NCS000233_Fact sheet binder_20230329

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 3/15/2023
Permit Number NCS000233
Owner/Facility Name Trinity Manufacturing Co.,Inc. /Trinity
Manufacturing Co,. Inc.
SIC AICS Code/Category 2869 325199 /Industrial Organic Chemicals,NEC
Basin Name/Sub-basin number Yadkin Pee-Dee/03-07-06
Receiving Stream/HUC UT to Falling Creek/030402010305
Stream Classification/Stream Segment WS-111/ 13-39-12-(1)
Is the stream impaired on 303 d list]? No
Any TMDLs? No
Any threatened and/or endangered species? See Section 2 below
Any compliance concerns? See Section 2 below
Any permit mods since lastpermit? See Section 1 below
New expiration date 4/30/2028
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
Trinity Manufacturing Co., Inc. is a chlor-alkali facility engaged in the production of agricultural,
specialty, and commodity chemicals. The chemicals produced are Sodium Hydroxide, 50% (Caustic
Soda); Sodium Hypochlorite, 15% (Bleach); Hydrochloric Acid, 32%; Chloropicrin; and Aqueous
Sodium Chloride (Saltwater). Chloropicrin is a soil fumigant and herbicide, nematocide, and fungicide.
Stormwater is directed into a single outfall via vegetated ditches and a detention pond. Previously the
facility produced sodium sulphanoiate but has since ceased production. The 2016 permit renewal
application also stated the facility had started implementation of a batch process to produce chlorinated
paraffins (batch process where dry chlorine gas is reacted with raw paraffin or olefin wax in a reactor),
however, this process was discontinued in December 2020. Additional changes since the last permit
include construction of a maintenance/receiving/warehouse building and expansion of the employee
parking lot.
Outfall SW001:
Drainage area includes gravel roadways, office area, a detention pond, railcar loading and unloading,
used equipment storage, empty drum and tote storage, parking lots, outdoor maintenance and laydown
and storage area, construction parking and laydown area, and shipping/receiving maintenance shop
Area 1: Storage of drums containing surfactant liquids and non-hazardous waste, storage of empty totes
and drums
Area 2: No longer exists
Area 3: Storage of empty nitromethane (raw material for chloropicrin process)metal drums
Area 4: Chloropicrin and Chlorine railcar loading/unloading stations
Area 5: Used equipment storage area
Area 6: Caustic and HCl railcar loading stations
Area 7: Brine filter waste collection dumpster and salt unloading
Page 1 of 6

Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• May 2012 to August 2022, no benchmarks were exceeded
Threatened/Endangered Species:
At the discharge location there are no threatened or endangered species. In the nearby vicinity there are
species of concern including the Coppery Emerald (Somatochlora georgiana;NC status: SR), Eastern
Tiger Salamander(Ambystoma tigrinum; NC status: T), Georgia Indigo-bush(Amorpha georgiana; NC
status: E), Sunnybell (Schoenolirion croceum;NC status: SR-H), Helicta Satyr(Neonympha helicta; NC
status: SR), Texas Hatpins (Eriocaulon texense; NC status: E), Bog Oatgrass (Danthonia epilis; NC
status: SR-T), Chapman's Yellow-eyed-grass (Xyris chapmanii;NC status: SR-D), and Sandhills Lily
(Lilium pyrophilum; NC status: E).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for May 2012 to August 2022. Quantitative sampling included pH, BOD, COD, chloropicrin,
chloride.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Trinity Manufacturing Co. Inc. site.
Page 2 of 6

Outfalls SWO01
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Chloropicrin BASIS: Potential pollutant from drainage area
Quarterly monitoring
Chloride BASIS: Potential pollutant from drainage area
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
Page 3 of 6

based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
(SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Chloride 860 mg/L EPA's National Recommended Water Quality Criteria, 2006
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
Page 4 of 6

• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Changes from previous permit to draft:
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• eDMR requirement added
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• TSS monitoring required per standard stormwater permitting requirements
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• Feasibility study removed in Part B
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 9/29/2022
• Initial contact with Regional Office: 9/29/2020
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 1/18/2023
Page 5 of 6

• Final permit sent for supervisor signature: 3/15/2023
Section 7. Comments received on draft permit:
• Mike Lawyer (FRO; via email 1/18/2023): Not sure if it's considered a significant change from
the current permit and would need to be included in the list on the cover letter,but the
current/expired permit only required TSS under the onsite vehicle maintenance monitoring,
which they don't conduct. The new/draft permit requires TSS monitoring regardless of any oil
usage, which is a change from the previous permit.
o DEMLR response: We will clarify this point in the final permit cover letter that TSS is
now a required monitoring parameter.
• Heidi Cox (PWS; via email 2/7/2023): We concur with the issuance of this permit provided the
facility is operated and maintained properly, the stated limits are met prior to discharge, and the
discharge does not contravene the designated water quality standards. The facility appears to be
located in the upstream area for the surface water source for the City of Rockingham Water
System NC0377015(1-5 miles away).
• Andy Borgstrom (permittee; via email 2/17/2023): Request Baseline Sampling Frequency
remain in line with previous permit on a semi-annual schedule (rather than quarterly)based on
good compliance history and the strain frequent testing places on resources. An additional
challenge is that the maximum hold time for the BOD parameter is 48 hours, which can make it
difficult to collect and transport samples to a lab on certain days of the week, particularly on a
weekend or holiday.
o DEMLR response: All individual industrial stormwater permits are being moved to
quarterly monitoring.
Page 6 of 6

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That she is Legal Advertising Representative of the The
Richmond County Daily Journal, a daily newspaper of
general circulation, printed and published in Rockingham,
Richmond County, North Carolina;that the publication, a
copy of which is attached hereto, was published in the
February 08, 2023
That said newspaper was regularly issued and circulated -C E I V E D
on those dates.
SIGNED:
Stonwater Program
Legal Advertising Repr entative
Subscribed to and swom to me this 8th day of February
2023.
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?Z�'NOTARY'= :
Holly Pankey, No ry Public, Richmond Wunty. North
Carolina =7". PU500 f:=
My commission expires:July 04,2027 �'S+'•IV cokAko-
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22051591 01107596
Brianna Young
201-NC Department of Environmental duality
1612 Mail Service Center
Raleigh, NC 27699

