NCS000536_COMPLIANCE_20101129

STORMUVATER DIVISION CODING SHEET
PERMIT NO.
�S 00 Cj3
DOC TYPE
❑FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
*COMPLIANCE
D OTHER
DOC DATE
[] Z(Xfl I 1 2
YYYYMMDD

Larsen, Cori _.._— FL0f t-*?-ZO �S i'�►✓M'ri�+�'17 /
From: John SIch [[e-mail]]
Sent: Monday, November 29. 2010 12;09 PM
To: Larsen, Cory
Subject: Floorazzo storm water permit
Cory,
I'm late getting this e-mail to you. Sorry. The factory has been very slow and I've been out of town trying to sell some
product so we can stay open.
I did find some work and Floorazzo will be able to remain open at least through the first week in February of 2011. After
that we might be forced to close down and wait for the construction industry to return to normal. We are trying hard to
have that not happen, but we are just not sure.
I can no longer pay Harvey Harmon to do the EPA engineering for the business, I'm the only engineer left on site, so I'll
complete the request for the storm water permit. Please correspond only to me about the issues you are having with
the Floorazzo site.
SW -3 .
While he was still consulting he suggested we ask that the sample from the drain near the road be removed from the O
plan. Harvey thought the normal road runoff would make the test fail all of the time and never be under our control.
We have made a viable plan for dealing with the sludge generated on site. One we can afford to implement. ch r"
Please give me a call to discuss what should be one next. I'm in town for the next two weeks. My cell phone number is
336-302-5737.
Thank you,
John Sich
Owner, Floorazzo Je-d
• J! � v1'f � r � d r �+. � P %t.d s ( �f Ut' $-' � u -. a � d L7 � I vl.�`�-�.
t

N.,9L
Larson, Gory *-C&yi?-4V" . f &kWA45%R 2-� 2
From: John Sich [[e-mail]]
Sent: Monday, November 29, 2010 12:16 PM
To: Larson, Cory
Subject; FW: Floorazzo Stormwater Permit
Hi Cory,
This is the last note I received from Harvey on the issue.
I wish I could just raise prices by the 15K needed or "figure out how to fund the work" as he suggests. However, we can
not raise prices and the funding will not happen until the volume picks up.
Please give me a call.
John Sich
336-302-5737
From: Harvey Harman[[e-mail]]
Sent: Monday, November 15, 2010 8:02 AM
To: John Sich
Subject: Fwd: Floorazzo Stormwater Permit
John, The main comment I wound-rrecommend you make to Cory is that you request that you not have to do the
24 hour acute toxicity test. T of the stormwater discharge points you are testing are storm drains in the
roadway and so the primary pollutants going into them are from the road. The main test from Floorazzo is to
verify styrene is not migrating from the plant into these drains.
[ W4
This stormwater permit is required and you not having it to date has given you some slack time for something
that is a requirement. You will need to do the long list of requirements listed, so you will need to have a person
paying attention to these items and making sure you are within compliance. I think you should plan on
budgeting $10,000-$15,000 per year for keeping within compliance once the updates are in place. Just roll this
cost into one of the costs of doing business.
Also, you will need to institute the improvements that have been talked about regarding seperating out the
sludge and keeping it away from the stormwater. You have to figure out how to fund this work, but it needs to
be done.
("V I51
Those are my suggestions. Email your comments to Cory today (Monday).
Thanks
Harvey
---------- Forwarded message ----------
From: Harvey Harman <harvey.harmanamgmail.com>
Date: Mon, Nov 15, 2010 at 7:53 AM
Subject: Fwd: Floorazzo Stormwater Permit
To: John Sich <John@,,floorazzo.com>

----------- Forwarded message --___-_---
From: Larsen, Cory <cory.larsennncdenr_gov_>
Date: Thu, Oct 14, 2010 at 11:11 AM
Subject: RE: Floorazzo Stormwater Permit
To: Harvey Harman <harvey.harm an u,gmai1.eom>
Cc: John Sich <John(a)tloorazzo.com>
We allow 30 days from receipt of the draft to submit comments. Because of the changes, I can allow for another 30 days
from today to submit comments. Then we consider all comments, revise as necessary, and issue the final perinit about 2
weeks after the comment period closes. Let's say November 14'h is the new comment deadline. Agreeable?
From: Harvey Harman [mailto:harve .harrnan a rrnail.com]
Sent: Thursday, October 14, 2010 11:07 AM
To: Larsen, Cory
Cc: John Sich
Subject: Re: Floorazzo Stormwater Permit
Thanks Cory, I know there is specified comment period that Floorazzo can respond before the permit becomes
permanent. What will that timeline be related to this permit? Many thanks.
--Harvey
On Thu, Oct 14, 2010 at 10:58 AM, Larsen, Cory <cory.larsen(@,nc_denraov> wrote:
Harvey,
I believe I may have forgotten to email you a copy of the draft permit when I sent the hardcopy to John. Here is a copy
for your review. Please note there have been two changes from the version that Jolm received which I've incorporated
based on comments from the Regional Office. The first change is to require analytical monitoring for styrene but without
a benchmark value to compare to (just monitoring). The second change is found under the Compliance Schedule in Part
III Section A to provide containment of styrene materials within 120 days of the effective permit date. I've also attached
a PDF of the original draft with cover letter and appendix. Sony for my mistake in not copying you earlier as I had
intended.
Cory
From: Larsen, Cory
Sent: Wednesday, September 29, 2010 9:50 AM
To: 'Harvey Harman'

Cc: John Sich
Subject: RE: Floorazzo Stormwater Permit
The hardcopy will go to John and l will email a copy to you Harvey if that is acceptable.
From: Harvey Harman [mailto:[e-mail]]
Sent: Wednesday, September 29, 2010 9:48 AM
To: Larsen, Cory
Cc: John Sich
Subject: Re: Floorazzo Stormwater Permit
Thanks Cory. Also, send a copy to me at 1108 Callicutt Road, Bear Creek, NC 27207. Many thanks. --Harvey
On Wed, Sep 29, 2010 at 9:43 AM, Larsen, Cory <cory.larsetl(c)ncdenr.gov> wrote:
i have been waiting to hear back from Vicki but will have to call her today. The draft will go out sometime this weck
after we talk.
Cory
From: Harvey Harman [mailto:harvey•liartnan(o)gmait.com]
Sent: Tuesday, September 28, 2010 4:52 PM
To: Larsen, Cory
Subject: Floorazzo Stormwater Permit
Dear Cory, Let me Know when you will be sending out the Draft for the Stormwater Permit for Floorazzo Tile
in Siler City. Many thanks.
Harvey Harman
Manager
Walk Softly, LLC/Earth Renewal Shelter
Specializing in sustainable land development,
renewable local economics, and "Green" Building
919-799-6819, harvey.harman cggmail.com
wwwwww. WalkSoftl OnTheEarth.com
3

Harvey Harman
Manager
Walk Softly, LLC/Earth Renewal Shelter
Specializing in sustainable land development,
renewable local economics, and "Green" Building
919-799-6819, liarvey.harmanrawnaii.com
www.WalkSoftly0tiTheEartli.com
Harvey Harman
Manager
Walk Softly, LLC/Earth Renewal Shelter
Specializing in sustainable land development,
renewable local economics, and "Green" Building
919-799-6819, harvey.harman(�_D -nail.com
www.WaIkSoftlyOnTheEarth.com
Harvey Harman
Manager
Walk Softly, LLC/Earth Renewal Shelter
Specializing in sustainable land development,
renewable local economics, and "Green" Building
919-799-6819, harvey.harmanAgmail.com
www.WalkSoftlyOnTheEarth.com
Harvey Harman
Manager
Walk Softly, LLC/Earth Renewal Shelter
Specializing in sustainable land development,
renewable local economics, and "Green" Building
919-799-6819, harvey.harman &gmail,com
www.WalkSoftlyOnTheEarth.com

Larsen, Cory
From: Harvey Harman [[e-mail]]
Sent: Thursday, October 14, 2010 11:25 AM
To: Larsen, Cory
Cc: John Sich
Subject; Re: Floorazzo Slormwater Permit
Great. Thanks for the added time. --Harvey
On Thu, Oct 14, 2010 at 11:11 AM, Larsen, Cory <cory.larsenRncdenr.ov> wrote:
We allow 30 days from receipt of the draft to submit comments. Because of the changes, I can allow for another 30 days
from today to submit comments. Then we consider all comments, revise as necessary, and issue the final permit about 2
weeks aver the comment period closes. Let's say November 14" is the new comment deadline. Agreeable?
From: Harvey Harman[mailto:harvey.liarman[aDpmail.com]
Sent: Thursday, October 14, 2010 11:07 AM
To: Larsen, Cory
Cc: John Sich
Subject: Re: Floorazzo Stormwater Permit
Thanks Cory, I know there is specified comment period that Floorazzo can respond before the permit becomes
permanent. What will that timeline be related to this permit? Many thanks.
--Harvey
On Thu, Oct 14, 2010 at 10:58 AM, Larsen, Cory <cory.larsen(c_r�.,nedenr,&ov> wrote:
Harvey, 4A441,4
I believe I may have forgotten to email you a copy of the draft permit when I sent the hardeopy to John. Here is a copy
for your review. Please note there have been two changes from the version that Jolui received which I've incorporated
based on comments from the Regional Office. The first change is to require analytical monitoring for styrene but without
a benchmark value to compare to (just monitoring). The second change .is found under the Compliance Schedule in Part
III Section A to provide containment of styrene materials within 120 days of the effective permit date. I've also attached
a PDF of the original draft with cover letter and appendix. Sorry for my mistake in not copying you earlier as I had
intended.
0 6n1LV-0V4 cluft Pt�w /o/L(//o -
Cory

