NCG060003_COMPLETE FILE - HISTORICAL_20140121

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V Ci&Q� 000
DOC TYPE
IAHISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
o 0019 o t al
YYYYMMDD

Taylor -Smith, Aana
From: [e-mail]
Sent: Tuesday, January 21, 2014 2:59 PM
To: Taylor -Smith, Aana
Subject: Inspection report
Hi Aana,
Thanks for getting your report to us so quickly (and thanks for the compliments as well. We do try!). I noted
that Duke Wilson is indicated as the point of contact. Could you remove him from your system? Duke hasn't
been with KSA since 2009.
regards, JT)uIL4 Wi4Sor YtvvrnoVcd i / 7-LI 14
Patrick B. Simcox -AU
Manager— Health, Safety, & Environmental
Kao Specialties Americas LLC
243 Woodbine Street
High Point, North Carolina 27261 USA
Telephone: [phone]
Fax; 1-336-884-4390
e-mail: [e-mail] ksallc.com

AT
4
4*M
NODENR
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral, and Land Resources
Land Quality Section
Tracy E. Davis, PE, CPM Pat McCrory, Governor
Director John E. Skvarla, III, Secretary
13 January 2014
Mr. Patrick Simcox, HSE Manager
Kao Specialties Americas, LLC
P.O. Box 2316
High Point, NC 27261
Subject: Compliance Evaluation Inspection
NPDES General Stormwater Permit NCG060000
Certificate of Coverage NCG060003
Kao Specialties Americas, LLC
Guilford County
Dear Mr. Simcox:
Aana Taylor -Smith of the Winston-Salem Regional Office of the NC Division of Energy, Mineral, and Land
Resources (DEMLR) conducted a compliance evaluation inspection at the subject facility on 13 January
2014. Your assistance and cooperation, as well as that of Mr. Craig Endean and Mr. Don Kaserman, were
greatly appreciated. An inspection checklist is attached for your records and the inspection findings are
summarized below.
This facility is located at 243 Woodbine Street in High Point, Guilford County, North Carolina.
Stormwater related to industrial activity is discharged from the site to Kennedy Mill Creek in the Yadkin -
Pee Dee River Basin.
Documentation & Monitoring Review
The facility's Stormwater Pollution Prevention Plan (SPPP) is very thorough and up to date. Qualitative
and analytical monitoring have been completed as required. Kao Specialties Americas, LLC is currently in
Tier One for the pH benchmark and all tiered response actions have been completed as required.
Detailed records were available for inspection. Employee training records are kept electronically.
There are two Stormwater Discharge Outfalls (SDOs) at this site that discharge Stormwater related to
industrial activity. Both outfalls are large basins that hold stormwater before discharging for slug control
purposes. Outfall 001 discharges directly to Kennedy Mill Creek and Outfall 002 discharges first to a fire
water pond. Samples are taken at the basin inlet pipe for both SDOs.
Site Review
The facility is clean and well -maintained. Secondary containment is implemented as required. Both
outfalls were inspected and found to be in good order. No evidence of erosion or instability at the SDOs
was observed. The receiving waters were free of pollution indicators.
Winston-Salem Regional Office
585 Waughtown Street, Winston-Salem, NC 27101 e Phone: [phone] / FAX: [phone]

Kao Specialties Americas, LLC
01/13/2014
Page 2 of 2
r-
We appreciate your efforts to comply with the stormwater permit and the proactive steps taken to
identify and eliminate potential sources of pollution. No additional response to this letter is required.
Should you have any questions regarding the NCGO60000 permit or this inspection, please do not
hesitate to contact Ms. Taylor -Smith or me at [phone].
Craig Endean
Kc`-1, i O
PST', fi Ooeralien5 Sile'frainer
Kao Specialties Americas LLC
243 Vdoodl:)oe sircue
PO Box 2316
High Point, NC 27251 USA
office- 336-878-4295 Fax: [phone]
Email: cendeancksallecom
j KOO Group
Patrick Simcox Kc`7s10
Manager
Heaitll Safety 8 Environmental
Kao Specialties Americas LLC
2431Nocdbine Street
PO Box 2316
High Point, NC 27261 USA
Otlice: 336-878-4312 Fax: [phone]
Email; PB1mcox6k5a1lo.com
KaO Group
Don Kaserman, CHMM KO
HS&F SpecialiSt 02
Kao Specialties Americas LLC
243 Woodbine Stteet Sivppirig Addross
PO Box 231E 1620 Belmar Street
Kgh Pont. NC 27261 USA High POint, NC 27260
Office : 336-878-4221
Fax :[phone]
Ermdl, dkase,manG,+ksnllc.com
hti pa/chemlcil.4.no,co� r i/us! -- _
KaO Group Enriching lives, in harmony with nature.
r --�
Enclosures: BIMS Inspection Checklist
cc: Central Files
4,WSRO%LQ 7
Sincerely,
Matthew E. Gantt, PE
I, Regional Engineer
Land Quality Section

