NCS000064_Fact sheet binder_20240221

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 2/13/2024
Permit Number NCS000064
Owner/Facility Name CNA Holdings,LLC/CNA Holdings,LLC—Shelby
2821 (325211)/Plastic Materials, Synthetic Resins,
SIC(NAICS)Code/Category and nonvulcanizable elastomers (Plastics material
and resin manufacturing)
Basin Name/Sub-basin number Broad/03-08-05
Receiving Stream/HUC UT to Buffalo Creek/030501050805
Stream Classification/Stream Segment C/9-53- 5
Is the stream impaired on 303 d list]? No
Any TMDLs? No
Any threatened and/or endangered species? No
Any compliance concerns? See Section 2 below
Any permit mods since lastpermit? See Section 1 below
New expiration date 3/31/2029
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The CNA Holdings, LLC—Shelby facility manufactures liquid crystal polymer. Information with the
permit renewal application states during the previous permit term, the facility shut down the
compounding operations (change did not affect stormwater activity).
Per the permit renewal application, significant materials include: loading and unloading docks, scrap
metal storage areas, oil and chemical tank farm areas, solid waste compactors and dumpsters, recycling
areas, wastewater treatment, and hazardous and non-hazardous areas.
• The east outfall includes loading and unloading of raw materials and by/co-products, Marley
cooling tower. The raw materials and by/co-products include 300 gallon of caustic, 120 gallon of
boiler treatment, 120 gallon of oxygen scavenger, 120 gallon of corrosion inhibitor, 120 gallon
of bromine, 120 gallons of biocide, and 120 gallons of coiling tower treatment.
• The north outfall includes compounding and Vectra waste dumpster roll-offs, cardboard and
scrap metal recycling, brown and root scrap yard, oil and chemical storage with secondary
containment, emergency firewater basin, HOA secondary containment basin and a cooling tower.
There are two storage tanks, 5,000 gallons capacity each, of Therminol 66 which is diked.
• The south outfall contains a number 6 empty closed in place AST, a gasoline and diesel
unloading/loading station(under roof), hazardous and non-hazardous storage (under roof), and a
cooling tower tank farm(empty and clean, abandoned in place). There is a 50,000 gallon tank of
acetic anhydride, a 50,000 gallon tank of acetic acid, a 30,000 gallon tank of triethylene glycol, a
30,000 gallon tank of spent glycol, and a 10,000 gallon tank of ethylene glycol. These are in
stainless steel tanks in a diked area. The hazardous and non-hazardous are currently has sodium
hydroxide 300 and corrosion inhibitor for the process water tank. There is also a waste holding
pad in the south.
Page 1 of 10

Per information in the permit file history, this facility manufactures semicrystalline "engineering resins".
These are such materials as acetal copolymers, liquid crystal polymers, long-fiber reinforced
thermoplastics and ultra-high molecular weight polyethylene.
• Vectra® LCP: A liquid crystal polymer.
• Polyester products: Celanex® PBT, Impet®PET, Vandaa Polyester Alloys and Riteflex®
Polyester Elastomer
• Compounds of Vectra® and polyester products (such as fiberglass compounds)
Per information in the permit file history, the polyester polymer unit and supporting utilities were shut
down in 2010 and the following industrial activities were removed:
• All railroad loading/unloading activity.
• All storage tanks associated with the Polymer business were decommissioned, decontaminated
and materials disposal of with outside waste management companies.
• Eliminated truck shipments and deliveries of raw materials used in the Polymer Unit and
coproducts produced by the Polymer unit.
• Closed the South Tank Farm, Polymer Building North Tank Farm, DMT Tank Farm, Dowtherm
system, and 90% of the North Tank Farm. One tank containing ethylene glycol was still in
service in the North Tank Farm.
• The Polymer Building was cleared of all chemicals used in the process (includes process tanks,
piping,pumps, drains, and ventilation).
• All maintenance activity ceased on decommission/closed outside equipment associated with the
Polymer Unit.
Outfall SWOOI: East
Drainage area consists of loading and unloading activities, Marley cooling tower, 300 gallons of caustic,
120 gallons of boiler treatment, 120 gallons of oxygen scavenger, 120 gallons of corrosion inhibitor, 120
gallon of bromine, 120 gallons of biocide, and 120 gallons of cooling tower treatment, decommissioned
tank farm and unloading station, decommissioned south tank farm, decommissioned railcar unloading
station, and north tank farm.
Outfall SW002: North
Drainage area consists of industrial waste dumpsters, covered storage area, cardboard and scrap metal
recycling, brown and root scrap yard, oil and chemical storage, emergency firewater basin, HOA
secondary containment basin, a cooling tower, and two (2) 5,000 gallons storage tanks of Therminol 66.
Outfall SW003: South
Drainage area consists of scrap metal dumpsters, hazardous waste storage, fuel oil tank storage, solid
waste dumpsters, potable water(used for process water in industrial activities), propane refueling, a#6
closed in place AST, a gasoline and diesel unloading/loading station, hazardous and non-hazardous
storage (sodium hydroxide 300 and corrosion inhibitor for the process water tank), an abandoned
cooling tower tank farm, one (1) 50,000 gallon tank of acetic anhydride, one (1) 50,000 gallon tank of
acetic acid, one (1) 30,000 gallon tank of triethylene glycol, one (1) 30,000 gallon tank of spent glycol,
one (1) 10,000 gallon tank of ethylene glycol, and a waste holding pad.
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
Page 2 of 10

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:
• November 2018 to June 2023, benchmarks exceeded for:
o North: COD Ix
• Annual samples for 2019, 2020, 2021, and 2022 were provided for numerous other chemicals
(see attachment in permit application).
• Permit renewal application(Table B of the application)provided parameters monitored for as
part of the facility's wastewater permit NC0004952, however, these are not expected to be
present in the stormwater discharge
• Per the November 2023 inspection report:
o Facility records were not well organized. The version of the SWPPP provided during the
inspection had not been reviewed within the last year and training records were not
available. After the inspection, permittee provided a more recent version of the plan that
had been reviewed within the last year and training records were provided shortly after
the inspection by email.
o The facility is conducting analytical monitoring and qualitative monitoring. However,
better follow up is needed for potential issues identified in the qualitative monitoring.
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for November 2018 to June 2023. Quantitative sampling included pH, TSS, BOD, and COD.
Annual samples for 2019, 2020, 2021, and 2022 were provided for numerous other chemicals (see
attachment in permit application).
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 CNA Holdings— Shelby site.
Page 3 of 10

Outfalls SWO01 (EAST) and SWO03 (SOTH)
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
Outfall SWO02 NRTH
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BM? effectiveness
(TSS) indicator.
Quarterly monitoring
H BASIS: Pollutant indicator and important to interpreting toxicity potential
p of metals.
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
Page 4 of 10

Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Copper BASIS: Discharge potential indicator due to scrap metal storage
Quarterly monitoring
Total Lead BASIS: Discharge potential indicator due to scrap metal storage
Quarterly monitoring
Total Zinc BASIS: Discharge potential indicator due to scrap metal storage
Quarterly monitoring
Total Hardness BASIS: Monitoring for hardness dependent metals required
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
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:
Page 5 of 10

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
Copper Total 10 µg/L Acute Aquatic Criterion, '/2 FAV
Lead Total 75 /L Acute Aquatic Criterion, '/2 FAV
Zinc (Total) 126 µg/L Acute Aquatic Criterion, '/2 FAV
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.
• 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-
Page 6 of 10

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
• Feasibility study requirement removed per updated stormwater program requirements
• eDMR requirement added
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Outfall-specific monitoring been implemented to reflect industrial activity and potential
pollutants specific to each discharge area
• Monitoring for total copper, total lead, and total zinc added for outfall SWO02 due to storage of
scrap metals outdoors
• Monitoring for total hardness added for outfalls where monitoring for hardness dependent metals
is required
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• Regulatory citations have been added
• Annual online SWPPP certification removed from Part B
o Mistakenly included in draft permit
• Outfall descriptions for SW001 (EAST) and SWO03 (SOTH)have been updated
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 9/22/2023
• Initial contact with Regional Office: 9/22/2023
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 1/4/2024
• Final permit sent for supervisor signature:
Page 7 of 10

Section 7. Comments received on draft permit:
• Melissa Bamford (Trinity Consultants on behalf of permittee; via email 2/2/2024):
o Update outfall IDs as follows in Table 1 title and outfall description to be consistent with
Permit Summary information:
■ East outfall ID changed from "SW001"to "EAST"
■ South outfall ID changed from"SW003"to "SOTH"
■ DEMLR response: Outfalls must be assigned a numeric value in order for NC
DEQ to transfer monitoring data from the state's database to the US EPA's
database. The outfall denotation provided during the renewal process is still
included in the permit to ensure clarity in reporting monitoring data for the correct
outfall.
o Add the following footnote to the Non-polar oil & grease monitoring line item to clarify
that monitoring is only required in vehicle or equipment maintenance areas with>55
gallons/month of oil: "Monitoring for Non-Polar Oil & Grease is only required in vehicle
or equipment maintenance areas in which more than 55 gallons of new motor oil and/or
hydraulic oil per month is used when averaged over the calendar year."
■ DEMLR response: Monitoring for non-polar oil and grease is no longer required
in only vehicle maintenance areas. This is a programmatic update. If more than 55
gallons (averaged) of oil are used per month, whether it's used for vehicle
maintenance, equipment maintenance, or other usage, monitoring is required.
o Update outfall descriptions under Table 1 (Page 14) as follows:
■ Outfall SW001 EAST (East): Drainage area consists of loading and unloading
activities, Marley cooling tower, 300 gallons of caustic, 120 gallons of boiler
treatment, 120 gallons of oxygen scavenger, 120 gallons of corrosion inhibitor,
120 gallon of bromine, 120 gallons of biocide, and 120 gallons of cooling tower
treatment, decommissioned tank farm and unloading station, decommissioned
south tank farm, decommissioned railcar unloading station, and north tank farm
consisting of one (1) 50,000 gallon tank of acetic anhydride, one (1) 50,000 gallon
tank of acetic acid, one (1) 30,000 gallon tank of trieth, leene glycol, one 1)
30,000 gallon tank of spent glycol, one (1) 10,000 gallon tank of ethyleneglycol.
■ Outfall SWO03 SOTH (South): Drainage area consists of scrap metal dumpsters,
hazardous waste storage, fuel oil tank storage, solid waste dumpsters,potable
water for processes, propane refueling, a#6 closed in place AST, a gasoline and
diesel unloading/loading station, hazardous and non-hazardous storage (sodium
hydroxide 300 and corrosion inhibitor for the process water tank), an abandoned
cooling tower tank farm, ,
50,000 gallon tank facet;,. aeid, e ( ) 30,000 gallon tank ftFiethyle„e gi,,eo
> >
glyeol, and a waste holding pad.
■ DEMLR response: Based on updated information provided on the draft permit,
the outfall descriptions have been updated.
o Update North outfall ID as follows in Table 2 title and outfall description to be consistent
with Permit Summary information:
■ North outfall ID changed from"SW002"to "NRTH"
■ DEMLR response: Outfalls must be assigned a numeric value in order for NC
DEQ to transfer monitoring data from the state's database to the US EPA's
database. The outfall denotation provided by the permittee is still included in the
permit to ensure clarity in reporting monitoring data for the correct outfall.
Page 8 of 10

o Add the following footnote to the Non-polar oil & grease monitoring line item to clarify
that monitoring is only required in vehicle or equipment maintenance areas with>55
gallons/month of oil: "Monitoring for Non-Polar Oil & Grease is only required in vehicle
or equipment maintenance areas in which more than 55 gallons of new motor oil and/or
hydraulic oil per month is used when averaged over the calendar year."
■ DEMLR response: Monitoring for non-polar oil and grease is no longer required
in only vehicle maintenance areas. This is a programmatic update. If more than 55
gallons (averaged) of oil are used per month, whether it's used for vehicle
maintenance, equipment maintenance, or other usage, monitoring is required.
o Update outfall description under Table 2 (page 15) as follows:
■ Outfall SWO02 NRTH (North): Drainage area consists of industrial waste
dumpsters, covered storage area, cardboard recycling,and covered scrap metal
recycling, brown and root scrap yard, oil and chemical storage, emergency
firewater basin, HOA secondary containment basin, a cooling tower, and two (2)
5,000 gallons storage tanks of Therminol 66.
• Note: See below regarding the requested addition of"covered" for scrap
metal recycling in the above bullet.
■ DEMLR response: Celanese is welcome to request a permit modification in the
future at such a time site conditions are changed. A site inspection by DEMLR
regional office staff will be required to confirm any changes made to the site that
will affect monitoring requirements. Until such a site change is made, monitoring
for metals and hardness will remain in the permit.
o Hardness and metals sampling requirement:
■ The metals (Total Copper, Total Lead, Total Zinc) and hardness benchmarks were
added to the North Outfall (SW002 or NRTH) due to the storage of scrap metal.
The scrap metal storage is contained in a dumpster at location#4 on the current
site map, which is currently uncovered.
■ Celanese proposes adding a cover to the scrap metal storage dumpster such that
the storage area is no longer exposed to stormwater and removing metals (copper,
lead, zinc) and hardness sampling requirements from Table 2 in the draft permit.
■ DEMLR response: Celanese is welcome to request a permit modification in the
future at such a time site conditions are changed. A site inspection by DEMLR
regional office staff will be required to confirm any changes made to the site that
will affect monitoring requirements. Until such a site change is made, monitoring
for metals and hardness will remain in the permit.
o The area at the North Outfall location is currently under construction under an approved
Erosion and Sediment Control Plan. Following completion of the construction, the
location of the north outfall is expected to be moved slightly from the current designated
location. The new outfall location will be selected to ensure the location will still capture
the full north drainage area as required and is not expected to change potential pollutants
in the North Outfall runoff. The construction is expected to be completed in the spring of
2024.
■ Celanese will notify NC DEQ within 14 days of establishing the new outfall
location, as required under Condition D-2. Until that time, Celanese will continue
to follow the Erosion and Sediment Control Plan.
■ If the current construction is not completed prior to the next required sampling
event, Celanese is seeking clarification regarding whether the quarterly
benchmark sampling is expected be completed under permit NCS000064.
Page 9 of 10

■ DEMLR response: In the event of a discharge, a sample is required to be
collected regardless of where the outfall is located.
o If the newly issued permit is effective prior to the start of the second quarter(April 1,
2024), Celanese is seeking clarification on the timing for the first quarterly sample under
the newly issued permit, if the expectation will be that a sample will be required to be
completed during the 1 st quarter of 2024, with a shortened timeframe within which to
complete the sampling.
■ DEMLR response: Per Part E-1. of the permit, "For permits issued between
March 1-31, June 1-30, September 1-30 or December 1-31, sampling shall not
commence until the next sampling period following initial issuance of the
permit."
Page 10 of 10

LOCALiQ
StarNews I The Dispatch I Times-News PO Box 631697 Cincinnati, OH 45263-1697
Sun Journal I The Daily News I The Star
The Free Press I Gaston Gazette
NORTH CAROLINA ENVI-
PROOF OF PUBLICATION RONMENTAL MANAGE-
MENT COMMISSION
INTENT TO ISSUE
Joyce Sanford NPDES STORMWATER
Brianna Young ThelNorth Carolina PERMITS
Demlr mental Management
1612 Mail Service CTR Commission proposes to
Issue NPDES stormwater
Raleigh NC 27699-1600 discharge permit(s) to the
person(s) listed below.
Public comment or abiection
to the draft Permits is
STATE OF NORTH CAROLINA,COUNTY OF CLEVELAND invited. Written comments
regarding the Proposed
Permit will be accepted until
The Star,a newspaper printed and published in the city of Shelby, 30 days after the publish date
of this notice and considered
-- and of general circulation in the County of Cleveland,State of to the final determination -- --
North Carolina,and personal knowledge of the facts herein state regarding Permit issuance
and that the notice hereto annexed was Published in said and permit provisions. The
Director of the NC Division
newspapers in the issue dated: of Energy, Mineral, and
Land Resources (DEMLR)
may hold a public hearing
01/11/2024 should there be a significant
degree of Public interest.
Please mail comments
and that the fees charged are legal. and/or information requests
Sworn to and subscribed before on 01/11/2024 to DEMLR at 1612 Mail
Service Center, Raleigh, NC
27699-1612.
• CNA Holdings, LLC (2525
Blacksburg Road, Grover,
NC 280731 has requested
renewal of Permit NCS000064
for the CNA Holdings, LLC-
Sheiby facility in Cleveland
County. This facility
discharges to unnamed tribu-
tary to Buffalo Creek In the
Broad River Basin.
Interested persons may visit
DEMLR at 512 N. Salisbury
Street, Raleigh, NC 27604 to
review information on file.
Legal Clerk Additional Information on
NPDES Permits and this
notice may be found on our
website:
Notary,State of WI,County of Brown https://deq.nc.gov/about/divis
)ons/energy-mineral-and.
1 land-resources/stormwa.
ter/starmwater-
My commision expires program/stormwater-public-
notices, or by contacting
Publication Cost: $91.50 Br)anna Young at
brionno.young®deq.nc.gov or
Order No: 9719075 #Of Copies: 1/ 3 11/24 9719075
Customer No: 929332 1
PO#: NCS000064 ` H
H
THIS IS NOT AN INVOICE! o -'
Please do not use this farm for payment remittance. Z _
KATHLEEN ALLEN
Notary PubliC
State, Of VVisconSirl
Page 1 of 1

