NCG030008_COMPLETE FILE - HISTORICAL_20121228

STORMWATER-DIVISION CODING SHEET
RESCISSIONS.
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COMPLETE FILE- HISTORICAL
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Taft Stettinius & Hollister LLP
One Indiana Square, Suite 3500 / Indianapolis, IN 46204-2023 / Tel: [phone] / Fax: 317,713.3699 / www.taftlaw.com
Cincinnati / Cleveland / Columbus / Dayton e/p fIndianapolis / Northern Kentucky/ Phoenix
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+ Michael P. O'Neil
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317.713.3561
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October 19, 2012 1-0,.1�-en
NCDENR_— Division of Water Quality
`XG Bernard Simons
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Energy Conversion Systems Holdings and affiliates
Permit No. — NCG030008
Dear Mr. Simons:
This firm has assisted Energy Conversion Systems Holdings and its affiliates
("ECS") in connection with their cessation of operations and out -of -court liquidation of
all assets. ECS ceased all business operations by the spring of 2009 and sold off, either at
auction or in private sales, all of its remaining assets in North America; likewise all of its
ECS' foreign affiliates have been sold or closed. All business locations, including all
those located in North Carolina, were closed and sold or abandoned by no later than
September 2009. Accordingly, the attached invoices for permits are moot.
ECS has no more employees, so there is no person that can respond in any more
detail than this. We wish you well in the future and thank you for your time and attention
to this matter.
MPO:dw
1633659
Very truly yours,
Michael P. O'Neii
RECEIVED
DEC 2 8 2012
DENR-FAYETTEOLLE REGIONAL OFRCE

Taft/
Taft Stettinius & Hollister LLP
One Indiana Square, Suite 3500 / Indianapolis, IN 46204-2023 / Tel: 317.713,3500 / fax: [phone] / www.taftlaw.com
7 f` Cincinnati / Cleveland / Columbus / Dayton / Indianapolis / Northern Kentucky/ Phoenix
Michael P. O'Neil
317.713.3661
moneilOtaftlaw.com
S'n%( °/ KK
October 19, 2012
NCDLNR_- Division of Water Quality
' Attil: Bernard SimollLo
- 17 Mail Service Center
Raleigh, NC 27699-1617
RE: Energy Conversion Systems Holdings and affiliates
Permit No. — NCG030008
Dear Mr. Simons:
This firm has assisted Energy Conversion Systems Holdings and its affiliates
("LCS") in connection with their cessation of operations and out -of -court liquidation of
all assets. LCS ceased all business operations by the spring of 2009 and sold off, either at
auction or in private sales, all of its remaining assets in North America; likewise all of its
LCS' foreign affiliates have been sold or closed. All business locations, including all
those located in North Carolina, were closed and sold or abandoned by no hater than
September 2009. Accordingly, the attached invoices for permits are moot.
ECS has no more employees, so there is no person that can respond in any more
detail than this. We wish you well in the future and thank you for your time and attention
to this matter.
Very truly yours,
� r
IV11V1 ICI 11. V 1VGIl '
NIPO:CIw
1633659

Taft/
Taft Stettinius & Hollister LLP
One Indiana Square, Suite 3500 / Indianapolis, IN 46204-2023 / Tel: [phone] / Fax 317.713,3699 / vve .taftlavvcom
Cincinnati / Cleveland / Columbus / Dayton / Indianapolis/ Northern Kentucky/ Phoenix
Michael P. O'Neil
317.713.3561
moneileelaftlaw corn
May 9, 2012
VIA ELECTRONIC TRANSMISSION (mark brantleY(a),ncdenr eov)
Mr. Mark Brantley
Division of Water Quality
RE: Energy Conversion Systems Holdings and affiliates
Permit No. — NCG030008
Dear Mr. Brantley:
This firm has assisted Energy Conversion Systems Holdings and its affiliates
("ECS") in connection with their cessation of operations and out -of -court liquidation of
all assets. As you probably know by now, ECS ceased all business operations by the
spring of 2009 and has since sold off, either at auction or in private sales, all of its
remaining assets in North America; likewise all of its ECS' foreign affiliates have been
sold or closed. All business locations, including all those located in North Carolina, were
closed and sold or abandoned by no later than September 2009.
Accordingly, it is virtually impossible that any funds or unencumbered assets will
be available for distribution to unsecured creditors. Moreover, ECS has no more
employees, so there is no person that can respond in any more detail than this. We wish
you well in the future and thank you for your time and attention to this matter,
e truly o y,
'��. \
lchael P. O'ursNeil
MPO:dw
1633659

