NC0070637_Issuance of Permit_19990324

�f North Carolina
:rnent of Environment
�tural Resources
of Water Quality
3. Hunt, Jr. Governor
McDevitt, Secretary
Stevens, Director
May 24, 1999
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Mr. Thomas
__ ._ e..
,,. III"
u._.
Production Manager
Kurz Transfer Products
4939 North NC Highway 150
Lexington, North Carolina 27292
Subject: Final NPDES Permit
Permit No. NCO070637
Kurz Transfer Products
Davidson County
Dear Mr. Amato:
In accordance with the application for a discharge permit received on February 16, 1998, the Division
forwarding herewith the subject NPDES permit. This permit is issued pursuant to the requirements
is
of
North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina
and the U.S. Environmental Protection Agency dated becember 6, 1983, and as subsequently amended.
Please note the following changes from the previous permit (as indicated in the draft) have been finalized:
• Permittee and facility name has changed, and address has been revised, as indicated on the renewal
application.
• Quarterly monitoring for total nitrogen and phosphorus has been added to outfall 001. This
change is consistent with an effort to gather more data about nutrient loading in this portion of the
watershed.
• Up and downstream monitoring has been removed from outfall 002 (boiler blowdown), in
accordance with the facility's request.
Please note a` change to the final permit. Per a telephone conversation with Mr. Robert Wallace on May
61P 1999, this facility does not use chlorine for disinfection at outfall 001. Therefore, a footnote has been
added that exempts the facility from monitoring for Total Residual Chlorine (TRC) at 001 as long as
chlorine is not used for disinfection.
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina, General Statutes, and filed with the Office of Administrative
Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such demand is made,
this decision shall be final and binding.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]/FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Please take note that this permit is not transferable. Part II, E. 4. addresses the requirements to be
followed in case of change in ownership or control of this discharge. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Land Resources or any
other Federal or Local governmental permit that may be required.
If you have any questions or comments concerning this permit, please contact Charles Weaver at (919)
733-5083, extension 511.
Sincerely,
t3riginal Signed By
Llavid A. Goodrich
Kerr T. Stevens
Enclosure
cc: Winston-Salem Regional Office/Water Quality Section
Division of Environmental Health (L)EH)
Central Files
NPDES Unit
Mr. Roosevelt Childress, EPA
Point Source Compliance Enforcement Unit

e
4-
Permit No. NCO070637
DEPARTMENT
STATE OF NORTH CAROLINA
OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
Incompliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
Kurz & Partners, L.P.
is hereby authorized to discharge wastewater from a facility located at
Kurz Transfer Products
4939 North NC Highway 150
Lexington
Davidson County
to receiving' waters designated as Reedy Creek in the Yadkin -Pee Dee River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III, and IV hereof.
This permit shall become effective July 1, 1999.
This permit and authorization to discharge shall expire at midnight on May 31, 2004.
Signed this day May 24, 1999.
Original Signed
David Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

SUPPLEMENT TO PERMIT COVER SHEET
Kurz & Partners, L.P.
is hereby authorized to.
1. Continue to operate a 0.0015 MGD wastewater treatment facility consisting of a
recirculating sand filter, 1500-gallon septic tank, dosing tank, and a chlorine contact
tank (Outfall 001), and discharge boiler blowdown (Outfall 002), located at Kurz
Transfer Products, 4939 North.NC Highway 150, Lexington, Davidson County, and
2. Discharge from said treatment works at the location specified on the attached map
into Reedy Creek, which is classified as WS4V waters in the Yadkin -Pee Dee River
Basin.

