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NCG090028_COMPLETE FILE - HISTORICAL_20180124
STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. I /V C& ag DOC TYPE 1 9 HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ Allow MMDD aot of a� Lyl ��. Division of Energy, Mineral & Land Resources Land Quality Section/Stormwater Permitting NC®ENR National Pollutant Discharge Elimination System .N�R— Enwpw..errr wo N.ruia.i R�ce+ PERMIT NAME/OWNERSHIP CHANGE FORM FOR AGENCY USE ONLY Date Received Year Month Da I. Please enter the permit number for which the change is requested. NPDES Permit (or) Certificate of Coverage N G 5 6 N ,C•, G (Q II. Permit status rp for to requested change. /] a. Permit issued to (company name): Yt a,n ea,°S'ws Lo{ b. Person legally responsible for permit Nov go Nil 11 �R' �, y 5C0p�Ylau;►��s tTUNG c. Facility name (discharge) d. Facility address: e. Facility contact person: iG t as. First M I Last Title Permit Holder Mailing Address mac- City State Zip ( 9/0 ) 3 7 / - 318Y ( 9/o ) Y7 5s7a Phone .. F�./_�.� 00 7tt%] Q. S C vt o� /TG Y I es TyeS (_ o � ✓� / D/ Pd/2"Ar SF /tfz_:� ! Address ,1-e1a�c/ c City State Zip Fa'l ) 37/ 3/8A1 First / MI / Last Phone III. Please provide the following for the requested change (revised permit). I a. Request for change is a result of: ❑ Change in ownership of the facility ❑ Name change of the facility or owner If other please explain: �� ,y� moo,,, �� �t y ti•L b. Permit issued to (company ngme): �— c. Person legally responsible for permit: i a'e_ First M I Last Title Permit Holder Mailing Address City State Zip { ) RiGk/0— t" r- C 0 4 b b S S . C 04A_ Phone E-mail Address d. Facility name (discharge): e. Facility address: Address City State Zip f. Facility contact person: Mo► r-•j- r First MI Last -{ --�- - M . Fat t (�D _ r 4 Coa Phone E-mail Address IV. Permit contact information (if different from the person legally responsible for the permit) Revised Jan. 27, 2014 NPDES PERMIT NAME/OWNERSHIP CHANGE FORM Page 2 of 2 Permit contact: Mao - First MI Last Title �^Mc 4-S 2t :0e'— Mailing Address City State Zip Phone E-mail Address V. Will the permitted facility continue to conduct the same industrial activities conducted prior to th' ownership or name change? ER Yes ❑ No (please explain) VI Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE INCOMPLETE OR MISSING: ❑ This completed application is required for both name change and/or ownership change requests. ❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill of sale) is required for an ownership change request. Articles of incorporation are not sufficient for an ownership change. ...................................................................................................................... The certifications below must be completed and signed by both the permit holder prior to the change, and the new applicant in the case of an ownership change request. For a name change request, the signed Applicant's Certification is sufficient. PFMITTEE CERTIFICATION (Permit holder prior to ownership change): I, attest that this application for a name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. i understand that if all required parts of this application are not completed and that if all required supporting information is not included, this application package will be retu ed a 'comp t -12 Signature Date APPLICANT CERTIFICATION 1, , attest that this application for a name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information is not included, this application package will be returned as incomplete. Signature Date PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO: Division of Energy, Mineral and Land Resources Stormwater Permitting Program 1612 Mail Service Center Raleigh, North Carolina 27699-1612 Revised Jan. 27, 2014 WILLIAMS MULLEN Direct Diah 919.981.4312 LNG G pa ssullivan@williamsmullen.com AS�p P`N� June 10, 2013 �ti`�,� �P il RY EMAIL — ORIGINAL .BYFIRST CLASS MAIL Mitch Gillespie Assistant Secretary for the Environment North Carolina Department of Environment and Natural Resources 1601 Mail Service Center Raleigh, NO 27699. Re; Coatings & Adhesives Corporation -- Disclosure of Results of Environmental Audit Dear Mr. Gillespie: As you know, this firm represents Coatings & Adhesives Corporation' ("C&A" or the "Company'). In accordance with the April 24, 2013 audit agreement between C&A and the North Carolina Department of Environment and Natural Resources ("DENR" ), the" Company hereby notifies DENR of the following potential violations identified by URS Corporation. CURS") atits facility located at 1901 Popular Street, N.E_ in Leland, North Carolina (the "Facility") during URS's audit of the Facility on May 7 and 8, 2013. C&A's actions to correct each issue, or its proposed date to complete corrective actions, are below each regulatory finding. 1. The Facility does,not have a preventative maintenance plan for its generator and does not have a system to track the generator's hours of operation in emergency -and non -emergency generator status. o C&A has already established, a preventative maintenance plan for its generator and is now maintaining records of the generator's emergency and non -emergency operation. 2. The Facility's Storm Water Pollution Prevention Plan ("SWPPP") requires updating, and it ,appears that the Facility has not satisfied the requirements'of DENR Division of Water Quality Permit Number NCG090028j.!art H.A regarding sampling, site inspections, annual reviews, nori `stormwater discharge' certifications and training. 301 Fayetteville Street, Suite 1700 (27601) P.O. Sox 1000 Raleigh, NC 27602 T 919.981,4000 F 919:981.4300 williamsmuilen.com DC NC VA } A Professional Corporation ' WILLIAMS MULLEN June 10, 2013 Page 2 o . C&A, with assistance from URS, will finish updating its SWPPP by July 15, 2013. The Company has designated Mr. Matthew Fail as the person responsible for ensuring that 'all sampling, inspection, plan review, certifications and training requirements are met going forward. C&A will submit its next semiannual sampling results by June 28, 2013. 3. Two sump pumps at the Facility were set to turn on automatically and pump storm water to a drainage ditch without prior inspection of the water. o The Company has already reset the sump pumps to manual mode and now performs an inspection before releasing storm water in the sumps to the drainage ditch. 4. URS observed boiler condensate and reverse osmosis rejects discharging through a storm water outfall. o C&A is containerizing boiler condensate and reverse, osmosis rejects until it completes construction of piping to convey this water to the Facility's sanitary sewer discharge. Construction of the new piping is ongoing and will be complete by June 21, 2013. 5. URS observed spent fluorescent light bulbs that were not in a closed, labeled and dated container. o The Company has already corrected this condition and instructed employees in the spent fluorescent bulb storage area regarding proper management of these materials. 6. Two of the Facility's hazardous,waste profiles were not available: o C&A has requested the missing profiles from its hazardous waste disposal vendor — Giant Resource Recovery. 7. URS obseryed a 5-gallon container in a satellite accumulation area for hazardous waste within the Facility's Quality Control ("QC") laboratory that was not labeled: C.o. The Company has already corrected this condition and instructed employees in the' QC laboratory regarding. proper labeling of containers in the satellite accumulation area. WILLIAMS MULLEN June 10, 2013 Page 3 8. Land disposal restriction records for some of the Facility's hazardous waste manifests were unavailable. o C&A has requested the missing records from its hazardous waste disposal vendor -- Giant Resource Recovery, 9. The Facility's hazardous waste training records were unavailable. o The Company proposes to complete hazardous waste training for appropriate employees by J«ly 19, 2013, and Mr. Matthew Fail will be responsible for maintaining those records going forward. 10. URS observed a drum containing used oil that was not closed. o The Company has already corrected this condition and instructed employees handling used oil regarding theneed to keep used oil containers closed except when adding or removing such oil from a container. 11. The Facility's Spill Prevention Control and Countermeasures Plan ("SPCC Plan")does not include all containers of oil at the Facility that are greater than 55 gallons in size. o Prior to the URS audit, C&A had already planned to update its SPCC Plan by August 1.6, 2013 and proposes to address this issue as part of its previously scheduled SPCC Plan update. 