S
Compliance Inspection Report
Permit: NCG060003 Effective: 12/01/12 Expiration: 10/31/17 Owner: Kao Specialties Americas LLC
SOC: Effective: Expiration: Facility: Kao Specialties Americas LLC
County: Guilford 243 Woodbine St
Region: Winston-Salem
High Point NC 27261
Contact Person: Duke Wilson Title: Phone: [phone]
Ext.4357
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 01/1312014 Entry Time: 10:35 AM Exit Tlme: 11:05 AM
Primary Inspector: Aana Taylor -Smith Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Food/Tobacco/Soaps/Cosmetics/Public Warehousing
Stormwater Discharge COC
Facility Status: ® Compliant D Not Compliant
Question Areas:
R. Storm Water
(See attachment summary)
Page: 1

Permit: NCG060003 Owner -Facility: Kao Specialties Americas LLC
Inspection Date: 01/13/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Please refer to attached inspection letter.
Page: 2

N
Permit: NCGO60003 Owner - Facility: Kao Specialties Americas LLC
Inspection date: 01/13/2014 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?
®n
Q
n
# Does the Plan include a General Location (USGS) map?
®
n
n
n
# Does the Plan include a "Narrative Description of Practices"?
®
n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
®
n
Q
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
®
Q
❑
n
# Has the facility evaluated feasible alternatives to current practices?
®
n
n
n
# Does the facility provide all necessary secondary containment?
®
n
n
n
# Does the Plan include a BMP summary?
®
n
n
Cl
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
®
Q
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
®
n
n
Cl
# Does the facility provide and document Employee Training?
®
Cl
n
n
# Does the Plan include a list of Responsible Party(s)?
®
n
n
n
# Is the Plan reviewed and updated annually?
®
0
n
Q
# Does the Plan include a Stormwater Facility Inspection Program?
®
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
®n
n
n
Comment:
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
®n
fl
n
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
®
n
n
Q
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
n
®
n
Comment: Facility is in Tier One for pH and has completed all actions as required.
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
®
❑
❑
n
# Were all outfalls observed during the inspection?
moo
n
# If the facility has representative outfall status, is it properly documented by the Division?
n
n
■
n
# Has the facility evaluated all illicit (non stormwater) discharges?
®
n
❑
n
Comment:
Page: 3

w„
A&
�-
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, R E.
Govemor Director
December 4, 2012
Frederick Koerwitz
Kao Specialties Americas LLC
PO Box 2316
High Point, NC 27261
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Kao Specialties Americas LLC
COC Number NCG060003
Guilford County
Dear Permittee:
In response to your renewal application for continued coverage under stormwater General Permit NCG060000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCG060000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http-.//Portal.ncdenr.org/web/wq/ws/su/npdessw, (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterouaiity.org
An Equal OpponurrAy 1 Affirmative Action Employer
One
No Carolina
dtul'al1l`

Frederick Koerwitz
December 4, 2012
Page 2 of 2
Some of the changes include:
Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections B, C: Failure to perform analytical stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections 8, C: A lower TSS benchmark of 50 mg/I for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections 8, C: The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections 8, C. The term "Representative Storm Event" has been replaced by "Measurable Storm
Event," A measurable storm event is defined in the permit.
• Section D: If the permittee fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal request prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,
II
for Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files -
Winston -Salem Regional Office

