NC0006351_Permit Issuance_19981207

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality ,
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
December 7, 1998
Mr. Sylvester J. Bartos, Compliance Manager
Chemical Specialties, Incorporated
Post Office Box 610
5910 Pharr Mill Road
Harrisburg, North Carolina 28075
M."A
IT
A&410
NCDENR
Subject: NPDES Permit Issuance
Permit No. NCO006351
Cabarrus County
Dear Mr. Bartos:
In accordance with the application for discharge permit received on March 27, 1997. the Division is
forwarding herewith the subject state - NPDES permit. This permit is issued pursuant to the requirements of
North Carolina General Statute 145-215.1 and the Memorandum of Agreement between North Carolina and
the U.S. Environmental Protection Agency dated December 6. 1983.
The Division received your comments concerning the draft permit on November 2, 1998. Based on
those comments. the following corrections and clarifications are offered:
Reference to the five sludge filters and pH adjustment tank have been deleted from the description
of the treatment system on the Supplement to Permit Cover Sheet:
Reference to "Once Through Cooling Water" has been deleted from the header of section A(I),
Effluent Limitations and Monitoring Requirements for outfall 001;
The chronic toxicity testing requirement at 0.96% effluent. using Ceriodaphnia as the test
organism. remains in place with this final permit. The change from an acute testing requirement
to the chronic testing requirement constitutes a statewide change in toxicity testing policy.
Permits issued prior to October of 1996. with instream waste concentrations (IWC) between
0.25% and 1.0%. that tested for toxicity, used the acute methodology. A policy change instituted
on October 14, 1996 stipulated that all facilities with IWCs greater than 0.25%. and required to
test for toxicity. use the chronic methodology testing at IWC: and
Regarding groundwater monitoring, as the permit is currently written. all groundwater monitoring
is to be forwarded to the groundwater section. Reporting of RCRA sampling is sufficient to satisfy
condition A(3) as long as the RCRA sampling includes data for those parameters listed in the
condition.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you. you have the right to an adjudicatory hearing, upon written request within thirty (30) days
following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter
150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings. Post Office
Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such a demand is made, this permit shall be
final and binding.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]/FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Please take notice that this permit is not transferable. Part 11, EA. addresses the requirements to be
followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be required by
the Division of Water Quality or permits required by the Division of Land Resources, C04stal Area
Management Act, or any other Federal or Local governmental permits maybe required.
If you have any questions or need additional information. please contact Mr. Mark McIntire, telephone
number [phone], extension 555.
Sincerely,
Original Signed BY
Qavid A. Goodrich
A. Preston Howard. Jr.. P.E.
cc: Central Files —with attachments
Mr. Roosevelt Childress, EPA — with attachments
Washington Regional Office. Water Quality — with attachments
NPDES Unit, Permit File —with all attachments
Point Source Compliance/Enforcement Unit — with attachments
Aquatic Toxicology Unit — with attachments

Permit No. NCO006351
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215. 1.
other lawful standards and regulcitions promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Chemical Specialties, Incorpomted
is hereby authorized to discharge wastewater from a facility located at
Chemical Specialties, Incorporated
5910 Pharr Mill Road
Harxisburg
Caharrus County
to receiving waters designated as the Rocky River in the Yadkin -Pee Dee River Basin
in accordance with effluent limitations. monitoring requirements, and other conditions set forth in
Parts 1, 11, 111 and IV hereof. .
This permit shall become effective January 1. 1999
This permit and authorization to discharge shall expire at midnight on November 30, 2003
Signed this day December 7. 1998
Original Signed By
David A. Goodrich
A. Preston Howard*, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NCO006351
SUPPLEMENT TO PERMIT COVER SHEET
Chetrd6� Sp'ecialtie's', Inc.
is hereby authorized to:
Continue to operate an existing wastewater treatment system consisting of a solids
mixing tank, two (2) reaction tanks for pH adjustment. a two acre unlined storage
lagoon. a final settling tank, instrumented flow measurement. and a 1/2 acre lined
storage lagoon at a facility located *at 59 10 Pharr Mill Road. Harrisburg, Cabarrus
County (See Part 111, A of this Permit), and
2. Discharge from said treatment works at the location specified on the attached map
into the Rocky River which is classified C waters in the Yadkin -Pee Dee River Basin.

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ROAD CLASSIFICATION
PRIMARYNIGHWAY LIGHT-DUrY ROAD. HARD OR
HARD SURFACE 0111111111111111� IMPROVED SURFACE
SECONDARY HIGHWAY
HARD SURFACE _ C==NNjC= UNIMPROVED ROAD
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Latitude - 35019'4511 Longitude 80037'2511
Map #F1 6SF_ & F1 6SW Sub -basin 03-07-11
StreamClass C
Discharge Class 100 % Industrial
Receiving Stream Roc!a River
Design Q 0.025 MGD Permit
expires
SCALE 1:24 000
0 1 MILE
0 7000 FEET
9P.P==
-0 1 KILOMETER
CONTOUR INTERVAL 10 FEET
QUAD LOCATION
Chemical Specialties, Inc.
NCO006351
Cabarrus County
Inorganic Chemical Manufacturer

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Permit No. NCO006551
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001.
Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS ' �
MONITORING REQUIREMENTS
Measurement
Sample
Monthly Average
Daily Maximum
Frequency
Sample Type
Locationl
Flow (MGD)
0.025
Continuous
Recording
I F®r E
BOD, 5-day, 200C
Monthly
Grab
E
Total Suspended Residue
2.Olbs/day
5.0 lbs/day
Monthly
Grab
E
NH,-N
2.0 lbs/day
3.0 lbs/day
Weekly
Grab
-I_
Arsenic
0.208 lbs/day
0.416 lbs/day
2/Month
Grab
E
Chromium
0. 104 lbs/day
0.200 lbs/day
2/Month
Grab
E
Copper
0.06 lbs/day
0. 12 lbs/day
2/Month
Grab
E
Selenium
0.208 lbs/day
0.416 lbs/day
2/Month
Grab
E
Zinc
0.3 IS lbs/day
0.626 lbs/day
2/Month
Grab
E
Lead
0.01 lbs/day
0.037 lbs/day
2/Month
Grab
E
Nickel
2/Month
Grab
E
]PH 2
i
i
Weekly
Grab
E
I Chronic Toxicity'
I
I
I Quar erly
Composite
E
NOTE&
1 Sample Locations: I — Influent. E - Effluent
2 The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
Chronic Toxicity (Ceriodaphnia) P/F @ 0.96%: January, April. July. and October: See condition A(2) of the Supplement to Effluent Limitations and Monitoring Section of this
permit.
THERE SHALL BE NO DISCRARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.

