NCG170023_COMPLETE FILE - HISTORICAL_20060503

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STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
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DOC TYPE
CT' HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑�Z�
YYYYMMDD

11
April 28, 2006
Highlands
Environmental
Solutions, Inc. 9405 Greenfield Drive; Raleigh, NC 27615
Phone: [phone] / Fax: [phone] / www.hesnc.com '
Mr. Ronald Boone
North Carolina Department of Environment and Natural Resources
Raleigh Regional Office
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Submittal of Interim Report
Glenoit Fabrics (HG) Corporation; Tarboro; Edgecombe County; North Carolina
HES Project#25040
Dear Mr. Boone:
On behalf of Glenoit Fabrics (HG) Corporation (Glenoit), Highlands Environmental Solutions, Inc. (HES) is
submitting this correspondence as an interim report regarding a release of #5 fuel oil at the above
referenced site. As you are aware, Eastern Environmental Management, LLC (EEM) and HES have been
retained by Glenoit to provide environmental assessment and remediation services associated with the
subject petroleum release. On April 7, 2006, HES submitted correspondence requesting an extension of
the due date for remediating the subject release. Based on correspondence from your office dated April
20, 2006, it is our understanding that the requested extension will not be granted.
Representatives of EEM and HES first visited the Glenoit site on April 13, 2006. During this site visit,
EEM and HES personnel inspected the subject stormdrain outfall, as well as, the boiler room and fuel
storage area. Fuel oil (#5 fuel oil) is stored in an underground storage tank (UST) located just outside the
boiler room. The fill spout of the UST is situated within an aboveground concrete secondary containment.
During the site visit, minor staining was observed within the secondary containment, with very minor
staining observed on the ground surface outside of the containment. Petroleum product is delivered to
the boiler system via underground lines that were not accessed during the site visit.
Inside the boiler room, trench floor drains were observed around the boiler units. Steam emanated from
the water observed in the floor drains. Based on information provided by Glenoit personnel, the floor
drains capture water (condensate, blow -down, etc.) from the boiler units. This water discharges to an
underground pipe, which in turn discharges to an underground sump. The sump discharges to an
underground stormdrain pipe, which discharges in a wooded area approximately 150 yards to the North
of the boiler room. It is this stormdrain discharge that is the subject of the April 20, 2006 correspondence,
as well as, an earlier NOV. Apparent petroleum leaks (Le stained pavement, black product on fuel lines,
etc.) were observed inside the boiler room during the April 13, 2006 site visit.
While the exact cause of the release has not been definitively determined and is still being investigated by
HES, it is suspected that the petroleum impacted soil observed at the stormdrain outfall originated from

Mr. Ronald Boone April 28, 2006
Glenoft Fabrics (HG) Corporation; Tarboro, North Carolina Page 2
the boiler room area. While a release of product from the subject UST is possible, given the viscous
nature of #5 fuel oil, it is considered highly unlikely that fuel oil released from the UST could have
migrated to the stormdrain outfall under natural conditions. A more plausible release scenario is as
follows:
1. A petroleum release(s) occurs inside the boiler room;
2. The petroleum enters the floordrain system, and co -mingles with hot water from the boiler units;
3. The petroleum and hot water are discharged to the underground concrete pipe. The concrete
pipe serves as to insulate the water and fuel, allowing the fuel oil to remain fluid; and,
4. The released fuel is discharged at the stormdrain outfall.
Additional information will be required to confirm this release scenario.
On April 25, 2006, EEM and HES mobilized to the site to remediate petroleum -impacted soil at the
stormdrain outfall. During excavation, dark stained soil/sediment was observed downgradient of the
stormdrain outfall. During remediation activities, approximately 111 tons of petroleum -impacted soil were
excavated, and transported to Soil Works, Inc. for disposal via land application. The resulting excavation
measured approximately 40 feet long, with widths varying from approximately eight to 16 feet, and depths
varying from approximately 3.5 to 4.5 feet. Neither the stormdrain pipe nor soil immediately beneath the
y pipe was excavated during remediation activities. Apparent groundwater was encountered in a sandy
clay unit, at a depth approximately four feet below grade. Neither free -product nor obvious hydrocarbon
j sheens were observed on groundwater entering the excavation. During excavation activities, random soil
samples were collected for field screening purposes using a flame ionization detector (FID). Upon
0 5 completion of excavation activities, 12 soil samples were collected from the floor and sidewalls of the
excavat
on. These
les were
tted to Paradigm
abs (PAL) fr
pbT y0 analyss of
',R" total oil land grease, y PMethod 9071. Additionally, one composite soil sampleo
owas coollec ed froml the
Sa' excavated soil for disposal profile analysis (Gasoline range organics, by Method 5030; diesel range
organics, by Method 3545; and total oil and grease, by Method 9071). We anticipate receipt of laboratory
analytical data for these samples within two weeks. A formal report summarizing remediation activities,
as well as, laboratory analytical data, will be prepared upon receipt of the analytical data.
z`y Observations made during outfall remediation activities suggest the petroleum impacted soiUsediment at
the stormdrain outfall resulted from several small release events over time, rather than one release event.
This supports the proposed release scenario with relatively small volumes of petroleum entering the
PP P po Y P 9
<✓ floordrain/stormdrain system over time, and being discharged at the subject outfall.
Additional site investigation activities are necessary at this site to (1) confirm the cause of the release, (2)
ensure future releases do not occur and (3) confirm that all petroleum -impacted media have been
remediated. In accordance with the provisions of your April 20, 2006 correspondence, Glenoit will be
performing the following actions, in association with the subject #5 fuel oil release:
1. Identification and Repair of all Fuel Leaks. All existing fuel leaks and/or potential fuel leaks inside
the boiler room will be identified and repaired
2. UST System Testing. Tightness testing will be conducted on the #5 fuel oil UST and all
associated product lines to verify their integrity.
3. Cleaning of Flooddrain System. All liquid within the floordrain system inside the boiler room will
be removed, and the floordrain system properly cleaned to remove any accumulated residue
(fuel, grease, sludge, etc.) that may be accumulated. All evacuated liquids and/or solids should
be properly disposed.
4. Inspection/Remediation of the Stormdrain Pipe. The subject stormdrain pipe from which the
release emanated will be inspected and properly remediated. Potential options for accomplishing
this task include: Video inspection of the interior of the pipe, hydraulic jetting of the pipe to
remove sludge and debris, and/or removal and replacement of the pipe.
5. Assessment of Potential Petroleum Impacted Soil Upgradient of the Outfall Area. Additional soil
assessment activities will be performed upgradient of the outfall to determine if additional areas of

Mr. Ronald Boone April 28, 2006
Glenoit Fabrics (HG) Corporation; Tarboro, North Carolina Page 3
petroleum -impacted soil are present. These assessment activities will be conducted based on
the results of UST system testing and/or inspection/remediation of the stormdrain pipe.
6. Review of Outtall Remediation Data. HES will review field and laboratory analytical data to
confirm the success of soil remediation activities conducted at the stormdrain outfall. Additional
assessment and/or remediation activities may be recommended based on these data.
7. Preparation and Submittal of a Site Investigation Report. A project report detailing the findings of
site investigation activities will be prepared.
Glenoit will proceed in a time efficient manner to address the concerns of the NCDENR with regards to
the subject release. However, several of the proposed action items will involve subcontractors, and/or
time for receipt and review of necessary analytical data. HES proposes to submit the subject Site
Investigation Report to the NCDENR no later than July 1, 2006. Interim progress reports may be
prepared if requested by the NCDENR.
If there are any questions or concerns regarding this correspondence, or the project in general, please
contact Mr. Joe Beaman (HES) at [phone], or Mr. Jerry Howard (Glenoit) at 252-641-6034.
Sincerely,
Highlands Environmental Solutions, Inc.
Joe Beaman, P.G.
Principal Geologist
cc: Mr. Jerry Howard — Glenoit Fabrics (HG) Corporation
Mr. Johnny Baines — Eastern Environmental Management, LLC
File

GL EIN Q ' T GLENOIT FABRICS [HGJ CORPORATION
April 27, 2006
Ron Boone
Environmental Technician
1628 Mail Service Center
Raleigh, N C. 26799-1628
Mr. Boone:
On Tuesday, April 25, 2006 Highlands Environmental Solutions, Inc. and Eastern
Environmental Management were on site to clean up the oil spill.
They dug out the contaminated soil and replaced it with 100 tons of new soil. Mr. Joe
Beaman is in the process of writing the final report once he has all of his information. He
can be contacted at [phone].
In the mean time we have found the cause of the spill and will seal off the need be
drainage pipes so that if the problem occurs again, the oil will be contained inside the
building.
The problem occurred when an oil line burst and drained into the storm water pipe. We
thought we had contained the oil.
Enclosed are pictures of the clean up.
Sincerely,
Jerry Howard
Glenoit Fabrics (HG) Corporation
3 001 NORTH MAIN STREET I P.0. OOX. 1,0111 fA R R 0 R 0, NC 2I885 T 252 823.77 98 F 252 641. 5195

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20 April 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jerry Howard
Plant Manager
Glenoit Fabrics [HG] Corporation
3001 North Main Street
P.O. Box 4011
Tarboro, NC 27886
Subject: NOTICE OF INTENT TO ENFORCE
NOV-2006-OC-0018
3001 North Main Street
Tarboro, North Carolina, Edgecombe County
Dear Mr. Howard:
.
a. t6
Michael F. Easley, Govevioi5>, o0
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
The NC Division of Water Quality (DWQ), Raleigh Regional Office (RRO), received a letter
from Mr. Joe Beaman, of Highlands Environmental Solutions, on 04/12/2006, requesting an extension
of the deadline placed upon Glenoit Fabrics [HG] Corporation to clean up the oil spill referenced in the
subject NOV. The original spill clean up deadline set by the subject NOV was 04/20/2006.
Yl!
The following milestones regarding this issue are hereby noted:
1. 03/09/2006 - Mr. Ronald Boone, of the RRO, observed a spill of what was believed to be
a #5 heating oil, located in the stormwater outfall #2 (SO2), of Glenoit Fabrics [HG]
Corporation's 3001 North Main Street plant, in Tarboro, North Carolina, Edgecombe
County. Mr. Boone discovered the spill during a routine annual Compliance Evaluation
Inspection (CEI) of the stated facility's stormwater permit, NCG170023.
2. 03/17/2006 - Mr. Boone and Mr. Jimmie Greer, also of DWQ RRO, revisited the site. At
this point, Glenoit had attempted to clean up the spill and took post clean up samples for
oil/grease analysis. Mr. Greer also took two post clean up samples for oil/grease analysis
at state labs. Detailed inspection of the clean up site revealed further contamination. Mr.
Boone and Mr. Greer then suggested that you commission an independent consultant to
perform the required clean up.
3. 03/21/2006 - The subject NOV was drafted and sent by DWQ to Glenoit Fabrics,
notifying you of the specific statutes violated and Glenoit's legal obligations regarding
spill clean up. This NOV set the clean up deadline of 04/20/2006.
[���`ttCaroina
Naturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Intemee ,,_,g.ns ,alvulwl i[ye or_ Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]

4. 04/03/2006 - DWQ received a letter from you dated 03/29/2006. In this letter you stated r!
that it was a follow-up to the inspection of 03/06/2006. Be it known that we performed
the aforementioned inspection on 03/09/2006, not 03/06/2006. You also stated in this
letter that Eastern Environmental Management would commence oil spill clean up
activities on 04/05/2006.
5. 04/06/2006 - Mr. Boone and Mr. Shannon Langley, also of DWQ RRO, again revisited
the site to check on the progress of clean up efforts. Clean up had not yet begun. The
results of the samples taken by Glenoit were reviewed, showing approximately 6,800
milligrams per kilogram (mg/Kg) of oil/grease. Mr. Boone then stressed the importance
of starting clean up as soon as possible.
6. 04/12/2006 - DWQ RRO received a clean up deadline extension request letter dated
04/07/2006 from Mr. Joe Beaman, of Highlands Environmental Solutions.
7. 04/18/2006 - Mr. Boone received a phone message from Mr. Beaman, asking whether we
had received the above -mentioned extension request and inquiring whether the deadline
would be extended.
8. 04/19/2006 - Mr. Boone returned Mr. Beaman's 04/18 call, to acknowledge receiving Mr.
Beaman's extension request. Mr. Boone stated he was not sure whether the deadline
could be extended but would investigate the issue.
9. Mr. Boone received the laboratory results for the two samples that Mr. Greer had taken
from the site of the spill on 03/17/2006. These samples, #1 and #2 respectively showed
4,020 mg/KG and 6,040 mg/Kg of oil/grease.
Be it known that DWQ is now considering further action regarding the subject oil spill. To
this date, clean up of the oil spill still has not commenced. Glenoit Fabrics is thereby in violation of
three separate sections of the Oil Pollution and Hazardous Substances Control Act as summarized
below:
1. G S 143-215 83(a) Unlawful Discharges:
It shall be unlawful for any person to discharge oil or other hazardous substances into or
upon any waters or lands within the state. The above noted discharges are in violation
of this statute.
2. G S 143-215 84(a) Removal of Prohibited Discharges:
Any person having control over oil or other hazardous substances discharged in violation
of this article shall immediately undertake to collect and remove the discharge and to
restore the area affected by the discharge as nearly as may be to the condition existing
prior to the discharge. You have not made sufficient efforts to comply with this
statute as of this date.
3. G S 143-215.85 Required Notice:
Any person having control over oil or other hazardous substances discharged, shall
immediately notify the Department of the nature, location, and time of the discharge and
of the measures taken or are proposed to be taken to contain and remove the discharge.
This office has not received any reports from you associated with the above -
mentioned releases as of the date of the inspection.

To correct the above violations, you are required to do the following:
1. Cease discharging all "oil" or other hazardous substances on the land or waters of the
state.
2. Cleanup the affected areas and collect soil and/or groundwater samples to confirm the
clean up. The soil and groundwater testing and laboratory analyses shall conform to the
appropriate sections of Groundwater Section Guidelines for the Investigation and
Remediation of Soils and Groundwater, July 2000 Edition.
3. Submit a report to the Raleigh Regional Office assessing the cause, significance, and
extent of the release, and listing all actions you plan to take to prevent future releases and
to clean up the observed releases by April 20, 2006. (This original deadline cannot be
extended.)
Please note that it is Glenoit's legal obligation to ensure proper clean up of the entire spill site
as well as take all appropriate measures to avert further spills of this nature in the future. The degree of
clean up that Glenoit has undertaken itself as of the 03/17/2006 revisit of the site by DWQ personnel is
not sufficient, as evidenced by the results of the samples taken by Mr. Greer. You should be aware that
DWQ will require evidence of proper sufficient clean up in the form of written reports summarizing all
clean up actions taken, as well as laboratory analytical results that show that all contaminated soil has
been removed.
To this date, Glenoit Fabrics has yet to specifically identify the source and cause of the
subject spill. It was stated during the 03/17/2006 revisit to the site, that the oil was assumed to have
come from a leak in a heating oil line in the January, 2005 timeframe; how the spilled oil found its way
to the stormwater discharge outfall, which is at least 100 yards to the north of the boiler room and
x h: underground storage tank that houses the fuel oil, had not yet been definitively determined. For that
reason, unless you determine unequivocally the source and cause of the spill, we cannot fully determine
your compliance with G.S. 143-215.84(a), Removal of Prohibited Discharges. For instance, if there is
an active leak in an underground fuel supply line, the illegal discharge and resulting contamination will
continue until the leak(s) are identified and repaired. Furthermore, the heating oil found at the site of the
stormwater discharge outfall (SDO) traveled from its point of origin to the SDO either on the inside of
the stormwater pipe or on the outside, and alongside, of the stormwater pipe, or both. As such, Glenoit
must show the following:
1. The definitive source and cause of the spill.
2. That the identified source is sufficiently contained to prevent further spills.
3. All steps taken to mitigate the cause of the spill.
4. That the underground fuel oil tank and piping system is leak free.
4. How the spilled oil got from its point of origin to the SDO, i.e. on the inside of the pipe,
on the outside of the pipe, or both.
5. The beginning, end and breadth or extent of oil contamination from the source to the
SDO, and whether it is on the inside of the stormwater pipe only, on the outside only, or
both.
6. That the structural integrity of the stormwater pipeline was sufficient so as to fully
contain all oil that entered the pipeline (that no oil exfiltrated the pipeline thereby
contaminating the surrounding soil).

7. If oil did exfiltrate the pipeline, that all contaminated soil, as defined above, has been
properly removed and disposed of.
8. That the contaminated area at the SDO has been completely cleaned.
NOTE: As stated above, all clean up must conform to the appropriate sections of
Groundwater Section Guidelines for the Investigation and Remediation of Soils and
Groundwater, July 2000 Edition.
You are requested to contact the Division in writing, within ten (10) days of receipt of this
letter, of your intention to comply and submit a response and a schedule for achieving compliance. Civil
penalties are now being recommended for the violations cited above. Your response to this NOV will be
included for consideration when a decision on assessing penalties is made. Please be aware that fines of
up to $5,000.00 for each violation can be assessed, and that each day that the violation(s) continue
constitutes a separate violation.
A report detailing the corrective action(s) taken and to be taken must be submitted to the
Raleigh Regional Office, Department of Environment and Natural Resources, 1628 Mail Service Center,
Raleigh, North Carolina 27699-1628, on or before 30 April 2006. Please note that we may require
different or additional corrective actions to be performed, other than those specified by you, to correct
the above mentioned violations. Your response and any questions you may have should be directed to
Mr. Boone or me, of the Raleigh Regional Office, at 919-791-4200.
AM
Shannon Langley
Acting Raleigh Regional SurVe ValeorQuality Supervisor
cc: Central Files
Non -Point Source Compliance Enforcement Unit
RRO Files

( L 3•1�11:0 1 r G L E N 0 1 T FABRICS [ H G I CORPORATION
March 29. 2006
Ron Boone
1628 Mail Service Center
Raleigh, N. C. 27699-1628
Dear Mr. Boone:
This is a follow-up of your inspection of March 6, 2006.
A. On March I we sent soil sample to Southern Testing
to be tested for oil
B. On March 20s' contacted Shaun Joyner of Appian
Consulting Engineers
C. On March 2e Shaun inspected site
D. On March 28s' contacted Johnny Baines of Eastern
Environmental Management to clean up the site
E. Johnny Baines set a date of April 5-7 to clean site
Thank you for your cooperation in this matter.
Regards,
Jerry Howard
Glenoit Fabrics (HG) Corporation
3 JaiI NJR ih AA1Y 5rI E E T I Y.J. BI:Y ^ I . , TA98.1 RJ, NC 2I33b T 252 321.7]98 1 2 , 1. 511v

Highlands
Environmental
Solutions, Inc. 9405 Greenfield Drive; Raleigh, NC 27615
Phone: [phone] / Fax: [phone] / www.hesnc.com
April 7, 2006
Mr. Ronald Boone
North Carolina Department of Environment and Natural Resources
Raleigh Regional Office
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Response to NOV I Request for Extension
Glenoit Fabrics (HG) Corporation; Tarboro; Edgecombe County; North Carolina
HES Project #25040
Dear Mr. Boone:
As you are aware, on March 21, 2006, a Notice of Violation (NOV) was issued to Glenoit Fabrics (HG)
Corporation in Tarboro, North Carolina (Glenoit), for a petroleum release in violation of the Oil Pollution
and Hazardous Substances Control Act of 1978. The subject NOV was issued In accordance with the
NOV, Glenoit has performed the following: Ceased discharging all "oil' or other hazardous substances on
the land or waters of the state. Furthermore, Eastern Environmental Management, LLC (EEM) and
Highlands Environmental Solutions, Inc. (HES) have been retained by Glenoit to provide environmental
assessment and remediation services associated with the subject petroleum release.
At the request of Glenoit, environmental remediation activities will be performed at the storndrain outfall
from which the subject release emanated. All petroleum impacted soil will be excavated, and
confirmation soil sampling will be performed upon completion of excavation activities. All samples'will be
laboratory analyzed in accordance with NCDENR requirements (as documented in the Groundwater
Section Guidelines for the Investigation and Remediation of Soils and Groundwater (July 2000). Upon
receipt of laboratory analytical data, a report will be generated documenting site remediation activities, the
results of confirmatory sampling, and recommendations for additional activities, if necessary.
In the subject NOV, a due date of April 20, 2006 was presented for receipt of a report assessing the
cause, significance and extent of the subject release. HES is still acquiring data regarding the release,
and propose to combine the information requested in the NOV into the report to be compiled and
submitted upon completion of environmental remediation activities at the stcrmdrain outfall.
Environmental remediation activities will be scheduled and performed in a time -effective manner,
however, to avoid additional expenses related to rushed analytical costs, etc., we respectfully request an
extension of the due date for submittal of the subject report. We respectfully request that the due date for
submittal of a report providing the information requested in the NOV, as well as, information related to
remediation activities performed at the site, be extended to June 1, 2006.