Michael F. Easley, Governor
Nil liam G. Ross Jr.. Secretary
North Carolina Department or Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
January 11, 2007
Norb Dickmann, Manager of Environmental Services
Energy Conversion Systems Holdings, LLC
One Morganite Drive
Dunn, NC 28334
Subject: COMPLIANCE EVALUATION INSPECTION
Energy Conversion Systems Holdings; LLC
Energy Conversion Systems
NPDES Stormwater General Permit-NCG030008
NPDES Wastewater General Permit-NCG500137
Harnett County
Dear Mr. Dickmann:
On January 10, 2007, I, Michael Lawyer from the Fayetteville Regional Office of the Division of
Water Quality, conducted a site inspection for the Energy Conversion Systems facility located at One
Morganite Drive in Dunn, Harnett County, North Carolina. A copy of the inspection reports is enclosed
for your review. Stormwater and wastewater from the facility drains to a municipal drainage ditch that
flows to the Black River, a Class C;Sw water located in the Cape Fear River Basin. The site visit and
file review revealed that the subject facility is covered by NPDES Storniwater General Permit-
NCG030008 and NPDES Wastewater General Permit-NCG500137.
Accordingly, the following observations were noted during the Division of Water Quality
inspection:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
implemented.
'es ® No ❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
IvesE No❑
3) Analytical Monitoring
Anal tical monitoring has been conducted and recorded in accordance with permit requirements.
Yes fa No ❑
INPorthCatrolina
.Alaturally
North Carolina Division of Water Quality 225 Green Street, Suite 714 Fayetteville. NC 28301-5043 Phone [phone] Customer Service
Internet: www.ncwaterpualitv.ore Fax [phone]
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Page 2
Mr. Dickmann
January II,2007
Other Observations:
Semi-annual monitoring of flow, p1l and temperature has been conducted per the conditions of the
general wastewater permit for non -contact cooling water discharges.
Please be advised that violations of the NPllES General Permit are subject to a civil
penalty assessment of up to $25,000 per day for each violation. If you or your staff has any
questions, comments, or needs assistance with understanding any aspect of your permit, please do not
hesitate to contact me at [phone].
Sincerely,
Michael Lawyer
Environmental Technician
Surface Water Protection Section
Enclosures (2)
cc: ,FRO -Surface Water Protection
Danny Smith-NPS-Assistance & Compliance Oversight Unit
Water Quality Central Files

r
Permit: NCG030008
SOC:
County: Harnett
Region: Fayetteville
Compliance Inspection Report
Effective: 09/01/02 Expiration: 08/31/07 Owner: Energy Conversion Sytems Holdings LLC
Effective: Expiration: Facility: Energy Conversion Systems
One Morganite Dr
Contact Person: Norb Dickmann
Directions to Facility:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Dunn NC 28334
Phone: [phone]
Certification: Phone:
Norb Dickmann Phone: [phone]
Inspection Date: 0111012007 Entry Time: 02:00 PM
Primary Inspector: Mike LawyerA�/'.x��
Secondary Inspector(s):
Exit Time: 03:40 PM
Phone: [phone]
Extj2t
33 2-5
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: U Compliant C) Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page:1

Permit: NCG030008 Owner - Facility: Energy Conversion Sytems Holdings LLC
Inspection Date: 01/10/2007 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
Facility manufactures metal brushes for electrical motors using a variety of materials including carbon, graphite and
copper. Inspection conducted with the assistance of Mr. Norb Dickmann, Manager of Environmental Services. Facility's
Stormwater Pollution Prevention Plan is detailed yet easy to follow and contains all permit required items. Analytical and
qualitative monitoring are being conducted per the conditions of the general permit. Facility has one outfall, which
conveys stormwater Flow from storm drains located throughout the facility into a municipal drainage ditch along the
backside of the property. Exposure of materials and waste products to stormwater has been limited through the use of
shelters, breezeways and "supersacks", which are large water resistant bags used in conjunction with the facility's dust
cll oectors to contain the fine metal shavings from the manufacturing process. Secondary containment is provided around
all above -ground storage tanks and the stormwater release valves are equipped with a lock.
After the inspection was completed, an assessment was conducted on the company's commutator facility that is located
directly across North Ash Avenue to determine if this separate facility needed coverage under a general stormwater
permit. While the commutator facility has pallets stored outside as well as a secondary containment structure with a
locked stormwater release valve around a used oil tank, there appeared to be no identifiable point of discharge. Based on
the lack of a concentrated stormwater discharge point, it was determined that the commutator facility does not require
l permit coverage at this time.
Page:2