12. The Facility's SPCC Plan training 'records were unavailable. and o The Company proposes tb complete training regarding the updated SPCC Plan by August 30, 2013, 1S. The Facility's SPCC Plan inspection records were unavailable. o Mr. Matthew Fail will be responsible for maintaining SPCC Plan inspection records .going forward. Yl. Finally,.as.,you know; C&A received a Notice of Deficiency,from the Division of Water Quality. ("DWQ") regarding industrial"stormwater discharges and it received an information request from the, Division of Air Quality ("DAQ") regarding: ' - WILLIAMS M U L.L.E N June 10, 2013 Page 4 (1) the potential for the Facility to cause objectionable odors on neighboring properties; and (2) whether the Facility is eligible for the exemption from the requirement to have an air emissions,permit codified in 15A N.C.A.C. 02Q.0102(c)(2)(E)(ii). The Company believes that its revised SWPPP will address DWQ's concerns regarding industrial stormwater discharges from the Facility and proposes to follow up directly with Mr. Jim Gregson when the update is complete, i.e., by June 30, 2013. Regarding DAQ's information -request, C&A has submitted an odor assessment prepared by URS to -Mr. Brad N'ewiand and has recently responded to a series of follow up questions posed by DAQ. In addition, URS has completed an assessment of the Facility's air emissions and determined that C&A's emissions of air pollutants are below the exemption thresholds in 15A N.C.A.C. 02Q.0102(c)(2)(E)(ii). The Company proposes to provide this assessment to DAQ by June 30, 2013 as the next step in responding to the information request. Please let we know if C&A's proposed schedule to complete corrective actions and respond to DWQ's and DAQ's pending -inquiries is acceptable or if 1 can provide you with any additional information regarding the foregoing. Thank you again for your assistance with this matter. Sincerely, Sean M. Sul ivan cc; Jay -Osborne, Esq., DENR ... Jim Gregson, DWQ Brad Newland, DAQ Rick Pasin, C&A April 23, 2013 Sean Sullivan, Esq. 301 Fayetteville Street Suite 1700 Raleigh, NC 27601 BY FIRST CLASS MAIL AND ELECTRONIC DELIVERY Re: Response for Proposal for Audit Agreement between Coatings and Adhesives, Inc. and DENR Dear Mr. Sullivan: This letter responds to your letter dated April 23, 2013, in which you outline a proposal for an audit agreement between Coatings and Adhesives, Inc. ("C&A") and the North Carolina Department of Environment and Natural Resources ("NCDENR"), and in which you request NCDENR's approval of your proposal. Subject to the following understandings, your proposal is acceptable to NCDENR. As you are aware, NCDENR has enacted the enclosed Enforcement Penalty Policy for Self -Reported Violations ("policy"). All terms of this policy, including provisions which limit the application of the policy, will apply to the proposed audit and actions taken pursuant to the audit. As addressed in Sections III and IV of your proposal, C&A will disclose any potential violation(s) of environmental laws identified through the audit. NCDENR and C&A will then meet to discuss outstanding issues, remedies and priorities for corrective action. As addressed by Section D of the policy, C&A will have the burden to prove eligibility for application of the policy. NCDENR's determination of the scope of the application of this policy can be made only after it has reviewed the results of the audit and has met with C&A to discuss those results. Also, C&A has proposed to complete its audit within 45 days of finalizing an audit agreement. Based on the reasons you have presented, NCDENR accepts this timeframe subject to the following understanding. First, C&A must immediately address, in the manner required by applicable state and federal law, violations causing significant harm to the environment or risk to public health. Such violations are excluded from protection by Section A.3 of the policy and require immediate response. Second, Section A.5 of the policy requires, among other things, that C&A cease or remediate any continuing violation upon discovery of the deficiency. While C&A will complete its audit within 45 days of finalizing an audit agreement, C&A still is required to address deficiencies as they are discovered, in the manner and timeframe normally required by NCDENR. As you have mentioned in your letter, C&A is not yet certain of the amount of corrective action that will be required at the site. if you find that, based upon your audit, that the amount of necessary corrective action at the site is such that it is difficult to comply with NCDENR's normal timeframes, please contact me to establish a schedule for response that is acceptable to NCDENR under Section A.5 of the policy. Subject to the terms of this letter, NCDENR accepts your proposal and considers the audit agreement between C&A and NCDENR finalized as of the date of this letter. Please confirm with me that you are in agreement. If you have any questions or wish, to further discuss, please contact me. Sincerely, Mitch Gillespie Assistant Secretary for the Environment North Carolina Department of Environment and Natural Resources Enclosure WILLIAMS M U LLE N Direct Dial: 919.981.4312 ssullivan@wilhamsmuLlen.com April 23, 2013 BY FIRST CLASS MAIL Mitch Gillespie Assistant Secretary for the Environment North Carolina Department of Environment and Natural Resources 1601 Mail Service Center Raleigh, NC 27699 Re; Proposal for Audit _Agreement between Coatings and Adhesives, Inc. and NCDENR Dear Mr. Gillespie: As you will recall, on March 25, 2013, Rick Zechini and I met with you to discuss the potential for our client, Coatings and Adhesives, Inc. ("C&A" or the "Company"), to enter into an audit agreement with the North Carolina Department of Environment and Natural Resources ("DENR") regarding C&A's facility located at 1901 Popular Street, N.E. in Leland, North Carolina (the "Facility"). This agreement would provide a mechanism by which C&A could perform a comprehensive environmental compliance audit of the Facility, disclose any potential violations identified thereby to DENR and correct those issues under the auspices of DENR's July 10, 2000 Enforcement Policy for Self -Reported Violations (the "DENR Audit Policy"). The Company's proposed approach for such an agreement — including deadlines to complete the audit and make disclosures to DENR — is below. I. Summary of the,C&A Proposal In brief, C&A proposes to engage URS Corporation ("URS") to complete an assessment of the Facility's compliance with applicable environmental laws and disclose the results of the assessment to DENR, within 45 days of finalizing an audit agreement. The assessment would focus on state and federal environmental regulations, as described below, and it would collect other information to support C&A's development of an environmental management system ("EMS"). Following the Company's disclosure of any potential violations identified through the audit, C&A would meet with DENR to discuss those issues and develop a schedule for completing any required corrective actions. 301 Fayetteville Street, Suite 1700 (27601) P.O. Box 1000 Raleigh, NC 27602 T 919.981.4000 F 919.981,4300 wiEiiamsmullen.com DC NC VA I A Professional Corporation WILLIAMS M U LLE N April 23, 2013 Page 2 H. Subiect Matter Covered and Related Matters Involving DENR C&A's comprehensive environmental compliance assessment will focus on all applicable federal and state environmental programs, including the following: • The Clean Air Act (permitting, hazardous air pollutant emissions, ozone depleting substances and risk management planning); • The Clean Water Act (stormwater, wastewater and Spill Prevention Control and Countermeasures planning); • The Resource Conservation and Recovery -Act (solid waste, hazardous waste and underground storage tanks); • The Emergency Planning and Community Right to Know Act (Tier I and Tier II reporting as well as Toxic Release Inventory reporting); • The Toxic Substances Control Act; and • The North Carolina Coastal Area Management Act. During the course of the assessment, C&A may also evaluate other issues and, therefore, proposes that this agreement apply equally to any other potential violations of environmental laws that URS may identify. On April 5, 2013, the Company requested a thirty day extension of the deadline to respond to the Division of Water Quality's ("DWQ") March 6, 2013 Notice of Deficiency (the "NOD") regarding the Facility, and on April 17, 2013 it requested a thirty day extension of the deadline to respond to the Division of Air Quality's ("DAQ") March 19, 2013 information request (the "Information Request"). C&A believes that the information developed by URS during the audit will be helpful in responding to these items and proposes to reset the response deadline for both once the Company has the benefit of URS's audit report regarding the Facility. III. Time to Complete the Assessment C&A proposes that, within five days of entering into an audit agreement with DENR, the Company will formally engage URS to conduct the audit. URS will complete its visits to the facility within 15 days of the date of the agreement, and C&A will disclose any potential violations of environmental laws identified through WILLIAMS MULLEN April 23, 2013 Page 3 the audit within 45 days of the audit agreement.' This schedule will afford the Company sufficient time to ensure that the assessment is complete and to vet URS's conclusions before the disclosure deadline. IV. Time to Complete