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GE Bet
GE Betz,Inc. Material Safety Data Sheet
4636 Somerton Road
Trevose,PA 19053 Issue Date: 28-MAR-2005
Business telephone: [phone]
EMERGENCY TELEPHONE(Health/Accident): [phone]
1 PRODUCT IDENTIFICATION
PRODUCT NAME:
DIANODIC DN2478
PRODUCT APPLICATION AREA
WATER-BASED CORROSION INHIBITOR.
2 COMPOSITION/INFORMATIONS ON INGREDIENTS
Information for specific product ingredients as required by the
U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer t0
additional sections of this MSDS for our assessment of the potential
hazards of this formulation.
HAZARDOUS INGREDIENTS:
CASO CHEMICAL NAME
7778-53-2 PHOSPHORIC ACID, TRIPOTASSIUM SALT
Severe irritant (eyes)
1310-58-3 POTASSIUM HYDROXIDE (CAUSTIC POTASH)
Corrosive; toxic (by ingestion)
202420-04-0 CHLOROTOLYLTRIAZOLE SODIUM SALT
Potential irritant
No component is considered to be a carcinogen by the National Toxicology
Program, the International Agency for Research on Cancer, or the
Occupational Safety and Health Administration at OSHA thresholds for
carcinogens.
3 HAZARDS IDENTIFICATION
EMERGENCY OVERVIEW
WARNING
May cause slight irritation to the skin. Severe irritant to the
eyes. Mists/aerosols may cause irritation to upper respiratory

tract.
DOT hazard: Corrosive to aluminum, RQ
Emergency Response Guide #154
Odor: Mild; Appearance: Amber To Brown, Liquid
Fire fighters should wear positive pressure self-contained breathing
apparatus(full face-piece type) . Proper fire-extinguishing media:
dry chemical, carbon dioxide, foam or water
POTENTIAL HEALTH EFFECTS
ACUTE SKIN EFFECTS:
Primary route of exposure; May cause slight irritation to the skin.
ACUTE EYE EFFECTS:
Severe irritant to the eyes.
ACUTE RESPIRATORY EFFECTS:
Mists/aerosols may cause irritation to upper respiratory tract.
INGESTION EFFECTS:
May cause gastrointestinal irritation with possible nausea,
vomiting, abdominal discomfort and diarrhea.
TARGET ORGANS:
No evidence of potential chronic effects. -
MEDICAL CONDITIONS AGGRAVATED:
Not known.
SYMPTOMS OF EXPOSURE:
May c redness or itching of skin, irritation, and/or tearing of
eyes (direct contact) .
4 FIRST AID MEASURES
SKIN CONTACT:
Remove contaminated clothing. Wash exposed area with a large
quantity of soap solution or water for 15minutes.
EYE CONTACT:
Immediately flush eyes with water for 15 minutes. Immediately
contact a physician for additional treatment.
INHALATION:
Remove victim from contaminated area to fresh air. Apply
appropriate first aid treatment as necessary.
INGESTION:
Do not feed anything by mouth to an unconscious or convulsive
victim. Do not induce vomiting. Immediately contact physician.
Dilute contents of stomach using 3-4 glasses milk or water.
NOTES TO PHYSICIANS:
No special instructions
5 FIRE FIGHTING MEASURES

FIRE FIGHTING INSTRUCTIONS:
Fire fighters should wear positive pressure self-contained breathing
apparatus (full face-piece type) .
EXTINGUISHING MEDIA:.
'dry chemical, carbon dioxide, foam or water
HAZARDOUS DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
FLASH POINT:
> 20OF > 93C P-M(CC)
MISCELLANEOUS:
Corrosive to aluminum, RQ
UN3266;Emergency Response Guide k154
6 ACCIDENTAL RELEASE MEASURES
PROTECTION AND SPILL CONTAINMENT:
Ventilate area. Use specified protective equipment. Contain and
absorb on absorbent material. Place in waste disposal container.
Flush area with water. Wet area may be slippery. Spread sand/grit.
DISPOSAL INSTRUCTIONS:
Water contaminated with this product may be sent to a sanitary sewer
treatment facility,in accordance with any local agreement,a permitted
waste treatment facility or discharged under a permit. Product
as is - Incinerate or land dispose in an approved landfill.
7 HANDLING& STORAGE
HANDLING:
Alkaline. Do not mix with acidic material.
STORAGE:
Keep containers closed when not in use. Do not freeze. If frozen,
thaw and mix completely prior to use.
S EXPOSURE CONTROLS /PERSONAL PROTECTION
EXPOSURE LIMITS
CHEMICAL NAME
PHOSPHORIC ACID, TRIPOTASSIUM SALT
PEE (OSHA) : NOT DETERMINED
TLV (ACGIH) : NOT DETERMINED
POTASSIUM HYDROXIDE (CAUSTIC POTASH)
PEE (OSHA) : 2 MG/M3(CEILING)
TLV (ACGIH) : 2 MG/M3(CEILING)
CHLOROTOLYLTRIAZOLE SODIUM SALT
PEE (OSHA) : NOT DETERMINED
TLV (ACGIH) : NOT DETERMINED
ENGINEERING CONTROLS:
Adequate ventilation to maintain air contaminants below exposure
limits.
PERSONAL PROTECTIVE EQUIPMENT:
Use protective equipment in accordance with 29CFR 1910 Subpart I
RESPIRATORY PROTECTION:
A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSMA'S 29 CFR
1910,134 AND ANSI ZS8.2 REQUIREMENTS MUST HE FOLLOWED WHENEVER
WORKPLACE CONDITIONS WARRANT A RRSPIRATOR'S USE.
USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED

WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS.
I£ air-purifying respirator use is appropriate, use a
respirator With dust/mist filters.
SKIN PROTECTION:
neoprene gloves-- Wash cff after each use. Replace a,
necessary.
EYE PROTECTION:
splash proof chemical goggles
9 PHYSICAL & CHEMICAL PROPERTIES
Specific Gray. (70F,21C) 1.392 Vapor Pressure (mmHG) - 18.0
Freeze Point (F) -- 11 Vapor Density (air-1) < 1.00
Freeze Point (C) - -12
Viscosity(cps 90F,21C) 18 Solubility (water) 100.0
Odor Mild
Appearance Amber To Brown .
Physical State Liquid
Flash Point P-M(CC) > 20OF > 93C
PH As Ie (approx.) 14.4
Evaporation Rate (Ether-1) < 1.00
NA = net applicable ND = not determined
10 STABILITY & REACTIVITY
STABILITY:
Stable under normal storage conditions.
HAZARDOUS POLYMERIZATION:
Will not occur.
INCOMPATIBILITIES:
May react with strong oxidizers.
DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
INTERNAL PUMPOUT/CLEANOUT CATEGORIES:
nBn
11 TOXICOLOGICAL INFORMATION
Oral LDSo RAT: - >2,000 mg/kg
NOTE - Estimated value
Dermal LD50 RABBIT: >2,000 mg/kg
NOTE - Estimated value
12 ECOLOGICAL INFORMATION
F
k-

AQUATIC TOXICOLOGY
Daphnia magna 48 Hour Acute Toxicity (Estimated)
LC50= 910; No Effect Level- 520 mg/L
Fathead Minnow 96 Hour Acute Toxicity (Estimated)
LC50= 360; No Effect Level= 140 mg/L
BIODEGRADATION
8OD-28 (mg/g) : 21
HOD-5 (mg/g) : 12
COD (mg/g) ; 160
TOC (mg/g) : 60
13 DISPOSAL CONSIDERATIONS
If this undiluted product is discarded as a waste, the US RHEA
hazardous waste identification number is
D002=C0rrosive(pH) .
Please be advised; however, that state and local requirements for
waste disposal may be more restrictive or otherwise different from
federal regulations. Consult state and local regulations regarding
the proper disposal of this material.
14 TRANSPORT INFORMATION
DOT HAZARD: Corrosive to aluminum, RQ
ON / NA NUMBER: W3266
DOT EMERGENCY RESPONSE GUIDE #: 154
15 REGULATORY INFORMATION
TSCA:
All components of this product are listed in the TSCA inventory.
CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ):
1,232 gallons due to POTASSIUM HYDROXIDE (CAUSTIC POTASH) ;
SARA SECTION 312 HAZARD CLASS:
Immediate(acute)
SARA SECTION 302 CHEMICALS:
No regulated constituent present at OSHA thresholds
SARA SECTION 313 CHEMICALS:
No regulated constituent present at OSHA thresholds
CALIFORNIA REGULATORY INFORMATION
CALIFORNIA SAFE DRINKING WATER AND TOXIC
ENFORCEMENT ACT (PROPOSITION 65) CHEMICALS PRESENT:
No regulated constituents present
MICHIGAN REGULATORY INFORMATION
No regulated constituent present at OSHA thresholds
16 OTHER INFORMATION
NFPA/HMIs CODE TRANSLATION
Health 2 Moderate Hazard
Fire 1 Slight Hazard
Reactivity 0 Minimal Hazard
Special ALR pH above 12.0
I
i

(1) Protective Equipment B Goggles,Gloves
(1) refer to section 8 of MSDS for additional protective equipment
recommendations.
CHANGE LOG
EFFECTIVE
DATE REVISIONS TO SECTION: SUPERSEDES
MSDS status! 21-JAN-1999 ** NEW **
16-MAR-1999 12 21-JM-1999
28-MAR-2005 2 16-MAR-1999
rt_
I—

GE Bed
GE Betz,Inc. Material Safety Data Sheet
4636 Somerton Road
Trevose,PA 19053 Issue Date: 03-7UL-2002
Business telephone: [phone]
EMERGENCY TELEPHONE(Health/Accident): [phone]
1 PRODUCT IDENTIFICATION
PRODUCT NAME:
CORRSHIELD MD401
PRODUCT APPLICATION AREA
WATER-BASED CORROSION INHIBITOR/DEPOSIT CONTROL AGENT,
2 COMPOSITION/INFORMATION ON INGREDIENTS
Information for specific product ingredients as required by the
U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to
additional sections of this MSDS for our assessment of the potential
hazards of this formulation.
HAZARDOUS INGREDIENTS:
CAS/{ CHEMICAL NAME
7631-9s-0 SO➢IUM MOLYSDATE (MOLYBDIC ACID,DISODIUM SALT)
Potential irritant (respiratory) ; potential lung
toxicity
1310-73-2 SODIUM HYDROXIDE (CAUSTIC SO➢A)
Corrosive; toxic (by ingestion)
29385-43-1 1-H-BENZOTRIAZOLE,METHYL- (TOLYLTRIAZOLE; TTA)
Solid is an irritant (by all routes) ; liquid is
corrosive
No component is considered to be a carcinogen by the National Toxicology
Program, the International Agency for Research on Cancer, or the
Occupational Safety and Health Administration at OSHA thresholds for
carcinogens.
3 HAZARDS IDENTIFICATION
EMERGENCY OVERVIEW
CAUTION
i

May cause slight irritation to the skin. May cause moderate
irritation to the eyes. Mists/aerosols may cause irritation to
upper respiratory tract.
DOT hazard is not applicable
Emergency Response Guide is not applicable
Odor: Slight; Appearance: Yellow, Liquid
Fire fighters should wear positive pressure self-contained breathing
apparatus(full face-piece type) . Proper fire-extinguishing media:
.....rrr•ryr chemical carbon dioxide,
dorm or water
rrrrrrrrrrrrrrrrr+.+ .*
r rr r r*POTENTIAL HEALTH EFFECTS
ACOTE SKIN EFFECTS:
Primary route of exposure; May cause slight irritation to the skin.
ACUTE EYE EFFECTS:
May cause moderate irritation to the eyes.
ACUTE RESPIRATORY EFFECTS:
Mists/aerosols may cause irritation to upper respiratory tract.
INGESTION EFFECTS:
May cause slight gastrointestinal irritation.
TARGET ORGANS:
Prolonged or repeated exposures may cause toxicity to the lung.
MEDICAL CONDITIONS AGGRAVATED:
Not known.
SYMPTOMS OF EXPOSURE:
May cause redness or itching of skin. .
4 FIRST AID MEASURES I.,.
SKIN CONTACT:
Wash thoroughly with soap and water. Remove contaminated clothing.
Get medical attention if irritation develops or persists.
EYE CONTACT:
Remove contact lenses. Hold eyelids apart. Immediately flush eyes
with plenty of low-pressure water for at least 15 minutes. Get III.
immediate medical attention.
INHALATION:
If nasal, throat or lung irritation develops - remove to fresh air
and get medical attention.
INGESTION:
Do not feed anything by mouth to an unconscious or convulsive
victim. Do not induce vomiting. Immediately contact physician.
Dilute contents of stomach using 3-4 glasses milk or water.
NOTES TO PHYSICIANS:
No special instructions
5 FIRE FIGHTING MEASURES G
I

FIRE FIGHTING INSTRUCTIONS:
Fire fighters should wear positive pressure self-contained breathing
apparatus (full face-piece type) .
EXTINGUISHING MEDIA:
dry chemical, carbon dioxide, foam or water
HAZARDOUS DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
FLASH POINT:
a 20OF o 93C P-M(CC)
6 ACCIDENTAL RELEASE MEASURES
PROTECTION AND SPILL CONTAINMENT:
Ventilate area. Use specified protective equipment. Contain and
absorb on absorbent material. Place in waste disposal container.
Flush area with water. Wet area may be slippery. Spread sand/grit.
DISPOSAL INSTRUCTIONS:
Water contaminated with this product may be sent to a sanitary sewer
treatment facility,in accordance with any local agreement,a permitted
waste treatment facility or discharged under a permit. Product
as is - Incinerate or land dispose in an approved landfill.
7 HANDLING & STORAGE
HANDLING:
Alkaline. Do not mix with acidic material.
STORAGE:
Keep containers closed when not in use. Do not freeze. If frozen,
thaw and mix completely prior to use.
S EXPOSURE CONTROLS /PERSONAL PROTECTION
EXPOSURE LIMITS
CHEMICAL NAME
SODIUM MOLYBDATE (MOLYBDIC ACID,DISODIUM SALT)
PEE (OSHA) : 5 MG/M3(AS Me)
TLV (ACUTE) ; 0.5 MG/M3(AS Me) RESPIRABLE FRACTION
SODIUM HYDROXIDE (CAUSTIC SODA)
PEL (OSHA) : 2 MG/M3
TLV (ACGIH) : 2 MG/M3(CEILING)
1-H-BENZOTRIAZOLE,METHYL- (TOLYLTRIAZOLE; TTA)
PEL (OSHA) : NOT DETERMINED
TLV (ACGIH) : NOT DETERMINED
ENGINEERING CONTROLS:
Adequate ventilation to maintain air contaminants below exposure
limits.
PERSONAL PROTECTIVE EQUIPMENT:
Use protective equipment in accordance with 29CFR 1910 Subpart I
RESPIRATORY PROTECTION:
A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 TER
1910.134 AND ANSI Z88.2 REQUIREMENTS MOST BE FOLLOWED WHENEVER
WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.
USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED
WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS.
If air-purifying respirator use is appropriate, use a
respirator with dust/mist filters.

9XIN PROTECTION:
neoprene gloves-- Wash off after each use. Replace as
necessary.
EYE PROTECTION:
splash proof chemical goggles
9 PHYSICAL & CHEMICAL PROPERTIES
Specific Gray. (70F,21C) 1,290 Vapor Pressure (mmHG) - 18.0
Freeze Point (F) 18 Vapor Density (air=1) c 1.00
Freeze Point (C) -8
Viscosity(cps 90F,21C) 12 & Solubility (water) 100.0
Odor Slight
Appearance Yellow
Physical State Liquid
Flash Point P-M(CC) > 20OF > 93C
PH As Is (approx.) 13.4
Evaporation Rate (Ether=1) c 1.00
NA = not applicable ED = not determined
10 STABILITY& REACTIVITY
STABILITY:
Stable under normal storage conditions.
HAZARDOUS POLYMERIZATION:
Will not occur.
INCOMPATIBILITIES:
May react with strong oxidizers.
DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
INTERNAL PUMEOUT/CLEANOUT CATEGORIES:
nBn
11 TOXICOLOGICAL INFORMATION
Oral LD50 RAT: >4,000 mg/kg
NOTE - Estimated value
Dermal LD50 RABBIT: >2,000 mg/kg
NOTE - Estimated value
12 ECOLOGICAL INFORMATION
AQUATIC TOXICOLOGY
Daphnia magna 48 Hour Static Acute Bioassay (pH adjusted)
0% Mortality= 5000 mg/L
Fathead Minnow 96 Hour Static Acute Bioassay (pH adjusted)
LC50= 3320; No Effect Level= 2110 mg/L
Menidia beryllina (Silversides) 96 Hour Static Acute Bioassay
(pH adjusted)
LC50= 4410; No Effect Level= IS62 mg/L
Mysid Shrimp 48 Hour Static Acute Bioassay (PH adjusted)
LC50= 6810; No Effect Level= 1562 mg/L
Rainbow Trout 96 Hour Static Renewal Bioassay (pH adjusted)
LC50= 1910; No Effect Level- 625 mg/L
BIO➢EGRADATION

ROD-28 (mg/g) : 2
BOD-5 (mg/g) : 0
COD (mg/g) : 31
TOO (mg/g) : 11
13 DISPOSAL CONSIDERATIONS
If this undiluted product is discarded as a waste, the US ROM
hazardous waste identification number is
D002=Corrosive(pH) .
Please be advised; however, that state and local requirements for
waste disposal may be more restrictive or otherwise different from
federal regulations. Consult state and local regulations regarding
the proper disposal of this material.
14 TRANSPORT INFORMATION
DOT HAZARD: Not Applicable
UN / NA NUMBER: Not applicable
DOT EMERGENCY RESPONSE GUIDE H: Not applicable
15 REGULATORY INFORMATION
TSCA:
All components of this product are listed in the TSCA inventory.
CERCLA AND/OR SAM REPORTABLE QUANTITY (RQ) :
0,759 gallons due to SODIUM HYDROXI➢E (CAUSTIC FOUR) ;
USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS:
SEC.G5,G9
SAM SECTION 312 HAZARD CLASS:
Immediate(acute) ;Delayed(Chronic)
SAM SECTION 302 CHEMICALS:
No regulated constituent present at OSHA thresholds
SAM SECTION 313 CHEMICALS:
No regulated constituent present at OSHA thresholds
CALIFORNIA REGULATORY INFORMATION
CALIFORNIA SAFE DRINKING WATER AND TOXIC
ENFORCEMENT ACT (PROPOSITION 65) CHEMICALS PRESENT:
No regulated constituent present at OSHA thresholds
MICHIGAN REGULATORY INFORMATION
No regulated constituent present at OSHA thresholds
16 OTHER INFORMATION
NFPA/MIS CODE TRANSLATION
Health 1 Slight Hazard
Fire 0 Minimal Hazard
Reactivity 0 Minimal Hazard
Special ALK pH above 12.0
(1) Protective Equipment B Goggles,Gloves
(1) refer to section S of MODS for additional protective equipment
recommendations.

CHANGE LOG
EFFECTIVE
DATE REVISIONS TO SECTION: SUPERSEDES
____________ __________
REDS status: 13-FEB-1997 ** NEW **
15-MAY-1999 15 13-FEB-1999
21-JUL-1990 15 15-MAY-1999
13-JM-2000 12 21-JUL-1999 !
02-JUN-2000 12 13-JM-2000
16-JAN-2002 3,4,16 02-SUN-2000
03-JUL-2002 12 16-JM-2002
i

GEBetz
GE Betz,Inc. Material Safety Data Sheet
4636 Somerton Road
Trevose,PA 19053 Issue Date: 07-DEC-2004
Business telephone: [phone]
EMERGENCY TELEPHONE(Health/Accident): [phone]
1 PRODUCT IDENTIFICATION
PRODUCTNAME:
SPECTRUS NX108
PRODUCT APPLICATION AREA:
BIOCIDE
2 COMPOSITION/INFORMATION ON INGREDIENTS
Information for specific product ingredients as required by the
U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to
additional sections of this MSDS for our assessment of the potential
hazards of this formulation.
HAZARDOUS INGREDIENTS:
CAB# CHEMICAL NAME
3252-43-5 DIBROMOACETONITRILE
Irritant (skin) ; IARC=3 (carcinogen status not
classifiable)
10222-01-2 DBNPA (2,2-DIBROMO-3-NITRILOPROPIONAMIDE)
Corrosive (eyes) ; highly toxic(by inhalation) ;
toxic(by ingestion); potential sensitizer
7647-15.-6 SO➢IUM BROMIDE
Irritant
1113-55-9 MONOBROMO-3-NITRILOPROPIONAMIDE
Irritant
73003-80-2 2,2-DIBROMOPROPANEDIAMIDE
Potential irritant
No component is considered to be a carcinogen by the National Toxicology
Program, the International Agency for Research on Cancer, or the
Occupational Safety and Health Administration at OSHA thresholds for
carcinogens.
3 HAZARDS IDENTIFICATION

EMERGENCY OVERVIEW
DANGER
May cause moderate irritation to the skin. Potential skin
sensitizer. Corrosive to the eyes. Mists/aerosols cause irritation
to the upper respiratory tract.
DOT hazard: Corrosive to aluminum
Emergency Response Guide #153
Odor: Slight; Appearance: Yellow To Amber, Liquid
Fire fighters should wear positive pressure self-contained breathing
apparatus(full face-piece type) . Proper fire-extinguishing media:
Flood with water. Use of CO2 or foam may not be effective.
•.r*wr.wr,.♦♦.•r,....x...+..+a..•x..:..xxwr:r*w*•wwwww♦.v.w.r.r.r:.x..+a.a...x.cxrr:.
POTENTIAL HEALTH EFFECTS
ACUTE SKIN EFFECTS:
Primary route of exposure; May cause moderate irritation to the
skin. Potential skin sensitizer.
ACUTE EYE EFFECTS:
Corrosive to the eyes.
ACUTE RESPIRATORY EFFECTS:
Mists/aerosols cause irritation to the upper respiratory tract.
INGESTION EFFECTS:
May cause gastrointestinal irritation. Very large doses may cause
diarrhea, depression, colic and death. May also cause severe
allergic reactions in sensitive individuals.
TARGET ORGANS:
Repeated skin contact may cause sensitization.
MEDICAL CONDITIONS AGGRAVATED:
Not known.
SYMPTOMS OF EXPOSURE:
Causes redness or itching of skin, possibly leading to burns
(dependent on the length of exposure) .
4 FIRST AID MEASURES
SKIN CONTACT:
Wash thoroughly with soap and water. Remove contaminated clothing.
Thoroughly wash clothing before reuse, Get medical attention if
irritation s.develops or persist
EYECONTACT:
URGENT! Immediately flush eyes with plenty of low-pressure water
for at least 20 minutes while removing contact lenses. Hold eyelids
apart. Get immediate medical attention.
INHALATION:
Remove to fresh air. if breathing is difficult, give oxygen. If
breathing has stopped, give artificial respiration. Get immediate r
medical attention. f-
INGESTION:

Do not feed anything by mouth to an unconscious or convulsive
victim. Do not induce vomiting. Immediately contact physician.
Dilute contents of stomach using 3-9 glasses milk or water.
NOTES TO PHYSICIANS:
No special instructions
5 FIRE FIGHTING MEASURES
FIRE FIGHTING INSTRUCTIONS:
Fire fighters should wear positive pressure self-contained breathing
apparatus (full face-piece type) .
EXTINGUISHING MEDIA:
Flood with water. Use of CO2 or foam may not be effective.
HAZARDOUS DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
FLASH POINT:
> 20OF > 93C SETA(CC)
MISCELLANEOUS:
Corrosive to aluminum
UN3265;Emergency Response Guide k153
6 ACCIDENTAL RELEASE MEASURES
PROTECTION AND SPILL CONTAINMENT:
Ventilate area. Use specified protective equipment. Contain and
absorb on absorbent material. Place in waste disposal container.
Flush area with water. Spread sand/grit. Neutralize with soda ash.
DISPOSAL INSTRUCTIONS:
Water contaminated with this product may be sent to a sanitary sewer
treatment facility,in accordance with any local agreement,a permitted
waste treatment facility or discharged under a permit. Product
as is - Dispose of in approved pesticide facility or according to
label instructions.
7 HANDLING & STORAGE
HANDLING:
Acidic. COrrosive(EyeS) . Do not mix with alkaline material.
STORAGE:
Keep containers closed when not in use. Avoid excessive heat and
contamination. Stare only in vented containers.
8 EXPOSURE CONTROLS /PERSONAL PROTECTION
EXPOSURE LIMITS
CHEMICAL NAME
DIBROMOACETONITRILE
FED (OSHA) : NOT DETERMINED
TLV (ACGIN) : NOT DETERMINED -
DENPA (2,2-➢IBROMO-3-NITRILOPROPIONAMIDE)
PEL (OSHA) : NOT DETERMINED
TLV (ACGIH) : NOT DETERMINED
MISC: Note- manufacturer's recommended exposure limit: 2
mg/m3(ceiling)-for powder.
SODIUM BROMIDE
PEL (OSHA) : NOT DETERMINRD

TLV (ACGIH) : NOT DETERMINED Ili,
MONOEROMO-3-NITRILOPROPIONAMIDE
PEL (OSHA) : NOT DETERMINED
TLV (ACGIH) : NOT DETERMINED
2,2-DIBROMOPROPANEDIAMIDE
PEL (OSHA) : NOT DETERMINED
TLV (ACGIH) : NOT DETERMINED
8) EXPOSURE CONTROLS/PERSONAL PROTECTION (continued)
ENGINEERING CONTROLS:
Adequate ventilation to maintain air contaminants below exposure
limits.
PERSONAL PROTECTIVE EQUIPMENT:
Use protective equipment in accordance with 29CPR 1910 Subpart I
RESPIRATORY PROTECTION:
A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CPR
1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER
WORKPLACE CON➢ITIONS WARRANT A RESPIRATOR'S USE.
USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED
WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS.
If air-purifying respirator use is appropriate, use a
respirator with organic vapor/acid gas cartridges and
dust/mist prefilter,
SKIN PROTECTION:
butyl gloves-- Wash off after each use. Replace as necessary.
EYE PROTECTION:
splash proof chemical goggles
9 PHYSICAL & CHEMICAL PROPERTIES
Specific Gray. (90F,21C) 1.269 Vapor Pressure (.HG) < 0.1
Freeze Point (F) - - 0 Vapor Density (air=1) > 1.00
Freeze Point (C) - -18
Viscosity(cps 70F,21C) 69 % Solubility (water) 100.0
Odor Slight
Appearance Yellow To Amber
Physical State Liquid
Flash Paint SETA(CC) > .20OF > 93C
PH As Is (appr0x.) 1.9
Evaporation Rate (Ether=l) < 1.00
NA . not applicable ND = not determined
10 STABILITY& REACTIVITY

STABILITY:
Stable under normal storage conditions.
HAZARDOUS POLYNBRIZATION:
Will not occur.
INCOMPATIBILITIES:
Above 120 deg. C bromine, cyanogen bromide and dibromoacetonitrile
are formed. May react with bases or strong oxidizers.
DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
INTERNAL PUMPOUT/CLEANOUT CATEGORIES:
nBn
11 TOXICOLOGICAL INFORMATION
Oral LD50 RAT: 510 mg/kg
Dermal LD50 RABBIT: >2,000 mg/kg
Inhalation LC50 RAT: 1.325 mg/L/4hr
NOTE - Rat inhalation LC50: >200 ppm/6hr
Skin Irritation Score RABBIT: NOT CORR
NOTE - Not DOT corrosive
Skin Sensitization G.PIG: POSITIVE
NOTE - 9/10 Positive from 53 aqueous DBNPA (active)
Skin Sensitization HUMAN: NEGATIVE
NOTE - 0/26 Positive from 1,250 ppm aqueous DBNPA (active)
Ames Assay NEGATIVE
Non-Ames Mutagenicity NEGATIVE
NOTE - CHO/HGPRT;Micronucleus Test;Rat Hepatocyte Unscheduled DNA
12 ECOLOGICAL INFORMATION
AQUATIC TOXICOLOGY
Bluegill Sunfish 96 Hour Static Acute Bioassay
LC50= 6.5 mg/L
Daphnia magna 21 Day Flow-Thru Life-Cycle Chronic Bioassay
Reproduction EC50- .65; Reproduction NOEL- .35 mg/L
Daphnia magna 98 Hour Static Renewal Bioassay
LC50= 3.3; No Effect Level= 2.15 mg/L
Fathead Minnow 96 Hour Static Renewal Bioassay
LC50= 8.9; No Effect Level= 3.1 mg/L
Marine Copepod (Acartia tonsa) 98 Hour Static Acute Bioassay
LC50= 1.98 mg/L
Rainbow Trout 96 Hour Static Acute Bioassay
LC50= 2.3; No Effect Level= 1.8 mg/L
Sheepshead Minnow 96 Hour Static Acute Bioassay
LC50= ] mg/L
BIODEGRADATION
BOD-28 (mg/g) : 0
BOD-5 (mg/g) : 0
COD (mg/g) : 1090
TOO (mg/g) : 300
13 DISPOSAL CONSIDERATIONS

If this undiluted product is discarded as a waste the US RCRA
hazardous waste identification number is _
D002=Corrosive(pH) .
Please be advised; however, that state and local requirements for
waste disposal may be more restrictive or otherwise different from
federal regulations. Consult state and local regulations regarding
the proper disposal of this material.
14 TRANSPORT INFORMATION
DOT HAZARD: Corrosive to aluminum
ON / NA NUMBER: UN3265
DOT EMERGENCY RESPONSE GUIDE W: 153
15 REGULATORY INFORMATION
TSCA:
This is an EPA registered biocide and is exempt from TSCA
inventory requirements.
CERCLA AND/OR SABA REPORTABLE QUANTITY (RQ) :
No regulated constituent present at OSHA thresholds
FIFRA REGISTRATION NUMBER:
3896- 95
FOOD AND DRUG ADMINISTRATION:
The ingredients in this product are approved by FDA under 21 CFR
116.300.
USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS:
SEO.GS,G]
SABA SECTION 312 HAZARD CLASS:
Immediate(acute) ;Delayed(Chronic) i
SABA SECTION 302 CHEMICALS:
No regulated constituent present at OSHA thresholds
SARA SECTION 313 CHEMICALS:
NO regulated constituent present at OSHA thresholds
CALIFORNIA REGULATORY INFORMATION
CALIFORNIA SAFE DRINKING WATER AND TOXIC
ENFORCEMENT ACT (PROPOSITION 65) CHEMICALS PRESENT:
No regulated constituents present
MICHIGAN REGULATORY INFORMATION
No regulated constituent present at OSHA thresholds
16 OTHER INFORMATION
NFPA/HMIS CODE TRANSLATION III
Health 3 Serious Hazard
Fire 1 Slight Hazard
Reactivity 0 Minimal Hazard
Special ACID AS below 2.1
(1) Protective Equipment B Goggles,Gloves
(1) refer to section 8 of MSDS for additional protective equipment
recommendations.
CHANGE LOG

EFFECTIVE
DATE REVISIONS TO SECTION: SUPERCEDES
--------- ---------------------
NEES status: 15-SEP-1999
17-SEP-1999 12 15-SEP-1999
02-DEC-1997 15 17-SEP-1997
23-DEC-1999 15 02-DEC-1999
21-APR-1998 ;EDIT:9 23-DEC-1995
01-JUL-1998 2 21-APR-1998
08-JUL-1998 2,3,5,9,8,14;EDIT:S 01-JUL-1998
27-JUL-1998 9 09-JUL-1998
28-MAY-1999 3,5,14 27- UL-1998
26-APR-2000 2 28-MAY-1999
29-NOV-2000 4 26-APR-2000
09-AUG-2001 15 29-NOV-2000
28-SON-2002 15 09-AUG-2001
09-DEC-2004 3,5,14 2B-SUN-2002

Jan.10'2006 09:9:37 028-669-6969 �� I� -'iSa�F� � b6770 P.901
FAX
JAN Q BASF Corpo ation
I I I I 2005
' �I 1451 and HllNAad
�nka NC 2 723
Date d
Number of pages Including rover sheet
TD�//,�, ,,,, From
U7 W f%ZtJS7 c d
Phone Phone 26 66
73
Fax Phone Fax Ph no 26 I96 -696
CC:
❑ Urgent For your review ❑ Rep ASAP ❑ Plea comma t
n<G=.1

JAN.1012006 09:30 028-667-6969 BASF f6770 P.002
d
VIOCID5WENCALTREATW ENT
- �� . .. ..•tNORKSHEEffi-ORM 191 .: .
The tolloadrig caicuMons arr7 to/ perfwmed on ariy bladdal pmoueb uU ety rged iBe, Est ..
Csrdina. Thla worksheetm'us�tre oompte'a3d aepara191yfar eadt Bfaei0a4 ocl Nru .This o rs to return
anfifh�lapprapr7ate �arte29dnt'o'grede6i�rated.�iea6wltlat8lanla,Uorrs eiarm¢d fifli
t Fadity Name O 60
NPDES#NC ra
COU* .
3iacettiAng 8lreamM/"J G _g)
f�1i above rnformahan supplledtrytlna Oh4etoaof.Watar[]aality)_
What is the Avefags DallyDls hstge(A-MOO volume ofthauaderh WON . term to the WmRw body2
APaease catculaledbeansirgam wastet;tmc>3rlbanmt:(A�ao perCsrrt3 dfUrfexf a Mh date
/l . 64.R61.X 1oD
= (7QfD)(E846)+(A.o.a} - ( x0.646)) + ( }
7:hls vetuefU1dCr+aepr�en�flle'araateLonoeotreUgh'DniheteosUng &tar dallow, av W oaa. -
U, -Matk the Pains cftha Whofe productdavaket treabnent Proposed oruealn I be dliul arge Id" edin aitt%
Z
+Y het••meac9vz•higrad'retileand+peroefit. aOSjgo�
. �;
6. -lo.o %
'e atfeEa or.tlaeQge 7ala.(AiR.j dsve�hr3hie•app➢wfian7'dbawnils mnstba %marl umg -s
z1FWhda'prdud aeetl inaZ4itrPentifd. - .
9ram®24hrpetfod .
'Please stole,YlaFtl ounoea(a otliame)angst"ber vertadfogfams fal M34 iil Tvrih comrers fe:
Grarr aftpraud- fiuid=eprodudx 9 rater 8 18Z4 Th. X af, :*,
t2BU,oz f get r q py,
JAN 0 z o6

JAN.10.2006 09:38 628-667-6969 GASP t6770 P.003
' Fadfdy3dame: 7-fir #6Pbt5#
E;sff
matetofe{trolume of the water barldlfngsystem bfteea emy yf. bloddal end NP@S - e.po
rtt
Onsnatfechatl sheet please provldefusittkmtfon for}his estimeQ( mwl me, go tlesper b"(d
ow
'Worm- '©5 -mflibngatlona �r '��
MatItOW PH Of the tamdlfng system Prior to=blodde,ad Wm? tf nhnormh Nf . Sm.7.. .
'rglretdaCae decayasfe(n_K3 of gre�prodr�r27 XuaImWm,asslflne �rl :�� d� ed io .
degradaEonmust�be sfamd'atpH develav7&fla A72.pSfreFarrdetd W@ fia igi lbelve film(Fl6
Ufa Is Via time required forihe Mial prodostto degradeto ha&of Ift�adgtndt.0 mwnln 'an); aaes:p ate
=Pies aftHesomees efffl,date. —W `
Sit.
'ihedecayr isdquafkf H:L X t1.69 = =R Rate @. }
tiaiculaEefilegradelfon factor:{f7:�.}. 3hm ts'lGeahstar8erfwsradgi
L_L a
(Volume) + (0.K)
"G'afcufamSlGady`3iate)dl6diaptle L^�ra�lffid6tf�'
rR Z
Ealculata tdnaenfFation ofbioelde,fruitawm"rig few ft,COMWn
(ReosIviv Ream Conaentnidon):
. fsdrg.Cmnc.3 x faRu�%t 1/S y x f!9-ertT -
rrm Ice = D•e .
As 81011 f hamm ®M2g
IV. Caloulaie ragulad'IM@a@oa.
fist sll LCW and EC60 data available forthe whole pmduetsrwrtA to gaefol WIMOolumns. (Noteft milts
shoelditinfargl!}. a+feesepmgfefa coptesd3filhesaur�s;pfgdg
nu alam ��' a -
J�Prdd).�!I)A6agI/�
fR7i/Er1s m �4
➢.W.Q.'FamriO4 fd/2tl04J - 2