Permit: NCG030008 Owner - Facility: Energy Conversion Sytems Holdings LLC
Inspection Date: 01/10/2007 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?
®
0
# Does the Plan include a General Location (USGS) map?
o
n
❑
n
# Does the Plan include a "Narrative Description of Practices"?
o
n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
®
n
11
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
®
n
Q
n
# Has the facility evaluated feasible alternatives to current practices?
®
n
Cl
n
# Does the facility provide all necessary secondary containment?
®
0
❑
0
# Does the Plan include a BMP summary?
®
Q
❑
[l
# 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
O
# Does the facility provide and document Employee Training?
®
0
Q
fl
# Does the Plan include a list of Responsible Party(s)?
©
❑
0
Q
# Is the Plan reviewed and updated annually?
®
n
Cl
0
# Does the Plan include a Stormwater Facility Inspection Program?
®
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
o
n
❑
n
Comment:
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
®
0
00
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? m 0 ❑ t]
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 ❑ ® n
Comment:
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?
®
0
0
0
# 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
Comment:
Page:3

United States Environmental Protection Agency
Form Approved
EPA Washington, D C 20460
OMB No 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fee Type
1 INI 2 151 31 NCG500137 111 121 07/01/10 117 181 GI 191 SI 201U
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 CA ------- ------------------- Reserved ------------- ----
671 169 701 s I 711 1 721 N I 731I I 174 75l I I I I I I 180
4- I I
• Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
ij2:00 PM 07/61/10
02/08/M
Energy Conversion Systems
Exit Time/Date
Permit Expiration Date
One Morganite Dc
Dunn NC 29334
03:40 PM 07/01/10
0-1/07/31.
Name(s) of Onsite Representalive(s)lTitles(s)/Phone and Fax Number(s)
Other Facility Data
Korb Dickmenn//910-892-9665 /9108916496
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Norb Dickmann,One Morganite Dr Dunn NC 283 4//919-892-B0B1/9]099296000
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
/Date 2
Mike Latuyer,;J / r�{�/� FRO W4//91t1-433-3300 Elt
?329
Signature of Management 0 A fjleviewer Agency/Office/Phone and Fax Numbers Date
A
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

It
NPDES yr/mo/day Inspection Type
NCG500137 I11 12I 07/01/10 I17 18I CI
Section Di Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Inspection conducted in conjunction with a routine stormwater inspection. Permit coverage is for the
discharge of non -contact cooling water. Since the facility does not use chlorine as part of a treatment
system and does not discharge air compressor condensate, the parameters to be analyzed consist only of
flow, pH and temperature. Mr. Norb Dickmann, Manager of Environmental Servies, provided copies of
monitoring data for these three parameters from 2004 through 2006.
Page # 2

r
'i
Y
Mr. Richard J. Morsch
Energy Conversion Systems Holdings, LLC
One Morganite Drive
Dunn, NC 28334
Dear Mr. Morsch::
Michael F. 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
January 7, 2005 DENR._FRO
JAN 1 12005
DWQ
Subject: NPDES General Permit NCG030000
Certificate of Coverage NCG030008
Energy Conversion Systems
Holdings, LLC
Formerly Morganite, Inc.
Harnett County
Division personnel have reviewed and approved your request to transfer coverage under the General Permit,
received on June 30, 2004.
Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General
Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of
North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at [phone], extension 502.
Sincerely,
ORIGINAL SIGNED BY
BRADLEY BENNETT
Alan W. Klimek P. E.
cc: DWQ Central Piles
Fayetteville Rebrional Office, Water Quality Section
Stormwater Permitting Unit
No thcarolina
No
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Intemet h2o.encstale.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
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STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030008
STORMWATER DISCIiARGES
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,
ENERGY CONVERSION SYSTEMS HOLDINGS, LLC
is hereby authorized to discharge stormwater from a facility located at
ENERGY CONVERSION SYSTEMS HOLDINGS, LLC
ONE MORGANITE DRIVE
DUNN
HARNETTCOUNTY
to receiving waters designated as the Black River, a class C SW stream, in the Cape Fear River Basin in accordance
with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, 1I, III, IV, V, and VI
of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective January 7, 2005.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day January 7, 2005.
ORIGINAL SIGNED BY
BRADLEY BENNETT
Alan W. Klimek, Director
Division of Water Quality
By Authority of the Environmental Management Commission

1
i
r
1
Richard J. Morsch
Energy Conservation Systems Holdings, LLC
One Morganite Drive
Dunn, NC 28334
Dear Mr. Morsch:
Michael F. 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
December 5, 2004
1fl�0 Jl
L�vv
Subject: NPDES General Permit NCG030000
Certificate of Coverage NCG030008
Energy Conservation Systems
Holdings, LLC
Formerly Morganite, Inc.
Harnett County
Division personnel have reviewed and approved your request to transfer coverage under the General Permit,
received on June 30, 2004.
Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General
Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of
North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at [phone], extension 502.
Sincerely,
Alan W. Klimek P. E.
cc: D WQ Central Files
Fayetteville Regional Office, Water Quality Section
Stormwater Permitting Unit
NotihCarolina
Ar turalljl
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.encstatemc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
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STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030008
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,
ENERGY CONSERVATION SYSTEMS HOLDINGS, LLC
is hereby authorized to discharge stormwater from a facility located at
ENERGY CONSERVATION SYSTEMS HOLDINGS, LLC
ONE MORGANITE DRIVE
DUNN
HARNETTCOUNTY
to receiving waters designated as the Black River, a class C SW stream, in the Cape Fear River Basin in accordance
with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, IV, V, and VI
of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective December 5, 2004.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day December 5, 2004.
Alan W. Klimek, Director
Division of Water Quality
By Authority of the Environmental Management Commission