From: Larsen, Cory
Sent: Wednesday, September 29, 2010 9:50 AM
To: 'Harvey Harman'
Cc: John Sich
Subject: RE: Floorazzo Stormwater Permit
The hardcopy will go to John and I will email a copy to you Harvey if that is acceptable.
From: Harvey Harman[mailto:harvey.harman(@,,gmail.com]
Sent: Wednesday, September 29, 2010 9:48 AM
To: Larsen, Cory
Cc: John Sich
Subject: Re: Floorazzo Stormwater Permit
Thanks Cory. Also, send a copy to me at 1108 Callicutt Road, Bear Creek, NC 27207. Many thanks. --Harvey
On Wed, Sep 29, 2010 at 9:43 AM, Larsen, Cory <cory. I arsen(d),nedenr. gov> wrote:
I have been waiting to hear back fi-orn Vicki but will have to call her today. The draft will go out sometime this week
afier we talk.
Cory
J ' s
From: Harvey Harman [mailto:harve .harman mail.com]
Sent: Tuesday, September 28, 2010 4:52 PM
To: Larsen, Cory
Subject: Floorazzo Stormwater Permit
Dear Cory, Let me know when you will be sending out the Draft for the Stormwater Permit for Floorazzo Tile
in Slier City. Many thanks.
Harvey Harman ;
Manager
Walk Softly, LLC/Earth Renewal Shelter
Specializing in sustainable land development,
renewable local economics, and "Green" Building
2

Affidavit of Publication
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with the issue dated the of ,
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NCQENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Mr. John Sich
Floorazzo Tile, LLC
215 West Third St.
Siler City, North Carolina 27344
Dear Mr. Sich:
Coleen H. Sullins
Director
October 5, 2010
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000536
Floorazzo Tile, LLC
Chatham County
Dee Freeman
Secretary
Enclosed with this letter is a copy of the draft stormwater permit for your facility in response to your
request for coverage under an individual NPDES Stormwater permit received in full on July 27, 2010.
Please review the draft carefully to ensure thorough understanding of the conditions and requirements it
contains.
Please note that analytical monitoring is required under this permit for parameters including COD, TSS, pH,
and Acute Toxicity at an initial frequency of quarrerly, then reduced to semi-annually for the remaincer of
the permit upon approval by the Raleigh Regional Office. Analytical results submitted with your
application showed highly polluted levels of BOD, COD and TSS at stormwater discharge outfall locations 1,
2 and 4 (in particular) as well as concentrations nearing levels of concern at outfalls 3 and 5. An
immediate investigation of each outfall location to locate and correct cause of the observed results should
be. performed upon receiving this letter.
Please submit any comments to my attention no later than thirty (30) days following your receipt of the
draft. Comments should be sent to my attention at the address listed at the bottom this letter. if no
adverse comments are received from the public or Floorazzo Tile, this permit will likely be issued within
tvio months.
If you have any questions or comments concerning this draft permit, feel free to contact me at (919) 807-
6365 or [e-mail].
Sincerely,
Cory rsen
Environmental Engineer
Stormwater Permitting Unit
cc: Raleigh Regional Office, Vick Webb
Harvey Harman [ [e-mail]]
Central Files
Stormwater Permitting Unit
Wetlands and Sior nwater Branch One
16 i7 Mail Service Center, Ralegh, North Carolina 27699-1611 No Ci h C aro 1 i rZ a
Localion: 512 N. Salisbury Sl. Raleigh, North Carolina 27604
Phone: [phone] FAX [phone] Customer Service 1-a77-623.6745 / �/atlrl' dly
Internet: www-ncwaterquality,org ✓ ;/
An Equal Opporti;My 1, Affirmative Action Employer

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
September 28, 2010
Cory,
Dee Freeman
Secretary
R-af— la Y/3-0 /ro
on September 16, 2010, 1, Vick Webb and Tom Ascenzo met with Mr. Harvey at site to
discuss pending permit. Looked at all outfalls and went over the containment area where
waste/cuttings are deposited and how it is still allowing flow to leave containment area.
Discussed the SP3 plan and what they need to start work on so when the new permit arrives
they will be on schedule.
Based on site visit and history of this site, RRO recommends that the facility perform analytical
monitoring quarterly until the facility installs the water separator or the first two years of the
permit whichever is the longest time. As for Toxicity sampling, I would recommend test
quarterly and if samples provide no failed results, then after the first year go to twice a year
sampling and then follow the rest of the permit as outlined in draft.
It is a concern that this facility will not have the funds to do the necessary upgrades to this site
to move them into a complainant status or to keep them in one at current standing.
Vick Webb
None hCarolina
Natura!!ty
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: www.ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer -- 50% Recycledl10% Post Consumer Paper

Larsen, Cory
From: Harvey Harman [[e-mail]
Sent: Monday, September 20, 2010 11:37 PM
To: Larsen, Cory
Cc: Webb, Vicki, John Sich
Subject: Draft Stormwater Permit
Dear Cory, I met with Vicki Webb last week regarding the draft Stonnwater Permit for Floorazzo Tile in Siler
City. When you send the draft copy of the Stormwater to Floorazzo Tile for review and comment prior to
issuance of the final permit please also send a copy to me at 1108 Callicutt Road, Bear Creek, NC 27207.
Many thanks.
Harvey Harman
Manager
Walk Softly, LLC/Earth Renewal Shelter
Specializing in sustainable land development,
renewable local economics, and "Green" Building
919-799-6819, harvey.l�ar �GEjk m il.ccyl l
�.c�.«.v. WalkSotIlyOnTheEarth.com

NCDENR
North Carolina Department of Environment and Natural
Division of Water Quality
Beverly Eaves Perdue
Governor
Coleen H. Sullins
Director
August 2, 2010
Individual NPDES Stormwater Permit Renewal Transmittal Cover Page
To: Raleigh Regional Office, Vicki Webb
Subject: NPDES Stormwater Permit No. NCS000536
Floorazzo Tile, LLC
Siler City, NC (Chatham County)
Attachment Description
Staff Report
Draft Permit
Renewal Application
Vicki,
Resources
Dee Freeman
Secretary
Please review, provide comments and return the staff report if acceptable to you and RRO for this
draft permit. Call me if you'd like to discuss 919-807-6365. Thanks.
C Return to Cory -Larsen at the Central Office by September 1, 2010 if possible
L . Cory Larsen
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
At
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1.877-623.6748
Internet: www,ncwaterquality.org
One
Nzmally
Carolina
An Equal Opportunity 1 Affirmative Action Employer

NCS000536
F� is AUG 3 20I0
RMENR
North Carolina Department of Environment and Natural Resources
Division, of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit,
Facility Name: Floorazzo.Tile, LLC
NPDES Permit Number: NCS000536
Facility Location: 215 West Third St, Siler City, NC (Chatham Co), See Figure 1
Type.of Activity: Tile Manufacturing
SIC Code (if applicable): 3272: Concrete Products, Except Block and Brick
Receiving Streams: Loves Creek
River Basin: Cape Fear. River Basin, Sub -basin 03-06-12
Stream Classification: C
Proposed Permit Requirements: See attached draft permit.
Monitoring Data: See Table 1.
Response. Requested by (Date): September 1, 2010
Central Office Staff Contact: Return to Cory Larsen, [phone]; [e-mail]
Special Issues:
Issue
Rating Scale:1(easy) to
10(hard) ,
Compliance history
N/A
Benchmark exceedance
N/A
Location (TMDL, ME species, etc)
4
Other Challenges:
S
• Site Visit,
NOV/enforcement process,,
delayed information
atherin /submittal
Difficult Rating:
(12)/40
Description of Onsite Activities:
• The facility manufactures pre -fabricated Terrazzo flooring (in tile form) trade primarily
from marble and glass chips, calcium carbonate, and a polyester, styrene -based resin. The
file product. replace the traditional labor-intensive .method. of. onsite Terrazzo installation.
Page 1 of 7