JAN.10'2006 09:38 828--�6__67/-6969 GASP 26770 P.009
. '�FacifitylVame: /77`�Y' 'AiPDES'# N
Choose the JMVW I-ME-CM hed'abo /dG SD 07
Enwthe LC50/EM: �6U
. '#.0aaheMO j"ri.L.)is 3eesalhan�i'd�s,7aerfo""Sae fallowing.cal laflon.
fZa0W h!d Umffa5o" = 9:05 x LC60 p
7lhehaYIM (14L)isgmaterMmotegaaIW4dW"Unkrmwi% 61fmmih ftill .cal alto".
Regotated WAaOo" = 0.01 x LC50
>r&r"os"#ae.�Pfopiiafe regrdated 9nritaH¢h7rom8he�skulat(prs� aglslaly Pi in"4
3, 6 mgditet
iFla"tPait"e�r0ae-recek4h0.sLESmlbYabaASatIG": .
o.cfffs2 mgtTithf
2u, Rnalyals.
' , Ift"e feceMng'atmam mncentrafh"fagreatefihan tlaaeadeulafed nlaledi "n,lhen.tp 'biodde
unecdapl9bkf'fMu5a
&aefao"fn ift$po"slble Ohaxge
/' Name(PHrd)
A�eraon-1;oulrjlaFnrg'idde 31VuA4heet{#9ft%rsmTmmahave)
Name(Print)
6"ig"ature - .
t#rfsfw of bubo adalttf/
AgUaffo**o/¢qg tJrdt
fSZi MSR Sandt9 Can6xr
7�ittelgh,R��6s§-i82f
A#h:Todd QrWahwh
f.7.�Q.Porm707(6f100"J ' - 3

,SAN.10'2006 09:39 028-667-6969 BASF N6790 P.005
. '"FaclSly Nsrne: �rr - T1POE5�: (: y 0'�
S9
Su AnagaLs
'popper,zlna of Chramluu are preserd lo- mpo . 'a»nFI -this, drafree &se - ratormm t
be used for each megi andformelol mmpeund present in fhe bloaft LIS themerat EuI dle Ifs ula,nlUl tl r
`�91Nj;'fontntla?.yelgM(FY4),and the ronnanbafion UfIttetnosl compound in the ' ids. ' �._ .. etea .aporete
ftra arg MW prasentlin lhe•bicddm
ANSI,;,,,,,_ Ciiart,leaLFarmvla MOESQUIRMBIOM OfMOEXAMPLE
Copper '0M..51dp B3,545'WWO .26'"O Ie 0.2
Dosage rate of Brocidw(DR)#mom page 4l:.
OR = ammslday . .
dlvemga'Stagy�lsdlrmge`(r7Dpj#iedt~d� L /
ADO- = - Mffor,90oWdalr /v
Discharge carsenhagon(Dq or Bfacidm
DR d •ma7n51daVY nm' Allongal hs
A'�D ` { � mifllongahorrs7day) t
Comrertr)Cto ralm"rawshttar(ppb);
Wametnalllan gal) x.. X.10 Pao
$.4B5xagB7iLefs/mi410N$al
Ca17w1aEutbefracson oEmeaatrnMte memlaertalnYMq�eompound t -
,MF _ W f n,2nm4noiM
CarouratethefracBen or meral•W theblocidal Sompound.jWk. . ..
OF � NIF x MCC _ x, ..
Me)
'F'+hlFJlrmetboaoflL811tr8Veh of mefarintiratllecltaego(M)c
M e DC x BF = .mrt x
'C'akalefe'&oEwkbwammefal concedbadun IblC)stEv"aw.condW
IMC = M x L �160 _ uglf x % -
qdg
xregwatedNerdfagonorote�l{rremhetm.+t: ,u:,vt
' NCDenere161ahrFee95A NCAC 2B: 27 define:
eeppal-ypgn'walar quality adlan level' Zme-flap 6ergo adt Lever
Chromb rn-pOnlrweierqualXy sun lard
(`Values w6 ch o>Eeaedacdantevels muatbe atrdmsaeddim lyhpe rtt ebal ' taatln j,
:W.Q.�'wirt9076A2p/JOJ - ,y

JM.1012006 09:39 828-667-5969 BASF f6770 P.006
/ 81OCIDEYCHEAhjMTFMhjv ENT
"R"HE£f-FORM-101
Thefollaming catculaffans mia� epedo=ad w any bioddal products idffn atelydi d t. the.. 4N
o lb
Carolina Thtsworhsheetin be cempleted separetalY fur each bfoddafIn tluct in Ta1s is ro reV3m
s�@l�if9pptaprtete:datar= dintaffie de9�natpd�'reaswttb aa(utlailmp erlormsd hml '
. . - -. t Facility Name a93F.C.afAa�t�u„I
NPC)FGfANC_& 5700bO O tfto At
Raaeiung 8liaam. / 'c71u' (, lL,. 7Li
(All obom Iafd mabcn suppiiAd$ythe DNlslon of Water Ousifly)
What Is the Average Mlly Dlscherge(A;D.D.DwMme of the Water h rdling sy rem to the m Wrt baayy
. �easerakalaleAieasSeam tA+'e5[eCronaontraLon+QVJC.in'perdant9 - fired 'gt da1a� a
Dcvc - GTQta?Ga. +(Ao:q� - (z3Ho.548) + G h
`Fhie,ratrre .,apmsantrnta ,o-alfrn,Su,gra nrtleking - d rlg lmr rieim �one,
Al WE—
H. What is the nama.afft whole product chentkal beenent proposed bruse in I he dJ&Cf Me Idl r0adta I art•19
S AIYJOS
f5easeSetGreadhasingadleirlsandyerrpnt -
TIT
—3
/ .$r�'dY��n-3—�iIllR/LtSp@yj5/Wd9��ois7,� 7 o 7r
URIat"feed✓ ge�¢ate` 7•u�.�d- 5i llca8atf7'fhe-antls Sore/ —fig tgsn
13
'vdvAwleprarlud rr5etl tnaWrpedotl.
D.R-= -7$ gratfs124hr Wed (. :r-�c ✓ ,
a -
ffesae wets,ytaid ouncesjg wtame)srmstbe cwrYertedlo�grams(a' y. Tt1 - darlh co rm
Gram dwfuduct'=1lufdmofpmdudX 9 nai.vmatar X X VBdTl 0,9MM of Pled IM X
12eit ca. 1 gal.web rp7.

JAN.10'2006 09:40 828-667-6969 BASE d6790 P.007
. Facil4yHame:_,._� ri7hClt=_S# c 6 7
Esthnate tafetrrolutne of the Water handling systvn between entry bloddal product IdNPOMfischargepoirt
On on attached sheet please tern aft
me;00 tags as per MWdmm,
'tWdlrrg legrmn sine,etc) jnlCtu ' C2 m .JG . pr,/,EZ Y�59
'Nolmr� �J, Dt�S mllgon{tagans .
vil IsihepHcfthehandbV,sya%mpdortablodde'addifony JjujkjoWfhe7wyNVAfO —�
1Nhatis•ihe de.0.ey+ate(p9C)of'91e,3nod!itlp tfankmsm:mBrraa dpm aedtsmist Me
degrada3cn as; 4+e s63fedafpRSevMaahNin A3 pW-shmlani eatg drkv ha ng thajw fife(MH '
llfals thetlme raquired'&rrihe inNla}product to degradato hoofftsgdghl rsxn np aasep
copies afthesoureea efVtadafa.
H.L
'Rre dacay mW fs dquaFw .r t X o,69FtL Rats(0. } —
grl9�tlegladasoA fadbo.fm .). -Mils is v*Tu$t oTdLrbsst6m umv ✓.
IOM.) W-�0'.�fi
_ 'CalcNaf/ef�6�t�gaty$tate$97a<.fiarge Qartrnn; �. �,.:•t.:;
L—M A4 .1.
fslctdale c=enbadon orbiodldeInOu m'du^iiup:rowflawro ditn
. - (ReeeKV Stream eonderiftow) .
. ii9.twene.8 R:ftA1C°61 .S��RS:> z .Srsf _,T
eirbaq nean6aflc
Of. CalauVda regul2@dlimff�ivn,.
Listail LC5 OM8=dataavallable*tha Wbole productamortlfn Nfffe, l umris: (Note Hid arirts
st+wtd6efa rapfq). �easayrw?�,eepisaml�resourres:ofi8ira
3dY.g^ l.�i Tea!'raxraribn
6-
.(�fldliF
iara rl�t/ate 6 .
irr9 tom» r J, 79
9,7
.P�1s�f(�1✓7 ' %h9L
sj,�as✓,�rra mnJi✓orJ qG.f� ,D
t.w¢. �a Ada{ur ooa� 2

_BAH.10'2006 09:40 B28-667-6969 BASF tt6770 P.008
- • 'Fac�ty'Name: ✓ - NME3gk C
AR
Chases the lowest LC60MM nstaclebta ; .. D
Enterthel-rftMw
lf5hehagfite {{'f.L)�c JessnlBas.d Bays,Pex{onn ilmttlllwiMg mt an,
'RegsletedlSmilaHort = -0.85 x t:C50 flO"6zS
UCie Falflffe (k(.L)Is ga�tertbaeor squat taq days ar dnknovm,. eforrrrfh foPlourin ,pko '
Regulated 4miFepon = 0.07 z Le6h = r:•. --
for»e9rem ropflatesegslaledllmhehenYrom nhezakulaflmskm iedla" Piece to IbWb1
Ftom Fait•g enter B:e t£teR�igq t1�dl foa0b1;
If theremMng am=ooncentradprt is gnx&rthetrthe WIMIOW m-pJated lih nation, houtm blodde
is
eracceptableionase
'raersan in%esponalblatpterga
Name(PC
sgryatste - ,pats
�EmmnlrornplenngTdde finmf MMAtg*"arenMrom above)
Name(Print) .
$igna4na Data
$Nevi suhmitfa: Mdsk*ofwbiarQMaw .
rigua6o r'ddcd)w Ung
1621 M8B bUivk'a Cellar -
Y.*Vb,HC.271699-4829
Affir.Todd Chdsteesorr
AW.Q..Form 101(612600;

JAN.10'2006 09:91 628-667-6969 BASF #6770 2.009
'Fag4d9 Nair: NpDtS C
Su I le Lab
Inst
:g copper,zinc,or Mlotnhan ere present hr 8iapfopasee161os1dal dompoun oomphthfs tfmh R:sepa 4ferm
be used for each metal anrffer metal mnppumhpfesent In the Modde.Gst the metal, Ifs chat nice Ufa,MoMmufar w - ht
'{fitLVf•foaMilaase ht�FlM,and the &A,metal compnvnd M Me Vito ids{Nt -j� plate4 pswta lb m
lerevey Waist yreserM thebtodde.
_ Gfia�icaP Furmela M�Ie .rarOt hsMMS brEomft aM rg icant 6
RiPLE
C peer AttSD�-5H2fl X3:S459 de .249"019 m 0.
Dosage rate of Biocide•(ORj(--
pag
e fin .
ON = nmm9dag . .
AAverage0ally3iisctrarge(ATibf mmRage 7Y•
AOO = miltoregatonefday - .
Discharge Conceniraffon M of Bloclde
= F7Ft = 4 ttramsfd;IA
POD R -Im-gmorrahaayy _ °aat nur MEM alai- e
. Convert mCtemimognmsditer(ppl*
h7C:ggtJ =—DC(gmmafmllllan gao % . A nr ids , c
Mfi
3.785 V,10 naafi hlion gel
Calqutaay tlrafraam bf melat lndha metal-oordahnirrg esmpwnd jAq.
WF � MW tire
Cetculate IM*Rcttbn of matab in the biocidaf compgand(BM:
.. �j .%
�+bleulate taecanwrrtradbn of mE9atfiothedieWarge(Mj:. .-
Me DC BF ` ugflz
'C'atsutotoghodnstremn•meTah maearitral4ont@4TC�at7ow+gotvcandhg -
VAC o M z 1 1gg ugn x 160 % i
ttegniatetlNmttatlonbfmeffiI gfrem'4btava wg11 .
NC General Staftool5A NCAC 2S.0V 1 define:
Dopper•,7 pgliwat9rqualdy action lever Zm-WR rfN torqu My scft niever
Chromium-51)powal rquality em Bland
slueawhjcreexeaedacdon levolsmrmtba addtasaeddl a tozi ' tesnn .
D.'�Q,$'mSnkal{NZBr1� eN

e of North Carolina
'Is
of Environn uxlt
'id Natural Resources t �.
jivision of Water Quality ���,.•�
Michael Easley, Governor �i(i NCDENR
Willam G.. Ross Jr., Secretary
Alan Klimek, P.E., Director NORTH D m N CA DEPARTMENT OP
QIVIRONMENT AND NATURAL RESOURCES
September 17,2002
MR.JACK A.DELLINGER,PHD
1451 SAND HILL RD
ENKA, NC 28728
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
BASF CORPORATION-ENKA
BUNCOMBE COUNTY
PERMIT NO: NC0000299
LV 02-308
Dear Mr.Dellinger: .
This letter is to acknowledge receipt of check No.00376002 in the amount of $355.50 received from
you dated August 28,2002. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes,Regulations or Permits.
If you have any questions,please call Robert Farmer at(919)733-5083.
Sincerely,
�l
—� Coleen Sullins,Chief
Water Quality Section
Cc: Enforcement File#: LV 02-308
ARORegional Office Supervisor
Central Files
1617 Mail Service Center,Raleigh,NC 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/10% post-consumer paper

�#NC0000299/BASF]
Subject: [Fwd: NPDES#NC0000299/BASF]
Date: Thu, 08 Aug 2002 14:16:32 -0400
From: Tom Belnick<[e-mail]>
To: Robert Farmer<[e-mail]>
CC: Roger Edwards<[e-mail]>,
Charles Weaver<[e-mail]> _
fyi. . .Robert- this email serves as their rescission request.
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: (919) 733-5083 ext. 543
Fax: (919) 733-0719
Subject: Re: NPDES#NC0000299/BASF
Date: Thu, 8 Aug 2002 13:30:39-0400
From: Raymond L Ackerman<[e-mail]>
To: Tom Belnick<[e-mail]>
CC: Jack A Dellinger<[e-mail]>
Yes, Tom we finally did it! and all systems are going well. Please activate
the rescission process fo us; and thanks for your support and patience
through out this project.
Ray Ackerman
Tom Belnick
<tcm.belnick®ncm To: Raymond L Ackerman
ail.neb cc:
Subject: NPDES #NC0000299/BASF
08/08/2002 09:51
AM
Hi Ray- Congratulations on completing the connection to MSD Buncombe on
7/31/021 At this point I assume you want .your NPDES permit rescinded,
so that annual fees and compliance reporting requirements will be
stopped. Please let me know by email response, and I'll foward to the
NPDES Compliance Unit, which actually carries out the rescission steps.
Mailto:tom.belnickoncmail.net
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: (919) 733-5083 ext. 543
Fax: (919) 733-0719
1 of2 8/9/2002 7:45 AM

Subject: BASF rescission
Date: Mon,26 Aug 2002 07:50:41 -0400
From: Roger Edwards<[e-mail]>
Organization: NC DENR-Asheville Regional Office
To: Robert Farmer<[e-mail]>
Robert,
BASF no longer discharges to surface waters. The connection to NSD was
completed on July 31, 2002. Proceed with the rescission of their NPDES
permit, NC0000299.
Thanks,
R. Edwards
Roger Edwards - Roger.Edwardsoncmail.net
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Roger Edwards<RoRcr.Edwards@ncmail net>
NC DENR-Asheville Regional Office
Division of Water Quality-Water Quality Section
1 of 1 8/26/2002 8:02 AM

State of North Cara
Department of Environment 00
and Natural Resources A94r
Division of Water Quality ���
Michael F. Easley, Governor NCDENR
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT MD NxruA RasoURCES
August 19, 2002
Ray Ackerman AUG 1 ?BASF Corporation-Enka �?
1451 Sand Hill Rd
Enka NC 28728
Subject: Acknowledgement of Rescission Request
BASF Corporation-Enka
NPDES Permit No. NC0000299
Buncombe County
Dear Ray Ackerman:
This is to acknowledge receipt of your request that NPDES Permit No. NC0000299
be rescinded. Your request indicated that this permit is no longer needed.
By copy of this letter,I am requesting confirmation from our Asheville Regional
Office that this permit is no longer needed. After verification by the Regional Office that
the permit is no longer needed, NPDES Permit No. NC0000299 will be rescinded.
If there is a need for any additional information or clarification,please do not hesitate
to contact Robert Farmer at(919)733-5083,ext. 531.
Sinc rely,
yr
E. Shannon Langley, Supervisor
Point Source Compliance/Enforcement Unit
cc: ".
Point Source Branch -Dave Goodrich- w/attachments
Point Source Branch -Robert Farmer- w/attachments
Central Files- Wattachments
1617 Mail Service Center, Raleigh, North Carolina 2 769 9-161 7 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 5o%recycled/10%post-consumer paper

,BASF]
Subject: [Fwd: NPDES#NC0000299/BASF] -
Date: Thu, 08 Aug 2002 14:16:32-0400
From:Tom Belnick [e-mail]>
To: Robert Farmer<[e-mail]
CC: Roger Edwards<[e-mail]>,
Charles Weaver<[e-mail]>
fyi. . .Robert- this email serves as their rescission request.
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: (919) 733-5083 ext. 543
Fax: (919) 733-0719
Subject: Re: NPDES#NC0000299BASF
Date:Thu, 8 Aug 200213:30:39-0400
From:Raymond L Ackerman<[e-mail]>
To: Tom Belnick<[e-mail]>
CC: Jack A Dellinger<dellinj @basf-corp.com>
Yes, Tom we finally did it! and all systems are going well. Please activate
the rescission process fo us; and thanks for your support and patience
through out this project.
Ray Ackerman
Tom Belnick
<tom.belnick@ncm To: Raymond L Ackerman
ail.net> cc:
Subject: NPDES #NC0000299/BASF
08/08/2002 09:51
AM
Hi Ray- Congratulations on completing the connection to MSD Buncombe on
7/31/02! At this point I assume you want your NPDES permit rescinded,
so that annual fees and compliance reporting requirements will be
stopped. Please let me know by email response, and I'll foward to the
NPDES Compliance Unit, which actually carries out the rescission steps.
Masi a to: tom.bel.ni.ckCancmail.net
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: (919) 733-5083 ext. 543
Fax: (919) 733-0719
1 of 2 8/8/02 3:12 PI

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F.Easley, Governor
Wiliam G.Ross,Sr., Secretary N C D EN
Alan D.Klimek,P.E.,Director NORTR CARouNA oER,.RTMENT of
Division of Water Quality En"ARONMENT AND NNl Rl RESOURCES
WATER QUALITY SECTION
August 19, 2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jack A. Dellinger, PhD
General Manager
BASF CORPORATION
Sand Hill Road
Enka, North Carolina 28728
SUBJECT: Notice of Violation and Assessment
of Civil Penalty for Violations of N.C.
General Statute 143-215.1(a)(6)
and NPDES Permit NC0000299
BASF CORPORATION
Case No. LV 02 - 308
Bun ombe County
Dear Mr. Dellinger:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$355.50 ($250.00 civil penalty+ $105.50. enforcement costs)against BASF Corporation.
This assessment is based upon the following facts: a review has been conducted of the
discharge monitoring report (DMR) submitted by BASF Corporation for the month of March, 2002.
This review has shown the subject facility to be in violation of the discharge limitations and/or
monitoring requirements found in NPDES Permit NC0000299. The violations, which occurred in
March, 2002 are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that BASF Corporation violated
the terms, conditions or requirements of NPDES Permit NC0000299 and N.C.G.S. 143-
215.1(a)(6) in the manner and extent shown in Attachment A. A civil penalty of not more than
twenty-five thousand dollars ($25,000.00), in accordance with the maximums established by
N.C.G.S. 143-215.6A(a)(2), may be assessed against a person who violates the terms, conditions
or requirements of a permit required by N.C.G.S. 143-215.1(a).

Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural Resources
and the Director of the Division of Water Quality, I, Forrest R. Westall, Division of Water Quality
Regional Supervisor for the Asheville Region, hereby make the following civil penalty assessment
against BASF Corporation:
$ 250.00 For 1 of the 1 violations of G.S. 143-215.1(a)(6) and
NPDES Permif No. NC0000299, by discharging waste into the
waters of the State in violation of permit daily maximum effluent
limits for Biochemical Oxygen Demand (BOD).
$ 250.00 TOTAL CIVIL PENALTY
$ 105.50 Enforcement costs.
$ 355.50 TOTAL AMOUNT DUE

Pursuant to G.S.. 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 G.S. 143B-
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 non-compliance;
(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.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and
Natural Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Please submit payment to the attention
of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit a written request for remission or mitigation 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 must be accompanied
by 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 and stipulation form and a detailed statement, which you believe establishes
whether:

(a) one or more of the civil penalty assessment factors in G.S. 143B-262.1(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:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for remission must be
submitted in writing. The Director of the Division of Water Quality will review the information
during a bimonthly enforcement conference and inform you of his decision in the matter of the
remission request. His response will provide details regarding case status, directions for payment
and provision for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions. Please be advised that the Committee can not consider
information that was not part of the original remission request considered by the Director and
therefore, it is very important that you prepare a complete and thorough statement in support of
your request for remission.
OR
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, 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
and
Mail or hand-deliver a copy of the petition to
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601

Failure to exercise one of the options above within thirty days, 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' Office with a request to initiate a civil action to collect the
penalty.
Please be advised that any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty. If you have any questions about this civil
penalty assessment, please contact Mr. Roger C. Edwards of the Asheville Regional Office at
828/251-6208.
O O�
( ate) VoFrest R. Westall
Water Quality Regional Supervisor
Asheville Region
Division of Water Quality
ATTACHMENTS
cc: Roger Edwards w/ attachments
Point Sources Compliance/Enforcement Unit w/attachments
Central Files w/ attachments

ATTACHMENT A
BASF Corporation
NPDES Number NC0000299
Case Number LV 02.308
Limit Violations, March 2002
Daily Maximum Limit Violations
Parameter Date Reported Value Limit Units
BOD 317/02 376 291 lb/day
it
i
i
i
I�,

STATE OF NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF BUNCOMBE
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
BASF CORPORATION ) STIPULATION OF FACTS
PERMIT NO. 0000299 ) FILE NO. LV 02 - 308
Having been assessed civil penalties totaling $355.50 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated August 13, 2002, 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.
This the day of 2002.
BY
ADDRESS
TELEPHONE

DMR REVIEW RECORD
Facility: BASF Corporation Permit/Pipe No.: 001 MonthNear: 03/02
Daily Violations
Date Parameter Permit Limit/Type DMR Value %Over Limit
3/7/02 BOD 2911b/day daily 376lb/day 23%
Completed by: Date: B/,3/z
i

DIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT
Violator: BASF Corporation
County: Buncombe
Case Number: LV 02 - 308
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private propwly resulting from the violation;
of significant ( ) moderately significant ( )significant
( ) very significant ( )extremely significant
2) The juration and gravity of the violation;
( of significant ( ) moderately significant (.) significant
( )very significant ( )extremely significant
3) Theoffect on ground or surface water quantity or quality or on air quality;
( of significant ( ) moderately significant ( ) significant
( )very significant ( ) extremely significant
4) The post of rectifying the damage;
of significant ( ) moderately significant ( )significant
( )very significant ( )extremely significant
5) The amount of money sav y non-compliance;
( ) not significant Kimoderately significant ( )significant
( )very significant ( )extremely significant
6) Whnot er the violation was committed willfully or intentionally;
( significant ( ) moderately significant ( ) significant
( ) very significant ( )extremely significant
7) The prior record of the violator in complying or failing to comply with programs over which the
Environme01 Management Commission has regulatory authority; and
( not significant ( ) moderately significant ( ) significant
( )very significant ( ) extremely significant
8) The�ost to the State of the enforcement procedures.
( not significant ( )moderately significant ( )significant
( )v ry significant O extremely significa t
Date rest R. es ll, Water Quality Supervisor
Asheville Regional Office
REMISSION FACTORS
( ) Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment
of the petitioner;
( ) Whether the violator promptly abated continuing environmental damage resulting from the
violation;
( ) Whether the violation was inadvertent or a result of an accident;
( ) Whether the violator had been assessed civil penalties for any previous violations; and
( ) Whether payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Date Alan D. Klimek P. E., Director
Division of Water Quality

N. C. DEPARTMEN',-'OF ENVIRONMENT AND
dTu.S:Aifa
NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTION
` ASHEVILLE REGIONAL OFFICE
59 WOODFIN PLACE
QWM N�Y
ASHEVILLE, NORTH CAROLINA 28801
PHONE : [phone] FAX: [phone]
FAX #:
FROM: �C_X��9F1.42.fI S
DATE: /7 A 'Z.
# OF PAGES INCLUDING THIS COVER:
MESSAGE: If questions, please call 828/251-6208 .

BASF Corporation (�) BASF
August 2, 2002 AUG — 5 2002
Mr. Roger Edwards
Waste Water Consultant
NC DENR
59 Woodfin Place
Asheville, NC 28801 —2414
Re : NPDES Permit NC 0000299
Dear Mr. Edwards:
This memo is to inform you that BASF has discontinued the discharging of waste
water to Hominy Creek (outfall #001 per the referenced permit), effective the 1st
of August. Flow was actually stopped on the evening of July 31". We are now
sending all of our waste water to the Metropolitan Sewerage District of
Buncombe County. They have issued us Permit Number S-072-02 for this
discharge; it is effective August 1, 2002.
Our NPDES Permit also covered outfall #002, non-contact cooling water
discharged through our East Ditch. This water has been commingled with the
several streams from condensers and cooling towers, which have been permitted
under our general discharge Permit Number NCG50067. This permit has recently
been reissued to also be effective August 1, 2002.
MSD's Engineering personnel were here yesterday, and Mr. Payne was at our
site today to obtain an initial TSS and BOD sample; all parties seemed satisfied
with the tie-in and start-up conditions.
My thanks to you and the DENR personnel in Raleigh for you exhaustive
patience and assistance in bringing this project to a satisfactory if not swift
conclusion.
Sincerely,
Ray Ackerman
Environmental Manager
Sand Hill Road,P.O.Box 669,Enka,North Carolina 28728-0669 [phone]

State of North Carolina
Department of Environs �mt 4
and Natural Resources �+
Division of Water Quality
Michael F. Easley, Governor NCDENR
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
July 26,2002
RAY ACKERMAN
BASFCORPORATION
SAND HILL ROAD
ENKA, NC 28728
Subject: Reissue-NPDES Wastewater Discharge Permit
BASF Corporation-Enka
COC Number NCG500607
Buncombe County
Dear Permittee:
Your facility was recently granted coverage under wastewater discharge general permit NCG500000. This letter
serves as your notification that the Division of Water Quality(DWQ)has reissued the general permit and that your
facility's coverage will continue under the conditions of the reissued general permit. Please review the new permit
and technical bulletin to familiarize yourself with the changes in the reissued permit.In addition,DWQ is
forwarding herewith a reissued wastewater discharge general permit Certificate of Coverage(COC)for your
treatment facility. This COC 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 May 9, 1994(or as subsquently amended).
The following information is included with your permit package:
* A copy of the Certificate of Coverage for you treatment facility
* Acopy of General Wastewater Discharge Permit NCG500000
* A copy of a Technical Bulletin for General Wastewater Discharge Permit NCG500000
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 Aisles Lau of the Central Office Storrawater
and General Permits Unit at(919)733-5083,ext.578
Sincerely,
for Alan W.Klimek,P.E.
cc: Central Files
Stormwater&General Permits Unit Files
Asheville 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

2002 14:26 #2499 P.001/003
PO�ef-
Fro M :
JUL 1 0 2,002

JUL.09'2002 14:26 #2499 2.002/003
BASF Corporation BASF
July 9, 2002
Mr. David Goodrich
Supervisor
NCDF_NRIDWQ/NPDES UNIT
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Goodrich:
This is in response to your request of Ray Ackerman for a letter detailing the
current status of the MSD project, But first[at me express my appreciation to you
and your staff for their understanding and support of our efforts to discontinue the
operation of our WWTP and discharge to the local POTW.This has been an
expensive and difficult undertaking given the complexity of the situation and the
number of parties involved. BASF has made a concerted effort to keep the local
DENR Office informed and Involved, and will continue to do so.
The project involves the following parties;
BASF Corporation
Colbond, Inc.
Biltmore Farms, Inc.
Fletcher Partners, Inc.
The Enka Village Home Owners
BASF, Colbond, and The Enka Village each have aline that will discharge to a
MSD sewer line. BASF's line is ready to use and Colbond's line will be completed
when The Village waste is removed from their lift station. Colbond, Biltmore
Farms, and Fletcher Partners own the parcels of land through which the line from
Enka Village traverses. BASF built and currently owns the line.The current delay
is the satisfaction of MSD on the easement from Biltmore Farms and the
satisfaction of the County Clerk's office with the proper signature on the deed
transferring ownership of the Village line from BASF to MSD. The Colbond
easement and the Fletcher Partners easement have been accepted by MSD.
Based upon our current information,the transfer of the deed from BASF to MSD
should be properly executed by the and of this week and MSD will have an
acceptable easement from Biltmore Farms by July 19t6.
snntl HIII Roes,P.O.Bea M,Enka,Nam 0arollno 2672&0669 (6261667.7110

2002 19:26 02999 P.003/003
2
Once these legal issues are resolved and MSD gives us permission to complete
the tie-in of the village line,we anticipate we will be discharging to MSD by the
middle of August. Given the history of the project so far, however,we would
request the extension of our NPDES Permit through the end of August.
Again, let me thank you for your understanding and assistance in the satisfactory
completion of this project.
Sincerely,
eact.
General Manager

Re:[Fwd:NPDES Permit Extension]
Subject: Re: [Fwd: NPDES Permit Extension]
Date: Tue, 18 Jun 2002 07:27:52 -0400
From: Roger Edwards<[e-mail]>
Organization:NC DBNR-Asheville Regional Office
To: Tom Belnick<[e-mail]>
Tom,
Thanks for handling this extension. The 60 days should be more than adequate
time to get everything completed. Again, thanks.
R. Edwards
Tom Belnick wrote:
> fyi. . . sounds like MSD has been dragging this one along. I don't think
> there will be a problem with an administrative extension.
> __
> Mailto:[e-mail]
> N.0 DENR-DWQ/NPDES Unit
> 1617 Mail Service Center, Raleigh NC 27699-1617
> Work: (919) 733-5083 ext. 542
> Fax: (919) 733-0719
------------------------------------------------------------------------
> Subject: NPDES Permit Extension
> Date: Mon, 17 Jun 2002 15:32:45 -0400
> From: Raymond L Ackerman <[e-mail]>
> To: [e-mail]
> Mr. Belnick,
> Needless to say it is both embarrassing and frustrating for me to ask, but
> I find myself totally at the mercy of others in discontinuing the operation
> of our WWTP. We will need to further extend the period of our permit. MSD
> is requiring the completion of four easements pursuant to the new "village
> line" and as you might expect, they are being held up by all the lawyers
> for the five parties concerned ( MSD, BASF, Colbond, The Fletcher Group,
> and Bil tmore Farm, Inc.) . With the exception of the two new manhole that
> will serve the Village, BASF has completed all the work necessary to send
> all of the waste to MSD. (We actually had our part done by mid-May as
> originally expressed to you as a completion date) . I have discussed this
> with Roger Edwards of the Asheville Water Quality Section and he has been
> in contact with MSD. Re has suggested that I request a 60 day extension of
> our permit, which should allow for all the legalities and our small amount
> of construction work to be completed. Your further patience and
> cooperation in this matter is greatly appreciated.
> Sincerely,
> Ray Ackerman
Roger Edwards - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
1 of2 6/18/2002 7:40 AM

State of North CarolinaEnvron
I�
Department of sources _ t 1
and Natural Resources
Division of Water Quality `�-
Michael F. Easley, Governor N C D EN R
Willam G. Ross Jr., Secretary
Gregory J. Thorpe, PhD., Acting Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
May 23, 2002 , st
�I u
JACK A.DELLINGER
1451 SAND HILL RD
ENKA, NC 28728
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
BASF CORPORATION-ENKA
BUNCOMBE COUNTY
PERMIT NO: NC0000299
LV 02.113
Dear Dear Mr.Dellinger:
This letter is to acknowledge receipt of check No.00320581 in the amount of $1,105.50 received from
you dated May 10, 2002. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes,Regulations or Permits.
If you have any questions,please call at(919)733-5083,
Sincerely,
RUC AL"
��Coleen Sullins, Chief
Water Quality Section
Cc: Enforcement File#:LV 02-113 -
ARORegimud Office Supervisor
Central Files
1617 Mail Service Center,Raleigh,NC 27699.1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50%recycledt10% post-consumer paper

BASF Enka Plant;NC0000299;Buncombe County
Subject: BASF Enka Plant; NC0000299; Buncombe County
Date: Fri, 24 May 2002 14:31:17 -0400
From: Tom Belnick<[e-mail]>
To: [e-mail]
CC: Roger Edwards<[e-mail]>
Ray- Based on our conversation today, BASF will need another 30 days to
complete the connection to MSD Buncombe County. The current BASF NPDES
permit expires 5/31/02. We will maintain this permit in active mode for
another 30 days to allow project completion. All terms and conditions
contained in the original permit remain unchanged and in full effect.
Mailto:tom.belnick®ncmail.net
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: (919) 733-5083 ext. 543
Fax: (919) 733-0719
1 of 1 5/24/2002 2:36 PM

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F.Easley,Governor
William G.Ross,Jr.,Secretary NCDENR
Gregory J.Thorpe,Ph.D.,Acting Director NORTH CARouNA DEPARTMENT OF
Division of Water Quality ENVIRONMENT AND NMURAL RESOURCES
WATER QUALITY SECTION
April 29, 2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jack A. Dellinger, PhD
General Manager
BASF CORPORATION
Sand Hill Road
Enka, North Carolina 28728
SUBJECT: Notice of Violation and Assessment
of Civil Penalty for Violations of N.C.
General Statute 143-215.1(a)(6)
and NPDES Permit NC0000299
BASF CORPORATION
Case No. LV 02 - 113
Buncombe County
Dear Mr. Dellinger:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$1,105.50 ($1,000.00 civil penalty + $105.50. enforcement costs) against BASF Corporation.
This assessment is based upon the following facts: a review has been conducted of the
discharge monitoring report (DMR) submitted by BASF Corporation for the month of November
2001. This review has shown the subject facility to be in violation of the discharge limitations
and/or monitoring requirements found in NPDES Permit NC0000299. The violations, which
occurred in November 2001, are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that BASF Corporation violated
the terms, conditions or requirements of NPDES Permit NC0000299 and N.C.G.S. 143-
215.1(a)(6) in the manner and extent shown in Attachment A. A civil penalty of not more than
twenty-five thousand dollars ($25,000.00), in accordance with the maximums established by
N.C.G.S. 143-215.6A(a)(2), may be assessed against a person who violates the terms, conditions
or requirements of a permit required by N.C.G.S. 143-215.1(a).