0+
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCGO60000
CERTIFICATE OF COVERAGE No. NCG060003
STORM WATER
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,
Kao Specialties Americas LLC
is hereby authorized to discharge stormwater from a facility located at:
Kao Specialties Americas LLC
243 Woodbine St
High Point
Guilford County
to receiving waters designated as Kennedy Mill Creek, a class C waterbody in the Yadkin River
Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts 1, ll, Ili, and IV of General Permit No. NCGO60000 as attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 41), day of December, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Ail
NC®ENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Frederick Koerwitz
Kao Specialties Americas LLC
PO Box 2316
High Point, NC 27261
Dear Permittee:
Division of Water Quality
Charles Wakild, P. E,
Director
December 4, 2012
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Kao Specialties Americas LLC
COC Number NCG060003
Guilford County
In response to your renewal application for continued coverage under stormwater General Permit NCG060000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U,S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCGO60000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://portal.ncdenr,orgfweb/wq/ws/su/npdessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center,.Ralelgh, North Carolina 27699-1617
Location: 512 N. Salisbury St Rateigh, North Carolina 27604
Phone: 919-M7-63001 FAX; 919-8074-192
Internet: wy v.ncwaterauality.org
An Equal Op; vlucRy 1la hmalivu Aclion Em iypr
Nne
orthCaiv ina
,Natural lrf

Frederick Koerwitz
December 4, 2012
Page 2 of 2
Some of the changes include:
Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections B, C: Failure to perform analytical stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections B, C: A lower TSS benchmark of 50 mg/l for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections B, C: The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections B, C: The term "Representative Storm Event" has been replaced by "Measurable Storm
Event." A measurable storm event is defined in the permit.
• Section D: If the per fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal request prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,I_
for Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files
Winston-Salem Regional Office

rA
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060003
STORM WATER
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,
Kao Specialties Americas LLC
is hereby authorized to discharge stormwater from a facility located at:
Kao Specialties Americas LLC
243 Woodbine St
High Point
Guilford County
to receiving waters designated as Kennedy Mill Creek, a class C waterbody in the Yadkin River
Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, 11, 111, and 1V of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 41h day of December, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

NC®ENR
North Carol ina.Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 19, 2009
Ms. Ana P. Davis, Environment, Health, & Safety Manager
KAO Specialties Americas, LLC
P.O. Box 2316
High Point, North Carolina 27261
Subject: General Stormwater Inspection
NPDES General Permit No. NCGO60003
Kao Specialties Americas
Guilford County
Dear Ms. Davis:
On February 13, 2009, Jenny Graznak of this office performed a General Stormwater
Permit Inspection at Kao Specialties located at 243 Woodbine Street in High Point, North
Carolina. This facility holds General Stormwater Permit No. NCG060003 under the National
Pollutant Discharge Elimination System (NPDES) to discharge Stormwater from Food and
Kindred Products, etc. Kao Specialties is a specialty chemical company, manufacturing toner
binder, surfactants, and construction chemicals. You were present for the inspection. This type
of inspection consists of two basic parts: a review of facility files and self -monitoring data, and
an on -site inspection of the facility's outfalls. This particular inspection evaluated five (5)
different areas and observations from each area are addressed below:
1. Permit
The permit became effective November 1, 2007 and expires October 31, 2012. A copy of the
permit was available for review during the inspection.
2. Records/Reports
As required by the Permit, the facility has a Stormwater Pollution Prevention Plan (SPPP) that is
updated on an annual basis. The SPPP appeared to be thorough and complete, including a
location map of the outfalls and a site plan listing potential stormwater pollutants and best
management practices used at the site. Employee Training occurs once per year and was
documented in the SPPP.
3. Facility Site Review
This facility has a wastewater pretreatment plant that is staffed 24 hours a day, 7 days a week.
The site contains a tank farm, which is diked. Stormwater that collects in this area is directed to
the pretreatment system and ultimately transferred to the City of High Point. The site is also
equipped with a Hazmat Team and equipment in case of a chemical release. Kao Specialties
will be participating in a Hazmat drill on site, which will involve local emergency responders, in
2009. All totes and drums are organized and maintained in a covered shed. Kao Specialties
has a fleet of tanker trucks, but washing takes place off site.
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location. 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Intemet www.ncwaterquality.org
NorthCarolina
;Vatura!!y
An Equal Opportunity 1 Affirmative Action Employer

