WQ0006099_Complete File - Historical

To permits and Engineering unit:
Water Quality Section
Gate: March 9, 1992
NON -DISCHARGE ST REPORT AND RECOMMENDATION
County: Mecklenburg
Permit No. WO 0006099
PARS" I - GENERAL INFORMATION
1_.. Facility and Address: Willard Industries, Inc.
101 Newbern Street
Charlotte, NC 28203
2. Gate of Investigation: March 5, 1992
3. Report prepared By: W. Allen Hardy, Environmental Engineer I;
. persons Contacted and Telephone Number: Clarence S. Willard
President (4) 523-1230
. Directions to Site:: From the intersection of South Boulevard
and Clanton Roadin Charlotte travel north on South Boulevard
to the intersection with New Bern Street. Turn left and the
plant will be on the left approximately 200 yards from this
intersection
6. Disposal Site( , List for all disposal sites:
Latitude 5 oll ' 56 a
Longitude: 80 5 '
Attach a USGS heap Extract and indicate treatment plant site
and discharge point on map
USGS Rued No.: G15NE
7. Size .land available for expansion and upgrading The land
available for expansion and upgrading appeared to be limited.
8. ___ Topography (location map or topographic indicating
relationship to 100 year flood plain included): The
topography is relatively flat. The site dial not appear to be
in or near a flood plain
a Location of Nearest Dwelling and dater Supply Well: There
were no houses located within 500 feet of the plant.

Page Two
10. Watershed Stream Basin Information: Irwin Creek
a. Watershed Classification: C
b. River Basin and Subbasin No.: Catawba 03-08-34
C. Distance to surface water from disposal system: The
nearest surface waters were greater than 500 feet from
the disposal system.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Type of wastewater, sludge or contaminated soil:
0% Domestic
100% Industrial
a. Volume: 0.0005 MOD (Design Capacity)
b. Types and quantities of industrial wastewater: The
industrial wastewater is produced from non -contact
cooling water and floor washdown. Approximately 430
gallons per day of non -contact cooling water and 100
gallons per day of floor washdown from the refining area
are produced daily.
c.- Prevalent toxic constituents in wastewater: Elements
such as copper, tin, lead, and antimony are known to be
present in the materials that are' being melted for
refining.
d. Pretreatment Program (POTWs only): N/A
in development approved
should be required not needed
2. Production Rates (industrial discharges only) in Pounds Per
Day: The production rate varies according to the demand.
3. Description of Industrial Process (for industries only) and
Applicable CFR Part and Subpart: Could not find specific Part
and Subpart to match industrial process.
4. Type of Treatment (specify whether proposed or existing): The
proposed recycle treatment facility will consist of a 550
gallon influent mixing tank, bag filter and a 3,740 gallon
effluent sump tank.
S. Sludge Handling and Disposal Scheme: The waste product (iron
oxide) generated during the refining process will be captured
and removed through a bag filter and transported to an
off -site lead reclamation facility
6. Treatment Plant Classification: Less Than 5 Points; No
Rating (include rating sheet). Class I

Page Three
. SIC Code(
Wastewater Code(s)
Primary. 67
Secondary:
FART III - OTHER PERTINENT O TIO
1is this facility being constructed with Construction Grant
Fund(municipals only) No
;. Special monitoring requests: N
3. Air Quality and/or Groundwater concerns or hazardous waste
utilized at this facility that may impact water quality, air
quality, or roundwater o air or groundwater quality
concerns are expected nor is hazardous waste utilized at this
site.
.. Other: N/A
PART IV - EVALUATION AND RECOMMENDATIONS
The applicant, Willard Industries, Inc., has applied for -
permit for the recycling of wastewater produced from the refining
of lead.. There did not appear to be any problems associated with
the proposedtreatment facilities or there location that world'
hinder the issuance of the permit.
_
Pending the review and approval by the Permits and Engineering
Unit it is recommended that the permit be issued:
signature of Report re -Pa rer Fa e
r
Water Quality Pe anal Supervisor Gate

.rim

RAT[NG SCALEFOP, CLASSIFICATION CAP FACILITlES
1\ 1 ,i m ca rN f P I'd n t- u Y[ _ I a n t o r'
-
Owner or Contact Person.
Mailing Address:
----------------
County, 1 t�'Telephone-III� 5 -(
( PDES Permit No NC C�.� Nondlsc. Per. Na._ A9'
y is ueDate. P dilation Date. -
Existing Facility New Facility
Rated y: date:
Reviewed (Train. & C,er.) Reg, fie
Reviewed (Train. & Cert.) Central Office
ORC Grade
Plant Class- (circle one) l 11 111 ILA Total Points
1TFl t POINTS; (5):SECONDARY TREATMENT UNITS
C: b
(1)
Industrial Pretreatment Units and/or
Industrial Pretreatment Program
(see definition No. 33)
4
(2)
EI FLOWS"" OFPLANT INGPi
(not applicable to non -contaminated cooling waters, sludge
handling facilities for water purification plains, totally
closed cycle systems (clef, No. 11), and facilities
consisting only of Item (4) (d) or Items (4) (d) and ;11)
(dt�
00,000 .............. ...........
l
20,001 50,000 . .. . . : . .. . ............. .
2
50,001 100,000 . . ........... . ... . ..:.....
3
100,001 250,000 ..........................
4
j
250,001 500,000 ; . .... . ......:......... . .
5
500,001 •-1,000,000 .... . .. . ............ . .... .
2,000,001 (and up) m, rate 1 point additionalfor each
200,000 gpd capacity up to a
maximum of 30
Design Flow (gpd)
(3)
PRELIMINARY UNITS (see definition no. 32)
(a) Bar' Screens ..... . .. . ..: : ................... .
1
or
(b) Mechanical Screens, Static Screens or
Comminuting Device .....:..... . .......... ti
2,
to Grit Removal ................ ....... .:......
1
or
,F
(d) Mechanical or Aerated Grit Removal . , .... , ... .
a
(e) Flow Measuring Device ..... .....:.....: . ...:.
1
or:
(f) Instrumented Flow Measurement . :.... ......
2
(g)Preaeralion,... .... ....:........:.....;...„:,
(h) Influent Flow -Equalization .:.........::...:: .
2
(i) Grease or Oil Separators - Gravity ... .. , ..:.
2
w
Mechanical . , , ..... , .
Dissolved Air Flotation.
Prechlorination ... , .. . ......... :. . ..........
5
a (4)
PRIMARY TREATMENT UNITS
(a) Septic Tank (.see definition no. 43)......... . ..
2
(b) lmho(i Tank ........ . ......... . ........ e ..: , ..
5
(c) Primary Clarifiers ......
5-
(d) Settling Pondq or Settling ranks for Inorganic
Non toxic Mauerials {sludge handling facifilies
for water. purification plants, sand, gravel,
stone, and other mining operations except
recreational activities such as germ or gold
raining) .
(a) ar onaceous Stage
(i)Aeration - High Purity Oxygen System .: ; , .
20
Diffused Air Syslem ....... ...
10
Mechanical .Air System (fixed„
floating or rotor) , ... , , .... ;, . , .
8
Separate Sludge Reae a,ion :..:.,
3
(ii) Trickling; Filter
High Rate
Standard Rate ,
5
Packed Tower ..............
(iii) Biological Aerated Filter` or Aerated
Biological Filter . . ... . .. . .... ..... . ..
10
(iv) Aerated Lagoons „ .. . ...... . ........ .
10
(v) Rotating Biological Contactors .. , .....-, .
10
(vi) Sand Filters -
intermittent biological ; . , , ,
2
recirculating biological .....
3
(vii) Stabilization Lagoons .... , , .. F..... „ .:
_5
(viii)Cfarifier ... ... ::.:. ... „ .:, , _ .. «: ,. . .. .:. .:.
5.
(ix) Single stage system for combined
carbonaceous removal of SOD and
nitrogenous removal by nitrification
(see def. No. 12) (Points for this item
have to be in addition to items (5) (a)
(i) through (5) (a) (viii) .. . . . . .:. . ..... .: «
8"
(x) Nutrient additions to entrance SOD
removal. .....:...........
(xi) Biological Culture ("Super Rugs") addition
to enhance organic compound removal .....
5
(b) Nitrogenous Stage
(it Aeration = High Purity Oxygen System . ..:
20
Diffused Air System ....... .. ... .
10
Mechanical Air System. (fixed,
floating, or rotor) , , . : . . ..., ..
S
Separate Sludge Reaeration . „ ...
3
(it) Trickling Filter
High (Rate .
7
Standard Rate ..... A. ti ,, ..
5
Packed Tower ..... ... , ..
5
(iii) Biological Aerated Filter or Aerates)
Biological Filter , .. n ... . .... . . ..... .....
10
(iv) Rotating Biological Conta lars .::.... , ....,
10
(v) Sand Filter -
intermittent biological ....
2
recirculating biological ..... ..
3
(v i) clarifier:.,.. .:............:...,........
5

,'6) TERTtAP ;, OR ADVANCC-0 TREATMENT UNIT
(a) Act vated Carbons Beds -
w,=::�nuC carbon regeneration ... ,
kv .'r carbon regeneration - , . _ .. 5
(b) Pov�, Bred or Granular Activated Carbon Feed .... is
"«w-i,.n€aut carbon regeneration .. „ . , .
carbon regeneration , . , 5
(r) i; Stripping . 15
(d) D e �iitrificalion Process (separate process} 15
(e) Ele-.wtrodialysis , . , .
(f) FOann Separation , 5
(9) lc , Exchange .
(h) La n�d Apphcahon at Treated Elltuent
(see definition no. 2b) (not applicable for
sand, gravel„ stone and other sirniiar mining
operations)
(if on agricrrfluralty managed &files (See cdel,
No, �)......... ..
(r") by high rate infiltration on non-agricullurally �
managed saes (includes rcslary distributors
arc similar fixed nozzle systems) . , , .. ,
(iii) by subsurface disposal (includes Iowa pressure
P'Pe systems and gravity systems except t
plants consisting of septic lank and nilrifica-
lion i4nesonly) , .. . :.
(i) t�licroryreen .. .. , .
(j) Phrasp`srarus Remoaal by Biological Processes'
(See 6ef. No. 26)
(k) Polish'ng Ponds ithoul aeration .. „ 20
With aeration... . .
(1) PostAeration cascade S
diffused or mechanical . 5
(rn ) Reverse Osmosis . .
(n) Send cr Mixed -Media Filters -glow rate .
(o) 7reatr v. t processes fhigh rate or remOvat of metal or
cyanide
(p) Treatment processes for removal of toxic 1 S
materials other than metal or cyanide
(10) CHEMICAL ADDJTION SYSTEM (S) (See clehnilic;; O g)
(not applicable to chemical additions rated as item
() (Jt` (5) (a) (xi). (6) (a), (6) (b), (2) (b), (T) (el,
(9) (a) (9) (b), car (5)(c) 5 Points each List,
5
(11$ MtSCELLANEt U S UNITS.
(a) Holding Ponds, Holding Tanks or Seufinl Porads
for Organic or Toxic Materials including waste
from tinning operation containing nitrogeand/or
n and
Phosphorous compounds as arnourats rO,2etecan d
neater than ly
is cornna011 for domestic V,°asiewater ....,.... (b) Effluent Flow Equalization (not applscabae to storage �
basins which are inherentn land ,application systems),
(c) Stage Discharge (not applicable to.storape basins inherent in land application systems.
(d) Pumps,-...
5
(e) Siand-J3y Poorer Supply.,,....
M Thermal Pollution Coni of Device 3
5
TOTAL'PC1NTS
CLA.SSiRCATION
Class 1,
Class if .„.. .,,.:: S - 25 Points
Gass t€i ....:., ,
6- 50 Points
Class
51- 65 Points
t'v ........
66- Up Points
Facilities having a, rating Of one through four points, inclusive,
do scat require a certified operator. Classification of QI: other
facifJlies requires a comparable grade operator in of 2:i the
charge.
Facilities having an activated sludge process will -be assigned
trUDGETR `Tt,rENT a mmirnum classification of Class IJ,
(a) Slu:'ge Digestion Tank -Pleated, .; 10 Facilities having treatment processes for the removal of metal
Aerobic ..: 5 or cyanide will be assigned a minimum classification of Class it,
Unheated .
(b) Slutge Stabilization (chemical or thermal) . " 5 Facilities haying treatment processes for the b"sraloclicat re rnoval
40) lurcge Drying beds - Gravity ... " , .. , .2
Of phosphorus will be assigned a minimum classification of Class
Vacuum Assisted .: , .. 5
(d) Mudge Efuinauon ............. .
(e) lurdge Conditioner (chemical or thermal) .... 5
(f) Sludge Thickener (gravity) ............ . . . ; .
(g) Dissolved Air Flotation Unit
(not applicable to a unit rates as () () a
(h) hedge Gas Utilization (including 6
( g gas storage) . . , .
(i) Sludr e Holding Tank - Aerated .
Non-aeraled ,
W ludrte Incinerator . , 2'
(not including activated
carbon regeneration) , , _ , . 1 tl
(k) Vacuum Fifler, Centrifuge or Fillet Press or other
Similar dewatering devices .. . ,
SLUDGE DISPOSAL (including incinerated ash)"
(a) Lagoons
(b) Land Application (surface and subsurface)
(see definition a)
where the facility holds the land app. permit .
-by contracting to at land application operator who i g
holds the land application permit
-land application of sludge by a cordtactor who does
not hold the Permit for the wastewater treatment
facility where the sludge is generated :. , ..... .
(c) Landli (burial) f
)ISINFECT ION 5;
(a) Chlorination . 5
(b) ch ror a lion , 5
(c) Ozone . _ .. ,
(d) Radiation— , .. a . . . . .... . ...... 5
5;
!n•polanf processes and related control equipment which are an
integral part of industrial production shall not be considered waste
treatment, likewise, discharges cal wastewater from residences
ratinghaving g, a design flow oP 1,000 gpd or less, ,shall not be subject to
A211tTJQ A C7dfih& "ttT
Z