WATF9
� —t
NORB DICKMANN
MORGANITEINCORPORATED
ONE MORGANITE DRIVE
DUNN, NC 28334
Dear Permince:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
August 23, 2002
Alan W. Klimek, P.E., Director
Division of Water Quality
". 2 US 9 200
Z
.ri
i 7
Subject: NPDES Stormwater Permit Renew
MORGANPPE INCORPORATED
CDC Number NCG030008
Harnett County
1n response to your renewal application for continued coverage under general permit NCG030000, 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 NCG030000
* A copy of the Analytical Monitoring Form (DMR)
'k 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 Bill Mills of the Central Office Stormwater
and General Permits Unit at [phone], ext. 548
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Fayetteville Regional Office
_e'n
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-623-7748

� —I
NORB DICKMANN
MORGANITE INCORPORATED
ONE MORGANITE DR
DUNN, NC 28334
Dear Permittee:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
'-N� GregoryJr Thorpe, Ph.D.
h 1 t4l,J Acting Director
--���D1vISlo fWater Quality
December 27. 2001 APR 1 2002
Subject: NPDES Stormwatcr Permit Renewal
MORGANITE INCORPORATED
COC Number NCG030008
Harnett County
Your facility is currently covered for stormwater discharge under General Permit NCG030000. "['his permit expires
on August 31. 2002. The Division staff is currently in the process of rewriting this permit and is scheduled to have
the permit reissued by late summer of 2002. Once the permit is reissued, your facility would he eligible for
continued coverage under the reissued permit.
In order to assure your continued coverage under the general permit, 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
advance that your permit will be expiring. Enclosed you will find a General Permit Coverage Renewal
Application Form. The application must be completed and returned by March 4, 2002 in order to assure continued
coverage under the general permit.
Failure to request renewal within this time period may result in a civil assessment of at least $250.00. Larger
penalties may be assessed depending on the delinquency of the request. Discharge of slormwater from your facility
without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to $10,000 per day.
Please note that recent federal legislation has extended the "no exposure exclusion' to all operators of industrial
facilities in any of the I I categories of "storm water discharges associated with industrial activity," (except
construction activities). If you feel your facility can certify a condition of "no exposure', i.e. the facilty industrial
materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional
information contact the Central Office Stormwatcr Staff nlcnlber listed below or check the Stormwatcr & General
Permits Unit Web Site al hap://112o.enr.state.tic.us/su/slormwater.hunl
If the subject stormwater discharge to waters of ere state 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.
If you have any questions regarding the permit renewal procedures please contact Ricky Revels of the Fayetteville
Regional Office at 910-486-1541 or Bill Mills of the Central Office Stormwatcr Unit at [phone], ext. 548
Sincerely,
Bradley Bennett. Supervisor
Stornlwaler and General Permits Unit
cc: Central Files
Fayetteville Regional Office
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
NCDERR
Customer Service
1- 800-623-7748

Morganite Incorporated
January 29, 1999
'I'o: Central Files
NCDENR
Division of Water Quality
Water Quality Section
PO Box 29535
Raleigh, NC 27626-0535
From: Norb Dickmann
CC: Ken Averette
NCDENR, Fayetteville Regional Office
ONE MORGANITE DRIVE
DUNN, NORTH CAROLINA 28334 USA
TELEPHONE [phone]
FAX [phone]
F EL B 2 1999
FAYETfEVILLE
REG. CFF ;CE
Re: Discharge Monitoring 12eport for NPDES Permit 4 NCG030008
The attached analysis of our slormwaler runoff was for a storm event in January 1999.
However, I ask you to please accept this analysis for reporting year 1998. 1 will sample
again later this year for reporting year 1999. 1 should have sampled a storm event in
1998, but failed to do so because there was not a representative storm event that I could
sample. II -YOU think about it, there are very fcw storm events ol'a representative rainfall
and duration that begin during the working day, Monday -Friday. It seems like most
storms start at night and drizzle through the following day. -rhe drought we had didn't
help. As it was, I had to sit for live hours on a Saturday night waiting for it to rain to gel
this sample and I drove in to work to Uo avail a couple of other Saturdays when rain was
lmccast but did not appear.
I had the lab run a full metals analysis. The permit requires analysis for lead only but we
know from our process and past analysis that the metals of concern are copper and zinc.
Cu Morgan

