NCG030245_MONITORING INFO_20190606

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V
DOC TYPE
❑ HISTORICAL FILE
[3K-MONITORING REPORTS
DOC DATE
❑ c). of Cl 00 0o
YYYYM M DD

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
May 28, 2019
Division of Water Quality
Attn: DWQ Central Files JUN 0 6 2019
North Carolina Department of Environment and Natural Resources CENT
RAL FILES
1617 Mail Service Center DWR SECTION)
Raleigh, NC 27699-1617
Re: May 2019 - STORMWATER DISCHARGE OUTFALL (SDO) MONITORING
REPORT
Dear Sir/Madam:
1 am submitting the following information:
May 2019- STORMWATER DISCHARGE OUTFALL (SDO) MONITORING REPORT
for the dormakaba USA Inc., (formerly Kaba Ilco) Winston-Salem Facility. Samples collected
were over the Benchmark for Copper and Zinc.
Thank you for your assistance in this matter. Please contact me with any questions.
Sincerely,
ohn Zit!
Operations Manager
335-725-1331 Ext. 1395
Enclosures:
May 2019- STORMWATER DISCHARGE OUTFALL (SDO) MONITORING REPORT (2 copies)
Kaba Access& Data Systems - Americas
2941 Indiana Ave., Winston-Salem, NC 27105
Phone: [phone], Fax: [phone]
www.kaba-adsamedcas.com

Semi-annual Stormwater Discharge Monitoring Report
for North Carolina Division of Water Quality General Permit No. NCG030000
Date submitted 05-28-19
CERTIFICATE OF COVERAGE NO. NCG030246
SAMPLE COLLECTION YEAR 2019
FACILITY NAME dormakaba USA Inc. (formerly KABA ILCO CORP.!
SAMPLE PERIOD - Jan -.tune - . July -Dec
or Monthl 1 Ma month
COUNTY FORSYTH
PERSON COLLECTING SAMPLES
DISCHARGING TO CLASS ORW - HQW - Trout - PNA
Zero -flow - Water Supply - SA
Other
LABORATORY R&A LABORATORIES Lab Cert. # 34
Comments on sample collection or analysis:
PLEASE REMEMBER TO SIGN ON PAGES 2 AND/OR 3 ==_�
Part A: Stormwater Benchmarks and Monitoring Results
Outfatl No.
Date Sample
CoNectedl
i m olddly r)
24-hour
rainfall
amount,
lnches3
Total Suspended
Solids
PH,
Standard
units
Copper
Lead
Zinc
Non -Polar
O&Grrotal
Petroleum
Hydrocarbons
Total Toxic
Organics5
Benchmarks =__>
- -
-
100 mglL or 50 m911-4
6.0 — 9.0
0.007 mg1L
0.033 mglL
0,067 mg1L
15 m91L
1 mg1L
B
05/13/2019
0.9
18.6
6.9
0.052
<0.005
0.625
<5.0
NA
1 Monthly sampling (instead of semi-annual) must begin with the second consecutive benchmark exceedance for the same parameter at the same outfall,
2 For sampling periods with no discharge at any single outfall, you must still submit this discharge monitoring report with a checkmark here,
3 The total precipitation must be recorded using data from an on -site rain gauge. Unattended sites may be eligible for a waiver of the rain gauge requirement.
4 See General Permit, Table 3 identifying the especially sensitive receiving water classifications where the more protective benchmark applies,
5 Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations, manufacture semiconductors, manufacture electronic crystals, or
manufacture cathode ray tubes. For purposes of this permit the definition of Total Toxic Organics is that definition contained in the EPA Effluent Guidelines for the facility subject to the
requirement to sample (far metal finishing use the definition as found in 40 CFR 43111; for semiconductor manufacture use the definition as found in 40 CFR 469.12: for electronic
crystal manufacture use the definition as found in 40 CFR 469.22; and for cathode ray tube manufacture use the definition found in 40 CFR 469.31)_
Permit Date: 11/1/2012-10/31/2017 SWU-245, last revised 10/25/2012
Page 1 of 3

Facilities that incorporate a solvent management plan into the Stormwater Pollution Prevention Plan may so certify, and the requirement
for TTO monitoring may be waived. The solvent management plan shall include a list of the total toxic organic compounds used and the other
elements listed in the General Permit. For those facilities electing to employ the TTO monitoring waiver, the discharger shall sign the following
certification statement:
"Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit monitoring requirement for
total toxic organics
(TTO), I certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the stormwater or areas which are
exposed to rainfall or stormwater runoff has occurred since filing the last discharge monitoring report. I further certify that this facility is
implementing the all the provisions of the solvent management plan included in the Stormwater Pollution Prevention Plan."
Name (Print name) John Zill
Title (Print title) Operations Manager
{Signature} (Date)
Note: Results must be reported in numerical format. Do-iiot report Below Detection Limit, BDL, <PQL, Non -detect, ND, or other similar non -numerical
format. When results are below the applicable limits, they must be reported in the format, "<XX mg1L", where XX is the numerical value of the
detection limit, reporting limit, etc. in mg/L.
Note: If you report a sample value in excess of the benchmark, you must implement Tier 1, Tier 2, or Tier 3 responses. See General
Permit text
Part B: Vehicle Maintenance Area Monitoring Results: only for facilities averaging > 55 gal of new oil per month.
No discharge this period?2
Outfall No.
Date Sample
Collected)
(molddlyr)
24-hour rainfall
amount,
Inches3
Non -Polar O&Grrotal Petroleum
Hydrocarbons
Total Suspended Solids
pH,
Standard units
Benchmarks
15 mglL
100 mglL or 50 mg/L4
6.0 — 9.0
Footnotes from Part A also apply to this Part B
* See General Permit text, Table 5, identifying the especially sensitive receiving water classifications where the more protective benchmark applies.
Permit Date: 11/1/2012-10/31/2017 SWU-245, last revised 10/25/2012
Page 2 of 3

Note: If you report a sample value in excess of the benchmark, you must implement Tier 1, Tier 2, or Tier 3 responses. See
General Permit text.
FOR PART A AND PART B MONITORING RESULTS:
A BENCHMARK EXCEEDANCE TRIGGERS TIER 1 REQUIREMENTS. SEE PERMIT PART 11 SECTION B.
2 EXCEEDANCES IN A ROW FOR THE SAME PARAMETER AT THE SAME OUTFALL TRIGGER TIER 2 REQUIREMENTS. SEE PERMIT PART II SECTION B.
TIER 3: HAS YOUR FACILITY HAD 4 OR MORE BENCHMARK EXCEEDENCES FOR THE SAME PARAMETER AT ANY ONE OUTFALL? YES
IF YES, HAVE YOU CONTACTED THE DWQ REGIONAL OFFICE? YES
REGIONAL OFFICE CONTACT NAME: Ms. Anna Taylor Smith
Mail an original and one copy of this DMR, including all "No Discharge" reports, within 30 days of receipt of the lab results
(or at end of monitoring period in the case of "No Discharge" reports) to:
Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
YOU MUST SIGN THIS CERTIFICATION FOR ANY INFORMATION REPORTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for
knowing violations."
(Sig a of iPe ee}
/pi_ .J.�
0v
Permit Date: 11/1/2012-10/31/2017
SWU-245, last revised 10/25/2012
Page 3 of 3

Semi-annual Stormwater Discharge Monitoring Report
for North Carolina Division of Water Quality General Permit No. NCG030000
Date submitted 4-18-19
CERTIFICATE OF COVERAGE NO. NCG030245
SAMPLE COLLECTION YEAR 2019
FACILITY NAME dormakaba USA Inc. (formerly
KABA ILCO CORP.)
SAMPLE PERIOD • Jan -June - July -Dec '
or Monthl 1 A ri1 month
COUNTY FORSYTH
GV
F'
PERSON COLLECTING SAMPLES
I
t �" """
DISCHARGING TO CLASS • ORW • HQW - Trout • PNA
KA Y 19
Zero -flow • Water Supply • SA
LABORATORY RSA LABORATORIES Lab Cert. # 34
Cl=iv I IKAL FILES
1
Other
Comments on sample collection or analysis:
Lw ' ` LV T "-',
PLEASE REMEMBER TO SIGN ON PAGES 2 AND/OR 3 =__>
Part A: Stormwater Benchmarks and Monitoring Results
Outfall No.
Date Sample
Collectedi
(molddlyr)
24-hour
rainfall
amount,
Inches3
Total Suspended
Solids
pH,
Standard
units
Copper
Lead
Zinc
Non -Polar
O&G1Total
Petroleum
Hydrocarbons
Total Toxic
Organics5
Benchmarks
- -
-
100 mg1L or 50 mg1L4
6.0 — 9.0
0.007 mglL
0.033 mg1L
0.067 mg1L
15 mg1L
1 mg1L
B
04/05/19
0.25
12.0
7.73
0.075
<0.005
0.312
<5.0
NA
I
1 Monthly sampling (instead of semi-annual) must begin with the second consecutive benchmark exceedance for the same parameter at the same outfall.
2 For sampling periods with no discharge at any single outfall, you must still submit this discharge monitoring report with a checkmark here.
3 The total precipitation must be recorded using data from an on -site rain gauge. Unattended sites may be eligible for a waiver of the rain gauge requirement.
4 See General Permit, Table 3 identifying the especially sensitive receiving water classifications where the more protective benchmark applies.
5 Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations, manufacture semiconductors, manufacture electronic crystals, or
manufacture cathode ray tubes. For purposes of this permit the definition of Total Toxic Organics is that definition contained in the EPA Effluent Guidelines for the facility subject to the
requirement to sample (for metal finishing use the definition as found in 40 CFR 433.11; for semiconductor manufacture use the definition as found in 40 CFR 469.12; for electronic
crystal manufacture use the definition as found in 40 CFR 469.22; and for cathode ray tube manufacture use the definition found in 40 CFR 469.31).
Permit Date: 11/1/2012-10/31/2017 SWU-245, last revised 10/25/2012
Page 1 of 3

Facilities that incorporate a solvent management plan into the Stormwater Pollution Prevention Plan may so certify, and the requirement
for TTO monitoring may be waived. The solvent management plan shall include a list of the total toxic organic compounds used and the other
elements listed in the General Permit. For those facilities electing to employ the TTO monitoring waiver, the discharger shall sign the following
certification statement:
"Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit monitoring requirement for
total toxic organics
(TTO), I certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the stormwater or areas which are
exposed to rainfall or stormwater runoff has occurred since filing the last discharge monitoring report. I further certify that this facility is
implementing the all the provisions of the solvent management plan included in the Stormwater Pollution Prevention Plan."
Name (Print name) John Zill
Title (Print title) Operations Manager
(Signature)0 - (Date) goz,l
Note: Results must be reported in numerical format. ynot report Below Detection Limit, BDL, <PQL, Non -detect, ND,/or other similar non -numerical
format. When results are below the applicable limits, they must be reported in the format, "<XX mg1L", where XX is the numerical value of the
detection limit, reporting limit, etc. in mg/L.
Note: If you report a sample value in excess of the benchmark, you must implement Tier 1, Tier 2, or Tier 3 responses. See General
Permit text.
Part B: Vehicle Maintenance Area Monitoring Results: only for facilities averaging a 55 gal of new oil per month.
No discharge this period72
Outfall No.
Date Sample
Collectedl
(molddlyr)
24-hour rainfall
amount,
Inches3
Non -Polar O&G1Total Petroleum
Hydrocarbons
Total Suspended Solids
PH,
Standard units
Benchmarks =__>
15 mg1L
100 mglL or 50 mgli_4
6.0 — 9.0
Footnotes from Part A also apply to this Part B
* See General Permit text, Table 5, identifying the especially sensitive receiving water classifications where the more protective benchmark applies.
Permit Date: 11/1/2012-10/31/2017 SWU-245, last revised 10/25/2012
Page 2 of 3

Note: If you report a sample value in excess of the benchmark, you must implement Tier 9, Tier Z or Tier 3 responses. See
General Permit text.
FOR PART A AND PART B MONITORING RESULTS:
• A BENCHMARK EXCEEDANCE TRIGGERS TIER 1 REQUIREMENTS. SEE PERMIT PART II SECTION 13.
2 EXCEEDANCES IN A ROW FOR THE SAME PARAMETER AT THE SAME OUTFALL TRIGGER TIER 2 REQUIREMENTS. SEE PERMIT PART II SECTION B.
TIER 3: HAS YOUR FACILITY HAD 4 OR MORE BENCHMARK EXCEEDENCES FOR THE SAME PARAMETER AT ANYONE OUTFALL? YES
IF YES, HAVE YOU CONTACTED THE DWQ REGIONAL OFFICE? YES
REGIONAL OFFICE CONTACT NAME: Ms. Anna Taylor Smith
Mail an original and one copy of this DMR, including all "No Discharge" reports, within 30 days of receipt of the lab results
(or at end of monitoring period in the case of "No Discharge" reports) to:
Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
YOU MUST SIGN THIS CERTIFICATION FOR ANY INFORMATION REPORTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for
knowing violations."
(Si re of Pe ee)
Permit Date:11/1/2012-10/31/2017
/A , /-2
( te)
5WU-245, last revised 10/25/2012
Page 3 of 3

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 18, 2019
Division of Water Quality
Attn: DWQ Central Files
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: April 2019 - STORMWATER DISCHARGE OUTFALL (SDO) MONITORING
REPORT
Dear Sir/Madam:
1 am submitting the following information:
April 2019- STORMWATER DISCHARGE OUTFALL (SDO) MONITORING REPORT
for the dormakaba USA Inc., (formerly Kaba Ilco) Winston-Salem Facility. Samples collected
were over the Benchmark for Copper and Zinc.
Thank you for your assistance in this matter. Please contact me with any questions.
Sincerely,
John Zill
Operations Manager
336-725-1331 Ext. 1395
Enclosures:
April 2019- STORMWATER DISCHARGE OUTFALL (SDO) MONITORING REPORT (2 copies)
Kaba Access& Data Systems - Americas
2941 Indiana Ave., Winston-Salem, NC 27105
Phone. [phone], Fax: [phone]
www. kaba-adsa mericas.ccm

PIEDMONT RECEIvEn 6003-145 Chapel Hill Rd.
27607
GEOLOGIC RaF:919 85 -9532 j. A: 919-854-9700 F: 919-854-9532
SnAP,RT EARTH sol UTlol`!s MAR 2 4 2010 www.piedmontgeologic,com
1
Regional office
office
STORMWATER POLLUTION
PREVENTION PLAN
Kaba Ilco Corporation
2941 Indiana Avenue
Winston-Salem, North Carolina
PREP 4RRD L Y
Piedmont Geologic, P.C.
6003 Chapel Hill Road, Suite 145
Raleigh, North Carolina 27607
Revised March 22, 2010

March 23, 2010
Mr. Steve Tedder
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Winston-Salem Region
585 Waughtown Street
Winston-Salem, NC 27107
RE: NOTICE OF VIOLATION
Compliance Evaluation Inspection
Kaba Ilco Corp -Forsyth
Permit No. NCGO30245
Forsyth County
Dear Mr. Tedder:
"IA106 RECOVE0
N.C, D9ot. of ENR
MAR 24 2010
i
WinatanSalem j
Regionai Office
This letter is being submitted in response to the Notice of Violation (NOV) for the Kaba llco facility located at 2941
Indiana Ave., Winston-Salem, Forsyth county, North Carolina issued by North Carolina Department of Environment
and Natural Resources (NCDENR), Division of Water Quality (DWQ), Winston-Salem Region on February 25,
2010. In response to the NOV, Kaba Ilco has taken the following actions to ensure compliance with NPDES
General Permit NCG030000:
Compliance Issue_ 1_ Failure to include annual recertification that outfalls do not contain non-stormwater
discharges.
Res onse 1: The non-stormwater discharge assessment and certification was completed on March 15, 2010.
Outfalls B and C were directly observed during the test. No non-stormwater discharges were observed. A copy of
the non-stormwater discharge assessment and certification is provided as Worksheet No. 5 in Appendix F of the
enclosed Stormwater Pollution Prevention Plan (SPPP), updated in March 2010.
Compliance Issue 2: The map does not list the drainage areas to each outfall nor the percentage of impervious area.
Response 2: An updated site map is provided as Figure 2 in the enclosed SPPP. The map lists the drainage areas
and percentage of impervious area for each drainage area.
Compliance Issue 3: The feasibility study of changing methods of operation to eliminate or reduce exposure
appears to need an update.
Response 3: In response to the comments on page 3 of the February 23, 2010 Compliance Inspection Report, Kaba
llco has taken the following actions:
1. The 55-gallon drums containing nitric acid and the 15-gallon drums containing sulfuric acid and
hydrochloric acid that were observed outside the wastewater treatment building have been transferred to the
secondary hazardous material area (chemical storage room inside the main building). Section 1.2 of the
SPPP has been updated with this storage practice. The 55-gallon drums of ammonia remain outside under
shelter until determination that storage in the chemical storage room is an appropriate storage practice.
2. The two 250-gallon, double -walled polyethylene tanks utilized for transferring wastewater to the
wastewater treatment building remain empty when not in use and are tightly sealed to prevent stormwater
exposure.
Kaba Access Control
2941 Endiana Ave., Winston-Salem, NC 27105
Phone: [phone], Fax: [phone]
www.kabaacGess.com

3. The empty drums that were observed in several locations, including near the south loading bay (20+), have
been removed from the facility.
4. The exposed wood pallets on the east and north sides of the plant and the open top dumpster containing
scrap metal equipment on the south end of the plant have been implemented into the SPPP as exposed
materials. These materials are itemized on Worksheet No.'s 3a and 7 in Appendix F of the SPPP. The
scrap metal dumpster was removed from the site in March 2010. Kaba Ilco is currently evaluating the
potential for construction of a canopy at the south end of the main building. The canopy would provide
sufficient cover for any future scrap metal waste generated and wood pallets stored at the facility.
5. Worksheet No. 4 (Significant Spills/Leaks) was updated on March 15, 2010 and is provided in Appendix F
of the SPPP.
Compliance Issue 4: Stotmwater data was not submitted for this facility in 2008 or 2009.
Res- o� nse 4: Kaba Ilco is working in conjunction with a North Carolina certified laboratory to collect stormwater
samples from the Outfall B sampling location on a semi-annual basis. Qualitative and analytical stormwater
monitoring will coincide during a representative storm event. Copies of the Analytical and Qualitative Stormwater
Discharge Out€all (SDO) Monitoring Reports are contained on file at the office of the main building at the facility_
Completed Qualitative and Analytical SDO Monitoring Reports will be mailed to the NCDENR-DWQ, Winston-
Salem Region within thirty days of receipt of laboratory results. The updated stormwater sampling protocol is
provided as Appendix E in the SPPP.
The first comment on page 4 of the February 23, 2010 Compliance Inspection Report states that the Kaba Ilco
facility in Winston-Salem, North Carolina did not have a copy of the NPDES General Permit or Certificate of�,��
Coverage issued in October 2007. it has been determined that NCDENR-DWQ, V utistbrr-Saletx�egion
inadvertently sent the 2007 NPDES General Permit and Certificate of Coverage to the Kaba Ilco facility in Rocky
Mount, North Carolina. Copies of the 2007 NPDES General Permit No. NCG030000 and Certificate of Coverage
No. NCG030245 are now contained on file at the office of the Kaba Ilco facility in Winston-Salem, North Carolina.
In order to ensure satisfaction of the requirements of the NPDES General Permit and to prevent the recurrence of
similar compliance issues in the future, Kaba Ilco personnel roles have been clearly defined as it pertains to the
SPPP. Personnel roles and responsibilities as it pertains to the SPPP will be reinforced and evaluated on a quarterly
basis. Stormwater monitoring timelines have been clearly defined and Kaba llco has contracted with a state -
certified laboratory to ensure the requirements of the NPDES General Permit are fulfilled. The SPPP will be
reviewed and updated annually or as facility conditions or processes warrant.
If you have any questions or would like any additional information, please do not hesitate to call.
Sincerely,
40���
Michael Kincaid
General Manager
Enclosure
Cc:. Steve.Mauney
Kaba Access Control
2941 Indiana Ave., Winston-Salem, NC 27105
Phone: [phone], Fax: [phone]
www,kabaaccess.com

TABLE OF CONTENTS
Page No.
1.0 INTRODUCTION.............................................................................................................................3
1.1 SITE DESCRIPTION................................................................................................................................
1.2 STORAGE AND LOADING PRACTICES, DISPOSAL METHODS, AND OUTDOOR PROCESSES ......................4
1.3 SITE MAP............................................................................................................................................. 5
1.4 SIGNIFICANT SPILLS/LEAKS ..................................................................................................................6
1.5 CERTIFICATION OF OUTFALLS FOR NON-STORMWATER DISCHARGES .................................................. 6
2.0 STORMWATER MANAGEMENT PLAN....................................................................................6
2.1 REGULATORY DEFINITION OF EXPOSURE............................................................................................. 6
2.2 EXPOSURE ASSESSMENT......................................................................................................................7
2.3 EXISTING STORMWATER MANAGEMENT PRACTICES ............................................................................8
2.4 MEASURES TO MINIMIZE EXPOSURE....................................................................................................8
2. 4.1 Good Housekeeping.................................................................................................................... 9
2.4.2 Preventative Maintenance........................................................................................................... 9
2. 4.3 Visual Inspections....................................................................................................................... 9
2.4.4 Spill Prevention and Response.................................................................................................... 9
.r 2.4.5 Erosion Control and Runoff Management................................................................................10
3.0 SPILL PREVENTION AND RESPONSE PLAN.........................................................................I@
3.1 RESPONSIBLE INDIVIDUALS................................................................................................................ 10
t 3.2 POTENTIAL SPILL AREAS.................................................................................................................... 11
3.2.1 Wastewater Treatment Building................................................................................................11
3.2.2 Material Transfer Operations...................................................................................................12
e 3.2.3 Miscellaneous Drum Storage....................................................................................................12
3.3 STORAGE AND MATERIAL HANDLING REQUIREMENTS.......................................................................12
3.4 SPILL CLEANUP EQUIPMENT............................................................................................................... U
4.0 PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING....................................14
5.0 EMPLOYEE TRAINING SCHEDULES......................................................................................14
List _of_Figures
1 USGS quadrangle map excerpt
' 2 Facility map
List of Appendices
A Inspection Comments
B Certificate of Coverage and General Permit
C Solvent Management Plan
D Contingency Plan
E Stormwater Sampling Protocol
F Pollution Prevention Plan Worksheets
G Photographs
pIEDMOAIT GiEOL0G.'C, AC: ii

1.0 INTRODUCTION
This document presents a Stormwater Pollution Prevention Plan (SPPP) for the Kaba Ilco Corp. facility in
Winston-Salem, North Carolina. The SPPP is part of the requirements for coverage under the National
Pollution Discharge Elimination System (NPDES) General Permit No. NCG030000 and is a revision of the
previous Stormwater Pollution Prevention Plan by Piedmont Geologic, P.C., dated June 2, 2004. The
revisions reflect continents given to Kaba Ilco Corp. by North Carolina Department of Environment and
Natural Resources (NCDENR) Division of Water Quality personnel following a site inspection on February
23, 2010. A copy of the comments sheet from the site inspection is contained in Appendix A.
A copy of General Permit facility Certificate of Coverage No. NCGO30245 is included in Appendix B. A
facility Solvent Management Plan is contained in Appendix C. The Contingency Plan for the Kaba Ilco,
Winston-Salem facility is included in Appendix D, and the Stormwater Sampling Protocol is contained in
Appendix E.
This Stormwater Pollution Prevention Plan will be updated any time there is a change in stormwater
discharge practices, control measures, or on -site processes with the potential to impact sormwater quality.
1.1 Site Description
The Kaba Ilco Corp., Winston-Salem facility is located at 2941 Indiana Ave., in Winston-Salem, Forsyth
County, North Carolina (Figure 1). The site is located at approximately 80° 14' 15" W longitude and 36'
07' 45" N latitude and comprises an approximately 120,000 square foot facility for manufacturing of
security products and lock components. Site activities include electroplating, stamping, die casting of metal
pans, and final assembly of locks. The facility is listed under the Standard Industry Classification (SIC)
Code of 34 (Fabricated Metal Products).
The facility occupies approximately 10.5 acres between Indiana Ave. and a Norfolk Southern Co. railroad
right-of-way (Figure 2). Approximately 7.0 acres (67%) of the site is impervious to rainwater due to
structures and paved areas. Structures at the facility include a main building used for manufacturing, office,
and warehouse purposes, a foundry building, a wastewater treatment building, and assorted outbuildings.
An asphalt parking area is situated between the main building and Indiana Ave. Formerly undeveloped
open ground (the "southern side yard") is situated between the main building and the southeast property
perimeter (Figure 2). The southern side yard was developed into an employee park in 1997.
PIEDMONT GEOLOGIC, P.C. 3

Stormwater at the site generally flows southeast to municipal storm sewers along Indiana Avenue.
Stormwater then drains from the storm sewers along Indiana Avenue to an unnamed tributary of the Brushy
Fork, from the Brushy Fork to Salem Creek, and eventually discharges to the Yadkin River. This drainage
travels south from the site.
1.2 Storage and Loading Practices, Disposal Methods, and Outdoor Processes
Storage, loading, and disposal practices at the Kaba Ilco facility were observed during a site visit on March
15, 2010. The Kaba Ilco facility is listed with the NCDENR Solid Waste Management Division (SWMD)
as a generator of hazardous materials (Facility ID No. NCD0248 9 5 8 64) as regulated by the Resource
Conservation and Recovery Act (RCRA).
Hazardous wastes which are generated during the on -site operation are contained and stored inside the
hazardous materials storage building. The storage building is divided into two separate bays for hazardous
materials and hazardous wastes. The building has a secondary containment dike designed to keep all spills
inside the storage area. A secondary hazardous materials storage area is located inside the chemical storage
room in the main building. No hazardous waste is stored inside of the chemical storage room. The
hazardous materials storage building and chemical storage room both remain locked with access restricted
to authorized personnel only. Signs are present designating these areas as hazardous materials storage areas.
Hazardous -waste containers are periodically removed by licensed haulers and disposed of in accordance
with state and federal guidelines. The Kaba Ilco facility does not have a hazardous waste storage permit;
therefore, hazardous materials containers are not stored at the facility for over 90 days.
Process liquid wastewater, which contains various metals and cyanides, is treated by the on -site wastewater
treatment facility to precipitate metals and adjust the pH. The treated water is discharged to the City of
Winston-Salem sanitary sewer system. The wastewater treatment facility has the capacity to store
approximately 6,000 gallons of untreated wastewater should it become necessary in an emergency situation.
Smaller quantities (<55 gallons) of various chemical and oils are stored at various tool locations around the
facility. These small quantities provide easy access to chemicals used in smaller volumes. Barrels used to
store the small quantities are triple rinsed, labeled, and reused for storage of hazardous materials.
The electroplating process area is surrounded by dikes and trenches which drain any spilled liquids to the
wastewater treatment facility. The concrete expansion joints in this area are sealed to prevent spilled liquids
from traveling through expansion joints and into the underlying soil.
PIEDMONT GEOLOGIC, P.C. 4

Solid non -hazardous materials are placed into covered dumpsters. Metal shavings and scraps that may still
contain some cutting oils are stored in a rollaway dumpster, under a permanent cover, located behind the
facility. Scrap metal equipment is placed into an open -top dumpster at the south end of the facility near the
loading bay. The dumpsters and their contents are periodically removed by private contractors. Used wood
pallets are stacked along the sides of buildings on the northwestern and central portions of the site.
Loading and unloading of materials from trucks is accomplished in an indoor loading area at the northwest
corner of the building. Bays for trailer loading/unloading are enclosed with weather sealing pads around the
doors. Materials being loaded and unloaded are not exposed to stormwater. There is an additional loading
dock on the south end of the building that is used occasionally. This loading bay is also enclosed with
weather sealing pads and loaded/unloaded materials are not exposed to stormwater.
There are no outdoor process operations with the exception of drums being moved between the main
building and the hazardous storage building. An area used for old equipment storage was located on the
southeast end of the site. The equipment was cleaned of process materials before being placed outside and
covered with plastic sheeting. The stored equipment may have contained some residual hydraulic oils and,
as a result, was covered with plastic sheeting minimizing exposure to stormwater. The old equipment was
removed from the site in July 2008.
1 1.3 Site Map
A site map of the Kaba Ilco facility is provided as Figure 2. The map shows the locations of materials
storage, disposal areas, process areas, and loading/unloading areas. Two distinct drainage areas are present
' at the facility, as shown on Figure 2. Drainage area I is comprised of approximately 5.6 total acres with 2.6
acres (46%) being impervious to infiltration and drains the main building rooftop, the hazardous storage
' building rooftop, the old machinery storage area, and undeveloped land. Stormwater in the Drainage Area 1
flows to the east then southeast off the Kaba 11eo property. Drainage Area 2 is comprised of approximately
Q 4.9 total acres with 4.4 acres (89%) being impervious to infiltration and drains the parking area and the
main building rooftop. Stormwater from Drainage Area 2 flows southwest off the Kaba Ilco property.
As requested by NCDENR and City of Winston-Salem personnel, sampling Outfall B. was moved from its
previous location (Figure 2) in the southeastern corner of the property to a location adjacent to the
hazardous materials storage building. A drop box with a stubbed out pipe was installed to grade to allow
proper stormwater sampling. Also as requested, Outfall C was eliminated from the stormwater sampling
plan.
PIEDMONT GEOLOGIC, P.C. 5

' 1.4 Significant SpilIs/Leaks
According to Mr. Ed Lodics, the Operations Manager for the Kaba Ilco facility, there have not been any
significant spills within the last 3 years at the facility. This is documented on Worksheet #4 in Appendix F.
1.5 . Certification of Outfalls for Non-Stormwater Discharges
Stormwater outfalls were evaluated for the presence of non-stormwater discharges during dry weather.
Examination of drainage piping and observation of the outfalls was performed by Piedmont Geologic
personnel on March 15, 2010. The certification statement included on Worksheet 95 in Appendix F of this
report is provided in accordance with the requirements found in Part II, Section A-1 e of General Permit
NCG030000.
2.0 STORMWATER MANAGEMENT PLAN
This Stormwater Management Plan is an integral part of the Stormwater Pollution Prevention Plan and is
included under the requirements of General Permit NCG030000, Part II, Section A-2.
1 2.1 Regulatory Definition of Exposure
The requirement for an NPDES stormwater permit is based on exposure of materials and activities to
Stormwater runoff. The NCDENR Division of Water Quality defines exposure as including areas such as:
• Material handling sites;
• Refuse sites;
1 • Sites used for the application or disposal of process wastewaters
• Sites used for the storage and maintenance of material handling equipment;
• Sites used for residual treatment storage, or disposal;
• Shipping and receiving areas;
• Manufacturing buildings;
• Storage areas for raw, intermediate, waste, byproduct, and finished materials; and
' • Areas where industrial activity has taken place in the past and significant materials remain open to
the elements.
1 PIEDMONT GEOLOGIC P.C. 6

' Exposure is interpreted to include the following conditions:
' • Dumpsters containing trash associated with the manufacturing processes that are exposed to
rainfall or subsequent stormwater runoff. Exceptions are fully enclosed compaction dumpsters that
are loaded from inside a building and dumpsters containing administrative office wastes or
cafeteria wastes;
e • Wood pallets that have been used to store or transfer materials associated with the industrial
manufacturing operations which are stored outside. The same interpretation applies to any type of
shelving system that is used to store materials associated with industrial activity;
• Bulk storage of liquid products that has no secondary containment or that has secondary
containment with a direct, uncontrolled connection to the stormwater conveyance system; and
• Drums, full or empty, that are stored outside without cover, such that stormwater can wash through
the storage area without control and discharge to the stormwater conveyance system.
2.2 Exposure Assessment
The following on -site areas, itemized on Worksheets #3A and #7 (Appendix F), are considered exposed
according to the above definition:
• Wood pallets located on northwestern and central portions of site; and
• Scrap metal located inside of an open -top rollaway dumpster on the central portion of the site near
the south loading bay.
The following activities were also observed and evaluated for the possibility of generating exposure:
• Loading(Unloading Docks located on the west side of the building and one additional bay on the
' south side of the building, which is only used occasionally. These bays are enclosed with weather
sealing pads that do not allow exposure to stormwater.
• The Hazardous Materials Storage building contains both hazardous wastes and hazardous
materials in separate bays. The building has restricted entry and is surrounded by containment
dikes.
• The Bulk Liquid Wastewater Tanks are located inside the wastewater treatment building.
Wastewater containing cyanides and metals is collected in a sump and various treatment tanks. The
' tanks are inside the building and surrounded by containment dikes.
PIEDMONT GEOLOGIC P.C. 7

• The Plating Bath Line is indoor and surrounded by trenches that collect spilled liquids and transfer
them directly to the facility wastewater treatment plant. The area is also surrounded by a concrete
dike.
• Garbage and metal recycling dumpsters are located under permanent cover that does not allow
exposure to stormwater.
• Smaller quantities (<55 gallons) of various chemicals are temporarily stored in different locations
around the plant to provide convenient access for use. Chemicals are stored on drip pads adjacent
to adequate supplies of spill absorbents.
The above activities were determined to be sufficiently covered and/or spill protected to prevent exposure
to stormwater. All of these activities are either indoors or covered. Bulk liquid storage tanks are spill
protected.
2.3 Existing Stormwater Management Practices
Efforts to minimize exposure to stormwater at the Kaba Ilco facility have resulted in the following Best
Management Practices. Worksheet #7 in Appendix F also lists some of these management practices.
• All large storage tanks have secondary containment dikes to prevent spills from entering
stormwater conveyances. Underground storage tanks and aboveground storage tanks located
outside the building have all been removed.
• All loading/unloading of materials and products from trucks takes place directly into the building
via weather sealed docks.
• Hazardous wastes and materials are stored in their respective bays inside the hazardous materials
storage building which is spill protected by secondary containment dikes.
• Paints and flammable solvents are stored inside locked cabinets when not in use.
• All garbage dumpsters are under permanent covers which do not allow exposure to stormwater.
0
2.4 Measures to Minimize Exposure
Areas of stormwater exposure at Kaba llco, Winston-Salem facility have been evaluated by Piedmont
Geologic for the feasibility of changing operation and storage practices to limit or eliminate stormwater
exposure. Best Management Practices are required in the following categories.
PIEDMONT GEOLOGIC, P. C 8

2.4.1 Good housekeeping
The most effective means of preventing stormwater pollution that results from accidental discharges is by
maintaining an organized and clean working environment. Inspections of manufacturing area for both safety
and good housekeeping are performed by department managers and members of the Pollution Prevention
Team listed in Worksheet #1 in Appendix F. All areas are observed during the course of normal facility
operation by trained operators and employees who are able to routinely detect any problems with
operations. Responsibilities for good housekeeping outside of the plant building belong to the Maintenance
Department Supervisor. Good housekeeping in each area inside the plant in the responsibility of each
employee assigned to that area.
2.4.2 Preventative Maintenance
The Maintenance Department Supervisor is responsible for preventative maintenance involving stormwater
management devices at the facility. Should potential problems be detected in containment, bulk storage, or
drainage pathways, the Maintenance Department is responsible for repairs. There are no stormwater
controls employed at the Kaba llco facility. Existing stormwater conveyances consist of surface flow across
an undeveloped field to an open ditch along the southern edge of the property and surface flow across the
employee parking lot to a municipal storm drain along Indiana Avenue. The open ditch eventually flows to
a municipal storm drain that is located south of the facility along Indiana Avenue.
I2A.3 Visual Inspections
Formal and informal inspections are conducted at the Kaba Ilco, Winston-Salem facility on a regular basis.
A member of the Pollution Prevention Team conducts weekly RCRA inspections of manufacturing areas
which use hazardous materials. The inspection checklist covers the waste treatment areas, plating
department, and hazardous material storage areas. Informal inspections are performed during the normal
course of operations by employees.
2.4.4 Spill Prevention and: Response
Best Management Practices addressing spill prevention, response, and cleanup are addressed in the attached
Spill Prevention and Response Plan and the Contingency Plan for the Kaba Ilco, Winston-Salem facility
(Appendix D). These documents also cover emergency procedures.
PIEDMONT GEOLOGIC, P.C. 9

2.4.5 Erosion Control and Runoff Management
Runoff from the southwest half of the property, along Indiana Avenue, flows over the ground surface and
asphalt parking area. There are no ditches and the unpaved area is vegetated resulting in little chance for
soil erosion. The northwest half of the property is primarily covered by buildings and paved areas. There
were no areas of significant soil erosion observed during site inspection on January 9, 2003.
There are no structural stormwater controls, such as collection basins, vegetative swales, or infiltration
trenches, employed at the facility. The primary goal of the Pollution Prevention Team is pollution control,
as, due to the space and topography of the property, it would be very difficult to incorporate any large scale
stormwater controls. Furthermore, the present stormwater handling system is well suited to the needs of the
facility.
3.0 SP1LL PREVENTION AND RESPONSE PLAN
This Spill Prevention and Response Plan is an integral part of the Kaba Ilco facility Stormwater Pollution
Prevention Plan. The performance and usefulness of this Spill Prevention and Response Plan will be
evaluated in the event of a spill at the facility and any necessary revisions will be made at that time.
At the request of NCDENR and City of Winston-Salem personnel, the City of Winston-Salem Stormwater
Division and Forsyth County Environmental Affairs Office telephone numbers have been incorporated into
the Spill Prevention and Response Plan.
' 3.1 Responsible Individuals
The responsibility for insuring that spill prevention measures included in this plan are maintained remains
with the Pollution Prevention Team. This plan will be implemented by the coordinated efforts of the
.Pollution Prevention Team and their designees. The Pollution Prevention Team is listed below
• James Edwin Smith 336-725-1331 ext. 247
• David Stewart 336-725-1331 ext. 278
• Ed Lodics 336-725-1331 ext- 200
• Duane Stratton 336-725-1331 ext. 317
' • Walter Dyson 336-725-1331 ext. 261
• David A. Spencer 336-725-1331 ext. 254
1 PIEDMONT GEOLOGIC P.C. 10

3.2.2 Material Transfer Operations
Areas in the building or on the grounds which are used frequently for the transfer of materials may be prone
to spills or leaks. These areas are the loading docks, the hazardous materials storage building, and the
plating bath line when it is being emptied and cleaned. The transfer of materials between buildings may also
expose materials to spillage.
The loading docks and plating bath line are inside the main building and spills in these areas have no
exposure to stormwater. Material transferred to and from the plating bath is very limited and only occurs
when the plating bath is emptied and cleaned. Material transfer outside the building consists primarily of
sealed 55-gallon drums that are moved from the hazardous materials storage building to the main building.
The maintenance department maintains sufficient amounts of powdered absorbent and other absorbent
materials that can be used in the event of a spill occurring inside or outside of the buildings. Spills occurring
inside the main building are easily contained. The only floor drains inside the main building are located in
the shipping area on the northeast end of the building and convey liquids directly to the POTW. Spills that
leave the building or outside spills would travel over the ground surface to the stormwater conveyances that
drain the northeast or southwest portions of the site.
3.2.3 Miscellaneous Drum Storage
The Kaba Ilco facility maintains smaller volumes of chemical storage in several locations for use at
individual point of use. Flammable chemicals are stored in approved, labeled, and locking cabinet. Drums
of lubricants and other miscellaneous chemicals are stored on drip pads in various locations convenient to
their use. The locations have three or fewer drums. Leakage from these drums would collect on the drip
pads and be removed. Spills on the concrete floor are removed by use of powdered absorbent and other
absorbent materials that are stationed adjacent to the drum storage areas. Drums that store hazardous
materials are kept in the hazardous materials storage building and chemical storage room.
1 3.3 Storage and Material Handling Requirements
All bulk liquid storage is enclosed with containment dikes with the capability to pump contained liquids
directly to a holding tank. Records of the disposal of hazardous materials and wastewater filtrate are kept as
required by RCRA.
PIEDMONT GEOLOGIC, P. C. 12

All areas of bulk storage and materials handling are observed by trained employees during the course of
their daily work. Periodic inspections by designated personnel are performed to insure that bulk chemical
areas are well maintained.
3.4 Spill Cleanup Equipment
Spill cleanup and emergency equipment is provided in various locations throughout the Kaba Ilco, Winston-
Salem facility. Each working area is equipped with an ABC fire extinguisher and, where necessary,
emergency showers and eyewash stations. The Emergency Response Procedures listed in the Contingency
Plan, revised March 2010 (Appendix D), specifies procedures to follow in the event of both small and large
spills of hazardous materials inside and outside of the building.
PIEDMONT GEOLOGIC, P. C. 13

4.0 PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING
The Maintenance Department is responsible for the proper upkeep and operation of all secondary
containment structures and all stormwater conveyances. This includes implementing erosion and
sedimentation controls, if necessary. The Maintenance Department Supervisor is the Pollution Prevention
Team member responsible for these areas of preventative maintenance. The detection of possible
maintenance concerns is also the responsibility of the Maintenance Department and all employees who
work in the area of concern. Pollution Prevention Team members are required to notify the Maintenance
Department of any suspect condition.
5.0 EMPLOYEE TRAINING SCHEDULES
Members of the Pollution Prevention Team are trained annually in applicable pollution control laws and
regulations and the operation and maintenance of equipment for the prevention of spills. These employees
are expected to perform duties relating to cleanup or containment of spills. Stormwater training is provided
to all employees who are involved with material procedures. Training schedules are documented in
Worksheet #9 in Appendix E.
Employees are familiar with the operation and condition of the equipment they operate on a daily basis and
are required to notify managers about conditions that could potentially lead to a spill or leak of chemicals.
The responsibility for proper training of employees rests with the area supervisors.
1 PIEDMONT GEOLOGIC, P.C. 14

1 0 Tammy Jones 336-725-1331 ext. 290
The responsibility for notification of the appropriate outside authorities in the event of a major spill rests
with the Pollution Prevention Team. Team member James Edwin Smith must be contacted immediately in
the event of a major spill or environmental incident.
1 3.2 Potential Spill Areas
' The potential for spills exists anywhere bulk chemicals, especially liquids, are stored, transferred or used.
Possible sources are itemized here along with probable flow directions and potential for exposure to
stormwater. Storage of bulk liquid chemicals occurs in aboveground storage tanks which are surrounded by
containment dikes and covered. The Kaba 11co facility does not have any underground storage tanks or
exposed aboveground storage tanks on site.
1 3.2.1 Wastewater Treatment Building
The majority of bulk liquid storage is associated with the wastewater treatment system. Wastewater
containing cyanide, metals, acid, and alkali solutions is stored in large, diked, aboveground storage tanks.
Floor trenches and a large sump also handle wastewater. Fifty-five gallon drums of acids used in the
wastewater treatment system are also stored in and around the wastewater treatment building. Two 250-
gallon, double -walled polyethylene totes, utilized for transferring plating chemicals from the plating line to
the wastewater treatment system, remain empty and tightly sealed when not in use and are stored outside the
wastewater treatment building.
Spills from any of these tanks would be contained in the concrete dikes, making discharge to the
environment improbable. Spills which Wright leave the diked area through overflow or containment leakage
would be small in volume. In addition, the spilled liquid contained inside the dike walls can be pumped into
one of several empty holding tanks. Spills within the wastewater treatment building would be immediately
contained by traveling through the floor grates to the wastewater sumps in the floor. Spills occurring outside
the wastewater treatment building can only occur from materials handling activities and would be small in
volume due to the limited quantities involved in such activities. All employees involved in materials
handling activities are trained to immediately notify their supervisor and perform clean-up activities in the
' event of a spill.
PIEDMONT GEOLOGIC, P.C.

FIGURES
PIEDMONT GEOLOGIC, P.C.

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Hazardous
Storage Building
Wastewater Sample Location
Treatment for Outfall B Southern Railroad
Building
Covered Scrap
Metal Dumpster
1 01d Equipment
Storage Drainage Area 1
Old 5.6 Total Acres with 7
Equipment Loading Bay 46% Impervious Surface F
Storage /
Outfall a
1 Undeveloped Land j
1 �►
aCovered Garbage /
Dumpsters
Drainage Area 2 /~
4.9 Total Acres with
Main Loading Bays 89% Impervious Surface
Outfall C \
Indiana Ave.
/ dto�s Scale (A.)
4L6
��. 0 120' 240'
Legend: PIEDMONT GEOLOGIC, P.C.
Environmental Consultants
quau,l Date: raeu,s e:
--mot► Surface Water Flow Directions 3116110 Fig2.dw
Outflow Locations
Site Map: Kaba Ilco
+++- Railroad Tracks WK
c Uli=L project No.:
— Approximate Site Boundary WK Kaba Ilco 1016
Cfteelre& cahap: Figure: 2941 Indiana Avenue 2
WK Winston-Salem, NC

APPENDIX A
INSPECTION COMMENTS
PIEDMOA7llEO1 0GIC, P.C.

7iA—
MCDEMR.North Cafofina Department of EnVir6 mn't a6d Natural Resources.
Qiv%inn of Water Quays
OevMy`Ewa4ds Perdue. e016en H::Sullins
Govemot Director
February 25, 20io: /-
' O#,II IFIkb _MAtL7608 X 140 O603 ssb5 6648
RETURN-REf EUPT REQU>{. ED:
1
r
P
NIrcMichaeiiUncaid,-General•Manager
i i tia ltco Co.moration
2941' lndiattiiiAve:
Ninstbn�Sailem;.�To�Caroiiririr271 US
Su*ci: N[]'ni" i Lt. OF "6OtA,t10N
Sto Mwatcr i nslsectIPIY
"
Kal a Ilco Cdiparition
P? -r nit _No::NCGo30245
Fors Gtii�iti" . .
bearMr. Kincaid:
Dee Freemen
Secretary
tnclomd=please 5nd a cc py of tbe:itnspeclion-Relw'; larn�the.t w ecion:cvnducted February 24-
201 p.: Th.6 Stonn%vater ntpeattort. Eves conducte4by Steve Mauney :ol`tlae Divrsson of Water•
ulity, F��,nsEon_S.#.m.Regioni&Ohic The inspection coasi to nft�va parts: --an onrsite
irispection.of,tbe_facilitv."and.a.limicetl.fde.rev ew: The :are the'fiFduhp from -the subject
TheftciEit :ivAs f©und io i�c ire iolandn of paraiit`�yCGlik302.451or:tlic.faElo vin
Inspection Area .
— prupiiance s' sues
Storm Water Plan
Faiilure'to include an.at nt�al Rc erh cation:tliat ot�tfalls°do not
Cant=ain nor--stt►rm- ,,kater discharges
Storm%vater.P;lan
The map does not lis the drainage, arm -.to each ouiWFiior the
pereencage of irnpe�ous � (i atn Fs listed at section l
Storm Water P. an
The feasibility study ofchsn�ing the:rnetE�tids bf ogerat,on to
eiiEninAte or i'educe`exposum� ppears to: need are.60i .
Starri�waterbata
Data was not submitted for t}iis`facitity. in 208 or 2009::
1 it lwmit
Tlie Certificate ofCoverase NCGO30245 for the Kaba 1166 CnrPoricion--Winston-Saterii facility
became dktive November 1, 2007 and expiivs on Oct of er 3 ti 2012; 'Me pffmitted'faeillty is
ti66 care%, Dmsbn of wa3a away.1€,vM sarc Refi t t1 e
L=Wrn 585 WeAMM7. SE, Y�ai6l�nsS�txs, R�tu3h Cw 27li17
PhXW gas n�v�s i errxa
inientsi m+nv..�dq:�iy:ory
Pfthcarolina
AaFPV4 OPP.•,firtA€ rUfte AdW Ewa

Kaba 11co Gorporafion
authorized io discharge storm',.vater from a facility located at2941 Indiana Avenue, Winston Salem,
North,Caroli-na wreceiVingy4ters designated as. an: Unnamed Tributary to Brushyi- Fork Creek, a
class. C-Streim in, the YddkiiiL-LPe6 -D= Riv'er"-Basia in aanc6.N;iih:the effluiehflimitations,
moniton'n'g. requirements, aril other conditions set f6rth in Generd Perifift No. NCG030000-
Ahy. bthe.r point source- discharge to su.rfa6eWaWrs; of 'the -state :ft.m, this ficility. is prohibited unldss
ii is an allowable non�"s'tonnwat'eT'discharge or is covered: by aribiher -permit, au riziaton or
approval'..
17he permit�identifics Uvo monitoring requirements thal apply to this; facility;:
> -Q itatiV6.Mon,itor'ini'for Storrnwater Dischargf.. Oinfialls per Par" H- SectionC.
> Ati;g�ticLd'M6nitdfihgfor Stohii�,,,At'e:r,Discharge N611"Perft H NiiSecition.B.
0f'i6e NC, G"03b, 00,0 -general pe the C. Kpiit.docurnents can be accessed from. e following.w b:pE!gp-
itj-4:e"n'r.state.nc-uvgu/Faf'Mq, D6NIMe"'. F,if P,ht' M''URMIr . M I ("ter'(1p
ALRecords/lIgports..
NCGO30006xe e ffiented:a acid records
qipr."-certain7 monitoring to b"Aocu .maintained facilit'" Y.
lfie:-followin records:are:rc required q� s site per.theWPDES permit:
L stdrnwater PoRud0n Prvention Plar�'as spe per Part.1.1Sections-A StoTTWatik t;Lt Disch-Or 0N)s - (SDO),..shd11 -.nave Q iW i mbfiftori g 'PCrfohtO as
, i�r e P .
described in:: Part
t"L M4. Section
tion C Aiid T616 4, �.a:nd: shalv`be ` conducted -during'.. the aixatytical
m . onitorinp-event,
Storm's6hirp�, Ouifiti§i (M-0). shall haveA6i i6a]. rii1bring p6rformed as
v�6ter Di" A mo
de'sOibed. in Pah 11. Sectidri-B'and Tables 14;1
K review *'vas "-r'n"ade'6f*e'stppIid:irecoids Posfair the Kabi1l6o:C6rp9radon facility
for 60 perW"LM
arch 2069 AibughJhespresent:
M . tis,*&i . 6,vy-indicatM.de'ticien"c'ie's'ii'i:thi 6110"pink-records:
The Stormw4tei-Pplifitio t
_VFn 199 P4n was inc I 6mPlete.
o PrP
T_ 11 �16-fi bde`iE�iei�id. P P ave n annually since : 2004: butit did "not iikluc[6,;
certi&Mion:that: iliestormwateroutfaiis:have ilien evaluated for. the, presence of non-; st.0,rmW.at�,-,r'._'djs'ch a-rges, The Qbnfin'gehb}r.Mh Yuly 2008...
. 0. Thef6as'ibility- Study - of th6 pdrmitshould be . as requiredin Parill, Section:
updated' , to evAluate'cuirent conditions_
.0 The
percentage cehtage of impervious. area dtain ini, to ea,ch'outfatl aril the total: drainage area
for. each otitfiill must be listed.on:the map,,. (Permit conditiOn, MA. I -(C)..)
-6 The North Carolina *11 rOPoTLij_jgLre' t9 for p&rblexi' j include any:spills that
q CP M nc L
iU " dik exc'eied 2.5 gallons; . 116n� any - spins
lls that �aie closer' &n
rok-b'sLirfiace, any. SP S SP
1!00 fi6 ' et ::' firolD S"ific , e, ..w ' Me ' rsiaridany soiHsAhat'6re no . t cleaned upwit} I in .2 . 4'houts.:or
the di'scharge. attached is GS 143:215.85'(b).

Kaba ilco Corporation
The Quantitative data tins not been submitted to this Division,
File semi-annual data has not been collected and submitted,
1TI • Facility Site'&y.,iew
At the lime of.the:inspection an oper�:op toasts°iiiri f©r scra'egiiipriYezt ;vas Iacatri at tlae siiuth end
of. tlie'buildirig. Ttie east outfall cons observed to be free of -industrial litter or debris:
Please. refer to,the eaclvsed Inspectian Repork f'or-a4radc]ati6 hl bW.ervations 04 i*hts.
carefully -rcvic. these xriola&ns'and deficiencies:arid:.iresy0nd=`iu4riting to tltos `o Ce.�it1i'in
thiM t3111: �varinng : d'a . of_: recc�rit . of #i is le#tcr.:.".:You: 'sh6uid 'tiddre'ss A.
: causes; of
noncorii Hance anil`.all> actions: takers. -ta: raven"t tiie recurrence :af 'sireiilar- srtui dio Yvt`r
response strauld_'iriciuhe d0 tfollowing:
}► `Describe steps sir o' to..satisfy :li a regirirenzents af:tha -NPDES'`-Creneral :PCMIit,'.:ass--=listed
abov-e; .immeiliatclyc :Please-- explain'` your. I�iluie to inipleriierit toe ; x�giu ments�- and
discuss°fiou=these reifintr+errienis;�'ill be niet:i ;:the futwe:
Piravide this office tN_=ith tlie:updates°t_o:your,completea,Storm;vatet ;pollution Pi VcntiOil
syrtlun she t'eeu%red r slionse �tirn_e rtpted al5oVd A & dance document tb asiisi- you ,in
. - . . - . 4. .- .. -
developing:'the updates tv .3Four; StvrtnWatcr-. Pvllufiori=I're�=ention'Plans for Stornr� ter
R,tii�of� at�Iridti>sbrim"-Activities is:availabfeat theT)zvision:ivebsite: .
�ttc 1ll2o enr:state:nG uslsii7lylariirals FaeCSlieefis htn - .
D ' Provide hny: oth6r relevant factors; zwhie;should be, consid=d. _
Thaniti you for-your,"h tentron:to.this matter Please be €rdvised+tluat.AoWidns of the Storm�vater
Permit may be sub3ect to civil>peni3lty sessrnetst5 of tip to;$2S,UQQ;OO per da3�,.per vl0yatron . our.
above.-niention� respons--to­--.... thin coi espontlence rvili be. cansrd �n tliis,process IF: you should'=
haaJe any questions, pieasc d€i iiot lesrtato:to contact Steve Niteurtey=ot (:35j '171 4b9
Sincerely,
Steve :W.. Twitter
`Water Quality:Xtegional Supervisor
Attaetimeiits-
Cc. S. VO-Cetitral,files
-'WSRO
l PS AssisUfnce and Comoliaiice QYersight�
-keith-Huff.,•City of .UFS: Stoi water Division

' Compliance -.1hsection Report
A. A
. Permit HCEa03024g 1=ffCCtivC; 1.116VO . Pxpiration: 1Ct31/12 OWr�-,r: Kaba tico Cow
SDC: Eliecttve: Explrat(on: Fie' llity: Katie 11oo Corp -Forsyth
County; Foisyth 2941' IndiansAve -
Regidri: Wmton-Salem
Wxsston Salem NC-2710S
Contact Person: Nader Iskander Tale: Phone.- 336-725-133I
' 00.256'
Directtdns.tc Facility:
' system ciassinc&i[on5:.
Fart maryC?RC: Certification: Phone:
sewn. dary :ORC(s}:
.. n .
C� S1t.o Representatives}:
Ralafed Permits:
e:. inspectlprt Date 42iZ312010 entry Ttme:_tg; AM ExIE Time:.i(I:CS`Al11
P--nIary. Inspector Max S Maundy Phone: [phone]t30
Secondary lnspector(s},.
Reason. far-tnspe.c,Uon: Rine Inspection Type: Compila-uw Evaluation
Permit Inspection Type: Metal FaMeatiori'Storrmvater: Disdla*,COC
tracllity Status . p Cnrrspilarit. (:Ict.cliar,t
Question Areas:
® Storm Walter
' (See attach merit sUm- Mary)
1
Page: 1

a5 1 �13-2�i i.85
!}ttp-Jf„�w ti��.nc�€�_state.rEc.usfE�actedl.e¢isl.ttion� St�n�teslHT��IL'!3}5e_..
143-21:5.b5. Rcquired no#icc.
(a) Except- as provided in G.S. 143-445;94E(61) and sthsectian (b);.of this section; every
Person ownmg or haying control over oil or other snbstaaztces dischazged in any. ciicumstanees 'other
tk an.pursuanrto°a. rule adopted -by the Con-urd on,,.a regulation of the U s Ehviror mental Protecti©ii
Agency,, or a=permit.requked-.,by C.S: 143 415J.or-thc Federal Neater. Pollution Control_ Act; upon
ndtice that such=discharge leas=occurred;. shall Immediately notify the Department; or ariy of itsageFtts
or. coiptoS�ees; ,of the. riateiTe, location and time of tlie. disnh ge -and 4. the measuures which are. b6ing
taken or are ptoposed.to:,be'talcen to contain.and -remove the°discharge Tbe'.ag�nt ar-employee of the
Depc�tnt recextzig the nttificattoii_ shall irizmediately rivti tle,.SeGrretary .or such rneimer -or
a ernUers of the permanent staff bf�the DepattmenC as _�* SeCr64vy may. a gnate If. the discharged
substance of w�ch Elie %7epaztmen t is noted i_s; a pes ictde regtzleteci by;,tFie Aicrth C_ afdlina_ Pesticide
Board; -the Depaitrncent shall ;immediately h form the.. Chairman- of -,the: Pesticide Board.-, Removal
p.
operanc�ns under this: .Article,of substances ideitfifed.-as 'esticidesde�"u�cd �n GS 143 454,shall
c€ orclinated in aceordance with-.the:Pesticide EnlergeneyPlan.adopted�by.the Forth Carolina Pesticide
Board; prbvtcled that; in instances'where.ehtr* siaoh haiftr'aous suiistanees wto. vaters_oEthe Stateis
iminuiei t; tliebepartmerit-rnay;take subh actiotis as are necessary'toYphy:sically�..contain:or.diveri such..
substance so as to"prevent:entry into the surface avaters.
(b).. As:used iiitliis subsection, "petfdletirn'! has the.sariie meaning as- ,C'r;5: I43-215.9 A. A
person who aths or: ;has '.cphtrol- Over- -petraletirft that is discharged 'info thtr environment shall
`isYuntydi 'A'"", A" take measures to collect .and i-em ►ve the ischar' e; sport -the -discharge to:,the
Department "thU'n � hours,of tlie,dtscharge,:and - Begin to restore the area affected by the discharge: in
ticcardance NVith the recluircrrtents o this. Article if.tlie volume:of the=petroieum:iliat is dschard is5
gallons or nioie or . the petroleum causes.. a 5ht'en on nearby suuface cvaler or tf "the petrojeum
discharged at a .tlistttriCe of 1:00'-feet 6r.Ws brow any: surface :wester-b6& If thi ...veiunie-af petrolepin
that -is isclta ged is less than .2S'. gallciris, the_petroleumd&�s-'AGV6:; use- a slieeii oin: nearby surface
water,; and the °petroleunt-.is discharged A a distance of more than. 1t?(l .het from all surface v�atar
:bQ(ffles, tie person wlio otvrts or has coatrcri over tM pe'Wleum shall igwWiatdly take measures:
"to
aallect,and remove the dtscliarge: If a discharge: of less than'-ZS: gallons of.petroleum attnnat be cleaned
rup .wthu 24 hours of�lhe.:discharge or>the discharge uses $ sheen ort ricartiy s►�rfcea#er, tfiec.
person-uvlzo ovnis or has cottirt�l'o�ertJae:p�traleutndial! nnnied�ately.tititiiy the-Deltartinefit'._. 1973 -C.
534, c. s: 1; 1262 s ?_3, 1977 c: 771, s 4; c &58 s 1,_1979 'c 535 .ss. 16, 17,:•19$7t c. 827:, Ss' 154`,.
19.4;; 2000=54;. s. L)

Perfnit NCG4=46 Owner- Fa6htj-`. Kab'a J6 C4
.tW..Date_'.=23nDID Gspectan TAe: Conpft= EvaluaUon, Reasop fqr
'6t6rmivat6r:POIjutjOn Preventionlslasi
es No.NA .NE
'Does ft site have a Stmmvmter Pdlution:Preventiah Plan?
e
# D6es the Plan includd a General LoOafioh (USGS) i mp?
# goes the Plan inckde aNarrative Descripwn afpmd ces'?
0 0 0
#Does fire d dl _1 bcebonsadra
1
,nncudL
4. Does the Plan iWuda a list of significant spills oouning airing 6iepaft 3 years?
0 0 a. U
Hawthe facifty evel.uat4d to cunv tprackes?
El 0' .0
19
Dopsjhe Facility : .Ovvide:a
-k 0-0 0:
'
'##. Does the.P€arr inc tda a 6MP suim`r'nariO.
d:0 0
9 Does the Plan include a Spill. Prevention and R"pon§e Plan (SPRP)?
0 0 0 0.
# floes ­tt4'Plaisin'dude a-L-OniVe6titive fWntenairice And.doodikousekeeping Ran?
Y
M 0 Q El
Does the ftn:.-trduft a U 69'Respotrft4e I OaMs)?'
A. 0 Al Q.
0 1s the Ptah re%6d and updated ai'nnui-
®0 Q 0'
'
# Does the'Plainlintlude a Stomvmt& - •P Mqmm
13 0 00
'kiitfie-Swffriviahu Pouution'Pre4ention.-P fan beefi i*effiintedl
t� �W- P q W ]h "d der
Comment'04hdk tE4':tfiaf- 66doallks are timpster. under
Pages 6f'
21., .pe &6o'rth_-�We�6) . WaAtI6 01011111. The
' . L'.
Aah'-nbtess thafii6 qqt§06 f I ... . , f the
!S.,-occvr- except.. pr:�movinj drurn�, rqrn e�-qlatn
'
IEuifdinj'td:th6 hai�r&�s'sto4g�i:Wldin :Ttiere�w6r655 gallon dnjas:of-and.-;and:.
i . . g� . - ' '
.
5'
1106 fOA& acid 06idd outside near the WdStW6atm6rit building.- -ze6WereAj$OI .9a
tih. Iki�bf SUlK.iripstared :6uwde'T"ivo',250+ gal: 66blewalled
CruMs were alsbbcat6d:butside'. StorAge66dee:r66fwith"6 bem'WbOld:61ir�i4q
-potenU41-ex'osu4. Tnihsfet&4quids fpin:dtums ou stdelts.apotential
i
Empty drums4ere-alsoldcafisd o�fsideafs6vdralbaWh.- (20 or.more i n oniei-tpbt};,A
:duqipstdrI6'c'aiqd on the'-south..6nd[L'qf the property wassf6fl-of sGrap:niejal e4ujOin6nfAt .
-nras.not6d thatho spWs'.h'av'e occurred iri th6 16SI-3 y6ar�s. but this:must belncluided-in
M6*inual ptah updat6.'Phin i6iblernenfati6h is not fultj-"ffeaW,
qudliWtive morifforlag Yes Ro NA. ME
OaS V.ie" f6dfity+ tuetod- its OuartWtive kdnl .Onqskriri-anntia!r_ 0 13 10
:Comment: Two inspections were conducted in 2008 and three were conducted -in
2009 meeting the new pennit reqWitrneAt.
Ah'M icalMqni!O_r_IA9 Yas N - a NA, ME
-Has the facility conducted.fts Analytical monitoring? 013011
Has the facitity conducted its Alotylical monitoring froin Vehide Maintenance areas? 0 0 03 C).

Permit; MCGO30245
Inspection Date: 02/23/2010
Owner - Facility. Kaba lice Corp
Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Comment; Mr. James Smith and David Stewart did not have a copy of the general
permit as issued in October 2007. Therefore no monitoring has been conducted. The
former Environmental Manager left in
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 oulfail status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: While the SWPPP of 2004 indicated that the outfalls were observed for
non-stormwater discharges during dry weather, there was no indication that more recent
observations were conducted as required in Part II. Section A. 7. of the current permit.
Section A.7 also requires an annual update of the SWPPP.
Yes No NA NE
Page: 4

APPENDIX B
CERTIFICATE OF COVERAGE AND GENERAL PERMIT
PIEDMONT GEOLOGIC, P. C

I
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NGG030245
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance 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,
Kaba Ilco Corp
is hereby authorized to discharge stormwater from a facility located at
Kaba Ilco Corp -Forsyth
2941 Indiana Ave
Winston Salem
Forsyth County
to receiving waters designated as a UT to Brushy Fork, a Class C water in the Yadkin -Pee Dee River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III, IV, V, and VI of General Permit No. NGG030000 as attached.
This certificate of coverage shall become effective November 1, 2007.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day November 1, 2007.
for Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NCG030000
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL
' RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance 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, this permit
is hereby issued to all owners or operators, hereafter permittees, which are covered by this permit
as evidenced by receipt of a Certificate of Coverage by the Environmental Management
Commission to allow the discharge of stormwater to the surface waters of North Carolina or
separate storm sewer systems conveying stormwater to surface waters in accordance with the
terms and conditions set forth herein.
Coverage under this general permit is applicable to all owners or operators of stormwater point
source discharges associated with activities classified as establishments primarily engaged in the
rolling, drawing, and extruding of nonferrous metals [standard industrial classification (SIC)
3351, heat treating of metal (SIC 3398), fabricating of metal products (SIC 34), manufacturing of
industrial and commercial machinery (SIC 35), manufacturing of electronic equipment (SIC 36),
manufacturing of transportation equipment (SIC 37), and the manufacturing of measuring and
analyzing instruments (SIC 38).
The following activities are specifically excluded from coverage under this General Permit: Ship
and boat building and repairing (SIC 373), which is covered by general stormwater permit
NCG 190000.
The General Permit shall become effective on November 1, 2007.
The General Permit shall expire at midnight on October 31, 2012.
Signed this day October 17, 2007.
Original signed by Coleen Sullins
Coleen H. Sullins, Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No. NCG030000
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: General Permit Coverage
Section B: Permitted Activities
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: On -Site Vehicle Maintenance Monitoring Requirements
PART III STANDARD CONDITIONS FOR NPDES STORMWATER GENERAL PERMITS
Section A: Compliance and Liability
1.
Compliance Schedule
2.
Duty to Comply
3.
Duty to Mitigate
4.
Civil and Criminal Liability
5.
Oil and Hazardous Substance Liability
6.
Property Rights
7.
Severability
8.
Duty to Provide Information
9.
Penalties for Tampering
10.
Penalties for Falsification of Reports
Section B: General
Conditions
1.
General Permit Expiration
2.
Transfers
3.
When an Individual Permit May be Required
4.
When an Individual Permit May be Requested
5.
Signatory Requirements
6.
General Permit Modification, Revocation and Reissuance, or
Termination
9

Permit No. NCG030000
7_
Certificate of Coverage Actions
Section C: Operation
and Maintenance of Pollution Controls
1.
Proper Operation and Maintenance
2.
Need to Halt or Reduce not a Defense
3.
Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
1.
Representative Sampling
2.
Recording Results
3.
Flow Measurements
4.
Test Procedures
5.
Non-Stormwater Discharges
6.
Representative Outfall
7.
Records Retention
$.
Inspection and Entry
Section E: Reporting
Requirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
5.
Planned Changes
6.
Anticipated Noncompliance
7.
Bypass
S.
Twenty-four Hour Reporting
9.
Other Noncompliance
10.
Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
M

Permit No. NCG030000
PART I INTRODUCTION
SECTION A: GENERAL PERMIT COVERAGE
All persons desiring to be covered by this General Permit must register with the Division of
Water Quality by the filing of a Notice of Intent (NOI) and applicable fees. The NOI shall be
submitted and a certificate of coverage issued prior to any discharge of stormwater associated
with industrial activity that has a point source discharge to the surface waters of the state.
Any owner or operator not wishing to be covered or limited by this General Permit may make
application for an individual NPDES permit in accordance with NPDES procedures in 15A
NCAC 2H .0100, stating the reasons supporting the request. Any application for an individual
permit should be made at least 180 days prior to commencement of discharge.
This General Permit does not cover activities or discharges covered by an individual NPDES
permit until the individual permit has expired or has been revoked. Any person conducting an
activity covered by an individual permit but which could be covered by this General Permit may
request that the individual permit be revoked and coverage under this General Permit be
provided.
If industrial materials and activities are not exposed to precipitation or runoff as described in 40
' CFR §122.26(g), the facility may qualify for a No Exposure Exclusion from NPDES stormwater
discharge permit requirements. Any owner or operator wishing to obtain a No Exposure
Certification must submit a No Exposure Certification NOI form to the Division, must receive
approval by the Division, must maintain no exposure conditions unless authorized to discharge
under a valid NPDES stormwater permit, and must reapply for the No Exposure Exclusion once
every five (5) years.
Facilities submitting NOls for coverage under this permit, and facilities submitting renewal
forms for continued coverage under this permit, prior to establishment or approval of a Total
Maximum Daily Load (TMDL) for pollutant(s) for stormwater discharges (i.e. wet weather
flows), may be covered under this permit during its term. For such facilities, continued coverage
under the reissuance of this permit is subject to the facility demonstrating that it does not have a
reasonable potential to violate applicable water quality standards for such pollutants due to the
stormwater discharge(s). For facilities that do have a reasonable potential for violation of
applicable water quality standards due to the stormwater discharge(s), the facility shall apply for
an individual permit 180 days prior to the expiration of this general pen -nit. Once the individual
permit is issued and becomes effective the facility will.no longer have coverage under the general
permit. Impaired waters scheduled for TMDL development are on North Carolina's 303(d) List
and can be found here: http://h2o.enr.state.ne.us/tmdl/Gencral-303d.litm#Downloads.
A list of approved TMDLs for the state of North Carolina can be found here:
http://`h2o.enr.state.ne.us/tmd[/General—TMDLs.litm.
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited, and monitored as specified in this permit.
Part I Page 1 of 2

Permit No. NCG030000
SECTION B: PERMITTED ACTIVITIES
' Until this permit expires or is modified or revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system which has
been adequately treated and managed in accordance with the terms and conditions of this General
Permit. All stormwater discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization, or approval.
The stormwater discharges allowed by this General Permit shall not cause or contribute to
violations of Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any other
' applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
Part l Page 2 of 2

1 Permit No. NCG030000
PART H MONITORING, CONTROLS, AND LIMITATIONS FOR
1 PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this general permit. The Plan shall include, at a minimum,
the following items:
I. Site Plan. The site plan shall provide a description of the physical facility and the
potential pollutant sources which may be expected to contribute to contamination of
1 stormwater discharges. The site plan shall contain the following:
(a) A general location map (USGS quadrangle map or appropriately drafted
equivalent map), showing the facility's location in relation to transportation
routes and surface waters, the name of the receiving water(s) to which the
stormwater outfall(s) discharges, or if the discharge is to a municipal separate
storm sewer system, the name of the municipality and the ultimate receiving
waters, and accurate latitude and longitude of the point(s) of discharge. The map
should identify whether each receiving water is impaired (on the state's 303(d)
list of impaired waters) or is located in a watershed for which a TMDL has
ebeen established, and what the parameter(s) of concern are.
North Carolina's 303(d) List can be found here:
http://h2o.enr.state.ne.us/tmdl/General_303d.htm#Downloads
North Carolina TMDL documents can be found here:
http://h2o.enr.state.nc.usltmdVFMDL_list.htm#Final_TMOLs
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices. A narrative description of the potential pollutants which
' could be expected to be present in the stormwater discharge from each outfall.
(c) A site map drawn to scale (including a distance legend) showing: the site property
boundary, the stormwater discharge points, all on -site and adjacent surface waters
and wetlands, industrial activity areas (including storage of materials, disposal
areas, process areas, loading and unloading areas, and haul roads), site
topography, all drainage features and structures, drainage areas for each outfall,
industrial activities occurring in each drainage area, buildings, existing BMPs, and
impervious surfaces. The site map must indicate the percentage of each drainage
area that is impervious.
(d) A Iist of significant spills or leaks of pollutants that have occurred at the facility
' during the three (3) previous years and any corrective actions taken to mitigate
spill impacts.
Part It Page 1 of 9

Permit No. NCG030000
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part III, Standard Conditions, Section
B, Paragraph 5.
A2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following:
(a) Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
' of materials and processes to stormwater. Wherever practical, the permittee shall
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Requirements and Records. Secondary containment is
required for: bulk storage of liquid materials; storage in any amount of Section
313 of Title III of the Superfund Amendments and Reauthorization Act (SARA)
water priority chemicals; and storage in any amount of hazardous substances, in
' order to prevent leaks and spills from contaminating stormwater runoff. A table
or summary of all such tanks and stored materials and their associated secondary
containment areas shall be maintained. If the secondary containment devices are
connected directly to stormwater conveyance systems, the connection shall be
controlled by manually activated valves or other similar devices (which shall be
secured closed with a locking mechanism), and any stormwater that accumulates
' in the containment area shall be at a minimum visually observed for color, foam,
outfall staining, visible sheens and dry weather flow, prior to release of the
accumulated stormwater. Accumulated stormwater shall be released if found to
be uncontaminated by the material stored within the containment area. Records
documenting the individual making the observation, the description of the
accumulated stormwater, and the date and time of the release shall be kept for a
period of five years.
(c) BMP Summary. A narrative description shall be provided of Best Management
Practices (BMPs) to be considered such as, but not limited to, oil and grease
separation, debris control, vegetative filter strips, infiltration and stormwater detention
or retention, where necessary. The need for structural BMPs shall be based on the
assessment of the potential of pollutant sources to contribute significant quantities of
pollutants to stormwater discharges and data collected through monitoring of
stormwater discharges.
1
Part II Page 2 of 9

Permit No. NCG030000
Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or team) responsible for implementing the
SPRP shall be identified. A responsible person shall be on -site at all times during facility
operations that have the potential to contaminate stormwater runoff through spills or
exposure of materials. associated with the facility operations. The SPRP must be site
stormwater specific. Therefore, an oil SPCC. plan may be a component of the SPRP but
may not be sufficient to completely address the stormwater aspects of the SPRP. The
common elements of the SPCC with the SPRP may be incorporated by reference into the
SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance program shall be developed. The program shall document schedules of
inspections and maintenance activities of stormwater control systems, plant equipment
and systems. Inspection of material handling areas and regular cleaning schedules of
these areas shall be incorporated into the program.
5. Employee Training. Training schedules shall be developed and training provided at a
minimum on an annual basis on proper spill response and cleanup procedures and
preventative maintenance activities for all personnel involved in any of the facility's
' operations that have the potential to contaminate stormwater runoff. Facility personnel
(or team) responsible for implementing the training shall be identified.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in
1 design, construction, operation, or maintenance which has a significant effect on the
potential for the discharge of pollutants to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis. The annual update
' shall include an updated list of significant spills or leaks of pollutants for the previous
three years, or the notation that no spills have occurred. The annual update shall include
re -certification that the stormwater outfalls have been evaluated for the presence of non-
stormwater discharges.
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part III, Standard Conditions, Section B, Paragraph 5) to the Director that the changes
have been made.
' 8. Facility Inspection Program. Inspections of the facility and all stormwater systems shall
occur at a minimum on a semi-annual schedule, once during the first half of the year
(January to June) and once during the second half (July to December), with at least 60-
days separating inspection dates (unless performed more frequently), The inspection and
any subsequent maintenance activities performed shall be documented, recording date
Part I.1 Page 3 of 9

Permit No. NCG030000
and time of inspection, individual(s) making the inspection and a narrative description of
the facility's stormwater control systems, plant equipment and systems. Records of these
inspections shall be incorporated into the Stormwater Pollution Prevention Plan. These
facility inspections are different from, and in addition to, the stormwater discharge
characteristic monitoring required in Part II of this permit.
9. Implementation. The permittee shall implement the Plan. Implementation of the Plan
shall include documentation of all monitoring, measurements, inspections, maintenance
activities, and training provided to employees, including the log of the sampling data and
of actions taken to implement BMPs associated with the industrial activities, including
vehicle maintenance activities. Such documentation shall be kept on -site for a period of
five years and made available to the Director or the Director's authorized representative
immediately upon request.
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1.
Table 1. Analytical Monitoring Requirements
_ __ Discharge
T7
urement
Sample's
�XSample`
�iP=Fre
Charactcrtstirs
i3
ly �'
�?
. , :
,
ticnc
� aaT , � .�,�
�.�Locataon3�.
Lead, Total
m /l
semi-annual
Grab
SDO
H
standard
semi-annual
Grab
SDO
Oil and Grease
m /l
semi-annual
Grab
SDO
Total Suspended Solids
mg/1
semi-annual
Grab
SDO
Total Toxic Or anics5 (TTO)
m Il
semi-annual
Grab
SDO
Total Rainfall4
inches
semi-annual
Rain gauge
-
Footnotes:
I Measurement Frequency: Twice per year during a representative storm event.
2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the pond shall
be collected within the first 30 minutes of discharge from the pond.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative outfall
status has been granted.
4 For each sampled representative storm event the total precipitation must be recorded. An on -site rain gauge or local rain
gauge reading must be recorded.
5 Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations,
manufacture semiconductors, manufacture electronic crystals, or manufacture cathode ray tubes. For purposes of this
permit the definition of Total Toxic Organics is that definition contained in the EPA Effluent Guidelines for the
facility subject to the requirement to sample (for metal finishing use the definition as found in 40 CFR 433.11; for
semiconductor manufacture use the definition as found in 40 CFR 469.12; for electronic crystal manufacture use the
definition as found in 40 CFR 469.22; and for cathode ray tube manufacture use the definition found in
40 CFR 469.311
Facilities that implement a Solvent Management Plan may so certify, and the requirement for TTO monitoring may be
waived. The Solvent Management Plan shall be incorporated as a separate chapter into the Stormwater Pollution
Prevention Plan. The Solvent Management Plan shall include an annually updated and quantified inventory of the
total toxic organic compounds present on site during the previous three years; a narrative description of the in -plant
locations and uses of the toxic organic compounds, the method of disposal including quantities disposed on -site and
Part II Page 4 of 9

I
0
Permit No. NCG030000
off -site; and the management procedures and engineering measures for assuring that toxic organics do not spill or leak
into stormwater. DWQ may at its discretion require submittal, review, and approval of the Solvent Management Plan
as a condition of continuing the TTO sampling waiver.
For those facilities electing to employ the TTO sampling waiver, the discharger shall include the following signed
certification statement on each discharge monitoring report:
"Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit
monitoring requirement for total toxic organics (TTO), I certify that to the best of my knowledge and belief, no leak,
spill, or dumping of concentrated toxic organics into the stormwater or onto areas which are exposed to rainfall or
stormwater runoff has occurred since filing the last discharge monitoring report. 1 further certify that this facility is
implementing all the provisions of the Solvent Management Plan included in the Stormwater Pollution Prevention
Plan."
All analytical monitoring shall be performed during a representative storm event at each
stormwater discharge outfall (SDO).
A representative storm event is a storm event that measures greater than 0.1 inches of rainfall
and that is preceded by at least 72 hours in which no storm event measuring greater than 0.1
inches has occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation. For example, if it rains for 2 hours without producing any collectable discharge,
and then stops, a sample may be collected if a rain producing a discharge begins again within the
next 10 hours.
The permittee shall complete the analytical samplings in accordance with the schedule specified
ain Table 2. A minimum of 60 days must separate Period 1 and Period 2 sample dates unless
monthly monitoring has been instituted under a Tier Two response.
Table 2. Monitoring Schedule
tf�Te.genre
Monttor'inggperlac
_;�SanapleµNumber
�"f_ � �"" �:�
Start ,�k
�:-� �
nEnd� ,
Year I — Period 1
l
January 1, 2008
June 30, 2008
Year 1 — Period 2
2
July 1, 2008
December 31, 2008
Year 2 — Period 1
3
January 1, 2009
June 30, 2009
Year 2 — Period 2
4
July 1, 2009
December 31, 2009
Year 3 — Period 1
5
January 1, 2010
June 30, 2010
Year 3 — Period 2
6
July 1, 2010
December 31, 2010
Year 4 —Period 1
7
January 1, 2011
June 30, 2011
Year 4 — Period 2
8
July 1, 2011
December 31, 2011
Year 5 — Period 1
9
January 1, 2012
June 30, 2012
Year 5 — Period 2
10
July 1, 2012
October 31, 2012
Footnotes:
1 Maintain semi-annual monitoring during permit renewal process. If at the expiration of the general permit, the
permittee has submitted an application for renewal of coverage before the submittal deadline, the permittee will
be considered for renewed coverage. The applicant must continue semi-annual monitoring until the renewed
Certificate of Coverage is issued.
' 2 If no discharge occurs during the sampling period, the permittee must submit a monitoring report indicating "No
Flow" within 30 days of the end of the six-month sampling period.
Part II Page 5 of 9

Permit No. NCG030000
Monitoring results shall be compared to the benchmark values in Table 3. Exceedences of
benchmark values require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater Best Management Practices (BMPs) in a tiered
program. See below the descriptions of Tier One and Tier Two.
Table 3. Benchmark Values for Analytical Monitoring Requirements
f Ischar a C6aracteristics_x �. .„ �, �°�
,Benchmark,Valiie'
Lead, Total
0.033 m /l
H
Within the range 6.0 -- 9.0
Oil and Grease
30 m A
Total Suspended Solids
100 m
Total Toxic Organics t
1 m
Footnotes:
t For those covered facilities that elect to monitor for TTO rather than implement a Solvent Management Plan.
TTO includes multiple organic compounds with varying environmental impact; the Division may evaluate the site
specific constituents from the TTO analyses and work with the facility to determine a more appropriate chemical -
specific value that could differ from this benchmark. DWQ may require the permittee to provide controls for
materials that DWQ concludes are present in significant, or potentially significant, amounts.
1TI..I o�.lc.n.
If: The sampling results are above a benchmark value, or outside of the benchmark range, for any
parameter at any outfall;
Then: The permittee shall:
l . Conduct a stormwater management inspection of the facility within two weeks of receiving
sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedence.
3. Identify potential, and select the specific: source controls, operational controls, or physical
improvements to reduce concentrations of the parameters of concern, or to bring
concentrations to within the benchmark range.
4. Implement the selected actions within two months of the inspection.
5. Record each instance of a Tier One response in the Stormwater Pollution Prevention Plan.
Include the date and value of the benchmark exceedence, the inspection date, the personnel
conducting the inspection, the selected actions, and the date the selected actions were
implemented.
Part Ll Page 6 of 9

Permit No. NCG030000
v _.Tier T .. �- _. ., : _ _ wo
If: During the term of this permit, the sampling results are above the benchmark values, or outside
of the benchmark range, for any specific parameter at a specific discharge outfall two times in a
row;
'Then: The permittee shall:
1. Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring for all parameters at every outfall where a
sampling result exceeded the benchmark value for two consecutive samples. Monthly
(analytical and qualitative) monitoring shall continue until three consecutive sample results
are below the benchmark values, or within the benchmark range.
3. If no discharge occurs during the sampling period, the permittee is required to submit a
monthly monitoring report indicating "No Flow" to comply with reporting requirements.
4. Maintain a record of the Tier Two response in the Stormwater Pollution Prevention Plan.
During the term of this permit, if the sampling results exceed the benchmark value, or are outside
the benchmark range, for any specific parameter at any specific outfall on more than four
occasions, DWQ may:
• Require that the permittee increase or decrease the monitoring frequency for the
remainder of the permit;
• rescind coverage under the General Permit, and require that the permittee apply for an
individual stormwater discharge permit;
• require the permittee to install structural stormwater controls;
• require the permittee to install other stormwater control measures; or
• require that the permittee implement site modifications to qualify for the No Exposure
Exclusion.
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
1 representative outfall status and shall be performed as specified in Table 4, and during the analytical
monitoring event. Qualitative monitoring is for the purpose of evaluating the effectiveness of the
Stormwater Pollution Prevention Plan (SPPP) and assessing new sources of stormwater pollution.
Part II Page 7 of 9

ITable 4. Qualitative Monitoring Requirements
Discharge Charactersttcs,�
i Frequency ; 5
Momtorng
Color
semi-annual
SDO
Odor
semi-annual
SDO
Clarity
semi-annual
SDO
Floating Solids
semi-annual
SDO
Suspended Solids
semi-annual
SDO
Foam
semi-annual
SDO
Oil Sheen
semi-annual
SDO
Erosion or deposition at the
outfall
semi-annual
SDO
Other obvious indicators
of stormwater pollution
semi-annual
SDO
Footnotes:
1 Monitoring Location: Qualitative monitoring shall be performed at each
stormwater discharge outfall (SDO) regardless of representative outfall status.
Permit No. NCG030000
SECTION D: ON -SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on -site which uses more than 55
gallons of new motor oil per month when averaged over the calendar year shall perform analytical
monitoring as specified in Table 5. This monitoring shall be performed at all outfalls which discharge
stormwater runoff from the vehicle maintenance areas, and in accordance with the schedule presented in
Table 2. All analytical monitoring shall be performed during a representative storm event.
Table 5. Analytical Monitoring Requirements for On -Site Vehicle Maintenance
Dttharge CharacertUmts
MeasurementSannpleSample
wFrc acne e
T e2tLocation3
H
standard
semi-annual
Grab
SDO
Oil and Grease
m
semi-annual
Grab
SDO
Total Suspended Solids
m
semi-annual
Grab
SDO
Total Rainfall4
inches
semi-annual
Rain gauge
-
New Motor Oil Usagegallons/month
semi-annual
Estimate
-
Footnotes:
I Measurement Frequency: Twice per year during a representative storm event.
2 If the stormwater runoff is controlled by a stormwater detention pond a grab sample of the discharge from the pond shall
be collected within the first 30 minutes of discharge from the pond.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) that discharges
stormwater runoff from area(s) where vehicle maintenance activities occur.
4 For each sampled representative storm event the total precipitation must be recorded. An on -site or local rain
gauge reading must be recorded.
Part lI Page 8 of 9

Permit No. NCG030000
Monitoring results shall be compared to the benchmark values in Table 6. Exceedences of
benchmark values require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater Best Management Practices (BMPs), as provided
in Part Il Section B.
Table 6. Benchmark Values for On -Site Vehicle Maintenance Activities
€Discliar' a Cliaracterjsti& _ , f= a
Bericlirriark Value „ _ _ ',,
H
Within the range 6.0 - 9.0
Oil and Grease
30 m /l
Total Suspended Solids
100 mgA
Part 11 Page 9 of 9

1 PART III
Permit No. NCG030000
STANDARD CONDITIONS FOR NPDES STORMWATER GENERAL
PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater
discharges in accordance with the following schedule:
Existing facilities already operating, but applying for coverage under this general permit
' for the first time: The Stormwater Pollution Prevention Plan shall be developed and
implemented within 12 months of the effective date of the initial Certificate of Coverage
issued pursuant to this general permit and updated thereafter on an annual basis.
a Secondary containment, as specified in Part II, Section A, Paragraph 2(b) of this permit,
shall be accomplished within 12 months of the effective date of the initial Certificate of
Coverage.
New facilities applying for permit coverage for the first time and existing facilities
previously permitted and applying for renewal under this general permit: All
requirements, conditions, limitations, and controls contained in this permit become
effective immediately upon issuance of the Certificate of Coverage. The Stormwater
Pollution Prevention Plan shall be developed and implemented prior to the beginning of
discharges from the operation of the industrial activity and be updated thereafter on an
annual basis. Secondary containment, as specified in Part H, Section A, Paragraph 2(b) of
this permit shall be accomplished prior to the beginning of discharges from the operation
of the industrial activity.
2. Duty to Comply
The permittee must comply with all conditions of this general permit. Any permit
noncompliance constitutes a violation of the Clean Water Act and is grounds for
enforcement action; for certificate of coverage termination, revocation and reissuance, or
modification; or denial of a certificate of coverage upon renewal application.
a. The permittee shall comply with standards or prohibitions established under
section 307(a) of the Clean Water Act for toxic pollutants within the time
provided in the regulations that establish these standards or prohibitions, even if
the permit has not yet been modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition is
subject to a civil penalty not to exceed $25,000 per day for each violation. Any
person who negligently violates any permit condition is subject to criminal
penalties of $2,500 to $25,000 per day of violation, or imprisonment for not more
than 1 year, or both. Any person who knowingly violates permit conditions is
subject to criminal penalties of $5,000 to $50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also, any person who violates a
permit condition may be assessed an administrative penalty not to exceed $10,000
Part III Page 1 of 11 Pages

Permit No. NCG030000
per violation with the maximum amount not to exceed $125,000. [Ref: Section
309 of the Federal Act 33 USC 1319 and 40 CFR 122.41(a).]
C. Under state law, a daily civil penalty of not more than ten thousand dollars
a ($10,000) per violation may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit. [Ref:
North Carolina General Statutes 143-215.6A]
' (I., Any person may be assessed an administrative penalty by the Director for
violating section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under
' section 402 of the Act. Administrative penalties for Class I violations are not to
exceed $10,000 per violation, with the maximum amount of any Class I penalty
assessed not to exceed $25,000. Penalties for Class It violations are not to exceed
$10,000 per day for each day during which the violation continues, with the
maximum amount of any Class lI penalty not to exceed $125,000.
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in
violation of this general permit which has a reasonable likelihood of adversely affecting
human health or the environment.
' 4. Civil and Criminal Liability
Except as provided in Section C of this permit regarding bypassing of stormwater control
1 facilities, nothing in this general permit shall be construed to relieve the permittee from
any responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-
215.3,143-215.6A, 143-215.613, 143-215.6C or Section 309 of the Federal Act, 33 USC
1319. Furthermore, the permittee is responsible for consequential damages, such as fish
kills, even though the responsibility for effective compliance may be temporarily
suspended.
' 5. Oil and Hazardous Substance, Liability
Nothing in this general permit shall be construed to preclude the institution of any legal
action or relieve the permittee from any responsibilities, liabilities, or penalties to which
the permittee is or may be subject to under NCGS 143-215.75 et seq. or Section 311 of the
Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this general permit does not convey any property rights in either real or
personal property, or any exclusive privileges, nor does it authorize any injury to private
property or any invasion of personal rights, nor any infringement of Federal, State or local
laws or regulations.
Part HI Page 2 of 11 Pages

Permit No. NCG030000
7. Severability
The provisions of this general permit are severable, and if any provision of this general
permit, or the application of any provision of this general permit to any circumstances, is
held invalid, the application of such provision to other circumstances, and the remainder
of this general permit, shall not be affected thereby.
8. Duty to Provide Information
The permittee shall furnish to the Director, within a reasonable time, any information
which the Director may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating the certificate of coverage issued pursuant to this
general permit or to determine compliance with this general permit. The permittee shall
also furnish to the Director upon request, copies of records required to be kept by this
general permit.
9. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
general permit shall, upon conviction, be punished by a fine of not more than $10,000 per
violation, or by imprisonment for not more than two years per violation, or by both. If a
conviction of a person is for a violation committed after a first conviction of such person
under this paragraph, punishment is a fine of not more that $20,000 per day of violation,
or by imprisonment of not more than 4 years, or both.
10. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to
be maintained under this general permit, including monitoring reports or reports of
compliance or noncompliance shall, upon conviction, be punished by a fine of not more
' than $10,000 per violation, or by imprisonment for not more than two years per violation,
or by both.
SECTION B: GENERAL CONDITIONS
General Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date, the permittee shall
submit forms and fees as are required by the agency authorized to issue permits no later
than 180 days prior to the expiration date. Any permittee that has not requested renewal
at least 180 days prior to expiration, or any permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will be
subjected to enforcement procedures as provided in NCGS § 143-2153.6 and 33 USC
1251 et. seq.
Part III Page 3 of I I Pages

Permit No. NCG030000
2. Transfers
The certificate of coverage issued pursuant to this general permit is not transferable to any
person except after notice to and approval by the Director. The Director may require
a modification or revocation and reissuance of the certificate of coverage to change the
name and incorporate such other requirements as may be necessary under the Clean
Water Act. Permittee is required to notify the Division in writing in the event the
permitted facility is sold or closed.
' 3. When an Individual Permit May be Required
The Director may require any owner/operator authorized to discharge under a certificate
of coverage issued pursuant to this general permit to apply for and obtain an individual
permit or coverage under an alternative general permit. Any interested person may
' petition the Director to take action under this paragraph. Cases where an individual
permit may be required include, but are not limited to, the following:
' a. The discharger is a significant contributor of pollutants;
b. Conditions at the permitted site change, altering the constituents and/or
characteristics of the discharge such that the discharge no longer qualifies for a
general permit;
The discharge violates the terms or conditions of this general permit;
d. A change has occurred in the availability of demonstrated technology or practices
for the control or abatement of pollutants applicable to the point source;
e. Effluent limitations are promulgated for the point sources covered by this genera]
permit;
f. A water quality management plan containing requirements applicable to such
point sources is approved after the issuance of this general permit.
g. The Director determines at his or her own discretion that an individual permit is
required.
4. When an Individual Permit May be Requested
Any permittee operating under this general permit may request to be excluded from the
coverage of this general permit by applying for an individual permit. When an individual
permit is issued to an owner/operator the applicability of this general permit is
automatically terminated on the effective date of the individual permit.
5. Signatory Rqquirements
All applications, reports, or information submitted to the Director shall be signed and
certified.
Part III Page 4 of 11 Pages

Permit No. NCG030000
a. All notices of intent to be covered under this general permit shall be signed as
follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of
this Section, a responsible corporate officer means: (a) a president,
secretary, treasurer or vice president of the corporation in charge of a
principal business function, or any other person who performs similar
policy or decision making functions for the corporation, or (b) the manager
of one or more manufacturing production or operating facilities employing
more than 250 persons or having gross annual sales or expenditures
exceeding 25 million (in second quarter 1980 dollars), if authority to sign
documents has been assigned or delegated to the manager in accordance
with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the
proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a
principal executive officer or ranking elected official.
b. All reports required by the general permit and other information requested by the
Director shall be signed by a person described above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having
responsibility for the overall operation of the regulated facility or activity,
such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or
position having overall responsibility for environmental matters for the
company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
C. Any person signing a document under paragraphs a. or b. of this section shall
make the following certification:
"I certify, under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing
violations."
Part III Page 5 of I I Pages

1
Permit No. NCG030000
6. General Permit Modification. Revocation and Reissuance, or Termination
The issuance of this general permit does not prohibit the Director from reopening and
modifying the general permit, revoking and reissuing the general permit, or terminating
the general permit as allowed by the laws, rules, and regulations contained in Title 40,
Code of Federal Regulations, Parts I22 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 2H .0100; and North Carolina General Statute 143-
' 215.1 et. at.
After public notice and opportunity for a hearing, the general permit may be terminated
for cause. The filing of a request for a general permit modification, revocation and
reissuance, or termination does not stay any general permit condition. The certificate of
coverage shall expire when the general permit is terminated.
' 7. Certificate of Coverage Actions
The certificate of coverage issued in accordance with this general permit may be
modified, revoked and reissued, or terminated for cause. The notification of planned
changes or anticipated noncompliance does not stay any general permit condition.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the
permittee to achieve compliance with the conditions of this general permit. Proper
operation and maintenance also includes adequate laboratory controls and appropriate
quality assurance procedures. This provision requires the operation of back-up or
auxiliary facilities or similar systems which are installed by a permittee only when the
operation is necessary to achieve compliance with the conditions of the general permit.
' 2. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
condition of this general permit.
e3. Bypassing of Stormwater Control Facilities
' Bypass is prohibited and the Director may take enforcement action against a permittee for
bypass unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property
damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary
control facilities, retention of stormwater or maintenance during normal periods of
Part Ill Page 6 of 11 Pages

1
Permit No. NCG030000
equipment downtime or dry weather. This condition is not satisfied if adequate
backup controls should have been installed in the exercise of reasonable
engineering judgment to prevent a bypass which occurred during normal periods
of equipment downtime or preventive maintenance; and
C. The permittee submitted notices as required under Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director
may approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
1. Re resentative Sampling
' Samples collected and measurements taken, as required herein, shall be characteristic of
the volume and nature of the permitted discharge. Analytical sampling shall be
performed during a representative storm event. Samples shall be taken on a day and time
that is characteristic of the discharge. All samples shall be taken before the discharge
joins or is diluted by any other waste stream, body of water, or substance. Monitoring
points as specified in this. permit shall not be changed without notification to and
approval of the Director.
2. Recording Results
For each measurement, sample, inspection or maintenance activity performed or collected
pursuant to the requirements of this general permit, the permittee shall record the
following information:
a. The date, exact place, and time of sampling, measurements, inspection or
' maintenance activity;
b. The individual(s) who performed the sampling, measurements, inspection or
maintenance activity;
C. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
1 3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with
accepted scientific practices shall be selected and used to ensure the accuracy and
reliability of measurements of the volume of monitored discharges.
Part IR Page 7 of I I Pages
e

Permit No. NCG030000
Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations
published pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting
Acts, and to regulations published pursuant to Section 304(g), 33 USC 1314, of the
aFederal Water Pollution Control Act, as Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this general permit, all test procedures
must produce minimum detection and reporting levels and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure.
5. Non-Stormwater Discharges
If a monitored storm event coincides with a non-stormwater discharge, the permittee shall
' separately monitor all parameters as required under the non-stormwater discharge permit
and provide this information with the stormwater discharge monitoring report.
6. Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater
discharges that are required to be sampled, the permittee may petition the Director for
representative outfall status. If it is established that the stormwater discharges are
substantially identical and the permittee is granted representative outfall status, then
sampling requirements may be performed at a reduced number of outfalls.
7. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with
the Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall
also be maintained on -site. The permittee shall retain records of all monitoring
information, including all calibration and maintenance records and all original strip chart
recordings for continuous monitoring instrumentation, and copies of all reports required
' by this general permit for a period of at least 5 years from the date of the sample,
measurement, report or application. This period may be extended by request of the
Director at any time.
8. Inspection and Entry
e The permittee shall allow the Director, or an authorized representative (including an
authorized contractor acting as a representative of the Director), or in the case of a facility
which discharges through a municipal separate storm sewer system, an authorized
representative of a municipal operator or the separate storm sewer system receiving the
discharge, upon the presentation of credentials and other documents as may be required
by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located
or conducted, or where records must be kept under the conditions of this general
permit;
Part III Page 8 of 1 1 Pages

Permit No. NCG030000
b. Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this general permit;
Inspect at reasonable times any facilities, equipment (including monitoring and
control equipment), practices, or operations regulated or required under this
general permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring general
permit compliance or as otherwise authorized by the Clean Water Act, any
substances or parameters at any location.
SECTION E: REPORTING REQUIREMENTS
1.
2.
3.
4.
Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the
Division on Discharge Monitoring Report forms provided by the Director. Submittals
shall be received by the Division no later than 30 days from the date the facility receives
the sampling results from the laboratory.
When no discharge has occurred from the facility during the report period, the permittee
is required to submit a discharge monitoring report within 30 days of the end of the six-
month sampling period, giving all required information and indicating "NO FLOW" as
per NCAC T15A 02B .0506.
Submitting Reports
Duplicate signed copies of all reports required herein, shall be submitted to the following
address:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Availability, o�ports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section
308 of the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms
shall be available for public inspection at the offices of the Division of Water Quality. As
required by the Act, analytical data shall not be considered confidential. Knowingly
making any false statement on any such report may result in the imposition of criminal
penalties as provided for in NCGS 143-215.6B or in Section 309 of the Federal Act.
Non-Stormwater Discharges
If the storm event monitored in accordance with this general permit coincides with a non-
stormwater discharge, the permittee shall separately monitor all parameters as required
Part Ill Page 9 of 1 1 Pages

Permit No. NCG030000
' under the non-stormwater discharge permit and provide this information with the
stormwater discharge monitoring report.
5. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes
at the permitted facility which could significantly alter the nature or quantity of pollutants
discharged. This notification requirement includes pollutants which are not specifically
listed in the general permit or subject to notification requirements under 40 CFR Part
122.42 (a).
6. Anticipated Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes
at the permitted facility which may result in noncompliance with the general permit
requirements.
' 7pass
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it
shall submit prior notice, if possible at least ten days before the date of the bypass;
including an evaluation of the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of
' becoming aware of an unanticipated bypass.
8. Twenty-four Hour Reporting
The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes;
the period of noncompliance, including exact dates and times, and if the noncompliance
has not been corrected, the anticipated time compliance is expected to continue; and steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case -by -case basis if the oral report has
been received within 24 hours.
9. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour
reporting at the time monitoring reports are submitted.
Part III Page 10 of 1 1 Pages

Permit No. NCG030000
10. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in a Notice
of Intent to be covered under this general permit or in any report to the Director, it shall
promptly submit such facts or information.
Part III Page I I of I I Pages

Permit No, NCG030000
PART IV LIMITATIONS REOPENER
This general permit shall be modified or alternatively, revoked and reissued, to comply with any
applicable effluent guideline or water quality standard issued or approved under Sections 302(b)
(2) (c), and (d), 304(b) (2) and 307(a) of the Clean Water Act, if the effluent guideline or water
quality standard so issued or approved:
a. Contains different conditions or is otherwise more stringent than any effluent limitation in
the general permit; or
1 b. Controls any pollutant not limited in the general permit.
The general permit as modified or reissued under this paragraph shall also contain any other
erequirements in the Act then applicable.
1 PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
rThe permittee must pay the administering and compliance monitoring fee within 30 (thirty) days
after being billed by the Division. Failure to pay the fee in timely manner in accordance with
a 15A NCAC 2H .0105(b)(4) may cause this Division to initiate action to revoke the Certificate of
Coverage.
' PART VI DEFINITIONS
Act
See Clean Water Act.
2. Arithmetic Mean
The arithmetic mean of any set of values is the summation of the individual values
divided by the number of individual values.
3. Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Nan-stormwater discharges which shall be
allowed in the stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
(b) Uncontaminated groundwater, foundation drains, air -conditioner condensate
without added chemicals, springs, discharges of uncontaminated potable water,
Parts IV, V, and VI Page 1 of 6 Pages

Permit No. NCG030000
waterline and lire hydrant flushings, water from footing drains, flows from
riparian habitats and wetlands.
(c) Discharges resulting from fire -fighting or fire -fighting training.
Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters.
BMPs may take the form of a process, activity, or physical structure.
Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control
facility including the collection system, which is not a designed or established operating
mode for the facility.
Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a
single above ground storage container having a capacity of greater than 660 gallons or
with multiple above ground storage containers located in close proximity to each other
having a total combined storage capacity of greater than 1,320 gallons.
Certificate of Coverage
The Certificate of Coverage (COC) is the cover sheet which accompanies the general
permit upon issuance and lists the facility name, location, receiving stream, river basin,
effective date of coverage under the permit and is signed by the Director.
Clean. Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as
amended, 33 USC 1251, et. seq.
Division or DWO
The Division of Water Quality, Department of Environment and Natural Resources.
10_ Director
The Director of the Division of Water Quality, the permit issuing authority.
11. EMC
The North Carolina Environmental Management Commission.
Parts IV, V, and VI Page 2 of 6 Pages

Permit No. NCG030000
1 12, Grab Sample
An individual samples collected instantaneously. Grab samples that will be directly
analyzed or qualitatively monitored must be taken within the first 30 minutes of
discharge_
13. Hazardous Substance
a Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean
Water Act.
14. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and
' which is not a land treatment facility, a surface impoundment, an injection well, a
hazardous waste long-term storage facility or a surface storage facility.
' 15. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such
as a city or town.
16. No Exposure
A condition of no exposure means that all industrial materials and activities are protected
by a storm resistant shelter or acceptable storage containers to prevent exposure to rain,
snow, snowmelt, or runoff. Industrial materials or activities include, but are not limited
to, material handling equipment or activities, industrial machinery, raw materials,
intermediate products, by-products, final products, or waste products. DWQ may grant a
No Exposure Exclusion from NPDES Stormwater Permitting requirements only if a
facility complies with the terms and conditions described in 40 CFR § 122.26(g).
' 17. Notice of Intent
The state application form which, when submitted to the Division, officially indicates the
1 facility's notice of intent to seek coverage under a general permit.
18. Overburden
p Any material of any nature, consolidated or unconsolidated, that overlies a mineral
deposit, excluding topsoil or similar naturally -occurring surface materials that are not
disturbed by mining operations.
19. Pertnittee
1 The owner or operator issued a certificate of coverage pursuant to this general permit_
Parts IV, V, and VI Page 3 of 6 Pages

Permit No. NCG030000
20. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited
to, any pipe, ditch, channel, tunnel, conduit, well, or discrete fissure from which
storm water is or may be discharged to waters of the state.
e21. Representative Storm. Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm
event may contain up to 10 consecutive hours of no precipitation. For example, if it rains for 2
hours without producing any collectable discharge, and then stops, a sample may be collected if a
rain producing a discharge begins again within the next 10 hours.
22. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is
representative of the discharges at multiple outfalls, the DWQ may grant representative
outfall status. Representative outfall status allows the permittee to perform analytical
monitoring at a reduced number of outfalls.
23. Rinse Water Discharge
The discharge of rinse water from equipment cleaning areas associated with industrial
activity. Rinse waters from vehicle and equipment cleaning areas are process
wastewaters and do not include washwaters utilizing any type of detergent or cleaning
agent.
24. Secondary Containment
Spill containment for the contents of the single largest tank within the containment
structure plus sufficient freeboard to allow for the 25-year, 24-hoar storm event.
25. Section 313 Water Priority Chemical
A chemical or chemical category which:
Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund
Amendments and Reauthorization Act (SARA) of 1986, also titled the Emergency
Planning and Community Right -to -Know Act of 1986;
b. Is present at or above threshold levels at a facility subject to SARA title III,
Section 313 reporting requirements; and
C. That meet at least one of the following criteria:
(1) Is listed in appendix D of 40 CFR part 122 on either Table II (organic
priority pollutants), Table III (certain metals, cyanides, and phenols) or
Table IV (certain toxic pollutants and hazardous substances);
Parts IV, V, and VI Page 4 of 6 Pages

Permit No. NCG030000
(2) Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the
CWA at 40 CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality
criteria.
a26. Severe Property Damage
Means substantial physical damage to property, damage to the control facilities which
causes them to become inoperable, or substantial and permanent loss of natural resources
which can reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
e27. Significant Materials
Includes, but is not Iimited to: raw materials; fuels; materials such as solvents, detergents,
and plastic pellets; finished materials such as metallic products; raw materials used in
food processing or production; hazardous substances designated under section 101(I4) of
1 CERCLA; any chemical the facility is required to report pursuant to section 313 of Title
III of SARA; fertilizers; pesticides; and waste products such as ashes, slag and sludge that
have the potential to be released with stormwater discharges.
a28. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of
reportable quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and
CFR 117.21) or section 102 of CERCLA (Ref: 40 CFR 302.4).
29. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately
' following rainfall or as a result of snowmelt.
30. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying
stormwater and which is directly related to manufacturing, processing or raw material
storage areas at an industrial site. Facilities considered to be engaged in "industrial
activities" include those activities defined in 40 CFR 122.26(b)(14). The term does not
include discharges from facilities or activities excluded from the NPDES program.
31. Stormwater Pollution Prevention Plan
' A comprehensive site -specific plan which details measures and practices to reduce
stormwater pollution and is based on an evaluation of the pollution potential of the site.
Parts IV, V, and VI Page 5 of 6 Pages

1
I
32.
33.
34.
Permit No. NCG030000
Ten Year Design Storm
The maximum 24-hour precipitation event expected to be equaled or exceeded on the
average once in ten years. Design storm information can be found in the State of North
Carolina Erosion and Sediment Control Planning and Design Manual.
Total Flow
The flow corresponding to the time period over which the sample collection occurs.
Total flow shall be either; (a) measured continuously, (b) calculated based on the amount
of area draining to the outfall, the amount of built -upon (impervious) area, and the total
amount of rainfall, or (c) estimated by the measurement of flow at 20-minute intervals
during the rainfall event.
Toxic Pollutant
Any pollutant Iisted as toxic under Section 307(a)(1) of the Clean Water Act.
35. Upset
36.
37.
38.
Means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the permittee. An upset does not include
noncompliance to the extent caused by operational error, improperly designed treatment
or control facilities, inadequate treatment or control facilities, lack of preventive
maintenance, or careless or improper operation.
Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning
operations, or airport deicing operations.
Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported
by water, air, gravity, or ice from its site of origin which can be seen with the unaided
eye.
25-year, 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the
average, once in 25 years.
Parts IV, V, and VI Page 6 of 6 Pages

I» > Diel11 KWO
SOLVENT MANAGEMENT PLAN
0 PIEDMONT GIsOLOGIC P.C.

1
KABA ILCO, WINSTON-SALEM FACILITY
SOLVENT MANAGEMENT PLAN
aThis Solvent Management Plan is part of the Stormwater Pollution Prevention Plan and has been prepared
to satisfy the requirement as a substitute for periodic sampling of total toxic organics is stormwater effluent
' under the National Pollution Discharge Elimination System (NPDES) General Permit No. NCG 030000.
This Solvent Management Plan will be updated if there is a change in spill/leak prevention measures or the
usage and disposal of total toxic organics as defined in 40 CFR 433.1 le.
SITE DESCRIPTION
The Kaba Ilco facility is located on the northeast side of Indiana Avenue in Winston-Salem, Forsyth
1 County, North Carolina. The site covers approximately 10.5 acres with 7.0 acres (67%) being impervious to
rainwater due to structures and paved areas. There are two stormwater outfalls for the site shown in Figure 2
of the Stormwater Pollution Prevention Plan. Outfall B is a gully located at the southeast corner of the
property and drains areas of industrial activity. Outfall C is located in the street along the southwest edge of
the site and drains the parking area in front of the administrative offices which includes several garbage
' dumpsters, roof drains, and storage trailers. Drainage from the site flows to an unnamed tributary of Brush
Fork River and eventually to the Yadkin River. The Certificate of Coverage for the facility is CDC No.
NCG030245,
SITE ACTIVITIES
' The plant is a 120,000 square foot facility is used for plating, stamping, machining, and assembly of locks
and lock components. The Standard Industry Classification (SIC) Code for the facility is 34 (fabricated
metal products). Site activities involving chemicals considered to be toxic organics consist of painting,
cleaning, coating, and metal plating of components.
USAGE OF TOTAL TOXIC ORGANICS
Chemicals used at the facility which are considered total toxic organics, as defined in 40 CFR 433.11e, are
listed as follows:
' • Xylene
• Phenol; and
• Stoddard Solvent.
PIEDMONT GEOLOGIC, P.C.

The chemicals listed above are all stored in quantities of 55 gallons or less and most are components is
other products. Small quantities of additional toxic organics may be present in other products used in small
volumes at the facility.
DISPOSAL METHODS
The Kaba Ilco, Winston-Salem facility is listed with the North Carolina Department of Environment and
Natural Resources, Solid Waste Division as a generator of hazardous wastes (Facility ID #
NCD024895864) as regulated by the Resource Conservation and Recovery Act. Solid non -hazardous
materials are placed into one of several dumpsters, located under permanent cover, which are periodically
removed by a private contractor. Metal scraps, shavings, and pieces, which may still contain some residual
cutting oils, are stored for recycling in a dumpster, under permanent cover.
Hazardous wastes that are generated during the on -site operations of the facility are stored inside the
hazardous materials storage building, in a dedicated bay, with a secondary containment dike. The hazardous
wastes are periodically removed by licensed hazardous waste haulers and recycled or disposed of in
accordance with state and federal guidelines. Hazardous wastes are not stored on site for more than 90 days
in accordance with applicable standards. No toxic substances at the Kaba Ilco, Winston-Salem facility are
disposed of on -site nor are any discharged to surface waters.
SAFETY PRACTICES AND PROCEDURES
Kaba llco has implemented numerous controls and preventative measures to insure that a release of toxic
organics to the environment does not occur. Loading/unloading or materials from trucks is performed
indoors with weather sealing pads around the bays. Material is not brought in or shipped out by rail. Bulk
storage of liquid chemicals occurs in barrels and aboveground tanks, both of which have secondary
containment dikes. Toxic organic are stored in sealed containers in the hazardous materials building, with a
secondary containment dike. Material storage, including solid, liquid, and waste products, which may have
been exposed to toxic organics compounds is covered to prevent exposure to stormwater. Process water to
be treated is stored in aboveground tanks inside the wastewater treatment building with secondary
containment dikes. Wastewater undergoes a precipitation/flocculation process to remove metals and a pH
adjustment before it is discharged to the Winston-Salem POTW. No significant levels of toxic organics are
present in the treated wastewater and it is not exposed to stormwater.
Routine inspections of storage and pumping areas for leaks or problems are made by maintenance
personnel. The expansion joints have been sealed on concrete floors where the potential for spills exist.
PIEDMONT GEOLOGIC P. C.

' Furthermore, the maintenance department stocks a generous supply of powdered absorbent and of absorbent
materials. Training in spill prevention and cleanup is provided to the members of the Pollution Prevention
Team. Team members are trained at the time of initial employment and annually thereafter, The training
encompasses proper spill prevention, spill response, and cleanup in addition to applicable pollution control
laws and regulations. Employees working in facility operations which have the potential to contaminate
stormwater receive informal training. The responsibility for this employee training rests with the area
supervisors.
1 PIEDMOjVT GEOLOGIC. P.C.

APPENDIX D
CONTINGENCY PLAN
ePIEDMONT GC0L0GIC, P.C.

a� �r r r �■■ o� �n r® r �r r r r r r��

Contingency Plan
KABA ILCO
CORP.
Winston-Salem
North Carolina

Contingency Plan
KABA ILCO CORP.
Winston-Salem, N.C.
Emeraency Coordinators
David Stewart — Ext. 278
Home: [phone]
Cell: [phone]
Walter Dyson — EA #261
Cell: [phone]
David Spencer — Ext. #254
Home: [phone]
Cell: [phone]
Ed Lodics --- Ext. #200
Cell: [phone]
Must be contacted when any
major spill or release occurs
Edwin Smith - Ext. 247
Cell: [phone]
(Revised March 2010)
2

Kaba ILC4 Corp.
Contingency Plan
SCOPE:
The Contingency Plan is designed to minimize hazards to human health
or the environment from fires, explosions or any unplanned sudden or
non -sudden release of hazardous waste or hazardous waste constituents
to air, soil or surface water.
The provisions
of this plan must be
carried out immediately
whenever
there is a fire,
explosion or release
of hazardous waste or
hazardous
waste constituents, which could threaten human health or the
environment.
R

This contingency plan has been prepared in compliance with NCAC 10F.
0032-10 (40 CFR 264.5 to 264.56 (Subpart D). It contains eight parts:
I. General Information
II. - Emergency Coordination
III. Implementation of the Contingency Plan
IV. Emergency Response Procedures
V. Emergency Equipment
VI. Coordination Agreements
VII. Evacuation Plan
VIII. Required Reports
n

I. GENERAL INFORMATION
Kaba ILCO Corp., the world's largest security product manufacturer
operates a plant in Winston-Salem North Carolina. The facility in
Winston-Salem primarily produces lock assemblies. Warehousing
distributions are also performed at this plant.
The Winston-Salem plant produces a great majority of its own zinc
castings used to manufacture lock assemblies. Thelock assemblies and
die cast parts may be plated (nickel, brass, zinc, chrome, copper and
lacquer finished or power coat painted).
These processes utilize many chemicals, some hazardous in addition to
the normal day to day manufacturing processes that use machining
lubricants and cleaning chemicals.
Kaba ILCO Corp. is located at:
2941 Indiana Ave
Winston-Salem, North Carolina 27105
General Manager: Michael Kincaid
6

I
Following is a summary of contingency related activities:
•:• Nickel plating process, like many other plating processes; produce
rinse waters containing metal hydroxides and small amounts of
cleaners and acids. These rinse waters are sent to the Waste
Treatment Plant where the pH is adjusted, a flocculent is added to
assist metal precipitation, the rinse waters then overflow to the POTW
and the filtered metals are recycled at an offsite recycling facility
within 180 days of generation onsite.
❖ Nickel plating baths contain a considerable quantity of nickel. Wastes
are normally not generated.
❖ Lacquers, thinners, oils and paints used during manufacturing are
stored in various departments throughout the plant in approved
flammable storage containers. Wastes are drummed separately by
type and sent offsite within 180 days following generation to a fuel
blending facility.
Sulfuric acid, nitric acid and ammonia used in plating operations are
stored outside the Waste Treatment Plant.
Cyanides and metal salts are stored inside a raw material storage cage
adjacent to the rack plating line under lock and key.
Brass plating and copper plating tanks contain large amounts of
cyanide solutions. Tanks are surrounded by dikes, which drain only

to the Waste Treatment Plant. Cyanides are destroyed during the
waste treatment process.
•:• Barrel plating consists Nickel, Brass, cyanide, copper, zinc and nitric
acid. All wastes generated by the barrel plating process are pretreated
in the Waste Treatment Plant.
:• The Waste Treatment Plant is used to treat cyanide and metallic
wastes, primarily rinse waters, generated in the plating processes.
Concrete dikes surround cyanide and chrome treatment tanks to
capture any spillage.
❖ Chrome chromate tanks contain chromic acid used in the zinc
chromating plating process. The tank is diked and drains to the Waste
Treatment Plant.
• Rack Plating Line tanks contains large amounts of cyanides, nickel,
copper, chrome, acids and caustic cleaners. Diking surrounds the
tanks and any spills or rinse waters will drain to the Waste Treatment
Plant.
❖ All hazardous waste except flammable hazardous waste is stored in a
building adjacent to the Waste Treatment Plant in what is commonly
known as the courtyard. The hazardous wastes stored in this location
are labeled as to their contents and sent offsite for treatment within
180 days of generation.
E

a II. EMERGENCY COORDINATORS

II. EMERGENCY COORDINATORS
® JAMES EDWIN SMITH
WORK:
[phone]; EXT 247
1055 Abby Place Court
CELL:
[phone]
King, N.C. 27021
' ALL EMERGENCY SITUATIONS
DAVID A. SPENCER
WORK:
[phone]; EXT 254
'
183 Hunters Horn Lane
HOME:
[phone]
Winston-Salem, N.C. 27103
CELL:
[phone]
ASSIST EMERGENCY SITUATIONS
David Stewart
WORK:
[phone]; EXT 278
144 Crackers Neck Rd.
HOME:
[phone]
Pilot Mountain, N.C. 27041
CELL:
[phone]
ALL EMERGENCY SITUATIONS
WALTER DYSON
WORK:
[phone]; EXT 261
1192 Seven Island Rd.
CELL:
[phone]
Danbury, N.C. 27061
'
ASSIST EMERGENCY SITUATIONS
ED LODICS
WORK:
[phone]; EXT 200
5691 New Avedon Dr.
CELL:
[phone]
Greensboro, NC 274551
The Emergency Coordinators can deputize other employees to assist them
in the event of an emergency. The deputized employees can not enter
the hazard perimeter under any circumstances.
" The Emergency Coordinator serves as Chief of the emergency crew.
Emergency coordinators have received 24-Hour Hazardous Waste
aOperation training. This training is in addition to standard plant
emergency training.
tOne of the emergency coordinators is always "on call' and can be reached
by telephone or pager.
The Emergency Coordinator has the authority to commit the resources
needed to carry out the contingency plan.
10

III. IMPLEMENTATION OF THE
CONTINGENCY PLAN

III, IMPLEMENTATION OF THE CONTINGENCY
PLAN
This contingency plan will be implemented if an incident occurs that may
threaten human health or the environment. At the time of an incident,
the Emergency Coordinator has full authority to make this decision.
Depending on the degree of seriousness, the following potential
emergencies could cause implementation of this contingency plan:
❖ Spill or release of electroplating baths at the barrel or rack plating
lines.
• Spill of electroplating waste during transfer, treatment or storage.
• Spill of sulfuric or hydrochloric acid at the storage area.
•:• Spill or release of hazardous waste located in the Waste Treatment
Plant Storage building.
+ Spill of electro or soap cleaners
' ❖ Any chemical used in the facility where a chemical reaction causes a
release of toxic fumes in the facility.
❖ Spill or release of bleaches or flocculent at the side of the Waste
Treatment Plant in the storage building.
❖ Spill or release of pretreatment solutions in the Waste Treatment
Plant.
1
12

❖ Spill or release of cyanides in any shape, type or form anywhere in the
facility.
❖ Release of ammonia hydroxide at the storage area outside of the Waste
Treatment Plant.
Fire and/or explosion at the propane tank outside by the Waste
Treatment Plant.
❖ Spill or release of alkaline, cleaners or brightener solutions in the
Chemical Storage Building.
❖ Spill or release of oils and lubricants in departments throughout the
plant.
•A Release of nickel, chrome, -chrome kill, acid salts and oxidizers in the
storage racks adjacent to the plating lines.
13

IV. EMERGENCY RESPONSE
PROCEDURES
14

N. EMERGENCY RESPONSE PROCEDURES
A. Notification
' 1. Any employee discovering a fire or hazardous release that is not
readily controllable with equipment and materials in the
' department must notify either the maintenance department,
security, or the operations manager. This can be done by:
(a) radio channel frequency 1 - for maintenance
(b) radio channel frequency 3 - for operations manager, or
(c) go to the nearest in -plant telephone and Dial 88 and then wait
for two beeps and then dial 00 - and say, "Emergency in
Department (number". Repeat three times.
2. All employees hearing the emergency notification or the alarm
must shut down their equipment and proceed immediately to
their designated_ evacuation location.
3. If the fire or release is extremely serious and may warrant a plant
evacuation, contact Security (Ext. 227) who will activate the plant
alarm system.
4. Following items two (2) and three (3) above, immediately contact
the Operations Manager (Ext. 200, or the General Manager Ext.
304). If the Operations Manager or the General Manager is not
available, contact any management employee.
15

5. The management personnel will immediately contact one or more
of the Emergency Coordinators.
6. The Emergency Coordinator will assess the situation and respond
as trained.
7. In the event of a major fire or explosion the emergency coordinator
or security guard on duty, will be responsible for notifying the fire
department (911). Note: If the alarm has been activated the fire
department has been notified.
8. In the event of a major fire, explosion, or release of chemicals, the
Emergency Coordinator will contact, the Incident Commander,
who will take the necessary steps to report the incident to the
Office of Emergency Management, if necessary. The report would
include the following:
i): Name and telephone number of the reporter.
ii): Name and address of the plant.
iii): Time and type of incident (e.g., spill occurred at 3:30pm).
iv): Identification and quantity of material involved (e.g., 50
gallons of electroplating hazardous waste overflowed on to the
property surface soil.
v): The extent of injuries (e.g., no injuries).
vi): The potential hazards to the environment or human
' health outside of the facility.
16
e

B: Containment and Control.
1. The emergency coordinator will take all necessary measures to
contain the hazard within the facility and prevent the spread of
contamination to nearby properties.
2. Absorbent, when necessary may be placed on the spill or used as
a dike. Absorbent is located in the Waste Treatment Plant or the
Tool Crib.
3. Should any spills reach the surface soils, a small bulldozer will be
rented. All potentially contaminated soils must be placed on a
polyethylene tarp (20-mil minimum) and then covered with tarps.
Temporary diking must surround the soil. The soil will be
considered hazardous unless analysis shows otherwise_ The
bulldozer will be decontaminated by triple rinsing and all water
collected following the decontamination process will be collected in
EPA approved 55-gallon drums and stored separately. All
Emergency Coordinators will utilize the proper level of protective
clothing as Hazwoper trained.
4. The Emcrgency Coordinator will utilize the following measures to
1 ensure maximum protection to the safety and health for the
employees and nearby residents.
i : Use of appropriate protective equipment
ii): Dismiss all non -essential personnel.
17

iii). Notify the appropriate City officials in the event that evacuation
of certain surrounding properties is required.
C. Basic Spill Clean-up for Liquids:
1. Determine whether the spill is aqueous (water-soluble), oil base, or
incompatible with water.
2. Obtain absorbent material from the Waste Treatment Plant or Tool
Crib.
3. Contain the spill and keep it segregated from other chemicals by
placing absorbent around the spill. If the spill is minor, absorbent
may be placed directly on the spill.
4. Insure the spill is completely contained.
S. The Emergency Coordinator is strictly required at this point.
6. The Emergency Coordinator will determine if treatment in -place,
recovery, or containment by drums, etc. for disposal is required.
Only qualified personnel will make these determinations.
7. Proper drums are required and must be approved by the
Emergency Coordinator.
8. Generator labeling will be required on all hazardous substances.
18

D. Follow-up Action:
1. Following
containment
and
control
of
the emergency, the
Emergency
Coordinator
will
provide
for
collection, treatment,
and/or disposal of any waste, contaminated soil or water.
2. The Emergency Coordinator will assure the emergency actions
have been completely eliminated prior to issuing an "all clear"
allowing employees to resume normal production operations.
3. The Emergency Coordinator will ensure that the emergency crew
restores all emergency equipment to full operational status.
4. The Emergency Coordinator(s), Operations Manager and the
General Manager will investigate the cause of the emergency and
take the necessary steps to prevent a reoccurrence of the
incident.
5. Minor injuries can be treated using first aid kits located in the
first Aid office or utilizing the facility emergency showers and/or
eyewashes.
6. Forsyth County Rescue Squad would transfer major injuries to
the closest hospital.
E

V. EMERGENCY EQUIPMENT
A. Each
working area is
equipped with ABC fire
extinguishers. Areas
that
house hazardous
and toxic chemicals are equipped with an
emergency shower and eyewash.
B. The Tool Crib and Maintenance departments contain a supply of
absorbent material, shovels and other cleanup supplies.
C. A First Aid office is located in the administrative office.
D. Each supervisor and the operations manager are equipped with mobile
radios.
E. The plant is equipped with a PA system that can be activated from any
telephone by dialing "88" and then wait for two beeps and then
dial 00.
F. An outdoor emergency telephone is located on the outside wall of
Technical Service in the courtyard.
G. If needed, dial 911 _
21

VI. COORDINATION AGREEMENTS
22

DTI. COORDINATION AGREEMENTS
A. WINSTON--SALEM FIRE DEPARTMENT( 9I1 or 773-7900 ]; The
Winston-Salem Office of Emergency Management has received a copy
of the Contingency Plan. This information is available to the local Fire
and Police Departments in the event of any emergency. The
Emergency Management Office has an aerial map and plant layout
that identifies the locations and types of hazardous materials.
B. WINSTON-SALEMPOLICE DEPARTMENT (911 OR 773-7700
The Winston-Salem Police Department has received a copy of this
plan.
C. FORSYTH MEDICAL CENTER ( 718-5000 ]
The Forsyth Memorial Hospital has received a copy of this plan.
D. NATIONAL RESPONSE CENTER 1800-424-8802 ).
The National Response Center in Washington would be contacted to
obtain guidance when handling major spills or incidents involving
unidentified chemicals. The National Response Center can assist in
providing information on local HAZMAT teams.
E. CITY OF WINSTON--SALEM STORM WATER DIVISION
Keith Huff, Stormwater Director Work: 747-6962
Cell: 406-3332
John Spainhour Work: 747-6965
Cell: 416-2379
23

Andrew Allen
Work: 747-6968
Cell: 4I3-0675
F. FORSYTH COUNTY ENVIRONMENTAL AFFAIRS OFFICE
336-703-24401
G. The Department of Environment & Natural Resources and/or State
Emergency Management would be contacted to verify procedures for
notification when a state or national response team is required to
' respond.
1 Local Services:
Department of Environment & Natural Resources -
Hazardous Waste Section: ( 919-508-8400 j
State Services:
State Emergency Management: ( 1-800-662-7956 j
This plan has been distributed as follows:
❖ MICHAEL KINCAID/ GENERAL MANAGER
❖ ED LODICS / OPERATIONS MANAGER
•:• ANN STRICKLAND / HUMAN RESOURCE MANAGER
•:• WINSTON-SALEM FIRE DEPARTMENT
❖ WINSTON-SALEM POLICE DEPARTMENT
❖ FORSYTH MEDICAL CENTER
❖ JAMES EDWIN SMITH - HEAD EMERGENCY COORDINATOR
❖ DAVID SPENCER -- EMERGENCY COORDINATOR
•:• WALTER DYSON - EMERGENCY COORDINATOR
❖ ISAAC WILLIAMS - ASSISTANT COORDINATOR
•:• ANTHONY WASHINGTON - ASSISTANT COORDINATOR
24

VII. Evacuation Plan
A. Plant personnel will evacuate the facility should the Emergency
Coordinator determine their personal safety is in danger.
B. The PA or Fire Alarm systems will be utilized to notify plant personnel.
C. Evacuation charts showing the routes of evacuation are posted
throughout the plant and at the end of this Contingency Plan.
26

VIII. REFIRED REPORTS
A. The Head Emergency Coordinator
will
notify the EPA
Regional
Administrator and appropriate Sate
and
local authorities to
confirm
follow-up actions have been implemented.
B. The Head Emergency Coordinator will note in an operating record, the
time, date, and details of the incident that required implementation of
the Contingency Plan. A written report in accordance with 40 CFR
265.560) will be submitted to the EPA Regional Administrator.
C. The Head Emergency Coordinator and Emergency Coordinators will
revise this Contingency Plan in accordance with the experience
acquired during each emergency situation and will provide copies of
the revision to the distribution.
28

APPENDIX E
STOR IWATER SAMPLING PROTOCOL
PMDMONT GEOLOGIC, P.C.

ll�

KABA ILCO, WINSTON-SALEM FACILITY
STORMWATER SAMPLING PROTOCOL
This sampling plan for the stormwater effluent at the Kaba Ilco facility located at 2941 Indiana Avenue,
Winston-Salem, Notch Carolina has been prepared to provide direction for sampling of the stormwater. The
information provided in this plan was obtained from state and federal regulations and the text of General
Permit No. NCG030000.
SAMPLING LOCATIONS
According to the requirements of General Permit NCG030000, stormwater samples are required only from
outfalls which drain area that contain industrial activity. For example, if the drainage area for an outfall was
determined to contain discharges from a non -industrial area (such as a parking lot) sampling would not be
required. Outfalls of areas that receive drainage from industrial activities, exposed storage, or transfer
operations must be sampled.
Based on comments received by Kaba llco Corp. from North Carolina Department of Environmental and
Natural Resources (NCDENR) Division of Water Quality and City of Winston-Salem Public Works
personnel following a March 26, 2004 site inspection, only one stormwater outfall (Outfall B) fits the
criteria for sampling. Outfall B is located adjacent to the hazardous materials storage building, as shown on
Figure 2, and is a drop box installed at grade and fitted with a stubbed out pipe to allow proper sampling of
stormwater.
STORM EVENT REQUIRED FOR SAMPLING
Runoff from a representative storm even must be sampled in order to obtain the data required by the permit.
A representative storm event is a storm event that measures greater than 0.1 inches of rainfall. The 72 hours
preceding the storm event must have had less than 0.1 inches of rainfall. The total amount of rainfall should
be measured at the end of the storm event with a rain gauge.
SAMPLE PROCEDURES AND ANALYTICAL METHODS
A grab sample will be collected from the sample location for outfall B within 30 minutes of discharge at the
outfall. A new pair of nitrile gloves shall be worn by the sampler to collect each stormwater sample.
Stormwater samples will be collected directly from the water stream into pre -preserved laboratory prepared
containers. Upon collection, stormwater samples will be labeled with sample identification , sample date
PIEDMONT GEOLOGIC, AC.

and time, sampler name, and the requested laboratory analysis and placed on ice in a cooler pending
transport to the laboratory.
Stormwater will be collected from the sampling location for outfall B and submitted to a North Carolina
certified laboratory and analyzed for the following:
• Total Lead by Method 200.7;
• Oil and Grease by Method 9071;
• Total Suspended Solids by Method 160.2; and
• pH by Method 4500 (must be measured by certified field parameter laboratory within 15 minutes
of collection)
Sampling for total toxic organics is not required since the facility has a Solvent Management Plan
incorporated into the Stormwater Pollution Prevention Plan. A signed certification on the discharge
monitoring reports attesting to the existence and implementation of the Solvent Management Plan allows
this waiver.
Qualitative monitoring of stormwater discharges will be conducted on a semi-annual basis and will coincide
with analytical monitoring described above. Qualitative monitoring will be conducted by Kaba llco
personnel and recorded on NCDENR SDO Qualitative Monitoring Report forms.
After the laboratory results of analysis are received, Kaba Ilco personnel will record the results on
NCDENR Stormwater Discharge Outfall (SDO) Analytical Monitoring Report forms. The original signed
copy and one duplicate copy of both the SDO Analytical and Qualitative Monitoring Report forms will
mailed to:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina
PIEDMONT CEOLr7GIC. P.C.

APPENDIX P
POLLUTION PREVENTION WORKSHEETS
1 PIEDMONT GEOLOGIC, P.C.

I
a
J
I
I
POLLUTION PREVENTION TEAM ROSTER
Site: Kaba Ilco, Winston-Salem Facility
Worksheet #1
Address: 2941 Indiana Avenue
Updated by: Waseem Kunbargi
Forsyth
County
Title: Consultant
Winston-Salem, North Carolina
Date: 3/15/2010
Member Name:
lames Edwin Smith
Title:
Wastewater Treament Supervisor
Office Phone:
336-725-1331 ext. 247
Responsibilities:
Signatory authority; spill response leader;
Member Name:
Ed Lodics
Title:
Operations Manager
Office Phone:
336-725-1331 ext. 200
Responsibilities:
Coordinate stormwater sampling; assist in developing plan elements; note any process
changes; conduct inspections; chose stormwater management options, keep all records and
submit appropriate reports.
Member Name:
David Stewart
Title:
Maintenance Dept. Supervisor
Office Phone:
336-725-1331 ext. 278
Responsibilities:
Implementing preventative maintenance program; conduct inspections; oversees good
housekeeping and best management practices outside ofplant; spill res once; assist in
plan development.
Member Name:
Duane Stratton
Title:
Office Phone:
336-725-1331 ext. 317
Responsibilities:
Conduct inspections; spill response; assist in developing plan elements.
Member Name:
Walter Dyson
Title:
Office Phone:
336-725-1331 ext.261
Responsibilities:
Conduct inspections; spill response; assist in devcloping plan elements.
Member Name:
David A. Spencer
Title:
Office Phone:
336-725-1331 ext. 254
Responsibilities:
Conduct inspections; s ill response; assist in developing plan elements.
Member Name:
Freddie Green
Title:
Office Phone:
336-725-1331 ext. 261
Responsibilities:
Manage hazardous materials throughout facility.
PIEDMONT GEOLOGIC. P. C.

DEVELOPING A SITE MAP
Site: Kaba Ilco, Winston-Salem Facility Worksheet I#2
Address: 2941 Indiana Avenue Updated by: Waseem Kunbargi
Forsyth County Title: Consultant
Winston-Salem, North Carolina Date: 3/15/2010
Instructions: Draw a map of your site including a footprint of all buildings, structures, paved areas, and
parking lots. The information below describes additional elements required by EPA's General
Permit.
EPA's General Permit requires that you indicate the following features on your site map:
- All outfalls and stormwater discharges.
- Drainage areas (with percentage of impervious cover) of each stormwater outfall.
- Structural stormwater pollution control measures, such as:
- Flow diversion structures.
- Retention/detention ponds.
- Vegetative swales.
- Sediment traps.
- Name of receiving water (or if through a Municipal Separate Storm Sewer System.
- Locations of significant exposed materials.
- Locations of past spills and leaks.
Locations of high -risk, waste -generating areas and activities common on industrial sites, such as.,
- Fueling stations.
- Vehicle/equipment washing and maintenance areas.
- Area for unloading/loading materials.
- Aboveground tanks for liquid storage.
- Industrial waste management areas (landfills, waste piles, treatment plants, disposal areas).
- Outside storage areas for raw materials, by-products, and finished products.
- Outside manufacturing areas.
- Other areas of concern
1 PIEDMONT GEOLOGIC, P.C.

M m m m r =r = M o w M air r m M M=,=
Worksheet #3
MATERIAL INVENTORY
Updated by: Waseem Kunbargi
Title: Consultant
Date: 3/15/2010
Instructions: List all materials used, stored, or produced on -site. Assess and evaluate these materials for their potential to contribute pollutants
to stormwater runoff. Also complete Worksheet 3A if the material has been exposed during the Iast three years.
Quantity
Quantity Exposed in
Likelyhood of Contact with
Past Significant
Material
Purpose/Location
Last Three Years
Stormwater. Describe
Spill or Leak
Used
Produced
Stored
Yes
No
Cyanide
Electroplating
Only in the event of major spill coupled
Wastewater
Solution
15,000 gat
none
with dike failure,
X
Metal
Electroplating
Only in the event of major spill coupled
Wastewater
Solution
15,000 gal
none
with dike failure.
X
Cutting
Oils
Used in stamping
55 gal
none
None; dumpstets now covered.
X
Stoddard
Paint
SaNcut
Supplies
55 gal
none
Only in material handling incidents.
X
Xylene
Paint Supplies
55 gal
none
Only in material handling incidents.
X
Aliphatic
Paint
Distillates
Supplies
55 gal
none
Only in material handling incidents.
X
Hydraulic
Only in the event of major spill coupled with
Oil
Used in Machinery
55 gal
none
dike failure; trace possible in stored equip.
X
Aluminum
Flocculating
Salts
Agents
55 gal
[tone
None; stored inside.
X
HCi1
Wastewater
H,SOa
Treatment
55 gal
none
None, stored inside.
X

r M M W M M M M M" M M M M W r= i r
EXPOSED MATERIALS
Warksheet #3a
Updated by: Waseem Kunbargi
Title: Consultant
Date: 3/15/2010
Instructions: Based on your material inventory, describe the significant materials that were exposed to stormwater during the past three years
and/or are currently exposed.
Description of
Exposed Material
Period of
Exposure
Quantity
Ex osed
Location (as indicated
on the site ma
Method of Storage or Disposal
e.. pile drum, tank
Description of Material Management Practice
e.. pile covered, drum sealed
Old Equipment
Machinery
15 months
n/a
Southern Portion of site,
On Concrete Pad
Partially covered with plastic sheeting and tarps.
Removed from site in July 2008.
Wood Pallets
3 years
n/a
Northwestern and central portion
of site.
On pavement
Periodically stacked along sides of buildings,
Scrap metal
3 years
n/a
Central portion of site.
Inside open -top dum ster
Periodically removed from site by private
contractor.

M M M M M M r r s M M M M M M�® M ■r
SIGNIFICANT SPILL AND LEAKS
Worksheet #4
Updated by: Waseem Kunbargi
Title: Consultant
Date: 3/15/2010
instructions: Record below all significant spills and leaks of toxic or hazardous pollutants that have occurred at the facility in the past three years
prior to the effective date of the permit. Significant spills and leaks incluse, but are not limited to, releases of oil or hazardous
substances in excess of reportable quantities.
1st Year Prior
Date
(month/day/year)
Spill
Leak
Location
Description
Res onse Procedures
Preventative
Measures
Taken
Material
Quantity
Source
Reason
Amount
Recovered
Still
Exposed
NONE
2nd Year Prior
Date
(month/day/year)
Spill
Leak
Location
Descrition
Res onse Procedures
Preventative
Measures
Taken
Material
Quantity
Source
Reason
Amount
Recovered
Still
Exposed
NONE
3rd Year Prior
Date
(month/day/year)
Spill
Leak
Location
Description
Res onse Procedures
Preventative
Measures
Taken
Material
Quantity
Source
Reason
Amount
Recovered
Still
Exposed
NONE

= M M M o M M M M M M M M M o ■o M M M
Worksheet #5
NON-STORMWATER DISCHARGE
Updated by: Waseem Kunbargi
ASSESSMENT AND CERTIFICATION
Title: Consultant
Date: 3/ 15/2010
Date of Test
Outfall Directly Observed
Method Used to Test
Describe Results
Identify Potential
Name of Person Who
or
During the Test
or Evaluate Discharge
from Test
Significant Sources
Conducted Test or Evaluation
Evaluation
3/15/2010
Outfall B
Visual Observation
No non-stormwater dishcharges
None
Waseem Kunbargi
Outfall C
observed.
Ed Lodies
Edwin Smith
David Stewart
CERTIFICATION
f, (responsible corporate official), certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief,
true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowinp violations -
Name & Official Title (type or print)
Area Code and Telephone No.
2 Z p p t C .s C) p e7l?4 OIJ S
3 3 6
Signature
Date Signed
r a

M M M M M M M M M o M= M M W r o i M
NON-STORMWATER DISCHARGE
ASSESSMENT AND FAILURE TO CERTIFY
NOTIFICATION
Workshect #b
Updated by. W suKunbargi
Title: ConsultUpdated ant
Date: 3/15/2010
Directions: If you cannot feasibly test or evaluate an outfall, fill in the table below with the appropriate information and sign this form to certify the accuracy of
the included information. List all outfalls not tested or evaluated, describe any potential sources of non-stormwater pollution form listed outfalls,
and state the reason(s) why certification is not possible. Use the key from your site map to identify each outfall.
Important: A copy of this notification must be signed and submitted to the Director within 180 days of the effective date of this permit.
Identify Outfall Not
Tested/Evaluated
Description of Why Certification
is Infeasible
Description of Potential Sources of Non-Stormwater Pollution
CERTIFICATION
I certify under penalty of law that this document and all attachments were prepared under my direction and supervision in accordance with a system designed to ensure
that yuilified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief. true, accurate, and complete. I am aware that
there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations, and the such notification has
been made to the Director within 180 days of (date permit was issued), the effective date of this permit.
Name & Official Title (type or print)
Area Code and Telephone No.
Signature
Date Signed

= r M r M= r M= M M= 0 i= r M= M
POLLUTANT SOURCE IDENTIFICATION
Worksheet #7
Updated by: Waseem Kunbargi
Title: Consultant
Date: 3/15/2010
Directions: List all identified stormwater pollutant sources and describe existing management practices that address those sources. List Best Management
Practices in the third column that can be incorporated into the plan to address remaining sources of pollutants.
S tormwater Pollutant
Source
Existing Management Practices
Description of New Best Management Practices
Old Equipment Stored
Outside
Removed from site in July 2008.
Not applicable
Wood Pallets i
Periodically stacked along sides of buildings.
Construct permanent cover for storage.
Scra2 metal
Contained in open -top dum ster.
Construct pennnent cover for stora e.

M M M r= M= M= M M = " = M r M M M
Worksheet #7a
BEST MANAGEMENT PRACTICES
Updated by: Waseem Kunbargi
IDENTIFICATION
Title: Consultant
Date: 3/15/2010
Directions: Describe the Best Management Practices that you have selected to include in your plan. For each of the baseline Best Management Practices
describe actions that will be incorporated into facility operations. Also, describe any additional Best Management Practices that you have selected.
Best Management
Brief Description Of Activities
Practice
Good Housekeeping.
Keep hazardous materials and hazardous wastes ni separate bays of the hazardous materials storage building. Keep dumpsters
under permanent cover.
Preventative Maintenance
Insure dikes are in working order.
Inspections
Continue inspection schedule.
Spill Prevention Response
Follow contingency plan.
Sediment and Erosion Control
Observe outfalls during normal operations to insure no erosion/sedimentation is present.
Management of Runoff
Observe stormwater flow during rain event to insure all areas drained to outfalls.
Additional Best Management
Practices

M M M M M M M M 0 M M M M M M M i M M
Worksheet #S
IMPLEMENTATION
Completed by: Waseem Kunbargi
Title: Consultant
Aate: 3/15/2010
Directions: Develop a schedule for implementation of Best Management Practices. Provide a brief description of each, the steps necessary for implementation,
schedule for completion., and persons responsible for implementation.
Best Management
Actions Required for Implementation
Completion
Responsible
Notes
Practice
Schedule
Person
Good Housekeeping
Maintain handling and storage of hazardous waste and materials.
Ongoing
Ed
Edwin Smith - Hazardous Waste
Lodics
Tammy Jones - Hazardous Mat.
Preventative Maintenance
Continued upkeep on secondary containment dikes.
Ongoing
David
Stewart
Inspections
Continued inspection routine.
Ongoing
David
Stewart
Spill Prevention Response
Follow contingency plan
Ongoing
Edwin
Smith
Sediment and Erosion Control
Follow SPPP.
Ongoing
Management of Runoff
Follow SPPP.
Ongoing
Ed
Lodics
Additional Best Management
Practices

M M = = = i M 0 M= M ® = = = M M M
EMPLOYEE TRAINING
Worksheet #9
Updated by: Waseem Kunbargi
Title; Consultant
Date: 3/15/2010
Directions: Describe the employee training program for your facility. The program should address spill prevention and response, good housekeeping, and
material management practices. Provide a schedule for the training program and list the employees who attend training sessions.
Training Topics
Description of Training
Schedule for Taining
Attendees
Spill prevention and response
Recertification through OSHA HA,ZWOPER refresher
Annually
Pollution Prevention Team
Good Housekeeping
Part of annual ISO Certification
Annually
Pollution Prevention Team
Material Management
Practices
Reviewed Annually
Anually
Pollution Prevention Team

APPENDIX G
PHOTOGRAPHS
1 PIEDMONT GEOI 0GIG P.C.

Containment Dices
Covered Dumpster

Hazardous Waste Storage
Loading Bays (west)
I

;4t
-70,-
Von
wor
Me
dd
IM4
OL

-41

w' -
Stamping Scrap Metal Area
Chemical Storage Room (east side)

1
1
Chemical Storage Room (west side)
Loading Bay Area (south)
1

Undeveloped Land (Former Old Equipment Storage)
7
11
1
1