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' "� _ _ - NC0070637 - - � - � �� � ' _ � _
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Latitude: 35 �4'47" 001 3� �4 5 ) .� `�
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Longitude: 80 °l 9' S 0" (001 } 80 °l 9' S 8" (002) -
Quad'#: D17NE "Welcome" Kurt Transfer Products
Stream Class:... WS-Iy NC0070637
Receiving Stream: Reedy Creek No Y't�l
Davidson County

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,cribed ;
.,zd perrrut.
. copy of the draft permit is
available by writing Dr call-
' ing the Division of Environ-
mental Management, P.O.
- Box 29535, Raleigh, North
` Carolina 27626-0535, (919)
733-7015.
' The application and other in -
_formation may b�=inspected
at these locations during nor-
�mal office hours. Copies of
the information on file are
available upon request and
payment of the costs of
:reproduction. All such com-
ments or requests regarding
. a 'proposed permit should
make reference to the
NPDES permit number list-
ed below. ,
:Date March 8, 1999
• David A. Goodrich
" A. Preston Howard Jr., P.E.,
Duector
Division of
. Environmental Management
f 'Public notice of intent to is -
,sue aState NPDES permit to
•the following:
.1. NPDES No. NC0031950.
: •Davidson County Board of
Education, PO Boz �-2057,
- Lexington; 'NC 27293 has
-applied for a permit renewal
'for a facility located at West
.Davidson High School, off
•NCSR 1213, east of Tyro,
;Davidson County. The fa-
�cility discharges 0.007 MGD
• � 'of treated domestic wastewa=
Ater from one outfall into an
- unnamed tributary to North
� • � Potts Creek, a Class C
� ` 'stream in the Yadkin -Pee
Dee River Basin �hich:has a
' ►'7Q10 flow of 0 cfs• and a
- � ,30Q2 flow of 0 cfs: Ammo-
nta, BODS ` and � dissolved
,oxygen are water "; 'quality
limited. For some parame-
ters, the available load ca-
pacity of the immediate
' ;receiving water will becon=
- � sumed. This may ` affect
: `future water quality based
• `• effluent limitations for addi-
tional dischargers within. this
_ ;portion of the watershed. ��•.
_ , : �� _.
� - ' ` 2. NPDES No. �NC0070637.
1•-
. - -' Kurz and Partners, L.P.;
4939 Nortli NC.: Highway
�� � 150, Lexington,' NC 27292
_ `; has applied for a permit re-
- . newal for a facility located at
- : �� Kurz Transfer Products;
- ," � 4939 North NC =Highway
' 150, Lexington," Davidson
. "County, The.,: facifity dis- .
- charges 0.0015 MGD of
', � �' treated domestic wastewater
' from outfall 001 and boiler
• ; _ ; : blowdown from • outfall: 002.-
-� This discharge is to an un-
named tributary to Reedy
Creek, a Class WS-IV
�- stream in the _Yadkin -Pee
I - 'Dee River Basin which has a
i � 7Q10 flow of 0.91 cfs. No
- � parameters are water quality
,� limited, but this discharge
may affect future waste load
- �•� allocations. - � ; �--_�
' � 3. NPDES No. NC 0023604.
Chomasville>:. Furniture :. In -
from one outfall into an un- Road, Clemmons, Davidson
named tributary to Abbotts County. The facility dis-
Creek, aClass WS V & B charges 0.100 MGD of treat -
steam in the Yadkin -Pee Dee ed ,: domestic =: wastewater
River Basin which has a from one outfall` into. the
7Q10 flow of 0 cfs and a Yadkin River; a Class WS-
30Q2 flow' of 0 -cfs. Ammo- IV stream in the Yadkin -Pee. Seal)
nia, � BODS � and' -dissolved- Dee River Basin which has a'
oxygen", are .water quality. 7Q10 flow; of 552 -cfs. The . td�,�,
limited..' For ..some_, parame- facility ._ is" - permitted4.for an ,:; ,,, �:
tens; ' � the`�`� available �`"load ultimate" expansion` � to : 0.140: :.� � °��,
capacity:< of :thee: immediate MGD:.: No :parameters.;. are �, r��' •A
receiving water: will becon- water � quality:; limited; .:.but a .-. � ':�
sumed. -a Tliis..�:-may affect this discharge" inay affect_ fu-
future .water.: quality. based ture allocations:;;: �. � A:
effluent limitations for- addi= ,, - - o
tional dischargers within. this 11,-. NPDES No.N00083941:
portion of the,watershed _ , y_ Heater Utilities, Inc: PO Boa � �� o
-- _� - -� - _ , =':�` � _' - , �- �� 29535, Cary, NC 27519 has `�',��`
6. NPDES No. NC0029947. applied for � a permit renewal � ti.-a
Davidson � .County ; Schools; � for :' a' facility _� located at �"
PO Box = 2057 � Lexington, . Spring' Creek Subdivision,
NC 27293 has applied for a ,Central._ . Road; : Clemmons,
permit'"ienewal for a facility Davidson'' County. The' fa -
located at Davidson Co Sch- cility discharges 0.08_ MGD
Churchland Elem; NC Hwy. of treated domestic wastewa-
150, Churchland,. lt?avidson ter: from., one outfall into
County: '�tte: ;facility' dis- Fryer Creek; a, Class WS-IV
charges � 0.0037�� MGD . of stream :inY� the :_Yadkin -Pee
treated domestic wastewater Dee River Basin which has a
from one outfall�.into-an_ un-- 7Q10 flow of 0.64 cfs-and a_
named_= tributary�,,,to�= South 30Q2';, flow_ :,;;;of=:= 2_.03.. cfs.
Potts Creek, a Class C Ammonia is water quality
stream ; �A. the.'.Yadkin-Pee: limited;= and. ,this discharge
Dee River Basin which has a may, affect future waste load
7Q10 flow`` of O ycfs` and `a- allocations. ,•:. �: °' ' �; � ._: .
30Q2 flow of.0 cfs. Ammo- �_ ..::. � "'
nix, BODS ; and � dissolved- .`= _March 10, 1999
oxygen , are � water quality � .: ,:
limited. For some parame-
ters, the a�•ailable load
capacity of the immediate
receiving water will be con-
sumed. This may affect
future water quality based
effluent limitations for addi-
tional dischargers within this
portion of the watershed.
.. _ Y -
7: NPDES "No. NC0042056.
Davidson';County' Board�i of
Education,: PO Boa 205T,
Lexington � NC, 27293 � has
applied for a permit renewal
for a facility located ' at
Davidson County Schools -
Tyro Middle School, NCSR
1215, southeast_ of Tyro, Da-
vidson County: The facility:
discharges' 0.005 MGD . of
treated domestic wastewater
from one � outfalf into an� un-
named tributary, to North
Potts Creek, �-a - Class � C
stream: �in = the' -.Yadkin -Pee
Dee River Basin which has a,