4. Effluent/Receiving Waters
Stormwater discharges from this site drain to Kennedy Mill Creek Yadkin Pee Dee River Basin.
There are three Stormwater basins on the property: one 15,000-gallon basin that drains to
Outfail 1 and two 10,000-gallon basins that drain to Outfall 2, via controlled release. If the water
in the basins shows signs of contamination, it is sent to the wastewater pretreatment plant
instead of released. All stormdrains on the property are labeled by basin.
5. Self -Monitoring Program
The stormwater permit requires semi-annual analytical and qualitative monitoring at stormwater
outfalls. The last analytical monitoring event took place in March 2007, and all sample results
were within the benchmark values listed in the permit. Meritech Laboratories performed the
analytical monitoring. Please note that the new permit does require semi-annual. analytical
monitoring at each of the outfalls, as opposed to that last permit which did allow monitoring in
the first and last years of the permit cycle if results were within benchmark values. Please
.familiarize yourself with the new permit requirements. All qualitative monitoring is performed
according to the specifications of the permit.
Please refer to the attached report for further details from the inspection. If you have any
questions concerning this report, please contact Ms. Graznak or me at [phone].
Sincerely,
Steve W. Tedder
Regional Supervisor
Surface Water Protection Section
cc: WSRO- �SVII;
Central Files — SWP
NPS Assistance and Compliance Oversight
t Ana P. Davis
Environment, Health,
& Safety Manager
r 'Em
E
PO Box 2316
A
1�^ A 878-4294`J�`-884-4390vis�ksaHc.com
r O Soo CIwLi4F5
♦MFoIC •5 LLL please vs�l our wa. s m
"IOr"j jiO"' ksallcL.com
www.

Compliance Inspection Report
Permit: NCG060003 Effective: 11/01/07 Expiration: 10/31/12 Owner: Kao Specialties Americas LLC
SOC: Effective: Expiration: Facility: Kao Specialties Americas LLC
County: Guilford 243 Woodbine St
Region: Winston-Salem
High Point NC 27261
Contact Person: Duke Wilson Title: Phone: [phone]
Ext.4357
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24-hour contact name Ana P Davis Phone: [phone]
Related Permits:
Inspection Date: 02/13/2009 Entry Time: 11:00 AM Exit Time: 12:30 PM
Primary Inspector: Jennifer F Graznak Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Stormwater
Permit Inspection Type: FoodlTobacco/Soaps/Cosmetics/Public Warehousing
Stormwater Discharge COC
Facility Status: ■ Compliant D Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

0
Permit: NCGC60003 Owner - Facility: Kao Speaatties Americas LLC
Inspection Date: 02/13/2009 Inspection Type: Stormwater Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■ n
n n
# Does the Plan include a General Location (USGS) map?
■
n
n
n
# Does the Plan include a "Narrative Description of Practices'?
■
n
n
n
# Does the Pian include a detailed. site map including outfall locations and drainage areas?
■
n
n
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
n
n
n
# Has the facility evaluated feasible alternatives to current practices?
■
n
n
n
# Does the faciJtyprovide all necessary secondary containment?
■
n
n
n
# Does the Plan include a BMP summary?
■
n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
n
n
# Does the facility provide and document Employee Training?
■
n
n
n
# Does the Plan include a list of Responsible Party(s)?
■
n
n
❑
# Is the Plan reviewed and updated annually?
■
n
❑
r!
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n
n
Has the Stormwater Pollution Prevention Ptan been implemented?
■
n
❑
n
Comment:
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
n
n
n
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
■
n
n
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
n
■
o
Comment: Please note that the new permit does require semi-annual analytical
monitoring at each of the outfalls, as opposed to that last permit which did allow
monitoring in the first and last years of the permit cycle if results were within benchmark
values.
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
®
n
n
n
# Were all outfalls observed during the Inspection?
■
o
n
n
# If the facility has representative outfall status, is it properly documented by the Division?
n
n
■
n
# Has the facility evaluated all illicit (non stormwater) discharges?
■
n
n
n
Page: 3