NCS000536
,�. Bulk materials are mixed, set, ground, Polished, and cut at the facility to produce boxed tile
which can be shipped to the construction site and uzstalled like conventional floor tile.
Documents Reviewed:
• EPA TRI Data & MSGP
• 2008 303(d) List
• NC TMDLs
• 2005 Cape Fear Basviwide Plan (BWP)
• NC Natural Heritage Program for ME
History:
• Site Visit Performed by CL, KP, V. Webb (.RRO): 01/06/2010
• . Application for NCS Permit Submitted in Full: 07/27/2010
Page 2of7

NCS000536
NCS000536
ii
ti
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Floorazzo Tile, LLC
k Il �f
a
FLOORAZZO TILE, LLC
Lab tulle; 350 43' 25" N
Longitude: 790 28' 01" W
County: Chatham
Receiving Stream; Loves Creek
Stream Class: C
Sub -basin: 03-05-12 (Cape Fear River Basin)
Figure,l: Location Map of Facility
Page 3 of 7
Facility Location

NCS000536
Central Office Review Summary:
I. Owner's Other Permits:
• N/A
2. General Observations:
• Small facility (1-2 ac) with approximately 50'%o impervious area;
• Five (5) identified SDOs.
3. Impairment:
o Loves Creek is 303(d) listed stream -- Dili segments;
o Impaired for aquatic life;
o Stressor study conducted on Loves Creek named. toxic chemicals in stormwater runoff as
source of impairment.
4. Threatened and Endangered (within 2 miles):
o No species .returned .in sea..rc.h.
5. Location:
o The facility in downtown Siler City in- a mixed industrial/commercia.1/residential area.
6. Industrial Changes Since Previous Permit:
o N/A - New permit.
7. Analytical Monitoring Notes:
o Five parameters were analyzed at five SDO locations and reported on EPA Form 2F: TSS, pH,
BOD, COD, and Styrene;
o Exceedances of benchmark values for TSS, BOD and COD at 3 of 5 outfalls with near
exceedances at the remaining outfalls;
o See Table 1. for full summary.
8. Oualitativ_e_Monitoring Notes:
o N/A - New permit.
Page 4 of 7

NCS000536
1
Table 1: Analytical Monitoring
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Dab C akdated by SPU based on reputed dranage area size and p-eapltabon.
ND = rot detected
NA= rot applicable
Page 5 of 7

NCS000536
Revised Permit Recommendations: Analytical Monitoring:
L Proposed strategy: Initial. frequency set to quarterly based on. elevated ana.lyt.i.cal results to help
encourage more rapid investigation of ,pollutant sources and solutions to bring results. back within
benchmark concentrations. Semi-annual frequency scheduled to begin Year 3 once discharges
normalize following SPPP and/or Tier response actions (if any).
a. Adding parameters:
i. COD - high levels of BOD/COD observed in analytical results;
ii. TSS - standard addition plus high TSS observed in results;
iii. pH - standard addition plus some elevated results observed;
ased on large use of styrene -based vinyl ester resin, the find�::�gs of
iv. Acute Toxicity - b
the Loves Creek stressor study that attributed impairment primarily to toxic cherrrcal.
stormwater runoff, and general impression of stormwater pollution potential of C.
facility observed during site visit. Performing this monitoring will help to eliirJnate
or identify the facility as a potential source of impairment.
2. New individual permit template utilized that includes the Tiered monitoring system, analytical and
qualitative monitoring required during representative storm events, and annual summary DMR due
to RO in March of every year
3. Qualitative monitoring required regardless of representative outfall status. Qualitative monitoring
to be performed at same schedule as analytical monitoring.
Discussions with Permittee: Harvey Harman, Env. Consultant, 2010, [e-mail]
Numerous email exchanges with Mr. Harman discussing application procedures and
requirements occurring during Jan -July 2010.
Page 6of7'

NCS000536
0
Recommendations:. Based on the documents reviewed and CO/RRO site visit, the application
information submitted fully on July 27, 2010 is deemed sufficient to issue an Individual Stormwater
Permit.
Prepared by (Signature) p
Stormwater Permitting Unit Supervisor K-�c�
for Bradley Bennett
Concurrence by Regional Office' Y
Water Quality Supervisor.
Regional Office Staff Comments
See c,4,-,L .A Imo.
Date 717 i /0
Date 1 2 !d
Date A8 Se ' �!6
Date
k- u �
V L�
�i dr
Page 7 of 7

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 28, 2010
Cory,
I on September 16, 2010, I, Vick Webb and Tom Ascenzo met with Mr. Harvey at site to
discuss pending permit. Looked at all outfalls and went over the containment area Where
waste/cuttings are deposited and how it is still allowing flow to leave containment area.
Discussed the SP3 plan and what they need to start work on so when the new permit arrives
they will be on schedule.
Based on site visit and history of this site, RRO recommends that the facility perform analytical
monitoring quarterly until the facility installs the water separator or the first two years of the
permit whichever is the longest time. As for Toxicity sampling, I would recommend test
quarterly and if samples provide no failed results, then after the first year go to twice a year
sampling and then follow the rest of the permit as outlined in draft.
It is a concern that this facility will not have the funds to do the necessary upgrades to this site
to move them into a complainant status or to keep them in one at current standing.
Vick Webb
Nlyrallb,
onehCaroiina
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: www.ncwaterquality.org 1628 Mail Service Center . Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Compliance Inspection Report
Permit: NCS000536 Effective: Expiration: Owner: Floorzazzo Tile LLC
SOC: Effective: Expiration: Facility: Floorazzo Tile, LLC
County: Chatham 215 W Third St
Region. Raleigh
Siler City NC 27344
Contact Person: John Sich Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 0911612010 Entry Time: 09:25 AM Exit Time: 11:36 AM
Primary Inspector: Vicki Webb d==. Phone:
Secondary Inspector(s):
tom ascenzo Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Q Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page: 1

Permit: NCS000536 Owner - Facility: Floorzazzo Tile LLC
Inspection Date: 09/16/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection summary:
Met with Mr. Harvey at site to discuss pending permit. Looked at all outfalls and went over the containment area where
waste/cuttings are deposited and how it is still allowing flow to leave containment area. Discussed the SP3 plan and what
they need to start work on so when the new permit arrives they will be on schedule.
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: Facility is in process of getting a permit. meeting was done to discuss
issues at facility and go over details of pending permit.
Yes No NA NE
Page: 2

Gmail - Question on EPA 2F Form
Page 1-of 1
G�'mail-
&/
Question on EPA 2F Form
Harvey Hannan <harvey.harmanfgmall.com>
Larsen, Cory <[e-mail]> Mon, Jul 12, 2010 at 9:13 AM
To: Harvey Hannan <[e-mail]>
Cc: "Webb, Vicki" <[e-mail]>, John Sich <[e-mail]>, Mack Greeson
<[e-mail]>
Your understanding is correct Harvey. Assuming that the discharge is stormwater only, there are no
nonstormwater discharges, thus no need for 2C or 2E. This section is asking the applicant to certify
there are no nonstormwater discharges at the stormwater outfalls.
From: Harvey Harman[maitto:[e-mail])
Sent: Saturday, July 10, 2010 3:60 PM
To: Larsen, Cory
Cc: Webb, Vicki; John Sich; Mack Greeson
Subject: Question on EPA 2F Form
Cory, I am working on finishing Form 2F for Fioorazzo Tile and getting it to you to complete their Stormwater
Application. In Section V. of Form 2F it asks that we "certify under penalty of law ...that all nonstormwater
discharged from these outlet(s) are identified in either an accompanying Form 2C or Form 2E application for the
outfall."
In earlier conversations we talked about needing to submit EPA -Form 1 and EPA Form 2F. Also, our plan is
to have discharge that is composed entirely of storm water, which is what we are working towards. As such it is
my assumption that we need to send in EPA Form 2F, but not 2C or 2E. Can you please confirm that I am
understanding this issue correctly.
Many thanks for your help.
Sincerely,
Harvey Harman
Manager
Walk Softly, LLC/Earth Renewal Shelter
Specializing in sustainable land development,
renewable local economics, and "Green" Building
919-799-6819, harv_ey.harman@gmail_com
www.WalkSottlyOnTheEarth.com
https://mail.google.com/maill?ui=2&ik=cc2c7baa7e&view=pt&q=Cory%2OLarsen&searc... 7/26/2010