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Young, Brianna A
From: Young, Brianna A
Sent: Wednesday,January 25, 2023 12:05 PM
To: Lawyer, Mike
Subject: RE: Draft NPDES Stormwater Permit NCS000233
I apologize—I see what you mean now. I can make it more clear in the final permit cover letter that TSS is required,
whether vehicle maintenance occurs or not.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Lawyer, Mike<[e-mail]>
Sent:Tuesday,January 24, 2023 10:58 AM
To:Young, Brianna A<[e-mail]>
Subject: RE: Draft NPDES Stormwater Permit NCS000233
The 2/15/2012 permit is the current/expired permit,which only requires TSS monitoring if they conduct onsite vehicle
maintenance using more than 55 gallons of new motor oil per month.The new/draft permit requires TSS monitoring
regardless of any oil usage,which is a change from the previous permit.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
mike.lawyer(a�ncdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301

D E
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From:Young, Brianna A<[e-mail]>
Sent: Monday,January 23, 2023 11:02 AM
To: Lawyer, Mike<[e-mail]>
Subject: RE: Draft NPDES Stormwater Permit NCS000233
Hey Mike,
The previous permit I have is from 2/15/2012 and has the following on-site vehicle maintenance monitoring. Is there a
different/more recent version of the permit you are referencing?
Table 5. Analytical Moniterin ire uirement% for On-Site Vehicle Maintenance
h t � p
i
H siandaGTd semi-annual Grab S DC,
Non-Polar OiI & C'rrww
mglL semi-ar mual grab SLx)
F,PA Method 16G4(ST-]{EM1
Total Suspended Solids rn r L semi-annual Grab SDO
Total RainfallA inches semi-annual Rain gauge -
New worOiI Usage gallonslrnonth semi-annual Estimate
Thanks,
Brianna
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
2

From: Lawyer, Mike<[e-mail]>
Sent:Wednesday,January 18, 2023 4:33 PM
To:Young, Brianna A<[e-mail]>
Subject: RE: Draft NPDES Stormwater Permit NCS000233
Brianna,
Not sure if its considered a significant change from the current permit and would need to be included in the list on the
cover letter, but the current/expired permit only required TSS under the onsite vehicle maintenance monitoring,which
they don't conduct.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
mike.lawyer ncdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301
Q�>
OIp�r4-wqfi�i�Y+E/rYrX����
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From:Young, Brianna A<[e-mail]>
Sent: Wednesday,January 18, 2023 3:32 PM
To: Lawyer, Mike<[e-mail]>
Subject: RE: Draft NPDES Stormwater Permit NCS000233
Sorry for the second email - I put some wrong information in my previous email.The draft permit is for Trinity
Manufacturing(NCS000233). See attached.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
3

as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent: Wednesday,January 18, 2023 1:29 PM
To: Lawyer, Mike<[e-mail]>
Subject: Draft NPDES Stormwater Permit NCS000233
Hey Mike,
The draft permit for the Perdue Foods Lewiston Mill (NCS000233) is being submitted for public notice. Please provide
any comments by February 181n
Thanks,
Brianna
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
D E "IQ��
NORTH CAROLINA -
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
4

Young, Brianna A
From: Andy Borgstrom <[e-mail]>
Sent: Friday, February 17, 2023 2:59 PM
To: Young, Brianna A
Subject: [External] RE: Draft NPDES Stormwater Permit NCS000233
Attachments: Trinity Comment Letter for DRAFT NPDES Permit NCS0000233.docx; Trinity Stormwater
Sampling History.xlsx
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good afternoon Ms.Young,
Please see attached for Trinity's comment letter regarding this draft permit.
Thank you very much for your time and consideration. Please reach out to me if any further questions or concerns arise.
Best,
Andy Borgstrom
EHS Manager
910-331-8338 cell
„ TR I N ITY
This e-mail and any files transmitted with it are confidential and are intended solely for the use of the individual or entity to which they are addressed.If you are not
the intended recipient or the person responsible for delivering the e-mail to the intended recipient,be advised that you have received this e-mail in error and that
any use,dissemination,forwarding,printing,or copying of this e-mail is strictly prohibited.If you have received this e-mail in error,please reply back to sender
advising that you have received the e-mail in error.
From:Young, Brianna A<[e-mail]>
Sent:Thursday,January 19, 2023 9:10 AM
To: Daryl Mitzel <[e-mail]>
Cc:Andy Borgstrom <[e-mail]>
Subject: Draft NPDES Stormwater Permit NCS000233
"EXTERNAL EMAIL SENDER"
Good morning,
Attached is the draft stormwater permit for the Trinity Manufacturing Co., Inc. (NCS000233).A copy of this permit will
be mailed to Daryl Mitzel. Please provide any comments by February 18, 2023.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
i

Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
4111lii{;iF§)I_RrA -W
De"rlmorr7 0l E(Mra-unDIA QualcIV
Emali correspondence to and from this address is subject to the North
Carolina Public Records Law and may be 6sclo,sed to third parties_
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
2