Based upon the abq-^ findings of fact and conclusiong-( law, and in accordance with
authority provided by the Secretary of the Department of Envii , ment and Natural Resources
and the Director of the Division of Water Quality, I, Forrest R. Westall, Division of Water Quality
Regional Supervisor for the Asheville Region, hereby make the following civil penalty assessment
against BASF Corporation:
$ 1,000.00 For 1 f the 1 violations of G.S. 143-215.1(a)(6) and NPDES
Permit No. 14C0000299, by discharging waste into the waters of
the State in violation of permit monthly average effluent limits
for total suspended solids.
$ 0 For 1 of the 1 violations of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0000299, by discharging waste into the
waters of the State in violation of permit daily maximum effluent
limits for total suspended solids.
$ 1.000.00 TOTAL CIVIL PENALTY
$ 105.50 Enforcement costs.
$ 1,105.50 TOTAL AMOUNT DUE

Pursuant to G.S. 143-215.6A(oj 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 G.S. 143B-
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 non-compliance;
(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.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and
Natural Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Please submit payment to the attention
of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit a written request for remission or mitigation 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 must be accompanied
by 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 and stipulation form and a detailed statement, which you believe establishes
whether:

(a) one or more of the ci("" enalty assessment factors in G.S^"'�3B-2B2.1(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;
(a) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for remission must be
submitted in writing. The Director of the Division of Water Quality will review the information
during a bimonthly enforcement conference and inform you of his decision in the matter of the
remission request. His response will provide details regarding case status, directions for payment
and provision for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions. Please be advised that the Committee can not consider
information that was not part of the original remission request considered by the Director and
therefore, it is very important that you prepare a complete and thorough statement in support of
your request for remission.
OR
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, 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
and
Mail or hand-deliver a copy of the petition to
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601

Failure to exercise no of the options above within thirtylys, 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' Office with a request to initiate a civil action to collect the
penalty.
Please be advised that any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty. If you have any questions about this civil
penalty assessment, please contact Mr. Roger C. Edwards of the Asheville Regional Office at
828/251-6208.
(D te) /Forrest
Water Quality Regional Supervisor
Asheville Region
Division of Water Quality
ATTACHMENTS
cc: Roger C. Edwards w/ attachments
Point Sources Compliance/Enforcement Unit w/ attachments
Central Files w/ attachments

ATTACHMENT A
BASF CORPORATION
NPDES Number NC0000299
Case Number LV 02-113
l
Limit Violations, November 2001
Monthly Average Limit Violations III
Parameter Reported Value Limit Units
TSS 289 209 Ibs/day
Daily Maximum Limit Violations
Parameter Date Reported Value Limit Units
TSS 11/07/01 575 565 Ibs/day
i

STATE OF NORTH CAR06,, DEPARTMLNT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OFBUNCOMBE
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
BASF CORPORATION ) STIPULATION OF FACTS
PERMIT NO. NC0000299 ) FILE NO. LV 02 - 113
Having been assessed civil penalties totaling $1,105.50 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated April 29, 2002, 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.
This the day of 2002.
BY
ADDRESS
TELEPHONE

DMR REVIEW RECORD
Facility: BASF Corporation Permit/Pipe No.: 001 Month/Year: 11/01
Monthly Average Violations
Parameter Permit Limit DMR Value % Over Limit
TSS 209 289 38
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value %Over Limit
11/07/01 TSS 565lbs/day 575 Ibs/day 2.0
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported #of Violations
Other Violations
Completed by: Date:

1)
DIVISION OF vVATER QUALITY - CIVIL PENALTY ASSESSMENT
Violator: BASF Corporation
County: Buncombe
Case Number: LV 02 - 113
ASSESSMENTFACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private prop resulting from the violation;
( of significant ( ) moderately significant ( ) significant
( )very significant ( ) extremely significant
2) The ration and gravity of the violation;
( of significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
3) The Vect on ground or surface water quantity or quality or on air quality;
( t significant ( ) moderately significant ( )significant
( ) very significant ( )extremely significant
4) The lost of rectifying the damage;
act significant ( ) moderately significant ( )significant
( ) very significant ( )extremely significant
5) The amount of money save y non-compliance;
( ) not significant ( oderately significant ( )significant
( )very significant ( )extremely significant
6) Wh er the violation was committed willfully or intentionally;
( of significant O moderately significant O significant
( )very significant ( )extremely significant
7) The prior record of the violator in complying or failing to comply with programs over which the
Environrn r1lanagement Commission has regulatory authority; and
( of significant ( ) moderately significant ( ) significant
( )very significant ( ) extremely significant
S) The st to the State of the enforcement procedures.
of significant ( ) moderately significant ( ) significant
( ) very significant ( )extremely signifi
D e Wrest R. Westall, VVat6r Quality Supervisor
Asheville Regional Office
REMISSION FACTORS
( ) Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment
of the petitioner;
( ) Whether the violator promptly abated continuing environmental damage resulting from the
violation;
( ) Whether the violation was inadvertent or a result of an accident;
( ) Whether the violator had been assessed civil penalties for any previous violations; and
( ) Whether payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Date Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality

,2 10:21 #2650 2.002/005
dASFCorporation r'SAW
March 27,2002
Central Files
NC Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699�1617
Dear Sir:
REFERENCE: Priority Pollutants Monitoring Report 1"Qtr.2002
Enclosed are two copies of the Reporting Form "A"for the Annual Pollutant Monitoring
Requirement of our NPDES Permit# NC 0000299.
Sincerely,
1aa-4Lft--
Rviro Ackerman
E nmental Manager
Attachment
Sand HIII Ramd,P.O.Sox 889,Enka,Notlh Cemlina 28728-0089 (828)8074119

AOG.0912002 10:21 #2650 P.001i.
Fond MIT
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-002 10:25 #2650 P.005/005
Pecs Anerymel8ervlcea,Inc.
FEW OmAvoum..Suite 100
aceAnalXicaf" " 70.075902
PAmm.754.e75anz
wnu,pace70Da.wm iAr704.8759091
to P"j"t Dumber: 9230360
Client.Penject ID: BASF 93273.0E
Dab Bampl.e 90, 93112e902 Px0190t Sample Nurbee: 9230360.001 Date Cottontail 02/15/02 4100
Client "In 10, Ooi 0111MA Matrix: Wear. Date Received: 02/18/02 41,63
ve�..wtera r...n 4. 1InI F9 aeam•t bade Motion ana6 vsnn M. ybnape Affe-ldmit
4,6•pWtro-2-m4rhylphmel ND vp/1 90. 1.0 02/21./02 16:04 "0 534.52.1
•R,4•pinl.teephen0l ND ug/1 50. 1.0 02/21/92 26:04 RPO 51-28-5.
a,4-pinitmhelmee RD to/1 10. 1.0 02/21./02 16:04 war 1.21.14.2
1,6-aW.tmmlvenr RD aN/1 10. 1.0 o2/21/02 a6:04 Rea 606-20-2
pi-n-sctylphthalat, No vg/1 10. 1.0 02/21/02 16,04 IN 17.7.04-0
hie(1.8GhylhrEyllykthalate 25. tell 10. 1.0 02/21/02 16:04 IN 117.61:7 1,M
Pivexanthana NO ug/1 10. 1.0 02/21/02 16:04 NPt 206.44.0
P1v=m ND ug/1 10. 1.0 02/21/09 16:04. NO 06.73.7
7aawwblom-4,3-bntadiene N0 ag/1 10. 2.0 02/21/02 16:04 Men 47-6e4
Mexmhlnrabmemr NO vR/1 10. 1.0 02/21/02 26:04 aPa 110.74-1
Mereehl0rary0l0ymtadiene 3® ep/1 Ia. 4.0 02/21/02 16,04 Ran 77.47.4
getashlOtaekhave ID vB/1 10. 4.0 02/21/02 29,04 too 67.72-1
2nMno(1,1,9-cd)pyrme ND uB/1 10. 2.0 02/21/02 16:04 00 1.93.39.9
1mvpb0mne 90 Vol, to. 1.0 02/21/02 10,04 Man 98-99-1
Nephtbalam DD vg/1 ID. IA 02/21/07 16,c4 "a 91-20-3
Rltmbencene m uP/1 to. 1.0 02/21/02 16,04 RPd 90.93.3
2-Nitx'Vhenol m UP/1 10. 1.0 02/11./0I 16,04 APO 80.16-6
4-N2LtapheP01 'Dr) Ag/1 so. 1.0 02/21./02 1604 RPO 1D0.02.7
R•Mitxse0diaetbyleEime N0 vg/l 10• 1.0 02/21./02 Mee RP0 62.76-9
N-Mikxsam di•n•pxepylemiae DO u9/1 Ia. 1.0 02/21/02 16,04 IN 621.64.7
M•Mitmaodiphm mama ND eg/l 10. 1.0 03/21/02 16;04 RPO 89.30.6
P�ter16ar0phm01 ND ep/1 50. 1.0 03/R1/uR 16;04 Dan 87-06-5
Pbevaathmane N0 ug/l to. 1.0 02/21/03 Mod Ran IS-01.1
7hen01 Dn eg/1 10. 1.0 02/21/07 16104 "a 108.05-2
pytma rap no/1 10. 1.0 02/21/92 16:04 Ran 129.00.0
1,2,44rich10rabeneene an uD/1 10, 1.0 02/21/02 19:04 RP9 120-e2.1
2,4,6-cr2ahlacophonal DN mg/1 10. 1.0 02/21/02 16:04 Ron so-06.2
Rittobenmam49 tat 34 8 1.0 02/21/01 16,04 09 4166-60-0 4
a•nmmrobiph.nyl (a) 34 1 1..0 02/21./02 16,04 Rog 921.00.8 4
T6rphm,y2•dl4 (9) 39 b 1.0 02/21/02 16,04 Pea 1718.51.0
a-elvormhmal (0) s2 1.0 02/21/02 16:04 Rea 367.22.4
2,4.6.4YibroMbeasl (St 0 F 1.0 oR/21/02 26:04 Rea 4
new RaLtmbd oR/20/02
ac 6emivalabilas
pea5leidm in water. by OR PrappletAad; BPA 408 By / EFA 608
A7.dv3n 0.27 va/1 0.050 1.0 0/27/02 COE 2DD-00.2
alpha-BRC to tell 0.860 1.0 02/27/02 CIE 31944-6
n.e., 01/15/02 Pal,.: 2
Lt=Modffim"on1°a REPORT OF LABORATORY ANALYSIS �vndnL°0b"owamWUWJO'JsB
NC Wastewater 12
NC 110000 Water 37706 TAID report shag am be reproduced,except to full, VA Drinking Water 213
SC Mao Without the written gonsent of Pats Analoold Services,Ian. M NELAP E87627

.002 10:22 #2650 P.003/005
QUARTERLY EFFLUENT MONITORING REPORT
March 27, 2002 FAcurY NAME: 6A5F Fibers Enke Plant
Wore PERMIT NO: NO 0000290
.i
Acrylonitnle 1.41 < 10 ,.G 0.041
d?U
Carbon Tetroehlorlde 0,22 < 1 < 0.004
1,2,4-Trichlorobenzena 0.61 '< 1 < 0.004
1,2-Dichloroethene 1.23 < 1A < 0.000.
Hexachlaroethans 0.32 < 10 < 0.041
11,2-Tdchloroethane 0.32 < 1 < 0.004
Chloroform 0.27 < 6 < 0.021
dimmo12-Dichlorobenzens 0.95 < 10 ,a��y< 0.04.1
bimmOv's1,4-Dichlorobenzene 0.16 < 10 < 0,041
1,2-trans-Diehloroekh one 0,32 < 1 < 0.004
9,2-Diohloro ro ane 1.34 < 1 < 0.004
2 4-Dimeth ,phenol , 0.21 10 < 0.041
2,6-1)initrotcluene 3.74 < 10 < 0.041
I
Fluoranthene 0.40 < 10 < 0.041
Methyl Chloride 1.11 < 1 < 0.004
Naphthalene 0.016 < 1 < 0.004
2-Nitro hencl 0.40 < 10 < 0,041
2 4-Dinitro hand 0.72 < 50 < 0.206
BI9(2-ethylhexyl htha,ate M .83 25 < 0.103

AUG.09'2002 10:24 /^`+y #2650 P.004/00,
l y
Nge2
Dimethyl hthalate 0.27 a 10 < 0.041
Benza(a retie 0,016 < 10 < 0,041
Benzo k fluoranthene 0.016 < 10 < 0,041
Acene h lene 0.016 < 10 < 0.041
I t
Fluorene 0.016 < 10 < 0,041
P retie 0.016 < 10 < 0.041
Toluene 0.47 < 1 < 0,004.
c
Vin I Chloride 1.57 < 1 < 0.004
Total Copper 18.7 9,4 0.022
Total Nickel 13.81 e 5 < 0,021
Total Cyanide h'0.78 < 2 < 0.008
Note:
All samples are grab samples taken an Febmary 11th,by Glenn Howell of pace Analyticel, Inc.
Tha 9swthat cloy was a.4a5 MGp.
I cee,,Nythel',this report Is accurate and complete to the beat of my knowledge.
Raymond L.Ackerman
Operator In Responalble Charge
, F

OF wATF9 ^ Michael F.Easley,Governor
William G.Ross Jr.,Secretary
y North Carolina DepaNnent of Environment and Natural Resources
r
y Gregory J.Thorpe, Ph.D.
Acting Director
Division of Water Quality
December 31,2001
Mr. Ray Ackerman
BASF Corporation
1451 Sand Hill Road
Enka,North Carolina 28728
Subject: - NPDES Permit Modification
Permit No. N00000299
BASF-Enka Plant
Buncombe County
Dear Mr.Ackerman:
The subject individual NPDES permit issued on October 23, 1995 has been modified as follows:
• The permit expiration date has been administratively extended to May 31,2002. This permit extension
will provide the permittee time to complete its wastewater connection to the Metropolitan Sewerage
District of Buncombe County. All other terms and conditions contained in the original permit and
subsequent modifications remain unchanged and In full effect.
Please find enclosed the revised Permit Cover Sheet, which will replace the old Permit Cover Sheet. This permit
modification is issued pursuant to the requirements of North Carolina General Statute 143.215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9,
1994(and as subsequently amended).
If any parts, measurement frequencies or sampling requirements contained in this permit modification are
unacceptable to you, you have the right to an ad)udicatory hearing upon written request within thirty (30) days
following receipt of this letter. This request must be In the form of a written petition, conforming to Chapter 150E of
the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center,
Raleigh, North Carolina 27699-6714. Unless such a demand is made,this permit shall be final and binding.
Please take notice that this permit is not transferable. Part II, EA.addresses the requirements to be followed in case
of change in ownership or control of this discharge. 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 permits may be required.
If you have any questions or need additional Information, please contact Mr. Tom Belnick, telephone number (919)
733-5083,extension 543.
Sincerely,
Original Signed By
Oevid A. Goodrich
Gregory J.Thorpe, Ph.D.
cc:
US EPA, Roosevelt Childress
Asheville Regional Office,Water Quality
Point Source Compliance
NPDES File
Central File
RO E
N.C.Division of Water Duality 1617 Mail Service Canter Raleigh.NC 27699.1617 [phone]
Customer Service: 1 800 623-7748

Permit No. NC0000299
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
BASF Corporation
is hereby authorized to discharge wastewater from a facility located at
Fiber Products Division- Enka Plant �.
1451 Sand Hill Road
Enka, North Carolina
Buncombe County
to receiving waters designated as Homony Creek in the French Broad River Basin in _
accordance with effluent limitations, monitoring requirements, and other conditions set forth
in Parts I, II, III, and IV hereof.
The permit shall become effective December 31, 2001
This permit and the authorization to discharge shall expire at midnight on May 31, 2002
Signed this December 31, 2001
Original Signed By
David A. Goodrich
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

file://[Untitled
Ray- In accordance with your request below and following review of the laboratory data you faxed me on
11/14/01,please use this e-mail as approval for the addition of 4 gpd of contaminated groundwater from
BASF's soil vapor extraction process to BASF's wastewater treatment facility(NC0000299). The resulting
discharge to Hominy Creek, Class "C" waters in the French Broad River Basin should present no water
quality compliance problems. Water quality standards assigned to this stream for Trichloroethene and
1,1,2,2-Tetrachloroethane should not be threatened as result of this waste addition.
Please advise if you want to discuss this in more detail. Max
Raymond L Ackerman wrote:
Max,
We are generating approximately 4 gallons a day of contaminated ground water
from the SVE(Soil Vapor Extraction) System under building 660,the former
Marketing Tech Building now leased by A B-Tech(We still own the land under the
building). The water is collected in an 80 gallon knock out tank down stream of
the suction pump. I have faxed you the test results from Pace Analytical
Laboratory showing the contaminants to be 14 ppb of Chloroform,4.5 ppb of
Trichloroethylene, and 140 ppb of 1,1,2,2,-Tetrachloroethane. I am requesting
permission to dump this ground water into our W WTP at the rate of approximately
8 gallons every two days.
Thanks for your attention to this request,
Ray
Max [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality- Water Quality Section
59 Wood£m Place
Asheville,NC 28801
Tel: [phone]
.Fax: [phone]
1 of 1 11/15/2001 1:36 PM

40870 P.001/003
,F CORMRATION BASF
Facsimile Cover Sheet
To:
A . /Y/@k ,dn,� r From: ka) �e.� rWle
7
BASF Corporation .
Sand Hill Read
h Enka,NC 29728
FaX:, phone.
Phone: Fax:
Date:
Pages: .
Subject:.
¢c
COMMENTS:
NV 14 2UUI

NOV.13'2001 15:44 40,
PaePAnetyNcel,.
aceAwvnnvap.lywltabicrmaml ry 9BO0NiWI M is
NO..
Phone:704.87
fist 104.575.M t
vac. An.lytiu.1 a...Laos, Inc. Lab Projeuk Mn er: P227106
54 eavamicroft Dr1ve clink Pnojeet 0: Bur/9324416
Apl.vLll., NC 20001
Attn: Me. Eeverly Mrinae.ad
Phone: [phone]
Lab Sample Ne: 031022347 project Semple N=ber: 92271.06-001 Date Collected: le/E3Jol 10:30
Mont Demple ID: ODE 31ATEB Natxlx: Rent Data a.r.Lvedr 10/13/01 11:06
fir^ „•Me.ylta--_, Daniel , RCWF.a..1,1N.1G Dilut.on-AnalyzaA fAS.X� rtzate Rer"lud,
FC Volxtileg
YPl.k11e Ealonanbom by 601 prop/Mathmd: SPA 6n1 / EPA 601
DicgloxnAltluorometheue MD vg/1 1.0 3.0 ].0/29/01 PPN 75-71-3
ahlanouchnal qD u0/1 2.0 1.0 10/29/01 PPN 74-37-3
Vinyl CbLorl a Na :101 1.0 1.0 1.0/29/al FPM 75-01-4
9ro.ethuff Na xg/1 110 1.0 1.0/29/01 PM 7443-9
Obiomotheme m ug/1 1.0 1.0 1.0/23/01 PPM 75-00-3
Triaglaxot].mxomePdana m uT/1 1.0 1.c 10/29/01 MPH 75-60.4
1,1-Dichlamethnne ND ug/1 1..0 1.0 10/29/03. PPM 15-35-4
Methylma ehlnrlde NO ug/1 2.0 1.0 10/29/01 PM 75.09.2
txm.•1,2-Dicgloxoethene NO ug/1 1.0 1.1) 10/29/01 rpm 156.60-5
1,]:DSCIIIemetbaae m ug/1 1.0 1.0 10/29/01 PPN 75-34.2
Chl".f.m 14. u9/l 1.0 1.0 10/2p/01 PPM 67.66.3
1,1,1-xrlrl1oreethme RD ug/1 1.a 1.0 10/20/01 rpm 71.55.6
Carbam tekrechlorida Ne ug/1 119 1.0 10/29/01 ➢➢N 56-23-5
1,2-D1c410rbatlena hest Nn ug/1 1,0 1,0 10/29/02 PPN 107.06.2
,Tn1.ohl.amnthem : �2:�WSt A.5 urA 1.0 1,0 10/29/01 FYN 79.OS-6
1,2-DLcklerapmpaue i ` L�^` fm u9/1 1,0 1,0 10/29/01 PPN 79-97-5
araaadichloeumetlme Fee ug/L S,a 1.0 10/29/01 ➢➢M 75-27.4
C1.-1,3-pichl...P..pene ND e9/1 1..0 1.a 10/29/O1 PPN 10061-C1-5
trine-1,3•nicllorapxopeue Nn ug/1 110 i,a 10/29/01 PM 10061.02.6
I,22-Trihleroetbme 0 h9/1 L,a 1.9 31V29/01 Fm 79.00.5
Tetrachlcroettme DD ug/1 110 1,0 3.0/29/P3 Fix 127.13-4
DSbromochlgxmmethlae ND ng/1 1.0 1.,0 1.0/29/01 pm 124-48-1
Chlorogeusme ND log/1 1.0 1.0 10/29/01 FIX NB-90.7 �
Emmnform 1,, (.a ND ug/1 1.0 1.0 1e/29/01 PPM 75.25.2
111,2,3-T.tr.dhI6p th e.r 140 ug/1 1.0 1.0 10/29/01 PPM 79-34-5 1
1,3-Piehlorobmn.0 ,)I++xx^^ tin uq/1 1.1 1.0 1.0/29/Al PPM 541-73-1
S,a-Dih].arobeuxeve >E1 ug/1 1.10 1.0 1.0/29/Ol PRE 106-46-7
1,2•D2.eb1orobeuxeae ND u9(1 1.0 1.0 1.0/29/al PPM 95.50.1.
1•C'hlem-3-Elmtabeauna. 1S1 D2 4 3.0 10/29/01 PPN 625.98,9
Y+HI II/OB/Of. W C I. .�d"� Po9ei t
J KKYY11
i
).yhg1�]pryy53Ei(1,4jjon INe �6nm19 WaterH'rall90I90
NO Wastewater 1z REPORT OF LABORATORY ANALYSIS KY Dd9krog water as
NC prinking Water 3770 This report shall nor be reproduced meept in lull, VA prinking Water 219
sc gDoo0 without the written consent at Pace Analyg9al 59NICa9,Inc. FI.NELAP FM27

00870 P.003/003
Pass Anafytfmf 36rPIS8i,Ins.
9Bp9pMxyAveaue,S6ik Im
aceAnalytical" Huao 10 NO2B078
wwn.parnla0rmm Mom.? 4 875909 Rrr.70PB75.9091
Lab FYP7[et MumbsY: 02271.86
C1i[mh. Fxoi[ct 1:0: MF/9324416
Leb Sample No; 931022364 Pm]0et sample Number.: 02271.36.002 Gate Cellecked: 10/21/01 00,00
Clieat Semple ip: BASE TRAVEL ELM Matrix: Racer fete Recelved: 10/23/01 12:05
Pex"Wre 13uu1 en Unit,— N,eeet Mai GklubiaP Avaiyzea [AS No. PlM&t[ Bag Listk
GC volabtlNm
Volatile Oa1eYAYb4A6 by 601 PYap/M[thod; HPA 601. / EPA 601
Cb1oYPloxs YG my/1 La 1.0 10/29/K 2104 PPM 67-66-3
1;-Cblom-3-tluorcbed%s=e t(S) 66 A 1.0 10/20/01 21r24 PPM 925-99.9
4�
aus, xx/pp/ex py�: i
REPORT OF LABORATORY ANALYSIS Ubnratodf.PHilixikOlDS
NO Wastewater 12 KY Drinking Water 90D9D
NO Drinking water 27708 This report shall not be reproduced,ompt In full, VA Drinking Willer 213
6D 09009 withoutthe written consent at Pete AneMICal 3elVINS,Ina Fl-NELAP E87627

State of North Carolina l
Department of Environment
and Natural Resources
Asheville Regional Office ,�
r� . �
Michael F.Easley,Governor N C D EN R
William G.Ross,Jr., Secretary ,.
Kerr T. Stevens,Director NORTR CAROUNA DP TMENT OF
Division of Water Quality ENVIRONMENT ANO NAT.R, RESOURCES
WATER QUALITY SECTION
June 26, 2001
Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Subject: Compliance Sampling Inspection
Status: In Compliance
BASF Corporation
Q Wastewater Treatment Facility
\ NPDES Permit Number NC0000299
uncombe County, North Carolina
Dear Mr. Dellinger:
The Compliance Sampling-Inspection- that I- conductedon May--23, -
2001, showed that the wastewater treatment facility for BASF
Corporation was in compliance with terms and conditions contained in
NPDES. Permit No. NC0000299 . Operation and Maintenance (O&M) activities
continue to be performed in a satisfactory and effective manner. A copy
of the inspection report is attached for your review.
Should you have questions or wish to discuss this report in more
detail, please contact me; telephone (828) 251-6208 .
Your
�L'vOuly
Max L. Haner
Environmental Chemist
Enclosure
CC : Maurice Horsey, EPA
Forrest R. Westall
59 Woodfin Place,Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%mcycledi10%post-consumer paper

..,_.....NORTH.CAROLINA DEPARTMENT OF ENVIRONMENT AND.NATURAL RESOURCES. _
Division of Water Quality -Water Compliance Inspection Report (EPA Form 3560-3)
Section A: National Data System Coding
transaction NPDES N Yrl.olday inspection type inspector facility type days facility self-mmitoam evaluation rarm
New NC0000299 00/05/23 CSI State (2) 1 3 (lv.unreliable/3 satisfactory/5v.reliable)
Section 8: Facility Dan
Name and Location of Facility Entry Time: Permit Effective:
BASF CORPORATION 0830HRS 95/12/01
US HWY 19/23 @ NC HWY 112 Exit Time: Permit
ENKA, N.C. 1125HRS Expiration:
BUNCOMBE COUNTY
2000/09130"
Name(s) of On-Site Representative(s) Title(s) Phone number(s): Fax number(s):
RAY ACKERMAN ORC 828- 667-7277
KAY CROWDER
Name, Title, Address of Responsible Official: Phone number(s): 828-667-7110
JACK A. DELLINGER BASF CORPORATION Fax number(s): 828-
ENKA, NC 28728 Contacted? No
Section C. Are.Evaluated During inspection is-satisfactory,M-Marginal, U-Unsatisfactory,N-Not Evaluated
5 Permit S Flow Measurement 5 Operations&Maintenance N Sewer Overflow
5 Records/Reports S Self-monitoring Program N Sludge Handling/Disposal N Pollution Prevention
S Facility Site Review N Compliance Schedules N Pretreatment N Multimedia
S Effluent/Receiving Waters N Laboratory N Storm Water N Other:
Section D* Surnmary of Findings/CommentskCampliance Status tAttach additional sheets f
EFFILLUENT DATA IGOMPOSIIE SAMPLES) EFFLUENT LIMITS (MO AVE/DAILY MAM PERMIT TO NOTICE 5/23101-
FLOW = Q.478 MGD 1.25 MGD �..
ISS
TRC sio UG& NOT LIMITED
19 C NOT LIMITED
ZINC Q.15 #1DAY 38 UG/L 6.35#/DAY/ 643.5''UG/L
THE WWTP WAS IN FULL OPERATION.WIYH ALL UNITS APPEARING IN GOOD WORKING ORDER. BOTH CLARIFIERS SHOWED SOLIDS IN
THE EFFLUENT LAUNDER. THE ORC ADVISED THAT THE CHLORINE CONTACT CHAMBERS CHECKED REGULARLY FOR SOLID
ACCUMULATION WITH REMOVAL AS NEEDED. TH€SYSTEM OPERATION IS BASED ON MLVSSWHICH ROUTINELY RUNS BETWEEN 1000 TO
1300 MG/L. CURRENT MLVSS LEVEL REPORTED AT-:1000 MGIL.SAMPLING EQUIPMENT,FLOW MEASUREMENT&RECORDING UNITS,
APPEARED WELL MAINTAINED, PM PROGRAM EFFECTIVE. VEGATATION IN FINAL BASIN SHOULD BE REMOVED. COMPLIANCE NOTED
Compliance Status: X Compliance Marginal Compliance/Deficiency Non-Compliance
Name(s)and 5ignatur (s)of lnspe tor(s)/reiephone: Agency/Office: Date: 6/26/00
MAX L. A
828-251-6208 Water Quality Section Asheville Region
Name and gna of Re e F rr t I Fax: [phone] Da
59 Woodfin Place,Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity A8lrmative Action Employer 50%recycled/10%post-consumer paper

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Sale of Conductive Fibers Unit
l 1
D,.. +,
IA
To: [e-mail]
Forwarded by Raymond L Ackerman/KFF/ENKA/BASF-CORP/BASF
on 01/29/2001 08:39 AM
Raymond L Ackerman
O1/23/2001 08:57 AM
To: max.haner
CC:
Subject: Sale of Conductive Fibers Unit
Max,
On January 9, 2001 BASF sold the Conductive Fiber Unit at Enka to Shakespeare
Corporation. The sales will not impact the operation our WWTP nor does it make
any change pursuit to the requirements our NPDES Permit. We will continue to
treat the 5 to 8 gallons per day of waste water that comes from this unit under
our service agreement with Shakespeare.
If you have any questions or concerns, I can be reached at 667-7277 or by e-mail
at ackermrobasf.com
Regards,
Ray
1 of] 10/4/2001 8:07 AM

Re Sale of Conductive Fibers Unit ^ n
To: Raymond L Ackerman<[e-mail]>
CC: Tom Belnick<[e-mail]>, Forrest Westall <[e-mail]>,
Max Haner<[e-mail]>
Reply
Ray - Thanks for the report of BASF's sale of its Conductive Fiber Unit to
Shakespeare Corporation. This notice constitutes compliance with Reporting
Requirements contained in Part I1 Section E of the permit even though there doesn't
appear to be any change in the waste characteristics or volume. I understand that
BASF will continue to accept and treat the wastewater from this process as part of a
service contract. I am placing a hard copy of this notice in your file for
reference and am forwarding this e-mail to Tom Belnick of our NPDES Permits Unit so
that this information can be added to your renewal application. Please advise if
there are additional changes. Max
> Raymond L Ackerman
> 01/23/2001 08:57 AM
> To: max.haner
> cc:
> Subject: Sale of Conductive Fibers Unit
> Max,
> On January 9, 2001 BASF sold the Conductive Fiber Unit at Enka to Shakespeare
> Corporation. The sales will not impact the operation our WWTP nor does it make
> any change pursuit to the requirements our NPDES Permit. We will continue to
> treat the 5 to 8 gallons per day of waste water that comes from this unit under
> our service agreement with Shakespeare.
>
> If you have any questions or concerns, I can be reached at 667-7277 or by e-mail
> at [e-mail]
Regards,
> Ray
Max Haner - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Max Haner<Max.Haner&ncmail net>
NC DENR-Asheville Regional Office
Division of W atcr Quality-Water Quality Section
1 of2 JOW2001 8:08 AM

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$ Ia " NORTH. CAROLINA DEPARTM NT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
IVF ASHEVILLE REGIONAL OFFICE
I WATER QUALITY SECTION
*�a" . April 17, 2000
WYY Ufa OR A�
A s' _
—^.� L OLMAN
¢G#`*e Rr Mr. Jack A. Dellinger, PhD
# �* General Manager
31. BASF Corporation
;a Sand Hill Road
Enka, North Carolina 28728
Subject : . Performance Audit Inspection
•6A �' Inspection Rating 'IC"
$ I 9 Wastewaters. Treatment Program
7� \ BASF Corporation
NPDES Permit Number NC0000299
\Bu combe County, North Carolina
Dear Mr. Dellinger:
The Performance Audit Inspection (PAI) that Gary
,$ Francies and I conducted an March 23, 2000, of BASF' s
wastewater treatment program resulted in an overall rating
jI d ,t j3 of "C" relative to the evaluation of sampling, flow
measurement, and laboratory procedures. Regulatory and
d• �{ g methodology violations were identified in the laboratory
portion of the inspection which centered again (see previous
$ 1 4a' ta inspection report of 2/18/99) around sample handling,'
analysis, or data reporting procedures for fecal coliform,
m " U. total suspended residue and BOD. Ammonia procedures were
also cited. Comparison of results of split sample analysis
1WUUWs. between the BASF laboratory and the NCDENR Water Quality
; =�±s laboratory was favorable as was data transfer.
The results of this PAI should not be interpreted to
question compliance with terms and conditions contained in
the NPDES permit. Sample analysis showed the discharge to be
.. meeting effluent limitations and the evaluation of the
wastewater treatment facility showed proper operation and
..eNfl'„ w •. control .
xs�ae >na
INTERCHANGE SUu.OING, 56 WOODFIN GLADE. Ae HEVILLE. NORTH CAROUNA 28201-2414
.""� PHON0628-2SI-6208 FAX [phone]
i i➢'�} } kk5§� �'Pd�L MWn AN EQUAL OPPORTUNITY /AFFIRMATIVE A<TION EMPLOYER - 50% RECYCLED/10% POST-CONSUMER PAPER

Page 2
April IV, 2000
Mr. Dellinger
A copy of the report is attached for your review. I£ you have
questions regarding this report, please do not hesitate. to contact
Mr. Francies or me at (828) 251-6208
Yo truly,
Haner
E ironment al Chemist
Enclosure
cc: Melinda Greene, EPA
Forrest R. Westall
Gary. Francies
I

United States E4 coral Protection Agency FApp�al
Approved
Washington, D.C.20460 No. 204M003
EPA Expires ]-31-85
NPDES Compliance Inspection Report
Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector F.Type
1 IN 1 215 1 3 1 NC0000299 11 12 00/03/23 17 16 19 20IZ
u LJ Remarks u LJ I_J
Reserved Facility Evaluation Rating BI QA Reserved
67 I I 69 70 Iu on
71 I N 72 N u 73 I I I 74 75 �80
I I Section B:Facility Date I
Name and Location of Facility Inspected .. Entry Time Permit Effective Data
BASF CORPORATION ()goo HR$ 95/12/01
US HWY 19/23 & NC 112
ENKA, INC, BUNCOMBE COUNTY Exit Time/Date Permit Expiration Date
1600 HRS 00/09/30
Names)of On-Site Representative(s)/Fitle(s) Phone No(s)
RAY C. ACKERMAN, ORC [phone]
MANAGER, ENVIRONMENTAL/SAFETY/QUALITY
Name,Address of Responsible Official Title
JACK A. DELLINGER GENERAL MANAGER
BASF CORPORATION
ENKA, N.C. 28728 Phone No. Contacted
[phone] NO
Section C:Areas Evaluated During Inspection CODES v S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated(Not applicable
$ Permit $ Flow Measurement N Pretreatment $ Operations &Maintenance
$ Records4teporls $ Laboratory N Compliance Schedules S Sludge Disposal
S Facility Site Review $ EHluent/Receiving Waters S Self-Monitoring Program Other:
Section D:Summary of Findings/Comments (Attach additional sheets it necessary)
EFFLUENT DATA( (COMPOSITE) PERMIT LIMITS (MO AVU DAILY MAXI
FLOW — 0.606 MGD 1.25 MGD
SOD,5-DAY — 71 #/DAY(14 MG/q 136 #/DAY / 291 #/DAY
TSS = 91 #/DAY(18MGA) 209#/DAY / 565 #/DAY
FECAL COLIFORM = NS /100ML (GRAB) 20W100MU 400/100ML
D.O. = 9.4 MG/L®14-C NOT LIMITED
PH 7.80 (BASF) 6.0 / 9.0(RANGE)
RCL — 0.14 NOT LIMITED
THE W WTP WAS IN FULL OPERATION.WITH ALL UNITS APPEARING IN GOOD WORKING ORDER.. ONE OF THE TWO CLARIFIERS(SOUTH CLARIFIER)
WAS OUT OF SERVICE FOR ROUTINE CLEANING, THE FINAL POLISHING BASIN CONTAINED A HEAVY VEGATATIVE GROWTH (ALGAE)WHICH
COULD CAUSE COMPLIANCE PROBLEM IF ALLOWED TO FURTHER DEVELOP. RECOMMEND THAT BASIN BE CLEANED OF ALGAE GROWTH AS NEEDED.
THE DISCHARGE WAS IN COMPLIANCE WITH PERMIT LIMITS.
Names)and Signaturels) Ins clans) Agency/Office/Felephone Date
MAX L. HANER
DWQ/ARO 828-251-6208
Signora fewer Agency/Office Date (�N
DWQ/ARO 828-251-6208
Regulatory Office Use Only
Action Taken Data Compliance Status
D Noncompliance
Compliance

PERFORMANCE AUDIT INSPECTION
WASTEWATER TREATMENT FACILITY (NC0000299)
BASF CORPORATION
ENKA, NORTH' CAROLINA
MARCH, 2000
INTRODUCTION
On Thursday, March 23, 2000,,. the North Carolina Division of Water
Quality conducted an on-site inspection of BASF' s wastewater
treatment program including evaluation of the laboratory and
sample collection procedures .
The Performance Audit Work with the Company' s laboratory, sample
collection and flow measurement procedures were conducted by Gary
Francies and Max Haner of the Division' s Asheville Regional
Office. Personnel from BASF Fibers were Ray L. Ackerman, Manager,
Environmental/Safety/Quality and Operator in Responsible Charge
(ORC) of the wastewater treatment facility; Kay Crowder,
Maintenance Superintendent and backup operator; Carl Jackson &
Darrell Mills, electrician; Glen "Butch" Howell, contract
laboratory (PACE) ; and Eric Barbour, Utilities Superintendent .
The purpose of this inspection was to determine the quality of t
the self-monitoring program being conducted by BASF Fibers
Corporation and assess the reliability of its reported data.
The inspection consisted of evaluation of the flow monitoring
equipment and data handling, evaluation of sample collection and
preservation techniques and evaluation of laboratory and -
analytical techniques, record keeping and data reporting
procedures. NPDES permit number NC0000299 provides for a
discharge (001) from the Company's wastewater treatment facility;
two equalization basins (series) , an aeration basin, dual final
clarifiers, a chlorine contact chamber, a mixing lagoon, sludge
handling and disposal (thickener, conditioner, filter press, BASF
landfill as cover) with discharge to Hominy Creek, Class "C"
waters in the French Broad River Basin. Additionally, the permit
provides for a discharge (002) of non-contact cooling water from
a barometric condenser into Hominy Creek via the east ditch on �.
BASF property.
BASF Fibers Corporation is conducting the self-monitoring part of j
this program in accordance with monitoring requirements contained
in NPDES Permit Number NC0000299. Flow measurement, composite
sampling and collection of samples is satisfactory. Violations
were found in the laboratory methodology part of the inspection
relating to procedures for Ammonia Nitrogen, TSS, Fecal Coliform,
and BOD.. Four (4) of these violations were cited in the previous
inspection report of February 18, 1999. As result the PAI rating

Page 2
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
for this inspection is "C" , as opposed to the "B-Minus" rating
received during the previous inspection. The PAI rating sheet is
attached for your review. A "C" rating results from a finding of
several minor problems during the inspection. For this rating,
the general operation of the overall facility is noted as good.
FINDINGS AND RECOMMENDATIONS
Recommendations contained in this section are based either on
regulatory requirements or approved methodology. These
recommendations are intended to correct violations noted during
the inspection.
A. FIELD EVALUATION
1 . FLOW MEASUREMENT: Flow is measured at the
discharge structure in the final mixing lagoon using a
30-inch cipolletti weir with a Miltronic ultrasonic
depth probe and Honeywell Recorder. The unit is
checked once per week for accuracy. It also is checked
for accuracy during zero flow periods when the level of
the final basin is lowered for maintenance. This
effluent flow measuring device and as well as the
calibration procedures that are being followed by BASF
personnel are evaluated annually by Law Engineering;
last report transmitted February 2 , 2000 . A check of
the weir showed it to be plumb, level, and meeting
requirements for a properly installed cipolletti weir.
Instantaneous flow measurement at the weir appeared to
show less than a 10% difference in comparison with the
recorded measurement .
a. RECORDS: Records are maintained in a hardbound
notebook by Carl Jackson and Darrell Mills,
maintenance (electrician) .
b. DATA HANDLING: Flow totalizer measurements are
handling properly.
2 . SAMPLING PROCEDURES : The effluent composite
sampling device for discharge 001 is an ISCO model
371OR unit with refrigeration. The permit requires no
monitoring of discharge 002 .
a. Effluent 24 hours composite samples are collected
proportional to flow with a setting of 125 ml per
cycle. The sample aliquot measured 120 mi. The
sampling cycle occurs at 32 pulse intervals;
approximately 5, 000 gallons.