gV DIVISION OF ENVIRONMENTAL MANAGEMENT
e,
WATER QUALITY SECTION
FEBRUARY 10, 1992
MEMORANDUM
xMictsm
TO. E CH LEA , I`v RE ILLE WATER QUALITYUPER iE I` � t
FROM; MARK E. HAWES4&�---'
ENVIRONMENTAL ENGINEER
STATE ENGINEERING II' EVIE' GROUP
SUBJECT: APPLICATION # WQ0006099
PROJECT TYPE: RECYCLE FACILITY
WILLARD INDUSTRIES, INC.
MECKLENBURG COUNTS
Please provide regional comments for the subject project. Attached you will
find a copy of the project documents. Please let me know if you require additional
inforni tion. Provide the regional contact for this project within 10 days of receipt.
If you have any questions please contact ire:
cc: Permit File
rz� ,
.w
,2
ry
ry

NON HPDEO FACILITY AND PERMIT DATA
UPDATE OPTION TR ID E0U KEY WQ0006099
PERSONAL DATA FACILITY APPLYING FOR PERMIT A P/PERMIT FEE_ 00,00 REGION
FACILITY NAME> WILLARD INDUSTRIES—WILLARD IN4 COUNTY> MECKLENBURG OE
ADDRESS: MAILING (REQUIRED) ENGINEER: NATIONAL ENVIRONMENTAL TE
STREET 101 NEWBERN STREET STREET: 9 00—E SOUTHERN PINE BLVD
CITY: CHARLOTTE ST NC ZIP 28203 CITY: CHARLOTTE ST NC ZIP 28273
TELEPHONE 70A EES 1230 TELEPHONE: [phone]
STATE CONTACT> HAWES FACILITY CONTACT CLARENCE WILLARD
i yPE OF PROJECT> RECYCLE 'FACILITY` LAT � LONQ
DATE APP RCVD 01 /2� /0 N=NEW, M=MODIFICATION, R=REI00U N
DATE ACKNOWLEDGED 01/29/92 DATE REVIEWED / / RETURN DATE
REAR COMM RE E 02/10/92 DATE DENIED / / NPDES -
REG COMM RCV"D DATE RETURNED 0 / TRIO Q' 0000 MGD
RDD INTO PEGS OT AG CON REQS 02/10/92 TRI'E DATE---
ADD INFO R'CV D OT PG CON RCVD / r
END ETR T APR P 0,1/23/92 DATE ISSUED / DATE EXPIRE
IRE r {'
FEE CODE( 9 )1-()1MD),=(>10KGD)aE=(>lKGD),,4=(<lKGD- F). -C >E00N ),6=CS<=300A),
7=(SENDEL).E-ISEDEL),13(CLREC),O=(NO FEE) DISC CODES HSN/CHG PRMT
ENGI CE RT DATE LAST NOV DATE CONK ILL I
COMMENTS
MESSAGE: xx* DATA MODIFIED SUCCESSFULLY
'ArsotTjtc,vs xNu
ODX. sa.
woe# of��"

IL Q . Of NATIVA&
RESOURCIES
State of North Carolina
Department of Environment, Health and Nato d
Division of Environmental Management
12 forth Salisbury Street w Raleigh, North Carolina 27604
James G. Martin, Governor George T. EEverett,Ph.D.
William m . Cobey, Jr., Secretary Director'
Januarys 29, 1992
MR CLARENCE WILLARD
WILLARD INDUSTRIES, INC.
101 NEWBERN STREET
CHARLOTTE, NORTH CAROLINA 28203
Subject. Application No, WQ0006099
Willard Industries
--Recyple, Facility ._.
Nish County
Dear MR VILLAt
The Division's Pen -nits and EngineeringUnit acknowledges receipt of your permit application and
supporting materials on Januarys 24, 1992. This application has been assigned the number shown
above. Please refer to this number when making inquiries on this project.
Your project has been assigned to Mark Hawes for a detailed engineering review. A technical
acknowledgement will be forthcoming,
e aware that the Division's ion's regional office, copied below, must provide recommendations front the
Regional Supervisor or a Procedure Four Evaluation for this project, prig to final action by the
If you have any questions, please contact Mark Hawes at (1) 733-5083,
Sincerely,
Ct
�to A,4-�p (�
..
Donald Saffit, i.E.
Supervisor, Permits and Engineering gait
cc Raleigh h Regional Office
National Environmental Testin
Pollution Preveruion Pays
P.O. Box 29535, Raleigh, North Carolina 7626-05 5 Telephone [phone]
n Equal Opportunity A furnarivc action Employer

!44
t a'
State of North Carolirra
Department of Environment, Health, and Natural Resources
Division of Environmental Management
Non -Discharge Pen -nit Application ?
(THIS FORM MAYBE PHOTOCOPIED FOR USE AS AN ORIGINAL) -_J
MECHANICAL TREATMENT AND NONDI ACT- AR E DISPOSAL FACILITIES
1. GENERAL INFORMATION:
1... Applicant (corporation, individual, or other):2. i on
Print Owners or Signing Official's Name and Title (the person who is legally
responsible for the facility and its compliance)-
3. �^�a�on i l lar
Mailing Address:
Cagy: ar Q State: zip: 2
Telephone No.: ( 7 4523-1230
4. Project Dame (subdivision, facility, or establishment name - should be consistent with
project name on plans/specs., letters of flow acceptance, Operational agreements, etc.):
Willard IndustriesInc.
5. Application Date: 10/1/ i 6. .
Fee Submitted:
7. County where project is located: Mecklenburg
. Address of treatment and disposal facility: Same as MailingAddress
9. Latitude: 350 Ill 5611 ; Longitude: o i "
g of disposal facility'
11. PERMIT INFORMATION:
1. Permit No. ; (will be completed by DE :
. Specify whether project is x new; renewal*; modification.
*if renewal, complete only sections 1, 11, 111 and applicant signature
(on pg.1 . ubmit only pgs= 1, 2, and 12 (origipal and 3 copies of each). Engineer
signature not required for renewal.
'F'+1 TD 4/ 1 Page l of 1 ;

TREATMENT
PAGE 2 MECHANICAL(4/9 1)
3; If this application is being submittedas a result of a renewal or modification to an
existing pe t, list the existing permit number
d issue date
. Specify whether the applicant is _ public or X
private.
--4
III, INFORMATION ON TEWA ER
1. Nat of Wastewater: % Domestic; % Commercial;
0-0 % Industrial; % ether waste (specify):
2, Please provide a one or two word description specifying the origin of the wastewater,
such as school, subdivision, hospital, commercial, industrial, apartments, etc,:
nduaril.
3. If wastewater is not domestic in nature, what level of pretreatment has been provided
to -ensure protection of the -receiving wastewater treatment facility:
otl ro cl of ilttd f-to roll tlon o
4. Volume of wastewater generated b this project- 5 0
g p 1 gallons per day
. Explanation of how wastewater volume was detour incd; Summation of floor
d non-corot coon water volume.
d. brief project description: taon:. �°loo a w��tr end rton-�rtt c+�crl..inwater I
I t them filtrate is reused in atotal
recycle operation.
IV. DE -INFORMATION:
AT"ION
1. Type of wastewater treatment facility (extended aeration, oxidation; ditch; activated
sludge, aero-mod, other)': Filtration
on
. For coastal facilities and golf course spray irrigation facilities, all ;essential treatment and
disposal units gust be provided in duplicate.Specify: ® golf course spray facility;
coastal facility; other. Howe many units have been provided
3. Specify the design flow of the facility: 500gallons per dad
" Specify the volume of the a nixed flower equalization basin or tank: 550 gallon
e required equalization tatty volume is determined from a diurnal hydro ph
analysis of the maximum and minimum flows expected.
. Specify the number of and capacity of the pumps used for flow equalization:
pumps at GPM each:
m How many bar screens are provided? North
7. Specify' whether bar screens are; manually cl ned; mechanically cleaned
of 13'

MECHANICAL 'i
PAGE 3 (4/ 1)
8. How 'Many flow sputter loxes are provided? None
. Are the flow sputter boxes designed to allow the excess of the average daily flow t
returnto the equalization basin? yes. no N/A
10. How many aeration basins are provided"? None
11. What type of aeration is provided (coarse bubble, fine bubble, floating aerators, etc.)?
N/A,
12. Specify thevolume for each aeration basin. N/A
gallons
gallons
11 What is the detention time in the aeration ba in(s)? hours
14. blow many clarifiers are provided?
15. Specify the volume for each. gallons
gallons1. . What is the sidewa,ter depth of the clarifier? t feet
17. at'is the de' tendon time in the cl °fier( )`? A hour
l at i the el fief surface loading rate? N/A GPD per square foot
. What is the clarifier solids loading rate"? N A pounds per square foot per hour
20. What is the weir loading rate? N/A per er t
2 L Specify the volume of the'mq_uired sludge holding tank: N/A
gallons
22. Is the sludge holding tank heated? yes; -no /A
23. Is the sludge holding l aerated? yes, no N/A
24. Determine thepopulation'equivalency (PE): P = flow in CPI / 100 GPD per person
tit � �G P / 100 G PD per person 5 population equivalency
25. Determine the per capita sludge capacity (PCSQ:
PCSC = sludge tank volume in gallons I ( (PE) (T48 gal. per cubic foot))
gallons (I ) (7.48 gal. per cubic ft.)) N/A
26. List the number and capacity of all blowers and what each serves:
27. How many tertiary filtration units are provided (dual, units required)? None
8. Specify what tertiary filtration units are provided (traveling bridge, dual beds, ether):
N
29. What is the area of each filter? square feet
30. What is the filter loading rate*? _- WA GPM per square ft.
*Filter loading rate should be less than 1.25 GPM per square foot
31. What is the clearwell capacity? gallons
e13

xi
° r PAGE 4(4/1)
2. The minimum clearwell capacity needed is: (filter area) (15 GpN4 per ft.) (10 minutes),
Min. clearwell capacity = ( to t
) 0 5 GPMper ft. (10 rein)
°n. clearwell capacity needed is:
3. at s the mudwdll capacity' A gallons
gallons
4, The minimum mudwell capacity needed is: backwash vol + inflow during backwash
backwash volume = clearwell capacity
inflow during backwash = (flow) 1 1 minutes) / 1440 minutes per day
`n. mudwell capacity LG D) (10 min.)) 1440 min./day al..
minimum mudwell capacity Wedded is:
A
35, What is the thickness of the d:� /'A gallons
inches
36. What is the thickness ofanthracite? N/A
inches
u What are the sand specifications? N/A mm for effective size;
uniformity coefficient; dust content
. The sand specifications are included on page A .� of the plans or
on page. of the specifications.
. What type of chlorination is provided?Non
40. What is the volume of the chlorine contact chamber`? A
gallons
41. How much detention time is provided(minimum 30 minutesrequired)? /A "notes
42. Has residual chlorins removal equipment been provided? � . yes; X no
If yes, what e?
43. What is the volume of the effluent dosing or spray tanks? N/A
gallons ,
44. Specify the'number of pumps and their capacity:
pu ps at 20 and 60 GPM
45. What is the total dynamic head? 40 and lea
feet.
4. The pump curves are included on page _ of the plans or
on page of the *See Attached Cut Sheets specifications.
4 Specify the high water alarms provided: audible & visual; : auto dialer
48. What sludge handling equipment is provided? Filter cake from the bag filter
manually transferred into on —site storage drums
a
How, where and by whom will the sludge be ultimately disposed` Sludge will
IIIf-; ,tea--1 L.- .---__ . -, ,
Metals: One Executive Die, Fort Lee, NJ 07024
tam if the sludge is going to be land applied by a contractor list the existing permit number
NZA ; and issue date
1. Explain how the sludge will be treated to comply with the "Processes to Significantly
Reduce Pathogens." Transported for off -site leach reclamation
4 of 1