Young, Brianna A
From: Melissa Bamford <[e-mail]>
Sent: Friday, February 2, 2024 8:05 AM
To: Young, Brianna A; [e-mail]
Cc: Johnson, Ericl, Celanese;Turner, Randall, Celanese
Subject: [External] RE: CNA Holdings, LLC - Shelby draft stormwater permit NCS000064
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
I have worked with Celanese to review the draft permit. We are submitting the following comments on the draft permit
following our review.
Please let me know if we need to discuss any of these items further.
1. Requested text corrections:
o Page 14:
■ Update outfall IDs as follows in Table 1 title and outfall description to be consistent with Permit
Summary information:
• East outfall ID changed from "SW001"to "EAST"
• South outfall ID changed from "SW003"to "SOTH"
■ Add the following footnote to the Non-polar oil &grease monitoring line item to clarify that
monitoring is only required in vehicle or equipment maintenance areas with >55 gallons/month
of oil:
• Monitoring for Non-Polar Oil & Grease is only required in vehicle or equipment
maintenance areas in which more than 55 gallons of new motor oil and/or hydraulic oil
per month is used when averaged over the calendar year.
■ Update outfall descriptions under Table 1 (Page 14) as follows,with added text in bold underline
and removed text in strikethrough below:
• Outfall SW001-EAST (East): Drainage area consists of loading and unloading activities,
Marley cooling tower, 300 gallons of caustic, 120 gallons of boiler treatment, 120 gallons
of oxygen scavenger, 120 gallons of corrosion inhibitor, 120 gallon of bromine, 120
gallons of biocide, and 120 gallons of cooling tower treatment, decommissioned tank
farm and unloading station, decommissioned south tank farm, decommissioned railcar
unloading station, and north tank farm consisting of one(1)50,000 gallon tank of acetic
anhydride, one(1) 50,000 gallon tank of acetic acid,one(1)30,000 gallon tank of
triethylene glycol,one(1)30,000 gallon tank of spent glycol,one(1) 10,000 gallon
tank of ethylene glycol.
• Outfall SIB SOTH (South): Drainage area consists of scrap metal dumpsters,
hazardous waste storage, fuel oil tank storage, solid waste dumpsters, potable water for
processes, propane refueling, a #6 closed in place AST, a gasoline and diesel
unloading/loading station, hazardous and non-hazardous storage (sodium hydroxide
300 and corrosion inhibitor for the process water tank), an abandoned cooling tower
tank farm, eneT150,000 gallen ace#s anhydride one (1) 50,000 gall en rani, Aacetic aeid, ene (1) 30,000 gallen tank ef tFiethylene glyeal, ene (1) 30,000 gallen tank Af
spent ,.l. eel ene (1) 10,000 gallon tank of ethylene glyc,4, and a waste holding pad.
o Page 15:
1

■ Update North outfall ID as follows in Table 2 title and outfall description to be consistent with
Permit Summary information:
• North outfall ID changed from "SW002"to "NRTH"
■ Add the following footnote to the Non-polar oil &grease monitoring line item to clarify that
monitoring is only required in vehicle or equipment maintenance areas with >55 gallons/month
of oil:
• Monitoring for Non-Polar Oil & Grease is only required in vehicle or equipment
maintenance areas in which more than 55 gallons of new motor oil and/or hydraulic oil
per month is used when averaged over the calendar year.
■ Update outfall description under Table 2 (page 15) as follows:
• Outfall SW002 NRTH (North): Drainage area consists of industrial waste dumpsters,
covered storage area, cardboard recycling,a-n4 covered scrap metal recycling, brown
and root scrap yard, oil and chemical storage, emergency firewater basin, HOA
secondary containment basin, a cooling tower, and two (2) 5,000 gallons storage tanks
of Therminol 66.
o Note: see Item #2 below regarding the requested addition of"covered"for
scrap metal recycling in the above bullet.
2. Hardness and metals sampling requirement:
o The metals (Total Copper,Total Lead,Total Zinc) and hardness benchmarks were added to the North
Outfall (SW002 or NRTH) due to the storage of scrap metal.The scrap metal storage is contained in a
dumpster at location #4 on the current site map, which is currently uncovered.
o Celanese proposes adding a cover to the scrap metal storage dumpster such that the storage area is no
longer exposed to stormwater and removing metals (copper, lead, zinc) and hardness sampling
requirements from Table 2 in the draft permit.
Also, Celanese is seeking clarification on the following:
3. The area at the North Outfall location is currently under construction under an approved Erosion and Sediment
Control Plan. Following completion of the construction,the location of the north outfall is expected to be moved
slightly from the current designated location.The new outfall location will be selected to ensure the location will
still capture the full north drainage area as required and is not expected to change potential pollutants in the
North Outfall runoff.The construction is expected to be completed in the spring of 2024.
o Celanese will notify NC DEQ within 14 days of establishing the new outfall location, as required under
Condition D-2. Until that time, Celanese will continue to follow the Erosion and Sediment Control Plan.
o If the current construction is not completed prior to the next required sampling event, Celanese is
seeking clarification regarding whether the quarterly benchmark sampling is expected be completed
under permit NCS000064.
4. If the newly issued permit is effective prior to the start of the second quarter(April 1, 2024), Celanese is seeking
clarification on the timing for the first quarterly sample under the newly issued permit, if the expectation will be
that a sample will be required to be completed during the 1"quarter of 2024,with a shortened timeframe
within which to complete the sampling.
Also, next week is Eric Johnson's last week with Celanese so please continue to keep myself and Larry Wolnick copied on
all communications.
Thank youl
Melissa
2

Melissa Bamford (she/her)
Senior Consultant
Mobile(Primary): 585.329.1367
Office: 704.553.7747 x3458
Email: mbamfordCa)trinityconsultants.com
325 Arlington Ave., Suite 500, Charlotte, North Carolina 28203
Trinity �
Consultants
Connect with us: LinkedIn/ Facebook/Twitter/YouTube/trinityconsultants.com
Stay current on EHS issues. Subscribe today to receive Trinity's free EHS Quarter/y.
From:Young, Brianna A<[e-mail]>
Sent:Thursday,January 4, 2024 8:24 AM
To: [e-mail]
Cc:Johnson, Eric1, Celanese<[e-mail]>; Melissa Bamford <M Bamford @trinityconsultants.com>;
Turner, Randall, Celanese <[e-mail]>
Subject: CNA Holdings, LLC-Shelby draft stormwater permit NCS000064
Good morning,
Please find attached a copy of the draft stormwater permit for CNA Holdings, LLC(NCS000064).A hard copy of this draft
permit will be mailed to Lawrence Wolnik. Please provide any comments by February 41n
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
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.
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.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
3

ROY COOPER
Governor
ELIZABETH S.BISER '
Secretary ►�
WILLIAM E.TOBY VINSON,JR. NORTH CAROB INN
Interim Director Ei¢YrtVA#W
WdQUaW
December 19, 2023
CNA Holdings, Inc.
Attn: Lawrence Wolnik, Site Director
2525 Blacksburg Road
Grover,North Carolina 28073
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater Permit NCS000064
CNA Holdings,Inc.
Cleveland County
Dear Mr. Wolnik:
On November 30, 2023, a site inspection was conducted for the CNA Holdings, Inc. facility located at 2525
Blacksburg Road, Grover, Cleveland County,North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. Eric Johnson and Randy Turner were also present during the inspection and their
time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is
covered by Individual NPDES Stormwater Permit NCS000064. Permit coverage authorizes the discharge of
stormwater from the facility to receiving waters designated as Buffalo Creek, class C waters in the Broad
River Basin.
As a result of the inspection, the facility was found to be compliant with the conditions of the NCS000064
permit. Please refer to the enclosed Compliance Inspection Report for additional comments and observations
made during the inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil
penalty assessment of up to $25,000 per day for each violation. If you or your staff have any questions,
comments, or need assistance with understanding any aspect of your permit, please contact me at
[phone] or via e-mail at [e-mail].
Sincerely,
DocuSigned by:
4A35D6802B02438...
Jerry W. Eplin, PE
Assistant Regional Engineer
DEMLR
Enclosure: Compliance Inspection Report
c: Eric Johnson, Environmental Manager, CNA Holdings, Inc.,2525 Blacksburg Rd, Grover,NC 28073
DEMLR NPDES Stormwater Permit Laserfiche File
North Carolina Department of Environmental Quality I Division of Energy,Mineral,and Land Resources
Mooresville Regional Office 1 610 East Center Avenue,Suite 3011 Mooresville,North Carolina 28115
704-663-1699

Compliance Inspection Report
Permit:NCS000064 Effective: 04/09/18 Expiration: 03/31/23 owner: C N A Holdings LLC
SOC: Effective: Expiration: Facility: Celanese Shelby Facility
County: Cleveland 2525 Blacksburg Rd
Region: Mooresville
Grover NC 28073
Contact Person:Lawrence Wolnik Title: Phone:[phone]
Directions to Facility:
Take 1-85 towards Spartanburg,take exit 2 NC-216 toward Kings Mtn. Park,Turn Right onto Battleground Road (NC-216),turn Left
onto S. Battleground Ave, right onto Carolina Ave(becomes Cleveland Ave), Left onto Lavendar Rd, Right onto Blacksburg Rd.
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 11/30/2023 Entry Time 01:OOPM Exit Time: 03:OOPM
Primary Inspector:Jerry W Eplin Phone: [phone]
Secondary Inspector(s):
Kathryn S Peterson
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: 0 Compliant Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000064 Owner-Facility:C N A Holdings LLC
Inspection Date: 11/30/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On November 30, 2023, a compliance evaluation inspection was completed by Jerry Eplin and Kathryn Peterson of DEQ.
Eric Johnson and Randy Turner from CNA Holdings were present for the inspection.
Facility records were not well organized. The version of the SWPPP provided during the inspection had not been reviewed
within the last year. After the inspection, Mr. Johnson provided a more recent version of the plan that had been reviewed
within the last year. Likewise, training records were not available on site, but were provided shortly after the inspection by
email.
The facility is conducting analytical monitoring and qualitative monitoring. However, better follow up is needed for potential
issues identified in the qualitative monitoring. Records indicating a light odor and indicating poor clarity were present in the
qualitative monitoring, without documented follow up actions. When a potential issue is identified via qualitative monitoring,
follow up actions should be well documented and should be maintained with the SWPPP.
The stormwater outfalls were observed during the inspection and no issues were identified. Construction was occuring near
one outfall under an approved Erosion and Sediment Control Plan.
Page 2 of 3

Permit: NCS000064 Owner-Facility:C N A Holdings LLC
Inspection Date: 11/30/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? 0 ❑ ❑ ❑
#Does the Plan include a General Location (USGS)map? 0 ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? 0 ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment? 0 ❑ ❑ ❑
# Does the Plan include a BMP summary? 0 ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
# Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)? M ❑ ❑ ❑
# Is the Plan reviewed and updated annually? M ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment: Organization of records should be improved. The version of the SWPPP reviewed on-site had
not been updated within the past year. After the inspection, the permittee provided
documentation that a newer SWPPP exists and provided a copy. Training records were not
available during the inspection, but were provided after the inspection.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? M ❑ ❑ ❑
Comment: Follow up to qualitative monitoring needs to be improved. When Qualitative Monitoring
indicates a potential issue, documentation of the facility responded is required and should be
kept with the SWPPP. Qualitative monitoring records indicating a light odor and indicating
clarity levels of 3 and 4 were observed without documented follow up actions.
Analytical Monitorinq Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑
Comment:
Permit and Outfalis Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#Were all outfalls observed during the inspection? M ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3

Young, Brianna A
From: Melissa Bamford <[e-mail]>
Sent: Tuesday, February 13, 2024 9:52 AM
To: Young, Brianna A; Wolnik, Lawrence, Celanese
Cc: Turner, Randall, Celanese
Subject: RE: [External] RE: CNA Holdings, LLC - Shelby draft stormwater permit NCS000064
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
Sorry about the confusion there!
The September 27, 2023 description was in error regarding these tanks.The following five tanks in question are
located at the "North Tank Farm"which is indicated by a red circled "5" in the facility drawing that was provided
(see snippet below the text response in this e-mail):
- 50,000 gallon tank of acetic anhydride
- 50,000 gallon tank of acetic acid
- 30,000 gallon tank of triethylene glycol
- 30,000 gallon tank of spent glycol
- 10,000 gallon tank of ethylene glycol
The North Tank Farm is located in the East Outfall drainage area, so the comments in the February 2, 2024 e-mail
were accurate.
also wanted to point out an a-mail error for Mr.Wolnik. His correct a-mail address is
[e-mail], as is copied on this e-mail. Please let us know if you need anything additional to
process that e-mail change on your end.
Please let us know if you have any additional questions as you complete your review.
Thanks!
Melissa
1

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Melissa Bamford (she/her)
Senior Consultant
Mobile(Primary): 585.329.1367
Office: 704.553.7747 x3458
Email: mbamfordCa)trinityconsultants.com
325 Arlington Ave., Suite 500, Charlotte, North Carolina 28203
Trinity
ConsuLtants ��
Connect with us: LinkedIn/ Facebook/Twitter/YouTube/trinityconsultants.com
Stay current on EHS issues. Subscribe today to receive Trinity's free EHS Quarterly.
From:Young, Brianna A<[e-mail]>
Sent: Monday, February 12, 2024 11:22 AM
To: Melissa Bamford <M Bamford @trinityconsultants.com>; [e-mail]
Cc:Johnson, Eric1, Celanese<[e-mail]>;Turner, Randall, Celanese<[e-mail]>
Subject: RE: [External] RE: CNA Holdings, LLC-Shelby draft stormwater permit NCS000064
Good morning Melissa,
I have a question on one of your comments.You wish to change the outfall descriptions moving(1) 50,000 gallon tank of
acetic anhydride, one (1) 50,000 gallon tank of acetic acid, one (1) 30,000 gallon tank of triethylene glycol, one (1)
30,000 gallon tank of spent glycol, one (1) 10,000 gallon tank of ethylene glycol from the South to the East outfall. On
September 27, 2023,the attached description was provided by Eric Johnson in response to an additional information
request in which the identified items were listed under the South outfall. Please confirm which discharge area these
items are in.
2

Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
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.
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.
From: Melissa Bamford <[e-mail]>
Sent: Friday, February 2, 2024 8:05 AM
To:Young, Brianna A<[e-mail]>; [e-mail]
Cc:Johnson, Eric1, Celanese<[e-mail]>;Turner, Randall, Celanese<[e-mail]>
Subject: [External] RE: CNA Holdings, LLC-Shelby draft stormwater permit NCS000064
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
I have worked with Celanese to review the draft permit. We are submitting the following comments on the draft permit
following our review.
Please let me know if we need to discuss any of these items further.
1. Requested text corrections:
o Page 14:
■ Update outfall IDs as follows in Table 1 title and outfall description to be consistent with Permit
Summary information:
• East outfall ID changed from "SW001"to "EAST"
• South outfall ID changed from "SW003"to "SOTH"
■ Add the following footnote to the Non-polar oil &grease monitoring line item to clarify that
monitoring is only required in vehicle or equipment maintenance areas with >55 gallons/month
of oil:
• Monitoring for Non-Polar Oil & Grease is only required in vehicle or equipment
maintenance areas in which more than 55 gallons of new motor oil and/or hydraulic oil
per month is used when averaged over the calendar year.
■ Update outfall descriptions under Table 1 (Page 14) as follows,with added text in bold underline
and removed text in strikethrough below:
• Outfall SW001 EAST (East): Drainage area consists of loading and unloading activities,
Marley cooling tower, 300 gallons of caustic, 120 gallons of boiler treatment, 120 gallons
of oxygen scavenger, 120 gallons of corrosion inhibitor, 120 gallon of bromine, 120
gallons of biocide, and 120 gallons of cooling tower treatment, decommissioned tank
3

farm and unloading station, decommissioned south tank farm, decommissioned railcar
unloading station, and north tank farm consisting of one(1) 50,000 gallon tank of acetic
anhydride, one (1) 50,000 gallon tank of acetic acid,one(1)30,000 gallon tank of
triethylene glycol,one (1) 30,000 gallon tank of spent glycol,one(1) 10,000 gallon
tank of ethylene glycol.
• Outfall SWQQ3 SOTH (South): Drainage area consists of scrap metal dumpsters,
hazardous waste storage, fuel oil tank storage, solid waste dumpsters, potable water for
processes, propane refueling, a#6 closed in place AST, a gasoline and diesel
unloading/loading station, hazardous and non-hazardous storage (sodium hydroxide
300 and corrosion inhibitor for the process water tank), an abandoned cooling tower
tank farm,ene (1) 58;000gallen tank ef aee#s-aRhYdFide e ( ) 50,000.ghee tank f
speRt .,l. cel ene ( ) 10,000 nnn gaII9R tank f ethylene l.,ee and a waste holding pad.
o Page 15:
■ Update North outfall ID as follows in Table 2 title and outfall description to be consistent with
Permit Summary information:
• North outfall ID changed from "SW002"to "NRTH"
■ Add the following footnote to the Non-polar oil &grease monitoring line item to clarify that
monitoring is only required in vehicle or equipment maintenance areas with >55 gallons/month
of oil:
• Monitoring for Non-Polar Oil & Grease is only required in vehicle or equipment
maintenance areas in which more than 55 gallons of new motor oil and/or hydraulic oil
per month is used when averaged over the calendar year.
■ Update outfall description under Table 2 (page 15) as follows:
• Outfall SWQQ2 NRTH (North): Drainage area consists of industrial waste dumpsters,
covered storage area, cardboard recycling,a-n4 covered scrap metal recycling, brown
and root scrap yard, oil and chemical storage, emergency firewater basin, HOA
secondary containment basin, a cooling tower, and two (2) 5,000 gallons storage tanks
of Therminol 66.
o Note: see Item#2 below regarding the requested addition of"covered"for
scrap metal recycling in the above bullet.
2. Hardness and metals sampling requirement:
o The metals (Total Copper,Total Lead,Total Zinc) and hardness benchmarks were added to the North
Outfall (SW002 or NRTH) due to the storage of scrap metal.The scrap metal storage is contained in a
dumpster at location #4 on the current site map, which is currently uncovered.
o Celanese proposes adding a cover to the scrap metal storage dumpster such that the storage area is no
longer exposed to stormwater and removing metals (copper, lead, zinc) and hardness sampling
requirements from Table 2 in the draft permit.
Also, Celanese is seeking clarification on the following:
3. The area at the North Outfall location is currently under construction under an approved Erosion and Sediment
Control Plan. Following completion of the construction,the location of the north outfall is expected to be moved
slightly from the current designated location.The new outfall location will be selected to ensure the location will
still capture the full north drainage area as required and is not expected to change potential pollutants in the
North Outfall runoff.The construction is expected to be completed in the spring of 2024.
o Celanese will notify NC DEQ within 14 days of establishing the new outfall location, as required under
Condition D-2. Until that time, Celanese will continue to follow the Erosion and Sediment Control Plan.
4