Page 3
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
b. Pump and sample tubing replaced as necessary as
per preventative maintenance program. Basis for
replacement is routine volume measurement of j
composite sample and physical appearance of tubing
The sample strainer is routinely checked as
cleaned (brushed) as necessary.
C. Records : Included in the records maintained for
this unit is-the volume of each composite sample,
when the pump and sample tubing is replaced, and
the temperature of each composite sample upon
collection.
3 . FIELD MEASUREMENTS :
a. The effluent dissolved oxygen (D.O. ) measurement
is measured daily during the time the composite
sample is collected for analysis using D.O.
.meter and probe. D.O. measurement of the
discharge was 9.4 mg/l @ 140 C (NCDWQ) .
b. The effluent pH measurement is performed in the
laboratory from a grab sample collected from the
discharge during sample pickup. The pH was
measured at 7 .8 s.u. (BASF) .
C. The effluent total residual chlorine concentration (.
is measured in the laboratory from a grab sample
collected from the discharge. during sample pickup.
The total residual chlorine was measured at 0 . 14
mg/l . (NCDWQ) .
4 . SAMPLE HANDLING : The composite sample (carboy)
was properly handled with the sample being thoroughly
mixed prior to transfer to the sample container(s) .
5 . RECORD MAINTENANCE : Preventative maintenance
work performed on the system was in accordance with
needs addressed in the weekly computer printout. F .

Page 4
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
6 . OPERATION & MAINTENANCE : O&M is being performed
in a satisfactory manner. The south clarifier had been
drained for routine maintenance. A condition of the
solids appearing sporadically in the clarifiers since
December, 1999, reportedly shows a characteristic of
being weighty and gelatinous; creating a torque
problem in these units . A determination of the cause of
this problem is underway. Wasting of solids is based on
F/M ratio and volatile solids in the system (target
1100-1200 mg/1) . -
7 . PERMIT VERIFICATION : The facility is operating
in compliance with terms and conditions contained in
the NPDES permit (NC0000299) . The permit accurately
reflects the existing wastewater treatment facility and
discharge location.
B . LABORATORY EVALUATION
1 . PERSONNELL : All NPDES testing performed at this
facility is under supervision of Ray Ackerman. The manager
of the laboratory is Jack Dellinger, PhD. Glen "Butch" -
Howell, retired from BASF, performs laboratory analyses
as an employee of Pace Laboratories, Inc.
2 . FACILITIES AND EQUIPMENT : The laboratory is
spacious and adequately equipped for testing performed at
this location of this facility. The laboratory routinely
conducts tests for pH, BOD, Total Suspended Residue, Fecal
Coliform, Ammonia, Zinc, Total Residual Chlorine, and
Temperature. The BASF laboratory is state certified for the
above parameters. Pace Laboratories, Inc . , performs the
remaining NPDES analyses including Aquatic Toxicity.
3 . METHODOLOGY : All testing procedures are based upon
the Laboratory Certification Regulation; 15A NCAC
2H.0800, or approved methodology. Violations are
entered as follows:
a. Violation —Ammonia
The value obtained for the laboratory control
standard was not always calculated and documented.
Regulatory Requirement : Supporting records shall
be maintained as evidence that these practices are
being carried out effectively. All analytical
records must be maintained and available for a
period of three years. 15A NCAC 2H . 0805 (a) (7) &
(7) (G) .

Page 5
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
b. Violation - Ammonia
The percent deviation from the standard curve for
5 of 62 samples was outside the recommended 10%
variance and the problem was not evaluated and
resolved.
Regulatory Requirement : Whenever a laboratory
control standard is outside the recommended 10%
variance, the analysis is out of control and must
be terminated until the problem is corrected.
15A NCAC 2H :0805 (a) (7) (B) & (F) and Approved '
Methodology: Standard Methods, 18`h Edition, ,
Method 1020 3.3 .
C. Violation - Fecal Coliform
Regarding sample preservation, dechlorination of -
the fecal coliform sample was not properly
documented and therefore is considered as not
being performed. This violation was cited in the
previous inspection (2/18/99) .
Regulatory Requirement : Samples containing
chlorine must be dechlorinated at the time of
sample collection and treated according to the
requirements of the analysis to be performed. Upon
receipt in the laboratory, samples treated for
chlorine must be checked and documented to be free
of chlorine . 15A NCAC 2H. 0805 (a) (1) & (7) (M) & (N)
d. Violation - Fecal Coliform
The autoclave log must provide a record to show
when the temperature gauge is used and when this
gauge is checked against the maximum holding
thermometer.
i
Approved Methodology: Standard Methods, 18th
Edition, Method 9020 B.2i The operating
temperature of the autoclave must be verified at
least once per week by checking it against the
maximum holding thermometer.
e. Violation - Total Suspended Residue
The time that the sample is placed in the oven for
drying and the time that the sample is removed
from the oven was not being documented. This
violation was cited in the previous inspection �-
(2/18/99) .
Regulatory Requirement: The drying times must be !,
documented unless every sample is reheated and
redried to a constant weight . 15A NCAC
2H. 0805 (a) (7) &(a) (7) (D)

Page 6
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
f. Violation - BCD
The seed correction factor must be in the range of
0 . 6 mg/l to 1 . 0 mg/l . Records indicate the seed
correction factor for this analysis was outside of
this range. This violation was cited in the
previous inspection (2/18/99) .
Approved Methodology: Standard Methods, 18th
Edition, Method 5210 B.4d 2 .
Regulatory Requirement : Any time that control test
results indicate an analytical problem, the
problem must be resolved and any samples involved
in the test must be reanalyzed if the holding time
has not expired. 15A NCAC 2H . 0805 (a) (7) (F) .
g. Violation - BOD
The BOD value obtained for 23 of the last 38
glucose-glutamic acid standard sets was outside
of the acceptable control range (167. 5 mg/l to
228 . 5 mg/1) and the resulting data were not
qualified.
Regulatory Requirement : Any time that control test
results indicate an analytical problem, the
problem must be resolved and any samples involved
in the test must be reanalyzed if the holding time
has not expired. 15A NCAC 2H . 0805 (a) (7) (F) and
Approved Methodology: Standard Methods, 18th
Edition, method 5210 B. 6a.
h. Violation - BCD
Data reported on the discharge monitoring report
(dmr) are not qualified on the dmr form when
quality control requirements are not met . This
violation was cited in the previous inspection
(2/18/99) .
Regulatory Requirements : iSANCAC 2B 0506 (a) (1) ;
15A NCAC 2B. 0506 (b) (3) (J) ; and Part II, Section
D, Monitoring and Records, Number 7 of NPDES
Permit Number NC0000299 require that all effluent
sample data be reported on certified monthly
report forms. 15A NCAC 2H. 0805 (a) (7) &(a) (7) (D)
requires that sample data reported but not meeting
quality control requirements must be noted on the
discharge monitoring report .

C"3
Page 7
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
4 . RECORDS KEEPING :
Laboratory record keeping was consistent with good
laboratory practice. Records were complete and well
detailed. - -
5 . QUALITY CONTROL :
Effluent samples split with the BASF laboratory showed
the following comparison:
BASF LABORATORY DWQ LABORATORY
SODS 11 .4 mg/l 13 .5 mg/l
TSS 19 mg/l 18 mg/1
FECAL COLI 284/100 ml 215/100 ml*
*Non-effluent - comparative purposes only
6 . DATA HANDLING & REPORTING :
A review of discharge monitoring report (dmr) and
supporting data for September & November, 1999 and
January, 2000, showed no data entry or dmr transfer
problems . The facility was transcribing data in a
satisfactory manner.
I
i�

PAI RATING SCALE
Rating General Descri tion
A The facility has no problems with flow monitoring,
sampling, analyses or data calculating and reporting
procedures. The overall self-monitoring program and
the quality and reliability of the data reported to
state/federal agencies are excellent. The general
operation of the entire facility is also very. good.
e The facility has a few minor problems in one or more
areas of flow monitoring, sampling, analyses or data
calculating and reporting procedures . Examples include
infrequent calibration of flow monitoring equipment,
improper refrigeration of samples, slight discrepancies
in oven or incubator temperatures and not keeping
thorough records. The self-monitoring program is good
and the problems have no major impact on data
reliability. The overall operation of the facility is
very good.
C The facility has a major or several minor problems with
flow monitoring, sampling, analyses or data calculating
and reporting procedures. Examples include
malfunctioning flow monitoring equipment, improper
sampling site, not dechlorinating fecal coliform samples,
unacceptable oxygen depletions and improper seed
correction factors in BOn analyses . The problems noted
at the facility cause the reliability of some of the data
to be questionable. The general operation of the overall
facility is good.
D There are major problems with flow monitoring, sampling
analyses or data calculating and reporting procedures.
Examples include estimating flow, collecting samples at
wrong locations, using improper glassware or equipment,
malfunctioning laboratory equipment, poor laboratory
techniques, or errors in data calculations . The problems
cause the reliability of the self-monitoring data to be
highly questionable. The overall operation of the
facility is fair.
E Severe problems with flow monitoring, sampling, analyses
or data calculating and reporting procedures cause the
self-monitoring data to be unreliable. Examples include
no flow monitoring capabilities, wrong sampling
frequencics and procedures, using unacceptable analytical
techniques or fabrication of information. The self-
monitoring program and the general operation of the
facility is poor.

LAW C
LAWG"iBB Group fliernberAIAL
January 24,2001
Mr. Kay Crowder
BASF Corporation
Sand Hill Road
Enka,North Carolina 28728
Subject: Wastewater Treatment System Effluent Discharge Weir Calibration Confirmation
BASF Corporation
Enka,North Carolina
LAW Project 30300-1-0893
Dear Mr. Crowder:
Law Engineering and Environmental Services, Inc. (LAW) is pleased to submit this report of our
assessment of the effluent flow measuring device used at yew Enka facility. The purpose of ow
services, as described in the attached report, was to observe the method of flow measurement and
equipment calibration for the wastewater treatment system discharge weir. Based on our
observations and calculations, the calibration method used by BASF appears to be complete and
accurate.
We appreciate the opportunity to provide our professional services on this project. Please contact
us at(828)252-8130 if any questions arise or if we may be of further service.
Sincerely,
LAW ENGINEERING AND ENVIRONMENTAL SERVICES,INC.
Matthew E. Wallace,P.E. l/J. David Wallace,P.E. bpq n;
Senior Engineer Principal Water Resources Engineer BY
WITH PERMISSION
Registered,NC#24933 Registered,NC#20055
MEW/JDW:mew
attachment
LAW Engineering and Environmental Services,Inc.
1308-C Patton Avenue
Asheville,NC 28806
828-252-8130•Fax [phone]

) -
BASF Corporation-Report oj . stewaier Treatment System Discharge January 14,2001
Weir Calibration Confirmation
LA W Project 30300-1-0893
Background Information
The BASF Enka facility processes raw materials used in the production of synthetic fibers. The
facility operates its own biological wastewater treatment system located on the property. The
wastewater treatment system is used to condition the process and domestic wastewater generated
at the facility to an acceptable level to allow for discharge to the environment. After treatment,the
wastewater is discharged into a creek that flows through the BASF property. Approximately
500,000 to 600,000 gallons of process water are treated and discharged each day from the facility.
A weir has been installed at the wastewater effluent discharge point to monitor the volume of fluid
that is discharged. The current weir has been in place for approximately seven years. As a
condition of the discharge permit, the flow-measuring device is required to be calibrated on a
regular schedule. BASF personnel have developed and are following a prescribed calibration
procedure. BASF has requested that LAW review their calibration procedure, and certify that the
procedure is complete and accurate.
Site Observations
On January 18, 2001, LAW representative Matthew E. Wallace visited the BASF Enka site to
inspect the head/flow measuring and recording equipment used and to observe the head measuring
and calibration procedures. BASF representative Cart Jackson conducted a tour of the equipment
and explained, step-by-step, the calibration procedure. Following is a discussibn of the equipment
observed and a description of the calibration procedure.
BASF uses a trapezoidal (Cipolletti) weir as the effluent flow-measuring device. The weir is
attached to a concrete wall that restricts and channels the effluent flow through the weir. The weir
is constructed of what appears to be a stainless steel plate, and is approximately one-quarter of an
inch thick. The weir plate is bolted to the concrete wall and is sealed around the perimeter to
prevent flow of water around the plate. The upstream edge of the weir crest is smooth and
perpendicular to the flow of fluid. The downstream section of the weir is chamfered. The crest
length of the weir is 30 inches long. The weir is level and perpendicular to the channel in both the
horizontal and vertical dimensions. A trapezoidal weir has angled sides at both ends of the weir
crest. The BASF weir crest is recessed approximately 15 inches below the top of the plate. The
1

BASF Corporation-Report o1 sharater Treatment System Discharge J January 24,2001
Weir Calibration Confirmation
LAU Prouct 30300-1-0893
angled sides above the weir crest are sloped outward at a slope of 1 unit horizontal to 4 units
vertical. Therefore the horizontal distance between the tops of the angled sides is approximately
37.5 inches(see Figure 1). The weir appeared to be free of excessive build up of debris.
The flow of water into the weir was not turbulent and was ventilated over the crest of the weir.
The cross-sectional area of the approach channel is at least eight times that of the nappe of the
weir at the crest for a distance upstream of greater than 20 times the head on the crest. Also, the
height of the weir from the bottom of the channel is greater than two times the maximum expected
head of liquid above the weir crest. It appears that the weir is positioned at an elevation sufficient
to prevent the downstream liquid level elevation from rising above the crest of the weir during
normal operation. The liquid head measuring device (Milltronics Multiranger Plus-Ultrasonic
level gauge) is positioned upstream at a distance greater than three times the maximum expected
head on the weir, in quiescent section of the channel. Based on these observations, the weir is
constructed in such a fashion that flow measurements should be reliable.
Calibration Procedure
To establish equipment accuracy, at a frequency of approximately once every two weeks, the
continuous ultrasonic flow-measuring device is calibrated against a manual check by BASF. A
wastewater treatment system operator measures the height of water over the weir, calculates the
flow of water expected at the measured head and compares the results with'the flows generated
from the continuous reading automated system. The operator first cleans the upstream face of the
weir with a scrub brush to remove any accumulated debris that may contribute to measurement
error. Next the operator takes a two-foot long jig, one end of which he places on the weir crest and
orients the jig parallel to the flow direction. A level attached to the jig is used to level the jig and a
depth of water reading is taken at the upstream end of the jig, which is positioned two feet behind
the weir crest. The depth of water upstream from the weir crest can be determined to within an
accuracy of one-sixteenth of an inch. The operator also measures the output from the ultrasonic
level gauge. The ultrasonic level gauge is calibrated to measure head depths upstream from the
weir crest from zero to eight inches with a corresponding output of 4 to 20 milli-amps (with 4
milli-amps corresponding to zero inches of head). The gauge also has a LCD display of liquid
head level in feet. The accuracy of the zero reading of the ultrasonic level gauge was evaluated by
2

BASF Cmporation-Report 0�stewaterT Treatment System Discharge J January 14,2001
Weir Calibration Confirmation
LdW Project 30300-1-0893
lowering the water level in the discharge channel. The water level in the discharge channel was
pumped down and the LCD display output for the ultrasonic level gauge was observed. As the
water level decreased, so did the LCD output. After the water level was lowered approximately
one-half inch below the crest of the weir, operation of the discharge pumps was terminated. The
LCD output was observed as the water level recovered in the discharge channel. The operator has
calibration tables for determining discharge flow rates based on head height over the weir and
ultrasonic liquid level gauge outputs. At the time just before the flow of water over the weir
resumed (within two seconds), the LCD display was fluctuating at 0.000 feet within a range of
0.007 feet (attributable to minor surface water waves), and the milli-amp output was 4.06. The
variance of 0.06 milli-amps represents a positive flow error of approximately eight gpm, based on
the transmitter calibration chart. A copy of the calibration tables has been attached.
At the time of our observations, the measured height of liquid over the weir was 2-5/16 inches.
During normal operation, the output from the Milltronics instrument is sent to the wastewater
treatment control room, where the signal is converted and physically recorded on a 24-hour
circular paper chart. The chart is multi-channel and records both the effluent weir flow in gallons
per minute (gpm) and the pH of the liquid. In addition to the circular chart flow rate display,there
is a liquid crystal display of the instantaneous discharge flow rate. The effluent flow rate value
recorded on the circular chart and the corresponding instantaneous:flow rate observed on the
digital readout at the time of the manual measurement was 336 gam. A Fluke hand-held meter
was used to measure milli-amp output from the Milltronics instrument. Ayceading of 6.84 milli-
amps was measured,and the corresponding control panel flow reading was 340 gpm.
Conclusions
The flow rate determined by the Milltronics instrumentation and taken from the strip chart
recorder with digital display was 336 gam. The flow rate calculated from the manual water level
reading at the weir (2-5/16 inches) using the calibration chart was 324 gam. .The flow rate
calculated from the manual water level reading at the weir(2-5/16 inches) was 320 gpm using the
discharge (head vs. flow rate) equation of a free flowing Cipolletti weir, as presented below:
3

BASF Corporation-Report astewafer Reatment SJsteni Discharge nl January 24,2001
Weir Ca/iboozes Confirmation
LAW Reject 30300-1-0893
Q=1511*L*H1.5
where: Q=Flow rate(gpm)
L=Crest length of the weir(feet)
H=Head on the weir(feet)
The measured electronic reading of 6.84 milli-amps corresponds to a flow of 370 gpm, utilizing
the transmitter calibration charts. The flow reading at the control panel at the time of the
electronic reading was 340 gpm. This difference in calculated flow based on the field milli-amp
reading and the displayed control room reading can be largely attributed to accuracy in the hand-
held electronic measuring device used at the transmitter panel in the field. LAW recommends the
continued practice of recording flow rate based on the converted reading of the flow meter in the
control room.
The flow rate at the time of the calibration was calculated from the weir equation to be 320 gpm.
The error between the flow rates from the control panel reading (i.e., 336 gpm) and calculated-
from the weir equation using the manual measurement (i.e., 320 gpm) is approximately 4.9
percent. The error between the flow rates from the head reading utilizing the calibration charts
(i.e., 324 gpm) and calculated from the weir equation using the manual measurement (i.e., 320
gpm)is approximately 1.2 percent.
It should be noted that the weir is oversized for the normal discharge flows. Based on information
received from BASF, the normal discharge flow rates from the BASF Enka facility fluctuate from
a low of around 250 gpm to a maximum of 650 gpm. The normal range of flows usually ranges
from 350 to 400 gpm. To handle flow rates of 250 to 400 gpm, the crest length of the weir needed
is only 1.5 feet long. The minimum suggested flow rate over a 2.5-foot wide crest length weir(as
installed at the BASF Enka facility) is 338 gpm. With average discharge flow rates ranging from
approximately 350 to 400 gpm the weir is operating at or below the minimum suggested flow rate.
However,the error introduced by using the current weir should be relatively negligible. It appears
that the calibration method used by BASF is proper and correct.
4

Cev6 '
5/24/'
MM WASTEWATER. TREATMENT PLANT TRANSMITTER CALIBRATION - 3 ' HGl
FINAL EFFLUENT DISCHARGE AT COVE
2.5 FT WIDE CIPOLLETTI WEIR MGD - 0. 6463 * 8.419 * H expl.5
CALC CALC APPROX
HEAD FLOW SIGNAL SIGNAL FLOW HEAD
IN MGD ma ma MGD IN
0 0. 0000 4.00 4 0.0000 0
1 0.1309 4.70 4.5 0.0938 13/16
2 0.3702 5.97 5 0.1675 1 1/4
• 3 0. 6801 7. 63 5.5 0.2813 1 11116
4 1.0470 9.58 6 0.3750 2
5 1.4633 11,.80-• - - 6.5 0.4688 2 5/16
6 1.9235 14.26 7 0.5625 2 .5/8
7 2.4239 16.93 7.5 0.6563 2 , 15/16
8 2.9615 19.79 8 0.7500 3 3/16
8.5 0.8438 3 7/16
9 0.9375 3 11/16
MAX MAX MAX MAX 9.5 1.0312' 3 15/16
HEAD HEAD FLAW FLAW 10 1.1230 4 3/16
FT IN MGD GPM 10.5 1.2188 4 7/16
11 1.312E 4 5/8
0.672 8.0640 2.9911 2081.21 ll.5 1:4063 4 718
12 1.SOu0 5 1/16•
12.5 1.3938 ' S 5116
13 1.6875 5 1/2
13.5 1.7813 5 21/16
14 1.8750 5 7/8
14.5 1.9698 6 1/16
15 2:0625 6 5/16
15.5 2.1563 6 1/2
36 2.2500 6 12/16
16.5 2.3438 6 13/16
17 2.4375 7
17.5 2:5313 7 3/16
18 2:6Z30 7 3/8
18.5 2.7188 7 9/16
19 2.8225 7 3/4
19.5 2.9063 7 7/8
20 3.0000 8 1/16

r7gure 3
SHARP.('RESTEDM� ,m
K.Fapm2. 118 hn I(...-. 1
POW to k—0-q
Za mee Draxdawn
heaa � or C
V
crasl
Nappy
ventilation
rya• a �'' WArPWa
/.�.�i�ll� � ?.;.;• Yam:®
TRAPEZO MA1, ( pL .F_�_.TTl) WEIR
CFS: -Q-3.367LHfs 2ema `
MOD: Q =2.176 L Hf'S mk mum omm lengti
GPM; Q= 1511 L H1.5 � #
Q=flow mte 4 1 Hmaz
H=Head on the weir
L -Crest length of weir in ft. ON=
MWMM
1 0.2 OS01' Od85. 1J5: 0.5 1.19 0.789 571
11h 0.7 0.45E 0,292 10J 0.75 3.28 1.17 1470
2 02 OS02 d8B8 _270.•n.•. „1-0 8,73 .1,95 ,70N
E1h 02 0.757 O.IB7 ]3B 1.25 11,8 7.60 5900
7 U . 0.m 0$81, ,_ 405;,.,,, .,IS 121 .120 6750
/ 02 1.20 0,778 539 20 38.1 24S 17.100
5 0,2 1 P1, o•f171 .._478.a_ .25 885 , .47.0 .20,100
6 0.1 1.81 1.17 112 3.0 105 874 47,100
1 0,2 7.41 1.5A ,1080 4.0 714 1]8 98,000
f0 0.2- 3of 1.95 1350 5.0 375 243 188,000

l
State of North Carolina
Department of Environment
and Natural Resources ���
Asheville Regional Office r
Michael F. Easley, Governor NCDENR
William G. Ross,Jr., Secretary
Kerr T. Stevens, Director NOA.h cARounn oeRnRrmeRr of
Division of Water Quality ErvviRory nerv-r 4Ro N.ttuRnr.. ResouRccs
- WATER QUALITY SECTION
March 28, 2001
Mr. Ray Ackerman
Environmental Manager
BASF Corporation - Enka Site
1451 Sand Hill Road
Enka, North Carolina 28728
Subject : NOTICE OF VIOLATION
Effluent Limitations
BASF Corporation
QtNPDES Permit Number NC0000299
Buncombe County
Dear Mr. Ackerman:
Review of subject self-monitoring report for the month of January,
2001, revealed violation (s) of the following parameter (s) :
Reported Monthly Ave Limits
Pipe Parameter Value/Unit Value/Type/Unit
001 00530 .RES/TSS 240 . 0 LB/DAY 209 . 0 FIN LB/DAY
Reported Daily Maximum Limits
Pipe/Date Parameter Value/Unit Value/Type/Unit
001/01-02-2001 00530 RES/TSS 575 . 0 LB/DAY 565 . 0 FIN LB/DAY
001/01- 04-2001 00530RES/TSS 627 . 0 LB/DAY 565 . 0 FIN LB/DAY
Remedial actions, if not already implemented, should be taken to
correct the above compliance problem(s) . Please understand that the
Division of Water Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if you need
assistance, do not hesitate to call Mr. Max L. Haner at (828) 251-6208 .
Sincerely, ��'/�,,'��/'�"�`"/'
rrest�Retall!,
Water Quality Regional Supervisor
xc : Max L. Baser
59 Wnndfin Plnce,Asheville Nnrlh Cm'olinp 28801 lde plmne 828-251;6208 FAX [phone]
An Rqud Oppnrlanily ARrmalive Acllnn Engnoyer 50%recycled/10%VRMs cnnsn ncr pdper

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place Asheville,North Carolina 28801
December 21, 2000
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Mr. Ray Ackerman
BASF Corporation-.Enka
1451 Sand Hill Road
Enka,North Carolina 28728
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0000299
BASF Corporation WWTP
Buncombe County
Dear Mr.Ackerman:
This is to inform you that a review of your toxicity self-monitoring report form for the month of October
2000 indicates a 'violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent
toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (TRE) which is a
site-specific study designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity,
evaluate the effectiveness of toxicity control options, and then confirm reductions in effluent toxicity. Please be
aware that North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES
permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note updated mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this
information and if it would be helpful to discuss this situation or possible solutions to resolve effluent toxicity
noncompliance,please contact Mr. Keith Haynes with this office at(828)251-6208.
Sincerel , �y
Porrest Westall %—" —
Regional Water Quality Supervisor
cc: Keith Haynes-Asheville Regional Office
Aquatic Toxicology Unit
Central Files

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following Items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information.ng Rcens belgw do not address
include'all the t f ily testing and Mn ding req i n1a contained in-YOULNEVIRS ptinm_t. If you should have any
questions about your toxicity testing requirement,please contact Mr.Kevin Bowden with the Aquatic Toxicology Unit at
[phone] or another Unit representative nt the same number.
➢ The ep rmittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data Is a dual requirement. All toxicity test results must be entered(with
the appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch �-
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity tot meillis shall be filed with the Environmental Sciencea Branch no later than 30 d4yo afterthe d of th
teoortrhg period(eg,January test result is due by the end of February).
D Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity
testing upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower
than the permit limit,then at least two multiple concentration toxicity tests(one per month)will be conducted over the
following two months. As many analysesas can be completed will be accepted. If your NPDES permit does not require
use of multiple concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either
single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement
initiatives effective Judy 1,1999. Follow-up multiple concentration toxicity testing will Influence the Division's
enforcement response. _
D Toxicity testing months are specified by the NPDES Permit,except for NPDES Permits which contain episodic toxicity
monitoring requirements leg,if the testing months specified in your NPDES permit are March,June,September,and
December,then toxicity testing must be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not
occur during the first six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should Immediately notify the
Environmental Sciences Branch at(919)733-2136 and provide written documentation indicating why the test was j
Invalidated and the date when follow-up testing will occur.
I
D If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete
the information block located at the top of the AT form indicating the facility name,permit number,pipe number,county
and the month/year of the subject report. You should also write"No Flow"on the AT form,sign the form and submit
following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for
facilities which have not received a facility classification. In these cases,a duly authorized facility representative must 4
sign the AT form. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider consider submitt� n
your toxicity teat results certified mail return receipt requested to the Environmental Sciences Branch.
0

permlc tccm sl nppfu.d..-NC0000299
Subject:permit renewal application-NC0000299
Date:Too,16 May 2000 14:11:47-0400
From:Charles Weaver<chaxles.weaveeQncmaiLnet>
To: arkermx@basfcom
Mr.Ackerman,the NPDES Unit received the renewal application for your
permit on April 3,2000. Thanks for submitting this package in a timely
fashion. I'm sorry that I didn't respond to your request sooner. I
(along with the other 9 members of our Unit) spent the last several
weeks working on a large project in the Neuse Rivet basin,a project
that included 2 public hearings on May 1st and May 4th. This"maximum
effort"was accomplished at the expense of all our other tasks-
uxluding the checking in of permit mnewsls.
The NPDES Unit has been working with at least 3(and as many as 5)
vacant positions since October 1998. This staff shortage is delaying
all of our permit renewals. Our remaining staff are currently reviewing
Authorizations to Construct,speculative limit requests,major permit
modificatims before working on Fount
renewals. This is necessary due to a variety of factors,including
mandatory deadlines in the statutes which govern our program.
I
If this staff shortage delays reissuance of NC0000299,the existing ,
requirements in that permit will remain in effect until the permit is co
renewed(or other action is taken by the Division). We appreciate your
patience and understanding as we operate with a severely depleted staff.
If you have any questions about your pemnt(or the permit renewal
Process in general),simply reply to this a-mail.
Sincerely,
Charles H.Weaver,Jr.
NPDES Unit
1 of 1
1
5/16/002:12 PM

BASF Corporation n BASF
r
March 27, 2000 —
i
Mr. Charles H. Weaver -� AI'fi 3
NC DENR/Water Quality/ NPDES Unit
1617 Mail Service Center - lrri olnury
Raleigh, NC 27699-1617 _rol r sn ,.,,r
uC,v
Subject: Request for Renewal of NPDES Permit NC0000299
Dear Mr. Weaver:
I am requesting renewal of our NPDES Permit# NC0000299 per your request dated
February 10, 2000.
Also, as requested, the following changes have taken place with our facility since our
last renewal in 1995:
The most significant change in the operation of our WWTP has been a major reduction
in both hydraulic and BOD load to our system since 1995. Through waste minimization
efforts, mainly in our Polymerization Plant, the flow to our WWTP has been reduced from
over 0.8 MGD to approximately 0.5 MGD. The organic load has also been reduced due
to these efforts from over 600 mg/1 BOD to around 400. This has been done while
increasing the capacity of the Polymerization Plant from 70 Million pounds per year to
approximately 110 million pounds per year.
Regarding changes in equipment or operating procedures, the WWTP is virtually
unchanged. Some change in aeration capacity has been affected by replacing rotor type
aerators with subsurface aerators.
There has also been a decline in sanitary waste during this time as the site has some
370 fewer employees.
The permit application requested the submission of Priority Pollutant Analyses, a Form A
submission was mailed to Central Files in Raleigh on March 23, 2000.
1 have authorized Ray Ackerman to prepare this application. If you have questions,
please contact Ray at [phone].
Sincerely,
J ctl k Deng
General Manager, Enka Site
UVV it
Sand hlll Roan, P.O.Box 669.Enka,North Carolina 28728-0669 [phone]

NPDEL :application Form - Standard(]rm C
Major Manufacturing or Commercial Facilities
SECTION It. BASIC DISCHARGE DESCRIPTION
Complete this section for each discharge from the facility to surface waters.
SEPARATE DESCRIPTIONS OF EACH DISCHARGE ARE REQUIRED EVEN IF SEVERAL DISCHARGES ORIGINATE IN THE SAME FACILITY
All values for an existing discharge should be representative of the twelve previous months of operation. If this is a proposed discharge,values should
reflect best engineering estimates.
t. Outfall Number 001 and Type Process and sanitary wastewater
Give the nature of the discharge(process water,non-contact cooling water,etc.)
2. Discharge To End Date: 12/31/00
If the discharge is scheduled to be discontinued within the next 5 years,give the date(or best estimate)the discharge will end
3. Discharge Receiving Stream Name: Hominy Creek
Give the name of the waterway(at the point of discharge)by which it is usually designated on published maps of the area. lithe discharge is to
an unnamed tributary,so state and give the name of the first body of water fed by that tributary which is named an the map,e.g.,UT to McIntire
Creek, where McIntire Creek is the first water way that is named on the map and is reached by the discharge.
4. Discharge Type and Occurrence
a. Check whether the discharge is continuous or intermittent. If the discharge is intermittent,describe the frequency of discharge
D Continuous Intermittent Frequency:
b. Enter the average number of days per week(during periods of discharge)this discharge occurs.
7 days per week
5. Water Treatment Additives
Complete the table below if this outfell;
• discharges cooling anclor steam water generation
• water treatment additives are used(any conditioner,inhibitor,or algicide(
• does not have whole-effluent toxicity testing required
Additive Manufacturer Quantity Chemical Composition
(pounds added per million (active ingrediti
gallons of water treated(
2 of

NPDOApplication Form - StandardIrm C
Major Manufacturing or Commercial Facilities
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
16,17 Mail Service Center, Raleigh, NC 27699-1617
SECTION 1. APPLICATION AND FACILITY DESCRIPTION
'Unlessothemisespecir,edonlhisfonnalldemsarefobeompleted Iran item is nor applicableiodabale'NA'
1. Applicant and facility producing discharge
This applies to the person,agency,fin,municipality,or any other entity that owns or is responsible for the permitted facility. This may or may not
be the same name as the facility or activity producing the discharge. Enter the name of the applicant as it is officially or legally referred to;do not
use colloquial names as a substitute for the official name.
Name BASF Corporation — Fiber Products Division
Mailing address of applicant:
Street address 1451 Sand Hill Road
City Enka County Buncombe
State NC Zip Code 28728
Telephone Number ( 828 ) 667-7277 Fax Number ( 828 ) 667-6969
e-mail address [e-mail]
2. Mailing address of applicant's Authorized Agent/ Representative:
Complete this section if an outside consulting fimd engineering firm will act on behalf of the applicant/committee
Street address
City County
State Zip Code It
Telephone Number ( ) Fax Number ( )
e-mail address
3. Facility Location:
Street address 1451 Sand Hill Road
City Enka County BuncombeI.
State NC - Zip Code 28728
Telephone Number ( 828 ) 667-7277 Fax Number ( 828 ) 667-6969
4. Nature of Business: Manufacturer of nylon 6 polymer and industrial fibers
State the nature of the business conducted at the plant or operating facility
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such
information is true,complete,and accurate.
Sack A. Dellinger General Manager
bonged Name of room assigning mle
alg tore of Arboreal or Authon Agent Date Appllcal n5igno—�
No M1 Cardlna General aWlue laJ 2166 b112 prnaides kal' Any person who knowingly makes any Wlsestatement spresenlalim,or unification In anyappli d ne record rived,pman,another
document tiles or repuimed tDEemaintamed under Anlcle21 or egulaiii d the Ereimnmerlal Management commission Implement,Nat Ankle,or who lalsihes,tampers,am or kndawngly
rmdeminaccumlemyre rdingormonllonngdeviaeormOthWmoiiredlobeoperatedormainWlnedunder ANCle2lore ulatimsollhe Emimnmental Management Commission lmplemmling
that Anid ,shall beguilly or a mademi punishable by a line nor toeneed n0i or by lmpnsmmminDl to orde¢tl sk monks,Dr by troh IIBUS.C.SttlionlWl Drovitl¢sa Wnlshm¢nl by _
a fine or more than Sudan or Imprisoamml not more than 5years,or both,fora similar offense)
1 of