11 E. V. Hogan Drive
y P.O. Box 1
TRINITY
+� Hamlet, NC 28345
MANUFACTURING , INC . 910-582-5650
February 17, 2023
Re: Draft Stormwater Discharge Permit No.NCS000233
Dear Ms. Young,
Thank you for sending us this Draft Permit and for giving us the opportunity to comment.
We have reviewed the changes from our previous permit and have noted the new requirements that have been
incorporated, including increased frequency of qualitative and quantitative monitoring. The only matter on which
we would like to comment is the quantitative sampling frequency for our Baseline Sampling Benchmarks in Part D.
I am writing to request that our Baseline Sampling Frequency remain in line with our previous permit on a semi-
annual schedule(rather than quarterly). This request is based on our good compliance history as well as the strain
that frequent testing places on our resources.
Trinity has consistently demonstrated a commitment to environmental compliance, and we take great care to ensure
that our stormwater management practices are up to par. For the past 10+years,we have sampled the stormwater
outfall at our site on a semi-annual frequency. Across more than 20 samples,we have had zero violations of any of
our Baseline Sampling Benchmarks(see attached summary spreadsheet).
We feel that increasing the required sampling frequency would present an unnecessary burden on our facility
resources,both in terms of time and money. The process requires a dedicated resource to monitor the weather for
"measurable storm events",collect a sample at our outfall within 30 minutes of discharge, and ensure that the
samples reach a qualified laboratory in time to analyze the samples. As you know, a storm event may not meet
permit requirements if another sample has been collected within 30 days or if another storm event has occurred
within 72 hours. An additional challenge is that the maximum hold time for the BOD parameter is 48 hours,which
can make it difficult to collect and transport samples to a lab on certain days of the week,particularly on a weekend
or holiday. These constraints already present a challenge in collecting samples on a semi-annual basis; it would be
especially burdensome if our requirement were to change to quarterly.
Given our excellent compliance history and our agreement to perform qualitative inspections on a quarterly basis,
we are confident that continuing to test stormwater samples for Benchmark parameters on a semi-annual schedule
would not compromise the quality of our stormwater management practices or the health of the environment.
Moreover,the Tiered Enforcement approach outlined in the permit(in Sections D-5 through D-7)would force us to
evaluate and address the source of any future Benchmark parameter exceedance.
We hope that you will take our request into consideration and work with us to determine a testing schedule that is
manageable for our company resources while still ensuring the protection of the environment.
Thank you for your time and consideration.
Regards,
U10-40 -ao
Andrew Borgstrom
EHS Manager Enclosure: Trinity Stormwater Sampling History.xls

Trinity Stormwater Sampling History(Since 2012)
Sample Date BOD COD TOW Chloride pH
30 mg/L 120 mg/L µg/L 860 mg/L 6.0-9.0
11/30/2022 4.96 22 130 154 7.2
8/1/2022 10.1 43.4 460 484 6.5
1/17/2022 < 3.00 < 20.0 300 203 6.3
7/8/2021 < 1.75 < 20.0 < 100 63.6 6.8
12/14/2020 4.34 38.5 < 100 261 7.8
8/4/2020 < 2.00 38 < 100 117 7.0
2/13/2020 19.4 31.5 < 100 411 6.5
8/14/2019 9.28 30.1 52.7 117 7.1
1/24/2019 2.81 32.1 25.8 65.3 6.7
4/24/2018 < 2.0 8.42 66.8 71.4 7.2
12/20/2017 25.7 <4.0 21.2 34.7 7.1
7/19/2017 < 2.0 17.3 83.5 188 7.3
1/22/2017 2.06 17.9 322 150 7.5
6/28/2016 2.25 16.8 23.1 10.3 7.4
2/4/2016 4.67 24.1 42.0 111 7.2
8/20/2015 3.5 4.32 28.0 48.4 8.5
11/17/2014 4.29 25.0 27.2 18.2 7.6
9/4/2014 4.54 25.4 48.5 22.9 8.5
12/4/2013 < 2.0 33.7 29.7 33.4 7.0
8/19/2013 < 2.0 6.06 4.2 4.58 7.3
1/31/2013 - - 64.7 - 7.9
1/17/2013 5.08 9.31 - 29.3 7.3
5/9/2012 16.0 29.0 < 50 7.29 7.3
*The TOH test is conducted as outlined in EPA Method 9020B

Young, Brianna A
From: Cox, Heidi
Sent: Tuesday, February 7, 2023 10:38 AM
To: Young, Brianna A
Cc: Walter, Carmalin
Subject: FW: Draft NPDES Stormwater Permit NCS000233
Attachments: Draft NPDES Permit NCS000233.pdf
We concur with the issuance of this permit provided the facility is operated and maintained properly,the stated limits
are met prior to discharge, and the discharge does not contravene the designated water quality standards. The facility
appears to be located in the upstream area for the surface water source for the City of Rockingham Water System
NC0377015(1-5 miles away).
Heidi Lane Cox
Regional Engineering Supervisor, Fayetteville& Wilmington Regional Offices
Division of Water Resources, Public Water Supply Section
North Carolina Department of Environmental Quality
Wilmington Office: [phone] 127 Cardinal Drive Ext. Wilmington, NC 28405
Fayetteville Office [phone] 225 Green St. Suite 714 Fayetteville, NC 28301
Cell: [phone]
[e-mail]
,�: D E
'Q /�
NORTH CAROLINA -
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From:Young, Brianna A<[e-mail]>
Sent:Thursday,January 19, 2023 9:10 AM
To: Cox, Heidi <[e-mail]>
Subject: Draft NPDES Stormwater Permit NCS000233
Good morning,
Attached is the draft stormwater permit for the Trinity Manufacturing Co., Inc. (NCS000233).This facility discharges
stormwater to class WS-III waters. Please provide any comments by February 18, 2023.
Thank you,
Brianna Young, MS(she/her/hers)
i

Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
,�: D_ E �%�'�
ti ;
NORTH CAROLINA
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
2

Young, Brianna A
From: Andy Borgstrom <[e-mail]>
Sent: Thursday, October 6, 2022 3:17 PM
To: Young, Brianna A
Subject: RE: [External] RE: Trinity Manufacturing, Inc. stormwater permit NCS000233
Attachments: Trinity Stormwater Sampling Results since 2012.xlsx; Stormwater Permit 2022 Requested
Information.docx
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hi Brianna,
Please see attached for the information you requested. If you need anything else or have follow up questions,just let
me know.
Thank you,
Andy Borgstrom
EHS Manager
910-331-8338 cell
,VTR I N IT
This e-mail and any files transmitted with it are confidential and are intended solely for the use of the individual or entity to which they are addressed.If you are not
the intended recipient or the person responsible for delivering the e-mail to the intended recipient,be advised that you have received this e-mail in error and that
any use,dissemination,forwarding,printing,or copying of this e-mail is strictly prohibited.If you have received this e-mail in error,please reply back to sender
advising that you have received the e-mail in error.
From:Young, Brianna A<[e-mail]>
Sent: Friday, September 30, 2022 10:32 AM
To:Andy Borgstrom <[e-mail]>
Cc: Karen Messana <[e-mail]>; Daryl Mitzel <[e-mail]>
Subject: RE: [External] RE:Trinity Manufacturing, Inc. stormwater permit NCS000233
"EXTERNAL EMAIL SENDER"
Thank you,Andy. Please let me know if you have any questions as you work through the requested information.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
1