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE NO. NCG03 0DO
FACILITY NAME
PERSON COLLECTING SAMPLE(S) n c c ch
CERTIFIED LABORATORY(S) Cc c C.k v cLab #'71_
Lab #
Part A: Specific Monitoring Requirements
ec(
SAMPLES COLLECTED DURING CALENDAR YEAR: l`t 9't
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
COUNTY IA atz :e+--
PH-(-�L C)�i �S
�. )
(SIGN ERMITTEt OR DESIGNEE)
By this signature,) certify that this report is accurate
complete to the best of my knowledge
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? _yes ')6o
(if yes, complete Part B)
STORM EVENT CHARACTERISTICS:
Date z:s `(°i
Total Event Precipitation (inches): I ch
Event Duration (hours): '> 1 z-
1 eve
(if more than one storm event was sampled)
Date
Total Event Precipitation (inches):
Mail Original and one copy to:
Attn: Central Files
DEHNR
Division of Environmental Mgt.
P.O. Box 29535
Raleigh, NC 27626-0535
Form MR03
Page I of 2

Footnotes:
1 Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations, manufacture semiconductors, manufacture electronic crystals, or
manufacture cathode ray tubes. For purposes of this permit the definition of Total Toxic Organics is that definition contained in the EPA Effluent Guidelines for the facility subje
to the requirement to sample (for metal finishing use the definition as found in 40 CFR 433.11; for semiconductor manufacture use the definition as found in 40 CFR 469.12; for
electronic crystal manufacture use the definition as found in 40 CFR 469.22; and for cathode ray tube manufacture use the definition found in
40 CFR 469.31).
Facilities that develop a solvent management plan to be incorporated into the Stormwater Pollution Prevention Plan may make a request to DWQ that monitoring of total toxic
organics be waived. The solvent management plan shall include a list of the total toxic organic compounds used; the method of disposal used instead of dumping, such as
reclamation, contract hauling, or incineration; and the procedures for assuring that toxic organics do not routinely spill or leak into the stormwater. For those facilities allowed sui
a waiver, the discharger shall include the following signed certification statement on the discharge monitoring report:
"Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit monitoring requirement for
total toxic organics (TTO), I certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the
stormwater or areas which are exposed to rainfall or stormwater runoff has occurred since filing the last discharge monitoring report. I
further certify that this facility is implementing the solvent management plan included in the Stormwater Pollution Prevention Plan."
Name (please print)
Title (please print)
Signature
Date
"1 certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
in a post t t f-fines and imprisonment for knowing violations."
i
(Date)
Form MR03
Page 2 of 2

a
STORMWATER DISCHARGE OUTTALL (Sll0)
QUALITATIVE MONITORING REPORT
Certificate of Coverage No. NCG 030005
Facility Name:_�� o •2 q f ,< . _ 1, r,,._ e.9
County: Phone No.: (�4/6)
Inspector: /\•'Dr L
Date of Inspection: it 23
lay this signature, 1 certify that this report is accurate and complete to the best of my
kt :eg e:
(Signature o nittee or Designee)
Outfall Description
Outfall No.: t1C71 Structure (pipe, di(ch, etc.):
Receiving Stream: C.t% ,,,) e (l C Qa
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:
I �
3. Odor
Describe any distinct ordors that the discharge may have (i.e. smells strongly of oil, weak
chlorine odor, etc.):
n- cue
8/22/97

Y
4. Clarity
Choose the number which best describes the clarity of the discharge where I is clear and .
10 is very cloudy:
1 2 � 4 5 6 7 8 9 10
5. Floating Solids
Choose the number which best describes the amount of floating solids in the stonuwater
discharge where I is no solids and 10 is the surface covered in floating solids:
1 3 4 5 6 7 8 9 10
A
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the
stormwater discharge where I is no solids and 10 is extemely muddy:
1 `2� 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? YES NO
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? YES NO
9. Other Obvious Indicators of Stornmater Pollution:
List and describe:
NOTE: Low clarity, high solids and/or the presence of foam or oil sheens may be
indicative of pollutant exposure. These conditions may warrant further
investigation.
8/22/97

N
COMPUCHEM
a division of Liberty Analytical Corp.
28/JAN/99
MORGANITE CORP.
ATTN: NORB DICKMAN
1 MORGANITE DRIVE
DUNN, NC 28334
Subject: Report bf Data - Account Number# 501177 Order# 34094
;,$ iiJTTN: N04B DICKMAN
4 tea_
nclosed are the results of analytical work performed in accordance
J,i:with the referenced account number.
This report covers 1 sample(s) appearing on the attached listing.
Thank you for selecting CompuChem Environmental for your sample
analysis. If you should have questions or require additional
analytical services please contact your representative at
1-800-833-5097.
Si rely,
Compl em Environmental
a division of Liberty Analytical
Attachment
501 Madison Avenue n Cary. N.C. 27513 a Tel: [phone] a Fax: -19-379-4050