Correctiyo_Action Given the uncertainty as to the outcome of the compliance assessment and the current lack of information to make a reasoned projection of the time needed to take corrective action, C&A proposes that, after DENR receives C&A's disclosures regarding the findings of the audit, C&A and DENR meet to discuss all outstanding issues; potential remedies that would be acceptable to DENR, and how best to prioritize the'corrective action necessary to ensure compliance with all state and federal regulations. The Company proposes that this meeting be held as soon as practicable after DENR has been able to review the report of findings. Prior to finalizing the schedule for corrective action, C&A will take reasonable steps to: (1) address any ongoing potential violations and (2) avoid additional potential violations. V, Application of the DENR Audit Policy to C&A and Coo_r_"tion with EPA As you know, the DENR Audit Policy does not specify a certain number of days for a regulated entity to disclose potential violations to DENR or to complete any related corrective actions. Rather, it simply requires "prompt" disclosure and provides the disclosing party with the opportunity to come to a written agreement with DENR regarding the steps -to correct any deficiencies identified during an audit. I believe the proposed structure for this agreement is consistent with these requirements. In order to prevent any future violations, C&A will develop an Environmental Management System for the Facility that insures compliance with all applicable regulations. Regarding the other criteria for penalty mitigation under the DENR Audit Policy, C&A proposes to complete the audit and any subsequent corrective actions first and to discuss the applicability of the other criteria to any potential violations once that process is. complete. To the extent the audit identifies potential violations of regulatory programs for which EPA has not delegated its enforcement authority to DENR, C&A will disclose any such issues to EPA in accordance with the agency's audit policy and seek to coordinate the deadlines for related corrective action with the schedule for any corrective action required for matters that C&A has disclosed to DENR. t In the event that C&A identifies any conditions presenting an imminent and substantial endangerment to human health or the environment, the Company will take immediate action to abate those conditions as soon as practicable. 4 WILLIAMS M U LLE N April 23, 2013 Page,4' Thank you again for your willingness to work with C&A to ensure that the Facility is — and remains — in compliance with environmental laws. Please feel free to contact me at (919) 981-4312 if I can provide you with any additional information in the interim. cc: - Rick Pasin, C&A Jay Osborne, Esq., NC DENR Sincerely, Sean M. Sullivan WILLIAMS M U LLE N Direct Dial; 919,981.4312 ssullivanGwilliainsmtrllen.com April 4, 2013 BY EMAIL — ORIGINAL BY FIRST CLASS MAIL Jim Gregson Surface Water Protection Supervisor N.C. DENR Wilmington Regional Office 127 Cardinal Drive Extension Wilmington, NC 28405 Re: Coatings and Adhesives Corporation Notice of Deficiency_ Dear Mr. Gregson: As we discussed earlier today, this firm represents Coatings and Adhesives Corporation ("C&A" or the "Company"). I am in receipt of the Division of Water Quality's March 6, 2013 Notice of Deficiency (the "NOD") regarding C&A's facility l6cated�at 1901 Populai'Street, N:E: in Leland, North Carolina (the "Facility"). The Company has retained URS Corporation ("URS") to address the matters identified in the NOD, beginning with an update of the Facility's Storm Water Pollution Prevention Plan, which is already underway. In addition, C&A is in the process of negotiating a comprehensive audit agreement with the North Carolina Department of Environment and Natural Resources ("DENR") regarding the Facility, which will include a schedule for: (i) performing an environmental audit of the Company's operations; (ii) disclosing any potential compliance issues to DENR; and (ill) developing a timeline for correcting any potential violations identified through the audit. C&A believes it will be more efficient to determine the deadline for completing NOD -related work at the same time that the Company and DENR determine the deadline for completing corrective actions regarding any potential violations identified through the audit. Therefore, the Company is requesting a thirty (30) clay extension of the deadline to respond to the NOD, with the understanding that this deadline may change as a result of the final terms of the audit agreement between C&A and DENR. ECERV APR 0 8 2013 • BY: __ 301 Fayetteville Street, Suite 1700 (27601) 11,0. Box 1000 Raleigh, NC 27602 T 919.981.4000 V 919,981.4300 Willi amsmullen.com DC NC VA I A Professional Corporation WILLIAMS M U LLEN April 4, 2013 Page 2 In the interim, please feel free to contact me at (919) 981-4312 if I can -provide you with any additional information. Sincerely, *- Sean M. Sullivan cc: Rick Pasin, C&A Jay Osborne, Esq., NC DENR W Postal Servicen., i CERTIFIEDU.S. + RECEIPT ' ro (DonteoicOnly;CoverageI 1 " N r � - OFFICIAL e USE m �m co r Postage $ � m CertlNed Fee O t O Relum Aecelpt Fee (Endomement Required]co Postmark Horses/ 0 Restricted Delivery Fes (Endorsement Requlnad) D Er i M Total Postage & Fees $ 1�0 • I! IC3 r% / �-- - Zmjw � �`- Apt. N717u.; or PO BGX o, ,--- .... ................................................ City. te, Z1P+4 P�i Form r, ■ Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. ■ Print your name and address on the reverse so that we ;an return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. Article Addressed to: C, fig, �, •,� 5 �,•- �/i�'S id�5 A. DA delivery address different from i m 1? ❑ Yes If YES, enter delivery address ow: ❑ No S. Service Type �rtified Mail ❑ dress Mail ❑ Registered ❑ Return Receipt for Merchandise ❑ Insured Mail ❑ C.O.D. a. Restricted Delivery? {Extra Fee) ❑ Yes 2. Article Number - - -- (iransferfromservicelabeO 7010' 0290 0003 0833 8789 i PS Form 3811, February 2004 Domestic Return Receipt 102585-02-M-1540 UNITED Az�vRSP MCL ;�-R �!�XJNA • Sender: Please print your name, address, and ZIP+4Jr fhis box NC DEN • DIV Is10N OF WATER QUALITY SURFACE WATER PROTECTION SECTION 127 CARDINAL DRIVE EXTENSION WILMINGTON, NC 28405 D. E� Its11,111 NC®ENR North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Charles Wakild, P.E. Governor Director March 6, 2013 CERTIFIED MAIL # 7010 0290 0003 0833 8789 RETURN RECEIPT REQUESTED Richard Pasin, President Coatings and Adhesives Corporation PO Box 1080 Leland, NC 28451-1080 Subject: NOTICE OF DEFICIENCY Tracking No. NOD-2013-PC-0108 NPDES Compliance Evaluation Inspection NPDES General Stormwater Permit No. NCG090028 Coatings and Adhesives Corp - Leland Brunswick County Dear Mr Pasin: John E. Skvarla, III Secretary A Compliance Evaluation inspection of the Coatings and Adhesives Corp - Leland was conducted by Dean Hun kele from this office on February 15, 2013. This inspection was to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES Permit No. NCG090028. The findings and comments noted during this inspection are provided in the enclosed copy of the Compliance Inspection Report. The following deficient items or issues were noted during the inspection: Compliance Issues No site or outfall monitoring data available No documentation of outfall inspections The Stormwater Pollution Prevention Plan has not been implemented, reviewed at least annually, nor updated as necessary. No site map is available and no outfalls are marked on the property. Wilmington Regional Office 127 Cardinal Drive Extension Wilmington, NC 28405 Phone: 910-796-7215 / FAX; 910-350-2004 Internet: www.ncwaterguality.ore North Carolina Naturally An Equal Opportunity/Affirmative Action Employer 50% Recycled/10% Post Consumer Paper !J NOD-2013-PC-0108 NCG090028 ? March 6, 2013 Page 2 of 2 Remedial actions should have already been initiated to correct these problems and prevent further occurrences in the future. The Division of Water Quality may pursue enforcement action forthis and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of noncompliance to prevent the recurrence of similar situations. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Deficiency regarding your plans or measures to be taken to address the indicated compliance issues including a timetable for implementation or completion. If you have any questions concerning this Notice of Violation or the enclosed inspection report, you may contact Dean Hunkele at the letterhead contact information or via email at Dean.Hunkele@ncdenr.gov. Sincerely, t Jim 7Gregison, Regional Supervisor Surface Water Protection Section Wilmington Regional Office Enclosure Cc: Wilmington Regional Office File — Permit Type by County Central Files, Surface Water Protection Section Permit: NCGO90028 SOC: County: Brunswick Region: Wilmington Compliance Inspection Report Effective: 12/12/12 Expiration: 10/31/17 Owner: Coatings and Adhesives Corporation Effective: Expiration: Facility: Coatings and Adhesives Corp - Leland 1901 Popular St NE Contact Person: Richard Pasin Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): 24 hour contact name Matt Fail On -site representative Matt Fail Related Permits: Title: President Certification: Leland NC 28451 Phone: 910-371-3184 Phone: Phone: 910-371-3184 Phone: 910-371-3184 Inspection Date: 02115/2013 Entry Time: 11:05 AM Exit Time: 12:40 PM Primary Inspector: Ins Dean A Hunkele p j`. _ t\1�_ Phone: 910-796-7215 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Paints, Varnishes, Lacquers Stormwater Discharge COC Facility Status: ❑ Compliant ® Not Compliant Question Areas: ® Storm Water (See attachment summary) Page: 1 Permit: NCGO90028 Owner - Facility: Coatings and Adhesives Corporation Inspection Date: 02/15/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: This was an unannounced visit following a complaint notification from the County health department. This facility or site was originally covered under NCG090015 issued in 10-1993 and was rescinded in 5-2004 due to failure to request renewal by the Permittee. The facility became covered again in 3-2009 under this number, thus a lack of coverage existed for nearly 5 years even though current staff indicated the facility has never closed down. Considering the facility was covered before and has been covered for 4 years now since the apparent lapse in coverage, it is very disappointing to find such non-compliance with the permit. Mr. Fail was very forthcoming and indicated the EHS Manager had left in 4-2012 and not been replaced. Since no record of any previous inspection exists, only a Notice of Deficiency is being issued which will require a written response with a plan -of -action and timetable for completion. Page: 2 Permit: NCGO90028 Owner - Facility: Coatings and Adhesives Corporation Inspection Date: 02/15/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? # Does the Plan include a General Location (USGS) map? # Does the Plan include a "Narrative Description of Practices"? # Does the Plan include a detailed site map including outfail locations and drainage areas? # Does the Plan include a list of significant spills occurring during the past 3 years? # Has the facility evaluated feasible alternatives to current practices? # Does the facility provide all necessary secondary containment? # Does the Plan include a BMP summary? # Does the Plan include a Spill Prevention and Response Plan (SPRP)? # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? # Does the facility provide and document Employee Training? # Does the Plan include a list of Responsible Party(s)? # Is the Plan reviewed and updated annually? # Does the Plan include a Stormwater Facility Inspection Program? Has the Stormwater Pollution Prevention Plan been implemented? Comment: The SPPP that could be located was written in 2009 following the previous re -issuance of this permit for the site in 3-2009 and has not been reviewed or updated since as some production practices have changed. No site map is available and no outfalls are marked on the property. The old Plan hints at only 2 outfalls to be monitored, but more than that exists on the site; thus assume the writer was thinking of them as being representative outfalls of the site. Representative Outfall Status must be requested via the Regional Office and approved in writing -- it generally requires 1-2 years worth of monitoring data to be available to coincide with a site inspection. The site has a lot of "raw" chemical product containers (both empty & full) onsite and waste product being stored in old "raw" containers -- all are exposed to rainfall events. Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Comment: No documentation of inspections per "current" plan. Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment: No monitoring data available ®nnn n®nn nnn■ nnn n®nn nnn® n®nn nnn® n n nnn® n■nn nnn® 0 a 0 0 n n n 53 n■nn Yes No NA NE n®nn Yes No NA NE n®nn nn®n Page: 3 Permit: NCGO90028 Owner - Facility: Coatings and Adhesives Corporation Inspection Date: 0211512013 Inspection Type: Compliance Evaluation Reason for Visit: Routine Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ® ❑ 0 n # Were all outfatls observed during the inspection? ❑ ® n n # If the facility has representative outfall status, is it properly documented by the Division? ❑ n ■ n # Has the facility evaluated all illicit (non stormwater) discharges? n n ❑ ■ Comment: Most of the outfalls were observed, but at least one other is believed to exist. All these should be marked with signage and mapped on the site plan to correspond to the SPPP whenever it is updated. Page: 4 Permit: NCG090028 SOC: County: Brunswick Region: Wilmington Compliance Inspection Report Effective: 12/12/12 Expiration: 10/31/17 Owner: Coatings and Adhesives Corporation Effective: Expiration: Facility: Coatings and Adhesives Corp - Leland 1901 Popular St NE Contact Person: Richard Pasin Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Re prose ntative(s): Title: President Certification: Leland NC 28451 Phone: 910-371-3184 Phone: 24 hour contact name Matt Fail Phone: 910-371-3184 On -site representative Matt Fail Phone: 910-371-3184 Related Permits: Inspection Date: 02115/2013 Entry Time: 11:05 AM Exit Time: 12:40 PM Primary Inspector: Dean A Hunkele Phone: 910-796-7215 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Paints, Varnishes, Lacquers Stormwater Discharge COC Facility Status: Q Compliant ■ Not Compliant Question Areas: ® Storm Water (See attachment summary) Page: 1 Permit: NCGO90028 Owner - Facility: Coatings and Adhesives Corporation Inspection Date: 02/15/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine Permit -and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # If the facility has representative outfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment: Most of the outfalls were observed, but at least one other is believed to exist. All these should be marked with signage and mapped on the site plan to correspond to the SPPP whenever it is updated. Page: 4 Permit: NCGO90028 Owner - Facllily: Coatings and Adhesives Corporation Inspection Date: 02/1512013 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? o ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ❑ 0 ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ 0 # Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ■ ❑ Cl # Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑ 0 # Does the facility provide all necessary secondary containment? ❑ ■ ❑ ❑ # Does the Plan include a BMP summary? ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑ # Does the facility provide and document Employee Training? ❑ ■ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ❑ ❑ ❑ 0 # Is the Plan reviewed and updated annually? ❑ ■ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ 0 Has the Stormwater Pollution Prevention Plan been implemented? ❑ ■ ❑ ❑ Comment: The SPPP that could be located was written in 2009 following the previous re -issuance of this permit for the site in 3-2009 and has not been reviewed or updated since as some production practices have changed. No site map is available and no outfalls are marked on the property. The old Plan hints at only 2 outfalls to be monitored, but more than that exists on the site; thus assume the writer was thinking of them as being representative outfalls of the site. Representative Outfall Status must be requested via the Regional Office and approved in writing -- it generally requires 1-2 years worth of monitoring data to be available to coincide with a site inspection. The site has a lot of "raw" chemical product containers (both empty & full) onsite and waste product being stored in old "raw" containers -- all are exposed to rainfall events. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ■ ❑ ❑ Comment: No documentation of inspections per "current' plan. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ■ ❑ Cl # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑ Comment: No monitoring data available Page: 3 Permit: NCGO90028 Owner - Facility: Coatings and Adhesives Corporation Inspection Date: 02/1512013 Inspection Type: Compliance Evaluation Reason for Visit: Rouline Inspection Summary: This was an unannounced visit following a complaint notification from the County health department This facility or site was originally covered under NCG090015 issued in 10-1993 and was rescinded in 5-2004 due to failure to request renewal by the Permittee. The facility became covered again in 3-2009 under this number, thus a lack of coverage existed for nearly 5 years even though current staff indicated the facility has never closed down. Considering the facility was covered before and has been covered for 4 years now since the apparent lapse in coverage, it is very disappointing to find such non-compliance with the permit. Mr. Fail was very forthcoming and indicated the EHS Manager had left in 4-2012 and not been replaced. Since no record of any previous inspection exists, only a Notice of Deficiency is being issued which will require a written response with a plan -of -action and timetable for completion. Page: 2 _ ma.me.m�®® HC®ENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director March 27, 2009 Mr. Richard Pasin President and Technical Director Coatings and Adhesives Corporation 1901 Popular St. NE Leland, North Carolina 28451 Subject: General Permit No. NCG090000 Coatings and Adhesives Corporation COC No. NCG090028 Brunswick. County - Dear Mr. Pasin: Dee Freeman Secretary In accordance with your application for a discharge permit received on December 17, 2008, we are forwarding herewith the subject certificate of coverage (COC) to discharge under the subject state — NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage. This permit does not -affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other federal or local governmental permit that may be required. If you have any questions concerning this permit, please contact Bill Diuguid at telephone nurnher (919) 907-6369, Sincerely, ORIGINPLSIGNED BY KEN PICKLE Coleen H. Sullins cc: .Wilmington Regional Office Central Files Storrnwater Permitting Unit Files Attachments 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury SL Raleigh, North Carolina 276D4 Phone: 919-847-#33D01 PAX: 919-807-6492 i Customer Service: 1-877.623-6748 Internet: www.ncwalerquality.org An Equal opportunity 1 Affirmative Action Employer Af R 0 1 Z009 NortCat-olina Nlltlll"allif M _ , STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG090000 CERTIFICATE OF COVERAGE No. NCG090028 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, Coatings and Adhesives Corporation is hereby authorized to discharge stormwater from a facility located at Coatings and Adhesives Corporation 1901 Popular St. NE Leland Brunswick County to receiving waters designated as Sturgeon Creek, a Class C; Sw creek to Brunswick River, Cape Fear River Basin; in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, 11, 11I, IV; V and VI of General Permit No. NCG090000, as attached. This Certificate of Coverage shall become effective March 27, 2009. This Certificate of Coverage shall remain in effect for die duration of the General Permit. Signed this day March 27, 2009. ORIGINAL SIGNED BY KEN PICKLE Coleen 11. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission s. @;r�� � r �'L � " .r�rzW�:- � � �� ^�-••_ u ! J ,�»'i. 1 �: •ti,�� •- � , t,.. ;'� ;-s��7 ri� yep g1� I� a /,' 1}411 >i; ^' '� �"'�� ,-3 r - n � .. 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County: Brunswick Coating and Adhesive Location Stream Class: Q Sw Corp --Leland Stream Index: 18-77-1 Receiving Stream: Sturgeon Creek Sub -basin: 03-06-17 (Cape Fear River Basin) Re: Lr wd, T CG090028 Coating & Adhesive Corp --Leland] Subject: Re: [Fwd: NCG090028 Coating & Adhesive Corp --Leland] From: Rick Shiver <Rick.Shiver@ncmail.net> Date: Thu, 26 Mar 2009 15:20:02 -0400 To: Bill Diuguid <bill.diuguid@ncmail.net> Go ahead. I need to find out why it fell through the cracks. Rick Bill Diuguid wrote: Rick Shiver: I never heard any Wilmington Regional Office comment back on this NOI. I am issuing the permit. Bill Diuguid Subject: NCG090028 Coating & Adhesive Corp --Leland From: Bill Diuguid <bill.diuguid(@7ncmail.net> Date: Tue, 30 Dec 2008 09:41:46 -0500 To: Rick Shiver <Rick.Shiverpnemail.net> To: Rick Shiver <Rick.Shiver@nctnail.net> Rick Shiver, Surface Water Supervisor, Wilmington Regional Office: Please review the attached NOI application with the objective of responding to me with a recommendation to issue the permit. I recognize that you may not visit each new, proposed permittee during this NOI review, but it affords you the opportunity to log the general permit into your regional database and add the industrial facility to a future monitoring and compliance visit schedule. Therefore, your recommendation now to issue the general permit serves as your acknowledgement that (1) the facility is located in your region, (2) that there are no current complaints outstanding about the facility that have not been dealt with, and (3) that the facility may ultimately be inspected by the regional surface water staff. I've also attached a scanned copy of the NO] and a location map for your review. COC # it Facility Ij Location ' City/County i..... ......... ...................... ... ..... -- NCGNCG090028 iI Coating & Adhesive Corp;1901 Popular Street NE ! Leland/Brunswick If you need any more info, give me a call. If you could send me a recommendation to issue the permit by 01/30/2009, I'd appreciate it, so I can issue their COC. I am not allowed to issue the permit until the respective regional office reviews and comments back to me with a recommendation to isse the permit. 1 of 2 3/26/2009 3:21 PM Re:IFNwd- ICC090028 Coating & Adhesive Corp --Leland] Thanks. Bill Diuguid, Staff Planner Stormwater Permitting William H. Diuguid, AICP Community Planner, Wetlands and Stormwater Branch Division of Water Quality Department of Environment and Natural Resources 1617 Mail Service Center Raleigh North Carolina 27699-1617 Phone: (919) 807-6369 Fax: (919) 807-6494 Website: http://h2o.enr.state.nc.us/Stormwater.html Rick Shaver Regional Supervisor Surface Water Protection Section Wilmington Region 910.796.7386 office 910.350.2004 fax E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. 2 of 2 3/26/2009 3:21 PM NCG090028 Coating & Adhesive Corp --Leland Subject: NCG090028 Coating & Adhesive Corp --Leland From: Bill Diuguid <bill.diuguid@ncmail.net> Date: Tue, 30 Dec 2008 09:41:46 -0500 To: Rick Shiver <Rick,Shiver@ncmail.net> Rick Shiver, Surface Water Supervisor, Wilmington Regional Office: Please review the attached NOI application with the objective of responding to me with a recommendation to issue the permit. I recognize that you may not visit each new, proposed permittee during this NOI review, but it affords you the opportunity to log the general permit into your regional database and add the industrial facility to a future monitoring and compliance visit schedule. Therefore, your recommendation now to issue the general permit serves as your acknowledgement that (1) the . facility is located in your region, (2) that there are no current complaints outstanding about the facility that have not been dealt with, and (3) that the facility may ultimately be inspected by the regional surface water staff. I've also attached a scanned copy of the NOI and a location map for your review. If you need any more info, give me a call. If you could send me a recommendation to issue the permit by 01/30/2009, I'd appreciate it, so I can issue their COC. I am not allowed to issue the permit until the respective regional office reviews and comments back to me with a recommendation to isse the permit. Thanks. Bill Diuguid, Staff Planner Stormwater Permitting William H. Diuguid, ATCP Community Planner, Wetlands and Stormwater Branch Division of Water Quality Department of Environment and Natural Resources 1617 Mail Service Center Raleigh North Carolina 27699-1617 Phone: (919) 807-6369 Fax: (919) 807-6494 Website: http://h2o.enr.staCe.nc.us/Stormwater.html Content -Type: application/msword NCG090028 Coating & Adhesives Corp Final Map.doc Content -Encoding: base64 k NCG090028 Coating & Adhesive Corp NOl.pdf Content -Type: application/pdf Content -Encoding: base64 1 of 1 3/26/2009 2:08 PM age 2 December 11, 2008 COATINGS a ADHESIVES N, 1901 Popular St. N.E., Route 74/76, P.O. Box 1080, Leland, N.C. 28451 (91 Q) 371-3184 ORPORATION If you have any further questions or concerns, please/feel free to contact me at (910) 371- 3184 or by_e-mail,7a_t-ritkpasin @cacoatings.com. You'jrnay also contact our consultant, Lisa Gideon,5l5 E..at-(910j 620-0851-o\ e-mail at lgideonbcfenvironmental.com. Th�k/� adyancfor YOUr-time in reviewing his n� l tification. Sincerely yours, �� i �ICIIL' Richard'pasin President and Technical Director Coatings and Adhesives Corporati Leland 0 panic Corporation Table 1 Chemicals To"Be'Stored i 1 Contained Outdoor Storage Tanks / I l Chemical // / CAS,Number ( I Company Styrene // i 1.00-42-4 1 Coatings and Adhesives Corporation I Butyl Acr late // / i141-32-2 I Coatings and Adhesives Corporation 2 EthylhexyI Acrylate" / / 103-11-7 ! Coatings and Adhesives Corporation I Vinyl Acetate' 108=05-4�_ Coatings and Adhesives Corporation ,7 BiodieseII.Meth.yl-Ester / I / 67.784,W8079 1 L!&and_0(r anic_Cor oration f-Methanol-- // / 67--56=1— Lelan d-Orq anic"Corporation cerin / �� 56-81-5 Leland Organic Corporation iurn-Meth late 30%) —=i24-41-4-1 Leland -Or anic.Cor oration rAniM21 Fats./ / NA I Leland Or anic Cor oration iata61 ,0i1 f i_ NA 1 L'eland-Organic Corporation Notes / a These chemicals are to•he stored in the future n, Conw,;,Jean From: Jean Conway [Jean.Conway@ncmail.net] Sent: Monday, November 24, 2008 10:15 AM To: LGideon Subject: Re: Permit for Coatings and Adhesives Corporation Attachments: Jean_Conway.vcf Lisa, It is possible that the facility might be covered under the NCG09 General Permit for the activity classified SIC code 2869, BUT they may need to be covered under an Individual Permit instead (or in addition to the NCG090000 permit for Paints and Varnishes). This is determined by the type of materials used and the constituents of the discharge contributions to water pollution. I suggest that we conduct a site visit at the facility in order to identify potential pollutant sources and determine the proper permits needed for these activities. We will be happy to provide guidance on ways to minimize exposure to stormwater which may contribute to discharges and a site visit should help facilitate the permit process as well. If you would like to schedule a site visit for compliance assistance, you can email or contact me by phone at 910-796-7339. Jean LGideon wrote: Jean, There is a second process at this location (same owner) with an SIC code of 2869, but the primary SIC code for the Facility is 2851. From my understanding of the rules, the entire facility would still be covered under the General Permit once they make the NOI, correct? They have not been storing chemicals outdoors, but are going to start doing so once the permit is in place. Thanks again for all of your assistance. Lisa Lisa L. Gideon, M=. Cape Fear F nvironmental Services 910-6 20-08 5 1 Fax: 910.68 6-5 853 leideon@cfenvironmental.com www.cfenvironmental.com From: Jean Conway [mailto:Jean.Conway@ncmail.net] Sent: Thursday, November 06, 2008 11:12 AM To: LGideon Subject: Re: Permit for Coatings and Adhesives Corporation Lisa, It will eventually drain into the Cape Fear River Basin usually listed as "From the source to the Brunswick River" in the classification list. Most ditches are considered to be surface waters and eventually drain to a water body. Even if it drains to a stormwater pond, it has the potential to discharge into a named body of water. If you believe this business does not have any stormwater discharge associated with the facility's activity you should look at the "No I -Exposure Certification for Exclusion Form_ " on the website to see if they may be eligible. Jean LGideon wrote: Jean, Thanks so much for your help. Do you know of a way that I can determine which body of water will end up receiving this stormwater? If the ditches do not drain to any particular body of water, is the permit still necessary? Lisa Lisa L. Gideon, F.E. Cape Fcar Environmental Services 910-6 zo-oa 5 i Fax. 910-686-5655 I ideonOcf cnvironmental.com www.cfenvironmental.com From: Jean Conway [mailto:Jean.ConwayOncmail.net] Sent: Tuesday, November 04, 2008 10:36 AM To: I ideon cfenvironmental.com Subject: Permit for Coatings and Adhesives Corporation Lisa, Here is the link for the permit forms needed to obtain the NPDES Stormwater General Permit for activities that include Paints and Varnishes: . http://h2o.enr.state.nc.us/su/Forms Documents.htm#stormwaterGP To apply for a Certi ticate of Coverage under this permit you will need to submit a "Notice of intent Form" which can be found under the General Permit Number NCG090000 on the Forms and Documents page using the link above. Please look through the NOI form and include all necessary documents and fees and send to: Stormwater Permitting Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Information regarding the permit can be found in the accompanying "Permit Text" and "Technical Bulletin" as well. My direct phone number is 910-796-7339. Please do not hesitate to call me with any questions or concerns regarding further assistance in order get this facility covered under the proper permit. Thank You, Jean Conway To: LGideon Subject: Re: Permit for Coatings and Adhesives Corporation Lisa, It will eventually drain into the Cape Fear River Basin usually listed as "From the source to the Brunswick River" in the classification list. Most ditches are considered to be surface waters and eventually drain to a water body. Even if it drains to a stormwater pond; it has the potential to discharge into a named body of water. If you believe this business does not have any stormwater discharge associated with the facility's activity you Should look at the "No Exposure Certification for Exclusion l"orm" on the website to see if they may be eligible. .lean LGideon wrote: .lean, Thanks so much for your help. Do you know of way that I can determine which body of water will end up receiving this stormwater? If the ditches do not drain to any particular body of water, is the permit still necessary? Lisa Lisa L. Gideon, r.F—. Cape Fear Environmental Services 91 0-62a-0851 Fax: 9 10-68 6-5 a 5 5 lZideon@cfenvironmental.com www.cFenvironmental.com From: Jean Conway[ma ilto:Jean.Conway@ncmai1,_net] Sent: Tuesday, November 04, 2008 10:36 AM To: {Qideon@cfenvironmental.com Subject: Permit for Coatings and Adhesives Corporation Lisa, Here is the link for the permit forms needed to obtain the NPDES Stormwater General Permit for activities that include Paints and Varnishes: httP://h2o.enr.state.11c:.usl U/Forms_Doculllellts litiiigstornlwaterGl' To apply for a Certificate of Coverage under this permit you will need to submit a "Notice of Intent Form" which can be found under the General Permit Number NCG090000 on the Forms and Documents page using the link above. Please look through the NO[ form and include all necessary documents and fees and send to: Stormwater Permitting Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Information regarding the permit can be found in the accompanying "Permit Text" and "Technical Bulletin" as well. 4 My direct phone number is 910-796-7339. Please do not hesitate to call me with any questions or concerns regarding further assistance in order get this facility covered tinder the proper permit. Thank You, Jean Conway 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Information regarding the permit can be found in the accompanying "Permit Text" and "Technical Bulletin" as well. My direct phone number is 910-796-7339. Please do not hesitate to call me with any questions or concerns regarding further assistance in order get this facility covered under the proper permit. Thank You, .lean Conway 1 . . Conway, Jean From: Jean Conway [Jean. Conway@ncmail.net] Sent: Monday, November 24, 2008 10:15 AM To: LGideon Subject: Re: Permit for Coatings and Adhesives Corporation Attachments: Jean_Conway_vcf Lisa, It is possible that the facility might be covered under the NCG09 General Permit for the activity classified SIC code 2869, BUT they may need to be covered under an Individual Permit instead (or in addition to the NCG090000 permit for Paints and Varnishes). This is determined by the type of materials used and the constituents of the discharge contributions to water pollution. I suggest that we conduct a site visit at the facility in order to identify potential pollutant sources and determine the proper permits needed for these activities. We will be happy to provide guidance on ways to minimize exposure to stormwater which may contribute to discharges and a site visit should help facilitate the permit process as well. If YOU WOUld like to schedule a site visit for compliance assistance, you can email or contact me by phone at 910-796-7339. Jean [Gideon wrote: Jean, There is a second process at this location (same owner) with an SIC code of 2869, but the primary SIC code for the facility is 2851. From my understanding of the rules, the entire facility would still be covered under the General Permit once they make the NQI, correct? "they have not been storing; chemicals outdoors, but are going to start doing so once the permit is in place. 'thanks again for all of your assistance. Lisa Liaa L. Giae--, F.171. Cape Fear Environmental,5ervices 9 1 C-62o-085 1 Fax: 91 o-6s 6-5 s 5 3 leideon@cfenvironmental.com www.c♦'environmcntal.com From: Jean Conway [ma ilto:Jean.Conway ncmail.net] Sent: Thursday, November 06, 2008 11:12 AM RE: NPDES Permit Reviews Subject: RE: NPDES Permit Reviews From: " Wideon" <lgideon@efenvironmental.com> Date: Fri, 31 Oct 2008 13:21:35 -0400 To: "'Jo Casmer"' <1o.Casmer@ncmail_net> I am looking for a stormwater (NPDES) permit for the Coatings and Adhesives Corporation/Leland Organic Corporation in Leland. Would I've able,to make a copy of the permit? CJQ�`(���40A J Thanks, Lisa Lisa L. Gideon, P.E. Cape Fear Environmental Services 910-620-0851 Fax: 910-686-5853 lgideon@cfenvironmental.com www.cfenvironmental.com -----Original Message ----- From: Jo Casmer [mailto:Jo.Casmer@ncmail.net] Sent: Friday, October 31, 2008 12:36 PM To: lgideon@cfenvironmental.cam Subject: NPDES Permit Reviews Lisa: I am the one you would contact to review these permits. I will need to know what permits you wish to see. After I have pulled them, T can call you and yes, we would need to establish an appointment for you to review them. i Jo Casmer Administrative Assistant �� NC Dept. of Environment & Natural Resources Division of Water Quality 127 Cardinal Drive Extension Wilmington, NC 28405 t Phone: (910) 796-7264 ot Xk_ Fax: (910) 350-2004 w 1-2,00 ('� 3 7� �1ti '- I I of I 11/3/2008 8:04 AM N C C�a�aals 0 wn�r: f-OM4 U� t4wl� Woodlands PRO11CTNOTES: Tax Parce10280000801 A. Proposed use of property: 1. Primary Use: Chemical Plant 2. Secondary Use: Norte Wetlands 3. Nonconformances: None B. Zoning 1. Classification: IG 2. Mininum Setbacks Front:50 Rear: 50 Left: 10 Right: 10 Actual Front: 160 Rear 2000 Left 150 Right 250 cioad Area is me Scope b 3. Adjacent Properties classification prPleca plat 0280000806- IG - Wood treatment plant Plot 0280000840- IG - vacant land + Plot 0280000809- IG - vacant land - county park Plot 0280000802- IG- warehouses C. Buffer R ')K 1, No buffer required. This project has no frontage on x NEW any property line. T. a, aI OWESEL PROCESS D. Existing Criteria HT -se' 1. Street : Popular Street 2. Wetlands: Yes - on plot plan 3. Total Acreage: 51.14 Acres evrrRru� F"*r"„�� E. Proposed Project Site Data 4e•rcevnn0. 