o If the current construction is not completed prior to the next required sampling event, Celanese is
seeking clarification regarding whether the quarterly benchmark sampling is expected be completed
under permit NCS000064.
4. If the newly issued permit is effective prior to the start of the second quarter(April 1, 2024), Celanese is seeking
clarification on the timing for the first quarterly sample under the newly issued permit, if the expectation will be
that a sample will be required to be completed during the Vt quarter of 2024,with a shortened timeframe
within which to complete the sampling.
Also, next week is Eric Johnson's last week with Celanese so please continue to keep myself and Larry Wolnick copied on
all communications.
Thank youl
Melissa
Melissa Bamford (she/her)
Senior Consultant
Mobile(Primary): 585.329.1367
Office: 704.553.7747 x3458
Email: mbamfordCa)trinityconsultants.com
325 Arlington Ave., Suite 500, Charlotte, North Carolina 28203
Trinity �
Consultants
Connect with us: LinkedIn/ Facebook/Twitter/YouTube/trinityconsultants.com
Stay current on EHS issues. Subscribe today to receive Trinity's free EHS Quarterly.
From:Young, Brianna A<[e-mail]>
Sent:Thursday,January 4, 2024 8:24 AM
To: [e-mail]
Cc:Johnson, Eric1, Celanese<[e-mail]>; Melissa Bamford <[e-mail]>;
Turner, Randall, Celanese<[e-mail]>
Subject: CNA Holdings, LLC-Shelby draft stormwater permit NCS000064
Good morning,
Please find attached a copy of the draft stormwater permit for CNA Holdings, LLC(NCS000064).A hard copy of this draft
permit will be mailed to Lawrence Wolnik. Please provide any comments by February 4tn
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
5

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.
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.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
6

Young, Brianna A
From: Johnson, Ericl, Celanese <[e-mail]>
Sent: Tuesday, October 3, 2023 11:01 AM
To: Young, Brianna A
Cc: Turner, Randall, Celanese
Subject: RE: [External] CNA Holdings, LLC Shelby Plant stormwater permit NCS000064
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Yes
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, October 3, 2023 10:59 AM
To:Johnson, Eric1, Celanese<[e-mail]>
Subject: [EXT]RE: [External] CNA Holdings, LLC Shelby Plant stormwater permit NCS000064
CAUTION: External Email
To confirm,the "process water" is water from the County's potable water system that will be used for industrial
processes?
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
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.
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.
From:Johnson, Eric1, Celanese<[e-mail]>
Sent:Tuesday, October 3, 2023 10:54 AM
To:Young, Brianna A<[e-mail]>
Subject: FW: [External] CNA Holdings, LLC Shelby Plant stormwater permit NCS000064
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
See highlighted answer
i

From:Turner, Randall, Celanese<[e-mail]>
Sent:Tuesday, October 3, 2023 9:47 AM
To: Melissa Bamford <[e-mail]>
Cc:Johnson, Eric1, Celanese<[e-mail]>
Subject: RE: [External] CNA Holdings, LLC Shelby Plant stormwater permit NCS000064
#8 has been decommissioned and removed. #9 is for clean process water that is received from the county. No pollutant
present in the process water
Randy Turner
ORC
Wastewater Operations
"_:i Celanese
The chemistry ins«c:nn ova iion'
NO ! Try not! DO or DO NOT, There is no try! YOGA
2525 Blacksburg Rd
Grover, NC 28073
Phone[phone]
Mobile[phone]
[e-mail]
www.celanese.com
The information contained in this e-mail,and any attachments thereto,is confidential and is intended only for use by the individual(s)and/or entity named above.If you are not the intended recipient of this
e-mail,you are hereby notified that any dissemination,distribution or copying of this communication or any disclosure of the contents of this communication to others
From: Melissa Bamford <[e-mail]>
Sent:Tuesday, October 3, 2023 9:35 AM
To:Johnson, Eric1, Celanese<[e-mail]>
Cc:Turner, Randall, Celanese<[e-mail]>
Subject: [EXT]RE: [External] CNA Holdings, LLC Shelby Plant stormwater permit NCS000064
CAUTION: External Email
Eric/Randy—
Can you answer Brianna's question regarding the water treatment and process water in the south drainage area? I
believe her question is based on the info in the site map-#8 is indicated as the water treatment and#9 is the process
water per the map legend.
Are these water streams expected to have any pollutants present, or are these tanks for"clean" process water and
treatment for that incoming process water?
Melissa
2

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Melissa Bamford he/her)
Senior Consultant
Mobile(Primary): 585.329.1367
Office: 704.553.7747 x3458
Email: [e-mail]
325 Arlington Ave., Suite 500, Charlotte, North Carolina 28203
Tri n it
ConsuLtants
Connect with us: LinkedIn/ Facebook/Twitter/YouTube/trinityconsultants.com
Stay current on EHS issues. Subscribe today to receive Trinity's free EHSQuarterly.
3

From:Young, Brianna A<[e-mail]>
Sent:Tuesday, October 3, 2023 9:26 AM
To:Johnson, Eric1, Celanese<[e-mail]>
Cc: Melissa Bamford<M Bamford @trinityconsultants.com>;Turner, Randall, Celanese<[e-mail]>
Subject: RE: [External] CNA Holdings, LLC Shelby Plant stormwater permit NCS000064
Good morning,
Thank you for submitting this information.After reviewing everything I have a follow-up question:The south drainage
area states there is water treatment and process water in the area. Can you provide more information regarding these
two activities? Is this material stored in the area or have the potential to be in the stormwater discharge?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
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.
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.
From:Johnson, Eric1, Celanese<[e-mail]>
Sent: Wednesday, September 27, 2023 3:21 PM
To:Young, Brianna A<[e-mail]>
Cc: Melissa Bamford<M Bamford @trinityconsultants.com>;Turner, Randall, Celanese<[e-mail]>
Subject: [External] CNA Holdings, LLC Shelby Plant stormwater permit NCS000064
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
Responses to your questions are below in blue text. Please let us know if you need any additional information
during your review.
• Provide an updated site map (the one provided is unclear and hard to read labels/identifications);
An electronic version of the site map that was included in the original application is attached ("4— Site
Map.pdf'). Please let us know if this will work for your review.
• A list of parameters tested for was provided as Table B of the application. Please confirm whether these
parameters have the potential to be present in the stormwater discharge, and more information on why
these parameters were tested for;
4

The pollutants listed in Table B of the application were measured as part of the facility NPDES
wastewater permit NC0004952. These pollutants are not expected to be present in the stormwater
discharges. They were included as part of the response for Item 7.4 in the application. The wastewater
outfall is 001 and is separate from the stormwater outfalls. The wastewater outfall is not on the area
covered by the submitted site map - the outfall is located southeast of the WWT ponds, towards the
green scale indicator on the area map provided.
• Description of industrial activity in each drainage area;
This industrial activity in each drainage area was provided in the attached information for the Section
4.2 response. The page from the original application is attached("Attached information— Section 4.2
Response.pdf').
In addition, the site notes at the top right corner of the map lists out the industrial activity associated
with each area, repeated below:
- South:
o Scrap metal dumpsters
o Hazardous waste storage
o Fuel oil tank storage
o Cooling tower tank farm
o Solid waste dumpsters
o Water treatment
o Process water
o Propane refueling
- East:
o Empty tank farm and unloading station(decommissioned)
o South tank farm(empty, decommissioned)
o Railcar unloading station (decommissioned)
o North Tank Farm(90% empty)
- North:
o Industrial Waste Dumpsters
o Covered Storage
o Scrap Metal
Please let us know if this information is sufficient, or if you need more details on any of the activities listed.
• Description of all chemicals stored onsite;
Chemicals onsite are listed below:
- Acetic Acid
- Acetic Anhydride
- Phenol
- Ethylene Glycol
- Hydroquinone
- Sulfuric Acid
- 1,4-dioxane
- Cobalt Acetate
- Phenanthrene
- Urea Ammonium Nitrate (URAN)
- Magnesium acetate tetrahydrate
- 4,4 Biphenol
- Acetaminophen
- Hostanox P-EPQ P
- Isophthalic acid
5

Potassium Acetate
- Triethylene glycol
An SDS for the Hostanox P-EPQ P material is attached. Let us know if you need any SDSs for the other
chemicals included in this list or if the chemical name listing is sufficient for these chemicals.
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
A spreadsheet is attached summarizing the monitoring data for this permit (Sample Summary Tables
Celanese Shelby_for DEQ.xls). Note that we have added the monitoring data for 2H 2O22 and 1H 2O23
sampling that were not included in the original application.
• Verification that the information in the renewal application is still complete and correct; and
All information in the renewal application is still complete and correct
• An explanation of any operational changes since the renewal application was submitted.
There have been no 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:
All information is correct in the Stormwater Permit Summary Report, except for slight adjustments to the
outfall locations when viewed in Google Earth WGS84 datum. We will send a separate e-mail to Bethany
Georgoulias and copy you to indicate the correct coordinates for the outfalls
Kindest regards,
Eric Johnson
EHS Manager—Shelby
1219 Celanese
The chemistry inride innovation
2525 Blacksburg Road
Grover,NC,USA 28073
Office+1 704-480-5759
Cell [phone]
Eric 1.Johnson(cr�,celanese.com
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
CAUTION:This email originated from outside of the Trinity Consultants organization. Do not click links or open attachments unless
you recognize the sender's name,sender's email address and know the content is safe.
6

Young, Brianna A
From: Johnson, Eric1, Celanese <[e-mail]>
Sent: Wednesday, September 27, 2023 3:21 PM
To: Young, Brianna A
Cc: Melissa Bamford;Turner, Randall, Celanese
Subject: [External] CNA Holdings, LLC Shelby Plant stormwater permit NCS000064
Attachments: 4 - Site Map.pdf, Attached information - Section 4.2 Response.pdf; Sample Summary
Tables-Celanese Shelby_for DEQ.xlsx; Hostanox P EPQ P SDS.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
Responses to your questions are below in blue text. Please let us know if you need any additional information
during your review.
• Provide an updated site map (the one provided is unclear and hard to read labels/identifications);
An electronic version of the site map that was included in the original application is attached ("4— Site
Map.pdf'). Please let us know if this will work for your review.
• A list of parameters tested for was provided as Table B of the application. Please confirm whether these
parameters have the potential to be present in the stormwater discharge, and more information on why
these parameters were tested for;
The pollutants listed in Table B of the application were measured as part of the facility NPDES
wastewater permit NC0004952. These pollutants are not expected to be present in the stormwater
discharges. They were included as part of the response for Item 7.4 in the application. The wastewater
outfall is 001 and is separate from the stormwater outfalls. The wastewater outfall is not on the area
covered by the submitted site map - the outfall is located southeast of the WWT ponds, towards the
green scale indicator on the area map provided.
• Description of industrial activity in each drainage area;
This industrial activity in each drainage area was provided in the attached information for the Section
4.2 response. The page from the original application is attached("Attached information— Section 4.2
Response.pdf').
In addition, the site notes at the top right corner of the map lists out the industrial activity associated
with each area, repeated below:
- South:
o Scrap metal dumpsters
o Hazardous waste storage
o Fuel oil tank storage
o Cooling tower tank farm
o Solid waste dumpsters
o Water treatment
o Process water
o Propane refueling
- East:
o Empty tank farm and unloading station(decommissioned)
o South tank farm(empty, decommissioned)
1

o Railcar unloading station (decommissioned)
o North Tank Farm (90% empty)
- North:
o Industrial Waste Dumpsters
o Covered Storage
o Scrap Metal
Please let us know if this information is sufficient, or if you need more details on any of the activities listed.
• Description of all chemicals stored onsite;
Chemicals onsite are listed below:
- Acetic Acid
- Acetic Anhydride
- Phenol
- Ethylene Glycol
- Hydroquinone
- Sulfuric Acid
- 1,4-dioxane
- Cobalt Acetate
- Phenanthrene
- Urea Ammonium Nitrate (URAN)
- Magnesium acetate tetrahydrate
- 4,4 Biphenol
- Acetaminophen
- Hostanox P-EPQ P
- Isophthalic acid
- Potassium Acetate
- Triethylene glycol
An SDS for the Hostanox P-EPQ P material is attached. Let us know if you need any SDSs for the other
chemicals included in this list or if the chemical name listing is sufficient for these chemicals.
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
A spreadsheet is attached summarizing the monitoring data for this permit (Sample Summary Tables
Celanese Shelby_for DEQ.xls). Note that we have added the monitoring data for 2H 2O22 and 1H 2O23
sampling that were not included in the original application.
• Verification that the information in the renewal application is still complete and correct; and
All information in the renewal application is still complete and correct
• An explanation of any operational changes since the renewal application was submitted.
There have been no 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:
All information is correct in the Stormwater Permit Summary Report, except for slight adjustments to the
outfall locations when viewed in Google Earth WGS84 datum. We will send a separate e-mail to Bethany
Georgoulias and copy you to indicate the correct coordinates for the outfalls
2

Kindest regards,
Eric Johnson
EHS Manager—Shelby
911 Celanese
The chemistry inside innovation
2525 Blacksburg Road
Grover,NC,USA 28073
Office+1 704-480-5759
Cell [phone]
Eric 1.Johnsonkcelanese.com
3

EPA Form 2F — Attached Information
Section 4.2 Response:
Significant materials include: loading and unloading docks, scrap metal storage areas, oil and chemical
tank farm areas, solid waste compactors and dumpsters, recycling areas, wastewater treatment and
hazardous and non-hazardous areas.
The north outfall includes compounding and Vectra waste dumpster roll-offs, cardboard and scrap
metal recycling, brown & root scrap yard, oil &chemical storage with secondary containment,
emergency firewater basin, HOA secondary containment basin and a cooling tower. There are two
storage tanks, 5,000 gallons capacity each, of Therminol 66 which is diked.
The south outfall contains a number 6 empty closed in place AST, a gasoline and diesel
unloading/loading station (under roof), hazardous and non-hazardous storage (under roof), and a
cooling tower tank farm (empty and clean, abandoned in place). There is a 50,000 gallon tank of acetic
anhydride, a 50,000 gallon tank of acetic acid, a 30,000 gallon tank of triethylene glycol, a 30,000
gallon tank of spent glycol, and a 10,000 gallon tank of ethylene glycol. These are in stainless steel
tanks in a diked area. The hazardous and non-hazardous are currently has sodium hydroxide 300 and
corrosion inhibitor for the process water tank. There is also a waste holding pad in the south.
The east outfall includes loading and unloading of raw materials and by/co-products, Marley cooling
tower. The raw materials and by/co products include 300 gallon of caustic, 120 gallon of boiler
treatment, 120 gallon of oxygen scavenger, 120 gallon of corrosion inhibitor, 120 gallon of bromine,
120 gallons of biocide, and 120 gallons of colling tower treatment. These are in totes and stored in the
building.
Approximately 80 gallons of"Roundup" is used each year throughout the plant site on edging, around
cooling towers, transformers, wastewater basins & railroad tracks as a grass and weed killer.
The use of"Ice Melt" is limited to sidewalks and pedestrian walkways when inclement weather
conditions require its use.