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Andy Borgstrom <[e-mail]>
Sent: Friday, September 30, 2022 10:31 AM
To:Young, Brianna A<[e-mail]>
Cc: Karen Messana <[e-mail]>; Daryl Mitzel <[e-mail]>
Subject: [External] RE:Trinity Manufacturing, Inc. stormwater permit NCS000233
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hi Brianna,
Thank you for reaching out to us regarding this renewal. I will begin compiling and reviewing the information you've
requested and aim to send it to you early next week. I'll also take a look at our information in the Stormwater Permit
Summary Report and make sure it's all accurate.
Hope you stay safe through this hurricane, and I'll be in touch soon.
Andy Borgstrom
EHS Manager
910-331-8338 cell
�. � �
This e-mail and any files transmitted with it are confidential and are intended solely for the use of the individual or entity to which they are addressed.If you are not
the intended recipient or the person responsible for delivering the e-mail to the intended recipient,be advised that you have received this e-mail in error and that
any use,dissemination,forwarding,printing,or copying of this e-mail is strictly prohibited.If you have received this e-mail in error,please reply back to sender
advising that you have received the e-mail in error.
From:Young, Brianna A<[e-mail]>
Sent:Thursday,September 29, 2022 2:12 PM
To: Daryl Mitzel <[e-mail]>
Cc: Karen Messana <[e-mail]>; Andy Borgstrom <[e-mail]>
Subject:Trinity Manufacturing, Inc. stormwater permit NCS000233
"EXTERNAL EMAIL SENDER"
Good afternoon,
2

I am working on renewing the individual stormwater permit for the Trinity Manufacturing, Inc. facility
(NCS000233). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Description of onsite facility processes;
• Confirmation of the number of outfalls and associated coordinates;
• SIC (NAICS) code;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Georgoulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePUment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
3

OrtpeflmMli of Enr7onrnoMal 41Fel+tj
Email correspondence to and from this address rs subject to the North
Carolina Public Records Law and may be disclosed to third parties_
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
4

Trinity Manufacturing Inc.
Stormwater Discharge Permit NCS 000233
Description of Onsite Facility Processes
Trinity Manufacturing, Inc. is a chlor-alkali facility engaged in the production of Agricultural,
Specialty, and Commodity Chemicals. The chemicals produced are Sodium Hydroxide, 50%
(Caustic Soda): Sodium Hypochlorite, 15% (Bleach); Hydrochloric Acid, 32%; Chloropicrin; and
Aqueous Sodium Chloride (Saltwater).
Outfall
Trinity has one (1) Outfall located at the following coordinates:
Latitude: 34.915830 Longitude: -79.671940
SIC/NAICS Codes
Trinity's primary SIC/NAICS codes are as follows:
SIC code: 2869 NAICS Code: 325199
Verification of Renewal Application
The information submitted in Trinity's 2016 Renewal Application is still complete and accurate,
with the exception of the operational changes listed below.
Significant Industrial Activity Changes
In our 2016 Renewal Application, we stated that we had begun a new process to produce
chlorinated paraffins at the Trinity Manufacturing facility. This process has been discontinued
as of December 2020.

Date BOD COD TOH Chloride pH
30 mg/L 120 mg/L µg/L 860 mg/L 6.0-9.0
8/1/2022 10.1 43.4 460 484 6.5
1/17/2022 < 3.00 < 20.0 300 203 6.3
7/8/2021 < 1.75 < 20.0 < 100 63.6 6.8
12/14/2020 4.34 38.5 < 100 261 7.8
8/4/2020 < 2.00 38 < 100 117 7.0
2/13/2020 19.4 31.5 < 100 411 6.5
8/14/2019 9.28 30.1 52.7 117 7.1
1/24/2019 2.81 32.1 25.8 65.3 6.7
4/24/2018 < 2.0 8.42 66.8 71.4 7.2
12/20/2017 25.7 <4.0 21.2 34.7 7.1
7/19/2017 < 2.0 17.3 83.5 188 7.3
1/22/20171 2.06 17.9 322 150 7.5
6/28/2016 2.25 16.8 23.1 10.3 7.4
2/4/2016 4.67 24.1 42.0 111 7.2
8/20/2015 3.5 4.32 28.0 48.4 8.5
11/17/2014 4.29 25.0 27.2 18.2 7.6
9/4/2014 4.54 25.4 48.5 22.9 8.5
12/4/2013 < 2.0 33.7 29.7 33.4 7.0
8/19/2013 < 2.0 6.06 4.2 4.58 7.3
1/31/2013 - - 64.7 - 7.9
1/17/2013 5.08 9.31 - 29.3 7.3
5/9/20121 16.0 29.0 < 50 7.29 7.3

Young, Brianna A
From: Lawyer, Mike
Sent: Thursday, September 29, 2022 3:17 PM
To: Young, Brianna A
Subject: RE: Trinity Manufacturing, Inc. stormwater permit NCS000233
I wouldn't think another inspection is needed unless facility operations have significantly changed since 2020. If you
need a more recent inspection, it will likely be end of October/first of November before I can get it scheduled.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Office: 910-433-3300 1 Direct: 910-433-3394
mike.lawyer ncdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301
DE
Q-0
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From:Young, Brianna A<[e-mail]>
Sent:Thursday,September 29, 2022 2:10 PM
To: Lawyer, Mike<[e-mail]>
Subject:Trinity Manufacturing, Inc. stormwater permit NCS000233
Hello Mike,
I have started working on the renewal for the Trinity Manufacturing, Inc. stormwater permit (NCS000233). I saw an
inspection report from 2020 on Laserfiche -do you feel another inspection is needed before the draft permit goes to
public notice? Please let me know if there are any concerns that should be addressed during this renewal.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
1