Permit No. NCO006351
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A (2). CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure." Revised November 1995, or subsequent
versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant
mortality is 0.96% (defined as treatment two in the procedure document). The. permit holder shall perform
quarterly monitoring using this procedure- to establish compliance with the permit condition. The tests will be
performed during the months of January, April, July and October. Effluent sampling for this testing shall be
performed at the NPDES, permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally. DWQ Form AT- I (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
4401 Reedy Creek Rd.
Raleigh. N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests. as well as all dose/response data. Total residual chlorine of the
effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste
stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number. pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will
revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream. this permit maybe re -opened and modified to
include alternate monitoring requirements or limits.

Permit No. NCO006351
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
A (2). Continued...
NOTE; Failure to achieve test conditions as specified in the cited document. such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day
of the month following the month of the initial monitoring.
A (5). Groundwater Monitoring Requirements
Monitoring wells 1, 4. 5. and 6 shall be sampled in conjunction with
quarltrly RCRA post closure permit samplin� for the following parameters:
NO3 Sulfate
Calcium
Chromium
Magnesium
Zinc
Iron
Arsenic
Manganese
Total Dissolved Solids
pH
Water Levels
Chloride
Specific Conductance
The measurement of water levels must be made prior to sampling for the remaining parameters. The depth to
water in each well shall be measured from the surveyed point on the top of the casing.
Separate sampling is not required for those parameters included in the RCRA post closure permit groundwater
monitoring requirements and the results of the RCRA permit sampling may be submitted in fulfillment of this
permit requirement for those parameters. Analysis for parameters contained herein but not included in the
RCRA permit should be conducted simultaneously with the RCRA mandated analysis and all results should be
submitted simultaneously.
The results of the sampling and analysis shall be sent to the Groundwater Section, Permits and Compliance
Unit. P.O. Box 29535. Raleigh. NC 27626-0535 on Form GW-59 [Compliance Monitoring Report Form]
every February, May. August, and November.
Any additional groundwater quality monitoring. as deemed necessary by the Division, shall be provided
The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC 2L,
Groundwater Classifications and Standards. The Compliance Boundary for the disposal system constructed
prior to December 31. 1983 is established at either (1) 500 feet from the waste disposal area. or (2) at the
property boundary, whichever is closest to the waste disposal area. An exceedance of Groundwater Quality
Standards at or beyond the Compliance Boundary is subject to immediate remedial action in addition to the
penalty provisions applicable under General Statute 143-215.6A (a) (1).

Permit No. NCO006351
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND 'MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
A (5). Continued...
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established -' around the disposal systems midway
between the Compliance Boundary and the perimeter of the waste disposal area. Any exceedance of standards
at the Review Boundary shall require remedial action on the part of the Permittee.

704-455-1940 CHEMICAL SPECIALTIES
519 P02 Nov 02 ge 11:io
November 2,1998
M FACSRvHLF-
NC DEFINR
Division of Water Quality
Permits and Engineering Unit
512 N. Salisbury Street
Raleigh, NC 27604
Alto.: Mr. Mark McIntire
Subject: Draft Permit Comments
NPDES Permit No. NCO006331
Chemical Specialties, Inc,
H"sburp, NC Facility
Cabarrus County
Dear Mr. McIntire;
Thank you for the copy of the druft permit for review. I do have several
comments that I would like to discuss as follows:
I . The description of the existing wastewater treatment system includes reference
to five (5) sludge filters- These should be deleted. The filters are not a part of
the treatment system. The filters previously generated sludge that was directly
introduced to the wastewater treatment system. However, the sludge is now
directly landfill and not introduced to waste treatment. This was discussed
during your vish of March 11, 1997 and with our inspector on August 13,
1997 has shown in the attached inspection report copy.
2. The description of the existing wastewater treatment system also includes
reference to a pH adjustment tank, Unfortunately, we requested this addition
in our application cover letter of March 21, 1997. 1 had discussed with you
during our recent telephone conversation of October 7, 1998 we are preparing
to design a solids and equalization system replacement to our existing settling
lagoon. This system design will be forwarded to you in the near future for an
"Authorization to Construct" permit. However, we do not wish to make the
proposed change in our current system to include a pH adjustment tank when it
will be demolished with the installation of the new system.
3. Section A(l) Effluent Limits and Monitoring Requirements indicates the outfall
serial number 001- is a Once Through Cooling Water. This should be deleted.
10 Box 640 - 5910 Pharr Mill Road - Harrisburg, NC 26075 - 704-455-5181 * FAX [phone] - LAB FAX 7044E6-1 123