Mr. Ronald Boone
Glenoit Fabrics (HG) Corporation; Tarboro, North Carolina
Thank you in advance for your consideration of this request. If there are
regarding this correspondence, or the project in general, please contact Mr.
414-7081, or Mr. Jerry Howard (Glenoit) at 252-641-6034.
Sincerely,
Highlands Environmental Solutions, Inc.
Joe Beaman, P.G.
Principal Geologist
cc: Mr. Jerry Howard — Glenoit Fabrics (HG) Corporation
Mr. Johnny Baines — Eastern Environmental Management, LLC
File
April 7. 2006
Page 2
any questions or concerns
Joe Beaman (HES) at (919)

�0F w A rF4
Michael F. Easley, Govemo
William G. Ross, Jr., Secretar
O 7 [ North Carolina Department of Environment and Natural Resource:
Alan W. Klimek, P.E., Director
Division of Water Qualin
March 23, 2006
Mr. Jerry Howard
Plant Manager
Glenoit Fabrics [HG] Corporation
3001 North Main Street
P.O. Box 4011
Tarboro, NC 27886
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Subject: Notices of Violation Resulting from Compliance Evaluation
Inspections on 03/09/2006, for NPDES General Wastewater
Permit No. NCG500307 (NOV-2006-PC-0080) and NPDES
General Stormwater Certificate of Coverage NCG170023
(NOV-2006-PC-0079) and Follow -Up Site Visit Conducted
17 Mar 2006
Glenoit Fabrics [HG] Corporation -Tarboro
Edgecombe County
Dear Mr. Howard:
Mr. Ronald Boone, of the North Carolina Division of Water Quality, Surface Water Protection Section,
conducted compliance evaluation inspections (CEI) for the permits referenced above at Glenoit Fabrics
[HG] Corporation's Tarboro, NC plant on 9 March 2006. Thank you for your assistance and
cooperation in providing him a tour of the site, as well as an interview to review your wastewater and
stormwater management programs. Please use the permit references listed throughout this report for
further explanation of each item cited.
SITE SUMMARY
Your plant is a textile mill primarily involved in the weaving and dying of several different fabrics.
Wastewater is produced from several cooling systems and possibly one air compressor system.
Cooling system water is treated with proprietary chemicals that contain Sodium Hypochlorite.
Stormwater generated at your site is collected via a system of in -ground drains.
INSPECTION FINDINGS
General
• Mr. Roy Lee, a plant electrician, provided Mr. Boone a tour of the facility and answered all of Mr.
Boone's questions. According to Mr. Lee, Mr. Tom Breedlove, an employee formerly responsible
for your wastewater and stormwater programs, left the company in December 2005. No one has
been hired to replace him yet. Mr. Lee also stated that no one else was available that would have
been better suited to show/discuss your plant's wastewater/stormwater management programs.
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection
Internet: h2o.enr.state.ne.us 1628 Mail Service Center Raleigh, NC 27699-1628
An Equal Opportunity/Affirmative Action Employer - 50% Recycledl70% Post Consumer Paper
N rhCarolina
,lValwally
Phone [phone] Customer Service
FAX [phone]t8 1-877-623-6748

Glenoit Fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG170023 & NCG500307 Page 2 of 8
There were several areas of the plant that showed a lack of general housekeeping/maintenance.
The two docks used to load/unload chemical deliveries for the latex recovery systems were full of
water, one of which was colored a deep milky white, indicating a spill of a considerable amount of
ALAR, hydrated lime, or other chemical used in this process (see attached photo). Although the
water/chemicals contained by this loading dock are subsequently pumped to the pretreatment
system located on the front (south) side of the plant, the dock should not be used continuously as
waste chemical containment. Use as a temporary containment structure for chemicals that are
spilled during the loading/unloading process is acceptable, but the chemicals should not remain in
the loading dock for extended periods of time and the loading dock should be kept as clean as
possible. This situation presents a few possible hazards such as: 1). The chemicals can be spread
by vehicles/personnel that come into contact with them, 2). It could become a drowning hazard, and
3). If personnel at the facility do not know the hazards associated with these chemicals, they may
not take appropriate precautionary measures while in the area. The loading dock for the western
latex recovery system was also full of water. Although this water did not seem to be contaminated,
the accumulation of trash was excessive and the standing water still presents a drowning hazard.
o Note: By the time of the follow-up visit conducted 17 Mar 2006, the loading dock for
the eastern latex recovery system had been pumped out and cleaned.
Some chemicals used in the latex recovery process were stored outside on pallets (see attached
photos). Although they were "under cover" it was apparent that the existing cover would not
provide protection in a severe storm. We recommend that you store all such chemicals inside the
latex recovery room or modify the cover to protect the chemicals in all circumstances. Another
alternative would be to cover chemicals stored outside with waterproof tarps.
Staining of the pavement just outside the roll -up door for the eastern latex recovery room indicated
that chemicals might be sheet -flowing out of the building into the surrounding stormwater
catchments (see attached photos). The operator confirmed that residual chemicals on the floor are
often washed down the ramped floor to the pavement outside. Not only does this leave your
stormwater system and receiving water vulnerable to contamination, but vehicles/personnel can
subsequently spread these chemicals to other areas of the plant, causing other environmental/health
related issues. These practices should stop immediately. Any spills should be cleaned up and
properly disposed of.
Waste sludge from the latex recovery process is being dumped in a large dumpster located on the
north side of the plant. The dumpster is not covered and stormwater falls directly into it. Leakage
from the dumpster was apparent during the inspection. This dumpster should also be fully covered
to protect it from stormwater.
o Note: By the time of the follow-up visit, dry absorbent material had been placed on the
leaked material. However, it had not yet been cleaned up.
Piles of excess fiber were observed just outside and inside the property fence line on the northern
side of the plant. This practice should stop immediately and waste fibers should be disposed of
properly. Please note that if these fibers are contaminated with chemicals of a hazardous or toxic
nature they require special handling and disposal.
One of the stormwater outfalls on the north side of the facility was the site of a petroleum spill (see
attached photos). This item is being addressed by way of a separate Notice of Violation (NOV).
o Note: By the time of the follow-up visit, Glenoit had attempted to cleanup the oil spill
and took samples for analysis. However, additional free product was found underneath
the end of the discharge pipe, requiring further cleanup and analysis. Further details of
the cleanup effort are forthcoming.

Glenoit Fabrics [HGJ Corporation, Compliance Evaluation Inspection, March 9, 2006, uCG170023 & NCG500307
Page 3 of 8
• Mr. Lee stated that there were several floor drains located throughout the facility and that he was
not sure where they drain. He also could not locate blueprints showing the existing floor drains. A
large variety of chemicals, including but not limited to acids, bases, scouring agents, and dyes, are
stored in the rooms aggregately known as the dye room. Although Mr. Lee and Mr. Ron Kanthak
(the Dyer) stated that chemicals spilled inside the dye room drain into the pretreatment system, it
was apparent that some chemicals could possibly leak out into the larger plant areas where Mr. Lee
indicated the floor drains are located. Furthermore, only one small chemical spill kit was located at
the plant, at the southwestern loading dock. Due to the amount of chemicals used at the plant, all
floor drains inside the facility should be identified and their ultimate discharge points (stormwater
or wastewater) determined. Once all drains and their points of discharge are identified they can be
addressed accordingly. You may also want to consider acquiring additional chemical spill kits for
your facility.
o Note: By the time of the follow-up visit, Mr. Lee claimed he was able to find the
blueprints in question. However, the blueprints were not shown to Mr. Boone and the
floor drains still remain a concern.
• The secondary containment structure for waste oil in the storage bam on the north side of the plant
was cracked in two places. These cracks would allow spillage of waste oil outside of the
containment. These cracks should be repaired/sealed or the secondary containment replaced
immediately.
o Note: By the time of the follow-up visit, the cracks in this secondary containment had
been patched with grout or epoxy.
• Excessive erosion was observed around the area of S02. This can negatively impact the receiving
waters and leave you vulnerable to further penalization if the erosion at your facility is
compromising the quality of the receiving waters. Appropriate measures should be taken to stop
this erosion and prevent it from happening in the future. Please note the requirements of Part III,
Section E, Paragraph 5, of permit NCG170000 before undertaking any projects to alter your
stormwater system.
Cooling System Wastewater Discharge (Permit No. NCG500307, NOV-2006-PC-0080)
• There were many autonomous cooling systems at the plant and at least one air compressor system.
Although Mr. Lee speculated that these discharges went to the pretreatment system, he could not
confirm this. The fact that you have permit NCG500307 indicates that you have at least one
discharge into waters of the state of one or more of the waste streams covered by this permit.
Failure to identify and monitor any and all such discharges places you in violation. Please note that
this permit regulates the discharge of non -contact cooling water, cooling tower and boiler
blowdown, condensate, exempt stormwater, cooling waters associated with hydroelectric
operations, and similar wastewaters. Part I, Section C discusses the different types of discharges in
greater detail.
o Note: By the time of the follow-up visit, Glenoit had commissioned a former/retired
maintenance supervisor, Mr. Marvin Lee, to come in and assist with answering questions
from the inspection. Mr. M. Lee at first stated that all such discharges covered by this
permit discharged to the pretreatment system. However, inspection of the Stormwater
Pollution Prevention Plan (SP3), which also was not found until the follow-up visit, revealed
at least one cooling system discharge that discharges through stormwater outfall SO1, as
labeled in the SP3.

Glenoit Fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG 170023 & NCG500307 Page 4 of 8
Analytical monitoring records of the discharges discussed above were not available for inspection.
This indicates that this monitoring has not been accomplished. Had the monitoring actually been
accomplished however, the absence of such records still places you in violation of Part II, Section
D, Paragraphs 5, 6, and 7 as well as Section E, Paragraph 1.
You're currently using proprietary biocide chemicals that contain Sodium Hypochlorite in your
cooling systems. You're therefore required to monitor the discharge for total residual chlorine (Part
I, Section A(1)). Also, we have no paperwork on file indicating that you have approval to use the
stated chemicals in your discharge, as required in Part I, Section A(1).
Stormwater Discharge (Permit No. NCG170023, NOV-2006-PC-0079)
• At the time of the initial inspection the number and location of stormwater outfalls was unknown
and undocumented. You did not have a Stormwater Pollution Prevention Plan (SP3) as required in
Part II, Section A, of your permit. However, by the time of the follow-up visit you had located your
SP3. Review of this document revealed a well -constructed stormwater management program, yet a
significant number of SP3 components had not yet been implemented or were significantly
outdated, as follows:
o <The site plan did not meet all requirements (Part II, Section A, Paragraph 1 and subparagraphs).
o The stormwater management plan did not meet all requirements (Part II, Section A, Paragraph 2
and subparagraphs).
o The Spill Prevention and Response Plan (SPRP) did not meet all requirements (Part 11, Section
A, Paragraph 3).
o� The stormwater preventative maintenance and good housekeeping plan did not meet all
,requirements (Part 11, Section A, Paragraph 4).
o The stormwater employee -training program did not meet all requirements (Part II, Section A,
/Paragraph 5).
o The list of personnel responsible for the overall coordination, development, implementation, and
revision of the plan was outdated (Part 11, Section A, Paragraph 6). .
o /�'he SP3 had not been revie�ved/updated as required (Part II, Section A, Paragraph 7).
o✓ The stormwater facility inspection program did not meet all requirements (Part 11, Section A,
/Paragraph 8).
o The SP3 has not been implemented in accordance with Part U, Section A, Paragraph 9.
Please note that not all permit requirements are listed above. Refer to your permit to ensure you
meet all requirements.
• No records of the qualitative monitoring were available for inspection as required in Part I, Section
B of your permit. This indicates that the required monitoring has not been accomplished. Please
ensure that all future qualitative monitoring is accomplished, recorded and stored in accordance
with the conditions of your permit.
• According to our records Glenoit has another permit, COC NCG170375, for a plant located at 3002
Anaconda Road in Tarboro. However, according to Mr. Lee this facility is closed. Please notify the
NC Division of Water Quality of this closure as required in Part III, Section B, Paragraph 2.
The above findings demonstrate mismanagement of your wastewater and stormwater management
programs and/or a misunderstanding of the requirements of your permits. Please be aware that these
findings constitute violations of North Carolina General Statute (NCGS) 143-215.1 et seq. and could
result in the assessment of civil penalties in an amount of up to $25,000 per day per violation.

Glenoit Fabrics [HGJ Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG 170023 & NCG500307 Page 5 of 8
Please reply within 30 days of your receipt of this letter with a narrative of your plan to achieve full
compliance with your permit and your schedule for doing so. If you need assistance with understanding
any aspect of your permit, please do not hesitate to contact Mr. Boone for assistance at 919-791-4259.
Sincerely,
MyrlI. Nisely
Acting Raleigh Regional Surface Water Quality Supervisor
cc: Stormwater Permitting Unit
Central Files
Non -Point Source Compliance Enforcement Unit

Glenoit Fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG170023 & NCG500307 Page 6 of 8

Glenoit Fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG170023 & NCG500307 Page 7 of 8

Glenoit Fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG170023 & NCG500307 Page 8 of 8

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CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jerry Howard
Plant Manager
Glenoit Fabrics [HG] Corporation
3001 North Main Street
P.O. BOX 4011
Tarboro, NC 27886
Subject: NOTICE OF VIOLATION
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AR JERRY HOWARD, PLANT MANAGER
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GLENOIT FABRICS [HG] CORPORATION
''n 3001 NORTH MAIN STREET
p _)niia P.O. BOX 4011
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atmJr,!af. xa., T. vICE O D 27886
NOV/CEI. EDGECOMBE CO. 3/21106
t;y, rta;7Pi'mailed: 321/06
M. 1
G.S. 143-215.75 et sec -
Oil Pollution and Hazardous Substance Control Act of 1978
3001 North Main Street
Tarboro, North Carolina, Edgecombe County
Dear Mr. Howard:
North Carolina General Statutes, Chapter 143, authorizes and directs the Environmental
Management Commission of the Department of Environment and Natural Resources to protect and
preserve the Water and Air resources of the state. The Division of Water Quality (D WQ) has the
delegated authority to enforce adopted pollution control rules and regulations. Based upon Mr. Ronald
Boone's observations on 9 March 2006, a #5 heating oil release has occurred at your place of business
located at the above address in Tarboro, North Carolina, Edgecombe County.
The DWQ has reason to believe that you are responsible for activities resulting in
noncompliance with North Carolina law. On 9 March 2006, Mr. Ronald Boone observed a spill of what
is believed to be a #5 heating oil, located in the stormwater outfall #2 (S02), of Glenoit Fabrics [HG]
Corporation's 3002 North Main Street plant, in Tarboro, North Carolina, Edgecombe County.
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North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] i Customer Scrvice
Internet ;. _._.;,:_�a;e'q�i�li)y,n;g Location: 512 N. Salisbury St. Raleigh, NC 27604 g Fax [phone]
An Equal OPPodunity/Affirmative Action Employer - 50% Recycled/10°/ Post Consumer Paper

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CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jerry Howard
Plant Manager
Glenoit Fabrics [HG] Corporation
3001 North Main Street
P.O. Box 4011
Tarboro, NC 27886
Subject: NOTICE OF VIOLATION
O $ E
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WilmaE',a •a Ej
North Carolina Department of Environment a.a o ;t =,
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Alan W. Klimeko C ' a
q'u,n
Division of
.-c E-�
21 March 2006
;q
G.S. 143-215.75 et seq..
Oil Pollution and Hazardous Substance Control Act of 1978
3001 North Main Street
Tarboro, North Carolina, Edgecombe County
Dear Mr. Howard:
North Carolina General Statutes, Chapter 143, authorizes and directs the Environmental
Management Commission of the Department of Environment and Natural Resources to protect and
preserve the Water and Air resources of the state. The Division of Water Quality (D WQ) has the
delegated authority to enforce adopted pollution control rules and regulations. Based upon Mr. Ronald
Boone's observations on 9 March 2006, a #5 heating oil release has occurred at your place of business
located at the above address in Tarboro, North Carolina, Edgecombe County.
The DWQ has reason to believe that you are responsible for activities resulting in
noncompliance with North Carolina law. On 9 March 2006, Mr. Ronald Boone observed a spill of what
is believed to be a #5 heating oil, located in the stormwater outfall #2 (S02), of Glenoit Fabrics [HG]
Corporation's 3002 North Main Street plant, in Tarboro, North Carolina, Edgecombe County.
o `
NhCarolina
,rl Wlma!!y
North Carolina Division of Water Quality 1617.Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internetp_,�v.,ncv_a i._i,l,rliiv,,, Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]_
g77-623-6748
An EqualOpportunity/A(Frmative Action Employer- 50% RenavclodRnk c„,, r^—,....., n_---

Mr. Jerry Howard
Glenoit Fabrics [HG] Corporation
March 20, 2006
Page 2
Specific. Violations of the Oil Pollution and Hazardous Substances Control Act, are as follows:
G.S. 143-215 83(a) Unlawful Discharges:
It shall be unlawful for any person to discharge oil or other hazardous substances into or upon
any waters or lands within the state. The above noted discharges are in violation of this
statute.
2. G.S. 143-215 84(a) Removal of Prohibited Discharges:
Any person having control over oil or other hazardous substances discharged in violation of this
article shall immediately undertake to collect and remove the discharge and to restore the area
affected by the discharge as nearly as may be to the condition existing prior to the discharge.
You have not made sufficient efforts to comply with this statute as of this date.
3. G.S. 143-215.85 Required Notice:
Any person having control over oil or other hazardous substances discharged, shall immediately
notify the Department of the nature, location, and time of the discharge and of the measures
taken or are proposed to be taken to contain and remove the discharge. This office has not
received any reports from you associated with the above -mentioned releases as of the date
of the inspection.
To correct the above violations, you are required to do the following:
A. Cease discharging all 'oil" or other hazardous substances on the land or waters of the state.
B. Cleanup the affected areas and collect soil and/or groundwater samples to confirm the clean up.
The soil and groundwater testing and laboratory analyses shall conform to the appropriate
sections of Groundwater Section Guidelines for the Investigation and Remediation of Soils and
Groundwater, July 2000 Edition.
C. `--Submit.a report "to the Raleigh Regional Office assessing the cause, significance, and extent of
the release, and listing all actions -y_ou plan to take to prevent future releases and(to cleanup the
observed releas<by Apri120, 200 .
�—--------
You are requested to contact the Division in writing, within ten (10) days of receipt of this
letter, of your intention to comply and submit a response and a schedule for achieving
compliance. Civil penalties may have already been recommended for the violations cited above.
Failure to respond within the time specified and to voluntarily achieve compliance may result in
further enforcement action, to include a recommendation for proposed penalty assessment, which
provides for a civil penalty of not more than $5,000.00 for each violation.

Mr. Jerry Howard
Glenoit Fabrics [HG] Corporation
March 20, 2006
Page 3
Please take the corrective action(s) specified in Paragraph C for the above violation(s). A
report detailing the corrective action(s) taken must be submitted to the Raleigh Regional Office,
Department of Environment and Natural Resources, 1628 Mail Service Center, Raleigh, North Carolina
27669-1628, on or before 20 April 2006. Please note that we may require different or additional
corrective actions to be performed, other than those specified by you, to correct the above mentioned
violations. Your response and any questions you may have should be directed to Mr. Ronald Boone or
me of the Raleigh Regional Office, at 919-791-4200.
Sincerely,
�--8ifannon Lange:
Acting Raleigh
cc: Stormwater Permitting Unit
Central Files
Non -Point Source Compliance Enforcement Unit
Edgecombe County Health Department
:er Quality Supervisor

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
DAVID GURLEY
GLENOIT CORPORATION
PO BOX 1157
TARBORO. NC 27886
Dear Permittee:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
July 28. 1999
Subject: Reissue - NPDES Stormwater Permit
Glenoit CORPORATION
COC Number NCG170023
Edgecombe County
In response to your renewal application for continued coverage under general permit NCG170000. 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 followine information is included with your permit package:
A copy of general stormwater permit NCG170000
* A Stormwater Pollution Prevention Plan (SPPP) Certification Form. Completion of this form is required to
certify that you have developed and implemented the SPPP as per the conditions of the 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 the Analytical Monitoring form and five copies of the Qualitative Monitoring form
* A copy of a Technical Bulletin for the general permit which outlines changes in the permit, key requirements,
and addresses frequently asked questions
* A Certificate of Coverage
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 Darren England of the Central Office
Stormwater and General Permits Unit at [phone], ext. 545
Sincerely,
for Kerr T. Stevens
cc: Central Files
Stormwater and General permits Unit Files
Raleigh 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

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG170000
CERTIFICATE OF COVERAGE No. NCG170023
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,
GLENOIT CORPORATION
is hereby authorized to discharge stormwater from a facility located at
GLENOIT CORPORATION
3001 N. MAIN STREET
TARBORO
EDGECOMBE COUNTY
to receiving waters designated as the Tar River in the Tar - Pamlico River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, II, III,
IV, V, and VI of General Permit No. NCG170000 as attached.
This certificate of coverage shall become effective August I, 1999.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day July 28, 1999.
for Kerz T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

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
October 14, 1994
David Gurley
Glenoit Mills, Inc.
Highway 33 West, P.O.Box 1157
Tarboro, NC 27886
Subject: General Permit No. NCG170000
Glenoit Mills, Inc.
COC NCG170023
Edgecombe County
Dear David Gurley:
In accordance with your application for discharge permit received on 08/23/94, 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 rcissuance 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 question concerning this permit, please contact Mr. Steve Ulmer at telephone number
919/733-5083.
Sincerely,
Cr tnai ,,gnediB6
Colee n
A. Preston Howard, Jr. P.E
cc: Raleigh Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer. 50% recycled/ 10 % post-consurner paper

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STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
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 die North Carolina Environmental Management Commission, aid the
Federal Water Pollution Control Act, as amended,
Glenoit Mills,. Inc.
is hereby authorized to discharge stotmwater from a facility located at
3001 North Main Street
Tarboro
Edgccombe County
to receiving waters designated as the Tar River in the Tar-Patnlico River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I,.11, III
and IV of General Permit No. NCG170000 as attached.
This Certificate of Coverage shall become effective October 21, 1994.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day October 21, 1994.
Original Sl(;ned By
Coleen K Suilins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
July 28,1999
DAVID E. GURLEY. JR.
GLENOIT CORPORATION
POST OFFICE BOX 1157
TARBORO. NC 27886
1�
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RE50URCES
Subject: Reissue - NPDES Stormwater Permit
Glenoit Corporation
COC Number NCG170375
Edgecombe County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG170000, 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 copy of general stormwater permit NCG170000
* A StOrmwater Pollution Prevention Plan (SPPP) Certification Form. Completion of this form is required to
certify that you have developed and implemented the SPPP as per the conditions of the 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 the Analytical Monitoring form and five copies of the Qualitative Monitoring form
* A copy of a Technical Bulletin for the general permit which outlines changes in the permit, key requirements,
and addresses frequently asked questions
* A Certificate of Coverage
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,
fj2s1.L�/-�,I
for Kerr T. Stevens
cc: Central Files
Stormwater and General permits Unit Files
Raleigh 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

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG170000
CERTIFICATE OF COVERAGE No. NCG170375
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, -
GLENOIT CORPORATION
is hereby authorized to discharge stormwater from a facility located at
GLENOIT CORPORATION
3002 ANACONDA ROAD
TARBORO
EDGECOMBE COUNTY
to receiving waters designated as a UT of the Tar River and Tarboro MSSS in the Tar - Pamlico 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. NCG170000 as attached.
This certificate of coverage shall become effective August 1. 1999.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day July 28, 1999.
for Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

,n
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
February 27, 1998
LIAR 3 )T'
Mr. David E. Gurley, Jr. �
Glenoit Corporation L
Post Office Box 1157 IDE14V LEIGI! %
Tarboro, North Carolina 27886
Subject: General Permit No. NCG170000
Glenoit Corporation
COC NCG170375
Edgecombe County
Dear Mr. Gurley,:
In accordance with your application for discharge permit received on December 31, 1997, 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 Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the
certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management
Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Bill Mills at telephone number 919/733-5083
ext. 548.
Sincerely,
ORIGINAL SIGNED BY
BRADLEY '.7rNNETT
A. Preston Howard, Jr., P. E.
cc: Raleigh Regional Office
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 AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG170000
CERTIFICATE OF COVERAGE No. NCG170375
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,
Glenoit Corporation
is hereby authorized to discharge stormwater from a facility located at
Glenoit Corporation
3002 Anaconda Road
Tarboro
Edgecombe County
to receiving waters designated as an unnamed tributary to Tar River and the Town of Tarboro Storm Sewer System
in the Tar -Pamlico River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III
and IV of General Permit No. NCG170000 as attached.
This certificate of coverage shall become effective February 27, 1998.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day February 27, 1998.
ORIGINAL SIGNED ^Y
BRADLEY BENNETT
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

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GLENOIT FABRICS [HG[ CORPORATION
March 29, 2006
Ron Boone
1628 Mail Service Center
Raleigh, N. C. 27699-1628
Dear Mr. Boone:
This is a follow-up of your inspection of March 6, 2006.
A. On March I we sent soil sample to Southern Testing
to be tested for oil
B. On March 20'h contacted Shaun Joyner of Appian
Consulting Engineers
C. On March 24 h Shaun inspected site
D. On March 28°i contacted Johnny Baines of Eastern
Environmental Management to clean up the site
E. Johnny Baines set a date of April 5-7 to clean site
Thank you for your cooperation in this matter.
Regards,
erry Howard
Glenoit Fabrics (HG) Corporation
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G`T GLENOIT FABRICS [HG] CORPORATION
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April 27, 2006 y
Ron Boone
Environmental Technician
1628 Mail Service Center t ~n
Raleigh, N C. 26799-1628
Mr. Boone:
On Tuesday, April 25, 2006 Highlands Environmental Solutions, Inc. and Eastern
Environmental Management were on site to clean up the oil spill.
They dug out the contaminated soil and replaced it with 100 tons of new soil. Mr. Joe
Beaman is in the process of writing the final report once he has all of his information. He
can be contacted at [phone].
In the mean time we have found the cause of the spill and will seal off the need be
drainage pipes so that if the problem occurs again, the oil will be contained inside the
building.
The problem occurred when an oil line burst and drained into the storm water pipe. We
thought we had contained the oil.
Enclosed are pictures of the clean up.
Sincerely,
G��s iJ
Jerry Howard
Glenoit Fabrics (HG) Corporation
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20 April 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jerry Howard
Plant Manager
Glenoit Fabrics [HG] Corporation
3001 North Main Street
P.O. Box 4011
Tarboro, NC 27886
Subject: NOTICE OF INTENT TO ENFORCE
NOV-2006-OC-0018
3001 North Main Street
Tarboro, North Carolina, Edgecombe County
`.
Michael F. Easley, Govevio,`bt
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
r Dear Mr. Howard:
The NC Division of Water Quality (DWQ), Raleigh Regional Office (RRO), received a letter
from Mr. Joe Beaman, of Highlands Environmental Solutions, on 04/12/2006, requesting an extension
of the deadline placed upon Glenoit Fabrics [HG] Corporation to clean up the oil spill referenced in the
subject NOV. The original spill clean up deadline set by the subject NOV was 04/20/2006.
The following milestones regarding this issue are hereby noted:
1. 03/09/2006 - Mr. Ronald Boone, of the RRO, observed a spill of what was believed to be
a #5 heating oil, located in the stormwater outfall #2 (S02), of Glenoit Fabrics [HG]
Corporation's 3001 North Main Street plant, in Tarboro, North Carolina, Edgecombe
County. Mr. Boone discovered the spill during a routine annual Compliance Evaluation
Inspection (CEI) of the stated facility's stormwater permit, NCG170023.
2. 03/17/2006 - Mr. Boone and Mr. Jimmie Greer, also of DWQ RRO, revisited the site. At
this point, Glenoit had attempted to clean up the spill and took post clean up samples for
oil/grease analysis. Mr. Greer also took two post clean up samples for oil/grease analysis
at state labs. Detailed inspection of the clean up site revealed further contamination. Mr.
Boone and Mr. Greer then suggested that you commission an independent consultant to
perform the required clean up.
3. 03/21/2006 - The subject NOV was drafted and sent.by DWQ to Glenoit Fabrics,
notifying you of the specific statutes violated and Glenoit's legal obligations regarding
spill clean up. This NOV set the clean up deadline of 04/20/2006.
Cam ina
�vatural/y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: �c�cu_ncameryualiiy.�tr^_ Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/AKrmative Action Employer- 50% Recycled/10% Post Consumer Paper