d

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water ouality
Beverly Eaves Perdue Coleen H, Sullins
Governor Director
July 1, 2010
CERTIFIED MAIL #7003 2260 0005 5382 7611
RETURN RECEIPT REQUESTED
Mr. John Sich
Floor=o Tile, LLC
215 West Third Street
Siler City, NC 27344
Dee Freeman
Secretary
CERTIFIED MAIL #7003 2260 0005 5382 7529
RETURN RECEIPT REQUESTED
Mr. Troy J. Smith, Jr.
WASLAW, LLC — registered agent
P.O. Box 867
New Bem, NC 28563-0867
SUBJECT: - Final Notice
Request for Payment of Civil Penalty
Case No, DV-2009-0051
Floorazzo Tile, LLC
Chatham County
Dear Sirs:
Your immediate attention to this matter is required. On' December 15, 2009, the Division of
Water Quality (DWQ) assessed a civil penalty against you in the amount of 4 046.59, including
$46.59 in investigative costs, for violations of North Carolina General Statute (G.S.) 143-
215.1(a)(1) and G.S. 143-215.1(a)(11). DWQ has the certified mail green card that shows that
you received the civil penalty assessment on December 16, 2009.
,The civil penalty assessment document clearly stated that you had three options available within
thirty (30) calendar days of your receipt, according to North Carolina General Statute 143-
215.6A. You could have paid the penalty, requested remission of the penalty, or filed a
contested case petition with the Office of Administrative Hearings. As of July 1, 2010, you have
failed to act on one of these options
Therefore, by State. law, the full amount of the penalty -is immediately due and payable.
This. letter serves as final notice and that DWQ will refer your case to DENR Collections
Team - and then if necessary to the North Carolina Attorney General's. Office unless
payment' is received within 15 (fifteen) calendar days of your receipt of this notice. If
necessarv. the Attornev General's Office will file a case aizairnst you in Superior Cotart to
collect the penal
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location: 512 N. Salisbury St. Ralelgh, North Carolina 27604
Phone: [phone] FAX: 91 M07.64941 Customer Service: 1.877.623.6748
Internet: www.ncwalerquatity.org
One No. Carolina
An Equal Opportunity 1 Afllrmative Aotior> Employer

Floorazzo Tile, LLC
DV-2009-005 I 1P
Page 2 of 2
Please make check payable to the Department of Environment and Natural Resources (DENR),
please reference the on your check or money order, and send the
payment within 20 (twenty) calendar days to:
John Hennessy
NC DENR-DWQ — Wetlands and Stormwater Branch
NPS Assistance & Compliance Oversight Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
The violations addressed by this assessment and any impacts to waters must be abated,
properly resolved and an NPDES permit obtained. Please be advised that additional
assessments may be levied for future, continuing, or other violations beyond the scope of
this specific assessment. You are encouraged to contact Vicki Webb with the DWQ
Raleigh Regional Office at (919) 791-•4200 if you need assistance in achieving compliance at
the site.
If you have any questions, please contact me at [phone].
Sincerely,
Shelton Sullivan
NPS Assistance and CompIian.ce Oversight Unit
Attachments
cc: Danny Smith / Vicki Webb — DWQ Raleigh Regional Office
NPS Assistance and Compliance Oversight Unit - File Copy
Corey Larsen — Stormwater Permitting Unit

&=man
NCDEWR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
December 15, 2009
CERTIFIED MAIL 7006 2150 0000 3312 8512
RETURN RECEIPT REQUESTED
Mr. John Sich
Floorazzo Tile, LLC
215 W Third Street
Siler City, NC 27344
Subject: Notice of Continuing Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a) (1) and (11)
Floorazzo Tile, LLC
Case No. DV-2009-0051
Chatham County
Dear Mr. Sich:
This letter transmits a Notice of Continuing Violation and Assessment of Civil Penalty in the
amount of $4046.59, ($4000A0 civil penalty + $4639 enforcement costs) against Floorazzo Tile,
LLC.
On May, July and November 2009, site visits were made at the subject facility and Notice of
Violation -Notice of Intent to Enforce (NOV-NOI) was issued on June 1, 2009. This assessment is
based upon the following facts: 1) making an outlet to the waters of the state; and 2) cause or
permit discharges regulated under G.S. 1432-214.7 that results in water pollution. The review has
shown the subject facility to be in violation of North Carolina General Statute (G:S:) 143-215.1 (a)
(I) and G.S. 143-215.1(a) (11).
Based' upon the above facts, I conclude as a matter of law that Floorazzo Tile, LLC violated the
terms, conditions or requirements of G.S. 143-215.1 (a) (1) and (11). In accordance with the
maximums established by G.S. 143-215.6A (a) (2),,a civil penalty may be assessed against any
person who violates the terms, conditions or requirements of a permit required by G.S. 143-
215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the .
Carolina
. �VQf!lM��IJ
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: www,Uw,hRggMANy.orst 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Actlon Employer— 50% Recycled110% Post Consumer Paper

Fla
Ca Yry o09 5 = 'A
r
CAM soon
Director of the Division of Water Quality, I, Daniel Smith, Division of Water Quality Regional
Supervisor for the Raleigh Region, hereby make the following civil penalty assessment against
Floorazzo Tile, LLC.
For violations of G.S. 143-215.1 (a) (1) and G.S. 143-215.1(a) (11)
by making an outlet to waters of the State and by causing or permit
4000A0 discharges regulated under G.S. 143-214.7 that result in water
pollution.
4000.00 TOTAL CIVIL PENALTY
46.59 Enforcement Costs
4046.59 TOTAL AMOUNT DUE
Pursuant to G.S. , 143-215.6A(c), in determining the amount of the penalty I have taken into
account the Findings of Fact and Conclusions of Law.and the factors set forth at G.S. 14313-
282.1(b), which are:
(1) The degree and extent of harm to -the natural resources of the State, to the public health, or
to private property resulting from the violation;
-' (2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6). Whether the violation was committed willfully or intentionally;
(7) ' The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do -one of the following:
1. . Submit payment of the penalty:
yPayment should be made directly to the order of the Department of Environment and Natural' ,
Resources (do not include waiverforrh). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Please submit payment to the
attention of
Noy\- 'Point Source Compliance/Enforcement Unit
�- Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
2. Submit a written request for remission or mitigation including a detailed justification
for such request:
Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the civil penalty assessed.

Floorazzo Tile, LLC
Case No. DV-2009-0051
Chatham County
Requesting remission is not the proper procedure for contesting whether the violation(s)
occurred or the accuracy of any of the factual statements contained in the civil penalty
assessment document. Because a remission request forecloses the option of an administrative
hearing, such a request must be accompanied by a waiver of your right to an administrative
hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please
prepare a detailed statement that establishes why you believe the civil penalty should be
remitted, and submit it to the Division of Water Quality at the address listed below. In
determining whether a remission request will be approved, the following factors shall be
considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b)
was wrongfully applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from
the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please note that all evidence presented in support of your request for remission must.be submitted
in writing. The Director of the Division of the Division of Water Quality will review your
evidence and inform you of her decision in the matter of your remission request. - The response will
provide details regarding the case status, directions for payment, and provision for, further appeal
of the penalty'to the Environmental Management Commission's Committee -on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that
was not part of the original remission request considered by the Director. Therefore, it is very
important that you prepare a complete and thorough statement in support of your request for
remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission
of Civil Penalties, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form
within thirty (30) days of receipt of this notice. The Division of Water Quality also requests that
you complete and submit the enclosed "Justification for Remission Request." Both forms should
be submitted to the following address:
Point Source Compliance/Enforcement Unit �ttorncss�/
Division of Water Quality
1617 Mail Service Center ,
Raleigh, North Carolina 27699-1617
OR
3. File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition
for an administrative hearing. You may obtain the petition form from the Office of Administrative
Hearings. You must file the petition with the Office of Administrative Hearings within thirty (30)
days of receipt of this notice. A petition is considered filed when it is received in the Office of
Administrative Hearings during normal office hours. The Office of Administrative Hearings
accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for
official state holidays. The original and one (1) copy of the petition must be filed with the Office
of Administrative Hearings. The petition may be faxed - provided the original and one copy of the

Floorazzo Tile, LLC
Case No. DV-2009-0051
Chatham County
document is received in the Office of Administrative Hearings within five (5) business days
following the faxed transmission. The mailing address for the Office of Administrative Hearings
is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
Telephone [phone] Facsimile: [phone]
and
Mail or hand -deliver a copy of the petition to
Mary Penny Thompson, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as
evidenced by an internal date/time received stamp (not -a postmark), will result in this matter being
referred to the, Attorney General's Office for collection of the penalty through a civil anion. Please
be advised that additional penalties maybe assessed for violations that occur after the review
period of this assessment.
If you have any questions, please contact Vicki Webb of the Raleigh Regional Office at 919-791-
4200.
Sincerely, ,
S. Daniel Smith
Water Quality Regional Supervisor
Raleigh Regional Office
Attachments
Cc: Point Source, Compliance w/ attachments
EnforcemerifFile w/ attachments
Eastern NPDES Program
Central Files w/ attachments
RRO File
Tony Tucker, Chatham Emergency Mgmt
P.O: Box 1809, Pittsboro, NC 27312
Jenne Walker, Solid Waste

Division of Water Quality
Biological Assessment Unit
November 18, 2003
Memorandum
To: Michelle Woolfolk
Through: Jimmie Overton
Trish MacPherson
From: Cathy Tyndall Crlj
Subject: TMDL Stressor Study of Loves Creek
Cape Fear River Basin, subbasin 12, Chatham County
BACKGROUND
Loves Creek is located in western Chatham County, and is a tributary to the Rocky River. The entire
Rocky River watershed is located within the Slate Belt ecoregion. Streams within this ecoregion are
characterized by very low base flows during summer months, and smaller tributaries often dry up
completely during prolonged low -flow periods. Land use in the Loves Creek catchment includes forest,
cultivated crops, pasture, animal operations (cattle and poultry) and urban areas. Siler City, the only
urban area in the watershed, discharges 4.0 MGD to loves Creek.
Loves Creek (6-4 miles from source to Rocky River) is listed on North Carolina's 303(d) list of impaired
streams. The section above the Siler City Wastewater Treatment Plant (2.8 miles from US 421 to the
Siler City WWTP) is rated partially supporting (PS) and the 0.5-mile segment below the WWTP is not
supporting (NS) based on the Poor benthos rating obtained in 1997. The upper segment of Loves Creek
(above US 421) is currently not rated (NR). Pollutants associated with the Siler City WWTP discharge
and urban nonpoint sources from Siler City are possible causes of impairment. In addition, agricultural
runoff in the upper portion of the watershed could be a contributing source of impairment.
Considering that the Loves Creek watershed is relatively small (8 square miles) and located in the Slate
Belt ecoregion, it was more than likely drastically affected by the drought conditions of 2002. Though
2003 was an above average rainfall year, all the sites sampled on Loves Creek had little water except the
lower site which is located below the Slier City WWTP and receives much of its flow as effluent. Given
these conditions, it is difficult to assess the benthic results from the 2003 sampling.
Fish Community Data
A fish community sample was collected from Loves Creek in 1998, upstream of the Siler City WWTP
discharge. This is the same location as the upstream of the WWTP benthos site. The fish community
sample resulted in a rating of Good -Fair. The species diversity (n=20) and fish abundance metrics scored
high and the number of species of sunfish collected (6) indicated good instream pool habitat. However,
the trophic metrics and the percentage of tolerant fish metrics scored in the mid -lower range. The most
abundant species collected was the tolerant redbreast sunfish (44% of all fish collected were of this
species).
Ambient Water Chemistry Data
There are no ambient water chemistry sites in the Loves Creek watershed.
Whole Effluent Toxicity
A review of toxicity data showed that the Siler City WWTP has achieved compliance with its 90 percent
chronic toxicity permit limit since 1995.

HISTORICAL
Sampling in Loves Creek was conducted above and below the WWTP discharge in both 1989 and 1997.
Benthic macroinvertebrates resulted in Fair ratings above the WWTP and Poor below the discharge both
years (Table 1). As in 2003, upstream historical sampling was conducted at the bridge crossing on
WWTP Road and the downstream sampling was accessed through the WWTP property. Downstream
sampling was conducted approximately 100-150 feet below the discharge, allowing for adequate mixing
of the effluent.
Table 1. Historical Biological Data from Loves Creek, 1989 and 1997.
Loves Cr
Loves Cr
Loves Cr
Loves Cr
above WWTP
below WWTP
above WWTP
below WWTP
811189
8/1/89
6/27197
6/27197
Total Taxa Richness
52
27
55
36
EPT Richness
7
2
8
4
EPT Abundance
27
4
46
17
Biotic Index
7.5
8.41
7.25
7.41
EPT BI
6.84
8.40
6.61
6.06
Bioclassitleation
Fair
Poor
Falr
Poor
Sample Type
Full Scale
Full Scale
Full Scale
Full Scale
METHODS
Benthic Macroinvertebrates
On June 23-25, 2003, Benthic macroinvertebrates were collected at four sites using the Division of Water
Quality's standard qualitative (Full Scale) method, and at three small (width less than 4 meters) sites
using the Qual 5 method.
The standard qualitative sampling procedure is comprised of ten composite samples, and includes two
kicks, three sweeps, one leaf pack, two rock/log washes, one sand sample, and visual collections. All
organisms are picked in the field. The Qual 5 sampling method consists of one kick, one sweep, one leaf
pack, a rock/log wash, and visuals. As in the standard qualitative method, all organisms are collected.
The collection of the rock/log wash provided a representative sample of the chironomid population to
more fully assess disturbance and evaluate potential sources of toxicity.
The purpose of these collections is to inventory the aquatic fauna and produce,an indication of the
relative abundance for each taxon. Organisms are classified as Rare (1-2 specimens, denoted by "R" on
taxa tables), Common (3-9 specimens, "C"), or Abundant L10 specimens, "A").
Several data summaries (metrics) can be produced from benthos samples to detect water quality
problems. These metrics are based on the idea that unstressed streams and rivers have many
invertebrate taxa and are dominated by intolerant species. Conversely, polluted streams have fewer
numbers of invertebrate taxa and are dominated by tolerant species. The diversity of the invertebrate
fauna is evaluated using taxa richness counts; the tolerance of the stream community is evaluated using
a biotic index.
EPT taxa richness (EPT S) criteria have been developed by DWQ to assign water quality ratings
(bioclassifications) for Full Scale and EPT samples. "EPT" is an abbreviation for Ephemeroptera +
Plecoptera + Trichoptera, insect groups that are generally intolerant of many kinds of pollution. Higher
EPT taxa richness values usually indicate better water quality. Bioclassifications for Full Scale samples
are also based on the relative tolerance of the macroinve rteb rate community as summarized by the North
Carolina Biotic Index (NCBI). Both tolerance values for individual species and the final biotic index values
have a range of 0-10, with higher numbers indicating more tolerant species or more polluted conditions.
EPT abundance (EPT N) and total taxa richness calculations also are used to help examine between -site
differences in water quality. Criteria for Piedmont streams were used for all determinations.

�'w
For the Qual 5 method, the additional rock/log wash was kept separate from the four other composites,
This allowed for the potential assignment of a minimum rating using EPT taxa richness (based on
piedmont criteria for EPT samples applied to the wash excluded sample, which is the same as an EPT
sample). Only EPT taxa richness values were used to determine impairment. A Not Impaired rating is
given if the stream would receive a bioclassifrcation of Good -Fair or better using DWQ EPT criteria
developed for larger streams. Small streams that would have a minimum bioclassification of Fair or Poor
continue to be Not Rated.
Habitat Evaluation
Habitat evaluations were made using BAU's Habitat Assessment Field Data Sheet for Mountain/Piedmont
Streams. This assessment assigns a numerical score from 0-400'for the reach of stream sampled, based
on channel modification, instream habitat, bottom substrate, pool variety, riffle habitats, bank stability and
vegetation, light penetration, and width of the riparian zone. Criteria are still being developed to rate
habitat scores, but the higher the score, the better the overall habitat.
Physical -Chemical
At the time of sampling, field measurements were collected for temperature, dissolved oxygen,
conductivity, and pH using a YSI 85 meter and an Accumet pH meter.
SAMPLING SITES
Figure 1. Benthic Macro invertebrate Sampling Sites, Loves Creek Watershed, June 23-25, 2003.
Lerer CiveIt ebw W P
Siler City
W L erec'Creok
•
Lwee CneA Seceed Me
Levee Cite 9Aebw palceerce
214fiH CITY W W T
i
I
i
N
I
GeeA Iebw WWTP
CN&A of BA toot
Medow Give
4}
0 1
�t
N
A

Loves Creek at SR 1006
SR 1006 was the most upstream location sampled on
Loves Creek. The drainage area was approximately
one square mile and the stream width was two meters.
The immediate land uses at this location appeared to be
a mixture of agriculture (active crops, active pasture with
low animal density, fallow fields) and rural residential.
There were areas of incised, steep, straight banks
indicating flashy conditions during rain events. The
water was slightly turbid and the average water depth
was only 0.1 meters. The substrate was a mix of
boulder, rubble, gravel, and sand, however, riffle areas
were small and infrequent. Overturned rocks revealed
abundant sponge growth, Indicating low dissolved
oxygen conditions. The conductivity was 111
µmhos/cm. Trees provided ample shading and the
riparian zone was wide and intact on both sides. The
habitat scored 70.
Loves Creek below golf course (Slier City Country Club)
Loves Creek at Second Avenue
At this location, the stream width was two meters and
the drainage area was approximately two square miles.
The substrate was mostly gravel and sand, which
provided infrequent, poor riffles. Bank erosion was
severe and the riparian zone was minimal due to the
stream following along the southern perimeter of a golf
course. There was moderate to heavy periphyton
growth on the rocks and the water was still turbid. The
canopy shaded 90 percent of the stream. Conductivity
was the same (111 pmhos/cm) as upstream. The
habitat scored 63.
Loves Creek at Second Avenue is located in a
residential section of Slier City. It is downstream of the
UT to Loves Creek that flows through Siler City and
commercial businesses were in close proximity.
Consequently, this location reflected all aspects of urban
nonpoint source runoff resulting from Siler City. The
stream width was six meters and the drainage area was
approximately six square miles. The water was still
slightly turbid and the stream was incised, with steep,
straight banks. The amount of sand in the substrate
increased from levels seen at the upper sites, resulting
in poor riffle habitat. Undercut banks and root mats
provided the most abundant habitat at this location. The
stream was shaded and the riparian zone was ample,
though breaks were common. The conductivity
increased to 157 µmhos/cm. The habitat scored 64,
similar to the upstream site.