7Q10 flow of. 0,: cfs and a
30Q2 flow of 0 cfs: -Ammo=
nix, BODS. and dissolvedj.
oxygen are water quality ``-
limited.= .For: some parame-
ters, ,the: "available: load � ca- '
pacity �.:of .., the.: immediate
receiving water. ,will be con-
sumed. This -may=- affect
future water quality based
effluent limitations for addi-
tional dischargers�,within this
portion of the watershed.
8. NPDES No.° NC0041602::
Davidson County Board of
Education, . PO... Box 2057,
Lexington, NC 27293 has
applied for a permit renewal
for a facility located at Da
vidson County SchoolsY- Sit=
ver. Valley .Elementary,• - in-.
tersection of NCSR` 2416 &
NCSR 2205, Denton, David-
son County...` The facility
���"J
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E.,
MEMORANDUM
Director
March 1691999
To: Hornlean Chen
Division of Environmental Health
From: Kim Murphy
Subject: Review of DRAFT PERMIT
Kurz Transfer Products
Davidson County
NCO070637
A W
LT!IF A
Please indicate below your agency's position or viewpoint on the DRAFT permit and
return this form by 4/5/99. If you have any questions on the draft permit, please contact
Bethany Bolt at 919/733-5083 ext. 551.
RESPONSE:
Signed
This agency has reviewed the draft permit and determined that the proposed
discharge will not be sufficiently close to any existing or know proposed
public water supply intake so as to create an adverse effect on water quality.
We concur with the issuance of this permit provided the facility is operated
and maintained properly, the stated effluent limits are met prior to discharge,
and the discharge does not contravene the designated water quality standards.
Concurs with issuance of the above permit, provided the following conditions
are met:
Opposes the issuance of the above permit, based on reasons stated below, or
attached:
10
Date: ��n c
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
f�epartment of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E.,
Mr. Thomas Amato
Production Manager
Kurz Transfer Products
4939 North NC Highway 150
Lexington, North Carolina 27292
Dear Mr. Amato:
Director
i
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCE:
March 3, 1999 _,(-�rd�""
N��ti� � he ,
f .��,
�� � � �
� � C- � ��.� � 4 �Q
� � � ��e. t
Subject: NPDES Permit Renewal Application
Permit No. NC0070637
Kurz Transfer Products
Davidson County
Enclosed with this letter is a copy of the draft permit for the above referenced facility. I encourage you to
review these documents very carefully to ensure thorough understanding of the information, conditions,
and requirements contained therein.
You should be aware that the following changes have been incorporated into your permit:
• Permittee and facility name has changed, and address has been revised, as indicated on the renewal
application. Please verify the accuracy of these changes.
• Monitoring for Total Residual Chlorine (TRC) 2/week has been added to outfall 001, since the
renewal application indicated chlorine is used for disinfection.
• Quarterly monitoring for total nitrogen and phosphorus has been added to outfall 001. This
change is consistent with an effort to gather more data about nutrient loading in this portion of the
watershed.
• Up- and downstream monitoring has been removed from outfall 002 (boiler blowdown), in
accordance with the facility's request.
Please review the draft permit carefully and submit any comments to David Goodrich no later than thirty
(30) days following receipt at the following address:
NCDENR
DWQ/Water Quality Section
NPDES Unit
Post Office Box 29535
Raleigh, North Carolina 27626-0535
If you have any questions or comments concerning this draft permit,
[phone], extension 551.
Enclosure
cc: NPDES Unit
Division of Environmental Health (DEH)
please contact Bethany A. Bolt at
NPDES Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]/FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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Staff Review and Evaluation
NPDES Wastewater Permit (NC0070637) Fact Sheet
Facility Information
Facility Name:
Kurz Transfer Products
NPDES No.:
NCO070637
Permitted Flow (MGD):
Facility Class:
0.0015 (001)
I
County:
Regional Office:
Davidson
Winston-Salem
Facility/Permit Status;
(i.e. New, Modification, Existing or
Renewal)
Renewal
USGS Topo Quad:
D17NE,
" Welcome"
Stream Characteristics
Receiving Stream:
303(d) Status:
Reedy Creek
Not Listed as impaired.
Stream Classification:
WS-IV
Winter 7Q10 (cfs):
1.82
Subbasm:
03-07-04
30Q2 (cfs):
--
Drainage Area (mi ):
18.36
Average Flow (cfs):
16.7
Summer 7Q 10 (cfs)
0.91
IWC (%):
0.25
Proposed changes:
ation
er Page
over
Effluent Limitations and
Monitoring Requirements A(1).
Effluent Limitations and
Monitoring Requirements A(1)
P
Changed P
ermittee name to Ku
& Partners, L.P./Name to Kurz
Transfer Products
• changes
mange or �wnersnipilvame rorm
included with renewal application.
pdated location of facility. Renewal application recei
2/16/98.
T,
orme
(TRC) monitoring 2/week.
Total nitrogen ("1'N) and
phosphorus (TP) monitoring
changed from quarterly to
monthly.
Effluent Limitations and Removed U, D temperature
Monitoring Requirements A(2). monitoring.
According to renewal application,
chlorine is used for disinfection.
Monitoring per 2B .0500s.
Per 12/7/98 Memo from Steve
Pellei outlining nutrient monitoring
strategy for Yadkin sub -basins.
Given 002 location and discharge
amount, discharge never makes it
to Reedy Creek. Also consistent
with General Permit requirements
for boiler blowdown.
Effluent Limitations and Moved biocide condition to Updated format.
Monitoring Requirements A(2). effluent page.
Compliance Schedule: N/A.
Special Condition(s): N/A.
Compliance History
• Flows normally run 200-1400 gpd; have been as high as 2200 gpd.
• pHs and temps. are fine. TSS usually <5 mg/1 or slightly above.
Peak flows were higher in '98.
• Ammonia usually 2-10 mg/1, depending on time of year. BODS typically <10 mg/le
1
02/16/99