4.
5.
6.
7.
8.
9.
04/03/2006 - DWQ received a letter from you dated 03/29/2006. In this letter you stated t,l,
that it was a follow-up to the inspection of 03/06/2006. Be it known that we performed
the aforementioned inspection on 03/09/2006, not 03/06/2006. You also stated in this
letter that Eastern Environmental Management would commence oil spill clean up
activities on 04/05/2006.
04/06/2006 - Mr. Boone and Mr. Shannon Langley, also of DWQ RRO, again revisited
the site to check on the progress of clean up efforts. Clean up had not yet begun. The
results of the samples taken by Glenoit were reviewed, showing approximately 6,800
milligrams per kilogram (mg/Kg) of oil/grease. Mr. Boone then stressed the importance
of starting clean up as soon as possible.
04/12/2006 - DWQ RRO received a clean up deadline extension request letter dated
04/07/2006 from Mr. Joe Beaman, of Highlands Environmental Solutions.
04/18/2006 - Mr. Boone received a phone message from Mr. Beaman, asking whether we
had received the above -mentioned extension request and inquiring whether the deadline
would be extended.
04/19/2006 - Mr. Boone returned Mr. Beaman's 04/18 call, to acknowledge receiving Mr.
Beaman's extension request. Mr. Boone stated he was not sure whether the deadline
could be extended but would investigate the issue.
Mr. Boone received the laboratory results for the two samples that Mr. Greer had taken
from the site of the spill on 03/17/2006. These samples, #1 and #2 respectively showed
4,020 mg/KG and 6,040 mg/Kg of oil/grease.
Be it known that DWQ is now considering further action regarding the subject oil spill. To
this date, clean up of the oil spill still has not commenced. Glenoit Fabrics is thereby in violation of
three separate sections of the Oil Pollution and Hazardous Substances Control Act as summarized
below:
1. G S 143-215 83(a) Unlawful Discharges:
It shall be unlawful for any person to discharge oil or other hazardous substances into or
upon any waters or lands within the state. The above noted discharges are in violation
of this statute.
2. G S 143 215 84(a) Removal of Prohibited Discharges:
Any person having control over oil or other hazardous substances discharged in violation
of this article shall immediately undertake to collect and remove the discharge and to
restore the area affected by the discharge as nearly as may be to the condition existing
prior to the discharge. You have not made sufficient efforts to comply with this
statute as of this date: l
3. G S 143-215 85 Required Notice:
Any person having control over oil or other hazardous substances discharged, shall
immediately notify the Department of the nature, location, and time of the discharge and
of the measures taken or are proposed to be taken to contain and remove the discharge.
This office has not received any reports from you associated with the above -
mentioned releases as of the date of the inspection.
c

0
l 'I To correct the above violations, you are required to do the following:
l . Cease discharging all "oil" or other hazardous substances on the land or waters of the
state.
2. Cleanup the affected areas and collect soil and/or groundwater samples to confirm the
clean up. The soil and groundwater testing and laboratory analyses shall conform to the
appropriate sections of Groundwater Section Guidelines for the Investigation and
Remediation of Soils and Groundwater, July 2000 Edition.
3. Submit a report to the Raleigh Regional Office assessing the cause, significance, and
extent of the release, and listing all actions you plan to take to prevent future releases and
to clean up.the observed releases by April 20, 2006. (This original deadline cannot be
extended.)
Please note that it is Glenoit's legal obligation to ensure proper clean up of the entire spill site
as well as take all appropriate measures to avert further spills of this nature in the future. The degree of
clean up that Glenoit has undertaken itself as of the 03/17/2006 revisit of the site by DWQ personnel is
not sufficient, as evidenced by the results of the samples taken by Mr. Greer. You should be aware that
DWQ will require evidence of proper sufficient clean up in the form of written reports summarizing all
clean up actions taken, as well as laboratory analytical results that show that all contaminated soil has
been removed.
(' To this date, Glenoit Fabrics has yet to specifically identify the source and cause of the
subject spill. It was stated during the 03/17/2006 revisit to the site, that the oil was assumed to have
come from a leak in a heating oil line in the January, 2005 timeframe; how the spilled oil found its way
to the stormwater discharge outfall, which is at least 100 yards to the north of the boiler room and
re-N
underground storage tank that houses the fuel oil, had not yet been definitively determined. For that
t = reason, unless you determine unequivocally the source and cause of the spill, we cannot fully determine
your compliance with G.S. 143-215.84(a), Removal of Prohibited Discharges. For instance, if there is
an active leak in an underground fuel supply line, the illegal discharge and resulting contamination will
continue until the leak(s) are identified and repaired. Furthermore, the heating oil found at the site of the
stormwater discharge outfall (SDO) traveled from its point of origin to the SDO either on the inside of
the stonnwater pipe or on the outside, and alongside, of the stormwater pipe, or both. As such, Glenoit
must show the following:
/ 1. The definitive source and cause of the spill.
2. That the identified source is sufficiently contained to prevent further spills.
3. All steps taken to mitigate the cause of the spill.
4. That the underground fuel oil tank and piping system is leak free.
4. How the spilled oil got from its point of origin to the SDO, i.e. on the inside of the pipe,
on the outside of the pipe, or both.
5. The beginning, end and breadth or extent of oil contamination from the source to the
SDO, and whether it is on the inside of the stormwater pipe only, on the outside only, or
both.
1 6. That the structural integrity of the stormwater pipeline was sufficient so as to fully
contain all oil that entered the pipeline (that no oil exfrltratcd the pipeline thereby
contaminating the surrounding soil).

7. If oil did exfiltrate the pipeline, that all contaminated soil, as defined above, has been
properly removed and disposed of
8. That the contaminated area at the SDO has been completely cleaned.
NOTE: As stated above, all clean up must conform to the appropriate sections of
Groundwater Section Guidelines for the Investigation and Remediation of Soils and
Groundwater, July 2000 Edition.
You are requested to contact the Division in writing, within ten (10) days of receipt of this
letter, of your intention to comply and submit a response and a schedule for achieving compliance. Civil
penalties are now being recommended for the violations cited above. Your response to this NOV will be
included for consideration when a decision on assessing penalties is made. Please be aware that fines of
up to $5,000.00 for each violation can be assessed, and that each day that the violation(s) continue
constitutes a separate violation.
A report detailing the corrective action(s) taken and to be taken must be submitted to the
Raleigh Regional Office, Department of Environment and Natural Resources, 1628 Mail Service Center,
Raleigh, North Carolina 27699-1628, on or before 30 April 2006. Please note that we may require
different or additional corrective actions to be performed, other than those specified by you, to correct
the above mentioned violations. Your response and any questions you may have should be directed to
Mr. Boone or me, of the Raleigh Regional Office, at 919-791-4200.
j ..
Acting Raleigh Regional
cc: Central Files
Non -Point Source Compliance Enforcement Unit
RRO Filess•
Quality Supervisor

Highlands
Environmental
Solutions, Inc. 9405 Greenfield Drive; Raleigh, NC 27615
Phone: [phone] / Fax: [phone] / w .hesnc.com
April 7, 2006
Mr. Ronald Boone
North Carolina Department of Environment and Natural Resources
Raleigh Regional Office
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Response to NOV / Request for Extension
Glenoit Fabrics (HG) Corporation; Tarboro; Edgecombe County; North Carolina
HES Project#25040
Dear Mr. Boone:
As you are aware, on March 21, 2006, a Notice of Violation (NOV) was issued to Glenoit Fabrics (HG)
Corporation in Tarboro, North Carolina (Glenoit), for a petroleum release in violation of the Oil Pollution
and Hazardous Substances Control Act of 1978. The subject NOV was issued In accordance with the
NOV, Glenoit has performed the following: Ceased discharging all "oil" or other hazardous substances on
the land or waters of the state. Furthermore, Eastern Environmental Management, LLC (EEM) and
Highlands Environmental Solutions, Inc. (HES) have been retained by Glenoit to provide environmental
assessment and remediation services associated with the subject petroleum release.
At the request of Glenoit, environmental remediation activities will be performed at the stormdrain outfall
from which the subject release emanated. All petroleum impacted soil will be excavated, and
confirmation soil sampling will be performed upon completion of excavation activities. All samples will be
laboratory analyzed in accordance with NCDENR requirements (as documented in the Groundwater
Section Guidelines for the Investigation and Remediation of Soils and Groundwater (July 2000). Upon
receipt of laboratory analytical data, a report will be generated documenting site remediation activities, the
results of confirmatory sampling, and recommendations for additional activities, if necessary.
In the subject NOV, a due date of April 20, 2006 was presented for receipt of a report assessing the
cause, significance and extent of the subject release. HES is still acquiring data regarding the release,
and propose to combine the information requested in the NOV into the report to be compiled and
submitted upon completion of environmental remediation activities at the stormdrain outfall.
Environmental remediation activities will be scheduled and performed in a time -effective manner,
however, to avoid additional expenses related to rushed analytical costs, etc., we respectfully request an
extension of the due date for submittal of the subject report. We respectfully request that the due date for
submittal of a report providing the information requested in the NOV, as well as, information related to
remediation activities performed at the site, be extended to June 1, 2006.

u
1p

Mr. Ronald Boone
Glenoit Fabrics (FIG) Corporation; Tarboro, North Carolina
April 7, 2006
Page 2
Thank you in advance for your consideration of this request. If there are
regarding this correspondence, or the project in general, please contact Mr.
414-7081, or Mr. Jerry Howard (Glenoit) at 252-641-6034.
Sincerely,
Highlands Environmental Solutions, Inc.
Joe Beaman, P.G.
Principal Geologist
cc: Mr. Jerry Howard — Glenoit Fabrics (HG) Corporation
Mr. Johnny Baines — Eastern Environmental Management, LLC
File
any questions or concerns
Joe Beaman (HES) at (919)

GL E ; o IT GLENOIT FABRICS [HG] CORPORATION
March 29, 2006
Ron Boone
1628 Mail Service Center
Raleigh, N. C. 27699-1628
Dear Mr. Boone:
This is a follow-up of your inspection of March 6, 2006.
A. On March 16'" we sent soil sample to Southern Testing
to be tested for oil
B. On March 2& contacted Shaun Joyner of Appian
Consulting Engineers
C. On March 24'" Shaun inspected site
D. On March 28t' contacted Johnny Baines of Eastern
Environmental Management to clean up the site
E. Johnny Baines set a date of April 5-7 to clean site
Thank you for your cooperation in this matter.
Regardsv�^
6erry Howard
Glenoit Fabrics (HG) Corporation
3001 NORTH MAIN STREET I P.O. 0OX 40111 TA R BO R 0, NC 27886 T 252 823.7798 F 252 641. 5195

1/
Michael F. Easley, Governor
\o17Z W AT �RpG
> l L/_WZ%_^1 _,
March 23, 2006
Mr. Jerry Howard
Plant Manager
Glenoit Fabrics [HG] Corporation
3001 North Main Street
P.O. Box 4011
Tarboro, NC 27886
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Subject: Notices of Violation Resulting from Compliance Evaluation
Inspections on 03/09/2006, for NPDES General Wastewater
Permit No. NCG500307 (NOV-2006-PC-0080) and NPDES
General Stormwater Certificate of Coverage NCGI70023
(NOV-2006-PC-0079) and Follow -Up Site Visit Conducted
17 Mar 2006
Glenoit Fabrics [HG] Corporation -Tarboro
Edgecombe County
Dear Mr. Howard:
Mr. Ronald Boone, of the North Carolina Division of Water Quality, Surface Water Protection Section,
conducted compliance evaluation inspections (CEI) for the permits referenced above at Glenoit Fabrics
[HG] Corporation's Tarboro, NC plant on 9 March 2006. Thank you for your assistance and
cooperation in providing him a tour of the site, as well as an interview to review your wastewater and
stormwater management programs. Please use the permit references listed throughout this report for
further explanation of each item cited.
SITE SUMMARY
• Your plant is a textile mill primarily involved in the weaving and dying of several different fabrics.
• Wastewater is produced from several cooling systems and possibly one air compressor system.
Cooling system water is treated with proprietary chemicals that contain Sodium Hypochlorite.
• Stormwater generated at your site is collected via a system of in -ground drains.
INSPECTION FINDINGS
General
Mr. Roy Lee, a plant electrician, provided Mr. Boone a tour of the facility and answered all of Mr.
Boone's questions. According to Mr. Lee, Mr. Tom Breedlove, an employee formerly responsible
for your wastewater and stormwater programs, left the company in December 2005. No one has
been hired to replace him yet. Mr. Lee also stated that no one else was available that would have
been better suited to show/discuss your plant's wastewater/stormwater management programs.
No `hCarolina
,ll�atura!!y
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: h2o.enr.state.ne.us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

Glenoit Fabrics [HGJ Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG170023 & NCG500307 Page 2 of 8
s '
• There were several areas of the plant that showed a lack of general housekeeping/maintenance.
• The two docks used to load/unload chemical deliveries for the latex recovery systems were full of
water, one of which was colored a deep milky white, indicating a spill of a considerable amount of
ALAR, hydrated lime, or other chemical used in this process (see attached photo). Although the
water/chemicals contained by this loading dock are subsequently pumped to the pretreatment
system located on the front (south) side of the plant, the dock should not be used continuously as
waste chemical containment. Use as a temporary containment structure for chemicals that are
spilled during the loading/unloading process is acceptable, but the chemicals should not remain in
the loading dock for extended periods of time and the loading dock should be kept as clean as
possible. This situation presents a few possible hazards such as: 1). The chemicals can be spread
by vehicles/personnel that come into contact with them, 2). It could become a drowning hazard, and
3). If personnel at the facility do not know the hazards associated with these chemicals, they may
not take appropriate precautionary measures while in the area. The loading dock for the western
latex recovery system was also full of water. Although this water did not seem to be contaminated,
the accumulation of trash was excessive and the standing water still presents a drowning hazard.
o Note: By the time of the follow-up visit conducted 17 Mar 2006, the loading dock for
the eastern latex recovery system had been pumped out and cleaned.
• Some chemicals used'in the latex recovery process were stored outside on pallets (see attached
photos). Although they were "under cover" it was apparent that the existing cover would not
provide protection in a severe storm. We recommend that you store all such chemicals inside the
latex recovery room or modify the cover to protect the chemicals in all circumstances. Another
alternative would be to cover chemicals stored outside with waterproof tarps:,
• Staining of the pavement just outside the roll -up door for the eastern latex recovery room indicated
that chemicals might be sheet -flowing out of the building into the surrounding stormwater
catchments (see attached photos). The operator confirmed that residual chemicals on the floor are
often washed down the ramped floor to the pavement outside. Not only does this leave your
stormwater system and receiving water vulnerable to contamination, but vehicles/personnel can
subsequently spread these chemicals to other areas of the plant, causing other environmental/health
related issues. These practices should stop immediately. Any spills should be cleaned up and
properly disposed of.
• Waste sludge from the latex recovery process is being dumped in a large dumpster located on the
north side of the plant. The dumpster is not covered and stormwater falls directly into it. Leakage
from the dumpster was apparent during the inspection. This dumpster should also be fully covered
to protect it from stormwater.
o Note: By the time of the follow-up visit, dry absorbent material had been placed on the
leaked material. However, it had not yet been cleaned up.
• Piles of excess fiber were observed just outside and inside the property fence line on the northern
side of the plant. This practice should stop immediately and waste fibers should be disposed of
properly. Please note that if these fibers are contaminated with chemicals of a hazardous or toxic
nature they require special handling and disposal.
• One of the stormwater outfalls on the north side of the facility was the site of a petroleum spill (see
attached photos). This item is being addressed by way of a separate Notice of Violation (NOV).
o Note: By the time of the follow-up visit, Glenoit had attempted to cleanup the oil spill
and took samples for analysis. However, additional free product was found underneath
the end of the discharge pipe, requiring further cleanup and analysis. Further details of
the cleanup effort are forthcoming.

Glenoit Fabrics [HGJ Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG170023 & NCG500307 Page 3 of 8
Mr. Lee stated that there were several floor drains located throughout the facility and that he was
not sure where they drain. He also could not locate blueprints showing the existing floor drains. A
large variety of chemicals, including but not limited to acids, bases, scouring agents, and dyes, are
stored in the rooms aggregately known as the dye room. Although Mr. Lee and Mr. Ron Kanthak
(the Dyer) stated that chemicals spilled inside the dye room drain into the pretreatment system, it
was apparent that some chemicals could possibly leak out into the larger plant areas where Mr. Lee
indicated the floor drains are located. Furthermore, only one small chemical spill kit was located at
the plant, at the southwestern loading dock. Due to the amount of chemicals used at the plant, all
floor drains inside the facility should be identified and their ultimate discharge points (stormwater
or wastewater) determined. Once all drains and their points of discharge are identified they can be
addressed accordingly. You may also want to consider acquiring additional chemical spill kits for
your facility.
o Note: By the time of the follow-up visit, Mr. Lee claimed he was able to find the
blueprints in question. However, the blueprints were not shown to Mr. Boone and the
floor drains still remain a concern.
The secondary containment structure for waste oil in the storage barn on the north side of the plant
was cracked in two places. These cracks would allow spillage of waste oil outside of the
containment. These cracks should be repaired/sealed or the secondary containment replaced
immediately.
o Note: By the time of the follow-up visit, the cracks in this secondary containment had
been patched with grout or epoxy.,
Excessive erosion was observed around the area of SO2. This can negatively impact the receiving
waters and leave you vulnerable to further penalization if the erosion at your facility is
compromising the quality of the receiving waters. Appropriate measures should be taken to stop
this erosion and prevent it from happening in the future. Please note the requirements of Part IIl,
Section E, Paragraph 5, of permit NCG 170000 before undertaking any projects to alter your
stormwater system.
Cooling System Wastewater Discharge (Permit No. NCG500307, NOV-2006-PC-0080)
There were many autonomous cooling systems at the plant and at least one air compressor system.
Although Mr. Lee speculated that these discharges went to the pretreatment system, he could not
confirm this. The fact that you have permit NCG500307 indicates that you have at least one
discharge into waters of the state ofone 'or more of the waste streams covered by this permit.
Failure to identify and monitor any and all such discharges places you in violation. Please note that
this permit regulates the discharge of non -contact cooling water, cooling tower and boiler
blowdown, condensate, exempt stormwater, cooling waters associated with hydroelectric
operations, and similar wastewaters. Part I, Section C discusses the different types of discharges in
greater detail.
o Note: By the time of the follow-up visit, Glenoit had commissioned a former/retired
maintenance supervisor, Mr. Marvin Lee, to come in and assist with answering questions
from the inspection. Mr. M. Lee at first stated that all such discharges covered by this
permit discharged to the pretreatment system. However, inspection of the Stormwater
Pollution Prevention Plan (SP3), which also was not found until the follow-up visit, revealed
at least one cooling system discharge that discharges through stormwater outfall SO1, as
labeled in the SP3.

- Glenoit fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG170023 & NCG500307 Page 4 of S
Analytical monitoring records of the discharges discussed above were not available for inspection.
This indicates that this monitoring has not been accomplished. Had the monitoring actually been
accomplished however, the absence of such records still places you in violation of Part H, Section
D, Paragraphs 5, 6, and 7 as well as Section E, Paragraph 1.
You're currently using proprietary biocide chemicals that contain Sodium Hypochlorite in your
cooling systems. You're therefore required to monitor the discharge for total residual chlorine (Part
t, Section A(1)). Also, we have no paperwork on file indicating that you have approval to use the
stated chemicals in your discharge, as required in Part I, Section A(1).
Stormwater Discharge (Permit No. NCG170023, NOV-2006-PC-0079)
• At the time of the initial inspection the number and location of stormwater outfalls was unknown
and undocumented. You did not have a Stormwater Pollution Prevention Plan (SP3) as required in
Part 11, Section A, of your permit. However, by the time of the follow-up visit you had located your
SP3. Review of this document revealed a well -constructed stormwater management program, yet a
significant number of SP3 components had not.yet been implemented or were significantly
outdated, as follows:
o''�The site plan did not meet all requirements (Part II, Section A, Paragraph I and subparagraphs).
o/The stormwater management plan did not meet all requirements (Part 11, Section A, Paragraph 2
and subparagraphs).
o�The Spill Prevention and Response Plan (SPRP) did not meet all requirements (Part II, Section
/ A, Paragraph 3).
o The stormwater preventative maintenance and good housekeeping plan did not meet all
requirements (Part II, Section A, Paragraph 4).
o The stormwater employee -training program did not meet all requirements (Part II, Section A,
✓ Paragraph 5).
o The list of personnel responsible for the overall coordination, development, implementation, and
revision of the plan was outdated (Part II, Section A, Paragraph 6).
o'��fhe SP3 had not been reviewed/updated as required (Part II, Section A, Paragraph 7).
o The stormwater facility inspection program did not meet all requirements (Part II, Section A,
aragraph 8).
o The SP3 has not been implemented in accordance with Part II, Section A, Paragraph 9.
Please note that not all permit requirements are listed above. Refer to your permit to ensure you
meet all requirements.
• No records of the qualitative monitoring were available for inspection as required in Part I, Section
B of your permit. This indicates that the required monitoring has not been accomplished. Please
ensure that all future qualitative monitoring is accomplished, recorded and stored in accordance
with the conditions of your permit.
• According to our records Glenoit has another permit, COC NCGI70375, for a plant located at 3002
Anaconda Road in Tarboro. However, according to Mr. Lee this facility is closed. Please notify the
NC Division of Water Quality of this closure as required in Part III, Section B, Paragraph 2.
The above findings demonstrate mismanagement of your wastewater and stormwater management
programs and/or a misunderstanding of the requirements of your permits. Please be aware that these
findings constitute violations of North Carolina General Statute (NCGS) 143-215.1 et seq. and could
result in the assessment of civil penalties in an amount of up to 525,000 per day per violation.