COMPUCHEM
a division of Liberty Analytical Corp.
28/JAN/99
MORGANITE CORP.
ATTN: NORB DICKMAN
1 MORGANITE DRIVE
DUNN, NC 28334
ACCOUNT #:' 501177
SAMPLE —ID
MORGANITE
TOTAL NUMBER OF SAMPLES =
RECEIPT DATE
1/25/99
1
501 Madison Avenue ■ Cary, N.C. 27513 a Tel: [phone] s F:z: 919-379-4050

CompuChem
A Division of Liberty Analytical Corp.
501 Madison Avenue
Cary, NC 27513
January 28, 1999
Mr. Norb Dickman
Morganite Corporati
1 Morganite Drive
Dunn, NC 28334
Dear Mr. Dickman:
We at CompuChem are pleased to provide our report for the analysis you requested.
Data for the following samples are enclosed:
Client ID CompuChem Analysis Case Description of
Number ID Number Code Number Work Requested
MORGA_NITE 926860 4006 34094.1 Oil & Grease in Water
1191 Fluoride in Water
1196 Total Suspended Solids
Thank you for selecting CompuChem Environmental for your sample analysis.
If you have any questions concerning this report or the analytical methods employed,
please contact your Sales Representative at 919-379-4100.
SiVJE
,
PT MANAGER
1

U.S. EPA - CLP
1 EPA SAMPLE NO.
INORGANIC ANALYSES DATA SHEET
Lab Name: COMPUCHEM ENV. CORP. Contract: SW-846 I
MORGANITE
Lab Code: COMPU Case No.: 34094
Matrix (soil/water): WATER
Level (low/med): LOW
SAS No.: SDG No.: 00001
Lab Sample ID: 926860
Date Received: 01/25/99
°s Solids: _0.0
Concentration Units (ug/L or mg/kg dry weight): UG/L
Color Before:
Color After:
CAS No.
Analyte
Concentration
C
_
B
U
_
U
U
B
B
_
_
_
B
U
B
_
B
B
_
U
B
Q
M
7429-90-5
74",-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-70-2
7440-47-3
7440-48-4
7440-50-8
7439-89-6
7439-92-1
7439-95-4
7439-96-5
7439-97-6
7440-02-0
7440-09-7
7782-49-2
7440-22-4
7440-23-5
7440-28-0
7440-62-2
7440-66-6
Aluminum_
Antimony_
Arsenic_
Barium_
Beryllium
Cadmium_
Calcium_
Chromium_
Cobalt_
Copper_
Iron
Lead
Magnesium
Manganese
Mercury_
Nickel_
Potassium
Selenium_
Silver_
Sodium_
Thallium
Vanadium_
Zinc
692
4.7
1.7
33.6
0.20
1.0
5640
1.9
2.2
786
293
297
449
15.6
0.10
2.8
1630
3.1
1.0
4940
2.9
3.6
581
N
P
P
P
P
P
P
P
P
P
P
P
P
P
P_
CV
P
P
P
P
P
P
P
P
_N_
COLORLESS
Clarity
Before:
CLEAR
Texture:
COLORLESS
Clarity
After:
CLEAR
Artifacts:
Comments:
Duplicate (MORGANITED)
FORM I - IN SW846
1

OIL & GREASE IN WATER ANALYSIS
SUMMARY REPORT
ITEM SAMPLE COMPUCHEM CONCENTRATION REPORTING LIMIT
NO. IDENTIFIER NUMBER (mg/L) (mg/L)
1. MORGANITE
2.
926860 BRL
BRL = BELOW REPORTING LIMIT
NWR = NOT WITHIN RANGE
Reviewed by/IDa: Q%
c,
2.5
2

FLUORIDE IN WATER ANALYSIS
SUMMARY REPORT
ITEM SAMPLE COMPUCHEM CONCENTRATION REPORTING LIMIT
NO. IDENTIFIER NUMBER (mg/L) (mg/L)
I. MORGANITE
926860 0.169
BRL = BELOW REPORTING LIMIT
NWR = NOT WITHIN RANGE
Reviewed by/ID#:
Date:
0.1
3

TOTAL SUSPENDED SOLIDS ANALYSIS
SUMMARY REPORT
ITEM SAMPLE COMPUCHEM CONCENTRATION REPORTING LIMIT
NO. IDENTIFIER NUMBER (mg/L) (mg/L)
MORGANITE
926860 BRL
BRL = BELOW REPORTING LIMIT
NWR = NOT WITHIN RANGE
Reviewed by/ID#: c mk Q , V1 �c� / a l �
4
Date: —4-4—(�7