704-455-1940 CHEMICAL SPECIALTIES 519 P03 NOV 02 198 11:11
Mr. Mark McIntire
October 13, 1 g9s
Page 2
4. Section A(1) Effluent Lainlits and Monitoring Requirements indicates that
chronic toxicity testing be based on Ceriod4phnia P/P @ 0.961/o. is t1lis 4
typographical error and should it be 960/a. If so, we are interestod in
understanding the rational for the dramatic change in this patameter. Our
previous permit was for Fathe4d Nfinnows P/P @45%. In fact, I remember a
request, but canot find the documents, to change from Ceriodaphnia to
Fathead Minnows in the past due to Ceriodaphnia's 'intolerance to chloride
salts that are Inherent '
in our waste stream, We are requesting that it be
returned to Fathead Minnows P/F @45% if possible.
3. CSI is requesting that the NPDRS group discuss how to coordinato reporting
of groundwater results and requirements with the RCRA group, As we
discussed CSI is presently under groundwater monitoring requirements from
both the NPDES and RCRA group. The reporting of results to the NPDES
group has resulted in concern over groundwater above MCL's. This wEss
reviewed previously but has unnecessarily triggered red flags in the
M00feSville office. CSI has recently completed the first phase of our RCRA
Facility Investigation to delineate potential ground and soil contamination.
It is CSI's belief that the SrOundWater requirements should be regulated under
the RCIRA program due to the already heavy involvement and investigation
work underway in this area. In addition, neighbor's in the adjacent community
have recently been connected to City water supply. CSI has made a
considerable contribution to the Town of Harrisburg tolimplement that system.
Once again we thank you for this opportunity to review the draft permit and look
forward to your response, If you have any questions of concerns please feel free to
contact me at [phone].
Sincerely,
SV vester J, Bartos
CompUnce Manager
Chemical Specialties, Inc.

NCDENR/DIVISION OF WATER QUALITY
Water QualitySection/NPDE5 Unit
September 17, 1998
MEMORANDUM
To: NPDES Permit File
From: Mark McIntire
Subject: Supplementary Notes
Chemical Specialties, Inc.
NPDES, Permit No. NCO006351
A review of waste load allocation files, federal guidelines, and federal development documents for
the inorganic manufacturers category has offered little insight into the development of permit limits
for this facility. Because this facility1-14a�'C'C-5many chemicals, some of which are regulated
and some of which are not, limit development is especially difficult.
Existing limits are considered to be BPJ and more stringent than federal guidelines. The only limit
change is to lead, which was monitored only in the previous permit. Calculations for lead in
accordance with 40 CFR 415, subpart BO (zinc chloride production) have yielded effluent
limitations of 0.01 lbs/day and 0.037 lbs/day for monthly average and daily maximum respectively.
These limits are based solely on process wasteflow and the federally listed concentrations.

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,�mical AFSpecialfles, Inc.
Additional Information
111
I 14.b Principal Products
S SIC 2819 - Discharge 001
November 1996 P. lof I
Product Name
Maximum
Tons/ Day Principal Product Uses
Amine Copper Carbonate Solution (ACC)
25.00
wood preservative (FIFRA Pesticide)
Aluminum Nitrate
12.00
nuclear industry
Ammonium Chloride
10.00
galvanizing flux raw material
Arsenic Acid
100.00
wood preservative (FIFRA Pesticide)
Borated Diammoniurn Phosphate
25.00
fire retardant for wood
Calcium Nitrate
120.00
latex gloves, concrete, micronutrient
Copper Ammonium Acetate (CCN)
15.00
fungicide (FIFRA Pesticide)
Copper Ammonium Carbonate (CAC)
25.00
biocide, wood preservative (FIFRA Pesticide);
animal feed raw material (not regulated by
FIFRA)
Copper Chromated Arsenate
150.00
wood preservative (FIFRA Pesticide)
Copper Nitrate
Not produced at
present - purchased
for re -sale only
water treatment, micronutrient
CT-87 (ACC + CAC)
25.00
wood preservative (FIFRA non -regulated)
Magnesium Chloride
96.00
textiles, baby food,
Magnesium Dihydrogen Phosphate
24.00
textiles
Magnesium Nitrate
150.00
ink processing, micronutrient
Manganese Chloride
16.00
micronutrient
Manganese Nitrate
18.00
micronutrient
Ora -Cop
10.00
animal feed supplement
Ultrawood (Paraffin Wax and Surfactants)
20.00
water repellant for wood
Zinc Acetate
30.00
micronutrient
Zinc Ammonium Carbonate
10.00
micronutient
Zinc Ammonium Chloride
30.00
galvanizing flux
Zinc Chloride �t V X
90.00
raw material for galvanizing flux, electrolyte
Zinc Nitrate
60.00 Imicronutrient
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Facility Name =
NPDES # =
Ow (MGD) =
7010S (Cfs)=
lWC (%) =
Chemical Specialties, Inc.
NCO006351
Oms-
4
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RNAL RESULTS
Cadmium
Max. Pred Cw
Allowable Cw
Parameter— [C d.i..
�a
Standard = pgn
n BDL--1/2DL Actual Data
RESULTS
1 2.31
Sid Dev.
1.389115666
2 2.55
Mean
3.2256
3 6.61
C.V.
0.430653418
4 5.66
5 2.34
6 2.5
Mull Factor
7 2.22
Max. Value
6.61 pgA
8 2-22
Max. Pred Cw
11.237 pgA
9 3.75
Allowable Ow
208.5 pgA
10 3-33
11 4
12 2.26
13 3.16
14 2.66
15 4
16 1.87
17 6
18 6
19 2.47
20 2.17
21 2.46
22 2.66
23 2.68
24 2.31
25 2.45

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Facility Name =
NPOES Of =
Ow (MGD) =
7QIOS (Cfs)=
Im (%) =
Chemical Specialties, Inc.
NCO006351
0.02i
4
0.9i
FINAL RESULTS
Mercury
Max. Prod Cw 1.68
Allowable Cw 1.3
All mercury values were actually
below detection level in ten of
mass. During the conversion to
concentration, less than values
were reported as 1/2 of <value.
Parameter— [Mercurv,
Standard = pgA
n BDL=1/2DL Actual Data
1 0.11
2 0.09
3 0.11
4 0.55
5 0.46
6 0.11
7 0.35
8 0.6
9 0.25
10 0.25
11 0.27
12 0.22
RESULTS
Std Dev. 0.176040199
Mean 0.280833333
C.V. 0.626849372
MuItFactx=F---- 2-81
Max. Value 0.6 pgA
Max. Pred Cw 1.68 pgA
Allowable Cw 1.3 pgA