Glenoit Fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG 170023 & NCG500307 Page 5 of 8
Please reply within 30 days of your receipt of this letter with a narrative of your plan to achieve full
compliance with your permit and your schedule for doing so. If you need assistance with understanding
any aspect of your permit, please do not hesitate to contact Mr. Boone for assistance at 919-791-4259.
Sincerely,
rL
Myrl !Nisely
Acting Raleigh Regional Surface Water Quality Supervisor
cc: Stormwater Permitting Unit
Central Files
Non -Point Source Compliance Enforcement Unit

Glenoit Fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCGI70023 & NCG500307 Page 6 of S

Glenoit Fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG170023 & NCG500307 Page 7 of S

Glenoit Fabrics [HG] Corporation, Compliance Evaluation Inspection, March 9, 2006, NCG170023 & NCG500307 Page 8 of 8

wArF9
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CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jerry Howard
Plant Manager
Glenoit Fabrics [HG] Corporation
3001 North Main Street
P.O. Box 4011
Tarboro, NC 27886
Subject: NOTICE OF VIOLATION
U Ssfalr$'"� Se'� re�ei" RECEIPT �
CERTIFIED MAIL„
No. ln_surance"y0oover8g P.�.1p°rded),
(Oomeshc MarlyOnty _ us s.co
� For delivery>Informatlonrv_isihour webslt'e�st www• 1 P`'
ru tEn w nameR q'U"�
MR JERKY HOWARD, PLANT MANAGER
90m1 POM908GLENOIT FABRICS tHGI CORPORATION
Ln 3001 NORTH MAIN STREET
0 ° P.O. BOX 4011
r" Siruet AN•
Yjo,C'TARBORO NC 27886
or PO gox Na NOVICEI. EDGECOMBE CO. 321/06
.jjy,"...—LW amailed: 321 /06
G.S. 143-215.75 et seq.
Oil Pollution and Hazardous Substance Control Act of 1978
3001 North Main Street
Tarboro, North Carolina, Edgecombe County
Dear Mr. Howard:
North Carolina General Statutes, Chapter 143, authorizes and directs the Environmental
Management Commission of the Department of Environment and Natural Resources to protect and
preserve the Water and Air resources of the state. The Division of Water Quality (DWQ) has the
delegated authority to enforce adopted pollution control rules and regulations. Based upon Mr. Ronald
Boone's observations on 9 March 2006, a #5 heating oil release has occurred at your place of business
located at the above address in Tarboro, North Carolina, Edgecombe County.
The DWQ has reason to believe that you are responsible for activities resulting in
noncompliance with North Carolina law. On 9 March 2006, Mr. Ronald Boone observed a spill of what
is believed to be a #5 heating oil, located in the stormwater outfall #2 (S02), of Glenoit Fabrics [HG]
Corporation's 3002 North Main Street plant, in Tarboro, North Carolina, Edgecombe County.
V� hCarollna a�tura/!y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC27699-1617 Phone [phone]
Internet wsrsr.nacat-N ialirv_orr Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10°/ Post Consumer Paper
Customer Service
1-877-623-6748

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CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jerry Howard
Plant Manager
Glenoit Fabrics [HG] Corporation
3001 North Main Street
P.O. Box 4011
Tarboro, NC 27886
Subject: NOTICE OF VIOLATION
G.S. 143-215.75 et seq.
Oil Pollution and Hazardous Substance Control Act of 1978
3001 North Main Street
Tarboro, North Carolina, Edgecombe County
Dear Mr. Howard:
North Carolina General Statutes, Chapter 143, authorizes and directs the Environmental
Management Commission of the Department of Environment and Natural Resources to protect and
preserve the Water and Air resources of the state. The Division of Water Quality (DWQ) has the
delegated authority to enforce adopted pollution control rules and regulations. Based upon Mr. Ronald
Boone's observations on 9 March 2006, a #5 heating oil release has occurred at your place of business
located at the above address in Tarboro, North Carolina, Edgecombe County.
The DWQ has reason to believe that you are responsible for activities resulting in
noncompliance with North Carolina law. On 9 March 2006, Mr. Ronald Boone observed a spill of what
is believed to be a #5 heating oil, located in the stormwater outfall #2 (S02), of Glenoit Fabrics [HG]
Corporation's 3002 North Main Street plant, in Tarboro, North Carolina, Edgecombe County.
o `
NhCarolina
A Wura!/y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.nc%%amr ua1iignrg Location: 512 N. Salisbury St. Raleigh, NC 27604 , Fax [phone]
An Equal OpportunitylAffrmafive Action Employer— 50% Recycled110% Post Consumer Paper

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Mr. Jerry Howard
Glenoit Fabrics [HG] Corporation
' March 20, 2006
Page 2
Specific Violations of the Oil Pollution and Hazardous Substances Control Act, are as follows:
G.S. 143-215.83(a) Unlawful Discharges:
It shall be unlawful for any person to discharge oil or other hazardous substances into or upon
any waters or lands within the state. The above noted discharges are in violation of this
statute.
2. G.S. 143-215.84(a) Removal of Prohibited Discharges:
Any person having control over oil or other hazardous substances discharged in violation of this
article shall immediately undertake to collect and remove the discharge and to restore the area
affected by the discharge as nearly as may be to the condition existing prior to the discharge.
You have not made sufficient efforts to comply with this statute as of this date.
3. G.S. 143-215.85 Required Notice:
Any person having control over oil or other hazardous substances discharged, shall immediately
notify the Department of the nature, location, and time of the discharge and of the measures
taken or are proposed to be taken to contain and remove the discharge. This office has not
received any reports from you associated with the above -mentioned releases as of the date
of the inspection.
To correct the above violations, you are required to do the following:
A. Cease discharging all "oil" or other hazardous substances on the land or waters of the state.
B. Cleanup the affected areas and collect soil and/or groundwater samples to confirm the clean up.
The soil and groundwater testing and laboratory analyses shall conform to the appropriate
sections of Groundwater Section Guidelines for the Investigation and Remediation of Soils and
Groundwater, July 2000 Edition.
C. SubC bmit.a.rep to the Raleigh Regional Office assessing the cause, significance, and extent of
the release, and listing all actions_
youu plan to take to prevent future releases and to cleanup the?
y observed releas< April 20, 200 .
You are requested to contact the Division in writing, within ten (10) days of receipt of this
letter, of your intention to comply and submit a response and a schedule for achieving
compliance. Civil penalties may have already been recommended for the violations cited above.
Failure to respond within the time specified and to voluntarily achieve compliance may result in
further enforcement action, to include a recommendation for proposed penalty assessment, which
provides for a civil penalty of not more than 55,000.00 for each violation.

r Mr. Jerry Howard
t Glenoit Fabrics [HG] Corporation
March 20, 2006
Page 3
Please take the corrective action(s) specified in Paragraph C for the above violation(s). A
report detailing the corrective action(s) taken must be submitted to the Raleigh Regional Office,
Department of Environment and Natural Resources, 1628 Mail Service Center, Raleigh, North Carolina
27669-1628, on or before 20 April 2006. Please note that we may require different or additional
corrective actions to be performed, other than those specified by you, to correct the above mentioned
violations. Your response and any questions you may have should be directed to Mr. Ronald Boone or
me of the Raleigh Regional Office, at 919-791-4200.
l
ly,n Langel
Acting Raleigh
( cc: Stormwater Permitting Unit
Central Files
Non -Point Source Compliance Enforcement Unit
Edgecombe County Health Department
er Quality Supervisor

April 28, 2006
Highlands
Environmental
Solutions, Inc. 9405 Greenfield Drive; Raleigh, NC 27615
Phone: [phone] / Fax: [phone] / w .hesnc.com
�PZ.0
Mr. Ronald Boone
North Carolina Department of Environment and Natural Resources
Raleigh Regional Office
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Submittal of Interim Report
Glenoit Fabrics (HG) Corporation; Tarboro; Edgecombe County; North Carolina
HES Project#25040
Dear Mr. Boone:
On behalf of Glenoit Fabrics (HG) Corporation (Glenoit), Highlands Environmental Solutions, Inc. (HES) is
submitting this correspondence as an interim report regarding a release of #5 fuel oil at the above
referenced site. As you are aware, Eastern Environmental Management, LLC (EEM) and HES have been
retained by Glenoit to provide environmental assessment and remediation services associated with the
subject petroleum release. On April 7, 2006, HES submitted correspondence requesting an extension of
the due date for remediating the subject release. Based on correspondence from your office dated April
20, 2006, it is our understanding that the requested extension will not be granted.
Representatives of EEM and HES first visited the Glenoit site on April 13, 2006- During this site visit,
EEM and HES personnel inspected the subject stormdrain outfall, as well as, the boiler room and fuel
storage area. Fuel oil (#5 fuel oil) is stored in an underground storage tank (UST) located just outside the
boiler room. The fill spout of the UST is situated within an aboveground concrete secondary containment.
During the site visit, minor staining was observed within the secondary containment, with very minor
staining observed on the ground surface outside of the containment. Petroleum product is delivered to
the boiler system via underground lines that were not accessed during the site visit.
Inside the boiler room, trench floor drains were observed around the boiler units. Steam emanated from
the water observed in the floor drains. Based on information provided by Glenoit personnel, the floor
drains capture water (condensate, blow -down, etc.) from the boiler units. This water discharges to an
underground pipe, which in turn discharges to an underground sump. The sump discharges to an
underground stormdrain pipe, which discharges in a wooded area approximately 150 yards to the North
of the boiler room. It is this stormdrain discharge that is the subject of the April 20, 2006 correspondence,
as well as, an earlier NOV. Apparent petroleum leaks (i.e stained pavement, black product on fuel lines,
etc.) were observed inside the boiler room during the April 13, 2006 site visit.
While the exact cause of the release has not beendefinitively determined and'is still being investigated by
HES, it is suspected that the petroleum impacted soil observed at the stormdrain outfall originated from

Mr. Ronald Boone
Glenoit Fabrics (HG) Corporation; Tarboro, North Carolina
April 28, 2006
Page 2
the boiler room area. While a release of product from the subject UST is possible, given the viscous
nature of #5 fuel oil, it is considered highly unlikely that fuel oil released from the UST could have
migrated to the stormdrain outfall under natural conditions. A more plausible release scenario is as
follows:
1. A petroleum release(s) occurs inside the boiler room,
2. The petroleum enters the floordrain system, and co -mingles with hot water from the boiler units;
3. The petroleum and hot water are discharged to the underground concrete pipe. The concrete
pipe serves as to insulate the water and fuel, allowing the fuel oil to remain fluid; and,
4. The released fuel is discharged at the stormdrain outfall.
Additional information will be required to confirm this release scenario.
On April 25, 2006, EEM and HES mobilized to the site to remediate petroleum -impacted soil at the
stormdrain outfall. During excavation, dark stained soil/sediment was observed downgradient of the
stormdrain outfall. During remediation activities, approximately 111 tons of petroleum -impacted soil were
excavated, and transported to Soil Works, Inc. for disposal via land application. The resulting excavation
measured approximately 40 feet long, with widths varying from approximately eight to 16 feet, and depths
varying from approximately 3.5 to 4.5 feet. Neither the stormdrain pipe nor soil immediately beneath the
pipe was excavated during remediation activities. Apparent groundwater was encountered in a sandy
clay unit, at a depth approximately four feet below grade. Neither free -product nor obvious hydrocarbon
sheens were observed on groundwater entering the excavation. During excavation activities, random soil
y�I -oo samples were collected for field screening purposes using a flame ionization detector (FID). Upon
completion of excavation activities, 12 soil samples were collected from the floor and sidewalls of the
excavation. samples �br"Y QQ" total oil and g ease by Method 9071. Add t onally, one compos Analytical
Lolaboratory esoil samplew scollec ed from/ the
excavated soil for disposal profile analysis (Gasoline range organics, by Method 5030; diesel range
organics, by Method 3545; and total oil and grease, by Method 9071). We anticipate receipt of laboratory
analytical data for these samples within two weeks. A formal report summarizing remediation activities,
as well as, laboratory analytical data, will be prepared upon receipt of the analytical data.
w+" � Observations made during outfall remediation activities suggest the petroleum impacted soil/sediment at
the stormdrain outfall resulted from several small release events over time, rather than one release event.
This supports the proposed release scenario with relatively small volumes of petroleum entering the
,y floordrain/stormdrain system over time, and being discharged at the subject outfall.
Additional site investigation activities are necessary at this site to (1) confirm the cause of the release, (2)
ensure future releases do not occur and (3) confirm that all petroleum -impacted media have been
remediated. In accordance with the provisions of your April 20, 2006 correspondence, Glenoit will be
performing the following actions, in association with the subject #5 fuel oil release:
1. Identification and Repair of all Fuel Leaks. All existing fuel leaks and/or potential fuel leaks inside
the boiler room will be identified and repaired
2. UST System Testing. Tightness testing will be conducted on the #5 fuel oil UST and all
associated product lines to verify their integrity.
3. Cleaning of Floordrain System. All liquid within the floordrain system inside the boiler room will
be removed, and the floordrain system properly cleaned to remove any accumulated residue
(fuel, grease, sludge, etc.) that may be accumulated. All evacuated liquids and/or solids should
be properly disposed.
4. Inspection/Remediation of the Stormdrain Pipe. The subject stormdrain pipe from which the
release emanated will be inspected and properly remediated. Potential options for accomplishing
this task include: Video inspection of the interior of the pipe, hydraulic jetting of the pipe to
remove sludge and debris, and/or removal and replacement of the pipe.
5. Assessment of Potential Petroleum Impacted Soil Upgradient of the Outfall Area. Additional soil
assessment activities will be performed upgradient of the outfall to determine if additional areas of

Mr. Ronald Boone
Glenoit Fabrics (HG) Corporation; Tarboro, North Carolina
April28,2006
Page 3
petroleum -impacted soil are present. These assessment activities will be conducted based on
the results of UST system testing and/or inspection/remediation of the stonmdrain pipe.
6. Review of Outfall Remediation Data. HES will review field and laboratory analytical data to
confine the success of soil remediation activities conducted at the stormdrain outfall. Additional
assessment and/or remediation activities may be recommended based on these data.
7. Preparation and Submittal of a Site Investigation Report. A project report detailing the findings of
site investigation activities will be prepared.
Glenoit will proceed in a time efficient manner to address the concerns of the NCDENR with regards to
the subject release. However, several of the proposed action items will involve subcontractors, and/or
time for receipt and review of necessary analytical data. HES proposes to submit the subject Site
Investigation Report to the NCDENR no later than July 1, 2006. Interim progress reports may be
prepared if requested by the NCDENR.
If there are any questions or concerns regarding this correspondence, or the project in general, please
contact Mr. Joe Beaman (HES) at [phone], or Mr. Jerry Howard (Glenoit) at 252-641-6034.
Sincerely,
Highlands Environmental Solutions, Inc.
Joe Beaman, P.G.
Principal Geologist
cc: Mr. Jerry Howard — Glenoit Fabrics (HG) Corporation
Mr. Johnny Baines — Eastern Environmental Management, LLC
File

'�p✓In DYtZ2A' e
General Stormwater Inspection Checklist
Type of Visit Compliance Inspection/Program Audit ❑Tech Assistance or Recon
Location: 3,!)z / AJ , Ha; h fi a��, ;o-
Facility Number NC 917ooz.3 Date -2/4/o 6.-i time InCla-o Time Out 26-4
People Interviewed, and Titles: rQGee K L� 1�
Name of Inspector: �, avy G ima 4 h 7 �j4 r
SPPP Documentation (Site Plan Part 11 (A) ))
1. Copy of Certificate of Coverage Dyes pCopy of Permit Dyes nKo Requested but not required
2. General Location USGS Map shows plant Oyes (t4o� lines of discharge P II(A)(I)(a)
to water of State Dyes Stream labeled Oyes 'o, Latitude and longitude OYes 0<0
Comments:
3. Narrative Descri ti n of Practices Dyes <o Part II(A)(1)(b)
4. Site map Dyes Cqt o Shows�ow's & areas served with arrows and Part II(A)(1)(c)
% impervious surface Dyes E o, buildings Dyes C9XO-, recess areas Dyes , o,
disposal eas Dyes ❑�to, drainage structures es pso, existing BMPs such as secondary containment
❑Yes �'o, list of potential pollutants ❑Yes � o
Comments:
5. List of significant spills in last 3 years or certif. if none Oyes 'o Part II(A)(1)(d)
RRO called? Dyes DNo
6. SW outfalls have been evaluated for process water Dyes 'o Part II(A)(1)(e)
7. Feasibility of Changing Practices Dyes :'o Part II(A)(2)(a)
S. Secondary Containment Dyes DK-0' Schedule needed? Dyes ❑jNo 441w- Part II(A)(2)(b)
Records of Draining Containment, Observations Made Dyes pNo
9. BMP Summary Dyes "0 Part II(A)(2)(c)
10. SPRP Plan Dyes o, Responsible personnel still employed here? Dyes ONo /J/- Part II(A)(3)
11. PM and Housekeeping Plan Dyes RK Record of Inspections? Oyes UR o Part II(A)(4)
12. Employee training Dyes 9?6�- for everybody Dyes D?co Part II(A)(5)
13. Responsible parties, chain of command page ❑Yes F! 7Ko Part II(A)(6)
14. Plan updated/reviewed annually Oyes pT o Part II(A)(7)
15. Stormwater Facility Inspection Program Oyes < o Part H(A)(8)
16. This Plan Has Been Implemented (documents in manual, Part II(A)(9)
employees show awareness Dyes ❑No Comments: ,11,¢
Sampling and Analytical Data Part II(C)
All Stormwater and Process Water is Recycled 11C 3 Dyes o
Rain Gauge on site (not required) Dyes D<o
Record of an overflow Dyes 2<oDetails
If not all recycled, what is allowed to discharge? Vehicle Cleaning (IIC2) ❑ Recycle overflow (IIC3
above) ❑ Wetting of Aggregate (IIC4)❑ Mixing drum cleanout (TICS) ❑ Vehicle Maintenance ❑
Note: this checklist does not take the place of your permit. You are fully responsible for
following the permit.

For the topics checked in last question, Analytical data present ❑Yes gjNo, Compliant? []Yes ❑No NIA -
Details:
Total precip OYes o, Storm duration ❑Yes u�'Total flow Est. []Yes L?<o,Field pH ❑Yes ©Ko,
Chain of custody ❑Yes• 1 o
Qualitative Monitoring performed semiannually pYes 2-'o Part II(F)
Stormwater not combined with process wastewater — general runoff PartII(C)(1)
Analytical data ❑Yes GqKo, Chain of Custody ❑Yes CKo, Qualitative Monitoring performed
semiannually (Section F) ❑Yes QK-0
If using cutoff policy, how many sample rounds Lf%crx�`
Cutoff Concentrations met ❑Yes ❑No Ever have a Bypass? ❑Yes ❑No (III (C)(4)al&2)
Notification given? pYes ❑No
Outdoor Inspection V�n
I located all discharge points ❑Yes []No No. of areas served
Sample points appropriate ❑Yes ❑No AN A
Location if different from discharge point
Housekeeping: Trash IWYes ❑No Dust ❑Yes MNo
Take pH ❑Yes a ,'o Value(s) /�-
r
Take photos QYes ON'o �A�ni�r-„�`-"I
Containment Area satisfactory ❑YzNo, Loose drums p'Ises []No, Locked dram es ❑No oi.
V-' 07
Inspection Summary Comments A" ao�
/1"j ,C.'r-'
Recommendations:
Requirements:
Letter is to go to:
Name
Title
Address
Helpful Information at http://h2o.enr.state.nc.us/su[Manuals Factsheets.htm
Note: this checklist does not take the place of your permit. You are fully responsible for
following the permit.
Revised 7/23/03, 10/2 1/03, 4/13/05

c576V�
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
January 21, 1994
Mr. David E. Gurley, Jr., CPE
Plant Engineering Manager
Glenoit Mills, Inc.
Post Office Box 1157
Tarboro, North Carolina 27886
✓®
dh Z
�Fhj�R e d JYp!
R9� 1%
Subject: NPDES Stormwater Permit Application
NOI for NCG050154
Glenoit Mills, Inc.
Edgecombe County
Dear Mr. Gurley:
On December 8, 1993, the Division of Environmental Management received an NPDES
Stormwater Permit Notice of Intent (NOI) for the subject facility to be covered by General Permit
NCG05000. We have reviewed your application and find that your industrial activity stormwater
discharge(s) does not qualify for coverage under General NPDES NCG050000.
General Permit NCG05000 covers stormwater discharges from facilities primarily engaged in SIC
Group 23 (Apparel and other finished products made from fabrics). Your NOI application identified your
facility as an SIC Code of 2253. According to the SIC Manual of 1987, this particular category involves
industries that are "...engaged in knitting outerwear from yarn or in manufacturing outerwear from knit
fabrics produced in the same establishment."
Presently there is no general permit for industrial activities in SIC Group 22. Your only
application alternative is to complete and submit an individual application (Forms I and 217, attached).
Your NOI submittal is being returned and your fee will be refunded in the near future.
If you have any questions concerning this letter, please contact Stephen Ulmer at 919 / 733-5083.
Sincerely,
1 ��6_11z,
David A. Goodrich, Supervisor
Enclosure (Forms 1 and 2F) f_NPDES Group
cc: (Steve Mitchell, -Raleigh Regional Office
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O.. Box 29535, Raleigh;.North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

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Ron Boone
From:
Priscilla Benson [[e-mail])
Sent:
Thursday, July 06, 2006 3:09 PM
To:
Ron Boone
Subject:
Glenoit Fabrics enforcement
Priscilla.Benson.vd
Hi Ron,
I'm going over your package for Glenoit fabrics right now. Sorry it has
taken us a bit to get to it. Everything looks really good! One thing
that I wonder if you could get for the case are the results from the oil
samples that Jimmie Greer took. We can include the costs for running
those tests in the enforcement costs of the case. It is important to
have those results in the case file plus I need the sample number to get
the lab to send me an invoice for them. Just fax them to me when you
get them to the number in my signature line.
Another thing is that I can't find the emailed F&D for the case, so
could you email that to me, as well as the one for the the other case
you sent.
Thanks a. lot.
Priscilla
Priscilla L. Benson
Environmental Specialist
NC DENR - Division of Water Quality
Non Point Source Assistance and Compliance Oversight Unit
Phone: [phone] ext. 360
Fax: [phone]
[e-mail]

FAX COVER SHEET
NORTH CAROLINA
DEPARTMENT RTMENT OF ENVIRONMENT
AND NATURAL. RESOURCES
Raleigh Regional Office
NCDENR 16 Mail Service Center
OVMT'"�M or
Raleigh, NC 27699-1626
.,. G.nouru FLW-
EMVI�OMNFM Wo NEVN/y ��
Pages, including cover sheet
9�33.
FAX: 9G/ z
TO: ?"5C D�ATE: 07-07-
FROM:
SUBJECT:
L ��/�csµlfr Ala -moo,
MESSAGE: F
tde.�
NAG
If you do not receive all pages, call 919. 7�01 or fax back to 919.571.4718.
EN TEO Krn THE FAX NUMBER REMAINS THE SAME

NC Division of Water
Quality Laboratory Section Results
Loc. Descr.: GLENOIT FABRICS
V0
Location ID: RROAPNLC
Sample ID:
A602288
County: Edgecombe
PO Number #
6G0478
� .
River Basin
V sitlD
Report To RROAP
Region: RRO
Date Received:
03/2112006
Collector: J GREER
Sample Matrix: SoillSediment
Time Received:
Labworks LoginlD
16:00
JWA
Loc. Type:
Date Reported:
04/26/2006
D
Sample Depth
O
Collect Date: 03/1712006
Collect Time:: 10:15
nalyte Name .
PQL \ Result Qualifier Units
Approved By
LAB
Sample temperature at receipt by lab
0.0 °C
JGOODWIN
SEM
TPH Diesel Range Organics in solid
10 350 P mg/Kg
RKELLING
WET
Grease and Oil in solid
10 6040 J4 mg/Kg
CGREEN
Laboratory Section>> 1623 Mail Service Center, Raleigh, NC 27699-1623 [phone]
Paae 1 of 1