D- E-
cl ;
NORTH CAROLINA 7.AM Q
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
2

9/28/22, 11:36 AM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Business Corporation
Legal Name
Trinity Manufacturing, Inc.
Information
Sosld: 0248196
Status: Current-Active O
Date Formed: 5/3/1989
Citizenship: Foreign
State of Incorporation: DE
Fiscal Month: April
Annual Report Due Date: August 15th
Currentgnnual Report Status:
Registered Agent: The Prentice-Hall Corporation System, Inc.
Addresses
Principal Office Reg Office Reg Mailing
11 Ev Hogan Dr 2626 Glenwood Avenue, Suite 550 2626 Glenwood Avenue, Suite 550
Hamlet, NC 28345 Raleigh, NC 27608 Raleigh, NC 27608
Mailing
PO Box 1519
Hamlet, NC 28345
Officers
President
Dean C Storkan
P O Box 1519
Hamlet NC 28345
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2

9/28/22, 11:36 AM North Carolina Secretary of State Search Results
Stock
Class: COMMON
Shares: 250000
Par Value 0.01
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2

Permit Coverage NPDES Permit Number �ir
NCDENR Renewal Application Form NCS000233 �!
National Pollutant Discharge Elimination System
Stormwater Individual Permit
Please provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to which permit correspondence will be mailed
Owner/Organization Name: Trinity Manufacturing, Inc.
Owner Contact: Daryl Mitzel
Mailing Address: PO Box 1519
Phone Number: 910-410-2726
Fax Number: 910-817-4791
E-mail address: [e-mail]
Facility Information
Facility Name: Trinity Manufacturing, Inc.
Facility Physical Address: 11 E.V. Hogan Drive /
Hamlet, NC 28345-8812 V
Facility Contact: Karen Messana
Mailing Address: PO Box 1519
Hamlet, NC 28345-1519
Phone Number: 910-419-6566 �6 ,
Fax Number: 910-401-1261 R�� V
E-mail address: kmessana! trinitymfmom Al [7% 3 Q
Permit Information
Permit Contact: Karen Messana �r�M ✓q]��ID�UALIjY
Mailing Address: PO Box 1519 RpERMlrrl'Vc
Hamlet NC 28345-1519
Phone Number: 910-419-6566
Fax Number: 910-401-1261
E-mail address: kmessana trini mf .corn
Discharge Information
Receiving Stream: South Prong Falling Creek
Stream Class: C
Basin: Yadkin River Basin
Sub-Basin: 03-07-16
Number of Outfalls: 1
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
Changes at the facility include implementing a batch process to produce chlorinated paraffins, constructing a maintenance/receiving/
warehouse building, and expanding the employee parking lot. See enclosures for more information.
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is tru , cgmp to an ccurate. JJ
Signature Date
Daryl Mitzel Executive Vice President
Print or type name of person signing above Title
SW Individual Permit Coverage Renewal
Please return this completed application form Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
r�l� 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities(including storage of materials,disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility(Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

General Notes
i SDO-OUTFALL 1
V IMPERVI❑US AREAS
STDRMWATER DITCH / - -- � __ t THE DRAINAGE AREA
CONTAINMENT PITS J 1 FOR ❑UTFALL I IS
/ 19,70 ACRES [IF
SMA AREAS 1 WHICH 6.82 ACRES
/ l t IS IMPERVI❑US AT
CB CATCH BASIN ' 1 TMI AND 4,96 ACRES
�—UNDERGROUND IS IMPERVI❑US AT
/ !11 STDRMWATER PIPE / DETENTION POND TCP FOR A TOTAL
' �\
RUNOFF DIRECTION / 1- ❑F 59.87 F THE
TOTAL DRAINAGE
❑
ytw FENCE / AREA,
/ 1 AREA 1. EMPTY DRUM AND TOTE STORAGE
AREA 3. EMPTY DRUM STORAGE
AREA 4. RAILCAR LOADING
AREA 5. USED EQUIPMENT STORAGE
Ha LDaDHL
o /
AREA 6, HCL AND CAUSTIC RAILCAR
c LOADING
ce-•ai
AREA 7. WASTE CDLLECTIUN DUMPSTER
\ \_ � n3En +b AND SALT UNLOA➢ING
9I
o EMERGENCY CONTACTS
SG f H-IIB K11i
T❑DD BARNES
995-C9 0):� C LL' E 1 8356
JAS❑N YARB❑R❑UGH
CELL: (910) 995-0056
Em
1
q o nm a s, vZ t 0 CURRENT/AS BUILT 8/25/16
«° 1
i aa[a •� cv-"v O � s No. REVISION/ISSUE DATE
H-tt3 IDF-1 ��- t -- O cv v ce•m
® TRANS-CAROLINA
PRODUCTS
i
AL
• c ��
\ / J
"� Y D_
�—�' --___ / aba O ® ® c► MANUFACTURING in
\ c-0 v a 0
avtEa v INCORPORATED
aaEa - �� Drawing Name 3
5 sN Mww :c 9
TRINITY MANUFACTURING
CHLOR—ALKALI PLANT
®CI•N J
O)
L
L
L
o l� - - / / I LHECKEB BY
\�JI NOT CHECKED W
(L / .
Ding Nunber
1 OF 1 a
CL J
Q Q
N Q�u author d
RLEVINER