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Poplar Trails WWTP
NPDES Permit No. NCO061786
SLUDGE D
Sludge t�,f6moved from the subject facility by Roter-Rooter in Concord, North Carolina
and transpo*, a to the Rocky River WWT? in Concord.
Ratin;. /Satisfactory

March 21, 1997 COSI
CHEMICAL SPECIALTIES, INC.
CERTTFIED MAH,
RETURN RECEIPT REQUEST
NC DEHNR
Division of Water Quality
Permits and Engineering Unit
-.0
512 N. Salisbury Street
—J
Raleigh, NC 27604
3C
--Azr.-O
Attn.: Mr. David Goodrich
J
M,::) M
rn
Subject: Permit Application Submittal
G,:1 M
NPDES Permit No. NCO006351
Chemical Specialties, Inc.
un
Harrisburg, NC Facility
CO
Cabarrus County
Dear Mr. Goodrich:
Thank you again for visiting with us to review our status concerning the NPDES
permit renewal. We are also very appreciative of your comments on our sites improved
condition and obvious expenditure of money on the facility. This letter is to formalize the
review of the outstanding permit conditions and agreements made during that meeting of
March 11, 1997. Attached are the required three copies of our permit application and a
check for $200.
Compliance with 40 CFR 455
The primary concerns with the issuance of this permit renewal surround the site's
compliance with 40 CFR 455. As discussed during our meeting the options are:
• The elimination of waste water from being discharged to the river through
connection to Water and Sewer Authority of Cabarrus County (WSACC) or
• The elimination of pesticide waste water from the treatment plant system and
thus the river.
WSACC Connection
The Division encouraged CSI to pursue connection to WSACC to eliminate
surface water discharge. As a result, a meeting was arranged between CSI, WSACC and
NCDEHNR representatives on June 21, 1995 following issuance of our permit in May,
1995.
PO Box 610 A 5910 Pharr Mill Road A Hardsburg, NC 28075 - 704-455-5181 - FAX [phone] - LAB FAX 704-455,1123

Mr. David Goodrich
March 21, 1997
Page 2
The meeting included a review of existing waste streams, an update on historical
ammonia effluent levels, pesticide process review and a site tour. General consensus
during that meeting was that the WSACC was apprehensive about taking our waste
stream due to the potential presence of zinc and arsenic. Additionally, it was noted that if
there were problems with the WSACC treatment system that we would be the first likely
focus of the WSACC concern.
CSI also considered the connection to WSACC from an environmental impact
position. It is believed that due to the inorganic nature of our pesticide products that these
compounds would "pass through" WSACC treatment systems. This would simply transfer
the pesticide waste water from being discharged to surface water from our facility to the
WSACC facility with no additional level of pollutant removal.
Connection to the WSACC would require a circa $200,000 capital investment and
a continued operating costs for disposal based on recent cost estimates obtained by CSI.
To summarize, the concerns associated with connecting to WSACC for elimination of
pesticide waste water discharge are as follows:
• WSACC concern over site metals potentially present in effluent
• No substantial reduction in actual pollutant loading to surface water
• And high initial capital costs and continued operating costs.
Thus, CSI will not pursue connection to WSACC as the best option to eliminating
pesticide process water from being discharged to surface water. However, CSI does
intend on fully complying with the requirements of 40 CFR 455 and the requirements of
the NPDES permit as outlined in the next section.
Elimination of Pesticide Waste Water from the
As stated in the NPDES Permit Issuance letter dated May 5, 1995, "compliance
with 40 CFR 455 will require complete recycle or non -surface water discharge handling
of all process waste waters, wash waters, scrubber blowdown wastes, etc. and the
complete segregation or containment of and non -surface water discharge disposal of all
storm water which contacts raw materials, process areas, orfinishedproduct. "
The CSI facility currently complies with these requirements for two of our
pesticide products; Chromated Copper Arsenate (CCA) and Arsenic Acid processes and
have complied for many years. The only remaining pesticides present on site, based on the
Division's assessment are:
1. Copper Count N (CCN)
2. Copper Ammonium Carbonate (CAC)

Mr. David Goodrich
March 21, 1997
Page 3
3. Amine Copper Carbonate (ACC)
4. Mold Guard Products
To comply with 40 CFR 455, CSI has contained the production, storage and
loading areas for CCN, CAC and ACC. The containment was facilitated by constructing
a containment dike around these specific areas and providing sump pumps and water
collection tanks to act as surge capacity. Internal to these containment areas are
segregation curbs which minimize cross contamination of stormwater between different
pesticide product areas. This allows for the collection of water to be recycled or reused
in the process unless it is uncontaminated stormwater. Should the amount of water
collected exceed the amount that can be reused in process CSI will either reduce the
volume of the water collected by heating or may elect to dispose of the water through off -
site facilities. As we gain experience with our usage rates we may need to roof areas to
reduce the amount of water collected but this is as of yet undetermined.
This approach is more economical and environmentally more attractive since it
completely eliminates the discharging of pesticide effluents to surface water either by CSI
or the WSACC. This methodology has worked well for the CCA and arsenic acid
processes and we feel confident that we can comply with the pesticide regulations. Based
on your feedback during your visit this places CSI in compliance with 40 CFR 455 with
regard to CCN, CAC and ACC.
Mold Guard products on the other hand, is being approached differently. CSI and
our sister company Laporte Water Technologies and Biochem have decided to eliminate
the production of Mold Guard products from the CSI site. However, we respectfully
request an extension of time to implement the elimination of the Mold Guard products
from site. This time will allow for the site to work off the remaining inventory of raw
materials, transfer out finished product and for Biochem to locate and contract with a toll
manufacturer We are anticipating that this process will take through the end of 1997 and
request an extension to 12/31/97 before Mold Guard must be eliminated from the waste
treatment system.
Influent Restrictions
Also in reference to the NPDES Permit Issuance letter dated May 5, 1995, the
letter indicates that with segregation the only waste streams allowable for surface water
discharge are softener blowdown, uncontaminated storm water, and other non -contact
waste streams such as boiler blowdown, condensate blowdown, etc. Please be advised
that information specifically submitted during our review of the draft permit leading up to
the permit issued May 3 1, 1995 concentrated on resolving the pesticide issue.
As we indicated in our meeting pesticide production is only a portion of the
chemicals manufactured at the CSI facility. To further clarify this issue we have included
the following as promised in our meeting:

Mr. David Goodrich
March 21, 1997
Page 4
1. The spreadsheets included in the permit application that identify products and
production throughput (Additional Information II 14.b) have been modified to
include a column that indicates what the final use of the product is.
2. A generic process flow diagram has been generated. Since the processes on
site are similar, we have elected to produce a generic flow diagram
representative of all the processes. Site processes are acid -base reactions
including a wet scrubber and some type of filtration step. These diagrams
identify process waste water generation points which are typically
contaminated stormwater, process equipment washdown between products,
scrubber blowdown between products, area washdown, filter washdown
between products, raw material & finished product spills and material not
passing quality control parameters.
Pollution Prevention, Spill Response and Process Waste Stream
Recycling Efforts
The following outlines continued efforts by the CS1 facility to minimize waste
generated at the site. We have recently implemented the following:
• Stormwater Pollution Prevention Plant, and per your request, have included a
copy of our plan for your review.
• Modified spill procedures consistent with our RCRA Contingency Plan.
• Hazwoper spill response team, who have just completed their required 8 hour
refresher course.
Understanding the departments desire to reduce our effluent, CSI would like to
report that we have, through internal reuse, made significant strides in reducing our total
annual effluent discharge rates. In 1994 our average discharge rate for the year was
16)400 gpd where our average rate for 1996 was 6,500 gpd. We continue to pursue new
methods and processes to allow higher levels of reuse and thus lower our total annual
effluent loading to the river. Although we have made significant progress in reducing that
rate we still wish to maintain our 25,000 gpd monthly average discharge rate. This is due
to the fact that during "wet months" the site frequently needs to use the 25,000 gpd rate
to handle the hydraulic surge placed on the treatment plant.
New Issues
As we reviewed with you during our meeting, CSI is requesting several permit
modifications with this permit application, for your consideration.

Mr. David Goodrich
March 2 1 � 1997
Page 5
Elimination of Specific Monitoring Parameter
CSI is requesting that cadmium, lead, mercury and selenium be removed from our
effluent monitoring requirements of our permit. These parameters have remained below
detection levels throughout the monthly monitoring program for at least the past 2 years.
It is felt that cadmium and selenium were added based on historic pollutants previously
used on site but no longer present. Lead and mercury, although present in raw materials
used, are trace contaminants and of little impact on the waste water treatment system.
Samplinq Protocol Chan-ge
CSI is requesting that our monitoring protocol for metal sampling be changed from
the present grab sampling to continuous sampling as our previous permit allowed.
Equipment Modifications
CSI is requesting to re -install a weir box as the final effluent monitoring point in
the system. Previously we have removed the weir box in lieu of a hard piped system from
our settling tank. Within the hard piped system a sampling port was installed for effluent
monitoring. This configuration has concerned inspectors from your Mooresville office.
Thus, we would like to re -install the weir, re -install the float -type flow recorder and install
a continuous pH meter in the weir basin. The pH probe would stop flow to the river
should the pH of the effluent exceed our permit limits.
Also, we are requesting that the settling tank be remwed and replaced with a final
effluent pH adjustment tank. The settling tank performs no function in our current system.
The final pH tank would give our ORC the ability to maintain the treated waste water
above a pH of 9, thus reducing our zinc concentrations. The final pH adjustment tank
would then permit us to adjust down the pH before discharge. The adjustment tank will
include a pH probe and facilities for pH adjustment using caustic, nitric acid or alum.
Both of these modifications are presented in a Process & Instrument Diagram
attached.
Groundwater Monitoring Requirements
CSI is requesting that the NPDES group discuss how to coordinate reporting of
groundwater results and requirements with the RCRA group. As we discussed CSI is
presently under groundwater monitoring requirements from both the NPDES and RCRA
group. The reporting of results to the NPDES group has resulted in concern over

Mr. David Goodrich
March 21, 1997
Page 6
groundwater above MCL's. This was reviewed previously but has unnecessarily triggered
red flags in the Mooresville office. CSI has recently completed the first phase of our
RCRA Facility Investigation to delineate potential ground and soil contamination.
It is CSI's belief that the groundwater requirements should be regulated under the
RCRA program due to the already heavy involvement and investigation work underway in
this area.
Once again we thank you for taking the time to visit with us and review our
situation. If you have any questions of concerns please feel free to contact Paul Miano at
704-455-5181 ext. 245 or myself at ext. 238. We look forward to your decision on these
issues.
Sincerely,
Sylvester J. Bartos
Compliance Manager
Chemical Specialties, Inc.
cc: Mr. Rex Gleason, URO
S. B. Ainscough
C.T. Baccich
D.W. Moon
P. Miano
B. Callihan, Delta Environmental Consultants

Chemical Specialties, Inc.
Narrative of Generic Process Flow Diagram
SIC 2819 - Discharge 001
March 1997 p. 1 of 1
Chemical Specialties, Incorporated produces many different cheriicals at its Harrisburg Plant.
All the chemicals can be divided into two groups, however - either they are FIFRA regulated
pesticides or they are not.
All of the FIFRA regulated pesticide formulating, packaging and transfer operation products and
wastewaters are now isolated from the on -site waste treatment operation by containment pits.
Pesticide wastes are either reclaimed for use in products or disposed of properly off -site. This is
the same method the Plant has successfully used for years in the arsenic acid and chromated
copper arsenate areas.
The remaining non -pesticide operations have many similar features, as is shown generically on
the attached process flow diagram. Production of these chemicals involves a reaction between
an acid and a base, usually creating a mineral salt (examples would be calcium nitrate, zinc
nitrate, magnesium nitrate, magnesium chloride, etc.). The chemical reactions produce vapors,
which are condensed and captured in a scrubber, usually for re -use in the next batch. When the
reactions are complete, the material is filtered, brought into proper lab specifications, and stored
in tanks as finished product until containerized.
Material normally enters the on -site waste treatment operation through the following routes (not all
are shown on the diagram):
1 - Direct rainfall.
2. Rinse waters from operations areas to maintain good housekeeping practices.
3. Rinse waters from cleaning vessels to switch production to a, -)other chemical.
4. Scrubber blow down.
5. Cooling tower blow down.
6. Boiler blow down.
7. Scrubber recirculation tank liquid disposal to switch production to another chemical.
8. Off -specification raw materials and products.
9. De-minimus losses while transferring chemicals by hand or by pump.
10. Pump seal water.
11. Stormwater contaminated by chemicals.
12. Product and raw material spills.
13. Losses from filtering operations.
14. Lab operations.
QSI has made major improvements in Plant design and in housekeeping to minimize the amount
of liquid entering the waste treatment operation, and will continue to do so in the future.

2 3 41 5 1 -6 1 7 1 8 9 1 11 131 141 151 10 9L
_L 201 211 221 23 241 251 26� 27[ 28 29
BASE - ALUMfNUM OXIDE, AMMONIA. COPPER OXIDE, LIME. MAGNESIUM OXIDE,
MANGANESE OXIDES, MANGANESE. ZINC. ZINC OXIDE
MINERAL ACID- NITRIC, HYDROCHLORIC, PHOSPHORIC. ACETIC. CITRIC. CO2
BUILDING
FLOOR
RINSE
WATE12
SLJMP/TQOLJGH/
DRANPIT
COLLECTION
SYSTEMS
RECIRCULATION
TANK
REACTOR
PRODUCT
STORAGE
SOLIDS TANK
FILTER TO LANDFILL
OFF -SPEC
12AW MATERIALS
REACTOR SCRUBBER FILTE12 DRIPS CONTAMINATED STORMWATE2
RINSE WATE12 BLOW DOWN LIOUID WASTE OfF_SPfC PIT WATER/ (DIRECT)
CLEAN -CUTS CLEAN -OUTS PRODUCTS SPILLS STORMWATER
WASTE WATER
TREATMENT PLANT
PRODUCTS TO TRAILERICONTAINEQS
NITRATES. CHLORIDES. PHOSPHATES, ACETATES. CARBONATES
CHEMICAL SPECIALITIES, INC.
CS1 HARRISBURG, NORM CAROIRA
PROCESS FLOW DIAGRAM
-GENERIC
A
REMOMS
DATE
BY
T
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1 2 3 4 51 6 7
I vq 111 14 131 141 151 11 1
231 24
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COMPOS!TE-
EFFLUENT
SAMPLE
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CHEMICAL SPECIALITIES, INC.
CS1 HARRISBURG, NORTH CAROUNA
PROCESS FLOW DIAGRAM
CURRENT EFFLUENT pH
SAMPLING AND FLOW CONTROLS
ummoNs
rmwrm
D
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21 3 41 51 6 7 1 8 1 9 1
151 11 1 10
11 221 231 2 1 251 261 271 281 291
pH
------------ ------
ALLIM. NITR[C ACID
OR CAUSTIC SODA
-------------------------------
-F SAMPLNG
�PUMP
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RECORDING
FLOW
METE2
CD
V-NOTCH WEIR
COMPOSITE
EFFLUENT
SAMPLE
EFFLUENT TO
ROCKY RIVER
GRAVITY FLOW
CHEMICAL SPECIALITIES, INC.
CS1 HARRISBURG, NORTH CAROUNA
PROCESS FLOW DIAGRAM
PROPOSED EFFLUENT pH
SAMPLING AND FLOW CONTROLS
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141 15� 161 17
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PLANT NORTH
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----------------------------------------------------------------------- - - --------------------- - --- - --- - --- - --- - --- - -- ---- =-
STORM WATER IS ALWAYS
USED IN PLANT PROCESSES
STORM WATER ALWAYS
DRAINS TO THE RIVER
STORM WATER ALWAYS
DRAINS TO W.W.T.P.
STORM WATER IS PUMPED TO THE RIVER
IF CLEAN, TO THE W.W.T.P. IF NOT CLEAN
M
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�)Z= 6rD
Water
Softeners
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Waste Treatment
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161jW "-U I I �' 7dto &
(?PD Two -acre Storage
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Manufacturing
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Schematic of Water Flow
Chemical Specialties, Inc.
Harrisburg, Cabarrus, NC
November 30, 1996 p. 1 of 1
I

Chemical Specialties, Inc.
Additional Information
11 14-a Principal Raw Materials
SIC 2819 - Discharge 001
L.November 1996 P. I of I
Raw Material Name Maximum
Tons / Day
Acetic Acid
Activated Carbon
6.00
Aluminum Chloride
0 C
0.01
Aluminum Oxide
00
0.05
4.00
Ammonia
6.20
Ammonium Chloride
Arsenic Trioxide
5.00
30.00
Boric Acid
0.50
Carbon Dioxide
5.00
Chromic Acid
26.00
Citric Acid
0.02
Copper Metal
5.00
Copper Oxide
10.00
Diatomaceous Earth
Dimethyl Benzyl Ammonium Chloride
1.00
5.00
Hydrochloric Acid
15.00
Hydrogen Peroxide
70.00
Igepal CO 730
0.01
Igepal CO 997
1 0.01
Lime lur
15.00
Lime, Hydrated
5.60
Magnesium Hydroxide
9.50
Magnesium Oxide
2.10
Manganese Metal
2.00
Manganese Oxide
2.00
Manganese Te*traoxide ------------
4.00
Nitric Acid
27.00
Paraffin Oil
0.02
Paraffin Wax
0.02
Phosphoric Acid
2.50
Potassium Hydroxide
0.01
Potassium Iodide
0.01
Quarternary Amine Comp unds
3.00
Sodium Bisuffite
0.01
Sodiu
0.01-
Surfactants
0.01
Zinc Chloride
2.60
Zinc Metal
2.00
Zinc Oxide
4.00

Chemical Specialties, Inc.
Additional Information
11 14-b Principal Products
SIC 2819 - Discharge 001
,November 1996 P. lof I
Product Name
Maximum
Tons/ Day Principal Product Uses
Amine Copper Carbonate Solution (ACC)
25.00
Aluminum Nitrate --
wood preservative (FIFRA Pesticide)
12.00
nuclear industry
Ammonium Chloride
Arsenic Acid
10.00
galvanizing flux raw mat—eri
al
100.00
wood preservative (FIFRA Pesticide)
Borated Diammoniu m Phosphate
Calcium Nitrate
25.00
fire retardant for wood
Copper Ammonium Acetate (CCN)
120.00
latex gloves, concrete, micronutrient
Copper Ammonium Carbonate (CAC)
.15.00
fungicide (FIFRA Pesticide)
25.00
biocide, wood preservative (FIFRA Pesticide);
animal feed raw material (not.regulated by
FIFRA)
Copper Chromated Arsenate
Copper Nitrate
150.00
wood preservative (FIFRA Pesticide)
Not produced at
water treatment, micronutrient
present - purchased
CT-87 (ACC + CAC)
for re -sale only —
magnesium Chloride
25.00
wood preservative (FIFRA non -regulated)
magnesium Dihydroqen Phosphate
96.00
24.00
textiles, baby f—oo—d",-'!
Magnesium Nitrate
Manganese Chloride
150-00
textiles
ink processing. micronutrient
16.00
micronutrient
Manganese Nitrate
Ora -Cop
18.00
micronutrient"
�Ultrawood (Paraffin Wax and Surfactants)--
10.00
animal feed supplement
Zinc Acetate
20.00
water repellant for wood
Zinc Ammonium Carbonate
30-00
micronutrient
Zinc Ammonium Chloride
10-00
micronutient
Zinc Chloride
30.00
galvanizing flux
Zinc Nitrate
�90-00
raw material for g rolyte
60.00
micronutrient

Chemical Specialties, Inc.
Additional Information
11 15.a Waste Abatement
SIC 2819 - Discharge 001
November 1996
P. 1 of I
15.a Waste Abatement Practices
Pesticide production wastewaters and contaminated stormwater is contained and used in
production. Stormwater from some building roofs is being directed away from the effluent
collection drains. Plant scrubbers, where applicable, are recirulated to individual processes.
Loaded tanker trailers are parked on paved, curbed areas to contain potential leaks. Most pump
seals in the Plant which formerly used water -flush seals have now been converted to mechanical
seals. Most of the tanks located outdoors are now located in containment pits to to prevent leaks
and catastrophic failures from reaching the waste treatment system. New filter presses have
been installed and they are now drying the sludges to the extent that most of the filtered solids are
now landfilled off -site rather than being disposed of in the waste treatment settling lagoon. The
stormwater, leaks and process water which drain to the waste treatment system undergoes pH
adjustment and then settling in the equalization lagoon before the lagoon supernatant is
discharged as effluent.

PRIORITY PROJECT: Yes
To; Permits and - U *t
Water Qua ty Section
Attenti Mark McIntire
T ; 7 Date: May 23, 1997
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Cabarrus
NPDES Permit No.: NCO006351
MRO No.: 97-25
PART I - GENERAL INFORMATION
1. Facility and Address: Chemical Specialties, Inc.
Post Office Box 610
Harrisburg, N.C. 28075
2. Date of Investigation: March 11, 1997
3. Report Prepared By: Michael L. Parker, Environ. Engr. II A%
W
4. Person Contacted and Telephone Number: Sylvester Bartos,
Compliance Manager, [phone]�y-
5. Directions to Site: From the junction of Hwy. 49 and SR
1158 (Pharr Mill Rd.) east of the Town of Harrisburg, travel
south on SR 1158 approx. 0.4 mile. The entrance to Chemical
Specialties (CSI) is on the right (west) side of SR 1158.
6. Discharge Point(s), List for all discharge Points: -
Latitude: 35* 19' 45"
Longitude: 80* 37' 25"
USGS Quad No.: F 16 SE
7. Site size and expansion area consistent with application:
Yes. Expansion area is available.
8. Topography (relationship to flood plain included): The
facility is located at or near the 100 year flood plain.
Existing WWT units appear to be located above the flood
plain elevation,
9. Location of Nearest Dwelling: None within 300+ feet of the
site.