Staff Review and Evaluation
NMEN Wastewater Permit (NC0070637) Fact Sheet
• 12/23/96 Compliance Evaluation Inspection revealed facility was well -maintained and had no
problems.
Additional Comments
• There are two Reedy Creeks; Huffmans Cr drains to this one. No ambient stations are nearby the
discharge. No particular strategies for this portion of the watershed in the Basinwide Plan.
• Outfall 002 will apparently need to moved in the future because the State or County is purchasing
land for road construction; however, facility knows nothing for certain at this time.
• Facility originally requested an expansion in flow to 2000 gpd but decided to withdraw request in lieu
of preparing an Engineering Alternatives Analysis (EAA). Not sure if facility is still planning to
install two new toilets and two new sinks, as indicated on the application, but flows should be
checked if it is.
Proposed Schedule:
Draft Permit to Public Notice: 3/3/99
Permit Scheduled to Issue: 4/26/99
State Contact
If you have any questions on any of the above information or on the attached permit, please
contact Bethany Bolt at [phone], extension 551.
Copies of the following are attached to provide further information on the permit development:
• TRC and Ammonia Calculations
• Existing Permit
NPDES Recommendation by:
Regional Office Comments:
[USkD
NPDES �.mL
A4-4-,t ca.lk C k
a- err-L.L a.�t
n.40. NCPo7o�33.
Signature:
Regional Recommendation by:
Reviewed By:
Signature:
Date:
Regional Supervisor:
%/ y
Signature:
Date
NPDES Unit:
,ll
2
02/ 16/99