® COMPUCHEM
® ENVIRONMENTAL
® ad`"``°"°`Lfben'^''yticta'Corp.
CHAIN -OF -CUSTODY RECORD
501 Madison Ave.
Can', NC 27513
Ship to: Project Name:
1-800-833-5097
Sampler Name:
Carrier: Alrbill No.: Sampler Signature:
BO% k1 t. Sunaca Water 6. Trip Blank
Box P2: A. Ha E. Ice Only
Box tla: F. Filtered
2. Ground Water 7, Oil
B. HNOs O. Other
U. Unfiltered
3, Leer3Mate 8. Waste �"�
C. NaHSOx N, Not Preserved
4. Rossi. 9. Other�IlJ.", LvnlL
D.NasSp03
5. Soil / Sediment t Sludge
No. 02479
-
Field Point -of -Contact:
Telephone No.:
Sampling for 1 — complete? Y
1ect
r N ( See Note 1
Project -specific (PS) or Batch (B) QC:
Box ifd: C. CLP 3190 R. Redlologlml
TCLP
series O. Od erL
�#5FLighT.
edlumbog
lox Cont. CLP
w
NOW [7J: temples stored fA de after date re "'agania aukeae regui. A. ID Ilmaed to maxhnum at slx cherapers.
Ys port matted at no ems charya, Nob (al: All led cople_ of data destroyed attar we years unless c ient rnuests and pays tw retum M copes: annual storage lea billed in January p year six.

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
JAN 24 1995
GENERAL PERMIT NO. NCG030000
CERTLW CA'bE ffF (C LERAGE NO. NCG03 QQQ8
gyYrrrr �i i F c�l(`N OFFICE
FAC LITYVNAMRE�5rg�rle S�C,�rPar��e.Q
PERSON COLLECTEN AMPLEO i lofc>3 d< nay
CERTIFIED LABORATORY(S) LJe1' ewl icro U
Part A: SDecific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR: I `M
(all samples collected during a calendar year, shall be reported no later than January 31 of the
following year)
COUNTY En
Dn z& PI 'IZ=99 4 S
ib#(7_ 0 6 fl— �, V 1 ,NEEn. l i 5 qs
b # I PERM R DE )
By this signature, I certify that this report is accurate and complete
to the best of my knowledge
Oudaa
Date'.
50050
00400
00S56
I 110720 ;i
00950 !
01027
01034
101042
0105Fi'
01043
010671 101077::01092
78141::
No
Samafe
Total
Dlt
GO and
':TnWl
Cyanide
k7uorld ;
Cadmium
Chromium
Copper
Gold :
Iron
Nickel
S0er
Glac.
Total
Collected
6144
Grease
Suspcaded,
Toxic
Sottds
O anlcs3
blGi.
watt
m
1.
m
u ✓1 ::
u !t :l
E
u t
u"
1;:
u
6
6.
< 5.0
O
< S
< 10
7
<SO
306
<Z.o
't
n�
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? _ yes ,-no
( yes, complete Part B)
is: venicie maintenance Act]
STORM EVENT CHARACTERISTICS:
u
Total Event Precipitation (inches): /1ovrnX• 0.3S it
Event Duration (hours): av�
(if more than one storm event was sampled)
Total Event Precipitation (inches):
Event Duration (hours):
-- FI cw FcensureH.e.�-F 1-�-�<P Fz•-.leg ' Flow war
NOI- h-etls�rc cQ .
Mail Original and one copy to:
Attn: Central Files
Division of Environmental Mgt.
DEHNR
P.O. Box 29535
Raleigh, NC 27626-0535
Fonn NIR03

l -1-or facilities not using or storing cyanide, the facility may make certification to the effect that cyanide is not used or stored at the facility and thus
obtain a waiver of the cyanide sampling requirement.
By this signature, I certify that cyanide is not being used or stored at this facility
L For facilities not using or storing fluoride, the facility may make certification to the effect that
obtain a waiver of the fluoride sampling requirement.
By this signature, I certify that fluoride is not being used or stored at this facility
fluoride is not used or stored at the facility and thus
3 Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations, manufacture semiconductors,
manufacture electronic crystals, or manufacture cathode ray tubes.
For purposes of this permit, the definition of Total Toxic Organics is that definition contained in the EPA Effluent Guidelines for the facility subject
to the requirement to sample (for metal finishing use the definition as found in 40 CFR 433.1 l; for semiconductor manufacture use the definition as
found in 40 CFR 469.12; and for electronic crystal manufacture use the definition as found in 40 CFR 469.22).
Facilities that develop a solvent management plan to be incorporated into the stormwater pollution prevention plan may make a request to DEM that
monitoring of total toxic organics be waived. The solvent management plan shall include as a minimum lists of the total toxic organic compounds
used; the method of disposal used instead of dumping, such as reclamation, contract hauling, or incineration; and the procedures for assuring that
toxic organics do not routinely spill or leak into the stormwater. For those facilities allowed such a waiver, the discharger shall sign the the following
certification statement:
"Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit
monitoring requirement for total toxic organics (TTO), I certify that, to the best of my knowledge and belief, no
dumping of concentrated toxic organics into the stormwater or areas which are exposed to rainfall or stormwater runoff
has occurred since filing the last discharge monitoring report. I further certify that this facility is implementing the
solvent management plan included in the Stormwater Pollution Prevention Plan."
Name (please print) \\
Title (please print) N
Signature Date
v Applies only for facilities at which fueling occurs.
5 Detergent monitoring is required only at facilities which conduct vehicle cleaning operations.
I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false inform 'on, mcluoing the possibility of
fines and imprisonment for knowing violations."
re of
Fonn MRn3

Page 1 WEBB TECHNICAL REPORT Work Order # 94-11-877
Received: 11/19/94 12/07/94 15:20:32
REPORT MORGANITE, INC. PREPARED Webb Technical Group, Inc. 1
TO ONE MORGANITE DR. BY 4320 Delta Lake Drive
DUNN, NC 28334 Raleigh, NC 27612 cY
ATTEN MR. NORB DICKMAN
CLIENT MORGAN SAMPLES 1
COMPANY MORGANITE, INC.
FACILITY DUNN, NC
WORK ID WW MONITORING
TAKEN
TRANS DELIVERY, CLIENT
TYPE WASTEWATER
P.O. # NAD
INVOICE under separate cover
CERTIFIED BY
ATTEN Client Services
PHONE [phone] CONTACT G FLYNT
We are pleased to Provide this certified report of analysis
SAMPLE IDENTIFICATION TEST CODES and NAMES used on this workorder
O1 WW OUTFALL 11/19 AG SILVER BY ICP
CD CADMIUM BY ICP
CR TOTAL CHROMIUM BY ICP
CU COPPER BY ICP
FE IRON BY ICP
FLUOR FLUORIDE
NI NICKEL BY ICP
OO GGWW OIL AND GREASE - WATER
PB LEAD BY ICP
TSS TOTAL SUSPENDED SOLIDS
ZN ZINC BY ICP

:age 2 WEBB TECHNICAL REPORT Work Order # 94-11-877
Received: 11/19/94 Results by Sample
SAMPLE ID WW OUTFALL 11/19 SAMPLE # 01 FRACTIONS: A,B,C
Date & Time Collected 11/19/94 16:30:00 Category
AG <0.01 CD <0.005 CR <0.01 CU 0.657 FE 0.306 FLUOR_ 1.50
MG/L MG/L MG/L MG/L MG/L MG/L
NI <0.02 O G W <5.0 PB <0.05 TSS_ 6.36 ZN 0.700
MG/L MG/L MG/L MG/L MG/L

P
4320 Delta Lake Drive • Raleigh, NC 27612
[phone] [phone]/FAX [phone]
A I _
Chain of Custody/Analysis
Request Form
WTG Order #
'Page I Of 1
3Additional Sampling/Form
Information Provided: _Yes )�_No
'Client/Facility jV/l9f-!j0-Jr4-e-
C
P.O. # D��
'Wastewater Specific Samples
Contact /�NAfLB
��c(c/�� ^�/J
Collected by: NA'b L/W
NPDES Permit Number
Address DNP
Pipe Number
City
State A) Zipcode 2933 y
Toxicity Testing: NC Mini chronic
Phone !?11) PA
9L1I Fax c/'I ORg2
IUCD
Effluent:
ANA SIS REQUESTED
�
'SAMPLE TYPE
'SAMPLE COLLECTION
a
o
V
Y
°SM
Composite
Start :End
o
�
'SAMPLE IDENTIFICATION
Code
Timel Flow Grab
Date/Time Date/Time Interval Temp
°REMARKS
WW
lao
3oPh
ov r
y3ee�
x
10Total # of Samples:
'.Total # of Containers:
°Sample Matrix (SM) Codes:
WW: Wastewater; GW: Groundwater; DW: Drinking Water; SL: Sludge S: Soil; HW: Hazardous Material'; F: Food'; O: Other'
• Please identify specifically under "Remarks"
SHIPMENT
"
RECEIVING
Condition of Sample
Relinquished bv
Received by
Date
Time
Received fro nl Temperature: '0/kJ °C
J
AM/PM
Received by:
pH Monitoring:
A"
Date: J� Time:
Perserved Bottles
: 2� 1M Non -Preserved Bottles