Loves Creek above the WWTP discharge
Loves Creek below the WWTP discharge
UT Loves Creels at Greensboro Road
This site was located at the bridge on WWTP Road and
is the historical sampling location. The stream width
was six meters and the drainage area was seven square
miles. The substrate was comprised of a mixture of
bedrock, boulder, rubble, gravel, and sand. Periphylon
and sponge growth were both abundant on the rocks.
The prolific sponge growth may be an indication that low
dissolved oxygen and low flow conditions may persist at
this location. Riffles were infrequent and the bank
erosion was moderate to severe. The canopy provided
good shading, but the riparian zone was partially intact
and contained breaks. Undercut banks and root mats
were plentiful. The habitat scored 55, reflecting the
moderately wide riparian zone, infrequent pools, and
absence of woody habitat and leafpacks.
Loves Creek below the WWTP discharge was the only
site in the study with adequate water quantity, due to the
increased water level and flow from the discharge. .
The WWTP effluent comprises most of the stream; the
instream waste concentration is 96%. Stream width was
six meters and the drainage area was eight square
miles. The substrate was a mix of boulder, rubble, and
gravel. Riffles were well defined and frequent.
Undercut banks and root mats were abundant and
snags, logs, and leafpacks were available for
macroinverteb rate habitat. Bank erosion was less
severe at this location, but was attributed partly to the
lower stream banks. The conductivity increased to 570
µmhoslcm due to the WWTP discharge. Trees provided
adequate shading and the riparian zone was wide. The
habitat score was 78, the highest of the Loves Creeks
sites.
UT Loves Creek flows through the center of Slier City.
A car wash with drainage pipes leading to the stream
was located just upstream of the sampling location, and
typical urban trash littered the stream. The stream
width was three meters and the drainage area was
approximately two square miles. The substrate was
embedded and was a mix of boulder, rubble, gravel,
and sand. Due to its urban setting, the riparian zones
were narrow and the banks were severely eroded. The
conductivity was 194 µmhoslcm, reflecting urban
nonpoint sources. The habitat scored 55.

,:-
;1 J.
Meadow Creek at SR 2170
Meadow Creek is a Slate Belt stream and was sampled
as a reference site for Loves Creek. It is similar to
Loves Creek in that the headwaters are located in a
rural agricultural setting. However, Meadow Creek is
not impacted by urban runoff like Loves Creek. The
drainage area was 4.6 square miles and the width was
4 meters. The substrate was a mix of boulder, rubble,
gravel, and sand. In addition to rocks, undercut banks
and root mats were found in abundance. Riffles were
frequent, bank erosion was moderate, and trees
provided good shading. The riparian zones were wide
and intact. Conductivity was 134 µmhoslcm. Long,
filamentous algae was observed in the sunny areas,
possibly indicating enrichment. The habitat score was
77,
RESULTS
Loves Creek at SR 1006
Benthos fauna that are commonly found in headwater locations were absent at this site. Only three EPT
taxa were collected: Stenonema femoratum (A), Cheumatopsyche (A), and Callibaetis (C). S. femoratum
is tolerant, and typically found in Slate Belt streams. Cheumatopsyche and Callibaetis are also tolerant.
Abundant Physella and heavy sponge growth on the rocks indicated periods of low dissolved oxygen
and/or low flow. Due to the combination of Slate Belt ecoregion characteristics, upstream location, and
drought impacts, the number of potential taxa may have been suppressed. Upstream of the sampling
location, Loves Creek flowed through a grass pasture and was very small (less than one meter in width).
Regardless of whether the decreased EPT taxa richness was caused by low water or agricultural inputs,
the EPT taxa richness was low.
Loves Creek below golf course (Siler City Country Club)
The number of EPT taxa increased from three at the upper site to thirteen at this location. The biotic
index decreased from 7.63 to 6.31, a significant improvement. Clearly this location supports a much less
stressed benthic community than the upper site. Several intolerant taxa were collected, including
Leucrocuta (C), Paraleptophlebia (R), Diplectrona modesta (A), and Chimarra (R). Perlesta, a moderately
tolerant stonefly was abundant. Only one individual Perlesta was collected at the upstream site. It is
unclear as to why this site, which was located below a golf course, and had a slightly larger drainage area
than the upper site would have more intolerant taxa. A possible explanation would be the absence of
adequate water at the upstream site. Similar to the upstream site, Physella was abundant and there was
heavy periphyton growth in sunlit areas. The benthic community at this site appeared to be the least
impacted in the entire survey, including Meadow Creek, the control site.
Loves Creek at Second Avenue
Loves Creek at Second Avenue reflected urban runoff as well as agricultural impacts. The 2003 Full
Scale sample rated Fair. The biotic index increased from 6.31 to 7.14, demonstrating a decline in the
benthic community from the site below the golf course. The most abundant habitats were root mats and
undercut banks, but edge dwelling taxa were not found. The total number of EPT taxa decreased to
seven and only one intolerant taxa was collected (Leucrocuta (R)). The other six taxa ranged from
moderately tolerant to tolerant (Stenonema femoratum, S. modestum, Baetis tlavistriga, Chumatopsyche,
Hydropsyche betteni, and Perlesta).
Loves Creek above the WWTP
Similar to 1989 and 1997, the 2003 benthic sample above the WWTP rated Fair. Seven EPT taxa were
collected and all were tolerant. Both the biotic index (7.37) and the EPT biotic index (6.90) increased
slightly from the Second Avenue site, indicating a decline in the benthic community. The most numerous
taxa were the filter feeding caddisflies, Cheumatopsyche and Hydropsyche betteni. Leeches were
abundant, indicating poor water quality, and sponges, an indicator of low dissolved oxygen and/or low

flow conditions, were abundant on the rocks. No edge dwelling EPT taxa were found although roots were
abundant.
Table 2. Benthic M acroi nverteb rate Results and Site Characteristics. Loves Creek Watershed and
Meadow Creek, June 2003. Cape Fear River Basin, Subbasin 12, Chatham County
Loves Cr.
SR 1006
6/23/03
Loves Cr.
at golf
course
6/23/03
Loves Cr,
Second Ave.
6/24/03
Loves Cr.
above
WWTP
6124/03
Loves Cr.
below
WWTP
6/24/03
Ut Loves Cr.
Greensboro
Road
6/23/03
Meadow Cr,
SR 2170
6/25/03
BIOLOGICAL
COMMUNITY
Ephemeroptera
2
7
4
5
4
2
11
Plecoptere
0
1
1
0
0
0
1
Trlchoptera
1
5
2
2
2
2
2
Coleoptera
2
4
7
5
3
4
6
Odonata
1
3
6
2
3
3
5
Megaloptera
2'
0
1
1
1
0
2
Dipterw Chironomidae
15
is
17
18
14
15
21
Misc. Diptera
5
2
4
3
3
3
5
Oligochaeta
1
1
4
4
2
1
3
Crustacea
1
3
2
2
3
1
2
Mollusca
6
4
2
4
2
4
5
Other
2
2
0
2
3
1
2
Total Taxa Richness
39
48
50
48
40
36
67
EPT Richness
3
13
7
7
6
4
14
EPT Abundance
23
44
31
43
44
22
65
Biotic Index
7.63
6.31
7.14
7.37
6.72
7.32
6.96
EPT Biotic Index
6.40
6.90
7.00
6.31
Bloclassllication
I Not Rated
Not Rated
I Fair
Fair
Fair
Not Rated
I Not Rated'
HABITAT
Stream Width (m)
2
3
6
6
6
3
4
Drainage areas . miles
0.97
1.e7
5.56
7.0
6.0
1.64
4.59
Depth -Average m
0.1
0.2
0.5
o.2
0.3
0.2
0.3
Canopy %
80
90
70
70
80
80
80
Substrate
Boulder
10
0
0
30
35
35
25
Rubble
30
20
10
35
35
35
30
Gravel
40
45
35
20
20
15
25
Sand
20
35
55
15
10
15
20
Silt
0
0
0
0
0
0
0
Habitat Score
70
63
64
55
78
55
77
PHYSICAL
Temp °C
21
22
1 21
1 20
23
19
20
DO rngA
8,0
7.8
8.6
8.5
8.5
9.1
8.6
Cvnd uSlcm
111
112
157
166
570
194
134
H
7.3
7.3
7.4
1 7.4
7.8
7.3
7.4
GENERALILOCATION
Latitude
354135 354225
1 354307
1 354336
354350
1 354308
1 354127
Longitude
792825 792738
1 792719
1 792630
792534
1 792735
1 792221
Sample Type
Oual 5 oual 5
1 Full Scale
I Full Scale
Full Scale
I oual 5
1 Full Scala
` Not Rated due to drought effects
Loves Creek below WWTP
The 2003 sample rated Fair, an improvement from the Poor samples collected in 1989 and 1997. The
biotic index (6.72) was actually lower at this location than above the WWTP (7.37) in 2003. The
macroi nverteb rate community was similar upstream and downstream of the WWTP discharge, with the
dominant taxa at each location consisting of tolerant taxa that can withstand impacted water quality.
Regarding flow and habitat, below the WWTP was the most favorable for supporting a diverse benthic
community. However, the Fair water quality that was a result of urban and agricultural runoff and WWTP
effluent only allowed tolerant taxa to exist. At 7010 conditions, the WWTP discharge comprises 96% of
the stream flow.

UT Loves Creek
Typical of an urban stream, the conductivity was elevated (194 µmhoslcm) reflecting urban nonpoint
influences from Slier City, The BPT richness (4) was low and all the taxa collected were tolerant. The
dominant taxon was Cheumatopsyche. The high biotic index (7.32) reflects the overall tolerant
community residing in this urban stream.
Meadow Creek
Meadow Creek was sampled as a control site. Similar to Loves Creek, Meadow Creek is a slate belt
stream and more than likely, like Loves Creek, was drastically affected by the 2002 drought. For this
reason, a rating was not assigned to Meadow Creek. Unlike Loves Creek, there are no urban impacts on
Meadow Creek. Fourteen EPT taxa were collected in Meadow Creek, but only two taxa were intolerant:
Leucroceuta (C), Paraleptophlebia (R). Overall, the benthic community in Meadow Creek was
moderately -tolerant to tolerant. The dominant taxa were Stenonema femoratum (A) Cheumatopsyche
(A), and Hydropsyche betteni (A). Physella was abundant, indicating low dissolved oxygen, and leeches
were also abundant. The biotic index of Meadow Creek (6.96) was slightly higher than Loves Creek at
the golf course (6.31) and the Loves Creek site contained a much more diverse caddisfly population than
Meadow Creek.
CONCLUSION
The main cause of impairment in Loves Creek appears,to be chemical and/or physical pollutants. These
are in the form of toxic chemicals from urban runoff. Until actions are taken to reduce urban stormwaier
runoff from Siler City, it is reasonable to assume that the water quality of Loves Creek will remain Fair at
best, or decline. The UT Loves Creek, which flows through Siler City and the Loves Creek sites located
below Siler City supported stressed benthic communities reflecting the degraded water quality. The site
located below the golf course (above Siler City) and Meadow Creek, the control site, supported the least
stressed benthic community in the stressor survey.
Other causes of impairment include enrichment, habitat degradation due to sedimentation and loss of
bank root mass due to channel erosion. Possible sources of sedimentation include runoff from the
watershed and streambank erosion due to hydromodification from impervious surfaces associated with
development. Sources of enrichment include agriculture and urban runoff.
Benthic conditions above the WWTP suggest that the WWTP is not the primary cause of impairment. The
WWTP discharge and sedimentation add to the stress the stream already experiences, but impacted
water quality exists prior to the WWTP discharge. The WWTP discharge is located approximately one
half mile prior to the confluence with the Rocky River. Although the WWTP discharge comprises most of
the stream flow (instream waste concentration = 96% at 7010 conditions) of Loves Creek, it affects a very
short segment of Loves Creek.
The upper site at SR 1006 did not contain benthos headwater fauna. This was most likely due to drought
conditions in 2002. Streams within the Slate Belt are characterized by very low base flows during
summer months, and often dry up completely during prolonged low -flow periods. This stress and
recovery cycle makes it difficult to characterize benthic communities in the Slate Belt ecoregion. The
Slate Belt characteristics of the upper reaches of Loves Creek are probably the cause of decreased
benthic fauna. However, since the upper portion is in an agricultural setting, nonpoint effects from
agricultural practices cannot be ignored as a possible source of impairment.
Cc: Ken Schuster, Raleigh Regional Office
Darlene Kucken, Planning Branch

Table 3. Benthic Macroinvertebrates Collected from the Loves Creek Watershed, June 23-25, 2003.
R (Rare) =1-2 specimens, C (Common) = 3-9 specimens, and A (Abundant) = > 10 specimens.
Loves C►
Loves C►
Loves Cr
Loves Cr
Loves Cr
Uf Loves Cr
Meadow Cr
6/23/03
6/23/03
6/24/03
6/24/03
6/24/03
6/23/03
6/25/03
SR 1006
below Golf
Second Ave
above
below
Greensboro
SR 2170
Course
WWTP
WWTP
Road
EPHEMEROPTERA
ACERPENNA PYGMAEA
R
BAETIS OUBIUS
R
BAETIS FLAVISTRIGA
A
A
A
A
R
BAETIS INTERCALARIS
R
R
C
BAETIS PLUTO
R
R
CAENIS SPP
R
A
CALLIBAETIS SP
C
R
CENTROPTILUM SPP
R
LEUCROCUTA SPP
C
R
C
PARALEPTOPHLEBIA SPP
R
R
STENONEMAFEMORATUM
A
R
C
A
A
R
A
STENONEMA MODESTUM
C
R
R
C
STENACRONINTERPUNCTATUM
C
STENACRON PALLIDUM
R
PLECOPTERA
PERLESTA SPP
A
C
A
TRICHOPTERA
CHEUMATOPSYCHE SPP
A
A
A
A
A
A
A
CHIMARRA SPP
R
DIPLECTRONA MODESTA
A
R
HYDROPSYCHE BETTENI
R
C
A
A
A
OECETIS SP A (FLOYD)
R
COLEOPTERA
DUBIRAPHIA SPP
C
R
R
R
HELICHUS SP
R
C
R
R
R
R
A
NEOPORUS SPP
A
A
A
C
R
A
OULIMNIUS LATIUSCULUS
R
PELTODYTES SPP
R
C
R
R
PSEPHENUS HERRICKI
R
RHANTUS SPP
R
SPERCHOPSIS TESSELLATUS
R
STENELMIS CRENATA
A
R
C
R
R
A
ODONATA
AESHNA UMBROSA
R
R
R
ARGIA SPP
R
C
A
A
BASIAESCHNA JANATA
R
R
C
BOYERIA VINOSA
C
C
C
ENALLAGMA SPP
C
C
C
GOMPHUS SPP
R
LIBELLULA SPP
C
SOMATOCHLORA SPP
C
R
R
R
A
MEGALOPTERA
CHAULIODES RASTRICORNIS
C
CORYDALUS CORNUTUS
R
NIGRONIA SERRICORNIS
C
SIALIS SPP
A
C
R
A
DIPTERA: CHIRONOMIDAE
ABLABESMYIA MALLOCHI
C
R
C
A
C
R
A
CRICOTOPUS BICINCTUS: CIO SP1
R
A
A
A
ORTHOCLADIUS (EUORTHOCLADIUS): CIO SP3
A
A
R
A
CRICOTOPUS/ORTHOCLADIUS SP44
C

Loves Cr
Loves Cr
Loves Cr
Loves Cr
Loves Cr
U1 Loves Cr
Meadow Cr
6/23103
6/23103
6/24/03
6/24/03
6/24/03
6/23/03
6/25/03
SR 1006
below Golf
Second Ave
above
below
Greensboro
SR 2170
Course
WWTP
WWTP
Road
CRICOTOPUS INFUSCATUS GR: C/O SP5
R
CRICOTOPUS VARIPES GR; CIO SP6
A
C
C
CHIRONOMUS SPP
R
CONCHAPELOPIA GROUP
A
A
A
A
A
A
A
CORYNONEURA SPP
A
R
C
R
CRYPTOCHIRONOMUS SPP
C
R
C
C
DICROTENDIPES SIMPSONI
R
TVETENIA BAVARICA GR (E SP1)
R
EUKIEFFERIELLA CLARIPENNIS GR (E SP11)
R
A
R
C
MICROPSECTRA SPP
R
MICROTENDIPES SPP
A
R
R
A
NANOCLADIUS SPP
R
R
C
C
R
NATARSIA SPP
A
R
A
A
R
C
NILOTHAUMA SPP
R
POLYPEDILUM CONVICTUM
A
A
A
A
A
A
POLYPEDILUM FALLAX
R
R
POLYPEDILUM ILLINOENSE
A
R
A
POLYPEDfLUM SCALAENUM
R
R
PARAMETRIOCNEMUS LUNDBECKI
C
C
C
R
C
PARATANYTARSUS SPP
A
PARATENDIPES SPP
C
PHAENOPSECTRA FLAVIPES
C
R
R
C
C
PROCLADIUS SPP
R
C
RHEOCRICOTOPUS ROBACKI
R
C
A
C
C
C
RHEOTANYTARSUS SPP
A
A
A
C
A
A
STENOCHIRONOMUS SPP
R
SYMPOSIOCLADIUS LIGNICOLA
R
TANYTARSUS SP1
R
TANYTARSUS SP2
C
R
R
TANYTARSUS SP3
C
TANYTARSUS SP6
R
THIENEMANIELLA SPP
A
C
A
C
THIENEMANIELLA SP B EPLER
A
THIENEMANIELLA XENA
C
XENOCHIRONOMUS XENOLABIS
R
R
R
ZAVRELIMYIA SPP
R
MISC. DIPTERA
ANOPHELES SPP
R
DIXELLA INDIANA
R
LIMONIA SPP
R
PALPOMYIA (COMPLEX)
R
R
R
C
SIMULIUM SPP
C
A
A
A
A
A
A
SIMULIUM VENUSTUM
A
A
A
R
C
TIPULA SPP
C
C
C
R
C
R
HEMIPTERA
BELOSTOMA SPP
R
CORIXIDAE
R
R
OLIGOCHAETA
CAMBARINICOLIDAE
R
C
ILYODRILUS TEMPLETONI
R
LIMNODRILUS SPP
C
C
LUMBRICULIDAE
C
R
A
A
A
R
A
NAIS SPP
R
SLAVINA APPENDICULATA
R
R
SPIROSPERMA NIKOLSKYI
R

Loves Cr
Loves Cr
Loves Cr
Laves Cr
Loves Cr
Ut Loves Cr
Meadow Cr
6/23/03
6/23/03
6/24/03
6/24/03
6/24/03
6123/03
6/25)03
SR 1006
below Golf
Second Ave
above
below
Greensboro
SR 2170
Course
WWTP
WWTP
Road
CRUSTACEA
CAECIDOTEA SP (STREAMS)
C
R
R
CAMBARUS SPP
A
C
A
C
A
A
CRANGONYX SPP
R
C
R
R
R
PELECYPODA
PISIDIUM SPP
R
R
A
C
SPHAERIUM SPP
C
VILLOSA DELUMBIS
R
GASTROPODA
FERRISSIA SPP
R
A
R
C
C
HELISOMA ANCEPS
R
R
A
MENETUS DILATATUS
C
R
R
R
C
PHYSELLA SPP
A
A
A
R
A
A
PSEUDOSUCCINEA COLUMELLA
C
R
OTHER
CLIMACIA AREOLARIS
A
❑UGESIA TIGRINA
R
A
R
ERPOBDELLA/MOOREOBDELLA
A
R
A
HELOBDELLA TRISERIALIS
R
R
HYDRACARINA
R
PETROPHILA SP
A
PROSTOMA GRAECENS
R

NCDENR WWIGW #624 Cameron Testing Services
US EPA Lab# NC0191a
Project: Initial Storm Water BOD 5 day (mg/L)
Client: Walk Softly, LLC Reference Std. Methods,
19th ed.
Sample Data
Report
5210 BOD5 - B
Sampled
HH
I Received
CSC Matrix
SW
Regulatory
Yes
Date
6/12/2010
Date
6/12/2010 Type
Grab
-LaWbirelctor
Page 1
a / zl 11D
Date

NCDENR WW1GW #624 Cameron Testing Services
LIS EPA Lab # NCO1918
Project: Initial Storm Water Styrene (ug1L)
Client: Walk Softly, LLC Reference SW-846
Sample Data
Report
5d35l826OB
Sampled 1- H
Received
CSC
I Matrix
SW Regulatory
I Yes
Date 6112)2010
1 Date
ShZ2014
I Type
Grata
k�, ,
����
Lab Director
Date
Palze I

NC WWIGW Certificate 654
EPA LAb# NCO1918
Cameron Testing Services, Inc.
Project: Initial Storm Water CTS Proj.
Solids Report
Client: Walk Softly LLC Regulatory
Sampled Received Due Ref. Methods Std. Meth. 19" ed.
By HH By CSC
Date 06/12/10 Date 06/12/10 Date Requested Analysis 2540 D - TSS
Tvpe Grab - Matrix SW
219 & Steele Str.
Sanford. NC 27330
SW-1
001
93
10
06/15/10
SW-2
002
257
10
06/15/10
SW-3
003
41
10
06/15/10
SW-4
004
296
10
06/15/10
SW-5
005
95
10
06/15/10
GSC
s
TSS (mglL�
LCS
..... ....
80.5
.:Rec,�Q
98.20%
Blank
< 10
Lab Director Date:
Notes: RL = Reporting Limit. Units always match analysis.
Rev. 1 c
Mar. 9, 2010

NC WWIGW Certificate 654
EPA LAb 9 NC01918
Cameron Testing Services, Inc.
219 S. Steele Str.
Sanford, NC 27330
Project:
Initial Storm Water
CTS Proj.
1flD5 OOT
Client:
Walk Softly, LLC
Regulatory
Yes
Sampled
Received
Ref:
Std. Meth. 19" ed.
By HH
By CSC
Date 06/12/10
Date 06/12/10
:.
Analysis
4500 HB - pH
-
Type Grab
Matrix SW
.,
i©
Lb'ID
pH
Analysis
Arla[yst
..Sampte
SW-1
001 7.95 06/12/10
SW-2
002 8.70 06/12/10
SW-3
003 7.29 06/12/10
SW-4
004 8.22 06/12/10
SW-5
005 7.98 06/12/10
a Hof /A)
Lab irector Date:
Notes: RL = Reporting Limit. Units always match analysis.
Sample pH was measured outside of holding time. Client brought samples immedaitely after collection.
Rev. 1 c
Mar. 9, 2010

NCDENR WWIGW #624 Cameron Testing Services
US EPA Lab # NC01918
Project: Initial Storm Water COD (mg/L) Report
Client: Walk Softly, LLC Reference Std. Methods, 5220 COD - D
19th ed.
Sam Ae Data
Sampled
HH
I Received
CSC
Matrix
SW
Regulatory
Yes
hate
6/12/2010
J Date
6/12/2010
Type
Grab
Lab Director
Page 1
66%zf/Ire
Date

Floorazzo Tile Manufacturing Facility Plan and Timeline for Separation of
Grinding Waste Product from Comingling with Stormwater Runoff
We expect to have funds from the Venture Capital organization we are currently
working with by the end of August. If we get those funds as currently planned we
will follow this time line. If we do not, we can not order this equipment until the
funds arrive.
1) September 1, 2010: Order one (1)Schubert Slurry Clean Water Clarifyer.
and Mud Separator*from VIC International with a 150 gallon per minute
capacity with storage tanks, filter bags, filters, and pump. This machine is
self contained and will separate the solids from the water and allow the, water
to be recycled back for reuse. The solids will be bagged and stored for
appropriate disposal.
2) October 15, 2010: Schubert Slurry Clean Water Clarifyer and Mud
Separator is built
3) October 30, 2010: Schubert Slurry Clean Water Clarifyer and Mud
Separator is shipped and delivered to Floorazzo Tile in Siler City.
4) November 30, 2010: Schubert Slurry Clean Water Claryfier and Mud
Separator is installed at Floorazzo Plant with corresponding piping, controls,
and overflow protections.
5) December 31, 2010: Troubleshooting and adjustments done to installation to
make sure installation takes care of all remaining stormwater issues and
checked to make sure there are no remaining violations or issues of possible
comingling of residuals from the facility with stormwater runoff.
Additional Items to be fully implemented by December 31, 2010 as per
suggestions by Vicki Webb of DENR:
1) Install permanent berm (minimum of 2" high) next to large garage style
door on Northwest side of building to keep material from plant migrating
outside the building and risk mixing with stormwater.

:ETILii
f. t'f l'�il� t '. r'r:�.
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ft. jig r1� �. .- 41 '�i-�f'{t W:
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Wi 791
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! vi, .`'t) tl�r 'S 1. /�; �A j�j�
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7-.. ,� f�tii�F :L'r._ ..• �!.
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f. C'i, ?�'., i` �.���'� 7 -y
V'�fr � _,ilr {�..?!'wf�`,:, �� .. ::a
:•� d'i!.i ;4 .`.r iit p l): + ;'! -
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ips: v!" ,l <.,°
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2) Close off storm drain outfall #4 and instead install a sump pump and pump
any material or water that collects at this -point into the sludge clarifying
system to be recycled.
3) Enclose the sludge clarifying area with a 16" high cement block berm to
contain any spills and add further assurance that no material from the plant
can comingle with stormwater.
4) Initiate a weekly inspection check list of items to inspect for compliance.
Items on the list will include but not be limited to: No evidence of material
from the plant migrating to outside the plant, sludge clarification machinery
operating correctly with no overflow, safety berms in place and functioning
correctly, and no outside storage of uncovered containers. Keep a record of
the weekly inspections with verification of any maintenance performed.

31