NC0070637
Facility: Kurz Transfer Products
Discharge to: Reedy Creek
Stream class and index #: WSW3 12=96=(0.7)
Residual Chlorine Ammonia as NH3
(summer)
7Q10 (CFS) 0.91 7Q10 (CFS) 0.91
DESIGN FLOW (MGD) 0.0015 DESIGN FLOW (MGD) 0.0015
DESIGN FLOW (CFS) 0.002325 DESIGN FLOW (CFS) 0.00233
STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0
UPS BACKGROUND LEVEL (UG/L 0 UPS BACKGROUND LEVEL (MG/L) 0.22
IWC (%) 0.25 IWC (%) 0.25
Allowable Conc. (ug/1) 6,670.8 Allowable Concentration (mg/1) 306.3
minimum = 2
Ammonia as NH3
(winter)
7Q10 (CFS) 1.82
Fecal Limit Not Required DESIGN FLOW (MGD) 0.0015
Ratio of 391.4 :1 DESIGN FLOW (CFS) 0800233
STREAM STD (MG/L) 1.8
UPS BACKGROUND LEVEL (MG/L) 0.22
IWC (%) 0.13
Allowable Concentration (mg/1) 1,238.6
minimum = 4

Permit No. NC00i0631
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
TIONAL POLLUTANT DISCHARGE ELIMINATION SYSTE
In compliance with the provision of North Carolina General Statute 1�3-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
_�tt� Z�xr� � �. P
is hereby authorized to discharge wastewater from a facility located at
' ;- Pnmrporaied
9 WR Highway 150
Lexington
Davidson County
to receiving waters designated as Reedy Creek in the Yadkin -Pee Dee River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth LA
Parts I, II, and III hereof.
This permit shall become effective•-T 1-�96
This permit and the authorization to discharge shall expire at midnight on
�lgncd tl'i1S tiay = ^ la , t
f js
A. Preston Howard, Jr., P.E,, Director
Division of Environmental Management:
By Authority of the Environmental. Management Comrnissian

Permit No. NC000637
SUPPLEMENT TO PEINJVU I COVER SHEET
rated
is hereby authorized to:
1. Continue to operate a 1500 gallon per day wastewater treatment facility consisting of a
recirculating sand filter, 1500 gallon septic tank, dosing tank, and a chlorine contact tank
(Outfall 001), and discharge boiler blowdown (Outfall 002) located at Piedmont Converting,
Incorporated, e ;Highway 150, Lexington, Davidson County;� perm-1t), and
C.
2 . Discharge from said treatment works at the location specified on the attached rnap into Reedy
Creek which is classified Class WS-IV waters in the Yadkin -Pee Dee River Basin.