1
General Notes
i SDO—OUTFACE 1
4R ®IMPERVI❑US AREAS
C-4
STORMWATER DITCH / THE DRAINAGE AREA
EF1R PIJTEAI I I IS
CONTAINMENT PITS
O 19,70 ACRES [IF
SMA AREAS / WHICH 6,82 ACRES
IS IMPERVIOUS AT
CB CATCH BASIN
TMI AND 436 ACRES
IS IMPERVI❑US AT
NDERGROUND STORMWATER PIPE / T C P F-❑R A TOTAL
DETENTION POND
[IF59,8% OF THE
RUNOFF DIRECTION FENCE TOTAL DRAINAGE
I/ AREA,
AREA 1. EMPTY DRUM AND TOTE STORAGE
I1 AREA 3. EMPTY DRUM STORAGE
AREA 4. RAILCAR LOADING
AREA 5. USED EQUIPMENT STORAGE
AREA 6. HCL AND CAUSTIC RAILCAR
LOADING
/ AREA 7. WASTE COLLECTION DUMPSTER
u aY —_ —.1 a "k, AND SALT UNLOA➢ING
AREA
EMERGENCY C❑NTACTS
AU 11 • o,
$ - T❑DD BARNES
C CELL: (910) 995-8356
pp
JAS❑N YARB❑R❑UGH
CELL: (910) 995-0056
y—8' oo o, re, -
1 rl W B1 r C.-.1
r.ttt...cC
K[ilU / t-. Ct-t16
—W
0-41
ct-tie �� 0 CURRENT/AS BUILT 6/25/16
AREA �o-.r O � b S Q ct-n1 No. REVISION/ISSUE DATE
M-113 � '"
TRANS-CAROLINA
1
AR A ' PRODUCTSC=Zilm _
i O
) / ' Q\®@ Q 9 A octe� 1 �✓ o a ¢
\ .y
MANUFACTURING in
c.-.t° `�O 0 ARCA INCORPORATED w
Qrawing Name 3
0
�� N
ACTUell i
_ n m
�HLOR—AL NT
04.
o
HE Q �!
lJ woo Orowln Number
o--j "� a 1 OF 1 ��9�/ o
in ¢¢ L
(U 8�u - Author d
RLEVINER

Trinity Manufacturing, Inc.
Stormwater Discharge Permit Renewal - 2016
NCS 000233
Analytical Monitoring Results Summary for Outfali OF-1
SM 5210B EPA 410.4 SW-946 9020E EPA 300.0 SW846 9040C
Outfall Total BOD COD Chloropi) rin Chloride pH Testing Lab
OF-1 Rainfall
Benchmark inches 30 mg/L 120 mg/L µg/L 860 mg/L 6 - 9
Cate Sample
Collected,
mm-dd-yy
06-26-16 0.4 2.25 16.8 23.1 10.3 7.37 Test America
02-04-16 0.5 4.67 24.1 111 7.19 Test America
02-04-16 0.5 42 8.46 ALS
08-20-15 0.4 3.5 4.32 48.4 8.46 Test America
08-20-15 0.4 28 8.46 G-Cal
11-17-14 0.35 4.29 25.0 18.2 7.63 Test America
11-17-14 0.35 27.2 7.63 G-Cal
09-04-14 0.3 4.54 25.4 22.9 8.46 Test America
09-04-14 0.3 48.5 8.46 G-Cal
12-04-13 0.3 MDL ND m IL 33.7 33.4 7.0 Test America
12-04-13 0.3 29.7 7.0 G-Cal
08-19-13 0.9 MDL ND m IL 6.06 4.58 7.3 Test America
08-19-13 0.9 4.2 7.3 G-Cal
01-31-13 0.3 64.7 7.89 G-Cal
01-17-13 0.6 5.08 9.31 29.3 7.3 Test America
05-09-12 0.3 16 29 7.29 7.3 Test America
05-09-12 0.3 ND< 50 7.3 G-Cal

Trinity Manufacturing, Inc.
Stormwater Discharge Permit Renewal -2016
NCS 000233
Analytical Monitoring Results Summary for Outfall OF-1
SM 5210B EPA 410.4 SW-846 9020B EPA 300.0 5W846 9040C
Outfall Total BOD COD Chl°T�Hi)rin Chloride pH Testing Lab
OF-1 Rainfall
Benchmark inches 30 mg/L 120 mg/L pg/L 860 mg/L 6 - 9
Date Sample
Collected,
mm-dd-yy
06-26-16 0.4 2.25 16.8 23.1 10.3 7.37 Test America
02-04-16 0.5 4.67 24.1 111 7.19 Test America
02-04-16 0.5 42 8.46 ALS
08-20-15 0.4 1 3.5 4.32 48.4 8.46 Test America
08-20-15 0.4 28 8.46 G-Cal
11-17-14 0.35 4.29 25.0 18.2 7.63 Test America
11-17-14 0.35 27.2 7.63 G-Cal
09-04-14 0.3 4.54 25.4 22.9 8.46 Test America
09-04-14 0.3 48,5 8.46 G-Cal
12-04-13 0.3 MDL N2D m IL 33.7 33.4 7.0 Test America
12-04-13 0.3 29.7 7.0 G-Cal
08-19-13 0.9 MDL ND m iL 6.06 4.58 7.3 Test America
08-19-13 0.9 4.2 7.3 G-Cal
01-31-13 0.3 64.7 7.89 G-Cal
01-17-13 0.6 5.08 9.31 29.3 7.3 Test America
05-09-12 0.3 16 29 7.29 7.3 Test America
05-09-12 0.3 ND< 50 7.3 G-Cal

Trinity Manufacturing, Inc.
SUMMARY OF VISUAL MONITORING RESULTS (2012 — 2016)
Stornawater Permit No. NCS000233
Outfall No. OF-1
Other
Sampling Floating Suspended Erosion or Obvious
Date Color Odor Clarity Solids Solids Foam Oil Sheen Deposition Indicators
of Pollution
06-28-16 Light gray None 2 l 1 None None None None
0.41'
02-04-16 Light gray None 2 l 1 None None None None
0.5,E
08-20-15 Light gray None 2 l 1 None None None None
0.4„
11-17-14 No Color
Grayish None 2 l 1 None None None None
0.35 Medium Tint
09-04-14 No Color 0.3" Medium Tint None 2 1 2 None None None None
12-04-13 No Color
0.3" Light None 2 1 1 None None None Niue
0$-19-13 No Color
0.9 Light None 2 1 1 None None None None
01-31-13 Typical Typical Typical Typical Typical Typical Typical Not None
0.31' Observed
01-17-13 Typical No Typical Typical Typical No No Not None
0.6" Observed
04-04-12 Typical Typical Typical Typical Typical Typical Typical Not None
> 0.1" Observed
Form 9046-Storm water Visual Summary

Trinity Manufacturing, Inc.
SUMMARY OF VISUAL MONITORING RESULTS (2012 — 2016)
Stormwater Permit No. NCS000233
Outfall No. OF-I
Other
Sampling Floating Suspended Erosion or Obvious
Date Color Odor Clarity Solids Solids Foam Oil Sheen Deposition Indicators
of Pollution
06-28-16 0.4" Light gray None 2 1 l None None None None
02-04-16 Light gray None 2 1 l None None None None
0.5"
08-20-15 Light gray None 2 1 1 None None None None
0.4"
1 1-17-14 No Color
Grayish None 2 1 l None None None None
0.35" Medium Tint
09-04-14 No Color
0.3" Medium Tint None 2 1 2 None None None None
12-04-13 No Color None 2 1 I None None None None
0.3" Light
08-19-13 No Color None 2 1 1 None None None None
0.9" Light
01-31-13 Typical Typical Typical Typical Typical Typical Typical Not None
0.3„
Observed
01-17-13 Typical No Typical Typical Typical No No Not None
0.6" Observed
04-04-12 Typical Typical Typical Typical Typical Typical Typical Not None
> 0.1" 1 1 1 1 1 Observed
Form 9046—Stormwater Visual Summary

Trinity Manufacturing Inc.
Stormwater Discharge Permit NCS 000233
Best Management Practices (BMPs)
Best Management Practices for the site include a combination of operational and source
control BMPs. These BMPs have been implemented to minimize precipitation contact with
potentially contaminating activity, contain and treat precipitation contacting industrial activity,
and preemptively provide systems and equipment to deal with unanticipated occurrences.
General BMPs implemented throughout the facility to achieve stormwater pollution prevention
goals include:
• Vegetative areas are created and maintained to prevent erosion and sedimentation.
• Loading and unloading operations are either covered and/or done in areas designed to
catch stormwater which may contact these operations as well as any minor drips associated
with connecting or disconnecting.
• Storage of all bulk liquid materials at Trinity is provided with secondary containment.
Stormwater collected in these secondary containment areas is treated and discharged
through the sanitary sewer in accordance with its POTW IUP permit.
• Impervious surface are sloped to catch basins and routed to a stormwater detention pond
for the majority of industrial activity. Use of the stormwater detention pond is incorporated
in the Spill Response Plan
• Concrete pad areas are sloped and laid out to minimize or prevent stormwater run-off into
areas containing significant materials associated with industrial activity.
• Significant material areas are included as part of facility inspections to identify improvement
opportunities.
Best Management Practices (BMPs) address potential pollutant areas that have been identified
during facility inspections. The BMPs are designed to help reduce the potential for stormwater
pollution. BMP categories considered include: Flow Diversion, Exposure Minimization, Mitigate
Practices, Sediment and Erosion Prevention, Infiltration Practices, and Other Preventive
Practices such as Good Housekeeping, Preventive Maintenance, Visual Inspections, Spill and
Stormwater Plan Training, and Documentation.

Area 1- Storage of drums containing surfactant liquids and non-hazardous waste as well as
storage of empty totes and drums.
• Materials are stored in this area only on a temporary basis. While stored in this
area, containers are readily visible and any leakage or run-off can be dealt with
quickly.
• Drums of liquid surfactant are used on a seasonal basis. These inventories are
minimized and managed to eliminate carry-over of inventory between seasons.
• Drumming of dry materials in the area is scheduled around weather forecasts and
covered during periods of unanticipated precipitation. Following completion, the
area is swept to prevent contamination.
Area 3- Storage of empty nitromethane metal drums.
• Drums are pumped until empty and the bung caps are re-secured before being
temporarily stored while awaiting pickup.
• Empty drums are picked up for recycling on a frequent and regular basis.
Area 4- Railcar loading/unloading stations (Chloropicrin & Chlorine).
• Spill containment (railcar pans) is included at each railcar loading station. The pans
are piped to a treatment tank,treated if necessary, and discharged to the sanitary
sewer.
• Area lighting and video cameras facilitate enhanced surveillance of loading
operations above and beyond operator attendance.
• Loading operations are instrumented and automated to minimize opportunities for
overfilling.
Area 5- Storage area for used equipment.
• Used equipment stored in the area is decontaminated prior to its storage.
• Storage containers allow small, primarily metal, parts to be housed out of the
weather, minimizing opportunity for the formation of rust.
Area 6- Railcar loading stations (Caustic and HCI).
• Spill containment (railcar pans) is included at each railcar loading station. The pans
are piped to a treatment area,treated if necessary, and discharged to the sanitary
sewer.

• Area lighting and video cameras facilitate enhanced surveillance of loading
operations above and beyond operator attendance.
• Loading operations are instrumented and automated to minimize opportunities for
overfilling.
Area 7- Brine filter waste collection dumpster and salt unloading.
• Dumpster is set in a curbed area to allow collection of any leakage.
• Dumpster is kept covered to prevent stormwater contact.
• Salt conveying system is inspected and cleaned as part of the preventative
maintenance program.

Trinity Manufacturing Inc.
Stormwater Discharge Permit NCS 000233
Best Management Practices (BMPs)
Best Management Practices for the site include a combination of operational and source
control BMPs. These BMPs have been implemented to minimize precipitation contact with
potentially contaminating activity, contain and treat precipitation contacting industrial activity,
and preemptively provide systems and equipment to deal with unanticipated occurrences.
General BMPs implemented throughout the facility to achieve stormwater pollution prevention
goals include:
• Vegetative areas are created and maintained to prevent erosion and sedimentation.
• Loading and unloading operations are either covered and/or done in areas designed to
catch stormwater which may contact these operations as well as any minor drips associated
with connecting or disconnecting.
• Storage of all bulk liquid materials at Trinity is provided with secondary containment.
Stormwater collected in these secondary containment areas is treated and discharged
through the sanitary sewer in accordance with its POTW IUP permit.
• Impervious surface are sloped to catch basins and routed to a stormwater detention pond
for the majority of industrial activity. Use of the stormwater detention pond is incorporated
in the Spill Response Plan
• Concrete pad areas are sloped and laid out to minimize or prevent stormwater run-off into
areas containing significant materials associated with industrial activity.
• Significant material areas are included as part of facility inspections to identify improvement
opportunities.
Best Management Practices (BMPs) address potential pollutant areas that have been identified
during facility inspections. The BMPs are designed to help reduce the potential for stormwater
pollution. BMP categories considered include: Flow Diversion, Exposure Minimization, Mitigate
Practices, Sediment and Erosion Prevention, Infiltration Practices, and Other Preventive
Practices such as Good Housekeeping, Preventive Maintenance, Visual Inspections, Spill and
Stormwater Plan Training, and Documentation.