CRANICAL A
PAGE 5 (4/ 1) TMENT
52. What is the name of the closest do nslop surface waters?
53. 1 in ree Classification best do�,nspe.suface t�vater9
established by the Environmental Management Corturrission and specie on page 10 of
this application)
54. If a power failure could impact waters classified as fir', , S A,1 , or S describe which of
the measures are being implemente l to prevent such impact, as required in 15 ,N
CAC
,m
55, If the facility is a coastal facility or a golf course spray irrigation facility describe
automatically activated standby power system: /
56. Describe any other treatment ent units that are not previously described;
floor
wash water an le a ncrt-�ocro e lr u
5er
allon it ti n- i in t �bgravity .flew and
aril thrsugh 'carfrdg filtration unit fag filtratln.'
cl an haldin tanl from which it i
" e for•r usd; �hd l e filter c e tram the
r ed atorec in onaitd car for
° � d reel. anon facilities ® 'phi f �. atotal. filtrate recycle to fee attached igur.
COMPLETESECTION V, V , OR VIf THAT APPLIES. FOR THOSE:
SECTIONS OR QUESTIONS THAT DO NOT APPLY, WRITE t
OT
APPLICABLE OR N/A. ALL OTHER SECTIONS MUST BE COMPLETED
V. RAPID INFILTRATION
L What type of rapid infiltration system has been provided (rotary distributor, s
beds, other)? pra
y
2. What is the vertical separation to the seasonal high water table?
® hat is the loading rate (rust not exceed 10 P I ft. ? feet
PI d ft.
4. Hoar many disposal areas are there?
5. What is the square footage ;of each disposal a?
square feet.
d. What is the square footage of the "green ea?"
. `hat material is the rot distributor constructed or.
square feel
. What is the diameter of the rotary distributor?
Is the roc distributor hydraulicallyor motor given? feet
5ofl

MECHANICAL TREATN[ENT
PAGE 4/1
10. The rotary distributor disposalarea should be completely surrounded by a masonry
type wall that extends at least 18 inches below ground surface and at least 12 inches
above ground surface. Specify how far below ground, inches; and above
ground. inches, these ells extend;_
V1. GOLF COURSE SPRAYS
1. What is the name and location of the golf course = that is being irrigated with treated
wastewater?
. What is the volume of wastewater to be irrigated? gallons per day
3. What is the volume of the five day detention pond? gallons
4a :how is public access prevented from the 5 day detention pond?
5. Is the 5`day detention pond lined? . yes, , no. at material
a at volume of storage is required by the'water balance minimum of 60 days)?
days; gallons
. What volume of storage is provided in the storage / irrigation pond
days; gallons
8. Is the storage/migation pond lined? ..m yes, no, What material?
. The spray node specifications are on page f the plans or specifications
10. What is the loading rate recommended y the sails scientist' Mess than 1.75 in.' w
in. / hour; in. / week; in. / year
i, SUBSURFACE DISPOSAL
l . Specify the loading rate recommendation, mendation, as determined by the sails scientist, for the
subsurface disposal field: GPD per square foot.
2. Specify the loading rate recommendation, as determined by the soils scientist, for the
repair area (100% replacement) subsurface disposal field: per square ft.
3. Specify design loading rate that will occur in disposal field: GPD / t.
(In coastal areas the maximum is 1.5 GPD / square foot for gravity systems and-1.
GPD per square foot for low pressure systems).
6 of13

P
;, Specify the number of subsurface fields: 'A The dimensions of the fields:
Supply line die.:
g Manifold dia.: ; Distribution lateral
d.ia.- bole dia_; Number of laterals. �-
Lateral length
(typically 70 ft, max. for LPP & 100 ft. max. for gravity): , Trench
width: Trench depth.
x Minimum pressure head::.
Maximum pressure head: Minimum vertical Separation between trench
bottoms d mean seasonal high water table: ; Distance on centers (fear LPP not
less th 5 ft-):Maximum shape of trenches (should be less than 0.2% for
gravity systems): . Details must be provided in plans/specs which
demonstrate that the ends -of lines are plugged, that turn -ups are provided
for LPP, and that measures will be taken (grade boards, etc.) to ensure
that laterals are properly installed.;
5. The following criteria should be used for the sizing of residential septitanks:
a" three bedrooms or less, use minimum 900 gallons;
b. four bedrooms , use minimum 1000 gallons;
c. five bedrooms, use minimum 1250 gallons.
. For businesses with a design flow less than 600 GPI , the'; minimum tank capacity shall
be twice the flow.
7. The following criteria should be used for the sizing of septic tanks for residences with
k
more than five bedrooms, multiple family residences, 'tanserving two or ore
residences*, or establishments with a flaw between 600 GPDand 1500 GPD-
Septic Tank Volume = (1 T17) (daily sewage flow) + 500 gallons
*Minimum septic tank capacity shall be 1500 gallons
. For design flows between 1500 GPD and 4500 GPI , the following criteria shall be,
used. Septic Tank Volume = 1.7) (daily sewage flow) + 1125 gallons
q. For design flows which. exceed 4500 GPD, use a septic tank capacity equal to the. flea.
Ili. Specify the septic tank volume: gallons
11. Specify the pump tank volume: gallons
11 Specify the number of pumps and their capacity:
pumps t GPM
1m Specify the high water alarms: audible & visual
earn dialer
typically . p laterals, or ups f laterals in subsurface system are
I The different disposal fields,
y signed to be dosed at different rues or volumes from one another. Explain
the method that will be used to ensure that the proper dosing rags and ;volumes occur:

WCHANICALTREATNENT
PAGE 1
III.BUFFERS:
1 The following buffer zones roust be maintained:
a) 400 feet between wetted irrigation area and any residence under separate ownership
b tl feet between the wetted area and residences outside of the
golf course development for golf course sprays,
c) 100 foot vegetative buffer between nearest residence and edge of spray influence
for golf course spray irrigation disposal systems;
d 150 feet between wetted area and property lanes;
150 feet between the wetted area and property lines of lots outside f
p pthe;.
golf course development for golf course sprays;
feet between spray irrigation systems and any adjoining proper and shall be
buffered by trees in coastal areas
I,
g) 100 feet between wetted area and wells;
feet
e from public surface water supplies orpublic
pp shadow (less than 50 feet
groundwater supplies; or 1.00 feet from private ,groundwater supplies in coastal_
100 feet between wetted area and drainage ways or surface water bodies;
J feet between Fretted area and public right of ways;
100 feet between wastewater treatment units and wells;;
1 feet between wastewater treatment units and property lines,
. if any of the applicable buffers are not being met, please explain how the proposed
buffers will provide equal or better protection of the Waters of the State with no increased
potential for nuisance conditions.
THIS APPLICATIONPACKAGE WILL NOT BE ACCEPTED BY THE
DIVISION OF ENVIRONMENTAL MANAGEMENT AGEMENT UNLESS ALL O'
THE APPLICABLE ITEMS ARE INCLUDED WITH THE SUBMITTAL
Required Items
a. One original and three copies of the completed and appropriately executed application
fo
b The appropriate permit processing fee; in accordance with 1 .A NCAC' 2H .0205(c)(5).
c: Five copies of the existing permit if a renewal or modification.
f1

h,
f 4
� i • i ! r
.. � ice •
tt # s
For sprayfields a signed agronomist report which states t do that is n
for the spray fields, s, alongwith rn ement and harvest schedulesed
For spray systems an analysis of the wastewater, including heavy
metals totals and synthetic
or antics, along with calculations for the most limiting constituents.
For golf course sprays the specifications rest require that signs be posted stating that the
golf coarse is irrigated with treated wastewater, that spraying will occur between 1 l.i p.rn
d three hours prig to the daily opening of the course, that the spray piping will bee a
separate system with no cross connections to a potable water supply (there shall be n
spigots on the irrigation distributionsystem), and that the treatment process will produce an
effluent with a Monthly average TSS of less than 5 milligrams per liter and a daily maximum
TSS of less than 10 milligrams per liter and a maximum fecal colifc� level of less thin I
per 1 millilitersprior to discharge into the five. day detention pond.
oft

1
TO: REGIONAL WATER QUALITY SUPERVISOR
Please provide me with the classification f the surface waters identified in number
below and on the attached reap segment.
Name of surface waters:
Classification (as established by the Environmental Management Co nissi an):
Proposed Classification, if applicable- _ L
Signature of regional office personnel: Date -
INSTRUCTIONS TO ENGINEER
I. Applicant (corporation, individual, or other):
,. Name and Complete Address of Engineering F° National: _ nvl.ronm nttal
Technologies, Inc. 9400-E Sofitherntrine Boulevard-
City- Charlotte State: NC dip: 28273
Telephone No. [phone]
3. Project e: lotal Recycle Operation & Sludge..Filtration
. Facility design flow: 500 GPD
l . of closest d- --ri lope surfacewaters:
. County(s) xiiere project and suzface waters are located- tuck e t
7. Map name and date. Topographic Location Map - 'October 31, 1991
SNorth Carolina. Professional Engineer's Registration No. 12844
9. Print Name of Engineer
10. Seal and Signature (specify date),
1 of 13

DIVISION OF ENVIRONMENTAL MANAGEMENT, REGIONAL
Asheville Regional WQ Super,
Washington Regional super.
44 i
59 n 'laceRaleigh
P O 1507
Regional °Q super.
Asheville, 880
Washington, ton, ` 88
38 Barrett Dr., Suite 1 1
704, Si-t
919/946-6481
Raleigh, N27 609
1 f73 -231
Avery Macon
Buncombe Madison
Beaufort Jones
Berrie
Nash
Burke McDowell
i e Lenoir
den n
% is pairs:
Caldwell Mitchell
hnw Pas�ilic
rntse Orange
CherokeePolk
Clay Ruth
cravenP u
"back
Franklin Person
�T Swainiare
u Perquirnans
Halifax }
ax
Haywood Transylvania
Pitt
Gates Tyrell
Johnston ' Warrco
c n Henderson 'k cy
Greene WashingtonLee
Wilson
Hertford a
Hyde
Fayetteville Regional WQ Super.
Wachovia
Mooresville Regional WQ Super.
Building, Suite 71Wilmington
91 Main Street
Region. WQ Super.
Fayetteville, 28301
Mooresville,
res ille, I t = 8'115
127 Cardinal Drive Extension
1i�8-15� I
7f3� 169
Wilmington, N 8 0 -3845
919f395-390
Anson Moore
Bladen Robeson
Alexander Mecklenburg
Cab
Brunswick blew river
Cumberland Richmond
Catawba Staianly
Carmret Onslow
Hamett Sampson
Gaston Union
Columbus Pender
Hoke Montgomery S
Iredell Cleveland
uplin
l.rilcnlri
Winston-Salem Regional WQ Super;
8025 North Point Boulevard, Suite 100
Winston-Salem, N 7106
919/761- 35
Alamance Rockingham
Alleghany Randolph
Ashe Stoke
Caswell Surry
Davidson Watauga
Davie Wilke
Forsyth Yadkin
Guilford
11 of 13

t
PAGE I C .I
Nameland complete address of Engineering Firm: National Environmental
oul he Pine Boulevard,
City: State: Zip: 28273
Telephone o. t
Professional Engineer's Certification:
I, Dolan F. o , attest that this application for a non -discharge ;
Permit has been reviewed by me'and is accurate
d complete to the best of my knowledge. l further attest that to the best of my knowledge the
proposed design has n prepared i accord ce with the applicable regulations. .lthoat h cermin
portions of this submittal package may have been developed by other professionals, inclusion of
these materials gander my signature and seal signifies that l have reviewed this material and have
gad it to be consistent with the proposed design.
Now Carolina Professional Engineer's Registration No. 12844
Printe of Engineer
4
Seal and Si e (sp, ify date): Iss
o a
SE AL
*
CIO
oS
Applicant's Certification: ����� ,, A1,431
r
a
attest that this application for p
has been reviewed by me and is accurate d complete to the lest of my knowledge. I understand t
that if all required parts of this application are not completed and that if all required supporting
information anti.: attachments are not included, this application package will e returned as
incomplete.
Si,a e—i—ate
THE COMPLETED APPLICATIONPACKAGE, INCLUDING ALL SUPPORTING
INFORMATION AND MATERtALS, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH A JLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER U L SECTION
PERMITS "S AND ENGINEERING UNIT
POST OFFICE BOX 29535
512 NORTH SALISBURY STREET
RALEIGH, NORTH CAROLINA 76 6- 53
TELEPHONE NUMBER: 19/ 33-5 3'
12ofl3

.
NMCHANICALTREATNENT
PAGE 1 4/91 )
PERMIT APPLICATION PROCESSING
FEES�
(effective October i, 199
4+'D A ONS
MODIMCATIONS
1,000,000 GPI
P
Industrial
4
Domestic/Cooling water
4
10,001 - 1,000,000 GPD
Industrial
4
2 50
Domestic/Cooling Water
400
1,001 - 10,000 GPD
Industrial
40
Domestic/Cooling Water
0
or = 1,000 GPD and
Single Family Dwelling
24
120
Sludge < or = 300 Acres
4
2.
,Mudge > 300 acres
400
$2 50
Sewer Extensions
nondele,ated
4
Serer Extensions
(delegated)
24
Closed -Loop Recycle
or Evaporative
4
24
NOTE: The Fees for Soil Re
ediatio n Projects are the
same as for Sludges
Under the Sewer Extension Fee, "delegated
only to those
to municipalities" applies
governmental ,jurisdictions that have ,specific delegation
review_ authority, as granted by the .Division of Environmental
Management.
13 of 1

>C00UNG TOWER
R"W KERN SNEE7
UCFI '
///RApRfCATPON .�
7777,
CL
Er
i,PRODUCTION
r STORM
PRAM
1 `
REFINING
STORM
DRAN
WASH
x
/ FILTRATE
OUFFAL
RET
CONCRP TE
SWWALE l - WFLL HOUSING
WASH
WAT( G
SUMP m_ to
OA sr AREA r SUMP PIPE r � , �� � ������ � AR
/f f ✓ r RECYCLED
Fr MtCHINE,rAL a
✓ SHIi' "=
CURB
Ito
f_
ME OF x,V, ass o.T—�_ �,
NOT TO SCAl
CEILN] /TITLE
DW
DATE WILLARD INDUSTRIES
DFC..x, 1991 C hTiHo tc NC
OWC NO

F 7:-
REFINING
BUILDING
f'?RAC
RECYCL;D FILTRATE UNE
17" (5�) ',ALV. STEEL PP`E
C A Rol
Ilk
of
MACHINE
SHOP
550 GAL, NIFLUEN'�
T,5NK & AGJATOR
I -ALARM FLOAT
okv
-HIGH FLnA-
BAG �MlLTER
LOW
rLOAT
-,J
'FILTER FEED PUMP
(20 GPM 0 40' TGH)
111/
FILTRATE RETURN PUMP FOOT VALVE
(60 GPM 0 160' IDH)
EALL VALVE
CHECK VALVE
PRESSLRE GAUGE
NOT 70 SCAIE
EEO - H CLIENT/TfTLE
DW 'TOK WILLARD INDUSTRIES
DATE Charlotte, NC
NTT—,oNAL DN-viR o N\T --Am4F N T A L E�-, C II—N O—L 0- -G�l /iS- -i Xrxc JAK 3, 1992
DWGNO, — Washwater Recycle System
077001PO3 Fiau,,re 2

1) ATTACHMENT A: Figures
a) Topographic Location Map
t) Site Plan
) Washwater Recycle Systems
) Recycle y'st m Process Flora Diagram
2 ATTACHMENT B: Equipm nt Specifications
a) Liquid Filter ;Bag Housing
t) 550 Gallon Receiver
) Filter Influent Pump
) Filter Effluent Pun
) Liquid Level Float Switch
) ATTACHMENT `alit mash Water "r.tahlty Study
Report

1,0 INTRODUCTION
The Willard Industries, Inc. (Willard) facility located at 101
New Bern Street in,,Charlotte, North Carolina, manufactures
various metallic products such as keels, solder, sheets,
pipes, flashings, and roofing accessories. Metals used in
these manufacturing processes include tin, and antimony, but
lead is used primarily. The Willard site plan is shown in
Figure 1. Part of regular operations conducted at the
facility includes the periodic washing down of floors in the
lead refining area. This refining area wash water flows into
four separate floor drains, through a single pipe, and is
collected in a water recycle pit located outside the machine
shop building as shown in the site plan, Figure 1. Single
pass non -contact cooling water from the refining area is also
discharged to the recycle pit. Water from this pit is
recycled back to the refining area and is used for floor
washing and single pass non -contact cooling water.
National Environmental Technologies, Inc. (NET), was retained
by Willard Industries to conduct a wash water treatability
study. This study includes the investigation of potential
treatment methods to reduce the concentration of lead and
other heavy metals in the recycle wash water and the
optimization of sludge handling operations at their recycle 7
pit. This report summarizes the findings of the wash water
treatability study.

2.0 REFINING AREA AND RECYCLE PIT PROCESS DESCRIPTION
In the refining process, blocks of lead are heated to 800 degrees
Fahrenheit (deg F) in two separate melting pots. As the
temperature increases, various chemicals are added to the batch of
molten lead to remove copper, tin, and antimony. The temperature
is then decreased to 600 deg F and the refined molten lead is
transferred to one of two different molds. Dross is then scraped
from the molten lead surface and placed in troughs. This dross is
drummed and transported to a secondary smelter for lead
reclamation. The refined, molded lead is then cooled and stacked
for further processing or sales. Single pass non -contact cooling
water flows in an enclosed channel around the melting pot to
decrease its temperature after the molten lead has been removed
from the pot. Non -contact cooling water is also used to cool the
lead molds following transfer from the melting pots.
Henry Sherrill of Willard Industries estimated that the refining
area floor is washed down once per day for approximately 10 minutes
as part of the routine cleaning procedure. Some of the dross to
be placed in the troughs is inadvertently spilled onto the floor.
Lead contaminated water is then washed to the recycle pit.
Assuming the wash water flows from the hose at 10 gpm,
approximately 100 gallons of wash water is discharged to the
recycle pit per day (100 gpd).
Non -contact cooling water is pumped from the recycle pit at
approximately 5 gpm. Refining batches requiring non -contact
cooling water are run approximately 5 days/week for approximately
2 hours per day. This operation produces approximately 430 gpd of
non -contact cooling water, discharged to the recycle pit. Beca-use
this cooling water does not come in contact with any process
materials, this input to the recycle pit is not believed to
2

increase the lead concentration in the pit. Non contact cooling
water from the refining area was previously discharged to a
concrete swale on the Willard property and out to a storm sewer
out all on Foster Road, west of the Willard property. The existing
recycle pit operation is outlined in Figure 2.
The only other known water input to the recycle pit, besides
refining area wash water and non -contact cooling water, is rain
water that falls directly upon the pit water surface. If a heavy
rain occurs, there is a potential for the recycle pit to overflow
to a drainage ditch located south of the Willard property.
The water recycle pit is approximately 18'x 24x V, which relates
to a capacity of approximately 16,000 gallons. During a May 16,
1991 site visit, an oil sheen and wood shavings were visible on the
surface of the recycle pit. The operator claimed that the pond's
appearance was not normal and that upset conditions existed.
tic

T
3.0 TREATABILITYTESTING
3.1 reatme at Methods
The most common method of removing dissolved heavy metals from
wastewater is chemical ; precipitation. This involves the
additionchemicals to wastewater, causing metals t
precipitate; out of solution. Since different metals
precipitate < at different p valves, the wastewater pH must
first be adjusted to the minimum solubility point for the
w
metal of interest. Insoluble heavy Metal particles are then
bound together, a process commonly enhanced by the use of
polymers, to form larger, heavier' particles that settle
readily. This precipitated heavy metal sludge can then
easily be filtered. If little or no dissolved heavy metals
exist in a. wastewater, insoluble heavy metal particulates can
often be filtered from the solution without t any previous
chemical additions:
Another heavy metals removal method is ion exchange. In this
process, positive metal ions in the wastewater are exchanged
to ions of salts as wastewater flaws through a bed of resin.
When the resin bed is saturated with metal ions, it 'must be
regenerated with a. brine, an acid., or alkaline solution. The
metals in the regeneration wastewater can then be properly
treated.
Laboratory scale experiments using actual refining area wash
water and recycle pit supernatant water samples were conducted
to determine the most appropriate heavy metals removal method.
The experiments were conducted in NET ° s laboratory to test the
fallowing treatmentoptions: chemical precipitation,
sedimentation, filtration, and ion exchange.

3.2 Wash dater Sampling
Wash water sample collection was conducted on April,. 2, 1991
Ten gallons of wash water was collected from two floor drains
located in the refining area. The operator used well stater
to wash down the floor because the recycle pit pump was not
in operation at the time of sample collection
A. Treatability° Experiment
The "raw'" wash water sample was transported to NET"
laboratory and used in treatability experiments t
investigate treatment options for the reduction in
concentration of lead and other heavy metals.
Experiments were run using several, combinations of
chemicals and processes. The following describes the
trea.tabil:ity experiments performed in which water samples
were sent to the 'laboratory for analysis.
i.
Experiment 1 EXP1 - 20 min of 0. 1 N sodium hydroxide
(NaOH) ) solution was added to 2000mL of the water sample
This increased the water pH from 8.7 to 9.5 tnda.rd phi
units, which is the minimum solubility point for lead.;
The solution was them rapidly Mixed for one minute, then
slowly mixed for an additional 5 minutes. 6 mE of a 1
aluminum potassium sulfate solution was added
followed by 19 minutes of slaw mixing. The water p
decreased to 7.0 after the APS addition.10 mE of
. 1 .American Cyanamid Magnifloc anionic 1820A polymer
solution were them added to the sample in "order t
enhance floc formation. After 5 minutes of slow mixing
and 5 minuted of settling, a fluffy, grey/brown layer of
solids collected ' in the bottom of the beaker. The clear

water above the solids was decanted to comprise sample
EXP1 Visually, the most favorable results were shown
in the water sample EXP1. The water sample EXP1 and the
raw wash water sample were then analyzed for all priority
pollutant metals: antimony, arsenic, beryllium, cadmium,
chromium, copper, lead, mercury, nickel, selenium,
silver, thallium, and zinc, in addition to the common
wastewater parameters: ammonia as nitrogen, biochemical
oxygen demand (BOD), total suspended solids (TSS), and
oil and grease (O&G). These parameters were chosen for
analysis on the RAW and EXP1 samples in order to achieve
removal efficiencyresults from a broad range of
wastewater pollutants.
Experiment 2 _JEXP2L - A beaker of the raw water sample
was allowed to settle for two days without any chemical
additions. Supernatant from this water, sample was
collected and analyzed for total lead and TSS. it was
assumed that the other metal and wastewater pollutants
analyzed for in the water sample EXP1 would be removed
proportionately those in the water sample EXP2. This
clear water sample, with no apparent solids, represents
the existing recycled wash water in the water recycle
pit.
Exogriment 3 (EXP3) 2000 mL of the raw water sample was
filtered using 0.45 filter paper. A heavy brown filter
cake formed on the top of the filter paper. Clear water
passed through the filter and was collected below. This
filtrate was analyzed for lead, the main pollutant of
concern in this experiment.
6

B Laboratory
Analysis
The three samples
of treated wash water (EXP1, ExP2, and
EXP3)
and a sample
of mixed, untreated wash water (RAW)
were
sent to 'Industrial & Environmental Analysts, Inc.
(SEA),-
an independent, certified analytical laboratory.
The following results were reported by SEA. A copy of
the analytical
results is included in Appendix A.
EXP1 EXP2 EXP3
Parameter
RAW
jLreci2j (Sediment) (Filtrationl,
Antimony
14
0.85 ---- ----
Arsenic
0.15
<0.005
Beryllium
<0.01
<0.01 ---- ----
Cadmium
<0.01
<0.01 ---- ----
Chromium
<0.03
<0.03 ---- ----
Copper
1.6
0.08 ---- ----
Lead
230
1.6 1.4 0.95
Mercury
0.0013
<0.0005 ---- ----
Nickel
<0.03
<0.03 ---- ----
Selenium
0.017
0.013 ----
Silver
<0.05
<0.05 ----
Thallium,
<0.005
<0.005 ---- ----
Zinc
0.92
0.05 ---- ----
Ammonia-N
<0.1
0.1 ---- ----
BOD
9.5
5.1 ----
TSS
400
<4.0 <4.0 ----
O&G
NOTE:
All results
are in units of milligrams per liter
kmg/) -
BOB = Biochemical Oxygen Demand
TSS = Total Suspended Solids
O&G = oil and Grease
Based on the analytical results, it appears that chemical
precipitation, sedimentation, and filtration (EXP1, EXP2,
and EXP3) all reduce the lead concentration by greater
than 99%. For most of the other parameters (antimony,
arsenic, copperr, mercury, zinc, and TSS) chemical
precipitation provided a greater than 90% removal
efficiency. The concentrations of selenium and BOD
decreased by approximately 50% by the use of chemical
7

9
precipitation. Ammonia as nitrogen, beryllium, cadmium,, y
chromium, nickel, silver, thallium, and O&G were not
detected in the RAW water sample at or above the method
detection limit ,' therefore, no further reductions in
concentrations were detectable. Due to the similar lead
and TSS concentration.s recorded from the chemical_
precipitation, sedimentation, and filtration experiment"
analyses, one can assume that most of the heavy metals
in the wash water are insoluble and their concentration
from the sedimentation and filtration experiments would
be similar to those recorded in the chemical
precipitation experiment.
3.3 Water Recycle Pit Sampling
The lowest lead concentration achieved to date in the
treatabil,idty tests has been 0.95 m by filtration of mixed;
refining area wash. water. NET decided to investigate the
applicability of using, an ion exchange ( eolite) softener to
further decrease the lead` concentration because additional
treatment, such as ion exchange, may be necessary in the
future if low pretreatment' discharge limits are imposed.
gallon water sample from the surface of the recycle pit was
collected on May 16,, 1991 and transported to NET's laboratory
for treatabi.lty testing. This water sample was collected i
order to identify the lead removal efficiency of the existing
recycle pit by sedimentation, then: filtered to determine i
insoluble lead particles exist in the pit supernatant water.
A. Treatability Experiments
The recycle pit supernatant water sample ( D1) contained
a slight oil sheen, but was clear, and contained little
or no solids This recycle pit water sample was analyzed

for total antimony, total lead, TSS, and O&G, the
parameters that recorded the highest concentrations from
the raw wash water sample collected on April 2, 1991.
Analysis for dissolved lead and total dissolved solids
(TDS) was also conducted to determine the amount of lead
and suspended solids that were dissolved in the water
sample compared that in suspension. The following
describes the treata,bility experiments performed on the
recycle pit supernatant water sample.
Filtration Experiment_CEDF21 - 2000 mL of the raw
supernatant water sample was filtered using 0.45 filter
paper. The filtered water sample was clear and did not
contain noticeable solids. During the filtration
operation of PD1 i to yield PDF2, very few suspended
particles appeared to collect on the filter paper, yet
the rate of filtration significantly decreased after the
first 300 mL processed. This fact leads one to believe
that small suspended solids did collect on the filter
paper. This filtered water sample was analyzed for total
antimony, total lead, TDS, and 'TSS
Ion Exchanae ExDeriment Using Zeolite Softener (PDZ3)
An ion exchange experiment was conducted on 1000 mL of
the supernatant -water sample using a column technique.
The ion exchange resin was transferred to a vertical
column (burette) as a slurry with deionized water to form
the resin bed. The resin bed filled one half of the
total burette volume (up to the 50 mL mark). The water
sample was then allowed to flow through the column at
approximately 8-10 mL/min. A constant water head was
maintained throughout the experiment by keeping the water
level at the 100 mL mark on the burette. The treated
9

water was then analyzed for total antimony, total lead,
and dissolved lead.
B. Laboratory Analysis
The sample of untreated supernatant water (PD1) and the
two treated water samples (PDF2 and PDZ3) were sent to
IEA for laboratory analysis. A copy of the analytical
results is included in Appendix A. In the analytical
report, TEA inadvertently switched TDS and TSS
concentrations for samples PD1 and PDF2. The following
table presents the corrected TEA analytical results.
PD1 < F2 PDZ3
Parameter (Untreated.). JfLilteredj (ion Exchanqe)
Total Antimony 0.53 0.55 0.43
Total.'Lead 0.89 0.76 0.33
Dissolved Lead 0.98 ---- 0.31
TDS 250 240 ----
TSS <4.0 <4.0 -®_
<5.0 ----
NOTE: All results are in units of milligrams per liter
(mg/L).
TDS Total Dissolved Solids
TSS Total Suspended Solids
O&G Oil and Grease
Based on the analytical results, it appears that
filtration (PDF2) reduces the lead concentration by a
15% over the PD1 water sample and ion exchange (PDZ3)
reduces the lead concentration by 63% over PD1 . Antimony
concentrations were similar in all three water samples.
The "ASS concentration did not vary significantly between
water samples PD1 and PDF2. TES was detected in the PD1
and PDF2 samples at or below the method detection limits.
O&G was detected in the PD1 sample at or below the method
detection limit.
10

These results indicate that the existing recycle pit
through sedimentation provides adequate solids separation
and that filtration of supernatant water does not
significantly improve water quality.
Ion exchange treatment markedly reduced the concentration
of total and dissolved lead in the <reccle pit
supernatant water. This alternative should be considered
if the existing refining area and recycle pit process is
modified and, consequently, if stringent water quality
limits are ever imposed.

4.0 RESIDUAL SLUDGE MANAGEMENT
According to Willard operators, the sludge from the recycle pit has
been removed approximately once in the past ten years for off -site
reclamation.
On November 12, 1990, NET representatives collected a recycle pit
sludge sample for Toxicity Characteristic Leaching Procedure (TCLP)
analysis. The concentration of lead in the extract from the pit
sludge sample was reported by IEA to be 1000 mg/L. A copy of the
analytical results is included in Appendix A.
As stated in 40 CFR 261.24, a waste is considered a hazardous waste
if the extract from a representative sample of the waste contains
lead in excess of 5. 0 mg/L. This specific type of material is
given an EPA hazardous waste number of D008. Because the recycle
pit sludge is considered a hazardous waste and the cumulative
amount of lead waste generated at the Willard facility indicates
that they are more than a small quantity generator (generation of
hazardous waste >1000 kg/month), Willard may accumulate the pit
sludge on -site for 90 days or less without a permit or without
having interim status provided the waste is placed in containers,
or tanks as specified in 40 CFR 262.34.
Willard will need to implement a scheduled program that accumulates
the recycle pit sludge and then transports it to an off -site lead
reclamation facility every 90 days or less.
12

5.0 CONCLUSIONS
A wash water treatability study was conducted, investigating
potential treatment methods to reduce the concentration of lead and
other heavy metals in the recycle wash water and to optimize the
sludge handling operations at the recycle pit. Laboratory scale
chemical precipitation, filtration, and sedimentation treatability
experiments were performed on a mixed water sample of refining area
wash water. Laboratory scale filtration and ion exchange
experiments were performed on a recycle pit supernatant water
sample.
The laboratory analytical results from these treatability
experiments indicated that the major contaminant of concern in the
wash water sample is lead. Results also indicated that chemical
precipitation, filtration, and sedimentation all reduced the lead
concentration in the wash water sample by over 99%, from 230 mg/L
to approximately 1 mg/L. Sedimentation in the recycle pit,
followed by ion exchange reduced the lead concentration to 0.33
mg/L. These results indicate that the existing recycle pit
provides adequate solids separation through sedimentation based on
current water quality criteria. The refining area and recycle Si
process is operated as a total recycle system, and as such, federal
wastewater pretreatment standards do not apply. Consequently,
chemical precipitation, filtration, and ion exchange do not appear
to be cost effective alternatives at the present time.
Based on the November 12, 1990 recycle pit sludge TCLP analytical
results and the fact that i the cumulative amount of lead waste
generated at the Willard facility indicates that they are more than
a small quantity generator, Willard should not accumulate sludge
in the recycle pit for more than 90 days. A regularly scheduled

recycle pit sludge collection and off -site transport system should
e implemented.
The results of a mass balance around the water recycle pit
indicated that refining single pass non -contact cooling water,
refining area floor wash weer,; and stormwater falling directly
into the pit are the only influents to the pit. Of the three pit
inputs, only the refining area flour wash water contains
significant amounts of lead (230 mg ). hater for the lead
refining single pass non -contact t. ooling water and water for
refining area floor washing'; are the only effluents from the pit._
These recycle pit effluents are returned to the refining process.
f a heavy; rain occurs, there currently is a potential for the
current recycle pit tee overflow to a drainage ditch located to the
south of the Willard pperfy.
14

i
t
e
t
6.0 RECOMMENDATIONS
NET recommends that Willard Industries install a filtration system
to collect and remove lead contaminated particulates from recycle
wash cater and. refining non -contact cooling water. The existing
recycle pit is not considered to be adequate because lead
contaminated sludge is held in this pit for more than 90 days and
there appears to currently be no efficient means to remove and
dewater sludge from the recycle pity
The treatment system would, include a cone bottom equalization and
"
settling tank, a sludge thickener tank, mixer and pump, a plate and
frame filter press, and a recycle cater holding tank and pump,NET
-
suggests that this treatment system be housed in the adjacent
machine shop building, if possible. This treatment option process
flow diagram is illustrated in Figure 3., The accumulated.,
dewa.tered sludge would be stored -site in drums, them transported
for off -site lead reclamation every 90 days or less. The equipment
capital costs for this type of system would be approximately
$20,000. In addition to equipment capital ;casts, construction,
engineering, and contingency expenses would total approximatelyapproximately^
�
, .,
NET recommends that the existing dater recycle pit be removed from:
m:
service because of the current hack of sludge removal and,
dewatering capabilities and the expectedly large expense to
retrofit the existing pit. This optionwouldalso eliminate the
direct input of stormwater to the recycle operation. While closing
the recycle pit, NET recommends that Millard Industries provide
proper documentation of the decommissioning process.
Without the use of the recycle pit, the direct input of stormwater
to the recycle operation would be eliminated and the inputs to the
1

proposed filtration system would always equal the outputs. Under
this scenario, Willard industries should apply for a non -discharge
ha:rge
permit with the State of North Carolina Department of Environment,
Health, and Natural Resources ( NR) , as requested in the June
1991 letter from D. Rex Gleason, DEHNR, Mooresville Regional
Office.
n order to decrease the amount of lead contaminated water
generated in the refining area, modifications to the dross removal
process' are recommended. Willard Industries could. increase ` the
width of the toughs, or instal a wider secondary containment
trough to capture more of the dross that is removed from the
surface of the molten lead.
s
1

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4' 3 x. 6' HEIGH°.. 4' x 5' 25 ' 2£59 F MAX. TEMPERATURE CEN'.TMFUGA.. U€.":N"KUCA[.
FRF dt%(4) FR IIQ GPM MAX FLOW SELF PRWR4G SELF rcm,NG
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FILTER , CAKE
""'+ FOR OFF -SITE
W"ASHWATER FROG
FSEt RECLAMATION
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DATE _INDUSTRIES
,� DEC. 4, 199 � Charlotte NC
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D. 21"
, 1 43/4"
Description.-
'vessel futures over the top inlet, hinged closure and
accommodates size #1 bag ( 1 bag: 7" diat x 16" long)
Specifications.-
Maximum Working Pressure 150 psi
Maximum Working Temperature 501 F
Maximum Water Plow 1 10 gpm
Maximum Support Basket Differential Operating pressure 75 psi
Hydrostatically Tested to 250 psi
Inlet & Outlet Connection 2" NPT
ShippingWeight: 75lbs
Standardt
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Model NS 112, type 304 stainless steel„ brushed finish
Model NC 1 17; carbon steel* one coat shop pruner
Perforated T- 16 stainless steel support basket
Adjustable tripod stand, carbon steel
Plated carbon steel hardware
Two Pura-1 0-rings
Two 1 4"" NPT connections in lief
Flanged Connections
Fluorocarbon Linings ,
Micron -Rated Strainer Baskets
Assorted 0-ring Materials
Steam and Hot Oil Jackets
Low -Profile, Horizontal OUti is
Cartridge Contaminant Chambers
iremovabte, positive seal fixture holds 4 st.andaid 10" cartridge ftitersl,
Available in Carbon Steel (Model C-1 1 /) '
Page

wJV%
perationg Instructions For Liquid Filter
Housings & Bags
For all operational cycles of single pass filtration, recycling or evacuation, the following steps
should be taken to assure optimum operation and maximum service life:
Filtration Systems standard housings can operate at a maximum of 150 psi.
The support basket can operate at a maximum of 75 psi pressure differential.
# Initial operating pressure, with a clean filter bag, will remain constant until the
bag is approximately 80% "blinded". When pressure differential increases by
15 psi (Ap), the filter bag should be changed. (The sooner the bag is changed, the
easier it is to replace.) Timely bag changes result in achieving maximum flow rate as
well as more consistent filtrate,
Lid Connections:
A pressure gauge should be installed in one of the two 1/4" NIT connections on the
cover. A second pressure gauge should be installed in the downstream pipe line, The
differential reading between the two gauges indicates the "pressure differential"
across the filter bag.
A vent valve should be installed in the second 1/4" NPT connection. As air in the filter
vessel is displaced by liquid, an air pocket will form at the top of the vessel. Venting
will allow the full surface area of the filter bag to be utilized.
NOTE: After operation, the vessel should be vented before opening the cover.
Bag Inserflow.
Insert the filter bag into the restrainer basket (already installed in the housing) and
form the bag to the contours of the support basket by pressing against the restrainer.
Closing Procedure. -
Close the cover carefully. (Do not drop the cover.) Bring the hold-down bolts into
position. Hand tighten the two rear bolts on the cover. Hand tighten the two front
bolts on the cover,
Final tightening should be done by repeating these steps, until the cover is tightly and
evenly closed. This procedure should be followed to insure complete sealing.
Authorized Distributor. -
Manufactured T
Filtration
By:
_jystems 7.
TM c 1988 mecnonjcai mfg, corn.
TM
Division of Mechanical Mfg. Corporation
10304 NW 50th Street, Sunrise, Florida 33351
(30S) 572-2700 n Fax 3OS-S72-3401
Product Warranty: In the event any vessel is found to be defective in material or workmanship, for a period of one
year from date of purchase, Filtration Systems only liability will'be to repair or replace the product.
The manufacturer reserves the right to change specifications without no ice. There are no expressed or implied
warranties, with respect to product merchantability arid/or fitness for a specific purpose, Filtration Systems will not Nl 189
be liable for any incidental damages froci the use or misuse of our products under any circumstances. Page 4

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Mmw8mler Gast Iron cast Iron
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Im eller Bronze Cast Iron
Shaft Steel Steel
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FACILITY WASH WATER TREATABILITY STUD
WILLARD INDUSTRIES, INC.
CHARLOTTE, NORTH CAROLINA
Prepared For
PreparedWillard Industries, Inc.
E
National Environmental Technologies, Inc.
August 11
��ys�a�erark�r,�
12,844
PJ.F. Kouba
F.
August 27, 1991

FACILITY WASH WATER TREATABILITY STUDY
TABLE OF CONTENTS
SECTION
PAGE
1.0
INTRODUCTION
1
2.0
REFINING AREA AND RECYCLE PIT PROCESS DESCRIPTION
2
3.0
TREATABILITY TESTING
4
3.1 TREATMENT METHODS
4
3.2 WASH WATER SAMPLING
5
A. Treatability Experiments
5
B. Laboratory Analysis
7
3.3 WATER RECYCLE PIT SAMPLING
8
A. Treaka bility Experiments
8
B. Laboratory Analysis
10
4.0
RESIDUAL SLUDGE MANAGEMENT
12
5.0
CONCLUSIONS
13
6.0
RECOMMENDATIONS
APPENDIX A - ANALYTICAL REPORTS

n environmental testing compare
.
[3 §., Rh
��S�a`�tCi'k iil�il�IC �., rw , hlp 631 Y'CYililc'[�f:7B7
i M
A ^ +, xr
John Meyer
National onal nviror:m ntal Technology
9101 Southern Pine Blvd., Suite 280
Charlotte, NC 28273
Reference l A Report tic+.: 726117
Project l.D.: 077002
Dear Mr. Meyer;
Transmitted herewith are the results of analyses on
four samples submitted
to our laboratory.
Tease see the enclosed reports for your results.
Very truly yours,
r
x
,
t:
INDUSTRIAL & ENVIRONMENTALANALYSTS, INC.
Li-nda F. Mitchel ;
Director, Techn.rcal `Sup os t Services
StateCertification:
Alabama - #40210 New Jersey - 967719 South
Carolina - #990 l
Georgia - #816 Tennessee 96 North
Carolina - N3 r720
Kansas - 4E-158 Virginia #00179
#64
Pdn*krxktv,...
Mamar,. SQsarnkmgt M K [3aAoW'
Whippany„ Ea%ox Junctioll
Canneatum
WWI iRti"is'. Mnsslchu:i olts
Now.3O..fWy: valmont
203-201-445YS
305-989-0920 700-705-0740 Pa17-272- 212
1101'APB- 1al 002.LI70.5194

IA, LABORATORY RESULTS`_
EA Project. 1'.:
72 -112
Client Maine:
stational Environmental Technology
Date
male
Client ID
Paremeter
Results
Analvzed
TOTJ� x AL
1
RAW
Antimony
14
rc /L
04/21,/91
2
:X91,
Antimony
0.85
met/L
04/21/"91
1
RAGS
.Arsenic
0.19
g/'I.
04,/23/91
2
EXPI
Arsenic
.00
m /L
04/23/91
1
RAW
Beryllium
c9.01
04/22/91,
2
EXPO
Beryllium
9 � 01
m /L:
04/22/91
l
RAW
Cadmium
0.01
m /L
04/22/91
2
Expi
Cadmium
.01
m /L
04/22/91;
1
RAW
Chromium
25. 2
m /L
4/22/9
2
EXPI
Chromium
< . 2
.m /L
04/22/91
1
RAW
Cowper
1.6
m /L
4/22/91.
2
EXP
o-oper
9.9
mg/L
04/22/91
1
RAW
Lear.
230
m /L
04/1 ,/91
2
Expi
Lead
1.6
m /L
4,/15/91
2
EXP2
Lead
1.4
mg/L
4/15/91
4
EX12
Lead
0.99
/L
04/1. /"91
1
RAW
Mercury
0.0013
m /L
4/°11/91
2,
EXPI
Mercury
<9.
mg/L
04/10/91
1
RAW
Nickel
c .02
m /L;
04/22/91
2
Expi
Nickel
e0. 02
m /L
4/22/91
1
RAW
Selenium
0.017
mg/L
04/22/91:
2
Expi
Selenium
O013
mg/L
04/11/91
1
RAW
Silver
.
/L
4/2.2/91
Xp1
Silver
<0.0
mr1/L
4/22/91.
1
RAW
Thallium
<0.005
m /L
04/19/91 M
2
EXPI
Thallium
<0.005
m /L
4/19/91
1
RAW
Zinc%
0.92
m9,/L
04/22/91,
2
Expi
Z Lac
0.05
m /L
04/22/91
1RAW
A=onia-N
.1
m /L
04/'1.1/91.
2
EXPI
onia t ,
0.1
mg/L
04/11/91
1
RAW
Biochemical Oxygen Demand
9.5
m /L
4/t12/91
2
EXP1
Biochemical Oxygen Demand
5.1
m /L
04/05/91
1
RAW
Total Suspended Solids400
m /L
04/10/91
2
EXPI
'Dotal Suspended Solids
<4.0
amr /L
04/10/91
2
X 2
Total Suspended Solids
<4.
€g/L
04/10/91
1
RAW
Oil & Grease ( ra imetric)
c2 . 9,
arc /L
04/10/91
2
Expi
Oil & Grease (ravimetric)
2.9
9/L
04/10/91

a] i # vol # I j ui " J+Y.�" iCt
testing company R'14
GARY, dim . 27513 KNPOES n DRINKING WATER ER 0 RCRA C HE � .
..�»,.�.� « ar�w"£ &"'t#"«`#o�.r�,f++z'k,„a z'. ,+'3`A .t" �N 9rL£ f..
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IEA REMARKS
a

n environmental testing company
tP,O. Box 12646
Research Triangle Park. North Carosina 27709
(919) 677,0090
FAX [phone]
T
June 10, 199
John: Meyer
National Environmental Technology
91.01. _Southern Pine Slvd., Suite 280
Charlotte; NC, 28273
a
c;
Reference 1A Report No.: 726128
t
Project l.D. z 07700
Dear m Meyer;
Transmitted herewith are the results of analyses can three samples submitted
to our laboratory.
Please see the enclosed reports for your results.
Very truly yours,
1EA, Inc.
F
"17fnda P. Mitc ell .
Director, Technical -Support Services
State Certification -
Alabama - #40210 New Jersey - # 771,9 South
Carolina: - #990 1
Georgia - #816 Tennessee #00 96 Furth
Carolina - # 7"7 0
Kansas - #E-158 Virginia #001.79
# 4
Monroe, miramar, Schaumburg. N. 9iilerica,
Whippany, - 6ssax Junction,
Connecticut Florida litinois lAa s useit
N&W Jersey' Vermont

IEA LABORATORY RESULTS
IEA Project
76-138
Client Name:
National Environmental Technology
Date
+ a.xle
Cryry Znt ID
Parameter
Results
Analyzed
TOTAL METALS.
1
PD1
Antimony
0.53
mg/L
05/2.4/91
2
NCC4
Antimony
1.0
mg/L
05/24/91
` 2
PD 2
Antimony
0.55
mg/L
05/24/91
PD1
Lead
0.89
mg/L
05/24/91
2
NCC4
Lead
33
mg/L
05/24/91
3
PDF2
Lead
0.76
mg/L
05/24/91
DISSOLVED METALS:
1
PD 1
Lead
0.98
mg/L
05/24/91
3
NCC4
Lead
15
mg/L
05/24/91
1
PD1
Total Dissolved Solids
<4.0
mg/L
05/3/91
3
NCC4
Total Dissolved Solids
160
mg/L
05/ /91
PDF2
Total Dissolved Solids
4.
mg/L
05/2 /91
1
PDI
Total, ,Suspended Solids
250
mg/L
s15/ 3/91
NCC4
Total Suspended Solids
77
mg/L
05/ 3/91
PDF2
Total Suspended Solids
240
mg/L
05/23,/91
1
PD1
'ail & Grease (G av° etri
5.8
mg/L
05,/24/91
3
NCC4
Oil & Grease (Gray° etriC)
14
mg/L
05/24/91
Result
confirmed through re -analysis.

0,00VVESTON PKWY.'
4 _
ARY, N.C. 27513
NPD a El DRINKING WATER 0 R RA El OTHER
PR14� PROJECT A ''
`.METERS
}
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TIME .,.R I E �3"a°.. "' 3s'UA'T: ;4x 4„ TItwT .t r
✓per } ° f' J
I F THY IGNAT °ITT
•, i �,!
TIME . '. F° �. R CEIVED FOR R, RY" . ,. , x�
`:C:�A"T E,.i �'.:TI,.
I
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IFA RRhrARl `,, ,
a
FIFI_I RF[viARP4
n �
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n environmental testing company
P.O. ox 12846
Aasearoh Trian le Park. North caroOna 27709
(519)677m0090
PAX (919} A77-t? 7
June 1, 199
s
John W. Meyer
National Environmental Technology
9101 Southern. Pine Blvd., Suite 280
Charlotte, NC 28273
Reference Report No.: 726129
Project I» « } 077002
Dear Mr. Meyer,
,.
Transmitted herewith are the results of analyses on
one sample submitted
to our laboratory.
Please see the enclosed reports for your resul.tsw
k
f
{
Very truly yours,
a i
P'.
Ir Incur
r
Linda F. Mitchell
Director, echnr cal Support Services'
State Certification:
Alabama - #40210 New ,jersey - 467719 South
Carolina - #99021
Georgia - #816 Tennessee• - #00296 North
Carolina - #37720
Kansas - # 1.58 Virginia - #00179
#84
Monraa« Miramar, Schaumburg, N. SitfefiM
"h' nY. Ssse* Junction,
Connecticut Florida Ilti ois kA s u tt�
Now Jereay `der nt
w.....— ....1.., n.... ....:.a
10I.Alw n w, N .nT6. i .

I A LABORATORY ITT
a
1EA project
725-12
Client Name:
National Enviro=ental Technology
Date
sample
Client ID
Parameter
Results
Analyzed
TOTAL METALS:
1
PDZ3
Antimony
0.43 m05/24/91
1
PDZ3
Lead
0.33; mg L
5 30/ 1.
DISSOLVED METALS:
Z3
Lead
0.31 mg/L
05 4 1

INDUSTRIAL & ENVIRONMENTAL CHAIN OF CUSTODY RECORD
ANALYSTS, IN � « � Il '
� 'ETA! PKWY,
NP EE 0 DRINKINGWATER[J RCRA 0 OTHER'
REQUESTED PARMTER
It
"
ATRIX
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1 A "t1 E DATE TIME
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f .. _ Ire EC,IAII:' FILCH REMARKS
A10T_ r'

Industrial & Envir >nmental Analysts, Inc.
10, Box 12846
Research TdaligW Park, Nonh Carolina 97709
(919) 77-0090
FAX t69$677-6427
g
December 11, 199
..
Joan Kouba
National Environmental Technology
9101 Southern Pane Blvd., Suite 25
Charlotte, NO 28273
Reference 1 A Report o. 726084
Project l.D, e: O77001
Dear . 1couba
Transmitted herewith are the results of analyses on four samples submitted
to our laboratory.
Please see the enclosed reports for your results.
#
very truly yours,
INDUSTRIAL & ENVIRONMENTAL ANALYSTS, INC.
.w
s
inch . F. Mitchell
Director, Technical Support Services
State Certification:
Alabama .- #40210 New Jersey - #67719 South
Carolina - #99021
Georgia - #816 "Tennessee - 400296 North
Carolina - #37720
Kansas s -158 Virginia - #00179

}
IEA LABORATORYRESULTS
IAA Project 726-084
Client s National Environmental Technology
Late
mule
Client ID >
Parameter
results
Analyzed
TCLP MET
I
Pit
Arsenic
<0.25
m /L
2,/06/90
2
Dross
Arsenic
<0.25
mg/°L
11/29/90
3
Dust
Arsenic
< »25
mg/L
11/29/9
Oil
Arsenic
<0.25
m°/L-
1/29/90
I
zit
Barium
<5. 7
g/L
12/05/"90
2;
Dross
Barium
<5,0
g/L
12/02/50
3
Lust
Barium,
<5.0
rg,/L
12/02/9
Oil
Bari
5.0
mg/I
12/02/90
1
Pit
cadmium
0.5
mg/L,
12/0/9
2
Dross
cadmium
<0.5
cog/L
12/0 /90
3
Dust
Cadmium
0.77
mg/L
2/ 2/9C {,
4
Oil
Cadmium
<0.5
mg/L
2/02;/90
1; ,
Pit
chromium
<1.5
mg/L
1.2/05/90
2
Dross
Chrome
1.5
mg/°L
12/02/9
3
Dust
Chromium
^ 1.5
mg/L
12/ 2/9
Oil
Chromium
1.5
gag/L
1:2/02/90
1
Pit
Lead
1,000
mg/L
12/0 /90 a.L�
2
Dross
Lead
5,40
m /L
2/ C/ 9C
3
Lust
Lean
7,400
mg/L.
12/0/9
4
Oil
Lead
0.53
z g/L
1.1/°30/90
1
Pit
Mercury
0.025
mg/L
12/05 9C
2
Dross
Mercury
.025
sag/L
1.2/06/ 0
3
Dust-
Mercury
<0.025
mg/L
11/29/90
Oil
Mercury
. 25
mg,/L
11../29/9
1
Pit
Selenium
0.25
mg/L
1.. /0 /90
2
Dross
Selenium
9 25
rg/"L
11/30/90
3
Lush
Selenium
25
mg/L
11/"30/90
Oil
gg;;y'q
Selenium
a
0/90
s
Pit
silver
<2.5
mg/L
12/05/90
2
Dross
Silver
2.5
g/L
12/02, 90
3
Dust
Silver
2.5
mg/L
1.2/02/'90
4
Oil
silver
° 2.5
mg/1
12/02/9 ,

TCLP/ZHE
GC/MS PURGEABLES
SW-846 METHOD
8240
A Sample Number: 726-084-4
Date Analyzed:
12/05/90
Sample Identification: Oil
By: Harris
TCLP/ZHE
Extraction Date: 12/04/90
Number
Compound Quantitation
Results
Limit
Concentration
(ug/L)
(ug/L)
I
Acetone
1000
BQL
2
Benzene
so
BQL
3
Bromodic hfor omethane
so
BQL
4
Bromoform
so
BQL
5
Bromomethane
100
BQL
6
2-Butanone
1000
BQL
7
Carbon disulfide
to
BQL
a
Carbon tetrachloride
so
BQL
9
Chlorobenzene
50
BQL
10
Dibromochloromethane
so
BQL
11'
Chloccethane
100
BQL
12
2- hlor by lvinyl> ether,
10o
BQL
13
Chloroform
50
BQL
14
Chloromethane
100
BQL
15
1,1-Dichloroethane
so
BQL
16
1,2-Dichloroethane
50
BQL
17
1,1-Di chloroethene
so
BQL
is
1,2-Dichloroethene (total)
50
BQL
19
1,2-Dichloropropand
so
BQL
20
cis-1,3-Dichloropropen e
50
BQL
21
trans-1,3-Dichloropropene
so
BQL
22
Ethylbenzene
so
BQL
23
2-Hexanone
500
BQL
24
Methylene chloride
so
BQL
2S
4-Met hyl-2-pentanone
500
BQL
26
Styrene
so
BQL
27
1,,1,2,2-Tetrachloroethane
so
BQL
28
Tetra chloroethene
so
BQL
29
Toluene
50
BQL
30
1,1,1-:Trichloroethane
so
BQL
.31
1,1,2-Tr1chloroethane
so
BQL
32
Trichloroethene
so
BQL
33
Vinyl acetate
Soo
BQL
34
Vinyl chloride
100
BQL
35
Xylenes (total)
so
BQL
Comments:
BQL
= Below Quantitation Limit
ZHE
extraction protocol exceeded.
FORM 8240-ZHE Rev. 082790

u
.. ANALYSTS, INC. r
'1 D1 NORTH HARRISON AVE.
GARS`, WC. 27513
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` Z. XC. rtrp'r� OF'" ATUMAL
e SD
V, A"
Mt,,,tTV pt*,VVL0VMVJ"
4CO11A
JUL 2 2 1992
wtUXLS State of North Carolina
#VKW%%Wnvironment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street Raleigh, North Carolina 27626
James G. in, Governor A, Preston Howard, Jr,, P.E.
Williain W, Cobey, Jr,, Secretary July 23, 1992 Acting Director
W. Clarence Willard, President
Willard Industries, Incorporated
101 Newbem Street
Charlotte, North Carolina 28203
Subject: Permit No. WQ0006099
Willard Industries, Inc.
Washwater Recycle System
Floor wash and Non -Contact
Cooling Wastewaters
Mecklenburg County
Dear Mr, Willard:
In accordance with your application received January 24, 1992 we are forwarding herewith Permit
No. WQ0006099 dated July 23, 1992 to Willard Industries, Incorporated for the construction and
operation of the subject washwater recycle system.
This permit shall be effective from the date of issuance until June 30, 1997 and shall be subject to
the conditions and limitations as, specified therein. Please pay particular attention to the monitoring
requirements in this permit. Failure to establish an adequate system for collecting and maintaining the
required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have
the right to request an adjudicatory hearing upon written request within 30 days following receipt of this
permit. This request must be in the form of a written petition, conforming to Chapter 150B of North
i�arolina General Statutes, and filed with the Office of Administrative Hearings, P.O. Drawer 27447,
Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affinnative Action Employer

lipforwarded to you, if YOU need additional
One sit f approved lens � specifications �being
information concerning this matter, please contact Mr. Jahn Seymour or Ids. Angela Griffin at l / -
S
Sincerely,
a
Acting tray
Mecklenburg County Health Department
Mecklenburg nb ounty Department of Environmental Protection
latxcn1 nnti�' «� Inca
Facilities Assessment Unit
Training d Certification Unit

DEPARTMENT OV ENVIRONMENTI HEALTH AND NATURAL RESOURCES
RECYCLE SYSTEM PERMIT

5. Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted
facility has been installed in accordance with this permit, the approved plans and
specifications. flail the Certification to the Permits and Engineering Unit, P.O. Box
2, Raleigh, NC 226-0.
6. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Pe tree shall take immediate corrective action, including those as
may be required by this Division, such as the construction of additional or replacement
wastewater treatment or disposal facilities.
7. The Mooresville Regional Office, phone no. 704/ 663-1699 shall be notified at lust forty-
eight 48) hours in advance of operation of the installed facilities so that an in -place
inspection can be made, Such notification to the regional supervisor shall be made during
the normal office hours from :0 a.m. until pain. on Monday through Friday;
excluding State holidays.
. e sludge generated from these treatment facilities must be disposed of in accordance with
General Statute 1 -21 .1 and in a manner approved by the North Carolina Division o
Environmental Management.
. The issuance of this permit shall not relieve the Permittee of the responsibility for damages-
to surface or groundwaters resulting from the operation of this facility.
10. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting_from the operation of this facility.
11. Diversion or bypassing of untreated wastewater from the treatment facilities is prohibited,
12. .any monitoring deemed necessary by the Division of Environmental Management to insure
surface and ground water protection will be established and an acceptable sampling
reporting schedule shall be followed.
13. adequate inspection, maintenance, and cleaning shall be provided by the Permittee to
insure proper operation, of the subject facilities.
14. The Permittee or his designee shall inspect the wastewater recycle facilities to prevent
malfunctions and deterioration, operator errors and discharges which may cause or lead to
the release of wastes to the environments a threat to human health, or a nuisance, The
Pennittee shall keep an inspection log or summary including at least the date and time of
inspection, observations tirade, and any maintenance, repairs, or corrective actions taken
by the Permittee. This log of inspections shall be maintained by the Pe tree for a period
of three years from the date of the inspection and shall be rode available upon request to
the Division of Environmental Management or other permitting authority.
15. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials:, enter and inspect any property,
remises or place on or related to the recycle system at any reasonable time for the purpose
of determining compliance with this permit; may inspect or copy any records that must be
kept under the terms and conditions of this permit; or may obtain samples of groundwater,
surface water, or leachate®
16. The annual administering and compliance fee must be paid by the Permittee within thirty
fl days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified. by 15 NCAC 2l` • '20

r
W A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
0. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone no.
704/ 663-1699 as soon as possible, but in no case more than 24 hours or on the next
working day following the occurrence or fiat knowledge of the occurrence of any of the
following;
a. Any occurrence at the wastewater treatment facility which results in the treatment of
significant amounts of wastes which are abnormal in quantity or characteristic, such
as the dumping of thecontents of a basin or tank; the known passage of a slug of
hazardous substance through the facility; or any rather unusual circumstances.
ba Any process cant failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures
of pumps, aerators, compressors, etc,.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-
pass directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
d. Any time that self -monitoring information indicates that the facility is not in
compliance with its pen -nit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following firstknowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recurs

Permit issued this the 23rd day of July, 1992`
NORTH CAROLINAENVIRONMENTAL LCOMMISSION
A. Preston " a-Trdd, Jr., cung Dire for
"vision of Env" amen agement
y authority of ental Management Commission
Permit No.

t No.
July 23, 1992
Engineer's ifictin
1, , s a duly registered Professional Engineer in die State of North
Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the
project,
Project Name i Location
Perrmttee herebystag that, to the best of tray abiliti
es, glue care and diligence was used in the observation
f the construction such that the construction was observed to be built within substantial compliance
and
intent of the approved plans and specifications.
Signature � i trati n No.
Date
7

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i C" t,
r It t and Natural Reso
Mooresville Regional ion ffl e
James B. Hunt, Jr,, Governor
Jonathan B. Howes, Secretary
DIVISION P WATER QUALITY
November 22, 1996
Mr. Ken lardic, Vice -President
Mayfield Manufacturing company
Post Office Box 1'
Birmingham, Alabama 35219-9397
Subject: Permit No. WQ0006099
Willard Division
(Formerly Willard Industries,
Inc.
Floor Wash and Non -Contact Cooling
Wastewater Recycle System
Mecklenburg County, ,
Dear Mr. ardic
,r records show that Permit No. WQ0006099 was issued on
November 0, 1995 for your race. -discharge wastewater treatment
facility. The purpose of this letter is to advise you of the
importance of the Permit and the liabilities in the event of
failure to comply with the terms and conditions of the Permit.
If you have not already done a, it is requested that you and
other appropriate eracns thoroughly read the Permit
The Permit sets forth specific performance standards,
oper4tiqn and maintenance requirements, monitoring requirements,
plus general: conditions applicable to non -discharge permits.
Failure to comply with the terms and conditions of the Permit
subjects the _Per ittee to enforcement action pursuant to Section
143-215.6 of the North Carolina General Statutes in the form of
civil or criminal penalties.
Please acute; that the subject Permit expires on October 31,
+1. Condition No. 20 of the Permit requires that a renewal
request he submitted at least six ( months Price to
expiration.. Also the Permit is non transferable until such time
that the Permittee has requested a name change to the new
Permittee_.
919 North Main Street,
Mooresvifle, North Carolina
Voice704-663-1699
I
I
1,-663-6040
ftirmative Action Employer
pest -ewer paper

. n Mardick
November 22, 1996
Pace Two
As mentioned previously, the purpose of this letter is to
advise you of the importance f your Permit. Please read the
Permit and contact this Office at 704/663-1699 In Mooresville if
you have any questions or need clarification. We look forward
to providinq any assistance.
sincerely,
Rex Gleason, P. E.
Water Quality Regional Supervisor
L l

, . IDEYT. Or, NATURAL
RU,"0U1?(JLS AND
J,1% 2 8 1993
State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North SalisburyStreet • Raleigh, North
James B. Hunt, Jr, Governor Jonathan B. Howes,
January Secretary
8,1993
. John W. Meyer, P.E.
National Environmental Technologies
9400-E SouthernPine Blvd.
Charlotte,
Subject: Permit No.
Professional Engineer's
Certification:
Willard Industries, Inc.
Mecklenburg County
Dear Mr. Meyer:
The Division is in receipt of the Professional Engineer' s Certification that you have submitted for
the above referenced project. The Division hereby accepts the engineer's certification as submitted and
acknowledges the engineer's is statement that due care and diligence was used in the observation of the
construction such that the construction was observed to be built within substantial compliance tent of
the approved plans and specifications.
If you have any questions on this matter, please contact Ms. Angela Griffin at 919/733-5083.
Sincerely;
Carolyn D. McCaskill, Supervisor
iso
State Engineering eview Group
Willard indusi s, lnc.
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington ton Winston-Salem
704/251-6208 91 1 -1 1 704/ -1 99 919/ 71 7 19 - 1 1 t -919/896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opporwnity Affirmative Action loye

PPPW-
`t No. WQ0006099
July 23, 1992
Engineer's Certification
1, jo1 'Meyer , ;as a duly registered Professional Engineer in the State of North
Carolina, having been authorized to observe (periodically, weekly, full time the construction the
project, eevele System Willard industries, Inc.
Project Ne, ,, Location a
Pennittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction n was gab to be built within substantial compliance and
intent of the approved d specifications. At /
Signature itratn .
18523
Date 4
*
16523
a ,
� M
' nowl
s

State of North Carolina
Department of Environment,
Health and [natural Resources
Mooresville Regional Office
J'A"_'
James .Hunt, Jr„ Governor
Jonathan B, Hawes, Secretary
Linda Diane Lang Regional Manager
DIVISION IRSMANAGEMENT
August 17, 1995
r. Clarence Willard, President
Willard Industries, Incorporated
101 New Bern Street
Charlotte, North Carolina 28203
Subject.* Permit No. WQ0006099
Willard Industries Inc.
ishter Recycle System
Floor Wash andNon-Contact
Cooling Wastewater
Mecklenburg County
Dear Mr. Willard:
n June 12, 1995, Ms. Barbara Wiggins of the Mecklenburg,
County Department of Environmental Protection conducted an
inspection at the subject facility. This inspection was conducted
as part of u cooperative working agreement between Mecklenburg
County and the Division of Environmental Management. The enclosed
report should he self-explanatory.
If you have any questions concerning this report or any other
matters, please de net hesitate to call Mr. Michael; parker or me at
this Office.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: musty Rozzelle, MCDEP
BSA
919 North Mdn Street, Mooresville, , North Carolina 28115 Telephone [phone] FAX [phone]
An Equal opportunity Affirmative Action Employer recycled/ 101% post -consumer paper

Name and Location of Facility Inspected Facility Type
illard industries, Inc. Washwater Recycle System
01 New Bern Street
Mecklenburg County, NC Permit Number
WQ0006099
Entry Time M Exit- Time/Date
9:55 Li 10.30 95/0 /1:
Name(s) of On -Site Representative(s) Title(s
r. Doan Clark; System Plant Manager
Phone Igo . (s )
(70) 23- 13
Name,Address of Responsible Official Title
Mr. Clarence Millard President
Willard 'Industries, Inc.
101 New Bern Street Phone No.,
Charlotte, NC 28203 7 4) 523-1230
Contacted Permit Effective Date Permit Expiration mate
Yes NoFx1_
/07/ 3 7/0 l30
Areas Evaluated, During Inspection
( = atisfa to , M Marginal, U= nsatisfa+ for , N=Not Evaluated)
Permit S Operations Maintenance
M Records/Reports NSelf-Monitoring Report
IS Facility Site Review Other
ummary of Findings/Comments (Attach additional sheets if necessary)
Permit The facility is a 500 GPD wash water recycle system with a 550
gallon mixing tank, filter feed.pump, bag filter, effluent sump
pit, and return pump.
Records and Reports No records, logs or, maintenance records are present
onsite. Mr. Clark was informed ,of Condition No 14 of the permit,
which requires the: 'permutes to keep an inspection log or
summary of operator visit
Facility/operations -- All process units appeared to -be operating properly.
No discharges outside of the system was observed. The filters
are recycled at the plant to recover the lead. Water is added
to the system as needed in the machine shop.- The warmer comes
from the mold cooling water and from washing the floor in the
plant.
Name(s) and Signature(s) of Inspector(s) Date
Barbara S. Wiggins July 20, 1995
Agency/Office/Telephone
M DEP/ harlotte/(704) 33 -5500

.. ter
SEP 25 1996
C x,=U,.a,n:?14
R q iI
September 19, 1996
CLARENC;E WLI,IARil
WLLLARD INDU TRIE-WILZARD IN
101 NEW BERN STREET
CHA LOI TE, NC 2E203
SUBJECT: PERMIT NO. WQ0006099
WILLARD I iUSTRlE-WILLARD I
M CiKLENBURG COUNTY
Dear Pe,rmi ttee':
Our .files Indicate that the subject permit issued on ;7/23/92 expires seas
6/30 We have not received as request for renewal from you as of this tlaateW
A renewal request shall consist of a Letter requesting renewal and completion o .
the enclosed application, submitted In; triplicate. A processing fee mast be submitted
with the request, Please find attached ra c°clay of the 1.5 NGACi 2l ,02 >5 c regulations,
The processing fee for your facility is based on the design or permitted flow,
whichever is appropriate, listed in the first fur ante caries of facilities. S Iud e
renewals are based on total acres of land permitted. ' If the ftacil.it.y covered by this
permit contains some type of treatment works, as narrative, aye e r r. i peon of the sludge,
management plan that is in effect at the facility must: be submitted with the
application for renewal.
The Environmental Management Commission adopted 'revised raffles can October 1, 1990
(attached), requiring the payment of an annual fee for most permitted facilities, You,
will be billed separately for that fare (ifapplicable), wafter your permit is approved.
Please be advised that this permit must not be allowed to expire. If the renewal
request is not received within 180 "days prior to thepermit's expiration 'date as
required by 15 NCAC2ll .021,1, you will be assessed an automatic civil penalty. This
civil penalty lay North Carolina Generaal, Statute may be as much as $10,000 per daay. If
a permit renewal request is scat;received 180 days before permit expiration, as civil.
penalty of at least Q25Q will, be assessed. Larger penn l t tes may be assessed depending

PPFV
on how late the rearrest Is made. In addition, any permit renewal. request received
after the permit's _ expiration date will be consider,-,(,] as n now application and will be
required to pay the higher permit pplication fee.
The letter requesting renewal, along with a completed' Non -Discharge Permit
ppll.crrtion and appropriate standard fed, should be seam t
Permits and Engineering Unit
Division of Environmental Management
agement
Raleigh, North Carolina 27626-0535
The check should be made payable to the North, Caarrt l fi,in Department of Environment,
Health, and Natural Resources ( gRl li) .,
If ou should have any iest.ions or need any additional information regarding this
matter, please contract me at ( 1 ) 7 -5t1 5<;
pail rerel,
Carolyn flcCra i '1 1, up rvi.:sr rw
State Engineering ReviewGroup
cc." Mooresville Regional. Office
permits and Engineering Unit
Central Files

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a
_john w, Mauer as a duty registered Professional Engineer in the, State Of North
having authorized to observe (periodically, wceklY, full the construction Of the
project, e l s tWillard industries, In
tName-
Location
Permlace hereby state that, to the best of my abilities, due Cwt d diligence was used in the observation
of the construction thatconstruction a t t bas is `thin s b� r 3i nee +
intent f the plansand specifications._i t
Signature
Dalm t b
a
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n
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Division of ,m=t q 1ry na.:: _
xko l ti'pp m a if.this a.¢
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1993
pp�p pp
i OR IN NO
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State of North Carolina
Department of Environment, Health, and Natural Resources
Moorewille Rtegional Office
James G. Martin, Govemor Albert F. Hilton, Regional Manager
William W. Cobey Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
July 22, 1992
Mr. Clarence Willard, President
Willard Industries, Incorporated
101 Newbern Street
Charlotte, North Carolina 28203
Subject: Permit No. WQ0006099
Willard Industries, Inc.
Washwater Recycle System
Floor Wash and Non -Contact
Cooling Wastewaters,
Mecklenburg County
Dear Mr. Willard:
Our records show that Permit No. WQ0006099 was issued on July
23, 1992 for your non -discharge wastewater treatment facility. The
purpose of this letter is to advise you of the importance of the
Permit and the liabilities in the event of failure to comply with
the terms and conditions of the Permit. If you have not already
done so, it is requested that you and other appropriate employees
thoroughly read the Permit.
The Permit sets forth specific performance standards,
operation and maintenance requirements, monitoring requirements,
plus general conditions applicable to non -discharge permits.
Failure to comply with the terms and conditions of the Permit
subjects the Permittee to enforcement action pursuant to Section
143-215.6 of the North Carolina General Statutes in the form of
civil or criminal penalties.
Please note that the subject Permit expires on June 30, 1997.
Condition No. 23 of the Permit requires that a renewal request be
submitted at least six (6) months prior to expiration. Also the
Permit is non -transferable until such time that the Permittee has
requested a name change to the new Permittee.
P0. Box 950,919 North Main street, Mooresville, N.0 28115-0950 * Telephone [phone] * FAX [phone]W
An Equal Opportunity Affirmative Action Employer

1
age Two
. Willard
July , 1992
As mentioned previously, the purpose of this letter is to
prise you of the importance an your Permit. Please read
the Permit and contact this Office at 704/663-1699 in
Mooresville if you have any questions or need clarification. We
look forward to providing any assistance.
Sincerely,
D. Rex Gleason,
Water Quality Regional Supervisor

Department of Ell
ivi
512 North aalh
James G, Martin, Governor
William W. Cobey, Jr.,,Secretary
Mr, Clarence Willard, l residen
Willard Industries, Incorporated
111 Newbern Street
Charlotte, .North Carolina 28203
Subject
tsar
ul Natural Resources
r1 ement
rrth Carolina 27626
. TOF 114ATtTR
t:S01t1r ' . verett, Ph. }
'V" Director
VISION OF INVIRGAMEXUL jvANgF'M[kT
l fR[GIOUL
iviecKienourg 1Louray
Dear 14r. Willard:
The Permits and Engineering Unit has completed a preliminary engineering review f the
subject application. e following item must be addressed before we can complete our review:
l e submitted permit application indicates that the washwatet to be filtered and recycled can
contain large and potentially hazardous quantities of heavy metals, before it is treated° Any
wastewater leaking from the existing wash later drain line between the refining building and the
recycle system could contaminatethe groundwater table with heavy metals. Please provide
evidence that the8 inch 'terra-cotta, pipe vvashwater drain line to be u� is water tight,
Defer to the subject permit application number when providing the requested information.
Also, please note that failure to provide this additional information on or before July 6 1992 will
subject your application to being returned as incomplete in accordance with 15 NCAC 2H .020&
If you have any questions on this matter, please call me at 1 / 733-5083.
Sincerely,
John Seymour
Environmental ngin r
cc: Mooresville Regional ional Office
National Environinental'rechnologies, Inc,
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 2726-053.5 Telephone [phone]
An Equal Opportunity Affirinative:,fiction Employer