COUN I Y :
EDGF.COMBF
QUAD NO:
REPORTTO :
RRO
Regional Office
COLLECTOR(S)
: J GREE WR DOONF.
DATE:
3/172006
TIML
— TTU.T�
PURPOSE:
COMPLAINT: SPILL
Owner:
-
Location or Site:
Description ol'sampling
Sampling Method:
Remarks:
LABORATORY ANALYSIS
DOD 310 mgfK9
COD Ilight 340 mg/Kg
COU I,a. 335 g/KEr
Cali form- MF Iica131616
CmilbmcSET Last 31504
TOC m Kg
-I urbidit N'IU
Residue., Suspended 530 mg/Kg
'1'ma1 Sus nded solids m
I ..its
Alkalinity to pH4.5 g
Alknlmily m PH g.3 g
Carbonam mg(Kg
Ricarhonarc mg K
Carbon dioxide mg/Kg
Chloride g
Chromium: Ilex 10J2 g
Color: Tore 1, en.
Cyanide 720 mg/Kg
COMM HINTS :
DIVISION OF WATER QUALITY
Chemistry Leboralm, Repo" / Ground Water Quality
SAMPLE PRIORITY
X]ROUTINE EMERGENCY
CRAM OF CUSTODY ❑
2
S� SAMPLE TYPE
GLF.NIOT FABRICS
3001 N MAIN ST I ARB0140 NC 27886
EXPECT NfL511FATING 011,
Diss. Solids 70300 mg1Kg
Fluoride951 - mgfKg
Hardness: total 900
I lardnes,(ann-carb)902 negfKg
Phenols 32730
Spceific Cond. 95 .mhos/ant
Sulfate mg/Kg
Sulfide 745 mg/Kg
MDAS
X
Oil and Grease 6040,J4 m K
Silica m
Boron
Fcmtnldchyde ragA.
NI13 as N 610 mEbKg
'FKN as N 625 mSfKg
NO2 �NO3 as.630 mg/K
P: Total as P 665 m K
PO4 g
Nitrate (NO, as N) 620
Nivite(NO, as N) 615
Ag-Silver 46566 mg/ g
AI -Aluminum 46557 m K
As -Arsenic 46551 n K
❑a -Barium 46558 n K•
Ca -Calcium 46552 ig K,
Cd-Cadmium 46559 m • K
Cr-Chromium 46560 mg/K
Cu-Copper 1042
Fs -Iron 1045 mgfKg
H - Mm-rmy 71900 mgfKg
K-Potassium 46555 m g
Mg - Magnesium 927
Mn-Mangancsc 1055 m • Kg
No -Sodium 929 t Kg
Ni-Nickel n Kg
Pb-Lead 46564 m g
Se -Selenium an 9
Zn-Zinc 46567 mg/Kg
Lab Number AR02288
Date Received 321/2006
Time Received : 4:001'M
Received 0y HMW�f')s
d By 44MM
Data reported: 4R4I1006
Pesticides
I I Acid herbicides I
1-Ill I?X
l0
A502288

GROUNDWATER FIELD/LAB FORM
County z
Quad No Serial No.
Lat.
SAMPLETYPE
❑ Water
ffsoll
❑ Other_
R� ��ui�PNLC III
eport To: ARO, FRO, MRO, BO WaRO, WiRO, L
WSRO, Kinston FO, Fed. Trust Central Off., Other:
Shipped by: Bus, Courie Hand De., Other,
Collector(s): fr2/ Date 3 / 7 m6 Time
FIELD ANALYS
pH400 Spec. Cond.94 at_250 C
Temp.10 eC Odor
Appearance
Field Analysis By
, nn�nnT�nv KXlnl vo CC
Long. —
SAMPLE PRIORITY
[9-Routine
❑ Emergency
❑ Chain of
Owner
Location or site
Descriptic
Sampling
Remarks
North Carolina
Department of Environment and Natural Resources
DIVISION OF WATER QUALITY - GROUNDWATER SECTION
TIJU, USS Lab Number
0
Date Received
Rec'd bv:—
Other:
_Time
Bus, Courier, and De ,
Data Entry By: Ck:
Date Reported:
Purpose:
Basel , Complaint, ompliance�LUST, Pesticide Study, Federal Tru Q� er — > >�
LHDVnmiunr
lS jVi TQGQ
BOD 310 m /I
Diss. Solids 70300 mrill
A - Silver 46566 u /1
Or anochlorine Pesticides
COD High 340 mg/I
Flouride 951 m /I
At - Aluminum 46557 u /I
Organophosphorus Pesticides
COD Low 335 m /I
Hardness: Total 90 I
AS - Arsenic 46551 U /l
Nltrc en Pesticides
Coliform: MF Fecal 31616 /100ml
Hardness noncarb 902 m A
Ba - Barium 46558 u A
Acid Herbicides
Coliform: MF Total 31504 /100ml
Phenols 3 730 uoA
Ca- Calcium 46552 m /I
PCB's
TOC 680 m /I
Snecific Cond, 95 uMhoS/CM2
Cd - Cadmium 46559 u /l
Turbidity 76 NTU
Sulfate 945 m /I
Cr - Chromium 46560 u /I
Residue., Suspended 530 mg/I
Sulfide 745 m /I
Cu - Copper 46562 u /l
Fe - Iron 46563 u /I
Semivolatile Organics
-
Oil and Grease- m /I
Hg - Mercury 71900 ug/I
TPH - Diesel Range
PH 403 unit
/ 9c!
K - Potassium 46555 m /l
Alkalinity to pH 4.5 410 mg/I
M - Ma nesium 46554 mg/1
Alkalinity to pH 8.3 415 mg/I
Mn - Manganese 46565 u /I
Carbonate 445 mg/I
NH as N 610 m /I
Na - Sodium 46556 mg/11
Volatile Organics (VOA bottle)
Bicarbonate 440 m /I
TIM ARM Rgs mall
Ni -
TPH - Gasoline Range
Carbon dioxide 405 mgA
NO + NO as N 630 m /I
Pb - Lead 46564 u A
TPH - BTEX Gasoline Wnge
Chloride 940 mgA
P: Total as P 665 m A
Se - Selenium u /I
Chromium: Hex 1032 ugA
Zn - Zinc 46567 u /l
Color: True 80 CU
i IF
Cyanide 720 mg/I
Lab Comments:
GW-54 REV. 12/1
For Dissolved Analysis - submit filtered sample and write "DIS" in bl

Report to: _RRO
NC DENRIDWQ Laboratory
Sample Anomaly Report (SAR)
Lab Number:
AB02288
Station Location:
GLENOIT
FABRICS
ample Type:
SOIL
Date collected:
3/17/2006
Sample ID: 2
County: EDGECOMBE Region: RRO
Priority: ROUTINE Collector:
Date received: 3/21/2006 Date analyzed:
Affected Parameter(s): OIL AND CREASE
Analytical Area (check one):
®INCH -❑METALS
❑NUT ❑MICRO
The following anomalies occurred (check all that apply):
❑Samples
❑Improper container used
❑ VOA vials with headspace
❑Sulfide samples with headspace
❑Samples not received, but listed on fieldsheet
❑Samples received, but not listed on fieldsheet
❑Mislabeled as to tests, preservatives, etc.
❑Holding time expired
❑Prior to receipt in lab
❑After receipt in lab
❑Insufficient quantity for analysis
❑Sample exhibits gross non -homogeneity
❑Sample not chemically preserved properly
❑pH out of range (record pH):
❑Improper chemical
❑Residual chlorine present in sample
❑Color interference
❑Heavy emulsion formed during extraction
❑Sample bottle broken in lab - no reportable results
❑Other (specify):
Comments: ANALYZED USING A MODIFIED METHOD 9071A
Corrective Action:REPORTED WITH QUALIFICATION CODE
J GREER/R BOONE
3/22/2006
❑VOA ❑SVOA
❑PEST
❑Quality Control
❑Instrument failure —no reportable results
❑Analyst error— no reportable results
❑Surrogates
❑None added
❑Recovery outside acceptance limits
,❑Spike recovery
❑None added
❑Recovery outside acceptance limits
❑Failed to meet criteria for precision
❑Internal standards
❑Blank contamination
❑QC data reported outside of controls (e.g., QCS, LCS)
❑Incorrect procedure used
®SOP intentionally modified with QA and Branch Head
approval
❑Invalid instrument calibration
❑Elevated detection limits due to:
[]Insufficient sample volume
❑Samples were rejected by DWQ Lab. Authorized by: Date:
❑Accepted and analyzed after notifying the collector or contact person and determining that another sample could not be secured.
❑Sample(s) on hold until:
®Sample reported with qualification. Data qualification code used:J4
❑Other (explain):
Notification Required? ❑ Yes ❑ No
Person Contacted: Date:
Form completed by: HEIDI L HU
Lead Chemist Review (initial):
❑BIOCHEM 1' L)
❑METALS
Branch Head Review (initial) il): ES
QA/QC Review (initial)
❑ PEST
❑VOA
Date: 3/23/2006
❑SVOA
Logged into database by (initial):
Wor &s aboramry\SM 10/23/01 dbs

ENR/DWO LABORATORY
pC SEMIVOLATILE TPH DIESEL RANGE REPORT
REPORTED BY '7
CHECKED BY
REVIEWED BY
SAMPLE TYPE: SOIL
ANALYTICAL RESULTS
DIESEL RANGE ORGANICS 100 350
P- Elevated POL due to matrix interference and/or sample dilution.
POL- Practical Ouantitation Limit- Subject to change due to
to instrument sensitivity.
J1- Estimated Value
U- Sample analyzed for this compound but not detected.
N3- Estimated Value;lhe estimated concentration is less than the
laboratory POL and greater than the laboratory method
detection limit.
A- Value reported is the mean(average) of two or more determinations.
LAB NO. AB02288
SUPERVISOR
DATE Q
ENTERED BY
DATE G

NC Division of Water Quality Laboratory Section Results
Loc. dek-r.:
GLENOIT FABRICS
Location ID:
RROAPNLC
Sample ID:
AB02287
County:
Edgecombe
PO Number#
6G0477
River Basin
VisitlD
Report To
RROAP
Region:
RRO
Date Received:
03121/2006
Collector:
J GREER
Time Received:
16:00
Sample Matrix:
Soil/Sediment
Labworks LoginlD
JWA
Loc. Type:
Date Reported:
04/2712006
Sample Depth
Collect Date:
03/17/2006
Collect Time::
10:00
LAB
Sample temperature at receipt by lab 0.0 C JGOODWIN
°
SEM
TPH Diesel Range Organics in solid 10 - 7900 P,J1 mg/Kg RKELLING
WET 4020 J4 mg/Kg CGREEN
Grease and Oil in solid 10
)�
l
Laboratory Section>> 1623 Mail Service Center, Raleigh, NC 27699-1623 [phone]

COUNTY :
QUAD NO:
EDGECOMBE
REPORTTO :
RRO Regional Office
COLLECTOR(S)
: J GREER/R BOONE
DATE:
3/17I2006
TIME:
DIVISION OR WATER QUALITY
Chemistry Laboratory Report I Ground Water Quality
SAMPLE PRIORITY
IROUTINE EMERGENCY
CHAIN OF CUSTODY 1
S� SAMPLE TYPE ❑
PURPOSE: COMPLAINT: SPILL Owner. GLENIOT FABRICS
Location or Site: 3001 N MAIN ST TARBORO 27886
Description of sampling point
Sampling Method:
Remarks:
LA RORATORY ANALYSIS
BOD 310 mg/K9
COD High 3J0 mg(K
COD Low 335 m K
Culilmor: MF Fecal 31616
Colifo m: MF Total 31504
TOC
Turbidity NTU
Residue., Suspended 530 m Kg
Tom[ Suspended solids mgfKg
pH ..its
Alkalinity, to PIT 4.5 m g
Alkalini to H 8.3
Carbonate mEig
Bicarbonate -Osg
Carbon dioxide mgig
Ch[ondc mgfKg
Chromium: Hex 1032 u
Ca[oo Tmc 80 c.u.
Cyanide 720 mWKg
COMMENTS:
Lab Number
AU0228'.
Dote Received :
3RIf2006
Time Received :
4:00 PM
Received By :
IIMW
R ,.Cd By `: '-
Date reported: 4R6R006
nBOM87

GROUNDWATER FIELD/LAB FORM
County
Quad f,
Serial No.
Lat. Long.
IzIF-OA?IV i C �QW
Report To: ARO, FRO, MRO�OUYVaRO, WiRO,
SAMPLE TYPE
Water
Soil
Other_
WSRO, Kinston FO, Fed. Trust, Central Off., Other:
Shipped by: Bus, Courier and Del., then
Collector(s): - ;+PerDate 3 / 7 Z2L Time
k' FIELD ANALYS
pH400 Spec. Cond.94 at 250 C
Temp.10 GC Odor —_F7 -4-cr"
Appearance A JL
Field Analysis By:
❑ Chain
North Carolina
Department of Environment and Natural Resources
DIVISION OF WATER QUALITY - GROUNDWATER SECTION
SAMPLE PRIORITY `DlJ tlflrl ��QD gLab Number 6
JARoutine / Date Received
❑ Emergency Rec'd by:_
Other:
of Custody Data Entry By: -
Owner
Location or site
Description of sar
Sampling Method
Remarks / '
Date Reported
A I Time 1 01) v
From: Bus, Courier, anr-f5 .,
Ck:
Purpose: CD . ��
Baseline, plaint ompliance�L�UST, Pesticide Study, Federal Trus1er
Sample Interval C�-
LABORATORY
ANALYSES
BOD 310 m /I
Diss. Solids 70300 m /I
A - Silver 46566 u /I
Or anochlorine Pesticides
COD High 340 mgA
Flouride 951 m
At - Aluminum 46557 uqA
Organophosphorus Pesticides
COD Low 335 m I
Hardness: Total 900 m
As - Arsenic 46551 u A
Nitro en Pesticides
Coliform: MF Fecal 31616 /100m1
Hardness noncarb 902 m A
Be - Barium 46558 u /I
Acid Herbicides
Coliform: MF Total 31504 /100m1
Phenols 32730 u
Ca - Calcium 46552 m /1
PCB's
TOC 680 m /I
SDeCifiC Cond. 95 uM c
Cd - Cadmium 46559 u A
Turbidity 76 NTU
Sulfate 945 m A
Cr - Chromium 46560 u /I
Residue., SuspenA410mgA
Sulfide 745 m
Cu - Copper 46562 ugA
EE]
Fe - Iron 46563 ugA
Oil and Grease *Z; 0, l m A
Hg - Mercury 71900 ugA
PH 403
K - Potassium 46555 mgA
Alkalinity to pH 4.M
- Ma nesium a6554 m /Alkalinity
to pH 8
Mn - Man anese 46565 u /I
Volatile Organics (VOA bottle)
Carbonate 445
NH as N 610 m A
Na -Sodium 46556 m /1
TPH - Gasoline Range
Bicarbonate 440 m /I
TKN as N CPS mn1l
Ni - Nickel Uall
Pb - Lead 46564 u /I
TPH - BTEX Gasoline ange
Carbon dioxide 405 mgA
NO + NO as N 630 mqA
Chloride 940 mgA
P: Total as P 665 m
Se - Selenium u /I
Chromium: Hex 1032 ugA
Zn - Zinc 46567 u /I
Color: True 80 CU
Cyanide 720 mg/I
-Lab Comments:
GW-54 REV. 12A For Dissolved Anal sis - submit filtered sample and write "DIS" in bl
'r Stu 7/

Report to:
NC DENR/DWQ Laboratory
Sample Anomaly Report (SAR)
Lab Number:
AB02287
Station Location:
GLENOIT
FABRICS
ample Type:
SOIL
Date collected:
3/17/2006
Sample ID: I
County: EDGECOMBE Region: RRO
Priority: ROUTINE Collector: J GREER/R BOONE
Date received: 3/21/2006 Date analyzed: 3/22/2006
Affected Parameter(s): OIL AND GREASE
Analytical Area (check one):
®WCH ❑METALS
❑NUT ❑MICRO
The following anomalies occurred (check all that apply):
❑Samples
❑Improper container used
❑VOA vials with headspace
❑Sulfide samples with headspace
❑Samples not received, but listed on fieldsheet
❑Samples received, but not listed on fieldsheet
❑Mislabeled as to tests, preservatives, etc.
❑Holding time expired
❑Prior to receipt in lab
❑After receipt in lab
❑Insufficient quantity for analysis
❑Sample exhibits gross non -homogeneity
❑Sample not chemically preserved properly
❑pH out of range (record pit):
I—hmoroner chemical
Residual chlorine present in sample
Color interference
Ileavy emulsion formed during extraction
Samole bottle broken in lab - no reportable results
❑Other (specify):
Comments: ANALYZED USING A MODIFIED METHOD 907IA
Corrective Action:REPORTED WITH QUALIFICATION CODE
❑VOA ❑SVOA
❑PESI'
❑Quality Control
❑Instrument failure —no reportable results
❑Analyst error —no reportable results
❑Surrogates
❑None added
❑Recovery outside acceptance limits
❑Spike recovery
❑None added
❑Recovery outside acceptance limits
❑failed to meet criteria for precision
❑Intemal standards
[]Blank contamination
❑QC data reported outside of controls (e.g., QCS, LCS)
❑Incorrect procedure used
[DSOP intentionally modified with QA and Branch Head
approval
[]invalid instrument calibration
❑Elevated detection limits due to:
❑Insufficient sample volume
❑Samples were rejected by DWQ Lab. Authorized by: Date:
❑Accepted and analyzed after notifying the collector or contact person and determining that another sample could not be secured.
❑Sample(s) on hold until:
®Sample reported with qualification. Data qualification code used:J4
❑Other (explain):
Notification Required? ❑ Yes ❑ No
Person Contacted: Date: ,
Form completed by: HFIDI L HUSTON Date: 3/23/2006
Lead Chemist Review jinitial)t ❑SVGA
❑BIOCHEM `AC-) ❑PEST
❑METALS ❑VOA
Branch Bead Review (initial): Logged into database by (initial):
QA/QC Review (initia
10/23/01 db,
W.. LLeb.m.mry SAa

ENRIDWQ LABORATORY LAB NO. AB02287
SEMIVOLATILE TPH DIESEL RANGE REPORT
SUPERVISOR
REPORTEDBY %C DATE
s_ �a
CHECKED BY—� y1,,
� REVIEWED BY ENTERED BY7-YY� • �/
DATE
SAMPLE TYPE: SOIL
ANALYTICAL RESULTS
DIESEL RANGE ORGANICS 200 7900 Jt
P- Elevated POL due to matrix interference and/or sample dilution.
PQL- Practical Quantitation Limit- Subject to change due to
to instrument sensitivity.
J1- Surrogate recovery limits less than laboratory control limit.
U- Sample analyzed for this compound but not detected.
N3- Estimated Value;the estimated concentration is less than the
laboratory PQL and greater than the laboratory method
detection limit.
A- Value reported is the mean(average) of two or more determinations.

W A T4S9
0
/] 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
July 31, 2006
Mr. Jerry Howard CERTIFIED MAIL
Glenoit Fabrics [HG] Corporation RETURN RECEIPT REQUESTED
3001 North Main Street 7003 1680 0001 0743 1335
PO Box 4011
Tarboro, NC 27886
SUBJECT: Assessment of Civil Penalties
Textile Mills General Stormwater Permit No. NCG 170060
Non -Contact Cooling Water General Wastewater Permit No. NCG500000
Glenoit Fabrics [HG] Corporation
Edgecombe County
Case No. OC-2006-0002
Dear Mr. Howard:
This letter transmits notice of a civil penalty assessed against Glenoit Fabrics [HG] Corporation
in the amount of $15,826.33,which includes $1,326.33 in investigative costs. Attached is a copy
of the assessment document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the Secretary
of the Department of Environment and Natural Resources and the Director of the Division of
Water Quality. Any continuing violation(s) may be the subject of a new enforcement action,
including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following three options.
These items are detailed below:
1. Submit payment of the penalty, OR
2. Submit a written request for remission, OR
3. Submit a written request for an administrative hearing.
Option 1- Submit payment of the penalty:
Payment should be made to the order of the Department of Environment and Natural
Resources (DENR)-. Payment of the penalty will not foreclose further enforcement action
for any continuing or new violation(s). Do not include the attached waiver form if
making payment. Please send payment to the attention of:
Ms. Priscilla Benson
NC Division of Water Quality — NPS Assistance & Compliance Oversight Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 0.
N Carolina
atura/!y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: w .ncwaterquality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50 % Recycled/10% Post Consumer Paper

Glenoit Fabrics [HG] Corporation
Edgecombe County
Case No. OC-2006-0002
Page 2 of 3
Option 2 — Submit a written request for remission including a detailed justification for
such request:
A request for remission or mitigation is limited to consideration of the reasonableness of
the amount of the'penalty and is not the proper procedure for contesting the accuracy of
any of the statements contained in the assessment letter.
Because a remission request forecloses the option of an administrative hearing, such a
request will not be processed without a waiver of your right to an administrative hearing
and a stipulation that there are no factual or legal issues in dispute. You must execute
and return to this office the attached "Waiver of Right to an Administrative Hearing and
Stipulation of Facts" and the attached "Justification for Remission Request' which
should describe why you believe:
(a) one or more of the civil penalty assessment factors in G.S. 14313-282.1(b) were
wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from the
violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please submit this information to the attention of:
Ms. Karen Higgins
NC Division of Water Quality — NPS Assistance & Compliance Oversight Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Option 3 — Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must request an
administrative hearing. This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 150B of the North
Carolina General Statutes. You must file your original petition with the:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
You must also mail or hand deliver a copy of the written petition to:

Ms. Mary Penny Thompson
NCDENR
Office of General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
Glenoit Fabrics [HGl Corporation
Edgecombe County
Case No. OC-2006-0002
Page 3 of 3
AUG 2 - 2006
And to: I, : - -, -
Mr. Shelton Sullivan
NC Division of Water Quality — NPS Assistance & Compliance Oversight Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Failure to exercise one of the above three options within thirty days of your receipt of these
documents, as evidenced by a date stamp (not a postmark) indicating when we received your
response, will result in this matter being referred to the Attorney General's Office with a request
to initiate a civil action to collect the penalty.
The violations addressed by this assessment and any impacts to waters must be abated.
You are encouraged to contact Ron Boone with the DWQ Raleigh Regional Office at (919)
791-4200 if you need assistance in achieving compliance at the site. Please be advised that
additional assessments may be levied for future, continuing, or other violations beyond the
scope of this specific assessment.
If you have any questions, please contact Priscilla Benson at [phone] extension 360 or
Danny Smith at [phone] extension 353.
r Quality
ATTACHMENTS
cc: Chuck Wakild — DWQ Raleigh Regional Office Supervisor
Ron Boone — DWQ Raleigh Regional Office
Danny Smith - DWQ NPS Assistance & Compliance Oversight
Water Quality Central Files
Susan Massengale, PIO
Unit Supervisor