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 1
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
SECTION 1. IDENTIFICATION
Identification of the Clariant Plastics & Coatings
company: (Deutschland) GmbH
Frankfurt am Main, 65926
Telephone No.: [phone]
Information of the substance/preparation:
Product Stewardship, [phone]
Emergency tel. number: [phone] CHEMTREC
Trade name: Hostanox P-EPQ P
CAS number: 119345-01-6
Primary product use: Antioxidant
Chemical family: Aryl Phosphonite
SECTION 2. HAZARDS IDENTIFICATION
GHS classification in accordance with 29 CFR 1910.1200
Combustible dust
GHS label elements
Signal word Warning
Hazard statements May form combustible dust concentrations in air.
Precautionary statements
Prevention:
P210 Keep away from heat, hot surfaces, sparks, open flames
and other ignition sources. No smoking.
P243 Take precautionary measures against static discharge.
P233 Keep container tightly closed.
Other hazards
Dust can form an explosive mixture in air.
Does not require a hazard warning label, but the normal safety precautions for handling
chemicals must be observed.
SECTION 3. COMPOSITION/INFORMATION ON INGREDIENTS
Substance/ Mixture Substance
Substance name Aryl Phosphonite
CAS-No. 119345-01-6

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 2
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Hazardous components
This product does not contain any components that require disclosure according to OSHA Hazard
Communication Standard 2012.
SECTION 4. FIRST AID MEASURES
General advice Get medical advice/attention if you feel unwell.
If inhaled Move the victim to fresh air.
Give oxygen or artificial respiration if needed.
Get immediate medical advice/attention.
Never give anything by mouth to an unconscious person.
In case of skin contact Wash thoroughly with soap and water for 15 minutes. If skin
irritation occurs, seek medical attention.
In case of eye contact Flush eyes with water at least 15 minutes. Get medical
attention if eye irritation develops or persists.
If swallowed IF SWALLOWED: Immediately call a POISON
CENTER/doctor.
Most important symptoms The possible symptoms known are those derived from the
and effects, both acute and labelling (see section 2).
delayed No additional symptoms are known.
Notes to physician None known.
SECTION 5. FIREFIGHTING MEASURES
Suitable extinguishing media Foam
Water spray jet
Dry powder
Unsuitable extinguishing High volume water jet
media Carbon dioxide (CO2)
Specific hazards during Carbon oxides
firefighting
Oxides of phosphorus
Further information Cool containers/tanks with water spray.
Exercise caution when fighting any chemical fire. Use NIOSH
approved self-contained breathing apparatus and full
protective clothing.
Special protective equipment Impervious clothing
for firefighters Protective helmets

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 3
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Self-contained breathing apparatus
SECTION 6. ACCIDENTAL RELEASE MEASURES
Personal precautions, Ensure adequate ventilation.
protective equipment and Wearing appropriate personal protective equipment, contain
emergency procedures spill and collect into a suitable container.
Prevent from entering into soil, ditches, sewers, waterways
and/or groundwater.
Environmental precautions The product should not be allowed to enter drains, water
courses or the soil.
Methods and materials for Take up mechanically
containment and cleaning up Avoid dust formation.
Take measures to prevent the build up of electrostatic charge.
Risk of dust explosion.
Treat recovered material as described in the section "Disposal
considerations".
SECTION 7. HANDLING AND STORAGE
Advice on protection against Take precautionary measures against static discharges.
fire and explosion
Avoid dust formation.
Keep away sources of ignition.
Advice on safe handling Avoid dust formation. Keep away from sources of ignition.
Lead off electrostatic charges.
Avoid inhalation, ingestion and contact with skin and eyes.
Wash thoroughly after handling.
Technical Store in original container.
measures/Precautions Keep container tightly closed.
Store in a cool, dry, well-ventilated area.
SECTION 8. EXPOSURE CONTROLS/PERSONAL PROTECTION
Components with workplace control parameters
Contains no substances with occupational exposure limit values.
Engineering measures Use adequate exhaust ventilation and/or dust collection to
keep dust levels below exposure limits.
Personal protective equipment
Respiratory protection Use NIOSH/MSHA approved respirators following
manufacturer's recommendations where dust or fume may be
generated.

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 4
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Hand protection
Remarks Nitrile rubber gloves.
Eye protection Safety glasses or chemical splash goggles.
Skin and body protection Wear suitable protective equipment.
Protective measures Observe the usual precautions for handling chemicals.
Hygiene measures Handle in accordance with good industrial hygiene and safety
practice.
Wash hands before breaks and immediately after handling
the product.
Avoid contact with the skin and the eyes.
SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES
Appearance powder
Colour yellow
Odour not specified
Odour Threshold cannot be determined
pH approx. 8 (20 °C)
Concentration: < 1 mg/I
Method: OECD Test Guideline 105
GLP: yes
saturated aqueous solution
Drop point 100 - 110 °C
Method: 92/69/EEC, A.1.
GLP: yes
Melting range 85- 103 °C
Method: OECD Test Guideline 102
GLP: yes
Boiling point > 280 °C
(1,013 hPa)
Decomposition: yes
Method: OECD Test Guideline 103
GLP: yes
Decomposes below the boiling point.
Flash point Not applicable
Evaporation rate Non-Volatile
Flammability(solid, gas) The product is not flammable.
Method: 92/69/EC (1-383)A.10 *flammability(solids)

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 5
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
GLP: yes
Self-ignition >400 °C
Method: Directive 67/548/EEC, Annex V, A.16
GLP: yes
The substance or mixture is not classified as self heating.
Method: Expert judgement
The substance or mixture is not classified as pyrophoric.
Burning number 2 (20 - 100 °C)
Method: Combustibility test safety laboratory
GLP: no
Short flaring up without spreading
Upper explosion limit/upper not tested.
flammability limit
Lower explosion limit/ Lower not tested.
flammability limit
Vapour pressure < 0.000001 Pa (approx. 25 °C)
Method: OECD Test Guideline 104
GLP: no
Relative vapour density Not applicable
Relative density 1.04 (20 °C, 1,013 hPa)
Method: OECD Test Guideline 109
GLP: yes
Density 1.04 g/cm3 (20 °C)
Method: OECD Test Guideline 109
GLP: yes
Bulk density 530 kg/m3 (20 °C)
Solubility(ies)
Water solubility < 1 mg/I ( 20 °C, approx. 1,013 hPa)
pH: 8
Method: OECD Test Guideline 105
GLP: yes
Solubility in other solvents not tested.
Solvent: fat
Partition coefficient: n- log Pow: > 6 (25 °C)
octanol/water Method: OECD Test Guideline 117
GLP: yes
Auto-ignition temperature Not applicable
Decomposition temperature > 500 °C

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 6
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Heating rate: 3 K/min
Method: OECD Test Guideline 113
Viscosity
Viscosity, dynamic 3,270 mPa.s (130 °C)
386 mPa.s (150 °C)
Viscosity, kinematic Not applicable
Explosive properties Not explosive
Not explosive
Method: Directive 84/449/EEC, A.14
GLP: no
Not explosive
Method: 92/69/EC (1-383)A.14 * Explosive properties
GLP: yes
Oxidizing properties The substance or mixture is not classified as oxidizing.
Reference substance: Potassium bromate/Cellulose
Method: Directive 84/449/EEC, A.17
GLP: yes
Self-heating substances Not applicable
Impact sensitivity Not impact sensitive.
Method: 92/69/EC (1-383)A.14 * Explosive properties
Sublimation point Not applicable
Dust deflagration index(Kst) 248 m.b_/s
Method: VDI 2263
GLP: no data available
Dust explosion class ST2 Capable of dust explosion
Minimum ignition energy 13 - 30 mJ
Method: Mike 3 apparatus
with inductive electrical resistance
Particle size approximately 35 lam
Method: Laser diffraction with dispersion in dry air.
Median value
SECTION 10. STABILITY AND REACTIVITY
Reactivity See section 10.3. "Possibility of hazardous reactions"
Chemical stability Stable

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 7
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Possibility of hazardous Stable
reactions Reactions with strong alkalies and oxidising agents.
The substance or mixture does not emit flammable gases in
contact with water.
Not corrosive to metals
Risk of dust explosion.
Conditions to avoid Strong oxidizing agents
Strong bases
Incompatible materials See under section "Conditions to avoid"
Hazardous decomposition Carbon oxides
products
Oxides of phosphorus
SECTION 11. TOXICOLOGICAL INFORMATION
Information on likely routes of exposure
Eye contact
Skin contact
Inhalation
Acute toxicity
Product:
Acute oral toxicity LD50 (Rat, male and female): > 2,000 mg/kg
Method: OECD Test Guideline 423
GLP: yes
Acute inhalation toxicity Remarks: not tested.
Acute dermal toxicity LD50 (Rat, male and female): > 2,000 mg/kg
Method: OECD Test Guideline 402
GLP: yes
Skin corrosion/irritation
Product:
Species: Rabbit
Exposure time: 4 h
Method: OECD Test Guideline 404
Result: No skin irritation
GLP: yes
Serious eye damage/eye irritation
Product:
Species: Rabbit
Result: No eye irritation
Exposure time: 72 h
Method: OECD Test Guideline 405

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 8
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
GLP: yes
Respiratory or skin sensitisation
Product:
Test Type: Maximisation Test
Species: Guinea pig
Method: OECD Test Guideline 406
Result: Not a skin sensitizer.
GLP: yes
Germ cell mutagenicity
Product:
Genotoxicity in vitro Test Type: Chromosome aberration test in vitro
Test system: Chinese hamster lung cells
Concentration: 3,1 - 100 pg/ml
Metabolic activation: with and without metabolic activation
Method: OECD Test Guideline 473
Result: negative
GLP: yes
Test Type: Ames test
Test system: Salmonella typhimurium
Concentration: 33 - 5000 pg/plate
Metabolic activation: with and without metabolic activation
Method: OECD Test Guideline 471
Result: negative
GLP: yes
Genotoxicity in vivo Test Type: Micronucleus test
Species: Mouse (male and female)
Cell type: Erythrocytes
Application Route: oral (gavage)
Exposure time: 24 h
Dose: 2500 - 5000 - 10000 mg/kg
Method: Other
Result: negative
GLP: no
Germ cell mutagenicity- In vitro tests did not show mutagenic effects, In vivo tests did
Assessment not show mutagenic effects
Carcinogenicity
Product:
Carcinogenicity- No evidence of carcinogenicity in animal studies.
Assessment
IARC Not listed
OSHA Not listed

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 9
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
NTP Not listed
Reproductive toxicity
Product:
Effects on fertility Test Type: One generation study
Species: Rat, male and female
Application Route: oral (feed)
Dose: 50 - 150 - 300 mg/kg
General Toxicity- Parent: NOAEL: 150 mg/kg body weight
General Toxicity F1: NOAEL: 150 mg/kg body weight
Method: Other
GLP: no
Effects on foetal Species: Rat, male and female
development Strain: wistar
Application Route: Oral
Dose: 100 mg/kg Futter
Duration of Single Treatment: 730 d
Method: Other
GLP: no
Remarks: Based on available data, the classification criteria
are not met.
Reproductive toxicity- Weight of evidence does not support classification for
Assessment reproductive toxicity
STOT -single exposure
Product:
Remarks: not available
STOT -repeated exposure
Product:
Remarks: not available
Repeated dose toxicity
Product:
Species: Dog, male and female
NOAEL: 150 mg/kg
Application Route: oral (gavage)
Exposure time: 93 - 97 d
Number of exposures: daily
Dose: 30 - 150- 500 mg/kg
Group: yes
Method: OECD Test Guideline 409
GLP: yes

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 10
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Aspiration toxicity
Product:
No aspiration toxicity classification
Experience with human exposure
Product:
General Information When used as intended, no effects to health are expected.
SECTION 12. ECOLOGICAL INFORMATION
Ecotoxicity
Product:
Toxicity to fish LC50 (Oncorhynchus mykiss (rainbow trout)): > 18.65 mg/I
Exposure time: 96 h
Test Type: static test
Method: OECD Test Guideline 203
GLP: yes
Remarks: No toxicity at the limit of solubility
NOEC (Oncorhynchus mykiss (rainbow trout)): >= 1.2 mg/I
Exposure time: 21 d
Test Type: flow-through test
Method: OECD Test Guideline 204
GLP: yes
Remarks: No toxicity at the limit of solubility
LOEC (Oncorhynchus mykiss (rainbow trout)): > 1.2 mg/I
Exposure time: 21 d
Test Type: flow-through test
Method: OECD Test Guideline 204
GLP: yes
Remarks: No toxicity at the limit of solubility
Toxicity to daphnia and other EC50 (Daphnia magna (Water flea)): > 12.7 mg/I
aquatic invertebrates End point: Immobilization
Exposure time: 48 h
Test Type: static test
Method: OECD Test Guideline 202
GLP: yes
Remarks: No toxicity at the limit of solubility
Toxicity to algae NOEC (Pseudokirchneriella subcapitata (green algae)): >_
78.6 mg/I
End point: Growth rate
Exposure time: 72 h
Method: OECD Test Guideline 201
GLP: yes
Remarks: No toxicity at the limit of solubility

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 11
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
ErC50 (Pseudokirchneriella subcapitata (green algae)): > 78.6
mg/I
End point: Growth rate
Exposure time: 72 h
Method: OECD Test Guideline 201
GLP: yes
Remarks: No toxicity at the limit of solubility
Toxicity to fish (Chronic NOEC (Oncorhynchus mykiss (rainbow trout)): >= 1.2 mg/I
toxicity) End point: mortality
Exposure time: 21 d
Test Type: flow-through test
Analytical monitoring: no data available
Method: OECD Test Guideline 204
GLP: yes
Remarks: No toxicity at the limit of solubility
Toxicity to daphnia and other NOEC (Daphnia magna (Water flea)): > 0.307 mg/I
aquatic invertebrates End point: mortality
(Chronic toxicity) Exposure time: 21 d
Test Type: semi-static test
Method: OECD Test Guideline 211
GLP: yes
NOEC (Daphnia magna (Water flea)): > 0.307 mg/I
End point: Reproduction rate
Exposure time: 21 d
Test Type: semi-static test
Method: OECD Test Guideline 211
GLP: yes
Toxicity to microorganisms IC50 (activated sludge): > 1,000 mg/I
End point: Bacteria toxicity(respiration inhibition)
Exposure time: 3 h
Test Type: static test
Method: OECD Test Guideline 209
GLP: yes
Remarks: No toxicity at the limit of solubility
Toxicity to soil dwelling Test Type: artificial soil
organisms NOEC (Eisenia fetida (earthworms)): > 1,000 mg/kg
Exposure time: 14 d
End point: Body weight
Method: OECD Test Guideline 207
GLP: yes
Plant toxicity EC50 (Avena sativa (oats)): > 100 mg/kg
Exposure time: 21 d
End point: Growth
Method: OECD Guide-line 208
GLP: yes
NOEC (Avena sativa (oats)): >= 100 mg/kg

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 12
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Exposure time: 21 d
End point: Growth
Method: OECD Guide-line 208
GLP: yes
LOEC (Avena sativa (oats)): > 100 mg/kg
Exposure time: 21 d
End point: Growth
Method: OECD Guide-line 208
GLP: yes
EC50 (Brassica rapa): > 100 mg/kg
Exposure time: 21 d
End point: Growth
Method: OECD Guide-line 208
GLP: yes
NOEC (Brassica rapa): >= 100 mg/kg
Exposure time: 21 d
End point: Growth
Method: OECD Guide-line 208
GLP: yes
LOEC (Brassica rapa): > 100 mg/kg
Exposure time: 21 d
End point: Growth
Method: OECD Guide-line 208
GLP: yes
EC50 (Lepidium sativum (cress)): > 100 mg/kg
Exposure time: 21 d
End point: Growth
Method: OECD Guide-line 208
GLP: yes
NOEC (Lepidium sativum (cress)): >= 100 mg/kg
Exposure time: 21 d
End point: Growth
Method: OECD Guide-line 208
GLP: yes
LOEC (Lepidium sativum (cress)): > 100 mg/kg
Exposure time: 21 d
End point: Growth
Method: OECD Guide-line 208
GLP: yes
Persistence and degradability
Product:
Biodegradability Test Type: aerobic
Inoculum: activated sludge
Concentration: 30 mg/I

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 13
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Result: Not readily biodegradable.
Biodegradation: 24.5 % (Biochemical Oxygen Demand
(BOD))
Exposure time: 28 d
Method: OECD Test Guideline 302C
GLP: yes
Test Type: aerobic
Inoculum: activated sludge, domestic
Concentration: 100 mg/I
Result: Not biodegradable
Biodegradation: 0 % (Biochemical Oxygen Demand (BOD))
Exposure time: 28 d
Method: OECD Test Guideline 301 F
GLP: yes
Physico-chemical Remarks: Not readily biodegradable.
removability The product is slightly soluble in water. It can be largely
eliminated from the water by abiotic processes, e.g.
mechanical separation.
Stability in water Test Type: abiotic
Method: OECD Test Guideline 111
GLP: yes
Remarks: Not applicable
Bioaccumulative potential
Product:
Bioaccumulation Species: Cyprinus carpio (Carp)
Bioconcentration factor(BCF): 103
Exposure time: 42 d
Temperature: 24.7 °C
Concentration: 0.79 mg/I
Elimination: no data available
Method: Other
GLP: yes
Remarks: The bioaccumulation potential of the main
component of the mixture is expected to be low.
Species: Cyprinus carpio (Carp)
Bioconcentration factor(BCF): 112
Exposure time: 42 d
Temperature: 24.7 °C
Concentration: 0.05 mg/I
Elimination: no data available
Method: Other
GLP: yes
Remarks: The bioaccumulation potential of the main
component of the mixture is expected to be low.

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 14
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Mobility in soil
no data available
Other adverse effects
Product:
Environmental fate and Remarks: The product has not been tested. Because of the
pathways product's consistency and low solubility in water bioavailability
is not likely.
Additional ecological The product should not be allowed to enter drains, water
information courses or the soil.
SECTION 13. DISPOSAL CONSIDERATIONS
Disposal methods
RCRA- Resource This product, if discarded as sold, is not a Federal RCRA
Conservation and Recovery hazardous waste.
Authorization Act
Waste Code NONE
Waste from residues Small quantities may be treated in aerobic wastewater
treatment systems. Larger quantities may be incinerated or
landfilled after solidification in permitted systems.
Contaminated packaging Dispose of in accordance with local regulations.
SECTION 14. TRANSPORT INFORMATION
DOT not restricted
IATA not restricted
IMDG not restricted
SECTION 15. REGULATORY INFORMATION
EPCRA- Emergency Planning and Community Right-to-Know Act
CERCLA Reportable Quantity
This material does not contain any components with a CERCLA RQ.
SARA 304 Extremely Hazardous Substances Reportable Quantity
This material does not contain any components with a section 304 EHS RQ.
SARA 302 Extremely Hazardous Substances Threshold Planning Quantity
This material does not contain any components with a section 302 EHS TPQ.
SARA 311/312 Hazards : Combustible dust

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 15
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
SARA 313 This material does not contain any chemical components with
known CAS numbers that exceed the threshold (De Minimis)
reporting levels established by SARA Title III, Section 313.
Clean Water Act
This product does not contain any toxic pollutants listed under the U.S. Clean Water Act Section
307
The components of this product are reported in the following inventories:
TSCA On TSCA Inventory, All components are compliant with the
TSCA Inventory Notification (Active) rule.
SECTION 16. OTHER INFORMATION
Further information
NFPA:
Flammability
s
m
v 0 a
x =
Special hazard.
Full text of other abbreviations
AICS -Australian Inventory of Chemical Substances; ASTM -American Society for the Testing of
Materials; bw - Body weight; CERCLA - Comprehensive Environmental Response,
Compensation, and Liability Act; CMR - Carcinogen, Mutagen or Reproductive Toxicant; DIN -
Standard of the German Institute for Standardisation; DOT - Department of Transportation; DSL -
Domestic Substances List (Canada); ECx - Concentration associated with x% response; EHS -
Extremely Hazardous Substance; ELx - Loading rate associated with x% response; EmS -
Emergency Schedule; ENCS - Existing and New Chemical Substances (Japan); ErCx -
Concentration associated with x% growth rate response; ERG - Emergency Response Guide;
GHS - Globally Harmonized System; GLP - Good Laboratory Practice; HMIS - Hazardous
Materials Identification System; IARC - International Agency for Research on Cancer; IATA -
International Air Transport Association; IBC - International Code for the Construction and
Equipment of Ships carrying Dangerous Chemicals in Bulk; IC50 - Half maximal inhibitory
concentration; ICAO - International Civil Aviation Organization; IECSC - Inventory of Existing
Chemical Substances in China; IMDG - International Maritime Dangerous Goods; IMO -
International Maritime Organization; ISHL - Industrial Safety and Health Law (Japan); ISO -
International Organisation for Standardization; KECI - Korea Existing Chemicals Inventory; LC50
- Lethal Concentration to 50 % of a test population; LD50 - Lethal Dose to 50% of a test
population (Median Lethal Dose); MARPOL - International Convention for the Prevention of

SAFETY DATA SHEET CLAR IANT 7A
Hostanox P-EPQ P Page 16
Substance key: KS14592 Revision Date: 10/04/2018
Version : 4 - 2 / USA Date of printing :10/18/2018
Pollution from Ships; MSHA - Mine Safety and Health Administration; n.o.s. - Not Otherwise
Specified; NFPA- National Fire Protection Association; NO(A)EC - No Observed (Adverse) Effect
Concentration; NO(A)EL - No Observed (Adverse) Effect Level; NOELR - No Observable Effect
Loading Rate; NTP- National Toxicology Program; NZIoC - New Zealand Inventory of Chemicals;
OECD - Organization for Economic Co-operation and Development; OPPTS - Office of Chemical
Safety and Pollution Prevention; PBT - Persistent, Bioaccumulative and Toxic substance; PICCS
- Philippines Inventory of Chemicals and Chemical Substances; (Q)SAR - (Quantitative) Structure
Activity Relationship; RCRA - Resource Conservation and Recovery Act; REACH - Regulation
(EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration,
Evaluation, Authorisation and Restriction of Chemicals; RQ - Reportable Quantity; SADT - Self-
Accelerating Decomposition Temperature; SARA - Superfund Amendments and Reauthorization
Act; SDS - Safety Data Sheet; TCSI - Taiwan Chemical Substance Inventory; TSCA - Toxic
Substances Control Act (United States); UN - United Nations; UNRTDG - United Nations
Recommendations on the Transport of Dangerous Goods; vPvB - Very Persistent and Very
Bioaccumulative
On the basis of an extensive test program, which had to be submitted to the competent authority
on the occasion of the Notification of the substance in the European Community, this product was
found to be toxicologically not dangerous within the meaning of the EC Directives.
Handle with care. Organic dusts have the potential to be explosive with static spark or flame
initiation.
Revision Date 10/04/2018
This information corresponds to the present state of our knowledge and is intended as a general
description of our products and their possible applications. Clariant makes no warranties, express
or implied, as to the information's accuracy, adequacy, sufficiency or freedom from defect and
assumes no liability in connection with any use of this information. Any user of this product is
responsible for determining the suitability of Clariant's products for its particular application. NO
EXPRESS OR IMPLIED WARRANTY IS MADE OF THE MERCHANTABILITY, SUITABILITY,
FITNESS FOR A PARTICULAR PURPOSE OR OTHERWISE OF ANY PRODUCT OR
SERVICE. Nothing included in this information waives any of Clariant's General Terms and
Conditions of Sale, which control unless it agrees otherwise in writing. Any existing
intellectual/industrial property rights must be observed. Due to possible changes in our products
and applicable national and international regulations and laws, the status of our products could
change. Material Safety Data Sheets providing safety precautions, that should be observed when
handling or storing Clariant products, are available upon request and are provided in compliance
with applicable law. You should obtain and review the applicable Material Safety Data Sheet
information before handling any of these products. For additional information, please contact
Clariant.
US/ EN

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CELANESE - SHELBY i icon a
RECORD CHL VAnn
ISSUE FOR RECORD DHL1, SHELBY SITE PLAN
ISSUE FOR
roc STORM WATER PERMIT RENEWAL 2005
P� ht/19/05 R mmF 2525 Blacksburg Road Grover, N.C. 28073
CHL DWG NO. TY-00-0023

Attachment 2
Summary of Analytical Monitoring Results
NORTH OUTFALL
Benchmark: 100 30 120 6-9
TSS BOD COD
Period Date (mg/L) (mg/L) (mg/L) pH
2H 2O18 11/12/2018 9.2 5.2 120 7.4
1H 2O19 5/11/2019 9.0 8.2 <50 7.7
2H 2O19 10/13/2019 57.6 3.1 <50 7.9
1H 2O20 3/10/2020 8.8 <2.0 <50 8.0
2H 2O20 11/11/2020 3.2 <2.0 <50 7.3
1H 2O21 3/16/2021 3.5 <2.0 <50 6.6
2H 2O21 8/3/2021 2.8 2.8 <50 7.4
1H 2O22 3/16/2022 21.1 13.4 53 6.7
2H 2O22 10/31/2022 59.7 6.2 <50 8.2
1H 2O23 6/4/2023 15.1 5.8 30 7.0
Minimum 6.6
Maximum 59.7 13.4 120 8.2
Average 19 6.4 37.8 7.4
Number of Storm Events Sampled 10
SOUTH OUTFALL
Benchmark: 100 30 120 6-9
TSS BOD COD
Period Date (mg/L) (mg/L) (mg/L) pH
2H 2O18 11/12/2018 7.9 <2.0 <50 6.7
1H 2O19 5/11/2019 14.7 5.3 <50 7.3
2H 2O19 10/13/2019 31.9 <2.0 <50 7.4
1H 2O20 3/10/2020 2.8 <2.0 <50 6.8
2H 2O20 11/11/2020 12.5 <2.0 <50 6.8
1H 2O21 3/16/2021 2.8 <2.0 <50 6.8
2H 2O21 8/3/2021 3.8 2.4 <50 6.6
1H 2O22 3/16/2022 3.9 <2.0 <50 6.9
2H 2O22 10/31/2022 44.9 11.7 99 8.8
1H 2O23 6/4/2023 32.3 8.7 36 7.4
Minimum 6.6
Maximum 44.9 11.7 <50 8.8
Average 15.8 7.0 33.5 7.2
Number of Storm Events Sampled 10
EAST OUTFALL
Benchmark: 100 30 120 6-9
TSS BOD COD
Period Date (mg/L) (mg/L) (mg/L) pH
2H 2O18 11/12/2018 6.5 <2.0 <50 7.3
1H 2O19 5/11/2019 16.0 5.7 <50 7.6
2H 2O19 10/13/2019 30.3 4.1 <50 7.5
1H 2O20 3/10/2020 14.4 <2.0 <50 8.2
2H 2O20 11/11/2020 13.4 <2.0 <50 7.4
1H 2O21 3/16/2021 7.3 <2.0 <50 7.6
2H 2O21 8/3/2021 2.5 2 <50 7.6
1H 2O22 3/16/2022 48.2 6.5 52 7.8
2H 2O22 10/31/2022 71.0 5.4 <50 8.1
1H 2O23 6/4/2023 9.7 9.3 <30 7.6
Minimum 7.3
Maximum 71 9.3 52 8.2
Averagel 21.9 5.5 1 28.0 1 7.7
Number of Storm Events Sampledl 10
CNA Holdings, LLC - Shelby September 2022
NPDES Permit No. NCS000064 Updated September 2023

Attachment 2
Summary of Visual Monitoring Results
NORTH
Erosion/
Floating Suspended deposition at Other
Period Date Color Odor Clarity Solids Solids Foam Oil Sheen outfall indicators
2H 2O18 11/12/2018 Lt Brown None 1 2 1 No No No No
1H 2O19 5/11/2019 Lt Brown None 1 1 1 No No No No
2H 2O19 10/13/2019 Lt Brown None 1 2 2 No No No No
1H 2O20 3/10/2020 Lt Red None 1 2 2 No No No No
2H 2O20 11/11/2020 Lt Red None 1 2 1 No No No No
1H 2O21 3/16/2021 Lt Brown none 2 2 1 No No No No
2H 2O21 8/3/2021 Lt Brown none 1 2 2 No No No No
1H 2O22 3/16/2022 Lt Brown None 1 2 1 No No No No
2H 2O22 10/31/2022 Lt Brown None 3 3 2 No No No No
1H 2O23 6/4/2023 Lt Brown None 3 2 3 No No No No
SOUTH
Erosion/
Floating Suspended deposition at Other
Period Date Color Odor Clarity Solids Solids Foam Oil Sheen outfall indicators
2H 2O18 11/12/2018 Lt Red None 3 3 3 No No No No
1H 2O19 5/11/2019 Lt Brown None 2 1 1 No No No No
2H 2O19 10/13/2019 Lt Brown None 1 2 2 No No No No
1H 2O20 3/10/2020 Lt Brown None 1 3 1 No No No No
2H 2O20 11/11/2020 Lt Brown None 2 2 2 No No No No
1H 2O21 3/16/2021 None none 2 1 1 No No No No
2H 2O21 8/3/2021 Lt Brown none 2 2 2 No No No No
1H 2O22 3/16/2022 Lt Brown None 1 2 1 No No No No
2H 2O22 10/31/2022 Lt Brown None 4 2 3 No No No No
1H 2O23 6/4/2023 Lt Brown None 4 3 3 No No No No
EAST
Erosion/
Floating Suspended deposition at Other
Period Date Color Odor Clarity Solids Solids Foam Oil Sheen outfall indicators
2H 2O18 11/12/2018 Lt Brown None 1 1 1 No No No No
1H 2O19 5/11/2019 Lt Brown None 1 1 1 No No No No
2H 2O19 10/13/2019 Lt Brown None 3 2 3 No No No No
1H 2O20 3/10/2020 Lt Brown None 2 2 2 No No No No
2H 2O20 11/11/2020 Lt Red None 2 2 2 No No No No
1H 2O21 3/16/2021 Lt Brown none 3 2 2 No No No No
2H 2O21 8/3/2021 Lt Brown none 1 1 2 No No No No
1H 2O22 3/16/2022 Lt Brown None 3 2 3 No No No No
slight
2H 2O22 10/31/2022 Lt Brown dowtherm 3 2 2 No No No No
1H 2O23 6/4/2023 Lt Brown None 2 2 3 No No No No
CNA Holdings, LLC-Shelby
NPDES Permit No. NCS000064 September 2022

Young, Brianna A
From: Young, Brianna A
Sent: Tuesday, October 4, 2022 2:38 PM
To: Jennifer Wheat
Cc: Johnson, Ericl, Celanese; Megan Neal
Subject: RE: [External] Shelby Stormwater Permit Renewal NPDES#NCS000064
Good afternoon,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000064.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action. Please note that due to the current backlog and
staff shortages, review of this permit renewal is not scheduled until 2024,however this schedule is subject to
change. Please let me know if you have any questions in the interim.
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
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:Young, Brianna A
Sent: Friday, September 30, 2022 4:20 PM
To:Jennifer Wheat<[e-mail]>
Cc:Johnson, Ericl, Celanese<[e-mail]>; Megan Neal<[e-mail]>
Subject: RE: [External] Shelby Stormwater Permit Renewal NPDES#NCS000064
Good afternoon,
I have received your email.An official confirmation will be sent once the paper copy with original signature is received in
our offices.
i

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
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:Jennifer Wheat<[e-mail]>
Sent: Friday, September 30, 2022 4:07 PM
To:Young, Brianna A<[e-mail]>
Cc:Johnson, Eric1, Celanese<[e-mail]>; Megan Neal <[e-mail]>
Subject: [External] Shelby Stormwater Permit Renewal NPDES#NCS000064
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hello Ms. Young,
On behalf of CNA Holdings, LLC, please find attached the scanned copy of the CNA Holdings, LLC—Shelby permit renewal
for NPDES#NCS000064.A copy has been sent as well to your attention on September 30, 2022.
Please confirm receipt of this application.
Much Thanks,
Jennifer
Jennifer Wheat
Senior Consultant
P 704.553.7747 x2852
M 980.322.7447
Email: [e-mail]
325 Arlington Ave. Suite 500 Charlotte, NC 28203
Trinity
Connect with us: LinkedIn/ Facebook/Twitter/YouTube/trinityconsultants.com
2

Stay current on EHS issues. Subscribe today to receive Trinity's free EHS Quarterly.
3

j Celanese
The chemistry inside innovation
Celanese Corporation
222 W. Las Colinas Blvd.
Suite 90ON
Irving,Texas, USA 75039
www.ce[anese.com
September 30, 2022
RECEIVED
Brianna Young
1612 MSC
Raleigh, NC 27699-1612 h
via e-mail: brianna. oun ncdenr. ov DEMLR-Stormater Program
RE: Individual Storm water Permit Renewal Application
CNA Holdings, LLC -Shelby
NPDES Permlt No. NCS000O64
Dear Ms. Young:
CNA Holdings, LLC (CNA Holdings) owns and operates a facility in Grover, NC (the Shelby Plant). The facility
currently operates under Permit No. NCS000064 that allows discharge of stormwater under the National
Pollutant Discharge Elimination System (NPDES). The current permit was effective starting on April 9, 2018
and expires on March 31, 2023. CNA Holdings is submitting this permit application to request renewal of the
permit within 180 days of the expiration of the permit (or by October 3, 2022) as required.
Consistent with North Carolina Department of Environmental Control (NC DEQ) instructions, one hard copy
of the required forms and supporting documents are included in this submittal, with two copies of supported
documentation included. The attached forms and supporting documents will also be e-mailed to your
attention.
If you have any questions concerning the information in the permit application, please contact me at 704-
480-5759 or Jen Wheat of Trinity Consultants at(704) 553-7747.
Sincerely,
CNA HOLDIN LC
ZE�ricJohn In
ESH Manager
cc: Ms. Jennifer Wheat, Trinity Consultants Inc.

Attachment 1
Application Forms
► EPA Form 1
► EPA Form 2F
► NC DEQ Supplemental Information Form
► NC DEQ SPPP Certification Form

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
110001503105 NCS000064 CNA Holdings LLC-Shelby OMB No.2040-0004
Form U.S.Environmental Protection Agency
1 "' EPA Application for NPDES Permit to Discharge Wastewater
NPDES %IWGENERAL INFORMATION
SECTION • '• 'I
1.1 Applicants.Not Required to Submit Form 1
Is the facility a new or existing publicly owned Is the facility a new or existing treatment works
1.1.1 treatment works? 1.1.2 treating domestic sewage?
If yes,STOP.Do NOT complete No If yes,STOP.Do NOT No
Form 1.Complete Form 2A. complete Form 1.Complete
Form 2S.
1.2 Applicants Required to Submit Form 1
1.2.1 Is the facility a concentrated animal feeding 1.2.2 Is the facility an existing manufacturing,
operation or a concentrated aquatic animal commercial,mining,or silvicultural facility that is
a production facility? currently discharging process wastewater?
cYes 4 Complete Form 1 No Yes-*Complete Form ❑� No
i and Form 213. 1 and Form 2C.
C 1.2.3 Is the facility a new manufacturing,commercial, 1.2.4 Is the facility a new or existing manufacturing,
C mining,or silvicultural facility that has not yet commercial,mining,or silvicultural facility that
commenced to discharge? discharges only nonprocess wastewater?
C. Yes+ Complete Form 1 ✓❑ No Yes 4 Complete Form ✓� No
y and Form 2D. 1 and Form 2E.
1.2.5 Is the facility a new or existing facility whose
discharge is composed entirely of stormwater
a associated with Industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
❑✓ Yes 4 Complete form 1 No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x)or
SECTION
•ME, MAILING ADDRESS. AND LOCATION (40
2.1 Faclllty Name
CNA Holdings LLC-Shelby
0 2.2 EPA Identification Number
110001503105
-o
ro 2.3 Factl€ty Contact
m Name(first and last) Title Phone number
V Eric Johnson EHS Manager [phone]
v
Q
Email address
[e-mail]
m
2.4 Facility Mailing Address
zStreet or P.O.box
2525 Blacksburg Road
City or town State ZIP code
Grover NC 28073
EPA Form 3510-1(revised 3-19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
110001503105 NCS000064 CNA Holdings LLC-Shelby OMB No.2040-0004
2.5 Facility Location
wStreet,route number,or other specific identifier
a o 2525 Blacksburg Road
�U
o County name County code(if known)
cts n Cleveland
City or town State ZIP code
r_ Grover NC 28073
CODESSECTION 3.SIC AND NAICS 1
3.1 SIC Code(s) Description(optional)
2821 PLASTICS MATERIALS,SYNTHETIC RESINS,AND NONVULCANIZABLE ELA5TOMERS
y
d
b
O
U
y
U
z 3.2 NAICS Codes) Description(optional)
a
c
v 325211 PLASTICS MATERIAL AND RESIN MANUFACTURING
in
SECTIONOPERATOR INFORMATION(40
4.1 Name of Operator
CNA Holdings LLC
0 4.2 Is the name you listed in Item 4.1 also the owner?
0
❑ Yes n✓ No
4.3 Operator Status
❑ Public--federal ❑ Public—state ❑ Other public(specify)
C ✓❑ Private ❑ Other(specify)
4.4 Phone Number of Operator
[phone]
4.5 Operator Address
o Street or P.Q.Box
a 2525 Blacksburg Road
d
c w City or town State ZIP code
`o o Grover INC 28073
is U
Q Email address of operator
D [e-mail]
SECTIONi
5.1 Is the facility located on Indian Land?
❑Yes El No
EPA Form 3510-1(revised 3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
110001503105 NC$000064 CNA Holdings LLC-Shelby OMB No.2040.4004
ENVIRONMENTALSECTION 6.EXISTING 1
6.1 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each)
a ❑ NPDES(discharges to surface ❑ RCRA(hazardous wastes) ❑ UIC(underground injection of
water) fluids)
•'N— NC0004952 NCDO03446721
E
L a ❑ PSD(air emissions) ❑ Nonattainment program(CAA) ❑✓ NESHAPs(CAA)
Cn
Synthetic Minor 037541357
x ❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) ❑ Other(specify)
W
SECTION 7.MAP i
7.1 Have you attached a topographic map containing all required information to this application?(See instructions for
specific requirements.)
Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 2B.)
SECTIONOF
8.1 Describe the nature of your business.
Liquid crystal polymer production
m Ln
au
a
m
a
m
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SECTION ' COOLING WATER '
9.1 Does your facility use cooling water?
Cn
✓❑ Yes ❑ No 3 SKIP to Item 10.1.
E 9.2 Identify the source of cooling water.(Note that facilities that use a cooling water intake structure as described at
41 r
40 CFR 125,Subparts I and J may have additional application requirements at 40 CFR 122.21(r),Consult with your
o Y NPDES permitting authority to determine what specific information needs to be submitted and when.)
Public water system
SECTIONi I 1
10.1 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)?(Check all that
apply.Consult with your NPDES permitting authority to determine what information needs to be submitted and
when.)
❑ Fundamentally different factors(CWA ❑ Water quality related effluent limitations(CWA Section
CU
[if Section 301(n)) 302(b)(2))
C,
❑ Non-conventional pollutants(CWA ❑ Thermal discharges(CWA Section 316(a))
Section 301(c)and(g))
❑v Not applicable
EPA Form 3510-1{revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
110001503105 NCS000064 CNA Moldings LLC-Shelby OMB No.204M004
SECTION 11.CHECKLIST 1 CERTIFICATION STATEMENT(40
11.1 In Column 1 below,mark the sections of Form 1 that you have completed and are submitting with your application.
For each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note
that not all applicants are required to provide attachments.
Column 1 Column 2
❑� Section 1:Activities Requiring an NPDES Permit ❑ wl attachments
❑� Section 2:Name,Mailing Address,and Location ❑ wI attachments
❑✓ Section 3:SIC Codes ❑ wl attachments
✓❑ Section 4:Operator Information ❑ wl attachments
❑✓ Section 5: Indian Land ❑ wl attachments
✓❑ Section 6: Existing Environmental Permits ❑ wl attachments
d
wl topographic
a ❑✓ Section l:Map ❑ wl additional attachments
ma
o Section 8:Nature of Business ❑ wl attachments
❑ Section 9:Cooling Water Intake Structures ❑ wl attachments
4)
�' ❑✓ Section 10:Variance Requests ❑ wl attachments
;� ❑� Section I I:Checklist and Certification Statement ❑ wl attachments
11.2 Certification Statement
U
1 certify under penalty of law that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted Based on my inquiry of the person or persons who manage the system,or those persons
directly responsible for gathering the information,the information submitted is, to the best of my knowledge and
belief,true, accurate,and complete.I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name(print or type first and last name) Official title
Lawrence Wolnik Site Director
Signature Date signed
-Z p Z Z
EPA Form 3510-1(revised 3-19) Page 4

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
110001503105 NCS000064 CNA Holdings LLC-Shelby OMB No.2040-0004
Form U.S Environmental Protection Agency
2F I=,EPA Application for NPDES Permit to Discharge Wastewater
NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
SECTIONOUTFALL LOCATION
1.1 Provide information on each of the facilib Is outfalls in the table below
Outfall Receiving Water Name Latitude Longitude
Number
EAST Buffalo Creek 35° 12' 30" N 81' 31' 25" W
c
0
it NORTH Buffalo Creek 35" 12' 40" N 81° 31' 30" W
0
J
�y SOUTH Buffalo Creek 35° 11' 51" N 81, 31' 47" W
O • ,
SECTION •• 4{
2.1 Are you presently required by any federal,state,or local authority to meet an implementation schedule for constructing,
upgrading,or operating wastewater treatment equipment or practices or any other environmental programs that could
affect the discharges described in this application?
❑ Yes ✓❑ No 4 SKIP to Section 3.
2.2 Briefly identify each applicable project in the table below.
Brief Identification and Affected Outfalis Final Compliance Dates
Source(s)of Discharge
Description of Project (fist outfall numbers)
Required Projected
w
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m
0
a
E
2.3 Have you attached sheets describing any additional water pollution control programs(or other environmental projects
that may affect your discharges)that you now have underway or planned?(Optional Item)
❑ Yes ❑ No
EPA Form 3510-21'(Revised 3-19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
110001503105 NCS000064 CNA Holdings LLC-Shelby OMB No.204MOW
SECTION 3.SITE D• I
0 3.1 Have you attached a site drainage map containing all required information to this application?(See instructions for
W rL specific guidance.)
® Yes ❑ No
SECTION 4.POLLUTANT SOURCESi
4.1 Provide information on the facility's pollutant sources in the table below.
Outfall Impervious Surface Area Total Surface Area Drained
Number (within a mile radius of the facility) {within a mile radius of the facility)
specify units specify units
EAST 20.5 acres 213 acres
specify units specify units
NORTH 36.2 acres 40.81 acres
specify units specify units
SOUTH 15.3 acres 31.5 acres
specify units specify units
specify units specify units
specify units specily units
4.2 Provide a narrative description of the facility's significant material in the space below.(See instructions for content
requirements.)
See attachment
m
0
y
c
0
0
a
4.3 Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in
stormwater runoff. See instructions forspecificguidance.)
Stormwater Treatment
Codes
Outfall from
Number Control Measures and Treatment Exhibit
2F-1
list}
North Bi weekly inspections,training,5WPP,semi-annual inspections,secondary containment N/A
South Bi weekly inspections,training,SWPP,semi-annual insp.,roofs(cover),secondary cont. N/A
East Bi weekly insp.,training,SWPP,semi-annual insp.,unloading/loading processes,sec.cont. N/A
EPA Form 3510-2F(Revised 3-19) Page 2

EPA Form 2F —Attached Information
Section 4.2 Response:
Significant materials include: loading and unloading docks, scrap metal storage areas, oil and chemical
tank farm areas, solid waste compactors and dumpsters, recycling areas, wastewater treatment and
hazardous and non-hazardous areas.
The north outfall includes compounding and Vectra waste dumpster roll-offs, cardboard and scrap
metal recycling, brown &root scrap yard, oil &chemical storage with secondary containment,
emergency firewater basin, HOA secondary containment basin and a cooling tower. There are two
storage tanks, 5,000 gallons capacity each, of Therminol 66 which is diked.
The south outfall contains a number 6 empty closed In place AST, a gasoline and diesel
unloading/loading station (under roof), hazardous and non-hazardous storage(under roof), and a
cooling tower tank farm (empty and clean, abandoned in place). There is a 50,000 gallon tank of acetic
anhydride, a 50,000 gallon tank of acetic acid, a 30,000 gallon tank of triethylene glycol, a 30,000
gallon tank of spent glycol, and a 10,000 gallon tank of ethylene glycol. These are in stainless steel
tanks in a diked area. The hazardous and non-hazardous are currently has sodium hydroxide 300 and
corrosion inhibitor for the process water tank. There is also a waste holding pad in the south.
The east outfall includes loading and unloading of raw materials and by/co-products, Marley cooling
tower. The raw materials and by/co products include 300 gallon of caustic, 120 gallon of boiler
treatment, 120 gallon of oxygen scavenger, 120 gallon of corrosion inhibitor, 120 gallon of bromine,
120 gallons of biocide, and 120 gallons of coiling tower treatment. These are in totes and stored in the
building.
Approximately 80 gallons of"Roundup"is used each year throughout the plant site on edging, around
cooling towers, transformers, wastewater basins& railroad tracks as a grass and weed killer.
The use of"Ice Melt"is limited to sidewalks and pedestrian walkways when inclement weather
conditions require its use.

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03f0511g
110001503105 NCS000064 CNA Holdings LLC-Shelby OMB No.204M004
SECTION !N STORMWATER 1 I CFR 122.26(c)(1)(i)(C))
5.1 1 certify under penalty of law that the outfall(s) covered by this application have been tested or evaluated for the
presence of non-stormwater discharges. Moreover, 1 certify that the outfalls identified as having non-stomtwater
discharges are described in either an accompanying NPDES Form 2C, 2D,or 2E application.
Name(print or type first and last name) Official title
Lawrence Wolnick Site Director
Signature f , J Bate signed
N
a� 5.2 Provide the testing information requested in the table below.
Onsite Drainage Points
Outfall Description of Testing Method Used Date(s)of Testing Directly Observed
a Number
During Test
m
Y
1°
� North Observation,SWPP review,site plan review 09/28/2022 Catch basins,drains,
swales and outfall
O
� South Observation,SWPP review,site plan review 9/28/2022
Catch basins,drains,
swales and outfall
East Observation,SWPP review,site plan review 9/28/2022 Catch basins,drains,
swales and outfall
SECTION , SIGNIFICANT LEAKSOR 1 1
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
2
Q No significant leaks or spills of toxic or hazardous pollutants in the last three years.
12
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m
J
C
R
Ci
.0
01
N
SECTION
+ ' •' • 1
See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must
o com fete.Not all applicants need to complete each table.
7.1 Is this a new source or new discharge?
aYes 3 See instructions regarding submission of ❑ No -* See instructions regarding submission of
d
estimated data. actual data.
i Tables A,B,C,and D
cc
y 7.2 Have you completed Table A for each outfall?
B Yes ❑ No
EPA Form 3510-21F(Revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Faardy Name Form Approved 03/05/19
110001503105 NCS000064 CNA Holdings LLC-Shelby OMB No.2040-M
7.3 Is the facility subject to an effluent limitation guideline(ELG)or effluent limitations in an NPDES permit for its process
wastewater?
❑✓ Yes ❑ No 4 SKIP to Item 7.5.
7.4 Have you completed Table B by providing quantitative data for those pollutants that are(1)limited either directly or
indirectly in an ELG and/or(2)subject to effluent limitations in an NPDES permit for the facility's process wastewater?
0 Yes ❑ No
7.5 Do you know or have reason to believe any pollutants in Exhibit 2F-2 are present in the discharge?
❑ Yes ✓❑ No 4 SKIP to Item 7.7.
7.6 Have you listed all pollutants in Exhibit 2F-2 that you know or have reason to believe are present in the discharge and
provided quantitative data or an explanation for those pollutants in Table C?
❑ Yes ❑ No
7.7 Do you qualify for a small business exemption under the criteria specified in the Instructions?
❑ Yes-SKIP to Item 7.18. ✓❑ No
7.8 Do you know or have reason to believe any pollutants in Exhibit 2F-3 are present in the discharge?
❑ Yes ❑✓ No 4 SKIP to Item 7.10.
7.9 Have you listed all pollutants in Exhibit 2F-3 that you know or have reason to believe are present in the discharge in
Table C?
❑ Yes ❑ No
a 7.10 Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greater?
❑ Yes ✓❑ No 4 SKIP to Item 7.12.
7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in
concentrations of 10 ppb or greater?
"V, ',; ❑ Yes ❑ No
7.12 Do you expect acrolein,acrylonitrile,2,4-dinitrophenol,or 2-methyl4,6-dinitrophenol to be discharged in concentrations
of 100 ppb or greater?
❑ Yes ❑ No 4 SKIP to Item 7.14.
7.13 Have you provided quantitative data in Table C for the pollutants identified in Item 7.12 that you expect to be
discharged in concentrations of 100 ppb or greater?
❑ Yes ❑ No
7.14 Have you provided quantitative data or an explanation in Table C for pollutants you expect to be present in the
discharge at concentrations less than 10 ppb(or less than 100 ppb for the pollutants identified in Item 7.12)?
❑ Yes ❑✓ No
7.15 Do you know or have reason to believe any pollutants in Exhibit 2F-4 are present in the discharge?
❑ Yes ❑✓ No 4 SKIP to Item 7.17.
7.16 Have you listed pollutants in Exhibit 2F4 that you know or believe to be present in the discharge and provided an
explanation in Table C?
❑ Yes ❑ No
7.17 Have you provided information for the storm event(s)sampled in Table D?
❑ Yes No
EPA Form 3510-2F(Revised 3-19) Page 4

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
110001503105 NCS000064 CNA Holdings LLC-Shelby OMB No.2040.0004
08W-Or Manut`actu0416 ics
7.18 Is any pollutant listed on Exhibits 2F-2 through 2F-4 a substance or a component of a substance used or
manufactured as an intermediate or final product or byproduct?
❑ Yes ❑✓ No 4 SKIP to Section 8.
7.19 List the pollutants below,including TCDD if applicable.
4. 7.
',.. 2. 5. 8.
3. 6. 9.
SECTION 8. BIOLOGICAL TOXICITY TESTING DATA(40 CFR 122.21(g)(11))
8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
any of your discharges or on a receiving water in relation to your discharge within the last three years?
°' ❑ Yes © No 4 SKIP to Section 9.
I' 8.2 Identify the tests and their purposes below.
ty p rp
,'�. '"f' } Pu ,off - -Sgb�tttgd>~o)VPQ�&; t�te'Sttbtrtl k
Perms ii..A�Gtfio
r„,.., ❑ Yes ❑ No
-� ❑ Yes ❑ No
❑ Yes ❑ No
SECTION • •• • .t
9.1 Were any of the analyses reported in Section 7(on Tables A through C)performed by a contract laboratory or
consulting firm?
[✓. Yes ❑ No>SKIP to Section 10.
9.2 Provide information for each contract laboratory or consulting firm below.
t,af>oftr [ i1t�ler,14 :^LabQla�gcthNumberf2 totatofr�l,�Ntf�rlbdt8
Name of laboratory/firm
Waypoint Analytical(Formerly
G< r Prism Laboratories)
Y:.
'I Laboratory address
,�•' - 449 Springbrook Road
Charlotte,NC 28217
Phone number
[phone]
Pollutant(s)analyzed
TSS,BOO,COD,pH
�h
EPA Form 3510 2F(Revised 3-19) Page 5

EPA Identifcabon Number NPDES Permit Number Facility Name Form Approved 03/05/19
110001S03105 NCS000064 CNA Holdings LLC-Shelby OMB No.2040-0004
SECTION1 CHECKLIST AND CERTIFICATION STATEMENT(40
10.1 In Column 1 below,mark the sections of Form 2F that you have completed and are submitting with your application.For
each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not
all applicants are required to com fete all sections or provide attachments.
Go►uirn 1 Colufnn 2
❑✓ Section 1 ❑ wl attachments(e.g.,responses for additional outfalls)
✓❑ Section 2 ❑ wl attachments
✓❑ Section 3 wl site drainage map
✓❑ Section 4 wl attachments
Section 5 ❑ wl attachments
'' ✓❑ Section 6 ❑ wl attachments
E'' ✓❑ Section 7 Table A ❑ wl small business exemption request
' ❑✓ Table B ❑ wl analytical results as an attachment
o :
�; ❑ Table C ❑ Table D
4� ❑✓ Section 8 ❑ wlattachments
❑✓ Section 9 ❑ wlattachments(e.g.,responses for additional contact laboratories or firms)
' ';,` ✓❑ Section 10 ❑
10.2
Certification Statement
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted.Based on my inquiry of the person or persons who manage the system or those persons directly responsible
for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information,including the possibility of fine
and imprisonment for knowing violations.
Name(print or type first and last name) Official title
Lawrence Wolnik Site Director
Signature Date signed
EPA Form 3510-217(Revised 3-19) Page 6

EPA Identification Number NPDES Permit Number Facility Name Farm Approved 03i05/19
110001503105 NC5000064 CNA Holdings LLC-Shelby
OMB No.2040-0004
SECTIONF CHECKLIST AND CERTIFICATION1
10.1 In Column 1 below,mark the sections of Form 2F that you have completed and are submitting with your application. For
each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not
all applicants are required to com fete all sections or provide attachments.
Column 1 Column 2
0 Section 1 ❑ wl attachments(e.g.,responses for additional outfalls)
❑ Section 2 ❑ wl attachments
0 Section 3 0 wl site drainage map
El Section 4 ✓❑ wl attachments
❑ Section 5 ❑ wl attachments
0 Section fi ❑ wl attachments
✓❑ Section 7 [Z] Table A ❑ wl small business exemption request
cc
"y ❑� Table B ❑ wl analytical results as an attachment
c
a
2 ❑ Table C ❑ Table D
U 0 Section 8 ❑ wlattachments
c
y ❑ Section 9 ❑ wlattachments(e.g.,responses for additional contact laboratories or firms)
✓❑ Section 10 ❑
10.2
Certification Statement
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted.Based on my inquiry of the person or persons who manage the system or those persons directly responsible
for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine
and imprisonment for knowing violations.
Name(print or type first and last name) Official title
Lawrence Wolnik Site Director
Signat a Date signed
o� (/� - -zoz z
RECEIVED
DPMLR-Stormnter Program
EPA Form 3510-2F(Revised 3-19) Page 6

EPA Identification Number NPIDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
110001503105 NCS000064 CNA Holdings LLC-Shelby North OMB No.2040-0004
TABLE A.CONVENTIONAL 1 NON CONVENTIONAL PARAMETERS(40
You must provide the results of at least one anal sis for every pollutant in this table.Complete one table for each outfall.See instructions for additional details and re uirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Flow-Weighted Grab Sample Taken Flow-Weighted Events Sampled (new souroelnew
During First During First dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
1. Oil and grease N/A N/A
2. Biochemical oxygen demand(BODs) 13.4 mg/L 6.5 mg/L 8
3. Chemical oxygen demand(COD) 120 mg/L 40.4 mg/L s
4. Total suspended solids(TSS) 57.6 mg/L 14.4 mg/L 8
5. Total phosphorus N/A N/A
6. Total Kjeldahl nitrogen(TKN) N/A N/A
7. Total nitrogen(as N) N/A N/A
pH(minimum) 6.6 s
pH(maximum) 9.0 7.4 a
f Sampling shall be conducted according to sufficiently sensitive test procedures(i.e., methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 7

EPA Identification Number NPDES Pemdt Number Facility Name Outfall Number Form Approved 03/05/19
110001503105 NCSOOOO64 CNA Holdings LLC-Shelby South OMB No.2040-0004
CONVENTIONALTABLE A. / NON CONVENTIONALPARAMETERS 41
You must provide the results of at least one anal sis for every pollutant in this table.Complete one table for each outfa9.See instructions for additional details and re uirements.
charge A�tera lttiaity Tsdta�±ge Sourctof
fmlrun "
I �� 3 # f ►,uii � 1 Num6et of Storm [n#ormatfon
sdif�tIroramr r � S$m useptea�ttlnr }- ' ChrentsSampltjd (newsaurgPfiew -
ttrin��1E'trst tl ftlgers only;
1 F 34?14�iBn O:Mttst ���}.� tntctions)
•t �?`T-•� F zIIIOY
r
Oil and grease I
Biochemical oxygen demand(BODs) 5.3 mg/L 3.9 mg/L 8
Chemical oxygen demand(COD) <50 mg/L <50 mg/L 8
Total suspended solids(TSS) 31.9 mg/L 10 mg/L s
Total phosphorus N/A N/A
Total Kjeldahl nitrogen(TKN) N/A N/A
�E"" Total nitrogen(as N) N/A N/A
pH(minimum) 6.6 8
s
pH(maximum) 7.4 6.9 8
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 7

EPA Ideni icadon Number NPDES Permit Number Facility Name Outfail Number Form Approved 03l05119
110001503105 NCS000064 CNA Holdings LLC-Shelby East OMB No.2040-0004
TABLE • • 1 NON CONVENTIONAL •A-• 1
You must provide the results of at least one anal is for everypollutant in this table.Complete one table for each outfall.See instructions for additional details and uirements.
i 4 ar�� Dai(�Discf�atge � $o
`(Pa1uaC'Pacam r =fib npi Tak_ eTakuj Nuntiber of Storm Elrtfomtattcn
( roelnew
VOW
�.
DurftfgiFlrbt Du1hlg FflBt tfi only,use
3Qdlinut� :30 MtMtiti s)
w)Neig Events Sampled
7 codes in instruction
Oil and grease N/A N/A
Jtr. Biochemical oxygen demand(BODs) 6.5 mg/L 4.6 mg/L s
Chemical oxygen demand(COD) 52 mg/L 28.4 mg/L a
k Total suspended solids JSS) 48.2 mg/L 17.3 mg/L 8
Total phosphorus N/A N/A
F� .� Total Kjeldahl nitrogen(TKN) N/A N/A
F`
x r��
Total nitrogen(as N) N/A N/A
L:., :.
pH(minimum) 7.3 a
pH(maximum) 8.2 7.6 a
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 7

EPA IdenBfrcaiion Number NPOES Pemrlt Number Fadlity Name OuFfall Number Form Approved 03/05/19
110001503105 NCS0004952 CNA Holdings LLC-Shelby 001 OMB No.2040-0004
List each pollutant that is limited in an effluent limitation guideline(ELG)that the facility is subject to or any pollutant listed in the facility s NPDES permit for its process wastewater(if the
facility,is operating under an existing NPDES permit).Complete one table for each outfall.See the instructions for additional details and requirements.
Matximu a BIsC a e, t Aveti a Etai{ Olscha, a 5ourre of
olltttal tiridr� u i (lf�ivallabTe t i�cBsMp efTalsei� +n Gs GraT`Sara to Taken unds i um40r of Storm ar e1n w
tot. ftoviFWetgfited E�►ents:Sampled. t ,
Doting Ftrst Darin First dischargers onty;use
30'Nllnutes: 30.Mirtutes codes in Instnu�ions}
ComposHe Composite,:
pH 8.7 su 8.31 su 9
BOD 21.4 Ibs/day 11 Ibs/day 9
TSS 91.4lbs/day 39.9lbs/day 9
FCOLI BR 20#/100ml 5.6#/100ml 9
1,1-DCE 0.00725lbs/day 0.0043lbs/day 4
1,1-DCEY 0.00725lbs/day 0.0039lbs/day 4
Additional pollutants in attachment
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-21'(Revised 3.19) Page 9

Form 2F-Table B
Supplemental Data
2019 2020 1 2021 2022 #of events
Pollutant Pollutant Code Max Discharge Units sampled
111-TCE 34506 NS NS NS 0.00261 Ibs/day 1
112-TCE 34511 NS NS NS 0.0013 Ibs/day 1
124-TCB CO551 NS NS NS <0.5 ug/I 1
124-TCB QD551 NS NS NS 0.0013 Ibs/day 1
1,2-DCB 34536 <0.012 <0.0145 <0.00241 0.00261 Ibs/day 4
1,2-DCE 32103 <0.012 <0.0145 <0.00241 0.00261 Ibs/day 4
1,2-DCP 34541 <0.012 <0.0145 <0.00241 0.00261 Ibs/day 4
t-12DCEY 34546 <0.012 <0.0145 <0.00482 0.00522 Ibs/day 4
1,3-DCPE 77163 <0.012 <0.0145 <0.00241 0.00261 Ibs/day 4
1,3-DCB 34566 <0.012 <0.0291 <0.0241 0.00261 Ibs/day 4
1,4-DCB 34571 <0.012 <0.0291 <0.0241 0.00261 Ibs/day 4
2,4-DCPH 34601 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
2,4-DMPH 34606 <0.024 <0.0291 <0.0482 0.0537 Ibs/day 4
2,4-DNPH 34616 <0.124 <0.148 <0.0723 0.0806 Ibs/day 4
2,4-DNT 34611 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
26DINITR- QD626 <20 <20 <20 0.0537 Ibs/day 4
2CPHENOL 34586 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
2NPHENOL 34591 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
34-BNZFA 79531 <10 <10 <10 <10.3 ug/I 4
34-BNZFA QD531 NS NS NS 0.0268 Ibs/day 1
46DN-o-C 34657 <0.0124 <0.148 <0.0723 0.0806 Ibs/day 4
4NPHENOL 34646 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
ACENAPEN 34205 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
ACENAPYL 34200 <0.049 <0.0582 <0.0482 0.0537 Ibs/day 4
ACRYLONI 34215 <100 <100 <5 0.013 Ibs/day 4
ANTHRACE QD220 NS NS NS 0.0268 Ibs/day 1
BENZENE 34030 <0.012 <0.0145 <0.001205 0.00013 Ibs/day 4
BNZO-A-A 34526 <10 <10 <10 <10.3 ug/l 4
BNZO-A-A QD526 NS NS NS 0.0268 lbs/day 1
BNZO-A-P 34247 NS NS <10 <10.3 ug/I 2
BENZO(A)- QD247 NS NS NS 0.0268 ibs/day 1
BNZO-K-F 34242 <10 <10 <10 <10.3 ug/I 4
BNZO-K-F QD242 NS NS NS 0.0268 ibs/day 1
B2E PHTH 39100 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
B2E PHTH C0100 NS NS NS <10.3 ug/I 1
CARBNTET 32102 <0.012 <0.0145 <0.00241 0.00261 Ibs/day 4
CHLROBNZ 34301 <0.012 <0.0145 <0.00241 0.00261 Ibs/day 4
CLROETHA 85811 <0.024 <0.0291 <0.00241 0.00261 Ibs/day 4
CHLRFORM 32106 <0.012 <0.0145 <0.00241 0.00261 Ibs/day 4
Cr-TOTAL 1034 <10 <10 <2 0.0104 Ibs/day 4
CHRYSENE 34320 <10 <10 <10 0.0268 Ibs/day 4
COPPER 1042 <20 <20 13.8 25.4 ug/I 4
COPPER- QD042 NS NS NS 0.014 Ibs/day 1
CN-CONC CO720 NS NS NS <10 ug/I 1
CN-QTY QD720 NS NS NS 0.0261 Ibs/day 1
CN-TOT 00720 <10 <10 <10 NS Ibs/day 3
DIETY-PH 34336 <0.049 <0.0582 <0.0482 0.0537 Ibs/day 4
DIMET-PH 34341 <0.024 <0.0291 0.0241 0.0268 Ibs/day 4
DNB PHTH 39110 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
ETHYLBEN 34371 <0.012 <0.0145 <0.00241 0.00261 Ibs/day 4
FLUORANT QD376 NS NS NS 0.0268 Ibs/day 1
FLUORENE 34381 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
TOT HARD 900 NS NS NS 27 mg/I 1
CNA Holdings,LLC-Shelby
NPDES Permit No.NCS000064 Page 1 of 2 September 2022

Form 2F-Table B
Supplemental Data
2019 2020 1 2021 2022 #of events
Pollutant Pollutant Code Max Discharge Units sampled
HCB-Qty QD700 NS NS NS 0.0537 Ibs/day 1
HEXCLBD 39702 <0.049 <0.0582 <0.0482 0.0537 Ibs/day 4
HEXCLBD CO702 N5 NS NS <20.6 ug/I 1
HCE 34396 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
LEAD 1051 <0.024 <0.0291 0.00361 0.00339 Ibs/day 4
METHYLCH 34418 <0.024 <0.0291 <0.00241 0.00261 Ibs/day 4
MECL2 34423 <0.012 <0.0291 <0.00482 0.00522 Ibs/day 4
NAPTHALE 34696 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
NICKEL 1067 <0.024 <0.0291 0.0151 0.013 Ibs/day 4
NITROBEN 34447 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
OIL-GRSE 556 <5 <5.5 <5.7 <5.5 mg/I 4
CERI7DPF TGP3B PASS PASS PASS PASS pass/fail 4
PHENANTH 34461 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
PHENOL 34694 <0.024 40.0291 <0.0241 0.0268 Ibs/day 4
PYRENE 34469 <0.024 <0.0291 <0.0241 0.0268 Ibs/day 4
SILVER 1077 NS NS NS <1 ug/I 1
TETCLETY 34475 <0.012 <0.0145 <0.00018 0.00196 Ibs/day 4
TOLUENE 34010 <0.012 <0.0145 <0.00241 0.00261 Ibs/day 4
TCETHYLE 39180 NS NS NS 0.00261 Ibs/day 1
VINYLCHL 39175 NS NS NS 0.00261 Ibs/day 1
ZINC 1092 NS NS NS <10 ug/I 1
HCB 39700 <20 <20 <20 <20.6 ug/I 4
FLUORANT 34376 <10 <10 <10 <10.3 ug/I 4
ANTHRACE 34220 <10 <10 <10 <10.3 ug/I 4
CNA Holdings, LLC-Shelby
NPDES Permit No.NCS000064 Page 2 of 2 September 2022

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
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)

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources— Stormwater Program
Facility Name: CNAHoldingsLL.0-Shelby
Permit Number: NCS000064
Location Address: 2525 Blacksburg Road
Grover,NC
County: Cleveland
"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 7 [Z�L4date �-3L �zpl
Lawrence Wdnik Site Director
Print or type name of person signing above Title
SPPP Certification 10/13

Attachment 2 (Copy 1)
Supplemental Information
► Current Site Map
► Summary of analytical monitoring results
P. Summary of visual monitoring results
► Summary of best management practices
► Significant changes in industrial activities

Site Map - -

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Analytical Monitoring Results

Attachment 2
Summary of Analytical Monitoring Results
NORTH OUTFALL
Benchmark: 100 30 120 6-9
TSS BOD COD
Period Date (mg/L) mg/L) (mg/L) pH
2H 2O18 11/12/2018 9.2 5.2 120 7.4
1H 2O19 5/11/2019 9.0 8.2 <50 7.7
2H 2O19 10/13/2019 57.6 3.1 <50 7.9
1H 2O20 3/10/2020 8.8 <2.0 <50 8.0
2H 2O20 11/11/2020 3.2 <2.0 <50 7.3
1H 2O21 3/16/2021 3.5 <2.0 <50 6.6
2H 2O21 8/3/2021 2.8 2.8 <50 7.4
1H 2O22 3/16/2022 21.1 13.4 53 6.7
Minimum 6.6
Maximum 57.6 13.4 120 8.0
Average, 14.4 6.5 40.4 7.4
Number of Storm Events Sampledl 8
SOUTH OUTFALL
Benchmark: 100 30 120 6-9
TSS BOD COD
Period Date (mg/L) (mg/L) (mg/L) pH
2H 2O18 11/12/2018 7.9 <2.0 <50 6.7
1H 2O19 5/11/2019 14.7 5.3 <50 7.3
2H 2O19 10/13/2019 31.9 <2.0 <50 7.4
1H 2O20 3/10/2020 2.8 <2.0 <50 6.8
2H 2O20 11/11/2020 12.5 <2.0 <50 6.8
1H 2O21 3/16/2021 2.8 <2.0 <50 6.8
2H 2O21 8/3/2021 3.8 2.4 <50 6.6
1H 2O22 3/16/2022 3.9 <2.0 <50 6.9
Minimum 6.6
Maximum 31.9 5.3 <50 7.4
Avera a 10.0 3.9 25.0 6.9
Number of Storm Events Sampled 8
EAST OUTFALL
Benchmark: 100 30 120 6-9
TSS BOD COD
Period Date (mg/L) (mg/L) (mg/L) pH
2H 2O18 11/12/2018 6.5 <2.0 <50 7.3
1H 2O19 5/11/2019 16.0 5.7 <50 7.6
2H 2O19 10/13/2019 30.3 4.1 <50 7.5
1H 2O20 3/10/2020 14.4 <2.0 <50 8.2
2H 2O20 11/11/2020 13.4 <2.0 <50 7.4
1H 2O21 3/16/2021 7.3 <2.0 <50 7.6
2H 2O21 8/3 2021 2.5 2 <50 7.6
1H 2O22 3/16/2022 48.2 6.5 52 7.8
Minimum 7.3
Maximum 48.2 6.5 52 8.2
Average 17.3 4.6 28.4 7.6
Number of Storm Events Sampled 8
CNA Holdings, LLC-Shelby
NPDES Permit No. NC5000064 September 2022

Visual Monitoring,Results

Attachment 2
Summary of Visual Monitoring Results
NORTH
Erosion/
Floating Suspended deposition at Other
Period Date Color Odor Clarity Solids Solids Foam Oil Sheen outfall indicators
2H 2O18 11/12/2018 Lt Brown None 1 2 1 No No No No
iH 2O19 5/11/2019 Lt Brown None 1 1 1 No No No No
2H 2O19 10/13/2019 Lt Brown None 1 2 2 No No No No
1H 2O20 3/10/2020 Lt Red None 1 2 2 No No No No
2H 2O20 11/11/2020 Lt Red None 1 2 1 No No No No
1H 2O21 3/16/2021 Lt Brown none 2 2 1 No No No No
2H 2O21 8/3/2021 Lt Brown none 1 2 2 No No No No
SH 2O22 3/16/2022 Lt Brown None 1 2 1 No No No No
SOUTH
Erosion/
Floating Suspended deposition at Other
Period Date Color Odor Clarity Solids Solids Foam Oil Sheen outfall indicators
2H 2O18 11/12/2018 Lt Red None 3 3 3 No No No No
1H 2O19 5/11/2019 Lt Brown None 2 1 1 No No No No
2H 2O19 10/13/2019 Lt Brown None 1 2 2 No No No No
1H 2O20 3/10/2020 Lt Brown None 1 3 1 No No No No
2H 2O20 11/11/2020 Lt Brown None 2 2 2 No No No No
1H2O21 3/16/2021 None none 2 1 1 No No No No
2H 2O21 8/3/2021 Lt Brown none 2 2 2 No No No No
1H 2O22 3/16/2022 Lt Brown None 1 1 2 1 No No No No
EAST
Erosion/
Floating Suspended deposition at Other
Period Date Color Odor Clarity Solids Solids Foam Oil Sheen outfall indicators
2H 2O18 11/12/2018 Lt Brown None 1 1 1 No No No No
1H 2O19 5/11/2019 Lt Brown None 1 1 1 No No No No
2H 2O19 10/13/2019 Lt Brown None 3 2 3 No No No No
1H 2O20 3/10/2020 Lt Brown None 2 2 2 No No No No
2H 2O20 11/11/2020 Lt Red None 2 2 2 No No No No
1H 2O21 3/16/2021 Lt Brown none 3 2 2 No No No No
2H 2O21 8/3/2021 Lt Brown none 1 1 2 No No No No
iH 2O22 3/16/2022 Lt Brown None 3 1 2 1 3 1 No No I No No
CNA Holdings,LLC-Shelby
NPDFS Permit No.NCS000064 September 2022

Best Management Practices

Maintenance of Vehicles and Equipment
DOs DONTs
Use drip pans for oil collection. Perform maintenance near an open sewer
drain.
Properly dispose of all oils and lubricants.
Maintain spare parts
Promptly repair/replace defective equipment.
Loading/Unloading of Chemical Materials
Tank truck unloading/loading are restricted to areas having secondary containment capable of holding at
least a single hose volume. The area beneath tank trucks is inspected for spills before and after
unloading/loading.
DOs DONTs
Block off nearby open drainage ditches until all Allow transfer of bulk liquids unless a facility
loading/unloading activities are completed, emDlovee is Dresent.
Use gates and signage to restrict access during Operate pumps above acceptable limits
unloading and loading.
Locate hose connections over drip pads
Construct temporary berms while conducting
loading/unloading activities of large quantities of
hazardous liquids
Clean up spills in accordance with facility spill plan
Liquid Storage in Aboveground Storage Tanks
All storage units are fabricated from appropriate materials of construction for use conditions. All tanks are
visually inspected daily for leaks as part of normal operation procedures. In addition, each tank is
periodically inspected under the site Preventive Maintenance Program and Mechanical Integrity Program.
DOs DOWN
Regularly inspect secondary containment ! Leave secondary containment valves open
berms and walls for cracks, breaks and gaps. unless releasing storm water that has been
Records: Semi-annual inspection tested.
Perform visual inspections of accumulated 1 Leave used open/uncovered containers
storm water prior to its release. Maintained by outside exposed to storm water.
the Individual Business Units. EHSA Form:
Secondary Containment inspection Form.
Ensure that all employees receive storm water Release storm water not meeting
training at least annually. requirements.
Clean up any spills in accordance with facility Overfill tanks.
spill plan. i

waste Management and Storage
DOs DONTs
Keep all waste containers closed. Store incompatible wastes near each other.
Label all containers as required by law. Store wastes in a non-designated area.
Regularly inspect waste containers and Store waste in high traffic areas.
storage areas for signs of leaks.
Clean up any leaks or spills in accordance with
the facility contingency plan.
Outside Storage of Raw Materials, Finished Products and By-Products
Dos DONTs
Regularly inspect drums for minor leaks and Store materials in high traffic areas where they
spills. may be punctured or knocked over.
Clean up spilled material promptly in accordance Store materials without proper lids.
with facility spill plan.
Maintain the minimum inventory necessary for Discharge storm water from storage areas that
operations. does not meet requirements.
Label all containers and tanks.
Lawn Maintenance and Pesticide Application
Contract personnel maintain Celanese Shelby lawns. This service projects a positive image of the facility and
controls pests. Lawn maintenance includes herbicide and fertilizer application. In order to control pests,
pesticides and insecticides may be applied around the facility, particularly in the office buildings.
DOs DONTs
Store maintenance equipment like lawn Over-apply chemicals. Use only the amount
mowers under a roof. necessary to do the job.
Dispose of unused Apply chemicals if a heavy rain is anticipated
pesticides/herbicides/insecticides properly. in the next few days.
Keep a minimum amount of these chemicals
in stock at the facility.
Apply pesticides, herbicides/insecticides in
accordance with label instructions.

Construction
Construction activities may occur at the facility on an irregular basis. Because of the nature of construction,
soil movement is a major component of most construction projects. Soil erosion and runoff are controlled
during construction activities.
DOs DONTs
Put up a silt fence to limit sediment runoff from i Establish uncontrolled soil piles near facility
the construction area. drains.
Use dust suppressant measures, like watering, if Leave contaminated soil uncovered at
heavy construction is occurring. the site.
Ensure mud/debris are minimized prior to Dispose of soil improperly.
entering public highways.
Re-seed or re-forest to minimize erosion.
Put up retention walls on steep slopes.
Equipment Painting
Tanks, piping, and other equipment are painted at the facility on an irregular basis.
DOs DON'Ts
Store paints in properly labeled containers in Maintain a large inventory of paints at the
000d condition. facilitv.
Protect soil using tarps and remove stained If contractor, leave unused paints and supplies
soil after paintinq. on plant site.
Collect all sand blast material and dispose of Dispose in the general plant trash
properly.
Dispose of paint residue, rags, tarps and
containers properly. Generally these materials
fall under Resource Conservation and Recovery
Act (RCRA).
Clean painting equipment properly and dispose
of old cleaning materials property. Generally
these materials fall under Resource
Conservation and Recovery Act (RCRA).
Clean up any spills promptly in accordance
with facility spill plan and notify the
Environmental Engineer(s) or ESHA
Technician(s) .
Recycling Areas
DOS DONTs
Dispose of scrap metals, which are clean of oil Use any faulty or damaged hoses or valves
and grease in the scrap metal dumpster. during unloading, which could contaminate
materials for recvclina.
Cardboard stations with clean cardboard only.

Significant Industrial Changes
During the permit term, the facility shut down the Compounding operations within the facility. This change
did not impact the stormwater activity at the facility.

Attachment 2 (Copy 2)
Supplemental Information
► Current Site Map
► Summary of analytical monitoring results
► Summary of visual monitoring results
► Summary of best management practices
► Significant changes in industrial activities

Site:Map

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Analytical Monitoring Results

Attachment 2
Summary of Analytical Monitoring Results
NORTH OUTFALL
Benchmark: 100 30 120 6-9
TSS BOD COD
Period Date mg/L) (mg/L) mg/L) pH
2H 2O18 11/12/2018 9.2 5.2 120 7.4
1H 2O19 5/11/2019 9.0 8.2 <50 7.7
2H 2O19 10/13/2019 57.6 3.1 <50 7.9
1H 2O20 3/10/2020 8.8 <2.0 <50 8.0
2H 2O20 11/11/2020 3.2 <2.0 <50 7.3
1H 2O21 3/16/2021 3.5 <2.0 <50 6.6
2H 2O21 8/3/2021 2.8 2.8 <50 7.4
1H 2O22 3/16/2022 21.1 13.4 53 6.7
Minimum 6.6
Maximum 57.6 13.4 120 8.0
Average- 14.4 6.5 40.4 7.4
Number of Storm Events Sampledl 8
SOUTH OUTFALL
Benchmark: 100 30 120 6-9
TSS BOD COD
Period Date (mg/L) (mg/L) (mg/L) pH
2H 2O18 11/12/2018 7.9 <2.0 <50 6.7
1H 2O19 5/11/2019 14.7 5.3 <50 7.3
2H 2O19 10/13/2019 31.9 <2.0 <50 7.4
1H 2O20 3/10/2020 2.8 <2.0 <50 6.8
2H 2O20 11/11/2020 12.5 <2.0 <50 6.8
1H 2O21 3/16/2021 2.8 <2.0 <50 6.8
2H 2O21 8/3/2021 3.8 2.4 <50 6.6
1H 2O22 3/16/2022 3.9 <2.0 <50 6.9
Minimum 6.6
Maximum 31.9 5.3 <50 7.4
Average 10.0 3.9 25.0 6.9
Number of Storm Events Sampledl 8
EAST OUTFALL
Benchmark: 100 30 120 6-9
TSS B D COD
Period Date (mg/L) (mg/L) (mg/L) pH
2H 2O18 11/12/2018 6.5 <2.0 <50 7.3
1H 2O19 5/11/2019 16.0 5.7 <50 7.6
2H 2O19 10/13/2019 30.3 4.1 <50 7.5
1H 2O20 3/10/2020 14.4 <2.0 <50 8.2
2H 2O20 11/11/2020 13.4 <2.0 <50 7.4
1H 2O21 3/16/2021 7.3 <2.0 <50 7.6
2H 2O21 1 8/3/2021 2.5 1 2 <50 7.6
iH 2O22 1 3/16/2022 48.2 6.5 52 7.8
Minimum 7.3
Maximum 48.2 6.5 52 8.2
Average_ 17.3 4.6 28.4 7.6
Number of Storm Events Sampledl 8
CNA Holdings, LLC-Shelby
NPDES Permit No. NCS000064 September 2022

Visual Monitoring Results

Attachment 2
Summary of Visual Monitoring Results
NORTH
Erosion/
Floating Suspended deposition at Other
Period Date Color Odor Clarity Solids Solids Foam Oil Sheen outfall indicators
2H 2O18 11/12/2018 Lt Brown None 1 2 1 No No No No
1H 2O19 5/11/2019 Lt Brown None 1 1 1 No No No No
2H 2O19 10/13/2019 Lt Brown None 1 2 2 No No No No
1H 2O20 3/10/2020 Lt Red None 1 2 2 No No No No
2H 2O20 11/11/2020 Lt Red None 1 2 1 No No No No
1H 2O21 3/16/2021 Lt Brown none 2 2 1 No No No No
2H 2O21 8/3/2021 Lt Brown none 1 2 2 No No No No
1H 2O22 3/16/2022 Lt Brown None 1 1 2 1 1 1 No No No No
SOUTH
Erosion/
Floating Suspended deposition at Other
Period Date Color Odor Clarity Solids Solids Foam Oil Sheen outfall indicators
2H 2O18 11/12/2018 Lt Red None 3 3 3 No No No No
1H 2O19 5/11/2019 Lt Brown None 2 1 1 No No No No
2H 2O19 10/13/2019 Lt Brown None 1 2 2 1 No No No No
1H 2O20 3/10/2020 Lt Brown None 1 3 1 No No No No
2H 2O20 11/11/2020 Lt Brown None 2 2 2 No No No No
1H 2O21 3/16/2021 None none 2 1 1 No No No No
2H 2O21 8/3/2021 Lt Brown none 2 2 2 No No No No
1H 2O22 3/16/2022 Lt Brown None 1 2 1 No No No No
EAST
Erosion/
Floating Suspended deposition at Other
Period Date Color Odor Clarity Solids Solids Foam Oil Sheen outfall Indicators
2H 2O18 11/12/2018 Lt Brown None 1 1 1 No No No No
1H 2O19 5/11/2019 Lt Brown None 1 1 1 No No No No
2H 2O19 10/13/2019 Lt Brown None 3 2 3 No No No No
1H 2O20 3/10/2020 Lt Brown None 2 2 2 No No No No
2H 2O20 11/11/2020 Lt Red None 2 2 2 No No No No
1H 2O21 3/16/2021 Lt Brown none 3 2 2 No No No No
2H 2O21 8/3/2021 Lt Brown none 1 1 2 No No No No
1H 2O22 3/16/2022 Lt Brown None 3 2 3 No No No No
CNA Holdings,LLC-Shelby
NPDES Permit No.NCS000064 September 2022

Best Management Practices

Maintenance of Vehicles and Equipment
DOs DONTs
Use drip pans for oil collection. Perform maintenance near an open sewer
drain.
Properly dispose of all oils and lubricants.
Maintain spare parts
Promptly repair/replace defective equipment.
Loading/Unloading of Chemical Materials
Tank truck unloading/loading are restricted to areas having secondary containment capable of holding at
least a single hose volume. The area beneath tank trucks is inspected for spills before and after
unloading/loading.
DOs DON'TS
Block off nearby open drainage ditches until all Allow transfer of bulk liquids unless a facility
loading/unloading activities are completed. emdovee is present.
Use gates and signage to restrict access during Operate pumps above acceptable limits
unloading and loading.
Locate hose connections over drip pads
Construct temporary berms while conducting
loading/unloading activities of large quantities of
hazardous liquids
Clean up spills in accordance with facility spill plan
Liquid Storage in Aboveground Storage Tanks
All storage units are fabricated from appropriate materials of construction for use conditions. All tanks are
visually inspected daily for leaks as part of normal operation procedures. In addition, each tank is
periodically inspected under the site Preventive Maintenance Program and Mechanical Integrity Program.
DOs DON'TS
Regularly inspect secondary containment Leave secondary containment valves open
berms and walls for cracks, breaks and gaps. unless releasing storm water that has been
Records: Semi-annual inspection tested.
Perform visual inspections of accumulated Leave used open/uncovered containers
storm water prior to its release. Maintained by outside exposed to storm water,
the Individual Business Units. EHSA Form:
Secondary Containment inspection Form.
Ensure that all employees receive storm water Release storm water not meeting
training at least annually. requirements.
Clean up any spills in accordance with facility Overfill tanks.
spill plan.

Waste Management and Storage
DOs DONTs
Keep all waste containers closed. Store incompatible wastes near each other.
Label all containers as required by law. Store wastes in a non-designated area.
Regularly inspect waste containers and Store waste in high traffic areas.
storage areas for signs of leaks.
Clean up any leaks or spills in accordance with
the facility contingency plan.
Outside Storage of Raw Materials, Finished Products and By-Products
DOs DONTs
Regularly inspect drums for minor leaks and Store materials in high traffic areas where they
spills. may be punctured or knocked over.
Clean up spilled material promptly in accordance Store materials without proper lids.
with facility spill plan.
Maintain the minimum inventory necessary for discharge storm water from storage areas that
operations. does not meet requirements.
Label all containers and tanks.
Lawn Maintenance and Pesticide Application
Contract personnel maintain Celanese Shelby lawns. This service projects a positive image of the facility and
controls pests. Lawn maintenance includes herbicide and fertilizer application. In order to control pests,
pesticides and insecticides may be applied around the facility, particularly in the office buildings.
DOs DON'Ts
Store maintenance equipment like lawn Over-apply chemicals. Use only the amount
mowers under a roof. necessary to do the job.
Dispose of unused Apply chemicals if a heavy rain is anticipated
pesticides/herbicides/insecticides properly. in the next few days.
Keep a minimum amount of these chemicals
in stock at the facility.
Apply pesticides, herbicides/insecticides in
accordance with label instructions.

Construction
Construction activities may occur at the facility on an irregular basis. Because of the nature of construction,
soil movement is a major component of most construction projects. Soil erosion and runoff are controlled
during construction activities.
DOs DONTs
Put up a silt fence to limit sediment runoff from Establish uncontrolled soil piles near facility
the construction area. drains.
Use dust suppressant measures, like watering, if Leave contaminated soil uncovered at
heavy construction is occurring, the site.
Ensure mud/debris are minimized prior to Dispose of soil improperly.
entering public highways.
Re-seed or re-forest to minimize erosion.
Put up retention walls on steep slopes.
Equipment Painting
Tanks, piping, and other equipment are painted at the facility on an irr ular basis.
DOs DONTs
Store paints in properly labeled containers in Maintain a large inventory of paints at the
aood condition. facilitv.
Protect soil using tarps and remove stained if contractor, leave unused paints and supplies
soil after painting. on plant site.
Collect all sand blast material and dispose of Dispose in the general plant trash
properly.
Dispose of paint residue, rags, tarps and
containers properly. Generally these materials
fall under Resource Conservation and Recovery
Act (RCRA).
Clean painting equipment properly and dispose
of old cleaning materials properly. Generally
these materials fall under Resource
Conservation and Recovery Act (RCRA).
Clean up any spills promptly in accordance
with facility spill plan and notify the
Environmental Engineer(s) or ESHA
Technician(s) .
Recycling Areas
DOs DONTs
Dispose of scrap metals, which are clean of oil Use any faulty or damaged hoses or valves
and grease in the scrap metal dumpster. during unloading, which could contaminate
materials for recvclina.
Cardboard stations with clean cardboard only.

Significant Industrial Changes
During the permit term, the facility shut down the Compounding operations within the facility. This change
did not impact the stormwater activity at the facility.