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060003
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,
KAO SPECIALTIES AMERICAS LLC
is hereby authorized to discharge stormwater Isom a facility located at
KAO SPECIALTIES AMERICAS LLC
243 WOODBINE ST
HIGH POINT
GUILFORD COUNTY
to receiving waters designated as Kennedy Mill Creek, a class C stream, in the Yadkin - Pee Dee River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, 11, III,
IV, V, and VI of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective September 1, 2002.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day August 23, 2002.
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Michael R Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
August 23, 2002
KEVIN COWAN
KAO SPECIALTIES AMERICAS LLC
PO BOX 2316
HIGH POINT, NC 27261
Subject: NPDES Stormwater Permit Renewal
Kao Specialties Americas LLC
COC Number NCO060003
Guilford County '
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG060000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983.
The following information is included with your permit package:
A new Certificate of Coverage
A copy of General Stormwater Permit NCG060000
A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division 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 DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment,'or
decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater
and General Permits Unit at [phone], ext. 578
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Winston-Salem Regional Office
e��
N5ERR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800.623-7748

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
111i710101AIIIN
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
ATTN: KEVIN COWAN
KAO SPECIALTIES AMERICAN LLC
PO BOX 2316
HIGH POINT, NC 27261
1•�
LTWAA
IT A;J
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL' RESOURCE5
Subject: NOTICE OF VIOLATION
FAILURE TO SUBMIT RENEWAL APPLICATION
KAO SPECIALTIES AMERICAN LLC
NCG060000
COC NUMBER NCG060003
GUILFORD COUNTY
Dear Permittee:
This letter is to inform you that, as of the date of this letter, the Division of Water Quality has not received a
renewal request for the subject permit certificate of coverage. This is a violation of NCGS §143.215A (c)(1) which
states "All applications shall be filed with the commission at least 180 days in advance of the date on which it is
desired to commence the discharge of wastes or the date on which an existing permit expires, as the case may be".
Any permittee that has not requested renewal at least 180 days prior to expiration or 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 § 143-215.6 and 33 USC 1251 et. seq.
In order to prevent continued, escalated action, including the assessment of civil penalties you must submit a
completed permit coverage renewal application to the attention of the "Stormwater and General Permits Unit" at
the letterhead address within ten (10) days of your receipt of this letter (renewal application enclosed). If the
subject discharge has been terminated, please complete the enclosed rescission request form. Mailing instructions
are listed on the bottom of the form. You will be notified when the rescission process has been completed.
Thank you for your prompt attention to this situation. If you have any questions regarding this matter, please
contact Aisha Lau of the central office Stormwater and General Permits Unit at 919-733-5083, ext. 578.
Sincerely,
for Alan W. Klimek, P.E.
Director, Division of Water Quality
cc: Stormwater and General Permits Unit Files
Central Files
Winston-Salem Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D,
Acting Director
Division of Water Quality
Decenther 27, 2001
KI?VIN COWAN
KAO SPE-CEAI E'IL S AME-MCAS LLC
PO BOX 2316
HIGH POINT, NC 27261
Subject: N1'DES Storntwater Permit Renewal
KAO SPECIALTIES AMERICAS LLC
COC Number- NCG060003
Guilford County
Dcar Perntiucc:
Your t"utility is Currently CovCred for storntwater discharge under General Permit NCG06(H)00. This hermit expires
on August 31, 2002. The Division staff is Currently in the process ot'rewriting this Permit and is SChcdulcd to have
the hCrntit reissuCd by late sunttner of 2002. Once the perntit IS ICiSSUCII, your facility would he eligible For
continued covCragc under 111C rcissucd PCI'111i1.
In order to,lssurC your Continual covermIQ under the general hermit, you must apply to the Division of Water
Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier. we are informing you in
adv,anCC that your permit will he expiring. L nCIOSed you Will find a General Permit Coverage Renewal
Application Form. The application must he completed and I-Clurncal by March 4. 2002 in order to IISsure Continual
CovcragC under the general perntit.
Failure to request rcncwal within this time period rimy result in :I Civil assessment nfat Icasl $250.00. Larger -
penalties nary he assessed depending on the delincluCrtcy of the recluCst. Dischar,C of stornlwmter Irons your Facilily
without Covcr1111c under a valid storntwalcr NPI)E 5 perntit would rnnSlitulC ,t violation ol' NCGS 143-215.1 all(]
Could result in aSSCSSntcnlS of Civil PCnaltiCS of up to S 10.000 Per day.
Plcase note that recent feclera] legislation has extended the "no exposure exclusion" to all open fors ol' industrial
l.Icilitics in any of the I I cale�k,a)ries of "storm water dischor4ges associawd with industrial activity." (excel)(
colls1ructlon aetiViliCS). If you FOCI your f aciGly can Certify at Condition ail "no exposure", i,e, the facihy induSO'Kil
nuatcrialS and oper,ations are not exposed to stormwater. you Can apply for 111C no cxposurC Cxclusion. For additional
information CantaCt the Central OfliCe Slorntwater Staff ntentber listed below or check the Storntwater & General
PCrntits Unit Web Site al http://h2o.Cnr.stale.11C.uS/su/sttlrinwater.htntl
11' the subject storntwalcr discharge 10 watCrs of the state has heen Eerntinated. please complete the enclosed
Rescission Request Form. Mailing instructions are listed net the bottom ol'the form. You will he 110tificcl when the
rescission process has been Completed.
If you LIVC any cluCMions I-cgardilt!g the perntit renewal proMlUres please contact Corey Basingcr ol' the
Winston -talent Regional Office at 336-771-4600 or Aislta L.,tu oi" the Ccnirul Office Stormwater Unit at (914)
733-5083. ext. 578
SIncercly.
Bradley BC1117CU. Supervisor
StormwatCr and GCncral PCrntits Unit
cc: Centl-al Files
Winston-Salem Regional Office
jA
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh. NC 27699-1617 [phone] Customer Service
1-800-623-7748

State of North Carolina
f Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
November 7, 2000
Mr. Kevin Cowan
Kao Specialties American LLC
PO Box 2316
High Point, North Carolina 27261
1 • �
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Modification — Name Change
Permit NCG060003
Kao Specialties Americas LLC
(FonnerlyHigh Point Chemical Corp.)
Guilford County
Dear Mr. Cowan:
In accordance with your request received November 6, 2000, the Division is forwarding the subject permit
modification. This modification documents the change in name at the subject facility. All other terms and conditions in the
original permit remain unchanged and in full effect. This permit modification is issued under the requirements of North
Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U. S. Environmental
Protection Agency dated December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit modification are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following
receipt of this letter. This request must be a written petition conforming to Chapter 150B of the North Carolina General
Statutes, filed with the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 2761 1-7447.
Unless such demand is made, this decision shall be final and binding.
This permit does not affect the legal requirement to obtain other permits which may be required by the Division of
Water Quality, the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local government
permit that may be required. if you have any questions concerning this permit, please contact Valery Stephens at the
telephone number or address listed below.
cc: Central Files
Sincerely,
PKerr T. Stevens
Winston-Salem Regional Office, Water Quality Section
NPDES Unit
Point Source Compliance Enforcement Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
919 733-5083, extension 520 (fax) 919 733-0719
VISIT US ON THE INTERNET @ htlp:I1h2o.enr,state.nc.usl [e-mail]

14
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060003
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,
KAO SPECIALTIES AMERICAS, LLC.
is hereby authorized to discharge stormwater from a facility located at
243 Woodbine Street
High Point, North Carolina
Guilford County
to receiving waters designated as Kennedy Mill Creels in the Yadkin -Pee Dee River Basin in accordance with the
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 11I, IV, V, VI and VII of
General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective November 7, 2000,
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day November 7, 2000.
f, Kerr T. Stevens, Director
rr Division of Water Quality
By Authority of the Environmental Management Commission