STATE OF NORTH CAROLINA
COUNTY OF EDGECOMBE
IN THE MATTER OF
GLENOIT FABRICS [HG] CORPORATION
FOR VIOLATIONS OF:
NCGS 143-215.1,
NCGS 143-215.83,
NCGS 143-215.84,
NCGS 143-215.85, and
NPDES GENERAL PERMIT NCG 170000
CERTIFICATE OF COVERAGE NCG170023
NPDES GENERAL PERMIT NCG500000
CERTIFICATE OF COVERAGE NCG500307
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
File NO. OC-2006-0002
FINDINGS AND DECISIONS
AND ASSESSMENT OF
CIVIL PENALTIES
Acting pursuant to delegation provided by the Secretary of the Department of Environment and Natural
Resources and the Director of the Division of Water Quality (hereby known as DWQ), I, Tom Reeder, of
the Division of Water Quality, make the following:
I. FINDINGS OF FACT:
A. Glenoit Fabrics [HG] Corporation is a company organized and existing under the laws of
North Carolina.
B. Glenoit Fabrics [HG] Corporation owns and operates a textile manufacturing plant in
Edgecombe County located at 3001 North Main Street, Tarboro, North Carolina.
C. Glenoit Fabrics [HG] Corporation was issued a Textile Mills General Stormwater NPDES
Permit No. NCG 170000 (Certificate of Coverage #NCG 170023) for the 3001 North Main
Street, Tarboro, NC location on August 1, 2004. The current Certificate of Coverage will
expire on July 30, 2009
D. Glenoit Corporation was issued a Non -Contact Cooling Water/Condensate General
Wastewater NPDES Permit No. NCG500000 (Certificate of Coverage #NCG500307) for
the 3001 North Main Street, Tarboro, NC location under NPDES Permit No. NCG500000
on July 31, 2002, effective August 1, 2002, with an expiration date of July 30, 2007.
E. On June 27, 2003, Glenoit Fabrics [HG] Corporation assumed ownership of Certificate of
Coverage NCG500307 from Glenoit Corporation.
F. On March 9, 2006, DWQ conducted a compliance evaluation inspection and observed
evidence of an oil spill of #5 heating oil at the stormwater discharge outfall 2 (S02, as
named by Glenoit Fabrics [HG] Corporation).
G. North Carolina General Statute 143-215.83 states that it shall be unlawful, except as

Glenoit Fabrics [HGl Corporation
OC-2006-0002
Edgecombe County
Page 2 of 10
otherwise provided in this Part, for any person to discharge, or cause to be discharged, oil
or other hazardous substances into or upon any waters, tidal flats, beaches, or lands within
this State, or into any sewer, surface water drain or other waters that drain into the waters of
this State, regardless of the fault of the person having control over the oil or other
hazardous substances, or regardless of whether the discharge was the result of intentional or
negligent conduct, accident or other cause.
H. North Carolina General Statute 143-215.84 states that any person having control over oil or
other hazardous substances discharged in violation of this Article shall immediately
undertake to collect and remove the discharge and to restore the area affected by the
discharge as nearly as may be to the condition existing prior to the discharge.
I. North Carolina General Statute 143-215.85 states that every person owning or having
control over oil or other substances discharged in any circumstances other than pursuant to
a rule adopted by the Commission, a regulation of the U. S. Environmental Protection
Agency, or a permit required by North Carolina General Statute 143-215.1 or the Federal
Water Pollution Control Act, upon notice that such discharge has occurred, shall
immediately notify the Department, or any. of its agents or employees, of the nature,
location and time of the discharge and of the measures which are being taken or are
proposed to be taken to contain and remove the discharge.
J. During the March 9, 2006 site visit, Glenoit Fabrics [HG] Corporation staff was unable to
locate blueprints showing existing floor drains and were unable to discern where they
drained. There was no documentation of the oil spill or the corrective actions taken to
mitigate the impacts.
K. General Permit No. NCG170000 contains the following limitation:
Part II. Section A Paragraph 1: Site Plan
(c) A site map drawn to scale with the distance legend indicating location of industrial
activities (including storage of materials, disposal areas, process areas and loading and
unloading areas), drainage structures, drainage areas for each outfall and activities
occurring in the drainage area, building locations, existing BMPs and impervious
surfaces, and the percentage of each drainage area that is impervious. For each outfall, a
narrative description of the potential pollutants which could be expected to be present in
the stormwater discharge.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the 3 previous years and any corrective actions taken to mitigate spill impacts.
L. During the site visit, DWQ observed that facility personnel responsible for implementing
the Spill Prevention and Response Plan were not identified.
M. General Permit No. NCG170000 contains the following limitation:
Part II Section A Paragraph 3• Spill Prevention and Response Plan
The Spill Prevention and Response Plan (SPRP) shall incorporate an assessment of
potential pollutant sources based on a materials inventory of the facility. Facility
personnel (or team) responsible for implementing the SPRP shall be identified.

Glenoit Fabrics [HGl Corporation
OC-2006-0002
Edgecombe County
Page 3 of 10
N. DWQ also observed that no schedules of inspections and maintenance activities of
stormwater control systems had been kept.
O. General Permit No. NCG170000 contains the following limitation:
Part II. Section A Paragraph 4: Preventative Maintenance and Good Housekeeping Program
A preventative maintenance program shall be developed. The program shall document
schedules of inspections and maintenance activities of stormwater control systems, plant
equipment and systems. Inspection of material handling areas and regular cleaning
schedules of these areas shall be incorporated into the program.
P. DWQ observed no updated list of personnel responsible for the components of the
Stormwater Pollution Prevention Plan.
Q. General Permit No. NCG 170000 contains the following limitation:
Part I1. Section A Paragraph 6: Responsible Party
The Stormwater Pollution Prevention Plan shall identify a specific position(s)
responsible for the overall coordination, development, implementation, and revision to
the Plan. Responsibilities, for all components of the Plan shall be documented and
position assignments provided.
R. DWQ also observed that the Stormwater Pollution Prevention Plan had not been reviewed
or updated since its inception.
General Permit No. NCG 170000 contains the following limitation:
Part II. Section A Paragraph 7: Plan Amendment
The Stormwater Pollution Prevention Plan shall be reviewed and updated on an annual
basis.
T. During the site visit, DWQ found no documentation of facility stormwater inspections.
U. General Permit No. NCG 170000 contains the following limitation:
Part I1. Section A Paragraph 8: Facility Inspection Program
Facilities are required to inspect all stormwater systems on at least a semiannual
schedule, once in the fall (September -November) and once during the spring (April -
June). The inspection and any subsequent maintenance activities performed shall be.
documented, recording date and time of inspection, individual(s) making the inspection
and a narrative description of the facility's stormwater control systems, plant equipment
and systems. Records of these inspections shall be incorporated into the Stormwater
Pollution Prevention Plan.
V. DWQ also observed that employee training was not implemented or recorded.
W. General Permit No. NCG 170000 contains the following limitation:
Part I1. Section A Paragraph 9: Implementation

Glenoit Fabrics [HG) Corporation
OC-2006-0002
Edgecombe County
Page 4 of 10
The permittee shall document all monitoring, measurements, inspections and
maintenance activities and training provided to employees, including the log of the
sampling data and of activities taken to implement BMPs associated with the industrial
activities, including vehicle maintenance activities. Such documentation shall be kept
on -site for a period of five years and made available to the Director or his authorized
representative immediately upon request.
X. On March 9, 2006, DWQ confirmed that for Glenoit Fabrics [HG] Corporation, no
qualitative monitoring was performed or records kept as required in the stormwater general
permit NCG170000. From August 1, 2004 to March 9, 2006, no qualitative monitoring
results were available for review.
Y. Part II, Section B of General Permit number NCG 170000 contains the following
relevant qualitative monitorine reauirements:
Discharge
Characteristics
Frequency
Monitoring Location
Color
Semi -Annual
SDO
Odor
Semi -Annual
SDO
Clarity
Semi -Annual
SDO
Floating Solids
Semi -Annual
SDO
Suspended Solids
Semi -Annual
SDO
Foam
Semi -Annual
SDO
Oil Sheen
Semi -Annual
SDO
Other obvious
indicators of
stormwater
pollution
Semi -Annual
SDO
Z. On March 9, 2006, DWQ confirmed that for Glenoit Fabrics [HG] Corporation, no
analytical monitoring was performed or records kept as required in the wastewater general
permit NCG500000. From June 27,2003 to March 9, 2006, no analytical monitoring results
were available for review.

Glenoit Fabrics [HG] Corporation
OC-2006-0002
Edgecombe County
Page 5 of 10
AA. Part 1 Section A (1) of General Permit number NCG500000 contains the following relevant
anaing requirements:
Effluent
Characteristics
Measurement
Frequency
Sample
Type
Sample Location
Flow
Semi -Annually
Estimate
Effluent
Temperature
Semi -Annually
Grab
Effluent, Upstream,
Downstream
Total Residual
Chlorine
Semi -Annually
Grab
Effluent
Oil and Grease
Semi -Annually
Grab
Effluent
H
Semi -Annually
Grab
Effluent
BB: During the site visit, DWQ observed that biocide chemicals that contain Sodium
Hypochlorite were being used in the cooling systems. DWQ has no record indicating that
Glenoit Fabrics [HG] Corporation sought authorization from DWQ prior to the use of this
chemical additive.
CC. General Permit No. NCG500000 contains the following limitation:
Part I Section A (1)
The permittee shall obtain authorization from the Division prior to the use of any chemical
additive in the discharge. The permittee shall notify the Director in writing at least ninety
(90) days prior to instituting use of any additional additive discharge which may be toxic to
aquatic life (other than additives previously approved by the Division).
DD. On March 21, 2006, DWQ issued a Notice of Violation (NOV) to Glenoit Fabrics [HG]
Corporation. The NOV noted violations for the Oil Pollution and Hazardous Substances
Control Act. DWQ requested that Glenoit Fabrics [HG] Corporation submit a report to
DWQ assessing the cause, significance and extent of the spill by April 20, 2006. ,
EE. On March 23, 2006, DWQ issued a NOV to Glenoit Fabrics [HG] Corporation. The NOV
noted violations for NPDES Permit NCG170000 and for NPDES Permit NCG500000.
DWQ requested that Glenoit Fabrics [HG] Corporation respond in writing, to these
violations.
FF. On March 29, 2006, Glenoit Fabrics [HG] Corporation responded to the NOV stating that
they had taken soil samples and sent them in for analysis and that they had contacted
consulting agencies about cleaning up the site.
GG. On April 7, 2006, Glenoit Fabrics [HG] Corporation requested in writing an extension of

Glenoit Fabrics [HG] Corporation
OC-2006-0002
Edgecombe County
Page 6 of 10
the due date of April 20, 2006 for submitting a complete report on the spill.
HH. On April 20, 2006, DWQ issued a Notice of Intent (NOI) to Enforce. This NOI denied the
request to extend the April 20, 2006 due date. The NOI noted violations for the Oil
Pollution and Hazardous Substances Control Act and for violations of NPDES Permits
NCG170000 and NCG500000.
II. On May 2, 2006 and May 3, 2006, DWQ received correspondence from Glenoit Fabrics
[HG] Corporation summarizing oil spill clean up activities, explaining the cause of the
spill, and identifying further clean up requirements. Violations of the NPDES permits were
not addressed in any of the correspondence.
JJ. Glenoit Fabrics [HG] Corporation is authorized to discharge stormwater and treated
wastewater to receiving waters designated as an unnamed tributary to the Tar River, a Class
WS-IV, Nutrient Sensitive Water in the Tar -Pamlico River Basin. Glenoit Fabrics [HG]
Corporation's discharges are approximately 5 to 6 miles upstream of the Town of Tarboro's
potable water supply intake.
KK. The costs to the State for enforcement procedures in this matter totaled $1,326.33.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Glenoit Fabrics [HG] Corporation is a "person" within the meaning of North Carolina
General Statute (hereby known as NCGS) 143-215.6A pursuant to NCGS 143-212(4).
B. Under NCGS 143-215.1, a permit is required to cause or permit discharges regulated
under NCGS 143-214.7.
C. The General Stormwater NPDES General permitNCG170000 and the General Wastewater
NPDES General Permit NC500000 was issued to Glenoit Fabrics [HG] Corporation in
accordance with NCGS 143-215.1 and 15A NCAC 2H .0126.
D. Glenoit Fabrics [HG] Corporation violated NCGS 143-215.83 by releasing #5 heating oil
upon lands of the state from its textile manufacturing plant located at 3001 North Main
Street, Tarboro, Edgecombe County, North Carolina.
E. Glenoit Fabrics [HG] Corporation violated NCGS 143-215.84 by failing to collect and
remove the 45 heating oil released and by failing to restore the affected area.
F. Glenoit Fabrics [HG] Corporation violated NCGS 143-215.85 by failing to report the
released 45 heating oil to DWQ as required.
G. Glenoit Fabrics [HG] Corporation violated Part II, Section A, Paragraph 1 of General
Permit NCG170000 by failing to indicate all drainage structures and drainage on the Site

Glenoit Fabrics [HG] Corporation
OC-2006-0002
Edgecombe County
Page 7 of 10
Plan and by failing to record the oil spill and the corrective steps taken to remediate the
impacts.
H. Glenoit Fabrics [HG] Corporation violated Part II, Section A, Paragraph 3 of General
Permit NCG 170000 by failing to document facility personnel responsible for implementing
the Spill Prevention and Response Plan.
I. Glenoit Fabrics [HG] Corporation violated Part II, Section A, Paragraph 4 of General
Permit NCG170000 by failing to document schedules of inspection and maintenance
activities as part of an adequate preventative maintenance and good housekeeping program.
Glenoit Fabrics [HG] Corporation violated Part II, Section A, Paragraph 6 of General
Permit NCG170000, by failing to keep updated the list of personnel responsible for the
overall coordination, development, implementation and revision of the stormwater
pollution prevention plan.
K. Glenoit Fabrics [HG] Corporation violated Part II, Section A, Paragraph 7 of General
Permit NCG 170000, by failing to review and update the stormwater pollution prevention
plan as required.
L. Glenoit Fabrics [HG] Corporation violated Part II, Section A, Paragraph 8 of General
Permit NCG170000, by failing to document facility inspections as part of a stormwater
facility inspection program as required.
M. Glenoit Fabrics [HG] Corporation violated Part II, Section A, Paragraph 9 of General
Permit NCG170000, by failing to document employee training and implement the
stormwater pollution prevention plan as required.
N. From August 1, 2004 to March 9, 2006, Glenoit Fabrics [HG] Corporation failed to
perform and to keep records of qualitative monitoring of the Stormwater Discharge
Outfalls (SDOs), a semi-annual monitoring requirement set forth in Part II, Section B of
General Permit No. NCG170000.
O. From June 27, 2003 to March 9, 2006, Glenoit Fabrics [HG] Corporation failed to perform
and to keep records of analytical monitoring of the wastewater discharges, a violation of the
semi-annual monitoring requirement set forth in Part I, Section A of General Permit No.
NCG500000.
P. Glenoit Fabrics [HG] Corporation violated Part I, Section A (1) of General Permit
NCG500000 by failing to obtain authorization from DWQ prior to the use of a chemical
additive in the discharge. .
Q. Glenoit Fabrics [HG] Corporation may be assessed civil penalties in this matterpursuant to
NCGS 143-215.88A, which provides that a civil penalty of not more than five thousand
dollars ($5,000) per violation may be assessed against a person who intentionally or
negligently discharges oil or other hazardous substances, or knowingly causes or permits

Glenoit Fabrics [HGJ Corporation
OC-2006-0002
Edgecombe County
Page 8 of 10
the discharge of oil in violation of this Part or fails to report a discharge as required by
NCGS 143-215.85 or who fails to comply with the requirements ofNCGS 143-215.84(a) or
orders issued by the Commission as a result of violations thereof.
R. Glenoit Fabrics [HG] Corporation maybe assessed civil penalties in this matter pursuant to
NCGS 143-215.6A(a)(2), which provides that a civil penalty of not more than twenty-five
thousand dollars ($25,000) per violation per day may be assessed against a person who is
required but fails to apply for or to secure a permit required by NCGS 143-215.1, or who
violates or fails to act in accordance with the terms, conditions, or requirements of such
permit or any other permit or certification issued pursuant to authority conferred by this
Part.
S. Glenoit Fabrics [HG] Corporation may be assessed civil penalties in this matter
pursuant to NCGS 143-215.6A(a)(1), which provides that a civil penalty of up to
twenty-five thousand dollars ($25,000.00) per violation may be assessed against a
person who violates any classification, standard, limitation, or management practice
established pursuant to NCGS 143-215, 143-215.1, 143-215.3.
T. The State's enforcement costs in this matter may be assessed against Glenoit Fabrics [HG]
Corporation pursuant to NCGS 143-215.3(a)(9) and NCGS 143B-282.I (b)(8).
U. Tom -Reeder of the Division of Water Quality, pursuant to delegation provided by the
Secretary of the Department of Environment and Natural Resources and the Director of the
Division of Water Quality, has the authority to assess civil penalties.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION:
Accordingly, Glenoit Fabrics [HGJ Corporation is hereby assessed a civil penalty of:
$ ZS For (1) violation of NCGS 143.215.83 for releasing #5
heating oil from the facility site.
$_ aso o For (1) violation of NCGS 143.215.84 for failure to collect
and remove released #5 heating oil and for failure to restore
the affected area.
$ For (1) violation of NCGS 143.215.85 by failing to report
release of #5 heating oil that may endanger health or the
environment within 24 hours.
$ Soo For (1) violation of General Permit NCG170000, Part II,
Section A, Paragraph 1 for failure to indicate all drainage
structures and drainage on the Site Plan and by failing to
record the oil spill and the corrective steps taken to

Glenoit Fabrics [HGl Corporation
OC-2006-0002
Edgecombe County
Page 9 of 10
remediate the impacts.
$ /oo o For (1) violation of General Permit NCG170000, Part II,
Section A, Paragraph 3 by failing to document facility
personnel responsible for implementing the Spill Prevention
and Response Plan.
$ S4!70 For (1) violation of General Permit NCG170000, Part II,
Section A, Paragraph 4 by failing to document schedules of
inspection and maintenance activities as part of an adequate
preventative maintenance and good housekeeping program.
Soo For (1) violation of NCG170000, Part II, Section A,
Paragraph 6 by failing to keep updated the list of personnel
responsible for the overall coordination, development,
implementation and revision of the stormwater pollution
prevention plan.
$ S O o For (1) violation of NCG170000, Part II, Section A,
Paragraph 7 by failing to review and update the stormwater
pollution prevention plan as required.
$ So0 For (1) violation of NCG170000, Part II, Section A,
Paragraph 8 by failing to document facility inspections as
part of a stormwater facility inspection program as required.
$ Sp O For (1) violation of NCG170000, Part II, Section A,
Paragraph 9 by failing to document employee training and
implement the stormwater pollution prevention plan as
required.
20p O For violations of Part II Section B of General NPDES
Permit NCG170000, occurring from August 1, 2004 to
March 9, 2006, from the failure to perform semi-annual
qualitative monitoring of the Stormwater Discharge
Outfall (SDOs).
$ SO O For violations of Part I Section A (1) of General NPDES
Permit NCG500000, occurring from June 27, 2003 to
March 9, 2006, from the failure to perform semi-annual
analytical monitoring of the wastewater effluent.
0 0 0 For (1) violation of NCG500000, Part I, Section A(1), by
failing to obtain approval from the Division of Water
Quality before using any chemical additive in mechanical
systems.

t . 56 d. 00
$ $1,326.33
$ s >r16.. 33
�1b'p�L %v�L Po,-,�t-rf4S
Enforcement costs.
TOTAL AMOUNT DUE
Glenoit Fabrics [HG] Corporation
OC-2006-0002
Edgecombe County
Page 10 of 10
Pursuant to NCGS 143-215.6A(c), in determining the amount of the penalty, I have taken into account the
Findings of Fact and Conclusions of Law and the factors set forth at NCGS 14313-282. 1 (b), which are;
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
7i
(D e)
of Water Quality

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: OC-2006-0002 County: Edgecombe
Assessed Party: Glenoit Fabrics [HG] Corporation
Permit No. (if applicable): NCG170000, NCG500000 Amount Assessed: $15,826.33
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission Waiver of Right to an Administrative Hearing and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as. they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages as needed).
(a) one or more of the civil penalty assessment factors in N C G S. 14313-282 1(b)
were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to, correct the violation and prevent future
occurrences);
- (c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for); t
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance).
EXPLANATION (attach additional pages as necessary):

STATE OF NORTH CAROLINA
COUNTY OF EDGECOMBE
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
GLENOIT FABRICS [HG] CORPORATION
ENVIRONMENTAL MANAGEMENT
COMMISSION
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. OC-2006-0002
Having been assessed civil penalties totaling $ 15,826.33 for violation(s) as
set forth in the assessment document of the Director of the Division of Water Quality dated
July 27, 2006 the undersigned, desiring to seek remission of the civil penalties, does
hereby waive the right to an administrative hearing in the above -stated matter and does stipulate
that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission
of this civil penalty must be submitted to the Director of the Division of Water Quality within
thirty (30) days of receipt of the civil penalty assessment. No new evidence in support of a
remission request will be allowed after thirty (30) days from the receipt of the civil penalty
assessment.
This the day of
NAME (printed)
SIGNATURE
ADDRESS
TELEPHONE

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
rAlan W. Klimek, P. E. Director
Division of Water Quality
.� Coleen H. Sullins, Deputy Director
Division of Water Quality
September 15, 2006
Ms. Lois Griffin
Glenoit Corp, LLC
l Linde Drive
Goldsboro, NC 27533
Subject: Rescission of NPDES General Permit
Permit Number NCG 170375
Glenoit Corp, LLC
Edgemcobe County
Dear Ms. Lois Griffin:
Reference is made to your recent request for rescission of the subject NPDES General Permit. In your
letter received on 6/29/2006, you stated that your facility closed manufacturing in September 2005. In
accordance with your request, NPDES General Permit NCG 170375 is rescinded, effective immediately.
Operating a treatment facility, discharging wastewater or discharging specific types of stormwater to waters
of the State without a valid NPDES permit will subject the responsible party to a civil penalty of up to
$25,000 per day. Enforcement action will be certain for persons that have voluntarily relinquished permit
coverage when, in fact, continuing permit coverage was necessary. If, in retrospect, you feel the site still
requires permit coverage, you should notify this office immediately. Furthermore, if in the future you wish
to again discharge to the State's surface waters, you must first apply for and receive a new NPDES permit.
If the facility is in the process of being sold, you will be performing a public service if you would inform
the new or prospective owners of their potential need for NPDES permit coverage.
If you have questions about this matter, please contact Sarah Young at [phone] x 502, or the
Water Quality staff in our Raleigh Regional Office at 919-791-4200.
Sincerely,
ORIGINAL SIGNED BY
KEN PICKLE
Alan W. Klimek, P.E.
cc: -Raleigh Regional Office w/attichnients�
�Stormwater & General Permits Unit
Central Files - w/attachments
Fran McPherson, DWQ Budget Office
N. C. Division of Water Quality- 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone]
WDEN"A
Customer Service
1-877-623-6748

A � �i
1
! �4
.., ...
,�
tv,.._ ..