Page Two
10. Receiving Stream or Affected Surface Waters: Rocky River
a. Classification: C
b. River Basin and Subbasin No.: Yadkin 030711
C. Describe receiving stream features and pertinent
downstream uses: Receiving stream has excellent flow
at the point of discharge. Downstream uses are
primarily agricultural in nature and no water intakes
are known to exist for several miles.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
a. Volume of Wastewater: 0.025 MGD
b. What is the current permitted capacity: 0.025 MGD
C. Actual treatment capacity of current facility (current
design capacity): Unknown. MRO records do not contain
any information that refers to actual treatment
capacity. This flow rate has been used by CSI as far
back as 1974 when they were operating under an EPA
issued NPDES Permit.
d. Date(s) and construction activities allowed by previous
ATCs issued in the previous two years: N/A
e. Description of existing or substantially constructed
WWT facilities: The existing WWT facilities consist of
a 1/2 acre lined storage lagoon, five (5) sludge
filters, a solids mixing tank, two (2) reaction tanks
for pH adjustment, a two (2) acre unlined storage
lagoon, a pH adjustment tank, a final settling tank,
and instrumented flow measurement.
f. Description of proposed WWT facilities: There are no
proposed WWT facilities, however, the permittee is
requesting approval to reinstall a weir box at the
effluent from the final settling tank. The weir box
will have a float -type recorder and pH meter installed
for effluent monitoring. Since these facilities are not
considered waste treatment facilities, an ATC is not
required for their construction.
9. Possible toxic impacts to surface waters: This
facility has consistently passed all toxicity tests
performed since 1995.
h. Pretreatment Program (POTWs only): N/A
2. Residual handling and utilization/disposal scheme: The
company has a contract with a private industrial landfill
near the Town of Kernersville to dispose of residuals
generated in the WWT process.
3. Treatment Plant Classification: Class II

Page Three
4. SIC Code(s): 2819
Wastewater Code(s): 32, 02
5. MTU Code(s): 52002
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved (municipals only)?
No.
2. Special monitoring or limitations (including toxicity)
requests: CSI has requested that monitoring for Cadmium,
mercury, lead, and selenium be removed from the Permit. It
appears that sufficient justification may be available for
the removal of cadmium and selenium, however, a final
decision on this matter should come from the TSB. CSI has
also requested that metals sampling be changed from grab to
composite.
3. Important Compliance Schedule dates: N/A
4. Alternative Analysis Evaluation
a. Spray Irrigation: Insufficient area available.
b. Connect to regional sewer system: This option has been
explored by the company, however, concern over
potential metal loading, minimal reduction in pollutant
loading to surface waters, and high capital and
operating costs have prompted CSI to abandon this
option for now.
PART IV - EVALUATION AND RECOMMENDATIONS
Chemical Specialties (CSI) requests that the subject Permit
be renewed. The company has requested a few minor changes to the
permit (see Part III, No. 2 above), which should be addressed
prior to reissuance. CSI has also implemented various
improvements designed to segregate the various waste streams from
the area where pesticide products are produced at their facility.
This segregation will allow them to reuse/recycle these waste
streams, and ultimately reduce the amount of contaminated water
being sent to the WWTP. One item that has been of particular
concern to the Division is the production of a product called
Mold Guard. CSI has requested that they be allowed to phase out
the manufacturing of this product by the end of 1997. With CSI's
ability to segregate waste streams, this appears to be a
reasonable request, however, P&E should make the final decision
on this matter.

Page Four
Pending receipt and approval of the WLA, it is recommended
that the permit.be renewed as requested.
Signature oy�-efort Preparer Date
Water Quali
h:�dsr�dsrV�CSI.sr
isor
Date

LOWN
The Independent Dibune, Inc.
Q () Q C)
NORTH CAROLINA
CABARRUS COUNTY
S*:TE OF NORTH CAROLINA
ENVIRONMENTAL
MANAGEMENT
COMMISSION
POST OFFICE 29535
RALEIGH, NORTH CAROLINA
27626-0535
On the basis of thorough staff
review and application of Article
21 of Chapter - 143i General
Statutes of North.Carblina. Pub-
Jlc Law * 92- . §90 �tnd other lawful
standards and 1,60ulations, the
North CaV6110a Environmental
Manhger.i*09ornmission pro-
posos to issue a permit to dis.
charge to the, persons listed be-
low effeqtivd .1217198 and sub-
ject tp specIaL0,n0Itl0ns-._,
1 A
I i it
Persons wl Ig 0 comment.
upon or object to the proposed
determinations'are Invited to
subm.kt 64W.ir! writing to the
a6brvV'Xddr6ss'nO later than
111/23/0. All comments re-
ceived prior to that date will be
considered in the formulated Of I
final,determinations regarding
the proposed permit. A public
meeting may'be held where the I
Director of the Division of Envi-
ronmental Manaiement finds a
signiOcant degree of public inter-
est irl a proposed Permit.
A C6�y'of the draft permit -is
availqible by, *rItIng"or calling the
Division of.Environmental Man-
agement, PO Box 29535' Ra-
leigh ' North Carolina 27626-'
0535 (919)'733-7015.
The application and other infor-
mation may be Inspected at
thesb lodad ' ons during nRrmal
OtIlcG.119Vrs.�_CopIes.Of the infor-
mation on fife are available upon
request and payment of the,
cd'sis of reproduction. All such,
comments or requests regarding'
a propose * d permit should make
reference to the NPDES permit
number listed below.
Date Oct. 14. 1998
David A Goodrich *
A Preston Howard Jr., PE.
DireCtOf
Division of Environmental
Management
Public notice of Intent to issue a
State NPDES permit to the fOl-
lowing. �;.
1. NODES No. NC 0006351.
Chemical Specialities. Inc.. Post
office Box 610. Harrisburg,
North Carolina 28075 has ap-
plied for a permit renewal for a
facility lo�ated at 5910 Pharr Mill
Road, Harrisburg, Cabarrus
C6,gn%The'factIIty discharges
0.025 GO of treated industrial
wastewater from one outfall Into
the'Roicky River. a Class C
stre'am in the Yadkin -Pee Dee
River Basin which has a 7010
flow of 4.00 cis. The load ca-
pacity of the receiving water in
the immediate vicinity of this dis-
charge may be consumed.
No. 734 OcL 20,1998
On this, the day of 19
of THE INDEPENDENT TRIELTNE, Inc., after being duly
sworn, says that the annexed advertisement was dul-
inserted in the paper on the following dates:
and was published therein once a week for
weeks. The total cost of this advertisement $ 7 ZJ 'Y" L/
Subscribed and sworn to tYd day above first mentioned.
4
My Commission Expires
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4b,