Area 1- Storage of drums containing surfactant liquids and non-hazardous waste as well as
storage of empty totes and drums.
• Materials are stored in this area only on a temporary basis. While stored in this
area, containers are readily visible and any leakage or run-off can be dealt with
quickly.
• Drums of liquid surfactant are used on a seasonal basis. These inventories are
minimized and managed to eliminate carry-over of inventory between seasons.
• Drumming of dry materials in the area is scheduled around weather forecasts and
covered during periods of unanticipated precipitation. Following completion, the
area is swept to prevent contamination.
Area 3- Storage of empty nitromethane metal drums.
• Drums are pumped until empty and the bung caps are re-secured before being
temporarily stored while awaiting pickup.
• Empty drums are picked up for recycling on a frequent and regular basis.
Area 4- Railcar loading/unloading stations (Chloropicrin & Chlorine).
• Spill containment (railcar pans) is included at each railcar loading station. The pans
are piped to a treatment tank,treated if necessary, and discharged to the sanitary
sewer.
• Area lighting and video cameras facilitate enhanced surveillance of loading
operations above and beyond operator attendance.
• Loading operations are instrumented and automated to minimize opportunities for
overfilling.
Area 5- Storage area for used equipment.
• Used equipment stored in the area is decontaminated prior to its storage.
• Storage containers allow small, primarily metal, parts to be housed out of the
weather, minimizing opportunity for the formation of rust.
Area 6- Railcar loading stations (Caustic and HCI).
• Spill containment (railcar pans) is included at each railcar loading station. The pans
are piped to a treatment area,treated if necessary, and discharged to the sanitary
sewer.

• Area lighting and video cameras facilitate enhanced surveillance of loading
operations above and beyond operator attendance.
• Loading operations are instrumented and automated to minimize opportunities for
overfilling.
Area 7- Brine filter waste collection dumpster and salt unloading.
• Dumpster is set in a curbed area to allow collection of any leakage.
• Dumpster is kept covered to prevent stormwater contact.
• Salt conveying system is inspected and cleaned as part of the preventative
maintenance program.

Trinity Manufacturing Inc.
Stormwater Discharge Permit NCS 000233
Significant Industrial Activity Changes
Changes in industrial activity at the site since the previous stormwater permit application
include implementing a process to produce chlorinated paraffins at the Trinity Manufacturing
facility. This is a batch process where dry chlorine gas is reacted with raw paraffin or olefin wax
in a reactor. This process is in contained areas. The original BMP philosophies for the facility
have been extended to encompass this process. Also, a maintenance/receiving/warehouse
building has been constructed and the parking lot has been expanded at the facility as well.

Trinity Manufacturing Inc.
Stormwater Discharge Permit NCS 000233
Significant Industrial Activity Changes
Changes in industrial activity at the site since the previous stormwater permit application
include implementing a process to produce chlorinated paraffins at the Trinity Manufacturing
facility. This is a batch process where dry chlorine gas is reacted with raw paraffin or olefin wax
in a reactor. This process is in contained areas. The original BMP philosophies for the facility
have been extended to encompass this process. Also, a maintenance/receiving/warehouse
building has been constructed and the parking lot has been expanded at the facility as well.

STOR `?VATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND,E MFLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources—Stormwater Permitting
Facility Name: Trinity Manufacturing, Inc.
Permit Number: NCS000233
Location Address: 11 EV Hogan Dr
Hamlet, NC 28345
County: Richmond
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the person or persons
who manage the system,or those persons directly responsible for gathering the information,the information gathered is,to the
best of my knowledge and belief,true,accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully
implemented at this facility location in accordance with the terms and conditions of the stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for
knowing violations."
Sign(according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
l
Signature Date
Daryl Mitzel Executive Vice President
Print or type name of person signing above Title
SPPP Certification 10/13

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources—Stormwater Permitting
Facility Name: Trinity Manufacturing, Inc.
Permit Number: NCS000233
Location Address: 11 EV Hogan Dr
Hamlet, NC 28345
County: Richmond
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the person or persons
who manage the system,or those persons directly responsible for gathering the information,the information gathered is,to the
best of my knowledge and belief,true,accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully
implemented at this facility location in accordance with the terms and conditions of the stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for
knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date-I-ekc.p
K�
Daryl Mitzel Executive Vice President
Print or type name of person signing above Title
SPPP Certification 10/13

11 E. V. Hogan Drive
TR I N ITY P.O. Box 1519
Hamlet, NC 28345
' MA4UFACTURI4G i N C 910-582-5650
910-817-4791 (fax)
August 25, 2016
SW Individual Permit Coverage Renewal
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, NC 27699-1612
Re: Stormwater Discharge Permit No.NCS000233
Dear Sir or Madam,
Enclosed is the information required by the Division of Energy, Mineral and Land Resources for renewal of Trinity
Manufacturing Inc.'s NPDES Individual Stormwater Permit. Following is a list of the enclosed information:
• Signed copy of Renewal Application Form
• Supplemental Information Checklist form
o Current site map from our Stormwater Pollution Prevention Plan
o Summary of Analytical Results
o Summary of Visual Monitoring Results
o Summary of Best Management Practices
o Short narrative of Significant Changes in Industrial Activities
o Signed Certification of the development and implementation of a Stormwater Pollution Prevention
Plan
If you have any questions, Karen Messana is our contact person for the permit and SPPP. She can be reached at 910-
419-6566.
Best Regards,
aryl Mitzel S�oUF4`R ` �� �®
Executive Vice President
EnclosuresR41jTT G