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
ALEXANDERSNAGE
HIGH POINT CHEMICAL CORP.
243 WOODBINE STREET
HIGH POINT, NC 27261
N1.9AA
A4
IDEHNF11
September 11, 1997
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG060003
Guilford County
Dear Permittee:
In response to your renewal application for continued coverage under the subject permit, the Division
of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit
is reissued 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 December 6, 1983.
The following information is included with your permit package:
■ A copy of the stormwater general permit.
■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit. This form must be completed and returned to the Division within 30 days of receipt of
this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
E Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program with outlines program components
and addresses frequently asked questions.
■ A corrected Certificate of Coverage if you indicated a name or address change on the Renewal
Form returned to the Division.
Your certificate of coverage is not transferable except after notice to DWQ. 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
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater Group at telephone number [phone]
Sincerely,
forA. Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
May 7, 1993
Alexander Snage
High Point Chemical Corporation
243 Woodbine Street
High Point, NC 2726I
&LT.9;TA
14
E3EHNF�
Subject: General Permit No. NCGO60000
High Point Chemical Corporation
COC NCGO60003
Guilford County
Dear Mr. Snage:
In accordance with your application for discharge permit received on September 9, 1992, we are
forwarding herewith the subject certificate of coverage 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
December 6, 1983.
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 Environmental Management. The Division of Environmental Management 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 Environmental Management 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 Mr. Bill Mills at telephone number 919n33-
5083.
cc:
ncerely
riginal Signed By
Coleen H. Sullins
A. Preston Howard, Jr., P. E.
Winston-Salem Regional Office
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal OpportunityAffirmative Action Employer

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
STORMWATER DISCHARGES
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,
High Point Chemical Corporation
is hereby authorized to discharge stormwater from a facility located at
High Point Chemical Corporation
243 Woodbine Street
High Point
Guilford County
to receiving waters designated as Kennedy Mill Creek in the Yadkin -Pee Dee River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, I1, I1I
and IV of General Permit No. NCGO60000 as attached.
This certificate of coverage shall become effective May 7, 1993.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day May 7, 1993.
original Sighed -by
Coleen H. Sullins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

. � .. ��. + �...-_� ` �� i fl. ~J 1 { 1' J J "'""•"l.. U r--• • / 'II K���
r_I J� ��f { •+ ' t` \ `` z }'t J �� �L_��� �`��'�� %`ti�1 1 } /,,1�
xm
'� � ~ � C "� \\ •� 1 lip � l �z`,�` �� � r i11 r �� •• `.:..�, •• t~u�
nL
'i:f i �:. ." •;, ,� 11 • f //' •- � ��; .fir• - ,�-' `^ , i � gr \.,..��:: ,�
�--- v �y� � ri- .,l f�' _+...- R\..�) %�•- ?' ' } : J ' � �;.�(••-_��vY':�• • � J � ,•J q✓ �/�, � . 1 � `.•v � f i
0 , `L 1 ;a • �'� __ .05YX
r 1 0 �� "�%' \ 1, I !I •� r+I ti,� I/'�
NORIO -:F
-• �� A�-l!�'�_�`�' 1�� � J�_. �`sas� ` _ -�1j ice_ IP
s -- � � }�i •l ._/i�\� ���� r��i '� �J ll' ' �.' � , I •:l: �`c\�� ,r ��.V-,� r, �G1 � � `1� � � �\
��''.r ( �� o�'i �- ' p'� moo= 2 y 1f' ��I • IIw V iA: fl ; =� i
V7
'1 � ,� �, •I a �� I w;, ��• �� �` \ �.,y� �,`1�,\.�... •aQl ,� d.
,`„j r./1\\��b�1 +:� �i`.��r' � -: � '.1'�/�,' �1�.//.i��% ra 6�' ��I _�I � �1..A��'• _•�=. '.;�, :�� !�.��V.� }
Mj
fr� j� � i�\ � ��� •J MN. '.1%p.� a 1 Y
LN fj1. GREENSBOR0 r6
�jr�i �
'} (
(HIGH POINT EAST),* ASHEBORO 21 MI
5055 ry NW

rAClLl'I•Y
I C. Ut�.
COUNTY
�—ul*ofj
NPDES
kf c -- UG
MAP
i8 NF
DSN FLOW
n! I"A
SUB BASIN
LATTITUDE
35°SS m"'
LONGITUDE
go, C)
RECEIVING STREAM % L
STREA -,o,)pe4A-// CLAS
C
DISCHARGE CLASS
slo1mwAer
EXPIRATION DATE.
A --�l - q