lF W ATF9 Michael F. Easley, Governor
William G. Ross Jr., Secretary
CO North Carolina Department of Environment and Natural Resources
Q Alan W. Klimek, P.E. Director
Division of Water Quality
October 6, 2006
Jerry Howard
Glenoit Fabrics [HG] Corporation
3001 North Main Street
Tarboro, NC 27886
Dear Mr. Howard:
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7003 1680 0001 0743 1137
Subject: Request for Remission of Civil Penalty
Glenoit Fabrics [HG] Corporation
Permit No. NCG170000 & NCG500000
Case No. OC-2006-0002
Edgecombe County
In accordance with North Carolina General Statute 143-215.6A(f), I, the Director of the North
Carolina Division of Water Quality, considered the information you submitted in support of your
request for remission and did not find grounds to modify the civil penalty assessment of
$15,826.33.
There are two options available to you:
1) You may pay the penalty.
If you decide to pay the penalty at this stage of the remission process, please make
your check payable to the Department of Environment and Natural _Resources
(DENR). Send the payment within thirty (30) days of your receipt of this letter to the
attention of:
Mr. Shelton Sullivan
NC Division of Water Quality — NPS Assistance & Compliance Oversight Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
2) You may decide to have the Environmental Management Commission's Committee on
Civil Penalty Remissions make the final decision on your remission request.
If payment is not received within 30 days from your receipt of this letter, your request
for remission with supporting documents and the recommendation of the Director of
the North Carolina Division of Water Quality will be delivered to the Committee on
Civil Penalty Remissions for final agency decision.
T7��"��nnCuraaro in
dvats
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwaterquality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Glenoit Fabrics [HG] Corporation
Case No. OC-2006-0002
Edgecombe County
Page 2 of 2
If you or your representative would like to speak before the Committee, you must complete and
return the attached form within thirty (30) days of receipt of this letter. Send the completed form
to:
Ms. Karen Higgins
NC Division of Water Quality— NPS Assistance & Compliance Oversight Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
The Environmental Management Commission (EMC) Chairman will review the supporting
documents and your request for an oral presentation (if you make the request). If the Chairman
determines that there is a compelling reason to require a presentation, you will be notified of
when and where you should appear. If a presentation is not required, the final decision will be
based upon the written record.
Thank you for your cooperation in this matter. If you have any questions, please contact Karen
Higgins at [phone] ext. 574 or Danny Smith at [phone] ext. 353.
Sincerely,
Alan W. imek, P.E.
AWK/sds
cc: ! Charles-Wakild-- DWQ Raleigh Regional Office Supervisor-
Ron Boone—DWQ Raleigh Regional Office Supervisor
NPS Assistance and Compliance Oversight Unit — File Copy
DWQ Central Files
I
OCT 10 ZOO&

il
STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF Edeecombe CASE NUMBER OC-2006-0002
IN THE MATTER OF ASSESSMENT ) REQUEST FOR ORAL PRESENTATION
OF CIVIL PENALTIES AGAINST: )
Glenoit Fabrics [HG] Corporation ) .
I hereby request the opportunity to make an oral presentation before the Environmental
Management Commission's Committee On Civil Penalty Remissions in the matter of the case
noted above. In making this request, I assert that I understand all of the following statements:
• This request will be reviewed by the Chairman of the Environmental Management
Commission and may be either granted or denied.
• Making a presentation will require the presence of myself or my representative during a
Committee meeting held in Raleigh, North Carolina.
• My presentation will be limited to discussion of issues and information submitted in my
original remission request, and because no factual issues are in dispute, my presentation will be
limited to five minutes in length.
This the
day of
20
SIGNATURE
TITLE (President, Owner, etc.)
ADDRESS
TELEPHONE

Glenoit LLC 7/14/2006
3002 Anaconda Rd.
Tarboro N.0 27886
Re: Permit NCG170375
` JUL 1 8 20M
1. Letter was sent to Storm water and General Permits Unit on 6/26/2006 copy to
Ron Boone North Carolina Department of Environment and Natural Resources
stating that manufacturing shut down in September 2005 at 3002 Anaconda Rd.
Glenoit LLC
3. Areas outside east side of building
A. Old plant machinery and equipment —This is being removed by salvage
company to be completed 7/17/2006
B. Pallets- as part of the agreement salvage company will also remove all
pallets. To be completed 7/17/2006
C. Trash- as part of the agreement salvage company will remove all trash. To
be completed 7/17/2006
D. 55 Gallon Drums — Will be removed by licensed Hazardous Waste
Removal Company. Safety—Kleen to remove on 7/19/2006
E. Carboy Containers — as part of the agreement with salvage company they
will remove all carboy containers. They have also agreed to clean up this
entire area with the help of Lee Sherrod who is caretaking the building for
Glenoit LLC. To be completed 7/17/2006
4. Waste water treatment area. - This area will be thoroughly cleaned and we will
remove and properly dispose of all accumulated dried fibers. Completed 7/14/2006
5. Machinery still in the building- The machinery has been and will be properly
maintained and any waste materials from the machinery will be disposed of properly.
All machinery has been given to salvage company planned to have it moved by
7/31 /2006
6. Glenoit will not be re -opening the facility for manufacturing and if it is sold or
leased we will advise new owner or tenant of the need for waste water permits.

GLENOIT LLC
Storm water and General Permits Unit
Division of Water Quality
Re: Permit NCG170375
Dear Sir or Madam:
June 22^a 2006
R 20061
This letter is to serve as official notification that Glenoit LLC located at 3002 Anaconda Rd. Tarboro N.0
27886 closed manufacturing in September 2005. The building is currently being used for storage of packed
merchandise only
Cc: Ron Boone
Cliff Campbell
Dan Martin
Sincerely;
Lois Griffin
Glenoit LLC
1 Linde Drive
Goldsboro N.0 27533
[STREET ADDRESS] • [CITY/STATE] • [ZIP/POSTAL CODE]
PHONE: [PHONE NUMBER] • FAX: [FAX NUMBER]

GLENOIT LLC
June 26,2006
Storm water and General Permits Unit
Division of Water (u iry
Re: Permit NCG170375
Dear Sir or Madam:
This letter is to serve as official notification that Glenoit LLC located at 3002 Anaconda Rd. Tarboro NC
27886 closed manufacturing in September 2005. The building is currently being used for storage of packed
merchandise only.
Cc: Ron Boone
Cliff Campbell
Dan Martin
Sincerely,
k Lois Griffin
Glenoit LLC c -
1 Linde Drive �o
Goldsboro NC 27533 / L
�IV
[STREET ADDRESS] • [CITY/STATE] • [ZIP/POSTAL CODE]
PHONE: [PHONE NUMBER] • FAX. [FAX NUMBER]

*08/13/2006 11:31 9197339612
— State of North • Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Govemor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
DAVID E. GURLEY, JR.
GLENOIT CORPORATION
POST OFFICE BOAC 1157
TARBORO, NC 27886
Dear Permitter:
PAGE 02
ErwiRONM6NT ANo NKURAL RESOURCES
July 28,1999
Subject: Reissue - NPDES Stormwater Permit
Glenoit Corporation
COC Number NCG170375
Edgecombe County
In response to your renewal application for continued coverage under general permit NCG170000, 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 witb your permit package
* A copy of general stormwater permit NCGI70000
* A Stormwater Pollution Prevention Plan (SPPP) Certification Form. Completion of this to= is required to
certify that you have developed and implemented the SPPP as per the conditions of the 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 the Analytical Monitoring form and five copies of the Qualitative Monitoring form
* A copy of a Technical Bulletin for the general permit which outlines changes in the permit, key requirements;
and addresses frequently asked questions
* A Certificate of Coverage
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 logal .
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 (919) 733-50832 ext. 548
Sincerely,
Ll�uU �A'Vru�
for Kea T. Stevens
cc: Central Files
Stormwatu and General permits Unit Files
Raleigh Regional Office
1617 Mall Service Center, Raleigh, North Carolina 27699.1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recyclecl/ 10 / post -consumer paper

06/13/2006 11:31 9197339612 PAGE 03
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL. RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG170000
CERTIFICATE OF COVERAGE No. NCG170375
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIN(INATION 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,
GLENOIT CORPORATION
is hereby authorized to discharge stormwater from a facility located -at
GLENOIT CORPORATION
3002 ANACONDA ROAD
TARBORO
EDGECOMBE COUNTY
to, receiving waters designated as a UT of the Tar River and Tarboro MSSS in the Tar • Pamlico River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, 11. H1, '
IV. V, and VI of General Pr it No. NCG170000 as attached.
This certificate of coverage shall become effective August 1, 1999.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day July 28, 1999,
for Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

06/13/2006 11:31 9197339612 PAGE 04
8t9te of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor�irrlt��Ifi
Wayne McDevitt, Secretary p E H M A. Preston Howard, Jr., P:E„ Director
February 27, 1998
Mr. David E. Gurley, Jr.
Glenoit Corporation
Post Office Box 1157
Tarboro, North Carolina 27886
Subject: General Permit No. NCG170000
Glenoit Corporation
COC NCG170375
Edgecombe County '
Dear W. Gurley,:
In -accordance with your application for discharge permit received on December 31, 4997, we' ar4.
forwarding herewith the subject certificate of coverage to discharge under the subject state - NEDE5 general:
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 3t aad the! .
Memorandum of Agreement between North Carolina and the US Environmental Protection agead dated:;
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this pe3imikiare:
unacceptable to you, you have the right to request an individual permit by submitting an individual pcitmt`
application. Unless such demand is made, this certificate of coverage shall be final did binding.
Please take notice that this certificate of coverage is not transferable except after notice to the'Divikon
of Water Quality. The Division of Water Quality may require modification or rcvocation and reissuarice of the,
certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required bythe-
Division of Water Quality or permits required by the Division of Land Resources, Coastal Area'Maftgertaent:
Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Bill Mills at telephone number 919f733-5083'.
ext. 548.
Sincerely,
ORIGINAL SIGNED BY
BR
A.D�oYwBENNETT
H aid, Jr., P. E.
cc: Raleigh Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10%post-corisurnerpflper

�0'6/13/2006 11:31 9197339612 PAGE 05
- i
J'
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES -'
DIVISION OF WATER QUALITY
GENERAL PFRM7T_NO NCG170000
o. NCG170375.
STORMWATER DISCHARGES
t
NA L DISCHARGEL TEM
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
Pederal Water Pollution Control Act, as amended,
Glenoit Corporatioo
is hereby authorized to discharge stotmwater from a facility located at P:
c
Glenoit Corporation
3002 Anaconda Road
Tarboro
Edgecombe County
to receiving waters designated as an unnamed tributary to Tar River and the Town of Tarboro Storm Sewer System 3
in the TaT-Pamlico River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set,forth in Pam 1, IF 111
and IV of General permit No. NCG170WO as attached
This certificate of coverage shall become effective February 27,1998.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
i
Signed this day February 27, 1998.
t
ORIGINAL SIGNED By
BRADLEY SENNETT
A- Preston Howard, Ir., PE., Director
Division of Water Quality
By Authority of the Environmental Management Cor mission
C.
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168

Highlands
Environmental
Solutions, Inc. 9405 Greenfield Drive; Raleigh, NC 27615
Phone: [phone] / Fax: [phone] / www.hesnc.com
May 24, 2006
Mr. Ronald Boone
North Carolina Department of Environment and Natural Resources
Raleigh Regional Office
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Submittal of Soil Abatement Report
Glenoit Fabrics (HG) Corporation; Tarboro; Edgecombe County; North Carolina
HES Project #25040
Dear Mr. Boone:
On behalf of Glenoit Fabrics (HG) Corporation (Glenoit) and Eastern Environmental Management, LLC
(EEM), Highlands Environmental Solutions, Inc. (HES) hereby submits the enclosed Soil Abatement
Report for soil excavation activities recently conducted downgradient of stormwater outfall SO2, located
on the property. Residual petroleum impacted soil remains at the site. Furthermore, the NCDENR — UST
Section is also investigating this release as it may be related to the 20,000 gallon #5 fuel oil UST located
on the property. Because of this, additional assessment actions are recommended in the enclosed
report.
If there are any questions or concerns regarding this correspondence, or the project in general, please
contact Mr. Joe Beaman (HES) at [phone], or Mr. Jerry Howard (Glenoit) at 252-641-6034.
Sincerely,
Highlands Environmental Solutions, Inc.
a�
Joe Beaman, P.G.
Principal Geologist
O I
cc: Mr. Jerry Howard — Glenoit Fabrics (HG) Corporation `�
Mr. Johnny Baines — Eastern Environmental Management, LLC
File 1
z

SOIL ABATEMENT REPORT
STORMWATER OUTFALL "SO2"
Glenoit Fabrics (HG) Corporation
3001 North Main Street
Tarboro, Edgecombe County, North Carolina
Report Prepared for.
Mr. Jerry Howard
Glenoit Fabrics (HG) Corporation
3001 North Main Street
Tarboro, North Carolina 27886
HES Project #25040
CZ) J
0 C
CO
u I
May 24, 2006
Z = !
Report Prepared by
Highlands
Environmental
Solutions, Inc.

SOIL ABATEMENT REPORT
STORMWATER OUTFALL "SO2"
Glenoit Fabrics (HG) Corporation
3001 North Main Street
Tarboro, Edgecombe County, North Carolina
HES Project #: 25040
May 24, 2006
Prepared for.
Mr. Jerry Howard
Glenoit Fabrics (HG) Corporation
3001 North Main Street
Tarboro, NC 27886
Report Prepared by:
Highlands Environmental Solutions, Inc.
9405 Greenfield Drive
Raleigh, North Carolina 27615
4eBan, P.G.
Principal Geologist
Highlands
Environmental
Solutions, Inc.

Soil Abatement Report - Glenoit Fabrics (HG) Corporation; Tarboro, North Carolina Page ii
EXECUTIVE SUMMARY
The Glenoit Fabrics (HG) Corporation facility is located at 3001 North Main Street, in Tarboro, Edgecombe
County, North Carolina. The site is an industrial facility, which manufactures textiles. On March 21,
2006, the North Carolina Department of Environment and Natural Resources (NCDENR) issued a Notice
of Violation (NOV) to Glenoit Fabrics (HG) Corporation in Tarboro, North Carolina (Glenoit), for a
petroleum release in violation of the Oil Pollution and Hazardous Substances Control Act of 1978. The
NOV was issued following the discovery of petroleum impacted soil at a stormwater outfall located on the
East side of the property. In response to the NOV, Glenoit contracted Eastern Environmental
Management, LLC (EEM) to perform soil remediation activities at the storrndrain outfali. EEM
subcontracted Highlands Environmental Solutions, Inc. (HES) to provide confirmation sampling and
regulatory reporting services.
Glenoit utilizes #5 fuel oil to fuel a boiler system located inside the main building. The fuel is stored in a
20,000 gallon underground storage tank located on the North side of the main building. Based on
observations made at the facility, as well as, the characteristics of #5 fuel oil, it is concluded that the
petroleum impacted soil at the stormdrain outfall resulted from multiple, historic, small volume product
releases. The released product entered floor trench drains located inside the boiler room, and co -mingled
with hot boiler"blow down" water. This liquid then entered the stormwater system and was subsequently
discharged at outfall SO2.
Approximately 111 tons of petroleum impacted soil have been excavated from the outfall, and transported
off -site for disposal. Based on the results of post -excavation soil samples, residual petroleum impacted
soil remains downgradient of the outfall, and beneath the stormwater pipe. Additional assessment
activities will be required, and are recommended, to delineate the extent of petroleum impacted soil at the
site. Additionally, groundwater was encountered at a depth approximately four feet below grade, and was
apparently in contact with petroleum impacted soil. As such, a groundwater assessment has been
recommended to determine if groundwater has been impacted by petroleum hydrocarbons.
Currently, the North Carolina Department of Environment and Natural Resources (NCDENR) Division of
Water Quality and the Division of Waste Management (UST Section) are both investigating the facility and
the subject release incident. A recommended assessment approach has been developed (and presented
herein) to allow for the rapid collection of valuable site data, which satisfying at least part of the
investigation requirements of these NCDENR divisions.

Soil Abatement Report - Glenoit Fabrics (HG) Corporation; Tarboro, North Carolina Page !it
CONTENTS
Subject
1.0 BACKGROUND
2.0 CAUSE OF RELEASE
3.0 SOIL EXCAVATION ACTIVITIES
4.0 DISCUSSION AND RECOMMENDATIONS
5.0 LIMITATIONS OF WORK PRODUCT
APPENDICES
Appendix A —
Figures
Appendix B —
Select Site Photographs
Appendix C —
Tables
Appendix D —
Copy of Laboratory Analytical Data Report
Appendix E —
Soil Disposal Documentation
Paae

Soil Abatement Report - Glenoit Fabrics (HG) Corporation; Tarboro North Carolina Page 1
1.0 Background
The Glenoit site is located at 3001 North Main Street, in Tarboro, Edgecombe County, North Carolina. The
site is an industrial facility, which manufactures textiles. The property consists of one large structure, paved
parking areas, landscaped areas, and wooded areas. The location of the facility is depicted on Figure 1,
included in Appendix A.
On March 21, 2006, the North Carolina Departmentof Environment and Natural Resources (NCDENR) issued
a Notice of Violation (NOV) to Glenoit Fabrics (HG) Corporation in Tarboro, North Carolina (Glenoit), for a
petroleum release in violation of the Oil Pollution and Hazardous Substances Control Act of 1978. The NOV
was issued following the discovery of petroleum impacted soil at a stormwater outfall located on the East side
of the property. The release was discovered during a routine regulatory site inspection conducted on March 9,
2006. The subject NOV required Glenoit to perform the following:
1. Cease discharging all oil or other hazardous substances on the land or waters of the state;
2. Remediate the affected areas, and collect soil and/or groundwater samples to confirm successful
remediation; and
3. Submit a report to the NCDENR assessing the cause, significance and extent of the release.
In response to the NOV, Glenoit contracted Eastern Environmental Management, LLC (EEM) to perform soil
remediation activities at the stormdrain outfall. EEM subcontracted Highlands Environmental Solutions, Inc.
(HES) to provide confirmation sampling and regulatory reporting services. Glenoit has plugged floor drains in
the source area of the release to prevent additional petroleum from entering the stormwater system, and is
repairing and conducting housekeeping in the source area of the release.

Soil Abatement Report - Glenoit Fabrics (HG) Corporation; Tarboro North Carolina Page 2
2.0 Cause of the Release
Glenoit utilizes #5 fuel oil to fuel boilers located on the property. The fuel oil is stored in a 20,000 gallon
underground storage tank (UST), which is located on the Northeast side of the building (see Figure 2). The
boiler room is located just inside the Northeast side of the building, as shown on Figure 2. Condensate and
boiler "blow -down" water has historically been discharged to floor trench drains located inside the boiler room.
These trench drains discharge to an underground pipe, which connects to a stormwater drain. This
stormwater drain discharges at an outfall (SO2), located in a wooded area in the Eastern portion of the
property. Based on observations made inside the boiler room (and during soil excavation activities), it is
concluded that rather than a single release event, the subject petroleum release resulted from multiple,
historic, small volume petroleum releases from the product lines and connections inside the boiler room. The
suspected release scenario is as follows:
1. A petroleum release(s) occurred inside the boiler room;
2. The petroleum enterd the floor drain system, and co -mingled with hot water from the boiler units;
3. The petroleum and hot water were discharged to the underground discharge line, and eventually the
concrete stormwater system. The concrete pipe served as to insulate the water and fuel, allowing the
normally viscous fuel oil to remain fluid; and,
4. The released fuel was discharged at the stormdrain outfall (SO2).
Glenoit has plugged the trench drains located in the boiler room; as such hot water and/or incidentally
released fuel are no longer discharged to the stormwater system. Furthermore, Glenoit is in the process of
performing housekeeping and repairs in the boiler room to prevent future fuel releases from this area.

Soil Abatement Report - Glenoit Fabrics (HG) Corporation; Tarboro North Carolina Page 3
3.0 Soil Excavation Activities
Personnel from EEM and HES mobilized to the site on April 25, 2006, to excavate petroleum -impacted soil
from the stormdrain outfall (SO2). The location of the outfall is identified on Figure 2. Select photographs of
site activities are included in Appendix B. The area of petroleum -impacted soil was readily apparent by the
presence of black, oil -stained soil just East of the subject outfall. Visibly stained soil was observed from the
ground surface (depth just beneath the outfall) to a depth approximately four feet below grade. Soil
excavation was performed using a track -hoe, and all accessible, visibly stained soil downgradient of the
outfall was excavated.
Grab soil samples were randomly collected during excavation activities, and field screened for organic vapors
using a flame ionization detector (FID), which was calibrated to 100-ppm methane standard. During
screening, an aliquot of soil was placed in a plastic zip -lock bag and allowed to volatilize indirect sunlight fora
period of approximately 10 minutes. The vapor headspace in the bag was then screened for organic vapors
using the FID. Excavation limits were determined in the field based on visual and FID screening data, as well
as limitations presented by the presence of the pipe and large trees. A total of 14 soil screening samples were
collected. Data regarding field screening samples are summarized on Table 1, included in Appendix C. The
locations of soil screening samples are depicted on Figure 3. The final excavated area measured
approximately 40 feet long, with widths varying from approximately 8 feet to approximately 14 feet, and with
depths ranging from approximately three to four feet below the bottom of the outfall.
Excavated soil was described as black, silty sand from the surface to depths approximately four feet below
grade (depth referenced to the bottom of the stormwater outfall pipe). Below this depth, a bluish -gray to gray -
orange sandy clay was encountered. During excavation, groundwater was encountered at a depth
approximately four feet below grade. A small volume of groundwater entered the excavation from the floor of
the excavated area. Groundwater observed in areas of the excavation closest to the outfall appeared to
exhibit a hydrocarbon sheen; however, due to the small volume of groundwater, the presence of a sheen
could not be confirmed. Groundwater samples were not collected during excavation activities.
Water was also observed entering the excavation from beneath the concrete stormwater pipe, and small
"blebs" of liquid phase hydrocarbons (LPH) were observed in this water. LPH entering the excavation was
stabilized with soil (as possible), and removed from the excavation. Stained soil was also observed beneath
the pipe and could not be excavated without removing or potentially damaging the pipe. Additionally, black
stains and/or tar were observed inside the concrete pipe at the outfall.
Upon completion of soil excavation activities, 12 confirmation soil samples were collected from the floor and
sidewalls of the excavated area. The locations of these soil samples are depicted on Figure 4. Upon
collection, these samples were split into two aliquots. The first aliquot was placed in a labeled, laboratory
supplied container, and maintained on ice pending shipment to the analytical laboratory. The second aliquot
was placed in a clean, labeled, zip -lock bag and screened for the presence of organic vapors using the
previously described methodology. Samples submitted for laboratory analysis were shipped (via overnight
courier) to Paradigm Analytical Labs (PAL) for laboratory analysis of total oil and grease, by Method 9071.
Laboratory analytical results are summarized on Table 2. A copy of the complete laboratory analytical data
report is included in Appendix D.
A total of 111 tons of petroleum impacted soil were excavated from the outfall area during the April 25, 2006
excavation event. The excavated soil was loaded directly into dump trucks, and transported to Soil Works,
Inc. in Zebulon, NC (a state permitted land disposal facility) for treatment and disposal via land application. A
copy of the soil acceptance documentation is included in Appendix E. The excavated area was backfilled
with clean soil, seeded, and covered with coconut matting to prevent erosion.