1. Phasing: None = 2. Proposed streets, sidewalks, etc: None r 6 lLOING 3. Impervious Surfaces Existing Ft2 w 102,494 p� % of Site 4.5 Proposed Ft2 = 112,274 � TANK ol%E rM J Tra "NEW HT-40 " % of Site 4.97 „ •sr °°-� ^ 4.Proposed Buildings I® Process Building � 90 x90 =8100 ft7 50 ft height Truck Pads(2) = 18.5 x 40 =740 ft2 20 ft height , eXeraw ❑-mp Utility Bullding = 30'x25'=750 ft2. 14' height ,;-GHT NOusE MCC Building - 1Tx30'-450 ft2 14' height °'"•°° Total footage- 8100+740+750+740+450=10,780 ;ER 5. Proposed Traffic TIA: N/A �s Driveways : None proposed �4 c' Aisle width In parking lot: 25' Space size: existing —9x18 Handicap spots : existing = 7 total-7+85-92 'ICE Sal t Handicap spots marked on surface and with signage 2 M T Parking space type: existing - blocked yy Parking tot surface: existing = asphalt S. Proposed Traffic Cont'd Parking Req'd Parking Provided Standard 73 85 Handicapped 3 7 Determination: Parking Space calculations: With the new project the total enclosed area Is 70,000 ft2 which would require 73 spaces. The esisting number of spaces is 88. Based on the existing 92 spaces we would need 5 handicapped spaces. There are existing 7 handicapped spaces. Based on the above calculations the existing parking meets the code requirement. 6 Off Street Loading Blodiesel Operation has two tank farms. Each tank farm has a truck unloading and unloading pad. The pads are 18.5 feet x 40 feet with an 18 feet roof with open sides. This facility receves all material and all products are shipped via tanker trucks, 7. Recreation - None required as this Is an industrial facility 8. Lighting is being provided Inside the buildings and external kghting will be as described an the drawing to provide sufficient lighting for night time operations. All external lighting is directed internally and will be mounted at 25' and 40' elevation. 9. The plant has one existing compactor/dumpster at Shipping and Receiving which Is shown on the drawing. 10. 5ignage - There Is one existing sign at the entrance to the plant. No new signs are planned. Lt. Landscaping - The existing parking areas have grass areas next to them as shown on the drawing. Since there are no new parking, no green space islands are required. 12. Utilities- Water and sanitary sewer are provided by Brunswick County, 13. Stormwater Permit has been approved by the Stormwater Administrator 14_ Building Facade Design - This project Is located in the Inside of the parcel and cannot be seen from any public road or site, Therefore the criteria is not applicable. 15. The form for "Determination of Wastewater Treatment and Potable Water service has been provided by the Utilities Department. ♦-- N 0 RTH BIODIESEL PLANT 14 COATINGS AND ADHESIVES CORPORATION I SCALE: V'= DATE APPROVED: 9/19/07 I APPROVED BY: CCM . c T A 4 5 7,- R (; A H[ Z A Y I" Business isn't the only place that needs quality management. Support Coasts and Oceans. D--G Z)---08(3Q�) 32)3-1B13(0)C4 444 North Capitol Street NW, Suite 322 • Washington, D.C. 20001 202-508-3860 9 http://www,coastalstates.org PAVED SHIPPING WAREHOUSE x H-T. 1 PAVED A rz- a a RM W= R-Mry SE z- DROP INLET L OFF12 21 12 C) M � 9t �J r LOT Q A -seralr/ aul rPrear . TRu yr 1i Clrra Orr a me cope rRllRN4 urw.oio SIODIESEL ruewipr TANK D[KE E NCGCO[is .4 ]M ISM 2 NEW -9 . q slooltsm PROCESS nT -w• DROP FkLET erlFrrRl xr rrru. leYw �,4H rP,s AAVEO *sir �`'}Ma ltrNva LrTY ]LDlNG { I EQUIP W co.nNG =ac.-s PROCESSAREA .......� it AM TANKS C.�_ �a PARKING LOT PAWO AISLE WIDTH-19' SPACES:sxla PARKING LOT PAVED gppp AISLE 'MIDrM-ia' INLET SPACES: 4'xla' ►dg w LJ Tyy% 0[Kf EQl11PwIE- � syq• lr lra x r ®C] `r1 PAVAL %1NP IGwTrlG MgUSE !r Erwka, GAS F.ISER x Nrna,npocc *c x so' Aermnp 'r 10 R2 ,14'. Woodlands PROTECT NOTES: Tax Parcel0280000801 A.Proposed use of property: 1. Primary Use: Chemical Plant 2. Secondary Use: None Wetlands 3. Nonconformances: None B. Zoning 1. Classification: IG 1- Mininum Setbacks Front :50 Rear: 50 Left: 10 Right: 10 Actual Front: 160 Rear 2000 Left 150 Right 250 3. Adjacent Properties classification plot 0280000806- IG - Wood treatment plant Plot 0280000840- IG - vacant land Plot 0280000609- IG - vacant land - county park Plot 0280000802- IG- warehouses C. Buffer 1 No buffer required. This project has no frontage on any property line. D. Existing Criteria xu 1. Street : Popular Street c 2. Wetlands: yes - on plot plan 3. Total Acreage: 51.14 Acres 5 E. Proposed ProJect Site Data g 1. Phasing: None 2. Proposed streets, sidewalks, etc: None 3. Impervious Surfaces w Existing Ft2 = 101,494 % of Site 4.5 Proposed Ft2 = 112,274 % of Site 4.97 4.Proposed Buildings Process Building = 90 x90 -8100 ft2 50 ft height Truck Pads(2) = 18.5 x 40 -740 ft2 20 ft height Utility Building = 30'x25'=750 ft2. 14' height MCC Building = 15'x30'=450 ft2 14' height Total footage= 8100+740+750+740+450=10,780 5. Proposed Traffic TEA: N/A rs Driveways : None proposed 1-' Aisle width in parking tot: 25' :HL t Space size: existing =gx18 F4M Handicap spots : existing a 7 total = 7+85-92 vE Handicap spots marked on surface and with slgnage 9Po Parking space type: existing = blocked .nie Parking lot surface: existing = asphalt 5. Proposed Traffic Cont'd Parking Req'd Parking Provided Standard 73 85 Handicapped 3 7 Determination: Parking Space calculations: With the new project the total enclosed area is 70,000 ft2 which wouid require 73 spaces. The esisting number of spaces is 88. Based on the existing 92 spaces we would need 5 handicapped spaces. There are existing 7 handicapped spaces. Based on the above calculations the existing parking melts the code requirement. 6 Off Street Loading Biodlesei Operation has two tank farms. Each tank farm has a truck unloading and unloading pad. The pads are 1B.5 feet x 40 feet with an 1S feet roof with open sides This facility receves all material and all products are shipped via tanker trucks. 7. Recreation - None required as this is on industrial facility 8. Lighting is being provided Inside the buildings and external lighting will be as described on the drawing to provide sufficient lighting for night time operations. All external lighting is directed Internally and will be mounted at 25' and 40' elevation. 9. The plant has one existing compactor/dumpster at shipping and Receiving which is shown on the drawing. 10. Signage - There is One existing sign at the entrance to the plant. No new signs are planned. 11. Landscaping - The existing parking areas have grass areas next to them as shown on the drawing- Since there are no new parKing, no green space islands are required. 12. Utilities- Water and sanitary sewer are provided by Brunswick County. 13. Stormwater Permit has been approved by the Stormwater Administrator 14. Building Facade Design - This project is located In the inside of the parcel and cannot be seen from any pubNc road or site. Therefore the criteria is not appllcabie. 15. The form for "Determination of Wastewater Treatment and Potable Water service has been provided by the Utilities Department. N ORTH BIODIESEL PLANT COATINGS AND ADHESIVES CORPORATION SCALE: 1"= DATE APPROVED: 9/19/07 APPROVED BY: CCM Important Contacts Main Number (910)371-3184 1 1 Guard Shack: ext 196 Front Desk: ext 221 &VIPO "S' Matt Fail: Emerg Coord, Plant Eng: Ext. 262 QRaC1RATEDN Jim Marcinko: 2nd Emerg Coord, Polymer Mgr: ext 261 Kirk Woodington: Plant Supt: ext 281 Nestor Guzman: Plant Mgr: ext 280 Visitor Safety 'In Dan Gaffney: Ship/Rec Mgr: ext 244 � Please see ouard or front desk to sion in - EHS: Ext 245 Y a� as �c err on 1901 Popular St NE Leland, NC 28451 910-371-3184 i.�wk,...rJ,lec4-e7� w, FriMa�r�rn�llr5dri�.lniii� iIrrtiiiAi - �r-+r�s�.-. _ - �r �"` General Safety Rules Emergency Evacuation Noise 5 Always keep a safe distance from machinery, forklifts, and 0 In the event of an emergency requiring evacuation, you will 0 UvlBase are hearing conservation area: This means heavy equipment both inside and outside the plant. be notified via alarm (chemical, fire alarms) or by radio or noise is below the allowable level, but at ive OSHA's word of mouth) action level for 12 hour shift Do not jump from docks, platforms, or other raised areas. ) Firearms and other weapons are prohibited on company property. 0 The use or possession of alcohol or illegal drugs on com- pany property is prohibited. ) All injuries must be reported as soon as possibleand prior to leaving company property. D Also report any unsafe conditions or acts observed imme- diately to your host Follow all signs, labels and posted warnings When in the plant, where available please walk in pedestri- an aisles. When not available walk to the side. ALWAYS stop at blind corners and intersections to look for traffic before proceeding D Phones and Cameras are not permitted on the production floor without prior permission No pictureslphotoslvideos should be taken without prior permission a Escort is required at all times as a visitor Tobacco Use Vaping and Tobacco use is only allowed in designated areas, ADMIN: under outside covered shelter PLANT: un- der awning outside breakroom incident Reporting 0 You will then report to the evacuation area with your escort 0 If it is necessary to move the evacuation you will be notified 0 Please do not leave the evacuation area, so that roll call may be taken Chemical Spill 0 Some of our chemicals have good warning properties (you can smell them at low levels) 0 However; if you smell any strong odors, or you began to feel any symptoms of overexposure such as nausea, dizziness, burning, irritation of eyes, respiratory tract, immediately evacuate the area and report to the nearest supervisor or manager (wearing white hats) or your escort Personal Protective Equipment 0 Visitors will be provided with a hard hat and eye protection with side shields which must be worn in the plant 0 Additional PPE may be required, your guide will give you instructions if necessary 0 Long hair should be contained under a hard hat at all times. 0 Loose fitting clothing that can become entangled in machin- ery is prohibited. 0 No open toed shoes, sandals, or heels exceeding two inches are permitted in the plant 0 All hanging jewelry such as necklaces, watches, bracelets, earrings, etc. must be removed before entering the manufac- turing floor. 0 Earplugs are available before entering It se areas Process Safety M mt. 0 PSM process involves flammable liquidE i excess of 10, 000 lbs. 0 Any work done on a PSM process or ne a PSM process must have prior approval Visitors cannot enter a PSM area without; iproval Hazards of PSM Process -Flammable liquid can cause fire -Chemical release (styrene and EA are susp( led carcino- gens) -Nitrogen is used in our process and can cau , oxygen deficient atmosphere -Processes maybe hot, steam lines run into p )cess J. 7 tdW � 31.1 � i �` � � _Its. a� ' j ��' `• x. � � w�, � r., a� AL - _ _ -' V ' - • _-r�k!"rr..- .-.11.E r ,.�X � .44" .1 lk _�s T• - � S *1r• � • tea.... w .� f �\ � 1 � • b'ia�ii! 1 P, I 11 it ~ r ```" ^---�----~ esn VALVE BODY SYMBOLS AND ACTUATORS PIPE. LINE SYMBOLS hD4 PATE wac fLOW OIRECTTW "orcau ✓ti mom VALVE-----�—� L Fu i= CONW-c " ACTUAJDA I BlhEp FlAlEGfp COH1iEC1TON Eiill %OL%E n REAOER DOD cA P L11.wm THREADED WON rR�} DUPHRACM VALE ACnWOR HN Kw IOLVE DEwHRu;sT WIITI �� FTEXSEE OWNECT10H DUf1ERrLY VALVEE ELECTRO-PNEWATIC I FT95Y OR [YESTRCTIOH ORfF10E POSHMERI L� AFIQE VALA REDUCM rLMCt "l�'• a -WAY vuve CAr.IE<WTED HAND VtLLE SO ewe ONjo `T HEA7 MT = PIPE UNE E - ETiC'1RC 5 - 6"[E4r1 NUMLE VALVE HpIW - NOT WATER AMTSTAED.E CRECKLVE VAY070R OPERAWA - 1 WILAT04 �Tw PftFrSA+E 1hYEGlTCR 11TT7T 0.EC'rRVWHR�PHiULA71C1 t50EAD1:6 Dr1PMUGl7 SEAL , P051TiCY1tR NW SiPJJlIEZi `� fttSTNOTI WfT 5'AITCRES SAFETY DEVICE SYMBOLS pfummIx SA." ---�- VAC" S M DOH4RYA (PRESSiPE A YAa vrioExnT rzEIET vx\,) Ur-• -I D � / A RUFnJRE ESTut EQUIPMENT SYMBOLS N�bUT�alSLFEATE M END-sLJCTTDR PWP CONTROL VALVE SYMBOLS PRESSURE WaAATOR � ! N SENSE iIAW 4ETER - — NTMm ApnrNE ODP'ULiLEM FR PriT'SSVRE FIDUATOR PAAQLLLL four PREWURE Da Aro"roa H � ROTAfOf vANL I'UIEP TTSEPERAIIlRE ca[nrtot VxtS w/ CAPDtI.Rv TIP H1i DWIHIiACAI PUMP FLOW C04FEROL VALVE COFTTDftk",>'i. "MP wTTkx MS Ci1FIPoFl1G4,- PUW PROGGRr�M1$ CA4[TY PUWP STEW EJECTOR OR EDUCEOR ISA INSTRUMENT IDENTIFICATION LETTERS fi1RST LETTER _ SUCCEEONG LETTERS VEASURED OR "PA" I p OO= VMVSL.E miDbur OR I ouTYur I ourPUr Fk3NCT10N NSTRUMENT LINE SYMBOLS INSTRUMENT SYMBOLS SHS'i32US7ETR OR PROG£SS L4iE �� f� �! 17�T--fl — PhiA1W1T1C saU1 � m gOPMATOR� ACCE.: MZ AOCESSIBLE ElECTTtlCAL SIGNAL VENDOR PACKAGE PUMP SEAL FLUSH (API) L401PtlENT PROV.Do BY PWP viumoR ® mm' DOICCESSELE trE51}WEN S 1EOME0 DElM ATE P NEL ARE EHETICATEM AS AUiE EKEPT 1uTH DASHED HOR,ZORi. UNES. INSTRUMENT TAGS ELECTRICAL SYMBOLS YM H0A-FiMCT" )0f--PISTR FNT 0 O ODU �00p RUTrsE9 P9 PUST3BUTTON VN SMvc, T SmTC„ L EfG1fl HOA A WD-M-AUTO 5 STARE -STOP 1#CiF.dAE. FLOW OIRLC,SOR .:��r:• LCCF'nQ •�cV •1 1 1 I LELAND ORGANICS, INC. BIODIESEL PURIFICATION ZE LEAD SHEEP NON PROJECT W"RG gUWBEER M. 061017 I'ID- I00 A tJT LMES TYPWAL FOR ALL SYSTEMS ORNPERW WA" SUPPLY TEl1PEm WATER REnm OPOT m SUPPLY OHOT 04 RETURN OWW PRESSURE Si 00 P51J O LOW Pfl-SLK CONODMUE OUEVVW PRESSURE STEW VQIKW PRESSURE 5fEW WrDmurf OFDOH PRESSURE STEM ID HIGH PRLWOZE STEAM CONDE) AIE I 1 P-a/ai5rnu- - 12 M-tJ» ve r CONTROL AIR 13 LOW PREMK NMWOEN 14 NITROGEN . t5 PROCESS SLk4Nf 18 GOOLNO WATER SUPPLY 17 CO"<; WATER MUM 18 TEMPERED NOT 01 SUPPLY 10 T37.TPERED HOT Oil MLWN 20 CKUM WATER SUPPLY 2T MLLW W1.TER RETURN ROr WAFER SW'PLY OHOT WATER Rmmi 2E WATER-F011RE (C,rY WATER) 0 WASM WATER COUCTIM 28 DEWNERNMIN WATER 0 WELL WATER CM I k HaAmm.H mRdv1 a W YOmCMb of Tidh IRSmae I WE a Ob Pb I`l .1-04. fi•.LSKp TRUCK 2„ l." WtICI• ✓`r � 4` fRCI-MI ��` L, T II ll pp II II I } Q-4 1ltU ��f�1�i 1 �wns,l 1�= 24' yc'rrt,tt-�D n R. P-CT-002 - 1r III T — ('l 1,. LI 0r-) n�a cr; .w.na SH-tI-rAI cl � -- -c, F+cc7 i� , l I E! 4" iV-[I mill lieLy L�LLiiI i�r rra►:, To 2103 Monifo! Pit;-109 J- 2'k S' Nct4�f -� olr� 37x 2 k 2` I rnwf- two �-c1-od1 ' U11LITIES TY?JCF1 FOR ALL SY5'FEIAS op snlu T01 AFan*td pcti "RkTS PID-T01 ©isin�rtla i✓i11�1 A�iC �a,um.rrut MW%'f ® otum "Tm rwrwi ® n*tn wasp axtr Q TollfJt "fist Fxr,-,i Q a wir,7 1[1 FMM %%TM KW N COA71 rr L AMMSIV69 T—C1 P--C1-002 P—cf-001 ORPORATION fl6n"er Tnnk JAMMER UNLOADING I.iGNOIJER TRANSfER 2 30,000 GALS PJMP PUitP VIafT 150 C L1 40 CP1S 304 SS 316 SS 316 SS 13.0, 0 x 30' 155 TbH 150 TDH ATMOSPHI-ple PRESSURE 6 HP & 1700 RPM 7.5 HP & 3400 RNA ,nv P4F7�IC � e�lA�c7f�AliOH OU7A7Ji �s AMBItfT KUPEARTLIRE GOULDS GOULDS DRAVVMO14UMM REV. P I"— C d 0 4r xev sua bAii 6Y pm B C E H ki '1 FA�Bk^O1 ', A t m Vent Protectoseal 3' itodei F673B /YW9 F134 Ev-BI-01 Pratectoseai 11J Id'-Hodet F7810H ST-01pSV19 w n-M SET a 0.25 PSIG N-n-m N-tl-0ft ex �• r r 4' w-xexe TT-5 XWIS Lr-n-0ct LT LI w-t:aa} nm TT-u XW37 "-N-au TI 11 rv-X-M 7 6-IN LT-3 rt XW05 T TI N-n"�l1 }rxs�an r PI n-ta-0eb �4 �� N-71.Ofb L — 1 SiT-01 C-00-SV46 nr->ti-0q !V•k-0eb N-CbW Teak ST-01 P�nP-91-OOl MWWNLCtl en VolFe MPChONC4 O.Or ctM"m ITT/GO&W MAgnslons 13, x 20' Hodeb EZ96 lz x i-s [apa dty, 19AW got Motam 7.5 hp / 3500 r," 13A`}A -a5 / La F 150T Typical for valve spibol, A rn-aa Y49E/FI3 0 ST-0I-SVI5 TT n-n�rR N-0.1W! 1 3n-a�az nr-n•o�1 w-nam ram J N-niW h n r Y49FI/F131 IA �Y Si-01-SV17 Y500/F132 ' G [nFrv-M-M 4l N_ iv-M-40 yw21-ti4 ram rn c41 0 n-n-0oe Mix ,i N-n-0a N-71-M N-n-a hl Y501 /F 136 Pa""� P-st-001 ilkl`F4U.1 �f� UTILITIES TYPICAL. FOR ALL SYSTEMS © smm 1@ CO1mL-gsATE 4j 9.15FRutlufT AIR F MtIRPQEY GitllED WATER SUPPLY 2 CHIUM WATER REIURM TUAER Y•A1ER StMY Q MAER WATER RFIUILY 01 WAFER ® IEWPWEO WAFER SUPPLY 0 1FUPFKo WATFiI rime i oIlf, 1H 6itn1.C[luaCiAIY-6 t/1LlNt1 k )i I BI MMA TANK FA-B3-OS F"tectoseat A.s. m Vent 3' Modet F6736 av-n-m Y494/F120 EV-B3-01 St-03-SVsE 6.2psisS \l kodel � SEi B B pS[G r»cq f I r a. r r r TT-i J.t![C . L LI " rsr rti3aw -n-re iT-2 PI iCtift3 - T T[ I " ,om r4e0/F1ts Lit "'04 TI " TI naesr TI n•q-r¢f r . p.k Pl 2{� rnW, B3 4/t-� r Nli-fi S T -03 IC-10-SV44 ev-tsam y FlsYael T.d. sr-a7 ! b Awp P-81-0Et Harulae ty x 2V INdfW[a! LYpvpaandene kY � p2s7 H2 5100 ■ .wr V 1ra++ifa Z96 L ttTlGOU.95 >toaw EZ% u X 1-6 Ibter+ TS M f 25a0 .pw TYp'eat for value Symbc* IA Y49?fF113 1'iFtYNi N-LYd 53-SVi 57-53-SV3 Y4Q81FIE2 rnaw ru+n w arw RN�<o1 1491/F117 row UTILITIES TYPICAL FOR -ALL SYSTEMS C STUM i&[ C0.:o>:' mur i 1 MiRiNnd 1 MR 1 HOROGD1 CIT: ED WATER SUPPLY 923 cm E Fn VIATFR RFi11RN u YcwsR WATER SJPP:.Y R5 MVER WATER F-,.-wRN Di amFR Y{�. 101PER-0 WAIM SUPPLY 0 TOIFEW) WATER Rt7URV =14 -1 F %Q2b�✓� E,-Sup 20NE:2 IS PRESSE1 SHUT DOW ZP V E1 rWow V a f0' e•_ 1(� g1131SM ap Capodtr 5m gel wf-- 3465 ipn. 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FOxrwr O Hodes, GAf3 SV Natory Gast 4a4-iiRV-SOC rrkr oa+ IA avaa4-0m Y510IF148 AAD-SV42 NOW R5 0 Sv Y509/F; M T - 0 4 T02-SV33 sv L XW07 4111'\ LT Ll Ll F lV-NT�-0W G7 n N-M1-ax ATP6-SV25 XW3€ rx ns�m CH2-a f E4 D[ Vnter i T02-SV35 C Y?7?lF142 SV Aaltaton kf05 Raton Gast 4AN-MV-223 er-Kr.t� S rv�sls aas 4M54 IA n MT--05 LI er-wr-m sv�i[yoae Fri n sv-ftrsmz Cy/;�Jx 1.1 UTiLIVES TYPICAL FOR ALL SYSTEMS ®�N lO COF:OETlStiE Of msTrimma m G finpo0Eti CF111D WATER SUPPLY v mj li7l Wktm R:TURN +' TiYRTR WATER SUPPLY Ta'AER WATER RMRH Q iN YiATER TEPPERED WATER SURAEY ! TfLPFREo WATER RL'f1 m P-U-001 I A c� FlvrTC-1 R-2103 C-2 i U3 RFI%TCK. eo!:Oe ,= VacU,>n plo-iu aztT 7 NOTES: va EC A.Wo t�J.z1b COKSFFUCIYN! UTILITIES TYPICAL FOR ALL SYSTEMS 0 Sim Cotriumm v�smxzwt RR Yrmoml F OtUM-w'AIER SIMPLY © ate wkrn CLtm ® Tonm whrm SLMY 2 TOWER $%ATA RET RIf S� Ot WTER © IIEN ,EL i_kIER *JF-MY TV -;Pa A i,ATFR wt-Rf r ORpQAFTION UST Uk'F T%J. 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