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_ DISCHARGE LOCATION — o. 7891
OOl 002 � f\ - _ .. _-
- PIEDMONT CONVERTING, INC.
` �� � �-- _ - 001 -REEDY CREED �:;= �`� = ��_
002 - U l�TNAMED TRIBUTARY TO xD CIEI� = . - - -� \a
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Part III
Permit No. NCO070637
E. Biocide Condition
The permittee shall not use any biocides except those approved in conjunction with the permit
application. The permittee shall notify the Director in writing not later than ninety (90) days prior
to instituting use of any additional biocide used in cooling systems which may be toxic to aquatic
life other than those previously reported to the Division of Environmental Management. Such
notification shall include completion of Biocide Worksheet Form 101 and a map locating the
discharge point and receiving stream.

KURZ TRANSFER PRODUCTS, L.P.
Ms. Bethany Bolt
NCDENR
Division of Water Quality
Post Office Box 29535
Raleigh, NC 27626-0535
Re:
Dear Ms. Bolt;
Kurz Transfer Products
Lexington, NC
NPDES Permit No. NCO070637
February 127 1999
We have reviewed approximately one year of weekly flow monitoring
measurements and determined that our February 12, 1998 permit renewal application
needlessly requested an increase in the monthly average flow discharge limitation from
1500 gpd to 2000 gpd. Weekly flow monitoring records indicate a monthly average
flow of around 1000 gpd, even after expansion of our workforce. Our 2/12/98 request
for permit renewal and the accompanying name change request both still remain,
of course. However, we are withdrawing our request for an increase in the monthly
average flow limitation.
With respect to the points raised in your 1/22/99 letter, we now expect
that withdrawing the flow increase request obviates the need for original design
capacity documentation and for an Engineering Alternatives Analysis.
Please call me with any questions or comments.
Sincerely, j�
Tom Amato
4939 N. NC Highway 150, Lexington, NC 27295 Telephone: [phone]

• • • ,tVAJ
Wastewater discharge from Kurz Transfer Products (Lexington, Davidson County) to
Reedy Creek in the Yadkin -Pee Dee River Basin.
15A NCAC /1/98. 2B .0300 Index #: Reedy Creek classified as WS-IV (#12-96- 0.7)) in
8
ATC Information:
• None in file.
Basinwide Plan Information:
• This sub -basin 03-07-04) has seen effects from some point sources on stream biota;
severe effects o urban runoff have been seen in cl poor bio assifications as ned to
Grants Cr and Town Cr during studies in 1990 (each listed on the 303 (d) list.
• Chemical samples from ambient sites indicate that most streams are very turbid,
but low DO is rarely a problem. Point source dischargers and urban runoff lead to
conductivity levels in Salem Cr, Muddy Cr, Grants Cr, Abbotts Cr, and
high conduct
Crane Cr. Many of these streams also have high concentrations of nitrogen and
phosphorus, but long-term data indicate these have been reduced by improved
wastewater treatment.
• There are two Reedy Creeks; Huffmans Cr drains to this one. No ambient stations
are nearby.
Correspondence:
• 12/23/96 Compliance Evaluation Inspection revealed facility was well -maintained
and had no problems.
DMR Review:
• Flows normally run 200-1400 gpd; have been as high as 2200 gpd. Peak flows were
higher in '98.
• pHs and temps. are fine. TSS usually < 5 mg/1 or slightly above.
• Ammonia usually 240 mg/l, depending on time of year. BOD5 typically < 10
mg/l.
EAA:
• Add info. requesting EAA sent 1/22/99. Applicant failed to address costs of
expanding the WWTP an additional 500 gpd and using a non -discharge alternative
to handle the additional flow (expansion in work force).
• Consultant (Ken Pickle, 336-541-8345) called on 2/10/99 to withdraw expansion
request. Company has monitored flows and does not feel that it will exceed limit;
it will send a letter.
General Comments:
Outfalls
Facility has two outfalls (002 is boiler blowdown). Jennifer Frye at the WSRO
could not find 002 during the inspection (facility has not been sampling it for years,
and Jennifer was worried about the non -compliant status). I spoke with Bob
Wallace of Kurz Transfer (215-632-2300 , who said that this outfall discharges a
ve small amount about 300' from Ree� Cr and the discharge never makes
ry y g it to

I C0070637
the stream (diagram submitted with 7/7/95 application letter is attached). He
would like the outfall eliminated, as there is no way to determine where to do up -
and downstream monitoring. I advised that the outfall should be left in the permit
(could be worse if it is not covered, and non -discharge normally does not permit
something like this), but I agreed that up- and downstream temp. monitoring are
not really applicable in this situation.
Outfall 002 will also have to be moved; apparently the land is being bought by
someone else (State or county is building a road), so an ATC request is in the
works. Per a message from Ken Pickle on 2/15/99, company knows nothing
concrete about relocation of outfall, so proceed on renewal as is.
Per Steve Pellei's 12/7/98 Memo regarding nutrient monitoring in the Yadkin
basin, this facility should be given quarterly TN and TP monitoring.
Expiration date to be assigned to this permit is May 319 2004.
�0 C?S VtL/ I.c SC
rQ C< <
C {� 1 � f i rL2
page 2
ll o

NC0070637
Facility: Kurz Transfer Products
Discharge to: Reedy Creek
Stream class and index #: WSW, 12-96-(M)
Residual Chlorine Ammonia as NH3
(summer)
7Q10 (CFS) 0.91 7Q10 (CFS) 0.91
DESIGN FLOW (MGD) 0.0015 DESIGN FLOW (MGD) 0.0015
DESIGN FLOW (CFS) 0.002325 DESIGN FLOW (CFS) 0000233
STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0
UPS BACKGROUND LEVEL (UG/L 0 UPS BACKGROUND LEVEL (MG/L) 0.22
IWC (%) 0.25 IWC (%) 0.25
Allowable Conc. (ug/1) 6,670.8 Allowable Concentration (mg/1) 306.3
minimum = 2
Ammonia as NH3
(winter)
7Q10 (CFS) 1.82
Fecal Limit Not Required DESIGN FLOW (MGD) 0.0015
Ratio of 391.4 :1 DESIGN FLOW (CFS) 0000233
STREAM STD (MG/L) 1.8
UPS BACKGROUND LEVEL (MG/L) 0.22
IWC (%) 0.13
Allowable Concentration (mg/1) 19238.6
minimum = 4