Soil Abatement Report - Glenoit Fabrics (HG) Corporation; Tarboro North Carolina Page 4
4.0 Discussion and Recommendations
On March 9, 2006, a release of #5 fuel oil was observed at stormwater outfall #2, at the Glenoit facility in
Tarboro, NC. The release was discovered during a routine regulatory inspection. The NCDENR subsequently
issued a Notice of Violation for the petroleum release.
The source of the release is believed to be historic, small volume petroleum releases from product supply
lines located in the facility boiler room. The released product co -mingled with hot water after entering floor
trench drains, was subsequently discharged to the stormwater system and eventually discharged at S02.
Given the viscosity of #5 fuel oil, the thickness (four feet) of visibly stained soil downgradient of the stormdrain
outfall supports the conclusion of multiple release events, rather than one event. Since receiving the subject
NOV, Glenoit has plugged the trench drains located in the boiler room, and is in the process of performing
housekeeping and repairs in the boiler room to prevent future fuel releases.
The subject stonndrain impacted by this release consists of a concrete pipe, which extends from the North -
central portion of the building to the outfall. The outfall is an unnamed, intermittent stream. This stream is a
tributary of the Tar River, which is located approximately 1300 feet North of the outfall. Petroleum stained soil
was not observed downgradient of the excavated area. Based on this observation and the viscous nature of
#5 fuel oil under normal conditions, it is concluded that LPH did not impact the Tar River.
Twelve confirmation soil samples were collected from the floor and sidewalls of the excavation following
completion of excavation activities. Laboratory analysis of these samples resulted in the detection of total oil
and grease (TOG), at concentrations greater than the State Action Limit of 250 mg/Kg, in four of the 12
samples. As such, residual petroleum impacted soil remains in place at the subject outfall and beneath the
stormwater pipe. Soil sample S-2 was collected immediately beneath the discharge pipe, approximately 1.5
feet into the Western sidewall of the excavation. The extent of petroleum impacted soil immediately beneath
the stormwater pipe has not been determined, and was beyond the scope of this investigation. The locations
of soil samples exhibiting TOG concentrations greater than 250 mg/Kg are depicted on Figure 4. Additional
excavation activities to remove residual impacted soil at the outfall will require removal of the stormwater pipe
and/or removal of large trees.
Because residual petroleum impacted soil remains in the area downgradient of the outfall and apparently
beneath the stormwater pipe, additional assessment and/or remediation will be required. Due to the relatively
shallow depth to groundwater, and since petroleum impacted soil was apparently in contact with groundwater,
a groundwater assessment should be performed to determine if groundwater has been impacted by the
release. Furthermore, the NCDENR — UST Section, which is also investigating this incident, has required
tightness testing and initial assessment activities near the fuel storage UST and associated product supply
lines. As such, HES recommends the following:
Tightness Testing of the UST and Product Supply Lines. Due to the characteristics of#5 fuel oil, HES
recommends the performance of a tracer test to determine if subsurface leaks are associated with the
subject LIST and product lines. In this test, a tracer chemical will be injected into and mixed with the
fuel stored in the UST. Probes will be installed into the subsurface around the UST and product lines
to facilitate the collection of soil gas. Soil gas samples will be analyzed to determine if the tracer
chemical is present in the subsurface outside the UST system.
Soil Assessment. A soil assessment should be performed to fully delineate the extent of residual
petroleum impacted soil downgradient of outfall SO2, to delineate petroleum impacted soil (if present)
along the underground stormwater line, and to determine if petroleum impacted soil is present near
the UST system. HES recommends the use of direct -push technology to facilitate the collection of
soil samples in the open areas of the site (i.e. around the UST and along the stormwater pipe). A
hand auger will be utilized to collect soil samples in the wooded areas of the site and along the stream
downgradient of the excavated area. Soil samples will be field screened for organic vapors, and
representative soil samples will be collected for laboratory analysis in accordance with NCDENR
requirements.

Soil Abatement Report - Glenoil Fabrics (HG) Corporation; Tarboro North Carolina Page 5
Limited Groundwater Assessment. A limited groundwater assessment should be performed to (1)
determine if impacted groundwater is present beneath the site and (2) to determine the direction of
groundwater flow beneath the site. HES recommends the installation of four EPA Type II
groundwater monitoring wells at the site as follows: One well near the UST system and boiler room;
two wells in the paved parking area, along the underground stormwater line; and one well near outfall
S02. The top of well casings will be surveyed to a common datum established at the site.
Groundwater samples will be collected using low -flow purging, and samples will be collected for
laboratory analysis in accordance with NCDENR requirements.
Preparation and Submittal of a Project Report. A project report detailing the results of investigation
activities will be prepared and submitted to the NCDENR. This report will also include
recommendations for future assessment and/or remediation, if required. HES will begin the
recommended assessment activities immediately, and anticipates submittal of the resulting report by
August 30, 2006. Because this facility is currently being investigated by two NCDENR divisions
(Division of Water Quality and Division of Waste Management— UST Section), HES will prepare and
submit interim progress reports on a monthly basis regarding site activities. These interim reports will
document completed investigation activities, preliminary results of investigation activities, and
recommendations for additional or modified assessment activities, if required.
Apparent hydrocarbon staining was observed inside the stormwater pipe at the outfall. Because of this, it is
strongly suspected that residual petroleum is present inside the pipe. Furthermore, the presence of petroleum
impacted soil beneath and along the pipe is also suspected. However, it is also suspected that this residual
fuel inside the pipe is not currently mobile given the normally viscous nature of the fuel, and since heated
water is no longer discharged to this stormwater system. A decision regarding the proper management of this
pipe will be made based on the results of the soil assessment to be conducted along the stormwater line.
Potential management options include (but may not be limited to): Hydraulic jetting, video inspection, and
excavation and replacement.
Additionally, depending on the results of the soil and groundwater assessment, a Comprehensive Site
Assessment (CSA) may be required at this site. However, should the subject UST system fail tightness
testing the NCDENR - UST Section will likely require a Phase I or II Limited Site Assessment (Phase 1/11 LSA).
The scopes of work for Phase 1/11 LSAs versus CSAs are vastly different. Furthermore, the NCDENR Leaking
Underground Storage Tank (LUST) Trust Fund (managed by the UST Section) requires Phase 1/II LSAs be
performed priorto conducting CSAs. As such, the performance of a full CSA is not recommended at this time.
The assessment recommendations presented above were developed by HES as a compromise to allow the
rapid collection of valuable site data, while partially satisfying the requirements of both the NCDENR Division
of Water Quality and the NCDENR UST Section. Additional assessment recommendations or modifications
will be presented in the interim project reports.

Soil Abatement Report Glenoil Fabrics (HG) Corporation; Tarboro North Carolina Page 6
5.0 Certifications and Limitations
Highlands Environmental Solutions, Inc. (HES) has performed the investigation documented in this report in a
professional manner using generally accepted environmental practices. This report shall not be construed to
create any warranty regarding the property on which the investigation was conducted. This report is a
representation and presentation of the findings and conclusions of HES based upon observations made at the
time of site reconnaissance visits; personal interviews; research of available documents (records, maps, etc.)
held by the appropriate government and private agencies; and/or analytical data for samples collected during
the course of the investigation. This report is subject to the limitation of historical documentation, and the
availability and accuracy of pertinent records. HES shall not be responsible for conditions, or consequences,
arising from relevant facts that were concealed, withheld or not fully disclosed to HES at the time the
investigation was performed.
This report is intended solely for the use of Glenoit Fabrics (HG) Corporation; Eastern Environmental
Management, LLC; the North Carolina Department of Environment and Natural Resources; their agents and
consultants. The information*provided in this report is relevant to the dates of our site and investigation
activities, and should not be relied upon to represent conditions at future dates.
With reference to the applicable technical requirements of 15 NCAC 2L .0115, and pursuant to 15A NCAC 2L
.0103(e), I certify that the work described herein has been performed in accordance with industry standards
and practices by me, or under my direct supervision.
Highlands Environmental Solutions, Inc.
Bobby J. Beaman, P.G.
Principal Geologist
NC Licensed Geologist #1468

r ;
z ~1 I . '•11
Incident Location
fff I Radio
it
MIS 1
N
Approximate Scale
0 1100 2200
feet
From USGS Tarboro SW 7.5 min
Topographic Quadrangle; Tarboro, North Carolina Topographic Location Diagram
Highlands
Environmental
Solutions, Inc
9405 GreerdiW a*vv - R~. NC 27615
Project Name
Petroleum Release Incident
Client:
Glenoit Fabrics (HG) Corporation
Project Number: Drawn by:
25040 JB
Scale: Date: Figure Number.
As Shown May 3, 2006 1

Location of
UST(source area)
i/ .
Jr
Location of
Boiler Room
(source area)
r +'
a
yy ry N
r .r
YY ii,. ry t T Ff i errit
'•,. {�; �w�4�r'�
Intermittent
Underground ~ Stream
Stormwater
Pipe
Gz
CO db�i
Tar oo�cs /y =
r
L
t, it
4 1
5 .
4z
L r<
1994 Aerial Photograph from Topozone. com
Highlands
Environmental
Solutions, Inc.
9405 Gmerfmid Dim Rellpoh, NC 27615
Project Name:
Stormwater
Outfall Area
(S02)
�. N<
Site Details Diagram
Petroleum Release Incident
Client:
Glenoit Fabrics (HG) Corporation
Project Number: Drawn by:
25040 JB
Scale: Date: Figure Number.
As Shown Mav 3, 2006 2

To Plant
1 2 3 I 1 7
�j 5/6 j
1
Approximate Extent
of Excavation
Thalweg of Stream
Approximate Scale
0 8 16
Highlands
Environmental
Solutions, Inc.
PGJB
JB
PEJB
Scene
As Shown
fete
May 3, 2006
9405 Gmnra)d Drim Raleigh, NC 27615
PhOrWFM [phone]
P1Of W #
25040
Concrete Pipe
(Outfall S02)
10 Soil Screening Sample
Excavation Diagram
Glenoit Fabrics (HG) Corporation
Tarboro, NC 3

) Plant
PSI
Thalweg of Stream
Approximate Scale
0 8 16
feet
Highlands
Environmental
Solutions, Inc.
9405 Onenroki DrtYW RaWgi; NC 27615
Phon&TF : (919)866,0563
S-2 _ I
S-3 S.1' i S-5
6 S-4 1
I
1
S-7 1 S.6
� S.10 1
S-11
IS-12'
Concrete Pipe
(Outfall S02)
�\ 11 Laboratory Soil Sample
I9 DB Dt ft TMe
JB JB
3JB PE Excavation Diagram
ceb gkaNRalam Name
As Shown
we Glenoit Fabrics (HG) Corporation r
clay 3, 2006
�« Tarboro, NC
25040

Appendix B
Select Site Photographs

Highlands Environmental Solutions, Inc.

Highlands Environmental Solutions, Inc.

Highlands Environmental Solutions, Inc.
enotoaraomc Kecora
Client Name: Glenoit Fabrics (HG) Corporation Project Number: 25040
Project Name: Soil Abatement at Outfall SO2 Project Location: Tarboro, NC
Photographer:
J. Beaman
Date:
4/25/2006 '•
,1
Direction:
Description:
Y
View inside
stormwater
pipe. Note the R
presence of
staining.
r-M
J. Beaman
Date:
4/25/2006
w
View of outfall
area following
completion of
excavation, ani
prior to
backfilling.

Appendix C
Tables

Table 1
Glenoit Fabrics (MG) Corporation
#5 Fuel Oil Release Incident; Tarboro, NC
HES Project #26040
Summary of Soil Analytical Results
(Soil Field Screening Data)
Sample
Number
Date of
Collection
Collection of
FID
(ppm)
Comments
1
4/25/06
2.5
3
2
4125/06
2.5
2.5
3
4/25/06
2.5
4
4
4/25106
2.5
2.5
5
4/25/06
4
40
Re -excavated area
6
4/25/06
4.5
5.5
Repeat sampling of point 5 after excavation.
7
4125106
2.5
2.5
8
4/25/06
2.5
0.5
9
4125/06
4
5.5
10
4/25/06
2.5
0.75
11
4/25/06
4.5
1.75
12
4/25/06
2.5
2.75
13
4/25/06
2.5
1.8
14
4/25/06
2.5
2
Notes: ppm' denotes parts per million
'FID' denotes flame ionization detector
FID was calibrated to 100-ppm methane standard, in accordance with manufacturers requirements.
All 'Depth of Collection' are referenced to the depth beneath the bottom of Me discharge pipe.

Table 2
Glenoit Fabrics (HG) Corporation
#5 Fuel Oil Release Incident; Tarboro, NC
HES Project #25040
Summary of Soil Analytical Results
(Laboratory Analytical Data)
Sample I Date of Depth of FID I TOG I GRO DRO Comments
Number I Collection I Collection (pp m) (mg/Kg) (mg/Kg) I (mg/K )
State Action Limit
. 250...........1........[.....40.....
S-1
4/25/06
4
5
BQL
na
na
Floor sample near outfall.
S-2
4/25/06
0.5
150
4120
na
na
Sample collected immediately under outfali pipe.
S-3
4/25/06
2.5
2
55.8
na
na
Sidewall
S-4
4/25/06
2.5
6
BQL
na
na
S-5
4/25/06
2.5
150
2550
na
na
S-6
4/25/06
2.5
0.75
BQL
na
na
S-7
4/25/06
4.5
1
BQL
na
na
S-8
4/25/06
2.5
5
179
na
na
S-9
4/25/06
2.5
0.5
BQL
na
na
S-10
4/25106
4
5
68.6
na
na
S-11
4/25/06
2.5
50
383
na
na
S-12
4/25/06
3
45
319
na
na
D-1
4/25/06
—
na
18800
36.9
6020
Profile sample for disposal.
Notes: mg1Kg denotes milligrams per kilogram
ppm"denotes parts per million -
"FID"denotes Name ionization detector
Bold denotes concentration greater then State Action Limit.
All "Depth of Collection- am referenced to the depth beneath the bottom of the discharge pipe.

Appendix D
Copy of Laboratory Analytical Data Report

SGS ENVIRONMENTAL SERVICES, INC.
Mr. Joe Beaman
Highlands Environmental Services
9405 Greenfield Dr.
Raleigh NC 27615
Report Number: G520-160
Client Project: 25040
Dear Mr. Beaman:
Enclosed are the results of the analytical services performed under the referenced
project. The samples are certified to meet the requirements of the National
Environmental Laboratory Accreditation Conference Standards. Copies of this report
and supporting data will be retained in our files for a period of five years in the event
they are required for future reference. Any samples submitted to our laboratory will
will be retained for a maximum of thirty (30) days from the date of this report unless
other arrangements are requested.
If there are any questions about the report or the services performed during this project,
please call SGS/Paradigm at [phone]. We will be happy to answer any questions
or concerns which you may have.
Thank you for using SGS/Paradigm Analytical Labs for your analytical services, We look
forward to working with you again on any additional analytical needs which you may have.
rdi Analytical Laboratories, Inc.
ivD ector a
J. Pdtrick Weaver
N.C. CERTIFICATION #481 1 of 18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Total Petroleum Hydrocarbons
"�— by GC/FID 8015
Client Sample 10: D-1
Client Project ID:
25040
Lab Sample ID:
G520-160-1
Lab Project ID:
G520-160
Report Basis:
Dry Weight
Analyte
Gasoline Range Organics
Diesel Range Organics
Comments:
Flags:
Result RL
MG/KG MG/KG
36.9 9.36
6020 945
Analyzed By:
MJC
Date Collected:
4/25/2006 8:45
Date Received:
4/27/2006
Matrix:
Soil
Solids
64.08
Prep
Dilution Date
Method
Factor Analyzed
5030
1 05/06/G6
3541
100 05/06/06
N.C. CERTIFICATION W1
Reviewed By' J
TPM s_W2 of 18

SGS ENVIRONMENTAL SERVICES, INC.
L'1 Results for Oil and Grease
Client Sample ID:
D-1
Client Project ID:
25040
Lab Sample ID:
G520-160-1 C
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Method RL
MG/KG
Oil 8 Grease 9071 45.2
Comments:
BQL = Below Quantitation Limit
All soils are corrected for percent solids.
N.C. CERTIFICATION #481
Date Analyzed:
5/2/06
Analyzed By:
eaw
Date Collected:
4/25/06 8:45
Date Received:
4/27106
Solids:
64.08
Result
MG/KG
16800
Reviewed By: �
9071—LIMS—vl.35
3of18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-1
Client Project ID:
25040
Lab Sample ID:
G520-160-28
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Method
Oil & Grease 9071
Comments:
BQL = Below Quantitatlon Limit
All soils are corrected for percent solids.
0
Date Analyzed:
512/06
Analyzed By:
saw
Date Collected:
4125/06 10:40
Date Received:
4127/06
Solids:
76.29
RL
Result
MG/KG
MG/KG
. 40.7
BQL
N.C. CERTIFICATION #481
Reviewed By:
9071_LIM _vl.35
4of18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-2
Client Project ID:
25040
Lab Sample ID:
G520-160-3B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Method RL
MG/KG
Oil & Grease 9071 34.4
Comments:
BOIL = Below Quantitation Limit
All soils are corrected for percent solids.
Date Analyzed:
5/2/06
Analyzed By:
eaw
Date Collected:
4/25106 10:45
Date Received:
4/27106
Solids:
83.71
Result
MG/KG
4120
N.C. CERTIFICATION #481
Reviewed By:
9071_LIM _v1.35
5of18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-3
Client Project ID:
25040
Lab Sample ID:
G520-160-4B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Method RL
MG/KG
Oil & Grease 9071 31
Comments:
BQL = Below Quantltatlon Limit
All soils are corrected for percent solids.
N.C. CERTIFICATION #481
Date Analyzed: 5/2/06
Analyzed By:, eaw
Date Collected: 4/25/06 10:50
Date Received: 4/27/06
Solids: 88.76
Result
MG/KG
55.8
Reviewed By:L
9071_1-IMS_0.35
6of18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-4
Client Project ID:
25040
Lab Sample ID:
G520-160-5B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Method RL
MG/KG
Oil 8 Grease . 9071 31.3
.Comments:
BQL = Below Quantitation Limit
All soils are corrected for percent solids.
Date Analyzed:
512/06
Analyzed By:
eaw
Date Collected:
4/25/00 10:55
Date Received:
4/27/06
Solids:
87.70
Result
MG/KG
BOIL
N.C. CERTIFICATION #481
Reviewed By:
9071_LIM _v1.35
7of18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-5
Client Project ID:
25040
Lab Sample ID:
G520-160-6B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Oil & Grease
Comments:
Method
9071
BOIL = Below Ouantitation Limit
All soils are corrected for percent solids.
RL
MG/KG
Date Analyzed:
5/2/06
Analyzed By:
eaw
Date Collected:
4/25/06 11:35
Date Received:
4/27/06
Solids:
83.20
Result
MG/KG
2550
N.C. CERTIFICATION #481
Reviewed By:
9071_LIM _0.35
8of18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-6
Client Project ID:
25040
Lab Sample ID:
G520-160-7B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Oil & Grease
Comments:
Method
711M
BQL = Below Quantitation Limit
All soils are corrected for percent solids.
RL
MG/KG
32.4
N.C. CERTIFICATION #481
Date Analyzed: 5/2/06
Analyzed By: eaw
Date Collected: 4125/06 11:40
Date Received: 4/27/06
Solids: 88.09
Result
MG/KG
BQL
Reviewed By: L
9071_LIMS_v1.35
9of18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-7
Client Project ID:
25040
Lab Sample ID:
G520-160-8B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Oil 8 Grease
Comments:
Method
9071
BQL = Below Quantitation Limit
All soils are corrected for percent solids.
RL
MG/KG
41.4
Date Analyzed:
5/2/06
Analyzed By:
saw
Date Collected:
4/25/06 11:45
Date Received:
4/27106
Solids:
72.55
Result
MG/KG
BQL
N.C. CERTIFICATION #481
Reviewed By:
9071_LIM _v1.35
10 of 18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-8
Client Project ID:
25040
Lab Sample ID:
G520-160-9B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Method RL
MG/KG
Oil & Grease 9071 33.8
Comments:
BOIL = Below Quantitation Limit
All soils are corrected for percent solids.
Date Analyzed: 5/2/06
Analyzed By: saw
Date Collected: 4/25106 11:50
Date Received: 4/27/06
Solids: 89,62
Result
MG/KG
179
N.C. CERTIFICATION #481
Reviewed By:
9071_LIM _0.35
11 of 18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-9
Client Project ID:
25040
Lab Sample ID:
G520-160-10B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Method RL
MG/KG
Oil 8 Grease 907136.4
Comments:
BQL = Below Quantitation Limit
All soils are corrected for percent solids.
N.C. CERTIFICATION #481
Date Analyzed:
513/06
Analyzed By:
eaw
Date Collected:
4/25/06 12:35
Dale Received:
4/27106
Solids:
82.85
Result
MG/KG
Reviewed By\.V--
9071_LIMS_vl.35
12 of 18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-10
Client Project ID:
25040
Lab Sample ID:
G520-160-11 B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Oil & Grease
Comments:
Method
9071
BQL = Below Quantitation Limit
All soils are corrected for percent solids.
RL
711WI L9
40.4
Date Analyzed: 5/3/06
Analyzed By: eaw
Date Collected: 4125/06 12:40
Date Recelved: 4/27/06
Solids: 75.58
Result
MG/KG
68.6
N.C. CERTIFICATION #481
Reviewed By:
9071_LIM _v1.35
13 of 18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
S-11
Client Project ID:
25040
Lab Sample ID:
G520-160-12B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Method RL
MG/KG
Oil 8 Grease 9071 34.5
Comments:
BOIL = Below Quantitation Limit
All soils are corrected for percent solids.
N.C. CERTIFICATION #481
Date Analyzed:
513/06
Analyzed By:
eaw
Date Collected:
4/25/06 12:45
Date Received:
4/27/06
Solids:
88.65
Result
MG/KG
383
Reviewed By:L
9071_LIMS_v1.35
14 of 18

SGS ENVIRONMENTAL SERVICES, INC.
Results for Oil and Grease
Client Sample ID:
5-12
Client Project ID:
25040
Lab Sample ID:
G520-160-13B
Lab Project ID:
G520-160
Matrix:
Soil
Parameter
Method RL
MG/KG
Oil & Grease 9071 36.7
Comments:
BQL = Below Quantitation Limit
All soils are corrected for percent solids.
Date Analyzed:
5/3/06
Analyzed By:
saw
Date Collected:
4/2510612:50
Date Received:
4/27/06
Solids:
64.79
Result
MG/KG
319
N.C. CERTIFICATION #481
Reviewed By:
9071_LIM _0.35
15 of 18

SGS ENVIRONMENTAL SERVICES, INC.
List of Reporting Abbreviations
and Data Qualifiers
B = Compound also detected in batch blank
BQL = Below Quantitation Limit (RL or MDL)
DF = Dilution Factor
Dup = Duplicate
D = Detected, but RPD is > 40% between results in dual column method.
E = Estimated concentration, exceeds calibration range.
J = Estimated concentration, below calibration range and above MDL
LCS(D) = Laboratory Control Spike (Duplicate)
MDL = Method Detection Limit
MS(D) = Matrix Spike (Duplicate)
PQL = Practical Quantitation Limit
RL = Reporting Limit
RPD = Relative Percent Difference
mg/kg = milligram per kilogram, ppm, parts per million
uglkg = micrograms per kilogram, ppb, parts per billion
mg/L = milligram per liter, ppm, parts per million
uglL = micrograms per liter, ppb, parts per billion
% Rec = Percent Recovery
% soilds = Percent Solids
Special Notes:
1) Metals and mercury samples are digested with a hot block, see the standard
operating procedure document for details.
2) Uncertainty for all reported data is less than or equal to 30 percent.
M134.030606.3
N.C. CERTIFICATION #481 16 of 18

SGS ENVIRONMENTAL SERVICES, INC
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N.C. CERTIFICATION #481 17 Of 18

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SGS Environmental Services Inc.
Loeado Nationwide
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• Louisiana . Maryland
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"es` Virginia
.�n 055181
CLIENT -
SGS Reference:
PAGE 2_—OF2,
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Date
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Time
Received By:
Special Deliverable Requirements:
Chain of Custody Seal: (CJrde)
INTACT BROKEN ABSEN
R Maned By: (3)
Date
Time
Received By:
Requested Turnaround Time and Special Instructions:
Waited By: (4)
Date
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Appendix E
Soil Disposal Documentation

12861 NC Hwy, 96 Nohh
Zebulon, NC 27597 .
SoilWorks, Inc.
Q
Phone [phone]oo
Fax [phone]
Soilworks, Inc., operating under the State of North Carolina Contaminated
Soil Disposal Permit N SRU600075, hereby acknowledges the receipt of
111.16 tons of soil contaminated with petroleum hydrocarbons and will
property execute the disposal of this soil in the prescribed manner Set forth by
the North Carolina Department of Environment and Natural Resources,
Division Of Waste Management, and in accordance with the requirements of
SRU600075.
Company: Eastern Environmental Management
PO Box 4030
Rocky Mount, NC 27803
Generator: Gleniot Fabrics
3001 N. Main St.
Tarboro, NC 27886
Transporter: Eastern Environmental Management
PO Box 4030
Rocky Mount, NC 27803
Date(s) Received: 04/25/06 (E-02112 odw# 7,,3w,mw mw,36t2.xn)
Soilworks, Inc.
By: