain a certification from
a professional engineer (PE) certifying that the drip field facility was installed in accordance with the
permit, the approved plans and specifications. The facility did not appear to be constructed in
accordance with the application specifications. In particular, the wastewater distribution system in the
application was designed at a pump rate of 30 gpm, while 60 gpm pumps were installed at the facility.
In addition, some of the drip lines were placed on semi -impervious to impervious surfaces such as the
gravel driveway. You should be aware that Permit Condition "VI. 1." states, "The permit shall become
voidable unless the facilities are constructed in accordance with the conditions of this permit, the
approved plans and specifications, and other supporting data."
Violation of Permit Condition " I.6." — During the site visit on September 30th DWQ staff
observed that the clarifier, the flocculation tank and the polymer feed system were not in operation.
During a subsequent phone conversation, Mr. Atwood stated that the clarifier and flocculation
equipment were not utilized if the wastewater were to be disposed of through irrigation. The permit
was issued with the understanding that this equipment would be utilized in the treatment of the
wastewater prior to irrigation. Not operating this equipment is considered a bypass of the treatment
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

UNITED STATES POSTAL SERVICE First -Class Mail
Postage & Fees Paid
LISPS
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Finetex Inc - NOV+ October 25 1999 Page 2 of 3
facilities and is prohibited by the permit. In addition, a small stream of cloudy wastewater was
observed flowing from an earthen berm located at the western corner of the aeration basins. The stream
flowed approximately 50 feet before infiltrating into the soil. Watermarks around the stream indicate
that the flow was greater prior to the site visit. Wastewater may be bypassing the treatment system
through holes or other imperfections in the earthen liner enclosing the aeration basins.
Violation of Permit Condition IT 7. b)" — During the September 30`h site visit, DWQ
personnel observed a mixture of stormwater and wastewater flowing off of the easternmost drip
irrigation field. The runoff appeared to enter into the eastern property buffer. Hydrology indicators in
the area, suggest that runoff has consistently flowed off of.the drip field and into the buffer area.
Violation of Permit Condition I'll. 1." - The facility did not appear to be operated and
maintained properly. The drip irrigation field was in poor condition. Many areas were barren of
vegetation and/or inundated with standing water. Several drip lines were observed to be overlapping
(should be 31 feet apart). The sample results of the treatment system effluent report wastewater
constituent concentrations in excess of the achievable limits specified in part "V. 14." of the July 1997
drip irrigation system application. In addition, the clarifier and flocculation units were not in operation.
Violation of Permit Condition I'll. 3." — Several areas within the drip irrigation fields were
without suitable vegetative cover.
Violation of Permit Condition "II.4." = Based on the application records submitted by
Finetex to this Office, Finetex has applied to the irrigation fields during inclement weather on multiple
occasions. From May through August 1999, Finetex applied to at least one irrigation field during 20 of
the 28 working days in which precipitation was reported. Mr. Atwood stated that the drip field had
received wastewater during similar circumstances prior to this Office's September 30`h site visit. The
condition of the drip field observed during the September 301h site visit was indicative of irrigation
during inclement weather.
Violation of Permit Condition "II.S." — Runoff was observed on September 30`h from the
easternmost application field of the drip irrigation system.
Violation of Permit Condition "II. 7." — Drip lines that are not separated by 31 feet or are
operated at pumping rates above the design rate of the drip irrigation system (as described in the 1997
application for the drip fields) may exceed the application rate of 0.25 inches per hour.
Comment regarding Permit Condition I'll. 10." — While equipment is allowed on the
application fields during maintenance activities, the permittee should be careful when operating the
equipment in order to avoid compaction of the soils that may retard and reduce the infiltration rates of
the soils in the application fields. Several tire ruts and other evidence of compaction were observed in
the drip irrigation fields.
Violation of Permit Condition "IV. 2." — The November 1998 groundwater quality sampling
and analysis report submitted to the Division's Groundwater Section did not contain the laboratory
analytical results for the volatile organic compounds analysis.

9
Finetex Inc. - NOV ' y October 25 1999 Page 3 of 3
Violation of Permit Condition "V. 2." — The permittee does not appear to be adequately
inspecting the wastewater treatment facilities. While Finetex possessed a form documenting equipment
repair activities, an adequate inspection log was not available. Finetex should be inspecting the
irrigation fields as well as the equipment. Finetex should begin keeping an inspection log that at a
minimum includes: the date and time of inspections; any observations made (field wet, pools of water,
etc.); all maintenance activities (mowing, pipe moving, parts, etc.); and any additional corrective
actions. The logs must be maintained for three years.
At this time, this Office is considering recommending enforcement for the violations described
in this Notice. North Carolina General Statute (NCGS) 143-215.6A provides for a civil penalty
assessment of not more than twenty-five thousand dollars ($25,000) per violation, per day against any
person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to NCGS 143-215.1.
It is requested that you respond to this Notice in writing by November 5, 1999. Your response
should document any comments you may have regarding the violations cited in this Notice, any
corrective actions to prevent any similar conditions, and anticipated dates to complete the necessary
corrective actions. Your response will be considered prior to this Office's recommendation for
enforcement and will be included in any enforcement recommendation packages.. You should not apply
to the new drip field until the PE certification for the as -built specifications has been forwarded to the
Division, the field has been rehabilitated, the Division has re -inspected the facilities, and the Division
has provided written authorization that you may resume irrigation to the field.
If you have any questions regarding this matter, please contact Mr. Charley Schwartz or me at
[phone].
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachments: October 12, 1999 MRO Staff Report for proposed Aeration Basin Expansion
April 20, 1998 Spray Irrigation Permit
cc: Non -Discharge Compliance & Enforcement Unit
Bob Cheek, Groundwater Section, Central Office
Ellen Huffman
hAFineEnf.doc
CMS

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44

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Aio
ADM -
id
Standing wastewater and stormwater 10-0-99

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State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Linda Diane Long, Regional Manager
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
DEHNR
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 24, 1995
Finetex, Inc.
Post Office Box 164
Spencer, North Carolina 28159
Attention: Anthony F. Bolton, Dept. Manager
RE: Notice of Violation of Permit Conditions
Permit N4 WQ0001077/GW93148
Rowan County, N.C.
Dear Mr. Bolton:
A review of the subject permit and your November 7, 1994
compliance monitoring data indicates that you are in violation of
the following permit conditions:
Permit Condition N° IV 2 by failing to analyze the sample
from MW-2 for total organic carbon (TOC); and
Permit Condition N° IV 3 by failing, upon detection of.
volatile organic compounds (VOCs) in all three wells, to run
EPA Methods 604 and 611 to detect other organic compounds
which may be present.
You are requested to submit the required analysis for TOC
and VOC, as well as a clarification as to which method of
analysis is being used to measure VOC, within 60 days of receipt
of this letter or an explanation of why you cannot comply. It
should be noted that the violations cited above and any
additional documented violations could result in the initiation
of an enforcement action by this Office in accordance with
General Statute 143.215.6A, which provides for a $10,000
assessment of civil penalties for each violation. Each day that
the violations continue may be considered a separate violation.
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

a
Finetex, Inc.
January 24, 1995
Page Two
Should you have any questions concerning this Notice,
contact Peggy Finley at [phone], ext. 235.
Sincerely,
i h Overcas , P.E.
Re onal Supervisor
cc: Re-x-G.le.ason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh
MAF/sc

�- OF W ATF9
,off QDUG
—I
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Colleen H. Sullins, Director
Division of Water Quality
u
AQUIFER PROTECTION SECTION
June 5, 2008
Innospec, Inc.
PO Box 164
775 Hackett Street
Spencer, North Carolina 28159
Attention: Clay White, Operations Coordinator
RE: Spray Irrigation Inspection Report
Permit No. WQ0001077
Rowan County, N.C.
Dear Mr. White:
Enclosed you will find the report for the inspection that I conducted on May 20, 2008. This report
supersedes the report issued on May 23, 2008. The treatment and disposal system appears to be
operating satisfactorily at this time and the facility is in compliance with the referenced permit. The
report should be self-explanatory.
As we discussed, the Water Pollution Control Operators Certification commission needs to be notified
of the change in the Operator of Responsible Charge (ORC). In addition, Innospec, Inc. needs to
send a written request to the Division of Water Quality regarding the change in the contact person for
this permit.
Please feel free to contact me via phone [phone]) or email at: peaay.finley(o1ncmail.net if you
have any questions.
Sincerely,
Pe�gFlnley
Environmental Specialist
Enclosure: Inspection Report
Cc: David Goodrich — APS Land Application Unit, Raleigh
MAF/surface irrig/innospec inspect rpt 6-5-08
NorthCarol
Division of Water Quality / Aquifer Protection Section I Mooresville Regional Office Phone: [phone] Fax: [phone] a'a�ut,�h
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service: 1-877-623-6748 Internet: wmv.ncwaterquality.org �/ V

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Colleen H. Sullins, Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
City/Town/Owner: Innospec, Inc.
Permit # WQ 0001077
Issuance Date: 6/27/07
Permittee Contact: Kirby atwood
ORC Name: Kirby Atwood
Backup ORC: Clay White
Reason for Inspection
X ROUTINE COMPLAINT
County: Rowan
Expiration Date: 5/31/08
Telephone No. 704/639-7919
Telephone No. 704/639-7920
FOLLOW-UP OTHER
Type of inspection
Collection System X Spray Irrigation Sludge Other
Inspection Summary; (additional comments may be included on attached pages)
The treatment plant is operating satisfactorily. Both application areas appear to be in
excellent condition. Records and documentation are organized and up-to-date. Clay White
will be succeeding Kirby Atwood as ORC and contact person for the permit. The Division.
needs to be advised of these changes.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 FAX [phone]
Date of Inspection: 5/20/08

Ar
i
Spray Irrigation
Permit #WQ0001077
Type .
Activated Sludge Spray, low rate
Activated Sludge Spray, high rate
Activated Sludge Drip, low rate
X Lagoon Spray, low rate
Reuse (Golf Courses)
Recycle /Reuse
Single Family Spray, low rate
Single Family Drip
Infiltration System
Other
Page 2
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Treatment & Storage Lagoons (one 252,536 gal. and one 247,156 gal.)
Primary (check any/all that apply)
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N Vegetation (is there excessive vegetation on the lagoon bank
_Y_ Liner (if visible, is it intact)
_NA_ Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
Y Staff gauge (clearly marked)
_N_ Evidence of overflow (vegetation discolored or laying down/broken)
_N_ Unusual color (very black, textile colors)
Y Foam (are antifoam agents used)
_N Floating mats (sludge, plants, inorganics)
N_ Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Influent pump station
Y all pumps present, operational
Y Bar screen, maintained
—Y—Bars evenly spaced
_N _Back-up power
Bypass structure present
—Y—Free of excessive debris
—N—Bars excessively corroded
Flow Measurement -Influent
_Y_ Is flowmeter calibrated annually?
_Y_ Is flowmeter operating properly?
_Y_ Does flowmeter operate continuously?
_ Does flowmeter record flow?
Y Does flowmeter appear to monitor accurately?

1
Spray Irrigation Page 3
WQ0001077
Clarifiers
—Y—weirs level —Y—scum rack operational Y easily accessible
Filters N/A
media present air scour operational clear well free of solids
Disinfection NA
Is the system working? Is the system properly maintained?
Flow Measurement - Effluent
Y Is flowmeter calibrated annually?
Y Is the flowmeter operating properly?
Y Does the flowmeter monitor continuously?
Y_ Does the flowmeter appear to monitor accurately?
Effluent Storage
Spill control plan on site _Y
Residuals
Storage/treatment — Sludge is removed from 8,000 gal capacity tank approximately
every two weeks by Wallace Farms of Huntersville.
Disposal (final end use)
_N Is application equipment in need repair?
Y Are buffers adequate?
Y Are cover crops the type specified in permit?
_N_ Is cover crop in need of improvement?
_N_ Signs of runoff?
N_ Signs of ponding?
Y Is the acreage specified in the permit being utilized?
Y Is the application equipment present and operational?
N Are there any limiting slopes in disposal fields?
Y Are restrictions for use of these areas specified?
Y 'is permit being followed?
N Is there evidence of runoff or drift?
Y Are monitoring wells called for in permit present?
Y Is site access restricted in accordance with permit?
Comments: Application fields appear to be in excellent condition

Spray Irrigation
WQ0001077
page 4
Recordkeeping
Y Is permit available upon request?
Y Are monitoring reports present: NDIVIR X NDAR X
Y Are operational logs present?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are annual soil reports available?
Y Are operation and maintenance records present? Complete? Y
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: A copy of the soil fertility analysis will be forwarded to the regional office
when available. The annual loading report documents PAN calculation for each of the
application zones. The 2007 report was available for review.

0( William G. Ross Jr., Secretary
� North Carolina Department of Environment and Natural Resources
ply Alan W. Klimek, P.E. Director
> _ Division of Water Quality
O "C
AQUIFER PROTECTION SECTION
April 26, 2007
Innospec Performance Chemicals US Co.
PO Box 164
775 Hackett Street
Spencer, North Carolina 28159
Attention: Kirby Atwood, Env. Compliance Coordinator
RE: Spray Irrigation Inspection Report
Permit No. WQ0001077
Rowan County, N.C.
Dear Mr. Atwood:
Enclosed you will find the report for the inspection that I conducted on April 13, 2007. The treatment system is
operating in compliance with the referenced permit. The report should be self-explanatory but please contact
me via phone [phone]) or email at: peg�gxj.finleyCa)-ncmail.net if you have any questions.
Sincerely,
Pegg Finley
Environmental Specialist
Enclosure: Inspection Report
MAF/surface irrig/ innospec inspect rpt 4-26-07
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, NC 28115
One
Phone: [phone] Fax: [phone] NorthCarollna
Internet: http://gw.ehnr. state. nc.us Aaturallff

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
Owner: Innospec Performance Chemicals
Permit # WQ 0001077
Issuance Date: 10/31/02
Permittee Contact: Phillip Matena
ORC Name: Kirby Atwood
24hr Contact Name: Kirby Atwood
US Co County: Rowan
Expiration Date: 9/16/07
Telephone No. 704/633-8028
Telephone No. 704/633-8028
Telephone No. 704/213-4529 (c)
Beason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System X Spray Irrigation Sludge Other
Inspection Summary: (additional comments may be included on attached pages)
The treatment plant appears operating within permit conditions. Discharge of effluent to the
City of Salisbury sewer is authorized under a Local Non-SIU Discharge Permit. Flow limits
are 27,500 GPD daily maximum and 22,500 GPD monthly average. The application fields
are in generally excellent condition. Records and documentation are organized and up-to-
date.
Is a follow-up inspection necessary yes X no
Inspector Name/Title Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 Fax No. 7041663-6040
Date of Inspection: 4/13/07

Spray Irrigation
Permit #WQ0001077
Type
Activated Sludge Spray, low.rate
Activated Sludge Spray, high rate
Activated Sludge Drip, low rate
X Lagoon Spray, low rate
Reuse (Golf Courses).
Recycle /Reuse
Single Family Spray, low rate
Single Family Drip
Treatment
Page 2
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Treatment Flow Measurement —Influent
_Y_ Is flow meter calibrated at least annually?
_Y_ _ Is flow meter operating properly?
_Y_ Does flow meter monitor continuously?
Does flowmeter record flow?
Y Does flow meter appear to monitor accurately?
Treatment Flow Measurement — Water Use Records
Is water use metered?
Are the average daily flows calculated correctly?
Treatment Flow Measurement — Effluent
Y_ Is flow meter calibrated at least annually?
Y_ Is flow meter operating properly?
_Y_ Does flow meter monitor continuously?
_ Does flow meter record flow?
_Y Does flow meter appear to monitor properly?
Lagoons (one 252,536 gal. and one 247,156 gal.)
Primary (check any/all that apply)
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N Vegetation (is there excessive vegetation on the lagoon bank
_Y_ Liner (if visible, is it intact)
_NA_ Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
Y Staff gauge ( clearly marked)
_N_ Evidence of overflow (vegetation discolored or laying down/broken)
_N_ Unusual color (very black, textile colors)
Y Foam (are antifoam agents used)
_N Floating mats (sludge, plants, inorganics)
N_ Excessive solids buildup (from bottom)

Spray Irrigation Page 3
WQ0001077
Y Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Influent puma station
Y all pumps present, operational Bypass structure present
Y Bar screen, maintained —Y—Free of excessive debris
_Y Bars evenly spaced _N _ Bars excessively corroded
_N _Back-up power
Clarifiers
_Y weirs level —Y—scum rack operational —Y—easily accessible
Filters N/A
media present air scour operational clear well free of solids
Disinfection NA
Is the system working? Is the system properly maintained?
Tablets Gas Liquid
Effluent Storage
LAGOON SEPTIC TANK(s)_X ABOVE GROUND TANK
Volume: 20,000 gals. Spill control plan on site Y
Residuals
Storage/treatment — Sludge is removed from 8,000 gal capacity tank approximately every two
weeks by Wallace Farms of Huntersville.
Disposal (final end use)
_N_ Is application equipment in need repair?
Y Are buffers adequate?
_Y_ Are cover crops the type specified in permit?
_N_ Is cover crop in need of improvement?
_N_ Signs'of runoff?
_N_ Signs of ponding?
Y Is the acreage specified in the permit being utilized? .
Y Is the application equipment present and operational?
N Are there any limiting slopes in disposal fields?
Y Are restrictions for use of these areas specified?
Y Is permit being followed?
N Is there evidence of runoff or drift?
Y Are monitoring wells called for in permit present?
Y Is site access restricted in accordance with permit?
Comments: Much of application area now has a good grass cover.

f.
Spray Irrigation
WQ0001077
Page 4
Recordkeeping
Y Is permit available upon request?
Y Are monitoring reports present: NDMR X NDAR X
Y Are operational logs present?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are annual soil reports available?
Y Are operation and maintenance records present? Complete? Y
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment:

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
AQUIFER PROTECTION SECTION
March 7, 2006
Finetex — An Octel Company
PO Box 164
775 Hackett Street
Spencer, North Carolina 28159
Attention: Philip Matena, VP and General Mgr.
RE: Spray Irrigation Inspection Report
Permit No. WQ0001077
Rowan County, N.C.
Dear Mr. Matena:
Enclosed you will find the report for the inspection that I conducted on March 2, 2006. The treatment system is
in compliance with the referenced permit. The report should be self-explanatory but please contact me via
phone [phone]) or email at: pe.. y.finley(cD-ncmail.net if you have any questions.
Sincerely,
Peggy Finley
Hydrogeological Technician
Enclosure: Inspection Report
Cc: Kirby Atwood, Environmental Compliance Coordinator, Fintex w/enclosure
MAF/inspections/finetex 3-2-06
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, NC 28115
None Carolina
Phone: [phone] Fax: [phone] //�
Internet: http://gw.ehnr.state.nc.us V VV tUr�1

Spray Irrigation
Permit #WQ0001077
Type
Activated Sludge Spray, low rate
Activated Sludge Spray; high rate
Activated Sludge Drip, low rate
X Lagoon Spray, low rate
Reuse (Golf Courses)
Recycle /Reuse
Single Family Spray, low rate
Single Family Drip
Infiltration System
Other
Page 2
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Lagoons (one 252,536 gal. and one 247,156 gal.)
Primary (check any/all that apply)
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N Vegetation (is there excessive vegetation on the lagoon bank
_Y_ Liner (if visible, is it intact)
_NA_ Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
_Y Staff gauge ( clearly marked) .
_N_ Evidence of overflow (vegetation discolored or laying down/broken)
_N_ Unusual color (very black, textile colors)
Y Foam (are antifoam agents used)
_N Floating mats (sludge, plants, inorganics)
N_ Excessive solids buildup (from bottom)
Y Aerators/mixers operational (if present)
NA Effluent structure (free of obstructions, easily accessible)
Influent Dump station
Y all pumps present, operational Bypass structure present
Y Bar screen, maintained Free of excessive debris
_Y Bars evenly spaced Bars excessively corroded
_N _Back-up power

Spray Irrigation Page 3
WQ0001077
Aeration Basin
Y aeration pattern even across surface of unit
Y easily accessed
Clarifiers
_Y weirs level —Y—scum rack operational Y easily accessible
Filters N/A
media present air scour operational clear well free of solids
Disinfection NA
Is the system working? Is the system properly maintained?
Tablets Gas Liquid
Effluent Storage
LAGOON SEPTIC TANK(s) X ABOVE GROUND TANK
Volume: 20,000 gals. Spill control plan on site Y
Residuals
Storage/treatment — Sludge is removed from 8,000 gal capacity tank approximately every
two weeks by Wallace Farms of Huntersville.
Disposal (final end use)
_N_ Is application equipment in need repair?
Y Are buffers adequate?
_Y_ Are cover crops the type specified in permit?
_N_ Is cover crop in need of improvement?.
_N_ Signs of runoff?
N_ Signs of ponding?
Y Is the acreage specified in the permit being utilized?
Y Is the application equipment present and operational?
N Are there any limiting slopes in disposal fields?
Y Are restrictions for use of these areas specified?
Y Is permit being followed?
N Is there evidence of runoff or drift?
Y Are monitoring wells called for in permit present?
Y Is site access restricted in accordance -with permit?
Comments: A good deal of tree clearing has taken place. Much of application area now
has a good grass cover. .

Spray Irrigation
WQ0001077
Page 4
Recordkeeping
Y Is permit available upon request?
Y Are monitoring reports present: NDMR X NDAR X
Y Are operational logs present?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are annual soil reports available?
Y Are operation and maintenance records present? Complete? Y_
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment:

03/17/2003 15:09 6337566
PAGE 01
'inet
Date
Number of pag
sheet
To:
Pc
x Inc.'
—I 7~ 3
as including cover
;
Phone
Fax Phone
CC.
PO Box 164
Spencer, NC 20159
From:
Kirby Atwood
Phone (704) $33 - 8028
Fax Phone (704) 633 - 7666

03/17/2003 15:09
W ATER
6337566
PAGE 02
EDGE EN-ARONMENTAL, LLC
3 POMONA DRIVE, SurTE L a GREENSBORO. NC 27407. PHONE [phone]= a FAX [phone]
March 14, 2003
Mr. Kirb Atwood
Firnetex, nc.
PO Box 64
Spencer, North Carolina 28159
Certification of Monitoring Well Locations
Finetex, Inc. Spray Irrigation System
Rowan County, North Carolina
WQ0001077/GW02140
Dear Mrl Atwood:
Waters Edge Environmental, LLC (Waters Edge) is pleased to provide this certification
of the locations of the newly installed groundwater monitoring wells at Sprayfield #1 and
Sprayfie d #2 at the Finetex, Inc. facility located in Rowan County, North Carolina.
Waters ge personnel recently inspected the locations of the newly installed wells and
verified that the locations are consistent with the locations indicated in the enclosed
maps.
Waters Uge appreciates the opportunity to continue to provide environmental consulting
services to Finetex, Inc. If you have any questions or require any additional information,
please ckatact us at [phone].
WA EDGE ENVIRONMENTAL, LLC
Edward . Kuhn, L.G.
Senior ject Manager
Emkonmeidel Consult nft

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02/20/2003 16:16 6337566
PAGE 01
Finetex Inc.
Date - :. ? -- -;:z C-) - 0'3
Number of pages including cover
sheet
To:
Phone
Fax Phone
CC:
From:
PO Box 164
spencer, NC 20159
Kirby Atwood
Phone (704) 633 - B028
Fax Phone (704) 633 - 7666
❑ Urgent For your review ❑ Reply ASAP ❑ Please comment
`V" ems(
P rI
� OQ CSC c� SS i �'l -'t'�l� morn' nS
-Fn, nk5
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02/20/2003 16:16 6337566 PAGE 02
WATERS EDGE ENVIRONMENTAL, LLC
302 POMONA DRIVE, SUITE L a GREENSBORO, NC 27407 • PHONE [phone]M3 • FAX [phone]
February 12, 2003
Mr. Kirby Atwood j
Finetex, Inc. 8 ?002
PO Box 164
Spencer, North Carolina 28159
Reference: Certification of Monitoring Well Locations
Finetex, Inc. Spray Irrigation System
Rowan County, North Carolina
WQ0001077/GW02140
Dear Mr. Atwood:
Waters.Edge Environmental, LLC (Waters Edge) is pleased to provide this certification
of the locations of the newly 'installed groundwater monitoring wells at Sprayfield #1 and
Sprayfield #2 at the Finetex, Inc. facility located in Rowan County, North Carolina.
Waters Edge personnel recently inspected the locations of the newly installed wells and
verified that the locations are consistent with the locations indicated in the enclosed
maps.
Waters Edge appreciates the opportunity to continue to provide environmental consulting
services to Finetex, Inc. If you have any questions or require any additional information,
please contact us at [phone].
Sincerely,
WATERS EDGE ENVIRONM"$A ',•
i
NSEO q
SEAL _
Edward M. Kuhn,L.G. c 1452
Senior Project Manager
F �.�FOtoo��J��
Enclosures ''J, '4HD M'
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OF W ATF9 Michael F. Easley, Gov or
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
co 7
r Alan W. Klimek, P.E. Director
Division of Water Quality
October 4, 2002
Mr. Robert Scala
Finetex Incorporated
P.O. Box 164
Spencer, NC 28159
Subject: Spray Irrigation Inspection
Permit No. WQ0001077
Finetex, Incorporated
Rowan County
Dear Mr. Scala:
Enclosed is the Spray Irrigation system inspection report for the inspection conducted on
October 3, 2002 by Ms. Ellen Huffinan with this Office.
The report indicates compliance with the subject permit. It was noted that the ORC is
continuing to improve the conditions of the spray field with a routine field maintenance program. The
Agronomist's comments on the April 2002 soils report (NCDA report #34420) suggest that the
routine application of plain water on the fields will help prevent soluable salts buildup from causing
problems in the future.
The inspection report should be self-explanatory; however, if you have any questions, please
contact Mrs. Huffman or me at [phone]..
Attachment
cc: Non -discharge compliance
h:finererac
NCDENR
Customer Service
1 800 623-7748
Sincerely,'
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
919 North Main Street, Mooresville, NC 28115
PHONE [phone]
FAX [phone]

d1.
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
O&TI?
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner Finetex County Rowan
Permit # W00001077 NPDES# N/A
Issuance Date April 0, 1998 Expiration Date -March 31, 2003
If applicable SOC Issuance Date N/A Expiration Date N/A
Permittee Contact Robert Scala ;, Telephone No. 704/633-8028
ORC Name Emmett (Kirby) Atwood Telephone No. 704/633-8028
24hr Contact Emmett (Kirby) Atwood i Telephone No.704/633-8028
Reason for Inspection
X ROUTINE
Type of inspection
Collection System
COMPLAINT I FOLLOW-UP
X Spray Irrigation
Sludge
• 1 '
Inspection Summary: (additional comments may be included on attached pages)
.•, MW
Current monitoring records (NDARs and NDMRs) for 2002 were available for review and
indicated compliance. The ORC is Emmett; (Kirby) Atwood, Spray Certification #23355.
Backup ORC is Anthony Bolton, Certification # 15582. All wwt units appeared to be
operational. The application field was in very good condition. There were no signs of solids
build-up (flashing), hydraulic overloading, or ponding on the application field. The ORC has
completed installing the new spray heads. Routine field maintenance, including soil aeration,
seeding, and cleanup of brush and clearing debris, has improved the overall appearance of all the
usable zones of field 2. Agronomist's comments on the April 2002 soils report (NCDA report
934420) suggest application of plain water on a routine basis to prevent soluable salts buildup
from causing problems in the future.
Is a follow-up inspection necessary _yes: X no
Inspector(s) Name(s)/Title(s)EHen Huffman /Environ
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection 10-03-02

.0s
Permit #WQ0001077 Finetex Rowan County
jLVM
Activated Sludge Spray, low rate
X Activated Sludge Spray, high rate
Activated Sludge Drip, low rate
Lagoon Spray, low rate
Reuse (Golf Courses)
Recycle /Reuse
Single Family Spray, low rate
Single Family Drip
Infiltration System
Other
Treatment
Yes Are treatment facilities consistent with those outlined in the current permit.
Yes Do all treatment units appear to be operational. If no, note below.
List any action items necessary for each unit.
Comments: All treatment units appeared to be operational.
Lagoons Y/N
Primary (check any/all that apply)
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
N Vegetation (is there excessive vegetation on the lagoon bank
Y Liner (if visible, is it intact)
N/A Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
Y Staff gauge ( clearly marked)
N Evidence of overflow (vegetation discolored or laying down/broken)
N Unusual color (very black, textile colors)
N Evidence of foam
Y Are antifoam agents used?
N Floating mats (sludge, plants, inorganics)
N Excessive solids buildup (from bottom)
Y aerators/mixers operational (if present)
N/A Effluent structure (free of obstructions, easily accessible)
Comments:
Pg 2

s
Permit #WQ0001077 Finetex Rowan County
Secondary Lagoon Y/N
N/A Influent structure (free of obstructions)
N Banks/berms (signs of seepage or erosion)
N Vegetation (excessive vegetation on the lagoon bank)
_Y Liner (visible, is it intact)
N/A Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
N Evidence of overflow (vegetation discolored or laying down/broken)
N Unusual color (very black, textile colors)
N Evidence of foam
Y Are antifoam agents used?
N Floating mats (sludge, plants)
Y are aerators/mixers operational (if present)
N/A Effluent structure (free of obstructions, easily accessible)
Comments:
Effluent uunam station
X all pumps present, operational N/A Bypass structure present
N/A Bar screen, maintained N/A Free of excessive debris
N/A Bars evenly spaced N/A Bars excessively corroded
N/A Back-up power
Comments:
Aeration Basin N/A
aeration pattern even across surface of unit
easily accessed
Comments:
Clarifier(s)
Y weirs level Y scum rack operational Y easily accessible
Comments:
Return Pumps N/A
in place
Filters N/A
media present
operational
air scour operational clear well free of solids

Permit #WQ0001077 Finetex Rowan County
Residuals
storage/treatment
Residuals from the final clarifier are pumped to the sludge storage tank. Residuals are removed by
Shamrock Environmental (1-800-881-1098), solidified (with lime), and landfilled.
Comments:
Disinfection N/A
If gas, is storage safe?
Is it dual feed system?
How do you know it is working?
If tablets - are tablets present?
Effluent StoraEe N/A
LAGOON(s) SEPTIC TANK(s) X ABOVE GROUND TANK OTHER
Volume 20.000 gallons
Number of months storage 30 days Spill control plan on site Y
Lagoon Is lagoon lined
Above ground tank Aerated Mixed X
In ground tank Aerated Mixed
Drying beds Concrete storage pad
Disposal (final end apse)
Is application equipment in need repair? No Are buffers adequate? Yes
Are cover crops the type specified in permit? Yes In need of improvement? No
Signs of runoff? No Signs of ponding? No
Comments: The application field was in very good condition. There were no signs of solids
build-up (flashing), hydraulic overloading, or ponding on the application field. The ORC has a
routine maintenance schedule which has helped improve field conditions.
Y Is the acreage specified in the permit being utilized?
Y Is the application equipment present and operational?
N Are there any limiting slopes in disposal fields?
No Are restrictions for use of these areas specified?
Y Is permit being followed?
N Is there evidence of runoff or drift?
Y Is site access restricted in accordance with permit?
How: Fence

P
Permit #WQ0001077 Finetex Rowan County pg 5
Y Is permit available upon request?
Y Are monitoring reports present: NDMR X NDAR X
Y Are monitoring wells called for in permit present?
Y Are operational logs present?
* Are lab sheets available for review?
* Do lab sheets support data represented on NDMR or NDAR?
Y Are annual soil reports available?
* Are operation and maintenance records present?
N Has permittee received any public complaints in the last 12 months?
Comments: *Did not review files on site. MRO file review indicated compliance. Soils report
comments from T. Kent Yarborough, Agonomist, NCDA, indicated that application of plain water
on a regular basis will prevent soluble salts from causing future problems.

P.O. Box 3096
Cary, NC 27519
V
919-467-1239
)NNELL
& ASSOCIATES, P.C.
April 12, 2002
Ms. Ellen Huffman
NCDENR - Division of Water Quality
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
Re: Finetex, Inc. - Spencer Facility
WQ0001077
Rowan County
Project No.: A16105.00
Dear Ms. Huffman:
909 Aviation Parkway
Suite 1400
Morrisville, NC 27560
Fax [phone]
idC
1Fii ft t.,' i'1 L'•Ys
APR 17 2002
In regard to continuing maintenance operations at the Finetex facility, the staff are planning to
race the existing sludge holding tank with a new sludge holding tank. The new fibergla`- ss tank
`wrll�f the same capacity (8,000 gallons) but will be in a new location about 40 feet from its
current location. Additional piping will be added to accommodate the new tank. Based on
similar situations at other facilities, we have advised Finetex staff that this is typically considered a
maintenance issue. Because there is no change in plant capacity, operations, nor process; it is our
understanding that no permit modification nor approval is required. However, Finetex is notifying
the Regional Office of its intentions by way of this letter, in a show of continuing cooperation.
If for any reason more information is requested, please contact me as soon as possible at
919/467-1239. Your continued assistance is appreciated.
Sincerely,
..�
GaryS. acConnell, P.E.
President
cc: Mr. Bob Scala
Mr. Kirby Atwood.

February 13, 2002
i
To: Bob Scala
From: Kirby Atwood
Subject: Consultant Inspection of Wastewater Treatment Systems
Dear Sir,
FEB 2 1 2002
Michael Allen, PE of MacConnell & Associates performed an independent
surprise inspection of the Wastewater Treatment Systems Monday February 1 Vh His
inspection covered the wastewater plant area, sprayfields, and documentation.
The wastewater plant was in operation with discharge going to the Spencer
POTW. Mr. Allen's inspection included a section pipe used to carry wastewater to the
sprayfields. Mr. Allen remarked that the piping was in good condition and recommended
that we continue present operation and maintenance activities. No other suggestions were
made concerning the wastewater plant.
The inspection of the sprayfields was done following .25 inches of rain on the
day prior. There had been no discharge to the fields in about a month. Mr. Allen noted
that small pockets of rainwater on the fields were clear with no visible wastewater impact
to the rainwater. Inspection of the fields did not show any solids build up. Rye/fescue
grass was green and healthy. Michael commented that he wished his yard was as green.
`Mr. Allen was complimentary of the voluntary improvements made to Sprayfield #2.
Those improvements were the installation of impact heads over most of the Zones and
clearing of brush from the Sprayfield. The only recommendation was to continue the
current project of impact head installation and clearing the zones.
Wastewater documentation was also covered in the inspection. This included
daily operator logs, monthly reports, monitoring well reports, annual loading report, etc.
All documentation was present and in order. No suggestions were made.
Results of the unexpected inspection were good and reflect the improvements
made in operation and maintenance of wastewater treatment systems.
Thank you,
' Atwood
Cc: Roger Porter
Ellen Huffman
Kris Houpt
Visit us at www.finetexinc.com
FINETEX INC., P.O. BOX 216, ELMWOOD PARK, NEW JERSEY 07407 [phone] FAX: [phone]
P.O. BOX 164, SPENCER, NORTH CAROLINA 28159 [phone] FAX: [phone]

Nov-15-00 13:07 From-HUNTONUILLIAMS
+0198993096 7-510 P.01/01 F-207
HuwoN&
WUJAMS
November 15, 2000
VIA TELEFAX 704-663-6040
Ms, Ellen Huffman
NC UENR
Mooresville Regional Office
Mooresville, North. Carolina
Dear Ms. Huffman_
POST OFFICE BOX 109
RALF1GK NORTH CAROUNA 27602
TEL 919 - iS99.3000
FAX 919 - 833 + 6352
919.899 - 3096
VALERMG. Ct1AFFIN, CL,%
CERT[FIED LEGAL ASSI$'j•ANT ,
DT"CT UTAL. 919.899.3044
I:W& L. vchafrlp&lMton cam
FILE NO. $0789.4
Pursuant to the North Carolina Public Records Law, N.C.G.S. § 132.6, I am
requesting that you make available to me, for inspection and copying, The files pertaining to
jFinetex—, r'nc�. in Spencer, North Carolina. I am interested is ail correspondence and
documentation regarding, their facility, including, but not limited to, their permit, any field
notes, inspections, permit interpretation, and civil penalties.
I will be in your area on Monday, November 20, 2000, and would like to view the
files at 3:00 pm. Should the review. require more time than you are open ou Monday, I would
like to complete the review the next day.
Sincerely yours,
HUNTON & WILLIAMS
Valerie G. ffin
.:L4\TA L:\XQKCi{ LC:'ti:s•71 ,M,l:._7\ MiiM
W _:jai: .� �nri.�i -lr_. � ,c.�i 8;k.l.v,ti:\.• Wn_A-mW Wf�h'!NC ZN
in' Ins W. iltlti w::. �v::a

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1
?inetex Site
Subject: Re: Finetex Site
Date: Mon, 02 Jul 2001 14:13:48 -0400
From: Peggy Finley <[e-mail]>
l
Organization: NC DENR - Mooresville Regional Office
To: John Walch <[e-mail]>
John:
I review the groundwater compliance monitoring for Finetex' wastewater
spray irrigation activities. Occasionally, the concentration of lead
reported in the three original monitoring (bored) wells has been above the
NC groundwater standard of 0.015 mg/L but generally not above one order of
magnitude. My review of both gw and effluent monitoring data for the last
several years does not indicate that the elevated gw concentrations are
related to the waste disposal activities. They may reflect natural
conditions for the surficial aquifer. The Groundwater Section does not
consider this a pollution incident at this time.
Peggy Finley
John Walch wrote:
> Hi Peggy-
> While reviewing the Superfund Section files I found an April 1996 memo
> from indicating that Hanna Assefa of our office spoke to you about the
> Finetex Site in Spencer, Rowan County. This site apparently has
> groundwater contamination that is associated with the wastewater
> treatment plant that is or at one time was permitted by DWQ.
> Representatives of Finetex have recently contacted our office to find
> out how they can get a No Further Action classification for this site.
> I am trying to determine if DWQ is actively working on this site.
> If you are the project manager for this site or know who I need to
> contact please let me know. Thanks for your help.
> John W . Wa 1 ch
> Environmental Engineer
> NC Division of Waste Management
> Superfund Section
> [phone], ext. 285
> email: [e-mail]
Peggy Finley - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality - Ground Water Section
919 N. Main St.
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
Peggy Finley <[e-mail]>
NC DENR - Mooresville
Div. of Water Quality - Ground Water Section
i of 2 7/2/01 2:20 PM

*.a/25/2000 14:24 6337566
Finetex Inc.
Date
Number of pages including cover
sheet
Phone
Fax Phone
CC:
PAGE 01
PO BOX 194
Spencer. NC 28159
T Kirby Atwood
Phone (TM 633 - 8028
Fax Phone (7AAj._83S - 7666

F19l2512000 14:24 6337566 PAGE 02
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08/ 24/ 2000 07: 59. 6337566 : PA6E: ..01.
PO Box I"
Finetex
Inc.
Spencer, NC 28169
Date -6- ;;) Lt - 00
Number of pages including cover
sheet
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NC.01�
Phone _
Fax Phone (A.71-- 6C �¢ 0
CC: ---
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Kirby Atwood
Phone (704) $33 - 3028
Fax Phone 704 633 R 7666

_0 08/24/2000 07:59 6337566
PAGE 02
August 24, 2000
To: Ellen Hu#fi nan
Fax: [phone]
From: Kirby Atwood, Comphauce Coordinator
Finetex, Inc.
Doar Ellen,
I ant Bending Ns letter to keep you informed of our wastewater operations. We
are not discharging any wastewater on sprayfield 2. We are continuing to mice progress
on the sprayfield 2. The hose extensions on sprayfield 2 are complete. We are doing
hose testing using non -contact cooling water to get the best distribution possible. I will
contact your office as soon as we start discharging on sprayfield 2. That will not take
place until Bob Scala has given us permission.
Expansion of the aeration basins has started. We have one basin empty for the
construotion. The grading on that basin is almost complete. Friday August 25th is the
projected completion date for the first basin. A PE from MaXopnell & Associates will
inspect the basin prior to operation. We will notify your office 49 hours prior to start up.
We have expanded the information on the mordbly X7IvIR. The July DMR
includes the discharge flow to Spencer and the PAN. The PAN caloulatcd to be 27.75
mg/l. That should not be the limiting factor for our discharge. We will be doing xx *uthly
monitoring of our effiueut. I will continue to monitor the amount of PAN and limit our
discharge to less thaw 300 Its Jacrv/Ycar-
Please contact my office at [phone] should you have any questions.
Thank you,
Kir ,Atwood
iETEX INC, ROL BOAC 216, ELMWOOD PARK, NEW JERSEY 07407 (201) 797-M FAX: [phone]s
P.Q BOX 164, SPENCE& NOM14 CAROUNA 28189 (704)1 33.8028 FAX: (704) 6=746

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Ifni 11ro11dbill Drive
Mooresville, N. C. 211117
From:
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Paul Pennlndor
11 rat Jacobs
704.663-6906
704-662-904 fi
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Fi*netex
Irrigation System
Meeting with NCDE&NR
December 3, 1999

I
I
■ Introduction - Bob Scala,
Finetex
■ Presentation - Gary MacConnell,
MacConnell & Associates, P.C.
■ Open Discussion, Questions & Responses
■ Summary & Conclusion

-SiOV
Ngnificant Issues
■ Irrigation Field O & M
■ WWTP - Operation
■ Application of TSS & COD

Irrigation Field O & M
■ Rain Water vs Irrigation Water
■ Removed Gravel from Field
■ Filled in Ruts and Low Areas
■ Cleared Fields
■ Seeded with Rye and Fescue �
■ Propose to Aerate with Drum Type Roller
■ Continue to Monitor Fields
On Going 0 & M (Field 3)

AV, WTP Operation
■ Operation of Clarifier
■ For Discharge to Spencer
■ Not in Irrigation Application
■ Not Currently Piped to Fields
■ Hydraulic Limitations
■ Requires HighlyCorrosive Ferric Chloride
Permit Took Away Freeboard (Capacity),----------"
■ Aeration - Safety & Environmental
■ Increased Aeration Basins - Solution

Application of TSS & COD
■ BOD5is about 1/3 of COD Value
■ Organic Waste Readily Biodegradable to
CO2and H2O
■ Low in Nutrients (Ammonia Limiting)
■ No Pathogens -1
■ With Clarified Waste Grass Died
■ Solicite Opinion from Agronomist

Summary
■ Maintain Irrigation Fields
■ Do Not Use Clarifier
■ Solicite Agronomist Opinion
■ Allow Irrigation to Begin
o Approve and Construct New Aeration
Basins ASAP

June 8, 1999
To: NCDENR
Mooresville Regional Office
Division of Water Quality
919 North Main St.
Mooresville, NC 28115
Frofnf: Kirby Atwood
Finetex Inc.
PO Box 164
Spencer, NC 28159
Sir,
AN 9 1999
Please find enclosed the questionnaire for our collection system, operation and
maintenance evaluation, and pump station. We have a very small wastewater treatment
facility that has a collection system. running from the production area to the wastewater
treatment plant. We discharge primarily to our sprayfields by permit number
WQ0001077. The only pumpstation is part of the discharge system to the town of
Spencer used a back-up discharge source. Please call my office with any questions or
concerns @ [phone].
FINETEX INC., P.O. BOX 216, ELMWOOD PARK, NEW JERSEY 07407 [phone] FAX: [phone]
P.O. BOX 164, SPENCER, NORTH CAROLINA 28159 [phone] FAX: [phone]

OPERATION & MAINTENANCE EVALUATION
1. Is staff designated full-time for collection system operation and maintenance? Yes ✓ No
2. Do you have a list of 24 hour contacts? ✓ Yes No (If Yes, please attach)
3. Do you have an emergency equipment list? ✓ Yes No (If Yes, please attach)
4. Staff distribution/time allocation:
Number Total staff
employed hours/week
Collection System (incl. part-time)
Pump Stations
III Correction
5. Are map(s) of the collection system available? Yes / No
6. Total number of pump stations: . / (Please complete a Pump Station form for each station.)
7. Is a preventive maintenance program in effect? Yes X
If yes, does it include:
a. Maintaining logs/records
b. Determining equipment/system malfunction rates
c. Establishing schedules
d. 1/1 evaluation
e. Manhole inspection
f. Sewer cleaning program
g. Hydrogen sulfide monitoring and control
h. Lift station operation
i. Easement/right-of-way maintenance
j. "Walking" or visual observation of lines
k. Spare parts inventory
B. Please describe what type of ongoing inspection program for
GnecC,+C,T 1� l KS -k�e IIA a Act c
9. Please describe the schedule for line cleaning: /)f A
No (If Yes, please attach)
_(- Yes
No
Yes
No
Yes
No
Yes
N, No
Yes
, No
Yes
_ CK No
Yes
X No
Yes
No
Yes
�_ No
T Yes
No
Yes
_ No
collection system exists:
E!S v:5L.,,.,1 IA54e-C-+
10. Is there a sewer use ordinance? _Yes JS­ No. Is there a grease ordinance? -- Yes i No
If yes, please identify the responsible party for ensuring the ordinance(s) is enforced.
--(name of responsible person/agency).
11. Please describe any sewer use ordinance enforcement practices that exist: /l.� �-

'. i nr `,. } n.�. > >.. fit! i.t sr n�`i�r�, ,..'�,.,-• l� �;ti rvl...l i 11}'4,5�'S°ii��( dt �6i �. !'S at,`S 'm �t. ,� �x. � � tiy�, .'.y. 1 A,�i.7n,YF ay1" �. r'S *�"�I>'k "�'-fdi
t r
. fir r,;. 3?
y
-The facility is equipped with ABC fire extinguishers and emergency shower/eye
wash stations throngi:out. Fire extinguisher are typically short use 10 lb. size.
absorbent a�
Tolls my ada lable n .Gi;
-Spit. cai�:. t.., :;tainin .
-SCBAs a—2 used for emergency' es=e and are located inside the fa .Aity.
-First Ala kits are available in production area and warehouse bn?.lding.
-The buildings have alarm system that can be activated from loc,' ions
throughout the plant to alert facility personnel to evacuate.
-Intercom system is utilized to communicate directions or emergency messages to �.
all facility personnel. ! I
-Telephone numbers of emergency coordinator, back-up emergency coordinator,
and local emergency responders are displayed throughout the facility.
-The Spencer Fire Dept., approximately Z miles away. is available and can call
for additional fire assistance from neighboring fire departments.
-Local emergency services car. be aOled on for ambulance service to transport any
injured personnel to the local hospital

24 HOUR CONTACT LIST
PRIMARY CONTACT:
KIRBY ATWOOD
OFFICE [phone]
HOME [phone]
SECONDARY CONTACT:
JACK HEATH
OFFICE [phone]
HOME [phone]
FINETEX INC., P.O. BOX 216, ELMWOOD PARK, NEW JERSEY 07407 [phone] FAX: [phone]
P.O. BOX 164, SPENCER, NORTH CAROLINA 28159 [phone] FAX: [phone]

Collection System Evaluation:
1. Please estimate how many miles of sewer line are in your collection system
—X<100mi. 100-500mi. 501-1,OOOmi. >1,OOOmi
2. How many pump stations are in your collection system? Ne- A e--
3. Please list any problem areas within your collection system. Include exact location of problems.
(e.g. Chronically surcharging manholes, pump stations which frequently fail, lines with severe
Infiltration and Inflow, etc..) N
4. Please rank the problems listed in No. 3 in order of importance. If possible, include an estimated date
by which the problem will be appropriately addressed.
5. Please describe any ongoing efforts or plans to rehabilitate and/or renovate the collention system.
Include exat:t location of ongoing or planned work.
(e.g. Infiltration and Inflow studies, pump station upgrades, pipe replacement, etc..)
NOTE: Please attach any additional sheets and/or information if needed.

PUMP STATION
(please complete one form for each pump station) n
Name of Facility: EULC-�e/- ^Lvic . Contact Person:
Phone Number -� (:)4)
Location of Pump Station:
1. How often is pump station inspected? X once per day
(check all that apply) once per week
other(explain)
twice per day
days per week
2. What is the pump station capacity? a GPM
Does the pump station have a flow meter, pump counters or other means to measure flow?
Yes No
3. Does the pump st:.tion have a backup power source? Yes K No
If yes, what type: Portable generator which can be moved to site
Standby generator on site
Alternate power feed
If a portable generator is used, how many other pump stations does the generator serve?
How often is the generator tested? (Mo./yr.)
When was the generator last load tested? (Mo./yr.)
Was the test successful? Yes No If No, what action was taken to address?
If no backup power exists, please explain
RA �-�- +- 0V1 s r
". . — !
�s
v7
4. Does the pump station have a working alarm system? X Yes No
On site alarm system: High water audio alarm
Other (describe)
X High water visual alarm
Tei�rnetrr "",-inaoring Syst i �.a cpi:.:4 ca•� IC.�e: ��_� ,.A i .vsi !`:: IaVC:
Dry well high `level High/ow pH
High/low current AC power status
Please describe other alarm systems at the pump station.
5. Is there a spare pump.available or an adequate spare parts inventory to replace or rebuild pump?
-Z-� Yes No If No, what actions are being undertaken to address?

0)
June 22, 1998
To: Division of Water Quality
Regional Office
919 N. Main St.
Mooresville, NC 28115
From: Kirby Atwood, Compliance Coordinator
Finetex, Inc.
W00001077
PO Box 164
Spencer, NC 28159
Here is the completed Spill Response Plan questionnaire that our wastewater treatment
plant is required to complete. We have a wastewater treatment plant that discharges to
city of Spencer and has a spray field application. The collection system for that plant is
very small and simple. I hope the information on the questionnaire will be helpful.
Please call me with any questions or concerns.
Thank you,
/,U 40id
Ki Atwood
FINETEX INC., P,O. BOX 216, ELMWOOD PARK, NEW JERSEY 07407 [phone] FAX: [phone]
P.O. BOX 164, SPENCER, NORTH CAROLINA 28159 [phone] FAX: [phone]

-.r
a-
SPILL RESPONSE PLAN EVALUATION
1. Do you have a current 24 hour contact list which includes phone numbers of key personnel and/or
contractors? ✓ Yes No (If Yes, please attach)
2. Do you have an equipment list which includes what functional equipment is available and where it is
located? —Yes ✓ No (If Yes, please attach)
3. Do you have the staff resources to make an on -site assessment of a spill with in two hours of notification
of the spill? ✓ Yes No (If No, please explain below)
4. Please list your standard spill response procedures:(
5. Is your spill response plan readily available to all essential personnel?
If No, please explain why: Yes No
6. Are all es.7tial personnel familiar with the spill response plan and Merry ur•de S;a„u r„ar.ris?:
Yes No
If No, please explain why:

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
ROBERT H. SCALA
FINETEX INC-FINETEX CHEM.PLT.
PO BOX 164
SPENCER, NC 28159
Dear ROBERT H. SCALA:
• •
A&;I
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
September 23, 1998
Subject: Missing Information on form NDMR-1
FINETEX INC-FINETEX CHEM.PLT.
Permit Number: W00001077
ROWAN County
The Non Discharge Compliance / Enforcement Unit has reviewed the submitted NDMR-1's for the month
of July, 1998. This review indicates that monitoring for the following parameters was missing from the
submitted forms:
Mg Na
COD Residual Chlorine
Ca Oil & Grease
Compliance with your Non -Discharge permit, requires monitoring for all required parameters, at the listed
frequency. Please reference the state issued Permit Number when providing the requested information.
All information should be signed and submitted in triplicate to the attention of Kevin Barnett at the
letterhead address. The information requested by this letter must be submitted within 30 days of receipt of
this letter.
Nothing in this letter should be taken as removing from you the responsibility or liability for failure to
comply with all applicable state laws and regulations.
If you have any questions regarding this request, please do not hesitate to call Kevin Barnett of our central
office staff at 919-733-5083 ext. 529.
Sincerely,
Jeff Poupart, Supervisor
Non -Discharge Compliance / Enforcement Unit
Non -Discharge Compliance / Enforcement Unit
cc:
Non -Discharge Permitting Unit
Mooresville Regional O_ffice
Technical Assistance and Certification Unit
Central Files
SEP P'4 1998
011'BS4G11 CF._ Y, s! IfT
29535, Raleigh, North Carolina 27626-0535
Telephone [phone] Fax [phone]
P.O. Box
An Equal Opportunity Affirmative Action Employer
50 % recycled/10 % post -consumer paper

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
F-0 rl
"CA"DENP DIVISION OF
July 20, 1998 OF D�7,Strjof-� LAM i
DAMES B. HUNTJR. 1 P-b1� f5
GOVERNOR
Finetex, Incorporated -- a -� --
Post Office Box 164 XPY
WAYNE MCnEV,,T ` Spencer, North Carolina 28159
SECRETARY Attention: Jack Heath
RE: Groundwater Compliance Monitoring
Spencer Facility
Wastewater Spray Irrigation System
Permit No. WQ0001077
Rowan County, N.C.
Dear Mr. Heath:
On June 8, 1998, this office received the laboratory results for the April 1 sampling
=:c . of monitoring wells MW-4, MW-5 and MW-6 along with the well certification and the
- .required map. The laboratory results included analysis for volatile organic compounds
- (VOCs). Although the laboratory method used for this analysis is one specified in your
permit, the detection limit was above the required 0.5ug/L or parts per billion (ppb).
- Please refer to the attachment and advise your laboratory accordingly for future VOC '
analyses for all six monitoring wells.
Should you have any questions, please call me.
....... -._.=_._.._---_.--_.._.-.�. Sincerely,
Margaret A. Finley
Hydrogeological Technician
s MAF/finetex.voc
r-^
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 28115
PHONE [phone]'699 FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/1 0% POST -CONSUMER PAPER

JUN 01 '98 11:02AN FINTEX LAB
s
TO: i J i.{p 0 b tr-•��
79� W
r-Ar,aIMfLEF -NsIi w,9jQbl
,r- J DATEII
P.1
LOCATION:
FROM
TRANSMISSION OF PAGES INCLUUITIG THIS S, EET
FINETEx INC. FACSIMILC MUMMER: (704)63.7-91142
UCI !)
Ew IN C, QX 216, ELM WOOD PAM, NEW IVISF,Y 07•107 (ZQJ) 797•AEBf TWX; 710.9aa.2 39 ,FIN�2•r. 9t nK
.7a,�soaa.a6 ;rWXI 010411211.0 o

JUN 01 '98 11:03AM FINTEX LAB P.Z
June 1, 19S
To: Division of Water Quality
919 North Main St.
Mooresville, NC 28115
1
From: Kirby Atwood, Compliance Coordinator
F'inetex, Inc.
PO Sox 164
Spencer, NC 2S159
Subject: Notification of Wastewater Start Up At WQ0001077
This is a follow up to the notification 48 hours in advance of starting
wastewater operations at our new spray field. I notified Robert Scheller i
your department about starting operations. He did not have any objection
with the start yap and suggested this fax. Please fax a response for my file
stating that you have been notified. We will start operating the wastewat
field on Wednesday, June 3rd 1998. i
Thank you,
Kirby Atwood

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
May 5, 1998
N1AY A 1�
Jack Heath
Finetex, Incorporated
PO Box 164 - -
Spencer NC 28157
Subject: Operator Designation
System: Finetex, Inc
Permit #: WQ0001077
County: Rowan
Dear Mr. Heath:
A review of the Water Pollution Control System Operators Certification Commission files
indicates that you may not be compliant with the requirements of 15A NCAC 8A .0202.
This rule requires owners of Water Pollution Control Systems classified by the Commission
to designate a properly certified Operator in Responsible Charge (ORC) and back-up
operator of the same type as the system's classification.
Our review indicates that the following information is missing from your file:
No ORC was designated.
No back-up ORC was designated.
X The designated ORC is not properly certified.
The designated back-up ORC is not properly certified.
The operator designation form was not signed by either the ORC, the
back-up ORC, or the system owner.
Please return a properly completed designation form to the WPCSOCC, PO Box 29535,
Raleigh, NC 27626-0535, within 30 days from the date of this letter. If you have any
questions, please contact Beth Buffington at 91gn33-0026, extension 313.
WATER POLLUTION CONTROL SYSTEM OPERATORS CERTIFICATION COMMISSION
P.O.BOX 29535, RALEIGH, NORTH CAROLINA 27626-0535
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST -CONSUMER PAPER

Finetex, Incorporated
May 5, 1998
Page Two
A Spray Irrigation System Operators Training School is scheduled for May 19-21, 1998, at
the McKimmon Center in Raleigh. The first certification examination offered after the
training school will be June 18, 1998. Enclosed is a brochure for the training school and an
application for the certification exam.
If you have any questions, please contact Beth Buffingfori at-919n33-0026, extension 313.
Sincerely,
Joseph B. McMinn, Supervisor
Technical Assistance and Certification Unit
bb/ORC designation
enclosures
cc: Water Quality Files
Raleigh Regional Office

f DESIGNATION FORM
OPERATOR IN RESPONSIBLE CHARGE OF
WATER POLLUTION CONTROL SYSTEMS
FACILITY INFORMATION:
Please Print Facility Name: Finetex, Incorporated
Mailing Address: PO Box 164
Address: Spencer NC 28157
Permit Number: WQ0001077 County: Rowan
Please circle type of facility Wastewater Collection Spray Irrigation Land Application
Classification of Facility (if applicable):. I II III IV
OPERATOR IN RESPONSIBLE CHARGE
Please Print Name:
Mailing Address:
City:
Certificate Types and Grade:
Certificate #s:
Work Phone:
State:
Zip Code:
Social Security #:
Home Phone:
Signature: Date:
BACK-UP OPERATOR
Please Print Name:
Mailing Address:
City: State:
Certificate Types and Grade:
Certificate #s:
Work Phone:
Zip Code:
Social Security #:
Home Phone:
Signature: Date:
SYSTEM OWNER/ADMIN. OFFICER
Please Print Name:
Mailing Address:
City: State: Zip Code:
Telephone #:
Signature: Date:
Please Mail to:
WPCSOCC
PO Box 29535
Raleigh, NC 27626-0535
Attention: Beth Buffington

f . �%
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Robert H. Scala
Finetax, Inc.
P.O. Box 164
Spencer, NC 28159
Dear Robert H. Scala,
2/5/98
C',
F-ED 5 om
r_,­ T?9 11,1,-0 i.t7:,i i.kfi
Subject: Monitoring Data Accuracy ­'
Permit Number: WQ000107T"
Finetax, Inc.
Rowan County
The purpose of this letter is to address reporting deficiencies with your monthly spray
irrigation report. Currently the State utilizes two (2) forms that have been developed to compile
all your required reporting information. These forms are the NDAR and NDMR. It is important
to use these forms properly and please remember that both forms must be submitted each month.
Regarding the NDMR, the first four columns; "Operator Arrival Time"," Operator Time
on Site","ORC on Site" and "Daily Rate (Flow) into Treatment System" must be reported
monthly. If you do not report flow on the NDMR form, your monthly average calculated for the
year will be inaccurately inflated. Required reporting parameters listed in the subject permit must
be submitted, three times a year, as regulated by the permit. This figure must also be measured
correctly; your system must have flow meters or some measurement device that allows you to
read the flow of wastewater into your treatment system. This is before diluting, processing,
aerating, etc... Also Daily Rate must be reported in the units of measurements stated on the
monitoring form. All parameters not preprinted on the NDMR form must be filled in by the
permittee and must be reported in the units stated in the subject permit.
Regarding NDAR forms, fields must be consistently identified and cover crops listed
when reports are submitted each month. Each. field must also be identified with acreage. and,
cover crop listed each time you submit reports with completed data. Please record 0.0 inches
Monthly Loading if there is no activity.
Nothing in this letter should be taken as absolving you of your responsibility to abide by
all relevant NC Statutes and Regulations.
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

Page 2
This is a reminder of the importance of accuracy and completeness in submitting the
State forms. Thank you for helping the Water Quality staff in our efforts to maintain accurate
records. If we can be of any further assistance in this matter, please do not hesitate to contact
Kevin Barnett of our staff at 919-733-5083 ext. 529.
Sincerely,
Wuwc
Dennis Ramsey
Assistant Chief for Non Discharge
cc: iIoaresvlhle Regional -Supervisor 7
Non Discharge Compliance/Enforcement unit
Central Files

State of North Carolina
Department of Environment,
Health and Natural Resources •
Mooresville Regional Office
James B. Hunt, Governor
B.
. tDF_=H"FZ Jonathan . Howw es, Secretary
Linda Diane Long, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
February 13, 1995
Finetex
Post Office Box 164
Spencer, North Carolina 28159
Attention: Anthony F. Bolton
RE: Policy Change on VOC Follow-up Requirements
Non -Discharge Permit Conditions
Permit #WQ0001077/GW93148
Rowan County, N.C.
Dear Mr. Bolton:
Enclosed is a copy of the memorandum which I discussed with
you by telephone on February 10. As I stated during our
conversation, this policy change negates the need for you to
submit the additional 604 and 611 analysis required in the
January 24 latter from this office.
Sincerely,
Margaret A. Finley
Hydrogeological Technician
�MAF-/ s c
Enclosure
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

( l 0
d „a ST it
State of North Carolina
Departmeq
i qX&unal Resources and Community Development
SAS '®1v1sion of Environmental Mangment
G� �� E�+v512 North. Salisbury Street • Raleigh/ North Carolina 27611
James G. Martin, Goveruio`�:'l�
R. Paul Wilms
S. Thomas Rhodes, SecretaryAoosEsvl��e Director
$IEGIGNAL OFFIG�
September 12, 1985
Mr. Anthony F. Bolton, Operations Manager
Finetex, Incorporated
P.O. Box 164
Spencer, N.C. 28159
Dear Mr. Bolton:
RE: MONITORING, ROWAN COUNTY FACILITY
Per our telephone conversation today, please find enclosed a copy
of the quality standards for classified groundwaters. I hope you will
find this information helpful.
As I mentioned, the bimonthly sampling schedule requirement for the
monitor wells was based primarily upon analyses from those wells which
have shown increased in the lead concentrations since June of 1984 that
exceed the groundwater standards. Additionally, although only one value
each has been reported for the concentrations of Chemical Oxygen Demand
and Phenol, those values vastly exceed the concentrations normally found
in uncontaminated groundwater. Since these two parameters are also re-
quired sampling parameters, you should keep those additionalparameters in
mind as you attempt to establish the source of the lead contamination.
If you have questions or feel I can be of further assistance, please
advise.
Sincerely,
Robert B. Cheek, Supervisor
Permits & Compliance Unit
Groundwater Section
RBC/cbe
Attachment:
cc: Ron McMillan Pollution Prevention Pays
BM11�C 4,foir r, P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]

State -of North Carolina
Department of 1 -gal Resources and Community Development
Ai't-§i€iRdof Environmental Management
tvato"MTK` rth Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governorto R. Paul Wilms
S. Thomas Rhodes, Secretary Director
��fOC3A� OFFICB ', .
Mr. Anthony F. Bolton,
Finetex, Incorporated
P.O. Box 164
Spencer, N.C. 28159
Dear Mr. Bolton:
September 12, 1985
Operations Manager
RE: MONITORING, ROWAN COUNTY FACILITY
Per our telephone conversation today, please find enclosed a copy
of the quality standards for classified groundwaters. I hope you will
find this information helpful.
As I mentioned, the bimonthly sampling schedule requirement for the
monitor wells was based primarily upon analyses from those wells which
have shown increased in the lead concentrations since June of 1984 that
exceed the groundwater standards. Additionally, although only one value
each has been reported for the concentrations of Chemical Oxygen Demand
and Phenol, those values vastly exceed the concentrations normally found
in uncontaminated groundwater. Since these two parameters are also re-
quired sampling parameters, you should keep those additionalparameters in
mind as you attempt to establish the source of the lead contamination.
If you have questions or feel I can be of further assistance, please
advise.
Sincerely,
Robert B. Cheek, Supervisor
Permits & Compliance Unit
Groundwater Section
RBC/cbe
Attachment:
Pollution Prevention Pays
cc: �, n
Bill Crawford P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]

State of North Carolina
Department of Natural Resources and Community Development
Mooresville Regional Office
James G. Martin, Governor
S. Thomas Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
April 29, 1985
Mr. Anthony F. Bolton, Operations Manager
Finetex, Inc.
P.O. Box 164
Spencer, N. C. 28159
Dear Mr. Bolton:
Enclosed is the new groundwater quality monitoring report form. It is
requested that this form be utilized in reporting future groundwater sampling
results required under Permit No. 3600-R for spray irrigation.
If you should -have any questions regarding this form or desire additional
ones, please contact me at [phone].
Sincerely,
pa t4
Jesse W. Wells
Hydrologic Technician
JWW: sju
Enclosure
cc: Mr. Ron McMillan
Mr..Bob:_Cheek.
919 North Main Street, P.O. Box 950, Mooresville, N.C. 28115-0950 • Telephone [phone]
An Equal Opportunity Affirmative Action Employer

DIVISION OF ENVIRONMENTAL 11ANA1301ENT
March 10, 1982
Mr. Tony Bolton,
Finetex, Inc.
Post Office Box 164
Spencer, i'l. C.. 28159
RE: Water Quality Monitoring Wells
Finetex, Iric.
Rowan County
Dear Mr. Bolton:
This.letteris a follow-up to the visit by rmyself and Jesse Wells of the
Groundwat-er Sect -ion, Division of Environmental INanagement, to your plant
4
property on Harch 8, 1-_Tt{-;32. Dijring this visit we selected sites for three (3)
water quality moni-It.orsing wells and discussed the design of these wells.
A mnininum of t1hreo (3) observation -V4,ells are required to- ade.quately
monitor the effects of the spray irrigation field at Finetex. One well should
be located oil the north side of 4-112 field adjacent to State Road 2124:' Two
wells should be placce dGwn grad " lent on the southeast and southwest sides of
the field. The total depth of each well should be a rninimum of ten (10) feet
beloW the top of the water table. The construction of the wells must' comply
t--,ith 1'. C. !,,!ell Construction SI-lavidards.
I have epclosed-a copyy of tho H. C. We'll C"onstrLICII.Aon Standards and forms
for use In cn,mpletinq the required well records,
If I can, be of further assistance, p1'ease'doc not hesitate to',cal l or
virite.
Sincerely,
'William H Cratvford
Hydrological Technician
�WHC:sju
Enclosure
cc: Mr. D. Re'x Gleason

DIVISION OF ENVIRONMENTAL IMANAGEt.109
March 10,, 1932
11r. Tony Bolton
Finetex, Inc.
Post Office Box 164
Spencer, H. C. 23159
RIE.* dater Quality 1-lonitoring Wells
Finatex, Ific.
Rowan County
Dear Mr. Bolton-,
This letter is a follow-up to the visit by myself and Jesse 'Wells of the
GroundwaterSection, Division of Environmental Manage;ir.0t, to your plant
property or March 3., 1,',032. During this visit we selected sites for threw (3)
water quality monitoring wells and discussed the design Qf these wells.
A of three (3) observation wells are required to adequately
monitor the effects of the spray irrigation field at'Fivetex. Cane .well should
be located on the north side,of tho field a4jacent to State Road 2124. No
wells should be placed down gradient on the southeast and southwest sides of
the field. The total depth of each well should be a r4inimurti of ten (10) feet
belovs the top of the water table. The construction of the viells must comply
with fl. C. Well Construction Standards.
I have enclosed a copy of the N. C. Well Construction Standards and forms
for use -in completinq the required well records.
If I can be of further assistance, please do not hesitate to call or
virite.
Sincerely,
William H. Crawford
Hydrological Technician
1*1 C: sj U
Enclosure
cc, Mr. D. Rex Gleason

North Corolino Deportment of Noturol
Resources &Community Development
James B. Hunt, Jr., Governor Joseph W. Grims1ey, Secretary
DLVISI.ON OF ENVIRONMENTAL MANAGEMENT
July 21', 1982 &60 H;_5
Mr. Anth-ony.F. Bolton, Operations Manager
Finetex, Lnco
Post Off itce Box 164
Spencer, .:N..C. 28159.
Subject; Permit No, .36.OJ --R-
S.ampl i:ng Requirements
Fi.netex, I:nc,
Rowan County,:N,.Co
Dear Mr. B-olton:
This letter is to confirm the items, dis.cussed via telephone. on July 20., 1982
w.i.th_ Mr.. Larry D. Cob -le of the Moor0sVi,l le Regional Office staff®
Lt has been determined that the following sample results are to b.e submitted
by Finetex on a.quarterly bas1s;-
Graundwater filel l s VastoWdter.: Treatment P1 ant Effl cent
Conducti:vi.ty NK3 as N
Oil and Grease Phendls.
MBAS- Detergents Oi.l and Grease
Lead Lead
Zinc
After a peri.od of one year the Company can request that th.is schedule be
reviewed, Based upon our -review- the: schedule -may b-e amended to. decrease frequency or
delete some parameters.o
Th-e. Company w.i.l l also be required to submit a yearly soils. analys-.is representative
of the spray f i.el d area.
I.t has also been determined, due tothe information submitted by the Company in
the Engineering Report, that an operati.on and maintenance manual will not be required
at this time. (Condition 21 of Permi.tj.
Lf you have any questions concerning this or other matters, please contact Larry
Coble or me.
Sincerely,
cc: Mr, Bill Crawford)
ORIGINAL SIGNED By
D® Rex Gleason, P. E.
Water Quality Regional Engineer
Mooresville Regional Office 919 North Main Street, Mooresville, N. C. 28115-0950 Telephone [phone]