0\117
Mr. Larry
Regional
NCDENR
D. Coble
Supervisor
KURZ TRANSFER PRODUCTS, L.P.
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Re:
Dear Mr. Coble;
Notice of Violation
Compliance Evaluation Inspection
Kurz Transfer Products
NPDES Permit No. NCO070637
Davidson County
February 2, 1999
This is to acknowledge receipt of your letter dated January 13, 1999, from the
Division of Water Quality concerning the above referenced matter. We have investigated the
situation and, although our Environmental and Safety Coordinator, Mr. Robert Wallace,
recallls discussing this outfall with the NCDENR central office in Raleigh in 1995 to the
effect that it was a "non -discharge" discharge and thus not appropriate for the NPDES permit,
we can find no records confirming those communications. Accordingly, we have taken steps
to ensure that Outfall #2 will be monitored as required in the applicable permit until such time
as clarification can be made as to whether this outfall is properly within the scope of the
permit.
We appreciate your office bringing this to our attention and we will continue to
communicate with you regarding monitoring this outfall and other information relevant to a
determination as to its appropriate status. Please call if you have any questions.
Included with this letter are the results and findings of our most recent
inspection of this outfall.
Sincer ,
Tom Amato z
4939 N. NC Highway 150, Lexington, NC 27295 Telephone: [phone]
_ J
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January 28, � 999
Ref exence: NPDES Boiler Blo�vdown Discharge Monitoring deport
Kurz Transfer Products '
4939 North High�ray 15Q
Lexington, NC
Permit # NC 007 0637
l�xl. TOxXi .A.zxtato
Kurz Transfer Products
4939 N NrC Higlt�nray x50
Lex�ngtonr NC: 2?295
�EaT Mr. An1at0:
In accordance with boiler blowdown monitoring requirements for the
1Gwrz Transfer Products facility NP]aPS permit (number NC 007 p63�:
ERM collected temperature and discharge data at the KTP facility on
7anuaxy 25, x9�9. The boilex bXowdown discharge data are svmn,ari�.Pd
below.
januart� �5, 1999
Boiler blowrdo�rn discharge rate:
Boi�ex blowrdowm discharge tennpexatu�re:
Upstream temperature:
T�ownstream temperature:
Total residual chlorine:
Max. 40 gallonsjday
148�F
52QF (1�.xQC)
51�F (10.5�C)
Not applicable
The discharge flowrate was estimated by measuring the discharge per
blowdowx1 event (approximately 10 gallons) and multiplying this
volume times the nsmbzr of blo�u,�do�vn events per day (4). Z'rr'ater
temperature data were collected using a bixxtetal thexxxtorxteter. Please
contact me if you have any questions.
S1nCErP.ly,
Jerky Pz'o6Sex
Project Manager, P.G.
Environmental
Resources
Management
7300 Carmel Exec hive Par1c
Suitt 200
Charlotte, NC 282:'6
[phone]
[phone] (Foa)
http://www.erm,co n
•�
'�
P.

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E.,
Mr. Thomas Amato
Production Manager
Kurz Transfer Products
1939 North NC Highway 150
Lexington, North Carolina 27292
Director
TRANSMITTED BY FACSIMILIE
Dear Mr. Amato:
CDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
January 22.1 1999
Subject: NPDES Permit Renewal Application
Permit No. NCO070637
Kurz Transfer Products
Davidson County
The Division received your permit renewal application and renewal fee on February 16, 1998. A review
m the application indicated that the facility is requesting to expand permitted now from 1500 gallons per
Jay (gpd) to 2000 gpd to accommodate additional work force. The following items must be submitted
before the Division can proceed with review of the renewal request:
• According to the renewal application, the existing system is designed for 1500 gallons per day only.
If this is not the case, please send documentation confirming what the design capacity of the existing
treatment system is.
• An Engineering Alternatives Analysis (EAA) comparing the cost of upgrading the existing system to
accommodate the expanded flow and the cost ofnon-discharge options for the additional 500 gpd.
Treatment Capacity
If the facility does require an upgrade to handle additional flow, the flow modification must first be
approved as part of the permit. Following issuance of the permit, the facility must submit a request for an
Authorization to Construct (ATC) for approval of the proposed modifications to the treatment system.
EAA
It is the Division's mandate to assure the most environmentally sound alternative be selected from all
reasonably cost effective options. Prior to the issuance of a permit for new or expanded flow, complete
justification for direct discharge must be made through a comprehensive cost analysis. This information
is very important, not only to provide sufficient assurance to the permit writer that the discharge is
warranted, but also because the alternatives analysis would be subject to careful scrutiny in court in the
event of adjudication. Attached is a guidance document for your use in performing this analysis. This
requirement is consistent with Title 15A NCAC 2H .0105.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]/FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Please submit the additional information no later than February 22, 1999. If you have any questions or
comments concerning this information, please contact me at [phone], extension 551.
Enclosure
cc: Winston-Salem Regional Office/Water Quality Section
NPDES Unit
�—