NPDEr-1flppiication Form - Standard(jrm C
Major Manufacturing or Commercial Facilities
SECTION 11. BASIC DISCHARGE DESCRIPTION
Complete this section for each discharge from the facility to surface waters.
SEPARATE DESCRIPTIONS OF EACH DISCHARGE ARE REQUIRED EVEN IF SEVERAL DISCHARGES ORIGINATE IN THE SAME FACILITY.
All values for an existing discharge should be representative of the twelve previous months of operation. If this is a proposed discharge,values should
reflect best engineering estimates.
1. Outfall Number 002 and Type Non—contact cooling water
Give the nature of the discharge(process water,noncontacl cooling water,etc.)
2. Discharge To End Date: N/A
It the discharge is scheduled to be discontinued within the next 5 years,give the dale(or best estimate)the discharge will and
3. Discharge Receiving Stream Name: Hominy Creek
Give the name of the waterway(at the point of discharge)by which it is usually designated on published maps of theses II the tlischarge is to
an unnamed tributary,so state and give the name of the first body of water fed by that tributary which is named on the map,e.g.,UT to McIntire
Creek, where McIntire Creek is the first water way that is named on the map and is reached by the discharge.
4. Discharge Type and Occurrence
a. Check whether the discharge is continuous or intermittent. If the discharge is intennibenl,describe the frequency of discharge
® Continuous 0 Intermittent Frequency:
b. Enter the average number of days per week(during pandas of discharge)this discharge occurs.
days per week
5. Water Treatment Additives
Complete the table below it this outtall
• discharges cooling and/or steam water generation
• watertreatmem additives amused Jerry conditioner,inhibitor,or algicide)
O does not have whole-effluent toxicity testing required
EEMI
Chemical Composition
er million (active ingredienl(s))
treated)
204

NPDE)Application Form - Standard'-'�rm C
Major Manufacturing or Commercial Facilities
OUTFALL NUMBER 001
6. Wastewater Characteristics
Check the box beside each constituent present in the effluent(discharge water),
This determination is to be based on actual analytical data or best estimate(for proposed discharges).
Parameter Present Parameter
Present
Color 00080 Copper 01042
Ammonia 00610 Iron 01045
Organic nitrogen 00605 l� Lead 01051
Nitrate 00620 Magnesium 00g27
Nitrite 00615 Manganese 01055
Phosphorus 00665 ✓ Mercury 71900
Sulfate 00945 Molybdenum 01062
Sulfide 00745 Nickel 01067
Sulfite 00740 Selenium 01147
Bromide 71870 Silver 01077
Chloride 00940 ✓ Potassium 00937
Cyanide 00720 Sodium 00929
Fluoride 00951 V Thallium 01059
Aluminum 01105 Tftanmm 01152
Antimony 01097 Tinacompounds*
Arsenic 01002 Zinc
Beryllium 01012 Algicides'
Barium 01007 Chlorinated orga52Boron 01022 Pesticides'
Cadmium 01027 Oil and grease 00550
Calcium 00916 Phenols 32730
Cobalt 01037 Surfactants 38260
Chromium 01034 Chloride 50060
Fecal coliform 74055 Radioactivity 74050
3of4

NPDEApplication Form — Standard -Irm C
Major Manufacturing or Commercial Facilities
7. Supplemental Documentation
Submit the following information appended at the end of this application form. All sheets should be approximately letter size with
margins suitable for filing and binding. All pages should include facility location and permit number(if available).
❑ Present Operating Status: Provide a narrative description of installed wastewater treatment components
at the facility. Include sizes&capacities for each component.
❑ Potential Facility Changes: Provide a narrative description of any planned upgrades/expansions/
repairs planned for the facility during the next five years. Do not include tasks associated with routine
operation &maintenance.
❑ Schematic of wastewater flow: Provide a line drawing of water flow through the facility. The schematic
should show flow volumes at all points in the treatment process. Specific treatment components should
be identified.
❑ Location map: Submit a map showing the location of each outfall. The usual meridian arrow showing
north as well as the map scale must be shown. On all maps of rivers,the direction of the current is to be
indicted by an arrow. All outfalls should be identified with the outfall numbers) used in Section II of this
application. A copy of the relevant portion of a USGS topographic map is preferred.
❑ Production Data: Submit the last 3 years' production data for the facility. Where applicable, use units
specified in the appropriate subpart of 40 CFR.
❑ Priority Pollutant Analysis: Industrial facilities classified as Primary Industries (see Appendix A to Title 40
of the Code of Federal Regulations, Part 122) must submit a Priority Pollutant Analysis (PPA) in
accordance with 40 CFR Part 122.21. If the PPA is not completed within one week of the due date for
the permit application, submit the application package without the PPA. Submit the PPA as soon as
possible after it is completed.
I
4 0l4

NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
Sludge Management Plan
The Enka Site Waste Water Treatment Plant is an activated sludge process designed to
handle 1.25 million gallons per day of industrial and domestic waste water. The plant now
operates at a nominal 0.5 millions gallons per day during the peak summer months.
Due to the large capacity of the aeration tank (2.0 million gallons) the plant operates in
the extended aeration mode with a sludge age of 30+ day.
Sludge is wasted continuously from the two 40 foot clarifiers operated in parallel. The
sludge is pumped to a 20,000 gallon thickner at approximately 20-40 gpm where it is
settled and pumped to a 0.5 million gallon aerobic digester with a detention time of
approximately 50 days.
The digested sludge is coagulated with polymer and pumped to a plate and frame filter
press where it is dewatered using diatomaceous earth as a precoat.
The resulting sludge cake is applied to the Enka Site Landfill as a soil conditioner for the
final cover for slope closures,
Approximately 2,600 Ibs of sludge are disposed of daily to the landfill.
A/e�Lu-1iu..—
R. L. Ackerman
Environmental Manager

NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
Present Operating Status
The Enka Site Waste Water Treatment Plant is an activated sludge process designed to
handle 1.25 million gallons per day of industrial and domestic waste water. The plant now
operates at a nominal 0.5 millions gallons per day during the peak summer months.
Due to the large capacity of the aeration tank (2.0 million gallons) the plant operates in
the extended aeration mode with a sludge age of 30+ day.
The plant is comprises of the following components listed in order from influent to effluent:
Waste water components:
Equalization Basin No. 1 — 1.75 MG clay-lined mixing basin.
Equalization Basin No. 2—0.5 MG metal tank for adding nutrients and pH control.
Aeration Basin - 2.0 MG concrete basin with 350 Hp of aeration capacity.
Clarifiers—two each 40 ft. diameter, 90,000 gallons capacity
Chlorine contact chamber— baffled 20' X 40' concrete basin
Sludge Handling Equipment:
Sludge thickner—20,000 gallon tank
Aerobic digester—0.5 MG steel tank with concrete bottom and
Plate and Frame filter press for de-watering sludge —2 each with 13 cubic ft capacity

NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
Potential Facility Changes
Plan are currently being formulated to close the Enka Site Waste Water Treatment Plant
and discharge our waste water to Metropolitan Sewerage District of Buncombe County
North Carolina. The target date for closure of the W WTP is December 31, 2000.

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NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
Production Data for Past Three Years
1997 1998 1999
(In 1,OOO pounds)
Polycaprolactam (Nylon Chip) 81,268 76,912 76,757
Conductive Fibers 550 550 528
Basofil® (Fire retardant fiber) 242 330 638

BASF-Enka Facility;NC0000299
� 1
From Tlrtn 90%ick <tO3116KOk@h6nW net'3-
SPb.,� btJ;$7 P7=Elk aFa01ifyNO@@299 , .,s,`':". , .a`,�kh"F'i* _. t °'it . x.'!it"t'..•. Mwr
To: Max Haner<[e-mail]>
Hello Max- I talked with Dave Goodrich and he wants to keep this permit
moving, given pressures from EPA about backlog. I proposed to draft the
permit with no substantive changes, and give a permit expiration date of
May 31, 2002 . This should cover them through the anticipated WWTP
closure by end of 2001, with some leeway in case construction problems
arise. I ran this by Ray Ackerman and he's o.k. with it. I told him we
could modify the permit to delete Outfall 002 requirements once they
secure General Permit coverage. Do you see any problems with this?
Mailto:tom.belnickuncmail.net
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: (919) 733-5083 ext. 543
Fax: (919) 733-0719
1 ON 3/12/2001 4:50 PM

.15'2000 14:99 82B 667 7778 SITE AOMIN 00299 P.001/003
BASF Corporation � r)
Facsimile Cover Sheet
To: Max Haner From: Ray Ackerman
BASF Corporation
Sand HIII Road
Enka, NC 28728
Fax: [phone] Phone;
Phone: Fax:
Date: 9/15/00
Pages: 3
Subject; Letter Sent to Enka Village Residents
cc:
Comments:
For your information.
Ray
Firf

.15'2000 14:99 928 667 7778 SITE ADMIN 40299 P.002/003
BASF Corporation �B�M
September 15, 2000
To residents and property owners of the Enka Village and businesses:
This letter is being sent to you on behalf of BASF Corporation to explain
anticipated changes that will affect sewage treatment services for residents and
other users in the Enka Village. BASF Is in the process of evaluating alternatives
to on-site treatment of its own wastewater. These alternatives will mean a
Change for all users of the current system.
By way of background, American Enka Corporation began treating Enka Village
sewage in 1966, In that year, American Enka Corporation agreed with Enka
Park Commission (then representing the Village residents and properly owners),
to allow sewage from the residences and other buildings in Enka Village to be
treated through American Enka's plant wastewater treatment system. BASF
Corporation became owner of the Enka site in 1966 and has continued the free
sewage treatment service for the past 14 years.
The treatment of the Enka Village sewage had been intended as a temporary,
Interim measure. As part, of the 1966 agreement between American Enka
Corporation and Enka Park Commission, the parties agreed that six (6) months'
prior written notice to tite Commission would be given before discontinuing
service. Upon the giving of that notice, service could he discontinued on March
15th in any calendar year after 1967,
In addition to this letter, a public notice terminating the 1966 agreement is being
published in the September 1 sth issue of the Asheville Citizen-Times newspaper.
According to the 1066 Agreement, the notice was to be given to the Commission.
However, to try to reach all affected persons In the Village, the newspaper public
notice is also addressed to residents and property owners.
The Commission and the residents and property owners in Enka Village will need
to have an alternate service in piece no earlier than March 15, 2001 because
service may be discontinued on that date.
BASF will cooperate with the Commission and the residents and property owners
to facilitate a smooth transition. BASF has met with the local Metropolitan Sewer
District (MS©) to discuss the situation. The plan is to work with MSp and the
residents and building owners to develop and implement an alternative for
sewage treatment for the Village. If the transition time extends beyond March 15,
2001, BASF is willing to consider changing the actual date for service
discontinuation to a reasonable time beyond March 15, 2001,
vwk U 1144
p ew ,(e ms 4L
S4md 1W F.ed, P.p.a-x 659,Enka,Np,th 01-11ha 28729.0a59 (8291 6 6 7-1119

.15'2000 14:99' 020 667 777E SITE ADMIN #0299 P.003/003
September 15, 2000
Page 2
Plans are very preliminary at this paint and are being developed with MSD.
BASF has discussed with MSD scheduling a series of public meetings M provide
detailed information about:the planned transition to connect to the MSD system.
Also, community leaders are being contacted to develop a resource network to
be involved in the planning and to provide Information to the residents.
It is anticipated that before the end of October 2000, additional information will be
available about the public meetings and a plan of action for the transition.
No additional information is available at this time. Therefore, please do not cal
BASF directly upon receipt of this letter. No one at the BASF Enka location will
be able to give you more Information than is contained in this letter. As plans
develop, BASF and MSD will convey the information to the Village residents and
building owners through the resource network being formed.
BASF is committed to working with the residents and building owners of Enka
Village, Its community leaders and the MSD to make this transition a smooth one.
Sincerely,
BASF Corporation

Cooling Water Discharge
January 12,2001
Proposal:
Our proposal is to remove the cooling water discharges from the plant wastewater
treatment system and permit them under a General Permit allowing them to be discharged
directly to Hominy Creek. This would require separate permits for BASF and Colbond.
Present Situation
Reference: Attachment A-- Sketch of cooling water discharge.
The existing non-contact cooling water process streams now combine with the
site's sanitary streams. This flow then is processed through our wastewater treatment
plant before being discharged to Hominy Creek. Some streams (#2 and#10 on
Attachment A) are part of the Plant's current NPDES permitted outfall 002 which
discharges via our east ditch to Hominy Creek,
Proposed Conditions:
Plans are being made to curtail the operation of the plant's wastewater treatment
facility and discharge wastewater to MSD. With this change, modifications to the input
streams are being completed. These modifications include the following: separation of
discharges from the Enka Village and the A-B Tech properties from BASF waste streams,
and the discharging of the sanitary sewers and process waste streams to MSD. MSD has
requested that we not discharge our cooling water steams to their facility.
To make this change, the plant's systems will have to be modified. We will use the
monitoring point of our existing permitted 002 outfall and add several additional
monitoring points. These additional monitoring points are necessary because of the
distance between locations. The monitoring points are designated by letters A through E
on Attachment A. We would request that the flow for the combined streams#1, #2, and
93 be determined by subtracting the flow of point A from that of point B.
Colbond would have one primary point designated as letter A and BASF would have
points B through E. The weir for the discharge point C will be new construction.
f

I� IIN
Biocide additions are made to streams designated as 1, 4, 5, 6 for BASF and 11 and 12 for
Colbond.
Biocides utilized:
Points 1 and 4 use Drew Chemical No 2155 cooling water treatment.
Point 5 uses Nalco StaBrEX
Point 6 uses Nalco 7346 TAB
Point 11 and 12 use Garratt-Callahan No 312 and No 315 with 2002 Rust Inhibitor
The water source for the process activity is from the site's process water system with the
exception of streams no 10(raw water) and no 11 (city water).

COOLING WATER DISCHARGE
ATTACHMENT A
COLBOND I BASF
50,000
EXTRUDER 10,000 GPD O I O GPD REFCOOLINGION '.BIOCIDE
COOLING I TOWERS
M-3 DRYER 7,500 GPD O I r
COOLING I
CB DRYER 12�000 GPD O I SO,P(p 0 POLYMERIZATION
COOLING I ® COLUMN
CONDENSERS
RAW WATER PET DRYER 95,000 GPD 10 I r COOLING
COOLING
C1 TY WATER
AIR COMP 5,000 GPD � �
BIOCIDE-- COOLING
HVAC 5,000 GPD 12 I O S�OPODO EST
XAN TA
TRUDER
BIOCIDE-- CH
SYSTEM I 8 IP D
I r COOLINGRYER
I
r I
500
BIOCIDE POLYMERIZATION T6PD O
COOLING TOWER
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BIOCIDE
+
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CREEK
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SPRAY POND
O 0 r"-BIOCIDE
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POWERHOUSE
COOLING TOWER
�.rA WEST STORM SEWER
ac
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Re:Sale of Conductive Fibers Unit
it4;oph, ax .'0' axu'fIn6'�"Qn©)nail:net> , c 'x m,
,,.
�'i7Y,.ttbirod
M�u
To: Raymond L Ackerman<[e-mail]>
CC: Tom Belnick<[e-mail]>, Forrest Westall<[e-mail]>,
Max Harter<[e-mail]>
Reply
Ray - Thanks for the report of HASPS sale of its Conductive Fiber Unit to
Shakespeare Corporation. This notice constitutes compliance with Reporting
Requirements contained in Part II Section E of the permit even though there doesn't.
appear to be any change in the waste characteristics or volume. I understand that
BASF will continue to accept and treat the wastewater from this process as part of a
service contract. I am placing a hard copy of this notice in your file for
reference and am forwarding this e-mail to Tom Belnick of our NPDES Permits Unit so
that this information can be added to your renewal application. Please advise if
there are additional changes. Max
> Raymond L Ackerman
> 01/23/2001 08:59 AM
> To: max.haner
> cc:
> Subject: Sale of Conductive Fibers Unit
> Max,
On January 9, 2001 BASF sold the Conductive Fiber Unit at Enka to Shakespeare
> Corporation. The sales will not impact the operation our WWTP nor does it make
> any change pursuit to the requirements our NPDES Permit. We will continue to
> treat the 5 to 8 gallons per day of waste water that comes from this unit under
> our service agreement with Shakespeare.
> If you have any questions or concerns, I can be reached at 669-9299 or by e-mail
> at [e-mail]
>
> Regards,
> Ray
Max Saner - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office -
Division of water Quality - Water Quality Section
59 Wcodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Max Haner<M m_ Hurernncmall.net>
NC DENR-Asheville Regional Office
Division of Water QualrtyyWater Quality Section
1 of2 1/29/2001 2:21 PM

SAS,.F r oration
G �
3 �
January 18, 2001 D �4• `16"2'' '
!1 JAN 22 2001
Mr. James W. Meyer DkJV°Q
Laboratory Section LABORATORY SECTION
NC DENR
1623 Mail Service Center
Raleigh,NC 27699 -1623
Re: DMRQA20
Dear Mr. Meyer,
We received two "Not Acceptable" ratings on the referenced DMRQA study for our lab
(USEPA Lab Code# NC00030). However, since we have closed our lab effective
December 31, 2000, 1 am assuming no further action is required by me. My guess is that
closing the lab would constitute the ultimate "corrective action"to a deficient laboratory.
I have enclosed a copy of my letter dated December 26.2000 informing you of our lab
closure.
If further action is required by me, I can be reached at [phone] or by e-mail of
[e-mail].
Sincerely, -
RAckerman
Lab Manager
Sand Hill Road,P.O.Box 689,Enka,North Carolina 28728-0669 [phone]

.dte of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
® ate►
James B. Jr.,Governor ��
Bill Holman,an, Secretary
Kerr T. Stevens,Director NCIDNDRm CAROLINh oEwarMENr of
Division of Water Quality ENVIRONMENT wdD MwuR.0 RESOURCES
WATER QUALITY SECTION
October 26,2000
Ms. Lynn Davis
Asheville Savings Bank
it Church Street
Asheville, N.C. 28801
Subject : Sewer Service For
39 Orchard Street
Enka Village
Buncombe County
Dear Ms. Davis :
This letter will confirm that the wastewater treatment facility serving the.BASF Corporation in
Enka,N.C., is operating under current NPDES Permit Number NC0000299. This five year permit was
last issued by this Division on October 23, 1995, with an effective date of December 1, 1995. Renewal of
this permit currently is being processed.
Based on information available to this office,property located at 39 Orchard Street is being served
by this treatment facility. Records indicate that the facility currently is in compliance with regulations
administered by this Division.
Thank you for the opportunity to comment in this matter. Should you wish to discuss the Bent
Creek wastewater treatment facility in more detail,please advise.
Yours
M L.H'n 4W
Environmental Chemist
59 Woodfin Place,Asheville North Carolina 28801 Telephone [phone] FAX [phone].
An Equal Opportunity AtSrmafive Action Employer 50%recycled1101l,post-consumer paper

N. C. DEPARTMENT ENVIRONMENT AND
6 STATE NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTION
^HEVILLE REGIONAL OFFICE
59 WOODFIN PLACE
WORTH CAROLINA 28801
PHONE: 828/ '251- 6452
FAX #
FROM: (/ yy
DATE: ,7 c;; �/�
�
# OF PAGES INCLUDING THIS COVER:
MESSAGE: If questions, please call 828/251-6..

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OCPSF Categorical SN
Subject: OCPSF Categorical SIU ���•�
Date: Mon, 24 Jul 2000 14:11:41 -0400
From: Keyes McGee<[e-mail]> -
Organization: NC DENRDWQ
To: Max Haner<[e-mail]>
CC: Monty Payne<[e-mail]>
Max,
Thanks for your question concerning BASF Company as an OCPSF Categorical Significant Industrial
User. Dana Folley and Steve Amigone assisted me in interpreting 40 CFR 403.6.
The issue in 40 CFR 403.6 (e) (i) &(ii)(c)referring to NRDC v. Costle paragraph 8, concerns Fri(Dilution
Flow). FD is either(a), (b), or(c) in this statement. This section is about a combined wastestream, formed
from the combination of categorical Fi(influent flow) and non-categorical FD .
OCPSF Categorical SIUs shall meet the following: "Samples shall be collected and analyzed by the
POTW Staff independent of the industry for each Significant Industrial User:", "for organic compounds
limited in the Significant Industrial User Permits, a minimum of once each year." (reference 15A NCAC
2H .0908 (d) (2)).
Please call the Pretreatment Unit if you have further questions.
Keyes McGee
Environmental Engineer Trainee
Department of Environment and Natural Resources
Division of Water Quality
Pretreatment Unit
Telephone: [phone], Extension: 580
Facsimile: [phone]
1 of I 7/25/2000 332 PM

Re:Sale of Conductive Fibers UNt
l 1 ��
From: Maz Harter<Max [e-mail]> w"' oli'2t041 PM
$object:Rei Sale of Conductive K1 pp Umt
To: Raymond L Ackerman<[e-mail]>
CC: Tom Belniek <[e-mail]>, Forrest Westall <[e-mail]>,
Max Haner<[e-mail]>
Reply
Ray - Thanks for the report of BASF's sale of its Conductive Fiber Unit to
Shakespeare Corporation. This notice constitutes compliance with Reporting
Requirements contained in Part II Section E of the permit even though there doesn't
appear to be any change in the waste characteristics or volume. I understand that
BASF will continue to accept and treat the wastewater from this process as part of a
service contract. I am placing a hard copy of this notice in your file for
reference and am forwarding this e-mail to Tom Belnick of our NPDES Permits Unit so
that this information can be added to your renewal application. Please advise if
there are additional changes. Max
> Raymond L Ackerman
> 0112312001 08:57 AM
> To: max.haner
> cc:
> Subject: Sale of Conductive Fibers Unit
> Max,
>
On January 9, 2001 BASF sold the Conductive Fiber Unit at Enka to Shakespeare
> Corporation. The sales will not impact the operation our WWTP nor does it make
> any change pursuit to the requirements our NPDES Permit. We will continue to
> treat the 5 to 8 gallons per day of waste water that comes from this unit under
> our service agreement with Shakespeare.
> if you have any questions or concerns, I can be reached at 667-7277 or by e-mail
> at [e-mail]
>
> Regards,
> Ray
Max Harter - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
FNC
ax Harter<Max Haner(c�nemad.net>
DENR-Asheville Regvision of Water Quality-Water Quality Section
I oft 1/31/2001 8:23 AM

wQBASF
BASF Corporation
December26, 2000 I,:( (ogn �; \7
!llSSSSSS DEC 28 20CD
Mr. James W. Meyer DVVQ
Laboratory Section LABORATORY SECTION
DENR 16
1623 Mail Service Center
Raleigh, NC 27699 -1623
Dear Mr. Meyer,
This letter is to confirm our telephone conversation of November 23, 2000 concerning
our certified Pollution Abatement Laboratory, As I stated to you then, our Laboratory,
USEPA Lab Code#NC0003O, will be shut down permanently on December 31"of this
year and all of our permit required testing will be done by Pace Analytical, Inc of
Asheville.
If you have any question concerning this action, I can be reached at [phone] or
by e-mail at [e-mail].
Sincerely,
- R Ackerman
Lab Manager
e>
r
Sand HIII Road,PA.Box 669,Enka,North Carolina 28728-0669 [phone]

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corporation ( 1 BASF
July 27, 2000
Mr. Max Harter § b
Water
f J (
Natural Resources NC Department of
59 Woodfin Place .-A
Asheville, NC 28801
Dear Mr. Haner:
On July 25, 2000 we experienced an unanticipated bypass to our waste
treatment plant. Following are the details of the event and the planned activities
to prevent a recurrence:
On July 24th at 19:34, there was an interruption of power to the pumps at the #3
lift station that handles waste from our polymerization area and sanitary waste
from several restrooms on the east side of the plant. The cause of the outage
was a short in an underground electrical line encased in conduit. This power loss
caused the #3 lift station to overflow into the east ditch and go directly into
Hominy Creek. Given that it would take about four hours for the lift station sump
and adjoining distribution system to fill up before overflowing, we estimate that
the lift station began overflowing at around 11:30 p.m. on the 24th and continued
until 08:30 a.m. on the 25th, when repairs were made and the pump was
restarted. Pumper trucks were called in immediately to pump out the lift station in
order to diagnose the problem.
The nominal flow rate on that lift station is approximately 55 gallons per minute.
This would give a total loss to the east ditch of about 29,000 gallons of waste
water. The BOD load contained in this overflow is estimated to be around 1200
pounds. This estimate is based upon the loss of TOC in our plant influent as
compared to the average incoming concentration of TOC and our correlation of
TOC to BOD.
There has been a temporary line installed to supply power and maintenance is
preparing a project to replace the underground line with a new above ground line.
This is the only recorded incident of this kind ever occurring with any of our lift
stations; however, to prevent a recurrence the lift station is being supplied with
primary power from CP&L and backup power from our powerhouse.
Sand HIII Road,P.O.Box 869, Enka,North Carolina 28728-0669 [phone]

1 � l,
Also to allow for earlier detection, an alarm system is being installed that will
send a signal to a control room that is manned 24 hours a day, 7 days a week
should there ever be another pump failure.
In compliance with House Bill 1160 and the Clean Water Act of 1999, BASF
issued a press release to the print and electronic media in Buncombe County on
July 27, 2000. A "Notice of Discharge of Untreated Sewage' will be submitted to
the Asheville Citizen Times during the week of July 31" in order to make the ten-
day deadline.
A "Sewage Spill Response Evaluation" is attached.
I can be reached at 667-7277 if you require additional information.
Sincerely,
6y`Ac�k'erman
Environmental Manager
BASF Enka Site

Smafte Spill Response Evaluation:
s (papa 1 of 2)
Pennktee AARF enrp..xarrnn Permit Number N .nr 0DZ9.2 Count' R,mrnmho
Incident Ended: (Date/Time L7 25/00 / 08:30 Eatrrlated Duredon(Time) 9 hours
First knowledge of incident! (011oon s") 7/25/00 1 07:30
Estimated volume of spill/bypees 29,700 pl orhs. Show rational for volume.
55 gals./min. x 9 hrs. x 60 min./hr. = 29,700 gals.
if spill Is angoing p/aete notiy/Nploml afte on a dolly basic until spill can be stopped.
Reported to: Max Raney (DstaNme) 7/25/00 / 16:00
Name of parson .
Weather conditions: Heavy rain
Source of spillibypass(check one):_SanRary Sawar X Pump Station W WPP
Level of treatment(check one): x None _Primary Treatment
�S000ndory,Tlaximaint, Chlorination Only
Did spik/bypass reach surface Wotan?__L_Yos _No(If Yes, please list Met'following)
Volume reaching surface waters? 29.700 gallons l
Name of surface water Hominy Creek I JUL 3 1 )['('9 ����I
wl ;
Did spiiUbypass result in a fish kllY/T,Ya _X_NO a
If Yes,what is the estimated number of fish kill 1 4V41VII 120AI l'I 6 IUY
III
Please provide the followingimbnrtadw:
1. Location ofspill/bypass: No. 3 lift station at (lead end of east ditch
2. Cause of spillbypase: Power line to pump shorted out
3. Did you have personnel"llobla to porbrmfiilYl onsomment 24 hours/day(Including weekends and
holidays)?
Yes_.Z_ No_
a. How long did R take to make on initial a okwornont of the spi Nonni or sttar first kttaale igs?
't Hours 30 Minutes
How long did R take to get a repok lines,onlift
0 Hours 0 Mklutas - on site
Please explain the tme token to malt inNW aosmmrmt Pumyer trucks er summoned
Immediately and arrived at 08:30. It took until 11:00 to evaw ecuate lift
tar' hefo was determined.
Revision Ml a/11/99

Sewage Spill Response Evaluation:
(Pees 3 of z)
Permiltee BASF Corporation permit Number NC0000299 County Buncombe
5. Action taken to contain.spill, dean up Waeta, anNOr rarrladoft the ahs: lift sl;ation sita
on bank of east ditch. The waste water flowed immediately into this
ditch which was heavily laden with rain water (2" overnight) . Due to
large volume of water, no attempt was made to pump to the waste Nater
treatment plant from the east ditch.
6. Were the equipment and parts needed to make repairs Iesilly"Noble?
Yes x No„ It no, plans explain why:
7. If the spill/overflow occurred at a pump station,or was the result of a pump station failure,
was the alarm system functional at the time of ft spill? Yes_ No 2 if the alarm
system did not function, please explain Why: • The high level alarms did not
function due to the power outage.
S. Repairs made are: Permanent Temporary X
Please describe what repairs were made. If the repairs are temporary, please indicate a date by
which permanent repairs will be completed,and notiry the Regional Office within 7 days of the
permanent repair. Temporary wire in place; permanent wire to be installed
creek of duly 31.
9.What actions have been made to prevent this discharge from occi rring again in the future?
New power cableto replace old wires. An alarm to be installed to
indicate loss of power to pump in control room.
10. Comments: This is the firsts failure of this type at BASF. There wati
bai;ktn power to the b tati n which Supplied the but not at Pump
itself. We reiaret this incident occurred but feel that it was
unavoidable. _
Other agencies noafed: None
Person repbrtl epilbby s: Ray Ackerman photo Number(828) 667-7277
Signature c Oate: 7
For OM Use Only
DWO requested additional written mpert7 Yea No
If yes,what additional Infomladon is needad7
Requested by
Revision 01 6l11/99

State of North Carolina V
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place Asheville,North Carolina 28801
October 19,2000
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Ackerman
BASF Corporation Enka
1451 Sand Hill Road
Enka,North Carolina 28728
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No.NC0000299
BASF Corporation WWTP
Buncombe County
Dear Mr.Ackerman:
This is to inform you that a review of your toxicity self-monitoring report form for the month of August
2000 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent
toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (TRE) which is a
site-specific study designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity,
evaluate the effectiveness of toxicity control options, and then confirm reductions in effluent toxicity. Please be
aware that North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES
permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note updated mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this
information and if it would be helpful to discuss this situation or possible solutions to resolve effluent toxicity
noncompliance,please contact Mr. Keith Haynes with this office at(828)251-6208.
Sincerely,
Fortal�
Regional Water Quality Supervisor
cc: Keith Haynes-Asheville Regional Office
Aquatic Toxicology Unit
Central Files

_9:99 828 667 7778` .� SITE ANMIN j.� #0299 P.001/003
.3F Corporation
BASF
Facsimile Cover Sheet
To: Max Honer From: Roy Ackerman
BASF Corporation
Sand HIII Road
Prika, NC 28728
Fax: [phone] Phone:
Phone: Fax:
Date: 9l16/00
Pages: $
Subject; Letter Sent to Fnka Village Residents
cc:
CPI) Merl'tS:
For your information.
Ray
D
n>i�;4wu(�iici s

/ \
.4:49 828 667 7778 1 SITE ADMIN� �T #0299 P.002/003
Corporation )BMF
September 15, 2000
To residents and property owners of the Enka Village and businesses:
This letter is being sent to you on behalf of BASF Corporation to explain
anticipated changes that will affect sewage treatment services for residents and
other users in the Enka Village. BASF is in the process of evaluating alternative$
to on-site treatment of its own wastewater. These alternatives will mean a
change for all users of the current system,
By way of background, American Enka Corporation began treating Enka Village
sewage in 1966. In that year, American Enka Corporation agreed with Enka
Park Commission (then representing the Village residents and properly owners),
to allow sewage from the residences and other buildings in Enka Village to he
treated through American Enka's plant wastewater treatment system. BASF
Corporation became owner of the Enka site In 1986 and has continued the free
sewage treatment service for the past 14 years.
The treatment of the Enka Village sewage had been intended as a temporary,
interim measure. As part. of the 1066 agreement between American Enka
Corporation and Enka Park Commission, the parties agreed that six (8) months'
prior written notice to the Commission would be given before discontinuing
service. Upon the giving of that notice, service could be discontinued on March
16th in any calendar year after 1967.
In addition to this letter, a public notice terminating the 1966 agreement: is being
published in the September 15th Issue of the Asheville Citlaen4imes newspaper.
According to the 1966 Agreement, the notice was to be given to the Commission.
However, to try to reach ail affected persons in the Village, the newspaper public
notice is also addressed to residents and property owners.
The Commission and the residents and property owners in Enka Village will need
to have an alternate service in place no earlier than March 15, 2001 because
service may be discontinued on that date.
BASF will cooperate with the Commission and the residents and property owners
to facilitate a smooth transition. BASF has met with the local Metropolitan Sewer
District (MSD) to discuss the situation. The plan is to work with MSD and the
residents and building owners to develop and implement an alternative for
sewage treatment for the Village. If the transition time extends beyond March 16,
2001. BASF Is willing to consider changing the actual date for service
discontinuation to a reasonable time beyond March 15, 2001,
SV W�qQ1 eopd,P.O.ace 659.Enka,Norlh 0...Ma 28728-%aq (828)e87-711 D

a4:44 828 667 777C 1 SITE ADMIN #0299 P.003/003
September 15, 2000
Page 2
Plans are very preliminary at this point and are being developed with MSD.
BASF has discussed with MSD scheduling a series of public meetings to provide
detailed information spout the planned transition to connect to the MSD system.
Also, community leaders are being contacted to develop a resource network to
be Involved in the planning and to provide Information to the residents.
It is anticipated that before the end of October 2000, additional information will be
available about the public meetings and a plan of action for the transition.
No additional information is available at this time. Therefore, please do not call
BASF directly upon receipt of tills letter. No one at the BASF Enka location will
be able to give you more information than Is contained in this letter. As plans
develop, BASF and MSD will convey the information to the Village residents end
building owners through the resource network being formed.
BASF is committed to working with the residents and building owners of Enka
Village, Its community leaders and the MSD to make this transition a smooth one.
Sincerely,
BASF Corporation

NORTH' )AROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
, ASHEVILLE REGIONAL OFFICE
��..: WATER QUALITY SECTION
ur
June 9, - 2000-
3AMESS H NTJ x.
g'GQV�9NOR Mr. R. L. Ackerman, Environmental Manager
BASF Corporation
'?' Sand Hill Road
�Q::S Enka, North Carolina 28728
FDEVI
1 _. Subject: Compliance. Biomonitoring Inspection
��. BASF - Enka Plant WWTP
NPDES Permit Number NC0000299
Buncombe County
' t-'Dear Mr. Mr. Ackerman:
q' Please find enclosed a copy of the Compliance
w Inspection Report for the Biomonitoring Inspection which I
conducted at the subject facility on May 16, and 19, 2000.
The test result and measured water quality parameters
for these samples indicate that the effluent would not be
Q predicted to have water quality impacts on the receiving
stream. As noted in the attached Report, the test result
was recorded as a "Pass" .
.k If you have any questions concerning the Report, or if
., you require any assistance, please do not hesitate to
:r contact me at 251-6208 .
Sincerely,/ , +
D. Keith Hayn
Environmental Specialist
Wlr:.g Attachment
xc: Jimmie Overton
Max Haner
n .
I NTePDXAN"E BVILOINO, 5s WOOOPIN PLAC., ABIIEVILLE, NO aeeo l-zala
HONER28-251-8208 FAX [phone]
"' AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - E.% RECYOLEe/10% ✓OST.....M Ea PAPER

United States Eovii. sdal Protection Agency Form Approved
Washington, D.C.20460 OMB No. 2040.0003
EPA NPDES Compliance Inspection Report Approval Expires 7-31-85
Section A:National Data System Coding -
Transanion Code NPDES, yonne/dey Inspection Type Im,poor Far Type
I HIV 1- _ 2 [5 1 3 NC0000299 Ill 12 00/05/16 17 IS 19 20�2
Remarks u u u
Reserved Facility Evaluation Rating el QA Reserved °
67 I I I69 70 141 71 [I ] 72 nl L 73 � L
74 75 I I I ] I 180
I I Section B:Facility Data
��u
Jame and Location of Facility Inspeaod Entry Time Permit Effective Date
IASF CORPORATION 9:50 am 95/12/01
JS HWY 19123 & NC HWY 112 (SAND HILL RD) Exit Time/Date Permit Expiation Date
INKA, NC (BUNCOMBE COUNTY) 11:00 am 00/09/30 ,
James)of Ou-Site Representative(sVfi lee) Phone Nob)
IAY C. ACKERMAN, ORC & MGR OF ENVIRONMENTAL SAFETY & QUALITY [phone]
;AY CROWDER/DON CANIPE .
Jame,Address of Responsible Official Title
)R.JACK A DELLINGER GENERAL MANAGER
IASF CORPORATION
NKA, N.C. 28728 Phone No. Contacted
(828) 667- 7110 No
selon C:Areas Evaluated During Inspection CODES w S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluatedlNot applicable
N Permit N Flow Measurement N Pretreatment N Operations &Maintenance
N Rec-:ds/Repods N Laboratory N Compliance Schedules N Sludge Disposal
N Facility Site Review N ] Effluent'Remiving Waters N Self-Monitoring Program $ Other.AQUATIC TOX
Section D:Summary of Findings/Comments (Attach additional sheets if necessary)
In May 17,2000,Division Aquatic Toxicology personnel Initiated a 3-Brood Cenodephnfe dubla passifail toxicity test on the effluent from the subject W WTP.
he samples were collected on May 16 and 1&19,2000 by Asheville Regional Office staff.
he result of the test indicated that the subject discharge met criteria set forth in established standards. Al the madman waste concentration of(IWC=8.0%),
radiated by the low stream flow 7010 of 23.0 eta and the permitted discharge volume of 1.25 mgd,91.7%survival occurred in the test population with an
verage of 22.6 neonates per lest organism.The control population exhibited 100%survival with an average of 24.0 neonates per control organism. Thus,the
ud was recorded as a°Pass". Other measured water quality parameter results were:first sample,pH=6.06 SU,conduativdy=1130 micromhoslcm,TRC=<0.1
1g/I;second sample pH=8.00 SU,conductivity=1060 micromhos/cm,TRC=<0.1 mg/I.
j
lames)and SignaNrels) speao(s) Agency/Office/Telephone Date
1.Keith Haynes
DWQ/ARO 828-251-6208
ignature of eviewer Agency/Office Data C/
DWQ/ARO 828-251-6208 G aD
Regulatory Office Use Only
,ction Taken Date Compliance Status
bao- Noncompliance
Compliance

NORTH�...AROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
June 9, 2000- _
]AM IE.B.H.NTJB.,
ISW@END. Mr. R. L. Ackerman, Environmental Manager
xy`�? BASF Corporation
}?` Sand Hill Road
4.'?µq Enka, North Carolina 28728
• poEn
r
" Subject: Compliance Biomonitoring Inspection
BASF - Enka Plant WWTP
NPDES Permit Number NC0000299
Buncombe County
Dear Mr. Mr. Ackerman:
i
Please find enclosed a copy of the Compliance
Inspection Report for the Biomonitoring Inspection which I
. I.a .
conducted at the subject facility on May 16, and 19, 2000 .
The test result and measured water quality parameters
for these samples indicate that the effluent would not be
predicted to have water quality impacts on the receiving
stream. As noted in the attached Report, the test result
was recorded as a "Pass" .
If you have any questions concerning the Report, or if
you require any assistance, please do not hesitate to
contact me at 251-6208 .
Sincerely, ..,,
D. Keith Hayn rr"
Environmental Specialist
Attachment
xc: Jimmie Overtodi
Max Haner
P \
INTpRmnNGE BUILDING, 58 WOOOFIN PLACE, AGNeVILLE, NC 28801-2414
PHONE [phone] FAX B2B-261-6963
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYEE - 50% MACYCLED/10% POET CON.UMEN PPPEE

United States Enviru.ntal Protection Agency ( i Form Approved
Washington, D.C.20460 OMB No.2040-0003
'
EPA NPDES Compliance Inspection Report Approval Expires 7-31-85
Section A:National Data System Coding Transaction Code NPDES, yorno/day, - Inspection Type Inspector F.Type
I IN 1 215 1 3 1 NC0000299 11 - 12 00/05/16 17 18 �B � . 19 �$ J 20 �2
Remarks u u t..—t
IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII I
Reserved Facility Evaluation Rating BI QA Reserved
fit l I I I69 70 a I 71 I13 I 72 �N � 73 LLU 75 80
I I u Sectioonn B:Facility Deal
Jame and location of Facility Inspected Entry Time Permit Effective Date
IASF CORPORATION 9:50 am 95/12/01 �.
JS HWY 19/23 & NC HWY 112 (SAND HILL RD)
'.NKA, NC (BUNCOMBE COUNTY) Exit Time/Date Permit Expiration Date
11:00 am 00/09/30
lamels)of On-Site Representativeh)/ride(s) Phone Nick)
.AY C. ACKERMAN, ORC & MGR OF ENVIRONMENTAL SAFETY & QUALITY [phone]
:AY CROWDER/DON CANIPE
Jame,Address of Responsible Official Title
)R.JACK A DELLINGER GENERAL MANAGER
IASF CORPORATION NKA, N.C. 28728 Phone No. Contacted
[phone] No
ection C:Areas Evaluated During Inspection CODES- S-Satisfactory M-Margland U-Unsatisfactory N-Not awduratedlNol applicable
N Permit N I Flow Measurement N Pretreatment N Operations &Maintenance
N Records/Ropohs N Laboratory N Compliance Schedules N Sludge Disposal
N Facility Site Review N Eflluent/Receiving Waters N Self Monitoring Program S Other:AQUATIC TOX
Section D:Summary of Findings/Comments (Attach additional sheets if necessary)
m May 17,2000,Division Aquatic Toxloology personnel Initiated a 3-Brood Cedodaphnie dubie passttail.toxicity lest on the effluent from the subject W WTP.
he samples were collected on May 16 and 11FI9,2000 by Asheville Regional Office staff.
he result of the test indicated that the subject discharge met criteria set forth in established standards. At the ii stream waste concentration of(IWC=8.0%),
indicted by the low stream Bow 7010 of 23.0 cfs and the permitted discharge volume of 1.25 mgd,91.7%survival occurred in the test population with an
verage of 22.6 neonates per test organism.The control population exhibited 100%.survival with an average.of 24.0.neonates per control organism..Thus,the
:st was recorded i s a°Pass". Other measured water quality parameter results were:Rest sample,pH=8.08$U,canductivity-I130 miaomhosIran,TRC=<0.1
ig/I;second sample pH=8.00 SU,conductivity=1060 micromhos/cm,TRC=<0A mg/l.
lame(s)and Signamrels) spectods) Agency/OPoce?elephone Dale
I.Keith Haynes
DWQ/ARO 828-251-6208 00001019
ignature of eviewer Agency/Office Data
DWQ/ARO 828-251-6208 & �D
Regulatory Office Use Only
,coon Taken Date Compliance Status
tLNoncompliance
e Compliance

�
Corporation C BASF
GF
May 12, 2000 MAY 15 2000
D1NQ
Mr. James W. Meyer LA60RATORY SECTION
Laboratory Section n
Division of Water Quality �3
NC DENR
1623 Mail Service Center
Raleigh, INC 27699-1623
Re: Laboratory Certification Maintenance Inspection
Dear Mr. Meyer:
This is in response to your letter of April 12, requesting a written response to
specific violations, recommendations, and comments in regards to our annual
Laboratory Certification Inspection.
Let me begin by saying that I too am concerned over the cited previously
violations found by Mr. Francies. While I am not making excuses for these
deficiencies, I would like to explain that these items were corrected last year by
Mr. Ross Peebles as I indicated to you in my response to you. However, on
March 1,2000 we discontinued the staffing of our Laboratory and contracted with
Pace Analytical, Inc. to provide a technician to run the analyses required by our
plant and our NPDES Permit. Mr. Glenn Howell, one of our former QC
Laboratory Technicians, was hired by Pace and has been working in our
Laboratory since then. I was mistaken in my assumption that since Mr. Howell
had relieved Mr. Peebles during vacations that he was fully informed of all the
procedures in the Lab, including the QC requirements. Obviously he was not, as
all of our deficiencies are related to quality control items.
We will make every effort to run our Laboratory in a manner that meets all the
requirements for the properenalysis,of samples, good quality control practices,
and proper documentation of rest is and other required data. Itemized corrective
actions are attached.
Sincerely, !ASHEVILLE
li
fa7Ackerman
MY1OLABORATORY SECTION 'REGIONAL OFFICE
Laboratory Supervisor
Sand Hill Road.P.O.Sox 669,Enka,North Caroline 28728-0669 f828)667-7110

Correction actions taken are as follows:
III. A. - Since our inspection, only ink has been used in the lab to record results
and other documentation. Errors are crossed out and initialed.
111. B. —A reagent preparation log is being maintained to record the preparation of
all reagents, standards, and media. Each entry will be under a heading which will
identify the manufacturer, lot number and expiration date. Any certificates of
analysis received will be retained by the Lab for three years.
Residual Chlorine and Ammonia Nitrogen
C. Every six months a 5-point regression curve will be prepared for the tests and
a mid-range standard will be prepared from a second source to run along with
the samples for control purposes.
D. 1. The use of the control sample as described in c. above should improve
significantly the accuracy of our data. When a greater than 10 % variance occurs,
corrective action will be taken.
D, 2.The value of the control standard will be calculated and recorded in all
future analyses.
TSS
3. An annual determination of the time required to dry samples to a constant
weight will be performed and documented. The time in and time out of the oven
will be recorded for all analyses in the future.
Fecal Coliform
4. —Samples containing chlorine are being dechlorinated when taken and tested
for chlorine upon reaching the Lab. If samples are detected out of limits the state
will be notified.
5. —The maximum holding temperature thermometer will be used exclusively and
its readings documented.
BOD
F. —The BOD bottles are being randomly chosen for use and cleaned weekly.
6. In the future, if the BOD of the glucose-glutamic acid standard is outside of
the accepted control limit range of 198 ± 30.5, the data will be qualified and the
problem corrected.

7. Unfrozen Polyseed will be used with buffered dilution water to seed material
for BOD analyses. Sufficient material will be used to give a seed correction in the
range from 0.6 to 1.0 mg/I.
8. In the future if quality control requirements are not met, the data will be
qualified on the DMR. The DO readings that we do on the permitted outfall are
now being recorded on the DMR.
RLA
5-12-00

Division of Water Quality
May 24, 2000
MEMORANDUM
To: Forrest Westall
Water Quality Supervisor,ARO
Through: Matt Matthews
Supervisor,Aquatic Toxicology Unit
From: Sandy Mort
Quality Assurance Officer, Aquatic Toxicology Unit '/ry
fa v
Subject: Whole effluent toxicity test results
BASF
NPDFS Permit#NC0000299/001
Buncombe County
The aquatic toxicity test using grab and 24-hour composite samples of effluent discharged from
BASF has been completed. BASF has an effluent discharge permitted at 4.0 million gallons per
day(MOD) entering Hominy Creek(7Q10 of 23.0 CPS). Whole effluent samples were collected
on May 16 (grab) and 19 (24-hour composite)by Keith Haynes for use in a chronic
Ceriodaphnia dubia pass/fail toxicity test. The test using these samples resulted in a pass.
Toxicity test information follows.
Test Type 3-Brood Ceriodaphnia dubia pass/fail
Test Concentrations 8% sample
Test Result Pass
Control Survival 100%
Control Mean Reproduction 24.0 neonates
Test Treatment Survival 91.7%
Treatment Mean Reproduction 22.6 neonates
First Sample pH 8.06 SU
First Sample Conductivity 1130 micromhos/cm
First Sample Total Residual Chlorine <0.1 mg/l
Second Sample pH 8.00 SU
Second Sample Conductivity 1060 micromhos/cm
Second Sample Total Residual Chlorine <0.1 mg/l
Test results for these samples indicate that the effluent would not be predicted to have water
quality impacts on receiving water. Please contact us if further effluent toxicity monitoring is
desired. We may be reached at(919)733-2136.
Basin: FRB02
cc: Central Files
Environmental Sciences Branch Water Qmlity Section

. urporation (� BASF
D pQ
May 18, 2000 MAY 82 2110111
UWQ
LANORATORY smarm
Mr. James W. Meyer
Laboratory Section
Division of Water Quality NC DENR
1623 Mail Service Center
Raleigh, NC 27699-1623
Re: DMR-QA Study 19 Chronic Toxicity "Not Acceptable"
Permit No. NC 0000299
Dear Mr. Meyer:
Enclosed please find a copy of a letter from Ms Jennifer Jones, Aquatic
Toxicology Laboratory Supervisor at Pace Analytical in Asheville, containing their
explanation for the "Not Acceptable" results received on the referenced DMR-QA
Study 19 for Ceriodaphnia Dubia Chronic Toxicity Test.
We have used Pace Analytical exclusively for this test for at least the past ten
years and have had mostly successful results with their analyses. Given the
stated corrective action, we see no reason to change laboratories at this time.
We trust that this is a satisfactory conclusion to this matter. If not, I can be
reached at [phone] or by e-mail at [e-mail].
Sincerely,
1� 1�
Ray Ackerman
Laboratory Supervisor
Send HIII Road,P.O.Box 669,Enka,North Carolina 28728-0669 [phone]

Pace Analytical Services, Inc.
- .d Analyticalft 288 l J :� 54 Ravens NC
Asheville.NC 28801
Phone:[phone]
Fax:[phone]
I
May 11, 2000
Re: DMR-QA Study 19-Ceriodaphnia dubia Chronic Test"Not Acceptable"
Results. Data review,summary & corrective actions.
Dear Valued Client,
We have completed a thorough review of all testing procedures and bench sheetsused
during the testing of the DMR-QA 19 sample for which we received a"Not Accept"for
the reproduction of the Ceriodaphnia dubia chronic test. We reported a NOEC at 6.25%
which was outside the acceptable range of 12.5%to 50%. After reviewing the bench
sheets from the initial DMR-QA Study 19 we determined that not all of the batches of
moderately hard synthetic water were allowed to age for a full 48 hours, as specified in
the instructions,before being used in the test.
In order to confirm that this was a factor, we reanalyzed the remaining toxicant sample
with water which was allowed to mix for a full 48 hours and obtained"acceptable
results." No other factors could be found which would have caused an incorrect NOEC
to be reported. Reference toxicant tests were run within one week of both DMR-QA tests
and fell within acceptable ranges.
The data from the DMR-QA Study rerun is available upon request. If you have any
questions please feel free to contact me at(828) 254-7176.
'Sincerely,
`Jennifer Jones
Aquatic Toxicology Laboratory Supervisor
Note: A copy of our findings should be forwarded to the DMR coordinator by June 6,2000.

corporation cn
F
BASF
m-D D pal i
May 12, 2000 NO 15 2000
G
Mr. James W. Meyer LABORATORY SECTION
Laboratory Section n
Division of Water Quality �3 1
NC DENR /l
1623 Mail Service Center
Raleigh, NC 27699-1623
Re: Laboratory Certification Maintenance Inspection
Dear Mr. Meyer:
This is in response to your letter of April 12, requesting a written response to
specific violations, recommendations, and comments in regards to our annual
Laboratory Certification Inspection.
Let me begin by saying that I too am concerned over the cited previously
violations found by Mr. Francies. While I am not making excuses for these
deficiencies, I would like to explain that these items were corrected last year by
Mr. Ross Peebles as I indicated to you in my response to you. However, on
March 1, 2000 we discontinued the staffing of our Laboratory and contracted with
Pace Analytical, Inc. to provide a technician to run the analyses required by our
plant and our NPDES Permit. Mr. Glenn Howell, one of our former QC
Laboratory Technicians, was hired by Pace and has been working in our
Laboratory since then. I was mistaken in my assumption that since Mr. Howell
had relieved Mr. Peebles during vacations that he was fully informed of all the
procedures in the Lab, including the QC requirements. Obviously he was not, as
all of our deficiencies are related to quality control items.
We will make every effort to run our Laboratory in a manner that meets all the
requirements for the proper analysis of samples, good quality control practices,
and proper documentation of resl Its and other required data. Itemized corrective
actions are attached. ( t �-
Sincerely, I�IJnU(}JI
MAYORY SECTION
LABORAT 1 a coot I�,
ASHEVILLLEREGIONAL OFFICE
Ra�¢Ackerman
Laboratory Supervisor
Sand Hill Road.P.O.Box 669,Enka,North Carolina 28728-0669 [phone]

1
Correction actions taken are as follows:
Ill. A. - Since our inspection, only ink has been used in the lab to record results
and other documentation. Errors are crossed out and initialed.
III. B. —A reagent preparation log is being maintained to record the preparation of
all reagents, standards, and media. Each entry will be under a heading which will
identify the manufacturer, lot number and expiration date. Any certificates of
analysis received will be retained by the Lab for three years.
Residual Chlorine and Ammonia Nitrogen
C. Every six months a 5-paint regression curve will be prepared for the tests and
a mid-range standard will be prepared from a second source to run along with
the samples for control purposes.
D. 1. The use of the control sample as described in c. above should improve
significantly the accuracy of our data. When a greater than 10 % variance occurs,
corrective action will be taken.
D. 2. The value of the control standard will be calculated and recorded in all
future analyses.
TSS
3. An annual determination of the time required to dry samples to a constant
weight will be performed and documented. The time in and time out of the oven
will be recorded for all analyses in the future.
Fecal Coliform
4. —Samples containing chlorine are being dechlorinated when taken and tested
for chlorine upon reaching the Lab. If samples are detected out of limits the state
will be notified.
5. —The maximum holding temperature thermometer will be used exclusively and
its readings documented.
BOD
F. —The BOD bottles are being randomly chosen for use and cleaned weekly.
6. In the future, if the BOD of the glucose-glutamic acid standard is outside of
the accepted control limit range of 198 t 30.5, the data will be qualified and the
problem corrected.

n
7. Unfrozen Polyseed will be used with buffered dilution water to seed material
for BOD analyses. Sufficient material will be used to give a seed correction in the
range from 0.6 to 1.0 mg/I.
8. In the future if quality control requirements are not met, the data will be
qualified on the DMR. The DO readings that we do on the permitted ouffall are
now being recorded on the DMR.
RLA
5-12-00

s NORTH CAROLINA DEPARTMENT OF
I ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
May 19, 2000
�l.
239
MR. RAY ACKERMAN
L.AR: BASF CORP - FIBERS DIV
CTARY .SAND HILL ROAD
ENKA, NC 28728
y
Dear Mr. Ackerman:
Your letter received May 15, 2000 that describes
corrective actions for your analytical procedures has
been reviewed. The actions taken are acceptable for
your North Carolina Wastewater/Groundwater laboratory
certification. If a future inspection should reveal
„a that the violations cited in the inspection report were
not corrected, enforcement actions will be recommended.
y �ry
Thank you again for your cooperation. Contact us
at (828) -251-6208 extension 285 if you have questions.
a
N ,
Sincerely,
.Gary Francies
Laboratory Section
w
cc: James W. Meyer
Marilyn Deaver
INTeRCXAN08 RUILgINO 8B WOOOFIN PIA... ....VILLe, NORTH 0...LINP 39801-Y419
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State of North Carolina
Department of Environment �`, • •
and Natural Resources
Division of Water Quality
James B. Hunt,Jr., Governor NCDENR
Bill Holman, Secretary
Kerr T. Stevens,Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
May 5,2000
MR. JACK A. DELLINGER,PHD
SAND HILL ROAD
ENKA, NC 28728
I
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
BASF CORPORATION ENKA PLANT
BUNCOMBE COUNTY
PERMIT NO: N00000299
LV 00-086
Dear Mr.Jack A.Dellinger :
This letter is to acknowledge receipt of check No.4250989 in the amount of $323.11 received from
you dated May 05, 2000. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes,Regulations or Permits.
If you have any questions,please call Rob Lang at(919)733-5083.
Sincerely,
in l 9
e
J'
�yl E. Shannon Langley,Supervisor
Point Source Compliance/Enforcement Unit
1
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Cc: Enforcement File#:LV 00-086
ARO Regional Office Supervisor
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' NORTH CAROLINA DEPARTMENT OF
K- ENVIRONMENT AND NATURAL RESOURCES
g � April 12, 2000
/;}�4<
239 DIVISION OF WATER QUALITY
1 `, NR Mr. Ray Ackerman
BASF Corporation - Enka Plant
-: Sand Hill Road
�JAMES B. HUNT JR}5j Enka, NC 28726
''GOVERNOR
SUBJECT: Laboratory Certification Maintenance Inspection
BILL HDLMANi 'a Dear Mr. Ackerman:
SECRETARY Y �,FS
Enclosed is a report for the inspection performed on March 29, 2000
x ' by Mr. Gary W. Francies. Within thirty days, please supply this office with a
RBRR r sTBYENB - written item for item description of how these violations were corrected. A
01REOTOX Os rt „ response is not required for comments or recommendations unless
specifically requested. We are seriously concerned about the CITED
if PREVIOUSLY violation(s) found during the inspection. Another inspection
will be scheduled within 3 to 6 months. If the violations cited in the enclosed
uT report are not corrected, enforcement actions will be recommended. For
f certification maintenance, your laboratory must continue to carry out the
requirements set forth in 15A NCAC 2H .0800.
1 Copies of the checklists completed during the inspection may be
requested from this office. Thank you for your cooperation during the
inspection. Please contact us at 919-733-3908 if you have questions or
1S need additional information.
1
Sincerely,
& k rta,Xa t
James W. Meyer
Laboratory Section
17
` ... 7 Enclosure
,a y cc: Marilyn 0. Deaver
x 9� Gary W. Francies
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ON-SITE INSPECTION REPORT
LABORATORY NAME: BASF Enka Plant
ADDRESS: Sand Hill Road
Enka, NC 28728
CERTIFICATE #: 239
DATE OF INSPECTION: 3/23/00
TYPE OF INSPECTION: Maintenance
EVALUATOR(S) : Gary Francies
LOCAL PERSON(S) CONTACTED: Ray Ackerman, Butch Howell
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A
NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory is spacious and adequately equipped. All equipment is well
maintained. Since zinc samples are no longer analyzed in the laboratory, it is
recommended that the lab drop certification for zinc. Several violations noted in
the last inspection have not been corrected. It appears this happened because of
personnel changes made in March 1999, shortly after the inspection. It appears that
the new analyst was not properly trained and since then, there has been a lack of
supervision of the laboratory. Some further quality control procedures need to be
implemented.
Samples were split with the following results:
Fecal Coliform performance sample:
Enka Laboratory State Laboratory
284/100 ml 215/100 ml
Composite Effluent samples:
HOD, mg/l 11.4 13.5
TSS, mg/1 19 18
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
Bench Sheets
A. COMMENT: Most documentation is performed with pencil. Good laboratory
practices dictate that all data be recorded on the worksheets, logbooks, and DMRS in
black (preferred) or blue ink. No white out or write overs of errors are allowed.
Any error must be crossed out with one ink line and the correction and analyst
initials placed near the error. A written responae is required.
General
B. RECOMMENDATION: It is recommended the laboratory increase the documentation of
reagent and standard preparation. The preparation of all reagents, standards and
media should be documented in a preparation log or logs. Traceable identifiers
should link solution preparation information to analytical batches in which the
solutions are used. Documentation of solution preparation should include the
analyst's initials, date of preparation, the volume or weight of standard used, the
solvent, and final volume of the solution. This information as well as the vendor,

age 2
manufacturer, lot number, certificate of analysis, and expiration date should be
retained for primary standards or chemicals used. A written response is required.
COMMENT: The lab has a reagent preparation log, but it is only sporadically used and
many items are not documented.
Residual Chlorine and Ammonia Nitrogen
C. COMMENT: The laboratory control standard is not from a second source. A ,
written response is required.
REQUIREMENT: Analyze one known standard in addition to calibration standards each
day samples are analyzed to document accuracy. This laboratory control standard must
be from a second source. For held curves for calorimetric methods, it must be
analyzed after the calibration verification standard is analyzed. It is recommended
that this laboratory control standard, like the calibration verification standard,
have a mid-range concentration and not vary by more than ± 10%. If it does, the
analysis is out of control. The analysis must be terminated and the problem
corrected. Ref: 15A NCAC 2H .0805 (a) (7) (B) , (F) , and Standard Methods, 18th
Edition - Method 1020 B.S.
• Ammonia Nitrogen
D. COMMENTS: The linearity of the curve is not easily determined.
Recommendation: It is strongly recommended that a linear regression be calculated to
document accuracy of the method and reliability of the curve. Document the linearity
of the curve (correlation coefficient) on the bench sheets with proper initials and
dates. Good laboratory procedures require a correlation coefficient greater than
0.995. Reference: 15A NCAC 2H .0805 (a) (7) (H) . Determine the absorbance
against the concentrations of standards to establish a working curve and the
agreement with Beer's law. Ref: Standard Methods, 18 Edition - Method 1070D pg. 1-
28. To establish agreement with Beer's law, a correlation coefficient must be
calculated to document linearity. For selective ion electrode analysis, a slope may
be documented each time samples are analyzed.
1. VIOLATION: The values obtained on the laboratory control standards indicate a
possible problem. The following values were obtained on 0.5 mg/1 laboratory control
standards (all values are mg/1) : 3/10/99=0.92, 3/17/99=0.93, 9/19/99=0.93,
6/30/99=0.99, 8/18/99-0.59. Five of the last sixty-two sample sets had questionable
results.
REQUIREMENT: See requirement for comment letter C above. And: Any time quality
control results indicate an analytical problem, the problem must be resolved and any
samples involved must be reanalyzed if the holding time has not expired. Reference:
15A NCAC 2H .0805 (a) (7) (F) .
2. VIOLATION: The value obtained for the laboratory control standard is not
always calculated and documented.
REQUIREMENT: Supporting records shall be maintained as evidence that these practices
are being effectively carried out. All analytical records must be available for a
period of three years. Ref: 15A NCAC 2H .0805 (a) (7) and (a) (7) (G) .
COMMENT: In order to document accuracy, the value of the laboratory control standard
must be calculated and documented. In eight of sixty-two sample sets the value was
not calculated.
TSS
3. VIOLATION: The adequacy of the drying time has not been verified. The time
samples are placed in the oven and the time samples are removed is not documented.
Cited in previous inspection.

Page 3
REQUIREMENT: If each sample is not redried"and reweighed, the laboratory may verify
that a specific drying time is adequate to dry samples to constant weight. This
verification may be performed 'annually.. by drying representative samples for a
determined time period and verifying thatthis time period is adequate with
additional drying and weighing cycles. This annual check must be documented.
-
Additionally, the time samples are placed, in the oven and the time samples are
removed from the oven must be recorded for each analysis thereafter. Ref: Standard
Methods 18th Edition; Method 2540 D. 36. 'and 15A NCAC 2H .0805 (a) (7)and (a) (7)
(D) ,
Fecal Coliform --
4. VIOLATION: Sample preservation is not properly performed and documented. Cited
in previous inspection
REQUIREMENT: Samples received for analysis "must be verified and documented to have
been properly preserved. Samples containing chlorine must be dechlorinated at the
- time of sample collection and treated according to the requirements of the analysis .,
to be performed. Upon receipt_ in the laboratory, samples must be checked and. .
documented to be free of chlorine. A variety of testing kits are considered to be
adequate for most chlorine interference 'checks and a maximum detection limit of 0.2
mg/L is allowed. When samples are received out of compliance, the lab must inform
the client and the State of NC in writing. Ref: 15A NCAC 2H .0805 (a) (1) and (7)
(M) and (N) .
5. VIOLATION: It is not possible to distinguish from the autoclave log which days
the temperature gage is used and which days the maximum holding thermometer is used.
REQUIREMENT: Supporting records shall be maintained as evidence that these practices
are being effectively carried out. All analytical records must be available for a
period of three years. Ref: 15A NCAC 2H .0805 (a) (7) and (a) (7) (0) .
REQUIREMENT: It is required that the operating temperature of the autoclave be
checked with a maximum holding thermometer at least once per week. Ref: Standard
Methods, 18th Edition - Method 9020 B.2i.
E. RECOMMENDATION: It is recommended that each lot of media be checked to confirm
the required pH.
REQUIREMENT: The pH of the media must be 74 t 0.2 after sterilization and cooling.
Incorrect pH values may indicate ' a problem with reagent water quality, medium
deterioration, or improper preparation. Ref': Standard Methods, 18th Edition - Method
9020 B. 3h 1.
BCD .
F. COMMENT; The bottles used for the dilution water blank, seed blank, seed
controls, glucose-glutamic acid standard,.:and samples are dedicated, i.e. the same. .
bottle is used each time for that particular item. A written response is required.
REQUIREMENT: The bottles be randomly selected and rotated. This is the only way to
assess whether bottles are being adequately cleaned.
G. COMMENTS: The BOD bottles appeared„to be dirty. When the bottle dedicated to
the dilution water blank was compared tq,.the rest of the bottles, . it was apparent
the bottles needed cleaning. The bottle�, tq' be used the day of the inspection were
then cleaned before they were used that day. -
RECOMMENDATION: It is strongly recommend 'that the bottles be cleaned thoroughly
after each use. Besides detergent and water, an occasional cleaning with chromerge
or acid may be needed.
6. VIOLATION: The value obtained for ,the glucose-glutamic acid standard is often
unacceptable. No evidence of corrective action is apparent. -

Page 4
REQUIREMENT: It is required that whenever the SOD of the glucose-glutamic acid
standard is outside the accepted control limit range (198 ± 30.5) the data from that
set must be qualified. Ref: Standard Methods, 18th Edition - Method 5210 B.6a, And
REQUIREMENT: Any time quality control results indicate an analytical problem, the
problem must be resolved and any samples involved must be reanalyzed if the holding
time has not expired. Reference: 15A NCAC 2H .0805 (a) (7) (F) .
COMMENTS: Twenty-three of the last thirty-eight sets had unacceptable standards
outside the acceptable limits.
7. VIOLATION: The seed correction factor is erratic and often unacceptable. No
evidence of corrective action is apparent. Cited in previous inspection
REQUIREMENT: Sufficient seed material must be used to yield a seed correction of 0. 6
to 1.0 mg/l. Ref: Standard Methods, 18th Edition - Method 5210 B. 4d 2.
REQUIREMENT: Any time quality control results indicate an analytical problem, the
problem must be resolved and any samples involved must be reanalyzed if the holding
time has not expired. Reference: 15A NCAC 2H .0805 (a) (7) (F) .
COMMENTS: Thirteen of the last thirty-eight sample sets were unacceptable. Frozen
Polyseed is used, made with distilled water. Polyseed must be made with buffered
dilution water and it is strongly recommended that it not be frozen.
8. VIOLATIONS: When all method quality control requirements are not met, the
reported data are not qualified. Cited in Previous inspection
Requirement: It is the desire of the State of North Carolina that all data generated
for any permitted location under NPDES requirements is to be reported. "Every person
subject to [15A NCAC 2B .0506) shall file certified monitoring reports setting forth
the results of tests and measurements conducted pursuant to NPDES permit monitoring
requirements." Ref: 15A NCAC 2B .0506 (a) (1) . Additionally, "the results of all
tests of the characteristics of the effluent, including but not limited to NPDES
Permit Monitoring Requirements, shall be reported on monthly report forms." Ref: 15A
NCAC 2B .0506 (b) (3) (J) .
The NPDES Permit itself states in Part II, Section D, Monitoring and Records, Number
7 - Recording Results, "for each measurement or sample taken pursuant to the
requirements of this permit, the permittee shall record the following
information. . .the results of such analyses."
This means all data are reported and none are rejected. If all quality control
requirements are not met, it is required that the data is qualified and the
qualification appears on the back of the Discharge Monitoring Report (DMR) .
Any rejection of .data from the storets will be issued by the agency, which receives
the data.
The Quality Control requirements of the method are outlined below:
1. The DO depletion of the dilution water blank must not be more than 0.2 mg/l.
2. The seed controls must deplete at least 2.0 mg/1 DO and have at least 1.0 mg/1
DO remaining.
3. The samples must also deplete at least 2.0 mg/1 DO and have at least 1.0 mg/l
DO remaining.
4. No evidence of toxicity should be present. This can only be evident when at
least three dilutions are analyzed. This is characterized by an increasing BOD
value as the sample concentration decreases.
5. The glucose glutamic acid standard must be in the acceptable range of 198 ,mg/l
+ 30.5 mg/l.
6. The seed correction, calculated from the seed controls, must be between 0.6
and 1.0 mg/l.
Anytime any of the above quality control requirements are not met, the data must be
qualified. The qualifying statement should indicate how QC requirements were not met
and indicate whether the data is valid. But the data must always be reported.

Page 5
IV. PAPER TRAIL: -
A review of data was conducted. This consisted of comparing laboratory bench sheets
and contract lab reports to DMRs submitted tp this Division. Data were reviewed for
these months: September, November 1999, and January 2000. No errors were noted. It
appears the facility is doing a good job of accurately transcribing data.
V. CONCLUSION:
We are concerned with the violation(s) that were cited previously and not corrected.
Failure to correct the violation(s) cited in this report will lead to enforcement
action.
Ref: 15A NCAC 2H .0607 (a) (1) and (14) -
Laboratory Decertification:
A laboratory may be decertified for any or all parameters for up to one year for any
or all of the following infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or
quality control program as set forth in the application, and these Rules; or
(14) Failing to comply with any other terms, conditions, or requirements of this
Section or of a laboratory certification.
Correcting the above violations should help to produce quality data and meet'
certification requirements. Implementing the recommendations will further improve
the quality of the data. Another inspection will be conducted in three to six
months.
Report prepared by: Gary Francies Date: 3/29/00

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place Asheville,North Carolina 28801
April 19,2000
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr.Ray Ackerman
BASF Corporation-Enka '
Sand Hill Road
Enka,North Carolina 28728
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No.NC0000299
BASF Corporation W WTP
Buncombe County
Dear Mr.Ackerman:
This is to inform you that a review of your toxicity self-monitoring report form for the month of
February 2000 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent
toxicity violation(s). Yom efforts may include conducting a Toxicity Reduction Evaluation (TRE) which is a
site-specific study designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity,
evaluate the effectiveness of toxicity control options, and then confirm reductions in effluent toxicity. Please be
aware that North Carolina General Statutes providefor assessment of civil penalties for violations of NPDES
permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note updated mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this
information and if it would be helpful to discuss this situation or possible solutions to resolve effluent toxicity
noncompliance,please contact Mr. Keith Haynes with this office at(828)251-6208.
Sincerely,
Po wl t t Regional Water Quality Supervisor
cc: Keith Haynes-Asheville Regional Office
Aquatic Toxicology Unit
Central Files

ON-SITE INSPECTION REPORT
LABORATORY NAME: BASF Enka Plant
ADDRESS: Sand Hill Road
Enka, NC 28728
CERTIFICATE $: 239
DATE OF INSPECTION: 3/23/00
TYPE OF INSPECTION: Maintenance
EVALUATOR(S) : Gary Francies
LOCAL PERSON(S) CONTACTED: Ray Ackerman, Butch Howell
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A
NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL C0MMENTS:
The laboratory is spacious and adequately equipped. All equipment is well
maintained. Since zinc samples are no longer analyzed in the laboratory, it is
recommended that the lab drop certification for zinc. Several violations noted in
the last inspection have not been corrected. It appears this happened because of
personnel changes made in March 1999, shortly after the inspection. It appears that
the new analyst was not properly trained and since then there has been a lack of
supervision of the laboratory. Some further quality control procedures need to be
implemented.
Samples were split with the following results:
Fecal Coliform performance sample:
Enka Laboratory State Laboratory
284/100 ml 215/100 ml
Composite Effluent samples:
BOD, mg/l 11.4 13.5
TSS, mg/1 19 18
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
Bench Sheets
A. COMMENTS: Most documentation is done with pencil. Good laboratory practices
dictate that all data be recorded on the worksheets, log books, and DMRs in ink. No
white out or write overs of errors is allowed. Any error must be crossed out with
one ink line and the correction and analyst initials placed near the error.

age 2
General
B. Recommendation:_It is recommended the laboratory increase the'jl.documentation of
Vreagent and...standard preparation.,' The preparation of all reagents, standards and
media should be documented in a preparation log or logs. Traceable identifiers
should link solution preparation information to analytical batches in which the
solutions are used. Documentation of solution preparation should include the
analyst' s initials, date of preparation, the volume or weight of standard used, the
solvent and final volume of the solution. This information as well as the vendor,
manufacturer, lot number, certificate of analysis and expiration date should be
retained for primary standards or chemicals used. .
COMMENTS: The lab has a reagent preparation log but it is only sporadically used and
many items are not documented.
Residual Chlorine-andAmmonia-:Nitrogen
C. COMMENTS: The laboratory control standard is not from a second source.
REQUIREMENT: Analyze one known standard in addition to calibration standards each
-day .samples. are analyzed to document accuracy. This laboratory control standard must'
be from a second source. For held curves for colorimetric methods, it must be
analyzed after the calibration verification standard is analyzed. It is recommended
that this laboratory control standard, like the calibration verification standard,
have a mid-range concentration and not vary by more than 1 10%. If it does the
analysis is out of control. The analysis must be terminated and the problem
corrected. Ref: 15A NCAC 2H .0805 (a) (7) (B) , (F) , and Standard Methods, 18th
Edition - Method 1020 B.3. A written response is required.
kAmmonia-NitrogeM--'
D. COMMENTS: The linearity of the curve is not easily determined.
Recommendation: �It is strongly recommended that a linear regression tie calculated)to
document accuracy of the method and reliability of the curve. Document the linearity
of the curve (correlation coefficient) on the bench sheets with proper initials and
dates. Good laboratory procedures require a correlation coefficient greater than
.995: "Re nce: 15A NCAC 2H . 0805 (a) (7) (H) .
/p1/ VIOLAT IO The values obtained on the laboratory control standards indicate a
L/ posse em. The following values were obtained on 0.5 mg/1 laboratory control
stanear (all values are mg/1) : 3/10/99=0.42, 3/17/99-0.43, 4/14/99=0.43,
6/30/99-0.44, 8/18/99=0.59. Five of the last sixty-two sample sets had questionable
results.
REQUIREMENT: See requirement for comment letter C above. And: Any time quality
control results indicate an analytical problem, the problem must be resolved and any
s
aOes involved must be reanalyzed if the holding time has not expired. Reference:
15 H .0805 (a) (7) (F) .
VIOLATIO The value obtained for the laboratory control standard is not
alwa ca ten and documented.
REQUIREMENT: Supporting records shall be maintained as evidence that these practices
are being effectively carried out. All analytical records must be available for a
period of three years. Ref: 15A NCAC 211 .0805 (a) (7) and (a) (7) (G) .

.,age 3
COMMENTS: In order to document accuracy, the value of the laboratory control
standard must be calculated and documented. In eight of sixty-two sample sets the
value was not calculated.
TSS
3. VIOLATION: The adequacy of the drying time has not been verified. The time
samples are placed in the oven and the time samples are removed is not documented.
Cited in previous inspection.
REQUIREMENT: If each sample is not redried and reweighed, the laboratory may verify
/that a specific drying time is adequate to dry samples to constant weight. This
1/ that
may be performed annually by drying representative samples for a
determined time period and verifying that this time period is adequate with
additional drying and weighing cycles. This annual check must be documented.
Additionally, the time samples are placed in the oven and the time samples are
removed from the oven must be recorded for each analysis thereafter. Ref: Standard
Methods 18th Edition; Method 2540 D. 3c. and 15A NCAC 2H .0805 (a) (7) and (a) (7)
4ecal Coliform
9. VIOLATION: Sample preservation is not properly performed and documented. Cited
in previous inspection
REQUIREMENT: Samples received for analysis must be verified and documented to have
been properly preserved. Samples containing chlorine must be dechlorinated at the
time of sample collection and treated according to the requirements of the analysis
44be performed. Upon receipt in the laboratory, samples must be checked and
umented to be free of chlorine. A variety of testing kits are considered to be
quate for most chlorine interference checks and a maximum detection limit of 0.2
L is allowed. When samples are received out of compliance, the lab must inform
the client and the State of NC in writing. Ref: 15A NCAC 2H .0605 (a) (1) and (7)
(M) and (N) .
5. VIOLATION: It is not possible to distinguish from the autoclave log which days
the temperature gage is used and which days the maximum holding thermometer is used.
REQUIREMENT: Supporting records shall be maintained as evidence that these practices
are being effectively carried out. All analytical records must be available for a
Aof three years. Ref: 15A NCAC 2H .0805 (a) (7) and (a) (7) (G) . and
✓ REQUIREMENT: It is required that the operating temperature of the autoclave be
checked with a maximum holding thermometer at least once per week. Ref: Standard
Methods, 18th Edition - Method 9020 B.2i.
E. Recommendation: It is recommended that each lot of media be checked to confirm
the required pH.
REQUIREMENT: The pH of the media must be 7.4 i 0.2 after sterilization and cooling.
Incorrect pH values may indicate a problem with reagent water quality, medium
deterioration, or improper preparation. Ref: Standard Methods, 18th Edition - Method
9020 B. 3h 1.
BOD _.
E. COMMENT: The bottles used for the dilution water blank, seed blank, seed
controls, glucose-glutamic acid standard, and samples are dedicated, i.e. the same
bottle is used each time for that particular item.

Page 4
RECOMMENDATION: It is strongly recommended that the bottles be randomly selected and
rotated. This is the only way one can assess whether bottles are being adequately
cleaned.
G. COMMENTS: The BCD bottles appeared to be dirty. When the bottle dedicated to
the dilution water blank was compared to the rest of the bottles, it was apparent
the bottles needed cleaning. The bottles to be used the day of the inspection were
then cleaned before they were used that day.
RECOMMENDATION: It is strongly recommended that the bottles be cleaned thoroughly
after each use. Besides detergent and water, an occasional clean with chromerge or
acid may be needed.
/6. VIOLATION: The value obtained for the glucose-glutamic acid standard is often
8/ unacceptable. No evidence of corrective action is apparent.
REQUIREMENT: It is required that whenever the BOD of the glucose-glutamic acid standard
is outside the accepted control limit range (198 } 30.5) the data from that set must be
:qualified. Ref: Standard Methods, 18th Edition - Method 5211 B.6a. And REQUIREMENT:
Any time quality control results indicate an analytical problem, the problem must be
resolved and any samples involved must be reanalyzed if the holding time has not
expired. Reference: 15A NCAC 2H .0805 (a) (7) (F) .
COMMENTS: Twenty-three of the last thirty-eight sets had unacceptable standards
outside the acceptable limits.
7. VIOLATION: The seed correction factor is erratic and often unacceptable. No
evidence of corrective action is apparent. Cited in previous inspection
/ REQUIREMENT: Sufficient seed material must be used to yield a seed correction of 0.6
to 1.0 mg/l. Ref: Standard Methods, 18th Edition - Method 5210 B. 4d 2. And
REQUIREMENT: Anytime quality control results indicate an analytical problem, the
problem must resolved and any samples involved must be reanalyzed if the holding
time has not expired. Reference: 15A NCAC 2H .0805 (a) (7) (F) .
COMMENTS: Thirteen of the last thirty-eight sample sets were unacceptable. Frozen
Polyseed is used, made with distilled water. Polyseed must be made with buffered
dilution-water_and it is strongly recommended that it not be frozen.
8 VIOLATION:6W n all method quality control requirements are not met, the
r[F(,ported. not qualified. Cited in previous inspection
Requ�'�rt2n'�It is the desire of the State of North Carolina that all data generated
for any permitted location under NPDES requirements is to be reported. "Every person
subject to [15A NCAC 2B .0506] shall file certified monitoring reports setting forth
the results of tests and measurements conducted, pursuant to NPDES _permit monitoring)
requirements." -Ref:. -15A NCAC 2B .0506 (1) ._ Additionally, "the results of all r
tests of the characteristics of. the. eff uentp!-includingbut .not limited to NPDES
Permit..Monitoring Requirements, shall..be reported on monthly report forms." Ref: 15A?
NCAC 2B .0506 (b) (3) (J) .
The NPDES Permit itself states in Part II, Section D, Monitoring and Records, Number
7 - Recording Results, "for each measurement or sample taken pursuant to the
requirements of this permit, the permittee shall record the following
information. . .the results of such analyses."
This means all data are reported and none are rejected. If all quality control
requirements are not met, it is required that the data is qualified and the
qualification appears on the back of the Discharge Monitoring Report (DMR) .

.age 5
Any rejection of data from the storets will be issued by the agency, which receives
the data.
The Quality Control requirements of the method are outlined below:
1. The DO depletion of the dilution water blank must not be more than 0.2 mg/l.
2. The seed controls must deplete at least 2.0 mg/1 DO and have at least 1.0 mg/l
DO remaining.
3. The samples must also deplete at least 2.0 mg/l DO and have at least 1.0 mg/l
DO remaining.
4. No evidence of toxicity should be present. This can only be evident when at
least three dilutions are analyzed. This is characterized by an increasing BOD
value as the sample concentration decreases.
5. The glucose glutamic acid standard must be in the acceptable range of 198 mg/1
+ 30.5 mg/l.
6. The seed correction, calculated from the seed controls, must be between 0.6
and 1.0 mg/l.
Anytime any of the above quality control requirements are not met, the data must be
qualified. The qualifying statement should indicate how QC requirements were not met
and indicate whether the data is valid. But the data must always be reported.
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory bench sheets
and contract lab reports to DMRs submitted to this Division. Data were reviewed for
these months: September, November 1999, and January 2000. No errors were noted. It
appears the facility is doing a good job of accurately transcribing data.
V. CONCLUSION:
We are concerned with the violation(s) that were cited previously and not corrected.
Failure to correct the violation(s) cited in this report will lead to enforcement
action.
Ref: 15A NCAC 2H .0807 (a) (1) and (14)
Laboratory Decertification:
A laboratory may be decertified for any or all parameters for up to one year for any
or all of the following infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or
quality control program as set forth in the application, and these Rules; or
(14) Failing to comply with any other terms, conditions, or requirements of this
Section or of a laboratory certification.
Correcting the above violations should help to produce quality data and meet
certification requirements. Implementing the recommendations will further improve
the quality of the data. Another inspection will be conducted in three to six
months.
Report prepared by: Gary Francies Date: 3/29/00

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
DENV� March 15, 1999
LAMER B.NUNTJR.
R Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
DZIN
Enka, North Carolina 28728
Subject: Performance Audit Inspection
Inspection Rating "B-Minus"
kRY ) Wastewater Treatment Program
BASF Corporation
NPDES Permit Number NC0000299
,,,TBuncombe County, North Carolina
Dear Mr. Dellinger:
The Performance Audit Inspection (PAI) that Gary
Francies and I conducted on February 18, 1999, of BASF' s
IT! wastewater treatment program resulted in an overall rating of
B-Minus relative to the evaluation of sampling, flow
measurement, and. laboratory procedures. Regulatory and
methodology violations were identified in the laboratory
portion of the inspection which basically centered around
handling of chlorinated samples for ammonia and fecal
coliform analysis. Additionally, documentation of drying
times for the total suspended residue analysis together with
BOD seed correction and dilution problems need to be
addressed. Comparison of results of split sample analysis
between the BASF laboratory and the NCDENR Water Quality
laboratory show concerns which need to be further evaluated.
The results of this PAI should not he interpreted to
question compliance with terms and conditions contained in
the NPDES permit. Sample analysis showed the discharge to be
meeting effluent limitations and the evaluation of the
wastewater treatment facility showed proper operation and
control. The high total suspended residue concentration
tentatively attributed to the presence of finishin . 1
g oi�s in
the wastewater stream is of concern as it -approached­�e-
daily maximum effluent limitation. The source of the high
total suspended residue concentration should be located and
addressed.
--Y........EU.13UN.,--WOOD 11.1..,A...
PHONK028,E51.620. FAXIUITI-M-.4.2
AN EQUAL OPPORTUNITY 1APPIRMATIVE ACTION EMPLOYED-309(R9QYCLZWI05'.POZY-=NQIUMKRPAP9R

PERFORMANCE AUDIT INSPECTION
WASTEWATER TREATMENT FACILITY (NC0000299)
BASF CORPORATION
ENKA, NORTH CAROLINA
FEBRUARY, 1999
INTRODUCTION
On Thursday, February 18, 1999, the North Carolina Division of -
Water Quality cond'iicted an on-site inspection of BASF' s
wastewater treatment program including evaluation of the
laboratory and sample collection procedures.
The Performance Audit Work with the Company' s laboratory was
conducted by Gary Francies and Max Haner of the Division's
Asheville Regional Office. Personnel from BASF Fibers were Ray L.
Ackerman, Manager, Environmental/Safety/Qualityand Operator in
Responsible Charge (ORC) of the wastewater treatment facility;
Kay Crowder, Maintenance Superintendent and backup operator; Don
Canine & Don Wilkey, electrician; Ross Peebles, laboratory; and
'Fric Barbour, iEe Facilities.
The purpose of this inspection was to determine the quality of r
the self-monitoring program being conducted by BASF Fibers
Corporation and assess the reliability of its reported data. _
The inspection consisted of evaluation of the flow monitoring
equipment and data handling, evaluation of sample collection and
Preservation techniques and evaluation of laboratory and
analytical techniques, record keeping and data reporting
procedures. NPDES permit number NC0000299 provides for a
discharge (001) from the Company's wastewater treatment facility;
two equalization basins (series) ,an aeration basin, dual final
clarifiers, a chlorine contact chamber, a mixing lagoon, sludge
handling and disposal (thickener, conditioner, filter press, BASF
landfill as cover) with discharge to Hominy Creek, Class "C"
waters in the French Broad River Basin. Additionally, the permit
provides for a discharge (002) of non-contact cooling water from
a barometric condenser into Hominy Creek via the east ditch on
BASF property. -
BASF Fibers Corporation is conducting the self-monitoring part of
this program in accordance with monitoring requirements contained
in NPDES Permit Number N00000299. Flow measurement, composite
sampling and collection of samples is satisfactory. Violations were found, however, with the laboratory methodology which
addressed sample preservati n (and documentation) for chlorinated
samples for ammonia and fecal coh orm analysis. Additional
violations were noted in documentation ofdr ing times. for total
suspended residue sample analysis and see � cor c ion and
dilution practices in the SOD sample analysis. As resu t,
the overa P rating for this facility is B-Minus. A PAI .
rating sheet is attached. ..

f,
Page 2
1999 PAI Report - - - - -
BASF Corporation Wastewater Treatment Facility
FINDINGS AND RECOMMENDATIONS
Recommendations contained in this- section ill appear as
regulatory requirements to correct deviations or as suggestions
to strengthen the self-monitoring and laboratory program.
A. FIELD EVALUATION
1 . - FLOW MEASUREMENT: Flow is measured at the 001
discharge structure in the final mixing lagoon using a
30-inch cipolletti weir with a Miltronic ultrasonic
depth probe and Honeywell Recorder, Accuracy of this
unit including the integrity of the work is checked
weekly, The unit is checked for accuracy during zero
flow periods when the level of the final basin is
lowered for maintenance. Last calibration. by Law
Engineering on 1/28/99 . A check of the weir showed it
to be plumb, level, and meeting requirements for a
properly installed cipolletti weir. Additionally,
instantaneous flow measurement at the weir compared
with instrumentation recordings showed a difference of '..
approximately 7. 6&, well within the allowable 10%-
difference.
a. . RECORDS: Records are maintained in a hardbound
notebook by Don Canipe, maintenance (electrician) .
Mr Canipe was assisted by Don Wilkey.
b. DATA HANDLING: Flow totalizer measurements are
handling properly.
2 . SAMPLING PROCEDURES : The effluent composite
sampling device for discharge001 is an ISCO -model
371OR unit with refrigeration. The permit requires no
monitoring of discharge. 002 .
a. Effluent 24 hours composite samples are collected
proportional to flow with a setting of 125 ml per
cycle. Each sampling cycle is approximately 5, 000
gallons. Two separate measurements showed the actual
sample aliquot to be 124 ml and 120 ml. -
b. Pump and sample tubing last was replaced in
October Tubing is checked routinely and
rep aced as necessary. The, sample strainer was in need
of cleaning.

Page 3
1999 PAI Report - -
BASF Corporation Wastewater Treatment .Facility
C. Records : The volume of each composite sample is
measured and recorded. These records also should
include the temperature of each composite sample upon -
collection.
3 . FIELD MEASUREMENTS :
a. The effluent dissolved oxygen (D.O. ) measurement
is measured daily during the time the composite
sample is collected for analysis using a D.O. meter
and probe. D.O. measurement of the discharge was
8 .9 mg/1 Q 11° C (NCDWQ) . -
b.. The effluent pH measurement is performed in the
laboratory from a grab sample collected from the
discharge during sample pickup. The PH was measured at
7.90 s.u. (NCDWQ) .
C. The effluent total residual chlorine concentration
is measured is the laboratory from a grab sample
collected from the discharge during sample pickup.
The total residual chlorine was measured at 0 .11 mg/1
(NCDWQ) .
4 . SAMPLE HANDLING : The composite sample (carboy)
was properly handling with the sample being thoroughly
mixed prior to transfer to the sample container(s) .
5 . RECORD MAINTENANCE : Preventative maintenance
work performed on the system was in accordance with
needs addressed in the weekly computer printout. -
Calibration records for the dissolved oxygen sensors in
the aeration basin should be maintained. Time of
operation records for the solids handling system need
to be maintained.
6 . OPERATION & MAINTENANCE : O&M is being performed
in a satisfactory with interest on preventative. The
south clarifier was being cleaned and its weir was
` being leveled duringthis inspection. Wasting of
solids based on F/M ratio and volatile solids in the
system (target 1100-1200 mg/1) . -
7 . PERMIT VERIFICATION: The facility is operating
in compliance with terms and conditions contained in
the NPDES permit (NC0000299) . The permit accurately
reflects the existing wastewater treatment facility and
discharge location.

Page 4
1999 PAI Report
BASF Corporation Wastewater Treatment Facility
B . LABORATORY EVALUATION
1 . PERSONNELL : All NPDES testing performed at this
facility is under supervision of Ray Ackerman. The manager
of the laboratory is Sack Dellinger, PhD.
2 . FACILITIES AND EQUIPMENT : The laboratory is
spacious and adequately equipped for testing performed at
this location of this faciltiy. The laboratory routinely
conducts tests for pH, BOD, Total Suspended Residue, Fecal
Coliform, Ammonia, Zinc, Total Residual Chlorine, and
Temperature. The BASF laboratory is state certified for the -
above parameters. Pace Laboratories, Inc. , performs the
remaining NPDES analyses including Aquatic Toxicity.
A new spectrophotometer has been obtained by BASF since the
last inspection for ammonia analysis.
3 . METHODOLOGY: All testing procedures are based upon
EPA' s approved methodology or the Laboratory Certification
Regulation; 15A NCAC 2H. 0800. Violations are entered as
follows :
a. Violation - Sample Preservation
Dechlorination of both the ammonia sample or the fecal
coliform sample is not documented and therefore
considered as not being performed>
Requirement: 15A NCAC 2H.0805 (a) (1) & (7) (M) & (N)
requires in part that samples containing chlorine ,must
be dechlorinated at the time of sample collection and
treated according to the requirements of the anaklysis
to be performed. Upon receipt in the laboratory, _
samples treated for chlorine must be checked and
documented to be free of chlorine.
b. Violation - Total Suspended Residue
The time that the sample is placed in the oven for
drying and the time that the sample is taken from the
oven is not being documented.
Requirement: 15A NCAC 2H. 0805 (a) (7) & (a) (7) (D)
.. requires drying times be documented.

Page 5
1999 PAI Report - -
BASF Corporation Wastewater Treatment Facility
C. Violation - BOD
The seed correction factor must be in the range of
0 . 6 mg/l to 1. 0 mg/1: Records indicate the seed -
correction factor for this analysis was below this
range.
Requirement: STANDARD METHODS, 18TH Edition, Method
52108. 4d 2 .
d. Violation - BOD
The dilutions used for seed control have been too low
to yield proper D.O. depletion and residual
requirements.
Requirement: STANDARD METHODS, 18TH Edition, Method
5210B. 5 - requires that seed controls and samples must
have at least 2.0 mg/l D.O. depletion plus a residual
D.O. of 1. 0 mg/1.
e. Violation - Method Quality Control requirements
not being met must be noted on the discharge monitoring
report - (DMR) . "
Requirement: 15A NCAC 2H.0805 (a) (7) & (a) (7) (D)
4 . RECORDS KEEPING:
Laboratory record keeping was consistent with good
laboratory practice. Records were complete and. well
detailed.
5 . QUALITY CONTROL :
Effluent samples split with the BASF laboratory showed
the following comparison:
BASF LABORATORY DWQ LABORATORY
BODS 17. 9 mg/l 26 .2 mg/1
TSS 85 mg/1 102 mg/l
a
Non-eff leunt sample split only for comparative purposes
FECAL COLI 520/100 ml 270/100 ml

Page 6
1999 PAI Report
BASF Corporation. Wastewater Treatment Facility .
6 . DATA HANDLING & REPORTING :
A review of discharge monitoring report (dmr) and
supporting data for August, October, and November,
1998, showed no data entry or dmr transfer problems .The facility was transcribing data in a satisfactory
manner.
i

PAI RATING SCALE
Ratinc _ General Description
A The facility has no problems with flow monitoring,
sampling, analyses or data calculating and reporting
procedures. The overall self-monitoring program and
the quality and reliability of the data reported to
state/federal agencies are excellent. The general
operation of the entire facility is also very good. -
B The facility has a few minor problems in one or more
areas of flow monitoring, sampling, analyses or data
calculating and reporting procedures. Examples include
infrequent calibration of flow monitoring equipment,
improper refrigeration of samples, slight discrepancies
in oven or incubator temperatures and not keeping
thorough records. The self-monitoring program is good
and the problems have no major impact on data
reliability. The overall operation of the facility is
very good.
C The facility has a major or several minor problems with
flow monitoring, sampling, analyses or data calculating
and reporting procedures. Examples include
malfunctioning flow monitoring equipment, improper
sampling site, not dechlorinating fecal coliform samples,
unacceptable oxygen depletions and improper seed
correction factors in BOD analyses. The .problems noted
at the facility cause the reliability of some of the data
to be questionable. The general operation of the overall
facility is good.
D There are major problems with flow monitoring, sampling
analyses or data calculating and reporting procedures.
Examples include estimating flow, collecting samples at
wrong locations, using improper glassware or equipment,
malfunctioning laboratory equipment, poor laboratory
techniques, or errors in data calculations . The problems
cause the reliability of the self-monitoring data to be
highly questionable. The overall operation of the
facility is fair.
E Severe problems withflow monitoring, sampling, analyses
or data calculating and reporting procedures cause the
self-monitoring data to be unreliable. Examples include
no flow monitoring capabilities, wrong sampling
frequencics and procedures, using unacceptable analytical
techniques or fabrication of information. The self-
monitoring program and the general operation of the
facility is poor.

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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
i DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
r WATER QUALITY SECTION
r.mE March 17, 2000
OR
w
W
R NAN CERTIFIED MAIL
EkTA TARY
RETURN RECEIPT REQUESTED
Mr. Jack A. Dellinger, PhD
General Manager
BASF CORPORATION
Sand Hill Road
Enka, North Carolina 28728
s.E
SUBJECT: Notice of Violation and Assessment
of Civil Penalty for Violations of N.C.
General Statute 143-215.1(a)(6)
and NPDES Permit NC0000299
4M BASF CORPORATION
Case No. LV 00-086
Buncombe County
a
Dear Mr. Dellinger:
AThis letter transmits a Notice of Violation and assessment of civil penalty in
:'r, the amount of 323.11 ($250.00 civil penalty+ $ 73.11 enforcement costs)
f against BASF Corporation.
This assessment is based upon the following facts: a review has been
Tz=`— E T ,: conducted of the discharge monitoring report (DMR)submitted by BASF
Corporation for the month of December, 1999. This review has shown the
subject facility to be in violation of the discharge limitations and/or monitoring
requirements found in NPDES Permit NC0000299. The violations, which occurred
in December, 1999 are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that BASF
Corporation violated the terms, conditions or requirements of NPDES Permit
NC0000299 and N.C.G.S. 143-215.1(a)(6) in the manner and extent shown in
Attachment A. A civil penalty of not more than twenty-five thousand dollars
($25,000.00), in accordance with the maximums established by N.C.G.S. 143-
215.1(a)(2), may be assessed against a person who violates the terms,
conditions or requirements of a permit required by N.C.G.S. 143-215.1(a ._ .....
7-
INTERCHANGE BUILDING, 68 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 29aO1-2414
- PHONATE.-261-E... FAX...-261-64E2
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYEE - 60% .Ec 00/10% POST mNDUMEP Y—ER

Based upon the above findings of fact and conclusions of law, and in
accordance with authority provided by the Secretary of the Department of
Environment and Natural Resources and the Director of the Division of Water
Quality, I, Forrest R. Westall, Division of Water Quality Regional Supervisor for the
Asheville Region, hereby make the following civil penalty assessment against
BASF Corporation:
$ -0- For 1 of the 1 violation of G.S. 143-
215.1(a)(6) and NPDES Permit No.
NC0000299, by discharging waste into the
waters of the State in violation of permit
monthly average effluent limits for TSS
$ 250.00 For 1 of the 1 violation of G.S. 143-
215.1(a)(6) and NPDES Permit No.
NC0000299, by discharging waste into the
waters of the State in violation of permit daily
maximum effluent limit for TSS
$ 250.00 TOTAL CIVIL PENALTY, which is 1.0%
percent of the maximum penalty authorized
by G.S. 143-215.6A
$ 73.11 Enforcement costs.
$ 323.11 TOTAL AMOUNT DUE
8

Pursuant to G.S. 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 G.S. 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 non-compliance;
(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.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of
Environment and Natural Resources (do not include waiver form).
Payment of the penalty will not foreclose further enforcement action
for any continuing or new violation(s). Please submit payment to the
attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit a written request for remission or mitigation including a detailed
9

2. Submit a written request for remission or mitigation 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
must be accompanied by 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 and stipulation form and a detailed statement, which you
believe establishes whether:
(a) one or more of the civil penalty assessment factors in
G.S. 143B-282.1(b)was 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;
(a) payment of the civil penalty will prevent payment for
the remaining necessary remedial actions.
Please submit this information to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for
remission must be submitted in writing. The Director of the Division
of Water Quality will review the information during a bimonthly
enforcement conference and inform you of his decision in the matter
of the remission request. His response will provide details regarding
case status, directions for payment and provision for further appeal
of the penalty to the Environmental Management Commission's
i
-10-

Committee on Civil Penalty Remissions. Please be advised that the
Committee cannot consider information that was not part of the
original remission request considered by the Director and therefore,
it is very important that you prepare a complete and thorough
statement in support of your request for remission.
OR
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, 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
and
Mail or hand-deliver a copy of the petition to
Mr. Dan McLawhorn, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Failure to exercise one of the options above within th v days, 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.
Please be advised that any continuing violation(s) may be the subject of a
new enforcement action, including an additional penalty. If you have any
questions about this civil penalty assessment, please contact Mr. Max L. Haner of
the Asheville Regional Office at 828/251-6208.
a 1-

3 i7 Dd
(Date) Pbrrest R. Westall
Water Quality Regional Supervisor
Asheville Region
Division of Water Quality
ATTACHMENTS
cc: Max L. Haner w/attachments
Compliance/Enforcement File w/attachments
Central Files w/attachments
L
-12-

ATTACHMENT A
ENTITY
NPDES Number NC0000299
Case Number LV 00-086
Limit Violations, December, 1999
Monthly Average Limit Violations
Parameter Reported Value Limit Units
TSS 242 .6 209.0 - #/Day
Daily Maximum Limit Violations
Parameter Date Reported Value Limit Units
TSS 12-15-99 701.0 565. 0 #/Day
Effluent Monitoring Violations, December, 1999
Required Monitoring
Parameter Monitoring Frequency Location
Insufficient Values
Parameter Date Number of Insufficient Values
-3-

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
-
COUNTY OF BUNCOMBE -
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
BASF CORPORATION ) STIPULATION OF FACTS
PERMIT NO. NC0000299 ) FILE NO. LV 00-086
Having been assessed civil penalties totaling $323 . 11 for
violation(s) as set forth in the assessment document of the Division
of Water Quality dated March 17, 2000, 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.
This the day of 2000 .
BY
I
ADDRESS
TELEPHONE

DIVISION ;`1 WATER QUALITY - CIVIL PENALT ' 1$ESSMENT
Violator: BASF CORPORI/ATION rr
County: BUNCOMBE
Case Number: LV 00-086
ASSESSMENT FACTORS
1) The degree e�nd extent of harm to the natural resources of the State, to the
public heyith, or to private property resulting from the violation;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
2) The durat n and gravity of the violation;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
3) The sffec on ground or surface water quantity or quality or on air quality;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
4) The coat o rectifying the damage;
not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
5) The amount of money saved by non-c liance;
( ) not significant ( moderately significant ( ) significant
( ) very significant ( ) extremely significant
6) Whether the iolation was committed willfully or intentionally;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
7) The prior record of the violator in complying or failing to comply with programs
over whic a Environmental Management Commission has regulatory authority, and
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
8) The cost the State of the enforcement procedures.
( not significant ( ) moderately significant ( ) significant
( ) very significant-)( ) extremel
// l si if'cant
3
Date F eat R. Wastall, Water-Quality Supervisor
eheville Regional Office
REMISSION FACTORS
( ) Whether one or more of the civil penalty assessment factors were wrongly applied
to the detriment of the petitioner;
( ) Whether the Violator promptly abated continuing environmental damage resulting
from the violation;
( ) Whether the violation was inadvertent or a result of an accident;
( ) Whether the violator had been assessed civil penalties for any previous
violations; and
( ) Whether payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Date Kerr T.Stevens, Director
Division of Water Quality
-2-

DMR REVIEW RECORD
Facility: BASF CORPORATION Permit/Pipe No. : NC0000299 Month/Year: 12/99
Monthly Average Violations
Parameter Permit Limit DMR Value % Over Limit
TSS 209 #/Day 242 . 6 #/Day 16. 1 %
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value %OverLimit
12-15-99 TSS 565 . 0 #/Day/ Daily Max 7014/Day 24 . 1%
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported 4 of violations
Other Violations
Completed by: Max L. Haner Date: March 16, 2000
-4-

DMR REVIEW RECORD
Facility: BASF CORPORATION Permit/Pipe No. : NC0000299 Month/Year: 12/99
Monthly Average Violations
Parameter Permit Limit DMR Value % Over Limit
TSS 209 #/Day 242 . 6 #/Day 16. 1 %
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value %OverLimit
12-15-99 TSS 565 . 0 #/Day/ Daily Max 701#/Day 24 . 1%
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported # of
Violations
Other Violations
Completed by: Max L. Haner Date: March 16, 2000
5

LAW
LAWGIBB Group Member
February 2,2000
Mr. Kay Crowder
BASF Corporation
Sand Hill Road
Enka. North Carolina 28728
Subject: Wastewater Treatment System Effluent Discharge Weir Calibration Confirmation
BASF Corporation
Enka, North Carolina
LAW Project 30300-0-0656
Dear Mr. Crowder:
Law Engineering and Environmental Services, Inc. (LAW) is pleased to submit this report of our
assessment of the effluent flow, measuring device used at your Enka facility. The purpose of our
services, as described in the attached report, was to observe the method of flow measurement and
equipment calibration for the wastewater treatment system discharge weir. Based on our
observations and calculations, the calibration method used by BASF appears to be complete and
accurate.
We appreciate the opportunity to provide our professional services on this project. Please contact
us at [phone] if any questions arise or if we may be of further service.
Sincerely,
LAW ENGINEERING AND ENVIRONMENTAL SERVICES,INC.
L+),,ua UJar
Matthew E. Wallace, P.E. David Wallace, P.E.
Senior Engineer Principal Water Resources Engineer WffR KRMISSION
Registered.NC #24933 Registered, NC#20055
MEW/JDW:mew
attachment
IAW Engineering and Environmental Services. Inc.
1308-C Patton Avenue
Asheville, NC 28806
828 252-8130•Fax [phone]

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor NCDENR
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 26, 1999
RAY ACKERMAN
BASF CORPORATION ENKA PLANT
SAND HILL ROAD
ENKA,NC 28728
SUBJECT: Revised Whole Effluent Toxicity Enforcement Policy
Effluent Toxicity Testing .
NPDES Permit No. NC0000299
BUNCOMBE County
RAY ACKERMAN:
Based on recent discussions with EPA Region IV, the Division of Water Quality (DWQ) is further
modifying its Whole Effluent Toxicity (WET) Enforcement Policy. The primary difference will be
separation of DWQ's application of civil penalties from compliance determinations. Any WET test result
that does not achieve compliance with the NPDES permit limit will be considered a violation of the
permit and the pennittee will be sent, at minimum, a Notice of Violation. The Division's new Whole
Effluent Toxicity Enforcement Policy will apply to whole effluent toxicity monitoring initiated on
or after September 1,1999.
Draft NPDES permits sent to public notice after 7/1/99 will contain chronic toxicity test condition
language which specifies follow-up multiple concentration toxicity testing upon any single quarterly test
failure. The first test of the quarter (three-month monitoring period defined by the permit) may be
conducted either as either a pass/fail test or as a multiple concentration (ChV) test If the pass/fail test
fails or if the chronic value is lower than the permit limit,then a NOV is issued and at least two multiple
concentration tests (one per month) are required over the following two months. NOVs will be generated
for each failure to meet the permit limit.As many analyses as can be completed timing the quarter will be
accepted. -
Permittees with NPDES permits which contain `old"chronic toxicity pass/fail testing language will have
the OPTION to respond to any single quarterly toxicity test failure with follow-up multiple concentration
toxicity testing or single concentration toxicity testing. The enclosed toxicity test condition language will
be incorporated in the NPDES permit upon permit renewal and/or permit modification. Initiation of
multiple concentration toxicity testing after any single quarterly failure will influence the Division's
enforcement response. Perndttees will be issued a NOV for any test result that does not achieve
compliance with the permit limit. A civil penalty will be assessed for each Qua rter of toxicity
noncompliance based on the arithmetic average of ChV s submitted for the remaining two months of the
quarter.
<gr-„
Musing Address; Telephone(919)Y33-2136 Location:
1621 Mail Service Center Fax[phone] 4401 Reedy Creek Road
Raleigh,NC 21699-1621 State Courier k52-01-00 Raleigh,NC 27699-1621
An Equal opwaunity Affirmative Action Employer 50%racycleNl0%post avnaumer paper

2
Important WET Enforcement Policy items are:
I. CHRONIC TOXICITY TESTING
• The first test of the quarter can be conducted as either a pass/fail test or a
chronic value(ChV)test.
• If the pass/fail test fails or if the ChV is lower than the limit, then a NOV is
issued and at least two ChV tests (one per month)will be conducted over the
following two months.As many analyses as can be completed will be
accepted.
• A NOV will be issued for any test result failing to meet the permit limit.
• Any civil penalty assessed will be based on performance over a quarter.
• NPDES Permits containing chronic toxicity pass/fail testing will be modified
upon permit renewal to include the new permit language.
II. ACUTE TOXICITY TESTING �r
• A NOV will be issued for each acute limit violation.
• A civil penalty will be assessed for any two consecutive acute limit
violations.
Note that no changes have occurred in DWQ's enforcement responses to acute limit noncompliances
since the May 13'mailing.
Choosing to respond to a chronic "fail' result with a pass/fail test instead of conducting multiple
concentration toxicity testing during the second and third months of the calendar quarter will
result in enforcement for single concentration test results which do not meet chronic toxicity
permit limitations.
As in the past, if you are unable to consistently comply with your toxicity permit limitation, you may
notify your respective Regional Office to discuss the possibility of entering into a Special Order by
Consent(SOC). The SOC provides conditional compliance for permit parameters that the facility can not
consistently comply with and may be issued in situations where facility operation and maintenance are
not in question. If a SOC is signed by the permittee/DWQ and contains toxicity as a noncompliant
parameter, you will be required to: conduct a Toxicity Reduction Evaluation (TRE), submit quarterly
TRH progress reports, and reduce/eliminate effluent toxicants to acceptable levels.
Additional explanation of key enforcement initiatives can be located on the Division's Aquatic
Toxicology Unit web page at http://esb.ehm.state.nc.us/ATU.html.
If you have any questions,please contact me or Mr. Kevin Bowden at(919)733-2136.
Sincerely,
7nCat
Matt Matthews,Supervisor
Aquatic Toxicology Unit
cc: Regional Office Supervisor, ARO
Facility Files
Central Files
Enclosure

NORTH' CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
r ASHEVILLE REGIONAL OFFICE
March 7, 2000
IS JRR,
239
.y H-.
i� OCMAN. -',�y- MR. RAY ACKERMAN
.. '. ETARY 13ASF CORP - FIBERS DIV
I.
SAND HILL ROAD
IP +6P ENKA, NC 28728
y
SUBJECT: Wastewater/Groundwater Laboratory Certification
{ Dear Mr. Ackerman:
Enclosed are inspection checklists to be used for the
r:lyy ,ey ' , upcoming inspection scheduled for March 23, 2000, at approximately
8:45 A.M. Excluding the data review sections and any sections that
specify they are to be completed by the auditor, please complete
� 9,kpzdt ) b} or have your analysts complete, each checklist. Any checklists for
4 Ilia ry .i) parameters that no samples have been analyzed since the last
inspection do not need to be filled out. Any checklists that your
laboratory are unable to complete, or any specific items that. you
+� do not understand, will be completed during the inspection.
6
Please submit the original checklists to the inspector(s) on
the first day of the inspection. Copies are not acceptable.
Contact us at 828/251-6208 ext. 285 if you have any
questions.
' d LRLRgF 4k-:i
IA #� g sY6b1 d'giv ..
sincerely,
Gary Francies
E +Av%-< Laboratory Section
;1i"unxut4 .e*
��g M
y'4 Enclosures
cc: Marily Deaver
James W. Me er
INTERCHANGE BUILDING, 88 WOODFIN PLACE, ASHEVILLE, NORTH
b20CR pFAXAR 22RR-8EOR,I-Z4,4
AN EQUAL OanoaiuNlTV /AFFIRMATIVE ACTION EMPLOYER - 60% RECYCLED/109 POST-DGN¢UMER PAPER rRd93Y8'6$tmtsM&4

State of North Carolina IVA
Department of Environment �,/ •
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor NCDENR
Bill Holman, Secretary
NO�TFJc GPtip61NA.QEPARTMT
Kerr T. Stevens, Director E ON E A A 7R SH•PS RFOES
February 10, 2000 �d °
RAY ACKERMAN �� � ��� I ����� ��•• •
BASF CORPORATION p .f
b n
SAND HILL ROAD 6Vltlff i� "� �Po
ENKA, NC 28728
Subject: Renewal of NPDES Permit NC0000299
ENKA PLANT
BUNCOMBE County
Dear Pernittee:
The subject permit expires on September 30, 2000. North Carolina Administrative Code (15A NCAC
211.0105(e))requires that an application for permit renewal be(fled at least 180 days prior to expiration of the
current permit.
To satisfy this requirement,your renewal package must be sent to the Division postmarked no later than
April 3, 2000. Failure to request renewal of the permit by this date will result in a civil assessment of at least
$250.00. Larger penalties may be assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after September 30, 2000 (or if continuation of the permit is
desired), the current permit must be renewed. Operation of wastewater treatment works or continuation of
discharge after September 30, 2000 would violate North Carolina General Statute 143-215.1 and could result in
assessment of civil penalties of up to$25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact Robert
Farmer of the Division's Compliance Enforcement Unit at(919) 733-5083, extension 531. You may also contact
the Asheville Regional Office at(828) 251-6208 to begin the rescission process.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must
submit with the permit renewal application. If you have any questions, please contact me. My telephone
number, fax number and E-mail! address are listed at the bottom of this page.
Sincerely,
( k '
Charles H.Weaver,Jr.
NPDES Unit
cc: Central Files
Asheville Regional Office,Water Quality Section
NPDES File
1617 Mail service Center,Raleigh,North Carolina 27699-1617 919733-5083,extension 511 (f Nj91973307i9
VISIT us ONTHE INTERI hUx//h2o.enr.slat000cs1NPDEs [e-mail]

rl
NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
The following items are REQUIRED for all renewal packages:
❑ A cover letter requesting renewal of the permit and documenting any changes at the
facility since issuance of the last permit. Submit one signed original and two copies.
❑ The completed application form (copy attached), signed by the permittee or an Authorized
Representative. Submit one signed original and two copies.
❑ If an Authorized Representative (see Part II.B.1 Lb of the existing NPDES permit) prepares
the renewal package, written documentation must be provided showing the authority
delegated to the Authorized Representative. !
❑ A narrative description of the sludge management plan for the facility. Describe how
sludge (or other solids) generated during wastewater treatment are handled and
disposed. If your facility has no such plan (or the permitted facility does not generate
any solids), explain this in writing. Submit one signed original and two copies.
The following items must be submitted ONLY by Industrial facilities
discharging process wastewater:
❑ Industrial facilities classified as Primary Industries (see Appendix A to Title 40 of the
Code of Federal Regulations, Part 122) must submit a Priority Pollutant Analysis (PPA) in
accordance with 40 CFR Part 122.21. If the PPA is not completed within one week of
April 3, 2000, submit the application package without the PPA. Submit the PPA as soon
as possible after April 3, 2000.
The above requirement does NOT apply to municipal or non-industrial
facilities.
cccticctititiitititi
PLEASE NOTE:
Due to a change in fees effective January 1, 1999, there is no renewal fee
required with your application package.
I
TTTrrcrrr rcc
Send the completed renewal package to:
Mr. Charles H. Weaver, Jr.
NC DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality L
James B. Hunt,Jr., Governor N D EN R
Wayne McDevitt, Secretary
Kerr T. Director NORTH CAROLINA DEPARTMENT OF
Stevens,> ENVIRONMENT AND NATURAL RE50U\5
August 2, 1999 , "' W:•"�
Mr. Jack A. Dellinger,PhD9^y, . 0
General Manager '.,y .� �'�\
BASF Corporation
Sand Hill Road
Enka,NC 28728
Subject: Payment Acknowledgment ^ ,'•
Civil Penalty Assessment _
NPDES Permit Number NC0000299
BASF Corporation
Buncombe County
Case Number LV 99-232
0
Dear Mr. Dellinger:
<o
This letter is to acknowledge receipt of check No.4095954 in the amount of$323.11
received from you on July 15, 1999.
This payment satisfies in full the civil assessment levied against BASF Corporation and this
case has been closed. Payment of this penalty in no way precludes future action by this Division for
additional violations of the NPDES Permit.
If you have any questions,please feel free to contact Vanessa Manuel at(919)733-5083,
extension 532.
i
Lent
Complian Unit
cc; Raleigh Regional Office
Enforcement/Compliance Files
Central Files
1617 Mail Service Center, Raleigh, N.C.276 99-1 61 7 Telephone [phone] FAX [phone]
An.Equal Opportunity Affirmative Action Employer 50%recycled/10%postconsumer paper

µ
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
st ° DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
June 25, 1999
(4
AA .IAMEBB MUNTJR
jOVERM
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
"aR " Mr. JackA. Dellinger, PhD
3 General Manager
BASF Corporation
Sand Hill Road
13 Enka, North Carolina 28728
SUBJECT: Notice of Violation and Assessment
( of Civil Penalty for Violations of N.C.
General Statute 143-215.1(a)(6)
�� and NPDES Permit NC0000299
BASF Corporation
* ° ` Case No. LV 99-232
>� )R Buncombe County
f Dear Mr. Dellinger:
This letter transmits a Notice of Violation and assessment of civil penalty
in the amount of $ 323.11. ($250.00 civil penalty + $ 73.11 enforcement costs)
1 against BASF Corporation.
Z This assessment is based upon the following facts: a review has been
a conducted of the discharge monitoring report (DMR) submitted by BASF
mx Corporation for Total Suspended Residue for the month of March, 1999. This
review has shown the subject facility to be in violation of the discharge
J Y 9
limitations and/or monitoring requirements found in NPDES Permit NC0000299.
The violations which occurred in March, 1999 are summarized in Attachment A
41 to this letter.
Based upon the above facts, I conclude as a matter of law that BASF
Corporation violated the terms, conditions or requirements of NPDES Permit
NC0000299 and N.C.G.S. 143-215.1(a)(6) in the manner and extent shown in
Attachment A. Pursuant to N.C.G.S. 143-215.6A(a)(2), a civil penalty of not
more than ten thousand dollars ($10,000.00) may be assessed against a
person who violates the terms, conditions or requirements of a permit required
t
INTERCHANGE BUILDING, 8B WOOOFIN PLACE,..... I....LLE, NC 28..I... E
P%....9EB-D/1 % P FAXBP B-EE11816E
"' AN fiOVPI OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER - 80% PECYCL¢O/10% pO9T CON9V MER PPPER

Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural
Resources and the Director of the Division of Water Quality, I, Forrest R. Westall, Division of
Water Quality Regional Supervisor for the Asheville Region, hereby make the following civil
penalty assessment against BASF Corporation
$ -0- For 1 of the 1 violation of G.S. 143-215.1(a)(6) and
ES NPD Permit No. NC0000299, by discharging waste
into the waters of the State in violation of permit
monthly average effluent limits for Total Suspended
Residue.
$ 250.00 For 1 of the 1 violations of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0000299, by discharging waste
into the waters of the State in violation of permit daily
maximum effluent limits for Total Suspended Residue .
$ -0- For 1 of the 1 violations of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0000299, by discharging waste
into the waters of the State in violation of permit daily
maximum effluent limits for Fecal Coliform .
$ 250.00 TOTAL CIVIL PENALTY, which is 0.83% percent of the
maximum penalty authorized by G.S. 143- 215.6A.
i
$ 73.11 Enforcement costs.
$ 323.11 TOTAL AMOUNT DUE
i
k
-2-

Pursuant to G.S. 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 G.S.
143B-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 non-compliance;
(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.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty
will not foreclose further enforcement action for any continuing or new
violation(s). Please submit payment to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
OR
2. Submit a written request for remission or mitigation 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
3

hearing, such a request must be accompanied by 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 and
stipulation form and a detailed statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-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:
Point Source Compliance/Enforcement Unit
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0636
Please note that ALL information presented in support of a request for remission
must be submitted in writing. The Director of the Division of Water Quality will
review the information during a bimonthly enforcement conference and inform
you of his decision in the matter of the remission request. His response will
provide details regarding case status, directions for payment and provision for
further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions. Please be advised that the Committee
cannot consider information_that was not part of the original remission request
considered by the Director and therefore, it is very important that you prepare a
complete and thorough statement in support of your request for remission.
OR
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, 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
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
-4-

n
and
Mail or hand-deliver a copy of the petition to
Mr. Dan McLawhorn, General Counsel
Department of Environment and Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Failure to exercise one of the options above within the days, 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.
Please be advised that any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty. If you have any questions about this civil
penalty assessment, please contact Mr. Max L. Haner of the Asheville Regional Office at
828/251-6208.
S
(Da ) p6rrest R. Vestal] '
Water Quality Regional Supervisor
Asheville Region
Division of Water Quality
ATTACHMENTS
cc: Max L. Haner w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
-5-

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT C-
AND NATURAL RESOURCES
COUNTY OF BUNCOMBE
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
BASF CORPORATION ) STIPULATION OF FACTS
PERMIT NO. NC0000299 ) FILE NO. LV 99 - 232
Having been assessed civil penalties totaling $323 .11 for
violation(s) as set forth in the assessment document of the
Division of Water Quality dated June 25, 1999, 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.
This the day of 1999 .
BY
ADDRESS
TELEPHONE
I'

ATTACIRAENT A
ENTITY
NPDES Number NC0000299
Case Number IV 99-232
Limit Violations. MARCH, 1999
Monthly Average Limit Violations
Parameter Reported Value Limit Units
TSS 240 209 #/Day
Daily Maximum Limit Violations
Parameter Date Reported Value Limit Units
TSS 3/10/99 821 565 #/DAY
Fecal Coliform 3/23/99 510 400 Colonies/100 ml
Effluent Monitoring Violations, MARCH 1999
Required Monitoring
Parameter Monitoring Frequency Location
Insufficient Values
Parameter Date Number of
Insufficient values

DIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT
Violator: BASF CORPORATION
County: BUNCOMBE
Case Number: IV 99 - 232
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the
public he th, or to private property resulting from the violation;
(g not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
2) The dura on and gravity of the violation;
( -Olt significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
3) The effect on ground or surface water quantity or quality or on air
quality;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
4) The co .lf rectifying the damage;
(st not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
5) The amount of money saved byn-compliance;
( ) not significant ( moderately significant ( ) significant
( ) very significant ( ) extremely significant
6) Whether t e violation was committed willfully or intentionally;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
7) The prior record of the violator in complying or failing to comply with
programs ov r which the Environmental Management Commission has regulatory
authority• and
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
B) The cost to the State of the enforcement procedures.
Date Fp' rest R. W s Water Qua. ity Supervisor
ahe.A ville Regional Office
REMISSION FACTORS
( ) Whether one or more of the civil penalty assessment factors were wrongly
applied to the detriment of the petitioner;
( ) Whether the violator promptly abated continuing environmental damage
resulting from the violation;
( ) Whether the violation was inadvertent or a result of an accident;
( ) Whether the violator had been assessed civil penalties for any previous
violations; and
( ) Whether payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Date Kerr T. Stevens, Director
Division of Water Quality

DMR REVIEW RECORD
Facility: BASF CORPORATION Permit/Pipe No. : NC0000299 Month/Year: 3 99
Monthly Average Violations
Parameter Permit Limit DMR Value "s Over Limit
Total Suspended Residue 209#/Dav 240#/Dav 15
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR. Value %Over Limit
3-10-99 TSS 565 #/Dav/Daily Max 821 #/Dav 45%
3-23-99 Fecal Coliform 400/100 ml/Daily Max 510/100 ml 28%
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported # of Violations
Other Violations
Completed by: Max L. Haner Date: June 25 1999

AUG-23-1099 MON 05: 17 PM D JI. WATER QUALITY FAX NO, U1197339950 P.
State of North Carolina
Department of Environment
and Natural Resources •
Division of Water Quality,
James S. Hunt, Jr., Governor D, E N VI
Wayne McDevitt, Secretary �
KarrT. Stevens, Director
Division of Water Quality
Environmental Sciences Branch
4401 Reedy Creek Road
Raleigh, N,C, 27607
FAX:[phone]
FAX TO: �° FAX NUMBER: Sag.
FROM: m@ ISSq
PHONE: MC,(L
NO. OF PAGES INCLUDING THIS SHEET: S

AUG-23-1999 MON 05: 18 PM DL WATER QUALITY FAX NO. g197339059 P. 02
DIVISION OF ENVIRONMENTAL MANAGEMENT
July 8, 1994
MEMORAND[JM:
To: Dave Goodrich
Through: Matt Matthews Yu ri" µp..�'
From: Melissa RosebmckO
Subject: Town of White Lake WWTP
Use of Rerbicide
NPDES No, NC0023353
Bladen County
On behalf of Town of White Lake W WTP,Michael Wicker has verbally requested that we
review the potential for aquatic toxicity regarding the proposed use of Sonar herbicide in the facility's
multi-cellular facultative lagoon. Mr.Wicker provided me with the appropriate herbicide name, .fWC,
minimum stream flow,NPDES number, and average daily discharge values. The Public Works
Director, Bill Stafford, provided data(through several phone conversations) conceming the proposed
dosage rate of the compound, lagoon surface area and depth,and retention time. I acquhed toxicity and
degradation data from the chemical manufacturer(SePRO Corp.) and Dr. Stratford Kay (aquatic weed
specialist at NCSU).
Mr. Stafford stated (phone conversation, 7/7/94)that the lagoon ranges from one to four feet
deep and that the entire lagoon is 4.42 acres in size. We have utilized an average depth of two Peet in
calculating the volume of the lagoon. He also said that the lagoon would be treated only around its
perimeter at a frequency of once per month.
Calculations summarized on the accompanying worksheet predict that the use of SONAR
herbicide at the proposed dosage rate and discharge conditions will not result in a toxic impact to aquatic
life in the receiving stream. Therefore,the use of this product as a herbicide at Town of White Lake
W WTP is deemed a=ptable.
If there are questions regarding this review please contact me at(91.9)733-2136.
Attaclunents
cc; Michacl Wickcr•PRO
Steve Tedder
Central files

AUG-23-1999 MON 05:18 PM D� WATER QUALITY FAX N0, �97339959 P. 03
Town of White Lake WWTP BIOCIDE WORKSHEET
PERMIT#: N00023353
RECEIVING STREAM: Colly Creek
7010 (cfs): 0.00
I.W.C.%: 100.00
PRODUCT: SONAR A.S.
ACTIVEINGREDIENT: 47.7% fltlrldone
HALF LIFE(DAYS): 20.00 STEADY STATE DISC CONC: 0.0448
LC50 OF SELECTED TOX DATA(MGfL)' 8.18 DEGRADATION FACTOR: 0.243
DECAY RATE: 0.0345 APPLICATION FACTOR: 0.010
DOSAGE RAT (GRAMS0AY):^ 118.60
AVG DAILY DISCHARGE(MGD)' 0.6 INSTRFAM BIOCIDECONG: 0.0448
VOLUME OF SYSTEM (MIL. GAL'S)::'** 2.88 REGULATED LIMITATION: 0.0818
IPASSIFAIL: PASS
Daphnis, 100% active formulation LC50=3.9, 47.7% active formulation LC50=8.18
4.0 oz. of product added per day with a minimum retention lime of 3.94 days
4.42 acres X 2 ft. deep � 8.84 acre feet
8.64 acre feet X 43,560 sq. feet = 385.070.4 cubic feel
885,070.4 cubic feet X 7.46 (conversion factor) = 2,880,526.6S6 gallons
2,880,526.636 gallon$ = 2.88 millon gallons
Half-life (hours) 480
Shut Off lime (hours) 94,56
Initial Amount 135.95
Final Amount 118.80

AUG-23-1999 MON 05: 19 PM DIy, WATER QUALITY FAX NO. 1Q197339959 P. 04
.Specimen Label
First Aid:
$e^nO It In eyes: Flush eyes or skin with plenty of water.
+1, Get medical attention if irritation persists.
If swallowed: Gall a physician or poison control
11930 N(,il,m.erdm„so-.m,suue xoo center,drink one or two glasses of water and induce
Camel,Indi, ,,46032 000
P1y,1,.e:i3l7)6808282r"vtm7)580axao vomitIngby touching back of throat with tit iDo
not induce vomiting or give anything by mouth to an
Cunconscious Remove.
JIf Inhaled!give m to fro,h r r ing,give artificial respiration, preferably mouth-to-
mouth. Get medical attention.
Environmental Hazards
Follow use directions carefully so as to minimize
adverse effects on nontarget organisms. In order to
avoid impact on threatened or endangered aquatic
plant or animal species, users must consult that
Specialty Herbicide State Fish and Game Agency or the U.S. Fish and
Wildlife service before making applications.
A herbicide for mans ement of Do
g Ponta shwaers.water when
shrusingowingi - `
aquatievegetationinfreshwater mentwashwaters. 7reesandshrubsgrowinyin
ponds, lakes, reservoirs, drainage water treated with sonar A.S. mayoccasionally
canals and irrigation canals. develop chlorosis. Do not apply in tidewatedbrack- o
ish water."
Active ingredient:
fluridone:ne: 1-methyl-3-phenyl-5-[3-(trifluoromelhyq Lowest rates should he used in shallow areas where
phenyl]-4(l1i pyridinone..................... 41.7% the water depth is considerably less than theaver-
inedingredients....................................... 58.31/6 age depth of the entire treatment site,for example,
Total................................................--.....100.0% shallow shoreline areas.
Contains 4 pounds active ingredient per gallon.
Notice: Read the entire label before using. Use
EPA Reg, No. 62719-124 only according to label directions. before buying
EPA Est.37429-GA-01 or using this product, read "Warranty
Net Contents 1 gal Disclaimer"and "Limitation of Remedies" else-
where on this label.
Precautionary Statements In case of emergency endangering health or the C4
Hazards to Humans and Domestic Animals: environment involving this product,call collect 517-
Keep Out of Reach of Children 636-4400
CAUTION PRGCAUCION: Specialty Chemical; Keep away from food, feed-
Precoucion al usuario: Sf used no lee ingles, no stuffs and water supplies. Do not ship or store with
use sale producto hssta cuts la etiqueta le haya sido food,feeds,drugs or clothing.
axpticada ampliamente.
Harmful If Swallowed,Absorbed Through Skin,
Or If Inhaled
Avoid breathing of spray mist or contact with
skin, eyes or clothing. Wash thoroughly with
soap and water after handling.Wash exposed
,
clothing before reuse.
i

AUG-23-1999 MON 05: 19 PM D`CL WATER QUALITY FAX NO. '0'97339959 P. 05
vascular Aquatic Plants Not Controlled by Sonar Average Water Depth quarts of Sonar A.S.per
A.S.: of Treatment Site Feet Treated Surface Acre
1 02-0.4
Algae(Chara and Nirella)" 2 0.4 011
Amorloan frogbit(Limnobium spongia) 3 0.6-1.2
Arrowhead(Ssm11arlaepP.) 4 0.0-1.6
Hacopa(Samoa SpP.) 5 1,0-20
Big tloallngheau,Banana Lily(Nymphbltles anUadca) 6 1,2-2`i
Bulrush(Screpussple.) 7 IA-2 8
Floating waterhyaclNh(Flchhomia crasslpes) B L5-32
Mafdencano(Panicum hemilomon) 9 1.0.3 6
Ficocielweed,lanceleal(Ponledodal Cordaro) 10 2.0-4.0 W
push(June Us Spa)
Tamgra55,America,)Celoeoss(✓olllsnond antariosl Use the higher rate within the ralararge wh a re file ro is a d anso wood
Walerlettuce(Pisfia Veatiotes) mass or when treating more difficult to control spaces.
Water pennywort(Hydrocotyle umbelohi
Application Rate Calculation-ponds,Lakes and
Mixing and Application Directions Reservoirs
The aqual)c plants present inthc treatment site should befder ied The amountof Sonar A.S.to be applied loprovide lire desired pram
prior to apprita tie n to determine their susceplfbfl fly to Sonar A.S.It is concentration of active ingredient in treated water may be calculate it as
important to determine the area(acres)to be treated'and lie average follows:
depth in order to seel act tha proper application rate.Do not exceed the if
maximum labe led rale(o r a given less lm a at site per an nu at g rowth quarts of Sonar A.S.required p,r true lad a,face acro-Average
" cycle water depth of treatment Site(feet)x Desired ppm concentration of
active ingredient x 2.7
Shake Sonar A.S.well oaten using.Add the recommended amount
of Sonar A.S.to we ter in the spray to nit duri ng in a Win g e partition, For example,the quarts pe r acm of Son at A.S.required to provide
Agitate while filing and during so raying.Surl or subsurface applica- aconcentratton of 0.075 ppm of active lngradion t in water With an
tion of the spray can be made with converlional spray equipment. average depth of 5 feet is calculated as follows-
Sonar A.S.can also be applied near the dodoes al the hydrosail using
weigh led trail in a hases.''A pray void me of S to 100 g allon a per acre 5x0.075x R.7=1.O quail per treated surface acre.
may be used;Sonar A.S.'may also be diluted with water and the Con- n
cenlrelad mix metered into the pumping system. :' Wh a a measu ring q bent ties of Sonar A.S-,quane may bocen-
Application to Ponds
varied to fluid ounces by multiplying queue to be menaudd x 22.
pond. For example,0.25 quarts x 32=.6 fluid ounces.
Saner A.S.may be applied to 0.06 to entire surfaceof area ofaedien Fates
maybe solacmdto provide Yates
a essary to oftain these active in M9he Notei'Calculai'ed rates should not exceed Iha mekhnum allowable rate.
ditreed
dcted ncentations ill treated
snater iresoobtainheseowing table, In uaris ertrcatsd slitface'acre'idrlHe waleP de lhlislud In liras II
When concentrations water
idepth o the tarerashown in thelarthingtable, q p P pp ^
When average water depth of the treatment s'ile is gf0aterthan 5leot„ cation tale fable torahs site to be treated.
apply Ito 1.s quarto of domain A.S.per tratted surace acts:
Application to Drainage Canals and Irrigation Canals
Average Water Depth Quarts of Sonar A.S. per In drainage and irrigation canals,Sonar A s,should be applied attire
of Treatment Site feet Treated Surface Acre rate of 2 quarts par treated sudaee acre. Where water retention is pos.
slot.,the performance of Sonar A.S.will be enhanced by restricting
1 0.16-0.25 water flow.In moving bodies of water,Use an application coital that
2 0.33.0,50 will provide a uniform attribution and avoid concentration of the herbl.
3 0.50.075 side.
4 0.65.1.00
5 0.60.1.25
Use the higher rate within the rala range whore there is a dense weed
mesa of when fronting more difficult to Oalllfol spades.
Application to Lakes and Reservoirs
For best results In takes and reservoirs,Sonar A.S.treatment areas
should be a minimum cis acros in size Troatmenl of areas smaller
then 5 acres or treatment of narrow drips such as boat lanes or Shore-
lines may not produce satisfactory results"due to addition by untreated
water,In Inkee and reservoirs,do nqt apply Sonar A.S.within coal�
fount Mile.(1a20 fed0 of any functioning"potable water snake,
Fates maybe selected to provide 0.075 to CAB plain of active ingredi-
ent in the treated water.Application rates necessary to obtain these
active Ingredient concentrations in moalad watom'are shown in the fol-
lowing table. When average water depth of the Ireetment site is greatof
than 10 feel.apply 3 to 4 quarts of Sonar A.S.per treated surface acre.
S
i>'

AUG-23-1999 MON 05:20 PM D 1 WATER QUALITY FAX NO. 10197339950 P. 06
;ua4-2�C-1994 10156 EEPPO CORPORATION ) 317 SEC 8�'ard F'.t33
Adve Ingredient
Ghcnucal Stnrrture: 0
N I
CFS CN3 Sonar SNP
NomWLature; 1.11zttlgl•3•phenyb5- -3(td"eo- Formulalim, type: siow-ralesse Pellet
moletlayl)01tenyll-4(1H)•PyTidinone composition: 6urdpne, 5 0`"0
e:ner inoredteuts: 03 0%
common Name) eluneone (contains T pounce acdee Inpatent
Molecuiar'We4ghe 329.3 (ter 4o-poltmi container)
,4ppemence; Technical nurldone is a white to ed11 Solubility Ito Wuler; N1105 d;cmt1rute in waver
cn srallple 50d2. APPearanea: dark-gray:to dark-broom pellet
]felting Point: li4.175'C odor: Faint nrd5;y odor
Vapor Pressure: Lem than 1 X 10'mm Hg at 25o C pg; 3,5(aqueous 50l�0)
Flnridona is considered to be non- Volatility: no➢voladlc
,volatile and will not umperate into the
almo=--pre:e dwing or nrter upptydng Made-oE-action
sonar to water.
Solubility In Rater; 12 ppm The active ;ng%ed ent lc annxr -.Iuridone,'.nhi6lts t.pha:[z::t=il-
ity to make food.Withal that ,knlny,the plant(Iic
S,P16Fcally,IF,rdone inhtioits GlTptcruid s)mllesis,
Products (iarotenuids(yellow pigments)are an intponant pan of the
planB phutw)'c:hectc(food-n•.al'.ng) These ycl:av:pig;
$OnBf As: meets pro:ect the plain's chlorophyll(green pigments) (m.n
decotmposition by nunlighl,o';phomdegrededon,lV;aen
FormulrtimtType: aqueaussuspertsion caro:enoAd yni!:esisisnhib4d.t6!orophyll becomes e::puaed
eompositiott: Ilun&)2: 41.1% to phmodegr'ada:im ,and is gradually destroyed.
other inpredient3; 58.3%
(uowmTA 4 pounds active ingredienr As a plattw ch'crophy'll
„ anon) deerrees',so does its cdpaciry•:o pm-
duce carbohydretey through phntaslmthesls.The seal,rtmp•
- g tom a puddones acti�ity in plan:S Is gra2.nal c'n':oro5is,which
Solubility In Water: disperes i11 water develops on the'.err final bed or gasving po ins of the p .nl.
Specific Grmiry; 1.15 at 23'C Chlnro;is nppems 55ableec'ngtg or v.•hlteP,in.�nl pfants due fo
appear=_me: light•tan to gray upacyue tiuuid the absence of deEcienev of green chlorophyll p`l,gtnents(plarus
Odor: slight odor beconl 'Whitish"or p; AS they base chdoroplly'q.
?lIt 8.45(agveuus 50150)
FIa5h Point greater than 200°F,93T C(method It Cokes 30 to 90 days Fur Sonar to co lt:ol eslabllshed v:eeds.
used—5Cc) '.u{dal heibicirie sy;nptonls appear Seven to 10 dams otter applo-
Volarility: nnrvolatile Batton.suscepub':e plants absorb sonar through thell'leaves
and 5ho6Ls and front the hy2ssoil tda roots.
3

AUG-23-1999 MON 05:20 PM D111, WATER QUALITY FAX N0. J$1 97330969 P. 07
SIJIJ-2D-7'394 10157 S'EPRO CORPORATION ) 317 5'c:0 E2EO P.CJA
Hflfora application grewth and a'atar movzment,Cmain cswbyshed „--etland
trees,Stoll as CvirtCss,'al'a NlUarn hV$Vtta,
Comidet the follomng factors before using Selz, for 4dtlwiw•
Govetmtent regulations.Alwoys rear',and follow`,a:oduct lahal
aquetic plane manapemxne
directions. Consult wrdt npprap:iaz!�i:ai,st,:u:or federal
bumdedwarer rise. Tnatmmts with Sonar shauldhticto watarvgocemiag.au[horidesbetoreauplyinaS.,narInrublic
c:porly developed and defined wirer-manager mI ol;ccnvc s ue,[aos. Sta[a or local punlic a;envies may mcutre p'lmts.
:hat[ek2 inus aeeoi;mt the water bodys trended ones.N:nethrr
us cw:nml'.ng and boxing, fish or waterfov!c,an;:,rn•.e:::.trot.
aronmrazstne[ics,Pneas•aterbody'sir.:erdedcsa;affeCt Application methods
mire and degree of control ulectetL 4.he&the late!for:he
mast up.w�dow statements regarding water iiu. ,apply.mono widt is uouied i en' cna N.fnm e turd i „0n-
application eve:rite irealyd area Scner may be u;ed i!1 cnn-
Time ojyc n; For beat results,apply Sonar immediately berm:e junc[ion with other regs[ered sgcadr:herbicidal or algicide;
or during the early ectlea of the target plant's active grow!,,,
Senar.aS.offers three applicecen opiinns': s.:rfaee-npplird,
goner may be applied when nnnkrget plant are domrn,:[ro �, i
subsurface-npp°ed,and bouonl apt liea[:on}laced along or
n:ttaitnte elects to theca specter.Maki applitadors tccen t l..,t
,rys[abrce the fydritSuiL Spray cn.urae n-,a)'vap'. UhanM
tl'tier mU1'amenl is 8[a❑11llllltllTd',m'Ojd Cnoda Lfl'ng CY
p be saffielent[or e1y npplica an and suiGcie:n rove,^age.
:rtmedistely after heavy rainfall to prevent diiuriun,s its
untreated water. Sonar SRP may he applied using equiprrzra drst.;;ned for
Movingwater. Sonar A.S,is recommended for naz in venter spreading granules or pellets,.app'y Ole recunucniiM imount
- or Sonar pellets over the roarer strface usimg'an dectric pellet
Mill Gale movemem(especially if plants are on tile surizce). III � �
moving water,Sonar SRF(sluw•releasa pelieti works best. Spii; ap.carter,a blmcsr nr a timrd gr,a`.u:^s app:;cator
riastn:aCts nlay increase the raea[n.,enx's L'ff avdVanass in mOtirg
wmarbyeatendingtha contact time withtng� Applicationptecautlons
weeds.Resmictirg water Ilow,w'hene posstLle.MAP nirn
enhance control.Rapid water moeemrnt,ar any cundtron that Fz!ore a 7plying Sonar,ces,at srrx 5sh,_nr✓rr gx.re ngencim
iaoldly dilutes water veated with Sonar,reduces zgect;venese. or the U S. FBh and Wtldllfe Sumer to evtcd umeslmg
Cse all appheadon method rh a panicles untlernl dstd'uutimt threatened or endangeoed nquaCc plant or ammal species. Do
of herhicide in the treated wirer. Avoid c'onemtra:ing the ra conratainate waterbrxlies C; deani,^.g a;>paication
herbicide. equipmers in Inem or disptrsing of a�p'.It`atlan to mates in;o
them.Trees and shrubs gmw°a:g'.:l w"zter u'z;;.ed tC.th Sotutr
Aria and dtylh Gau'idt'rnti0tt5.Entirx ppndp.mxy'4d«rated al May necaaionaliy develop ch;orosis.Do no:ap?Ii Sonar to
one time.When neatlnglakes and ressrt-oirs,umumen:areas aidewamr or bracklah water.
should be a minimnm of lice acres in Size, Tre_tirg 97em
smaller than live acres or treating narvoav strips,may resvl:in
cniaisfactory results due m dilution with untreated water. Application tatu
Rates necessary for effective control vary with,cater depth Det=inc the area(aces)rind acuraAw,rater depth of the
check the tables on page 5 as a guide.
treatment site before selenin-the propxr eppt;tacal ra[a.)au
Desirable vegetation.Seriar may be used to manage exe:ic not exceed the maximum labeled we for a given Irzatmen[site
cpeelea,Such as hydrilla and Eurasian watelrnil+oil,selemvely, per annual $nawv It cycle. The tabl±a on page 5 psnipe lhcc
will,minimal erect on many desinable,native plena;. pceia5 genar,i uae rates Inr Sotutr A S and Sonar SRR.Consult the
susceptibility can vaq,depending on time o-year.stage of product labels for complete use mstmClio. and precautions.
T

AUG-23-1999 NON 05:21 PM '(' ( WATER QUALITY FAX N0. 97339959 P. 08
7UI 1-20-1S94 10!57 SFPf20 7N CORPORAT I[ (j
LPkris & Reservoirs Panfls
For best rPsuas In ha':tcs and resen-oirs,Sonar treatment areas 5anar may f L in5pliaci to tin mot:e surface area of a pond
should F,e a minimum of five aces in size.Treating na¢ow 5elee Mtn eoeMilent to adding 0,06,io 0,09 ppm of"!I"
9rdps,such'aa boat lanes or shorelines,may pnlduce uns'ads• :rpredient to ccaced water.The follo,,ing cable lists th:,rates
factory result;Sue to dilation with untreated vueer. needed N achieca these ncti,e-II',grcdienl ec, :calzmF. Use th:e
higher rate•.vithin thu me mitt where there is dense weed
In lakes,,norescn'oas,do not apply jonar wft4in one-[outrh •,pass,or when treating dif:icult•tp•[ontrol species. (<_ze Kett'
Mile(1,320 feztl Of any fttnetimring potable water intake. yo;l:I r I for rotes spamfic to t1w snre.l
'(4'aes 1pa) heselected egIwalent ld adding 0.015100.15 ppm A,'g tumor tleptAaf tiarm cYP aer neared Sa^ai:.aer tr<a.ed
ofeetive ingredianao treated waver.The followingtabla show; ,mawmt 51,e(f0 suck",ii&a(.hs7
toe rates needed to achieve these active ingrcdiem 2quiealenr I 3.2 -s� 16.u.u la
Use the laglxr rate within the rate range where there is a dense 2 6 5-10 033 050
weed nim.ar,i-Ie'lre:flung dffAatli-LRc0:11rOl5pecie5,(Sco tom- 1U- 13 050.m)
New York label for feces spednc!n the stare ---"s 13 20 g'6>-t 00
n'zarraev s'ne dt) 4sArfru pCe``rhea;ed Sunarl'aee acre itsa)d ._. 16-25 0 1.?S
02'�-0.4 r3 20.i0 100^1 50
l 6tl6 i- . ,c,.":,:Ga,n:,,:,c:a to to se
--.. �'. _. fh^o•:dung gnmmeo:r.:�.:�,:nu 9w
`�•,! t •_ 4 +a
632 e1.9-I6
de,ns a±-xN,;,�.ir b-.uFzeJ:enr:-
d,Ne,acre r:n:vrn,ck4g,,krdmo v.-s1
l.u-2o .
to- e s
—....._ r 32.64 t.e-3_2
O 60-fill 3.0•i:3
k:drum..+:::uaurs n-r :d msrx.=rt!vnu,^f,P:r 6'wtt c ony n,ra r!m,e:a:o'.„
:roue;:rns hsa:''rr-:<(:e,puaowrne:,.nap nn::r d=r:6 a ms:Gn:7y.'mrhen r.t.n.-.
rd Appination rase calculation 5d p A.S.
uarrs of Sonar A.S.required per treated acre=Average aster
When figuring ount❑tfpr races for ponds,er treated urfaase rs' depth of treatment site(feet) X Desired pptn coucentration t
if
calculate the amount of product to apply per[mated surface H
g
acre to achleYP.tha desired ppm CdnCCtltra[ion as(ollow active in6redient X 2.1
•s:
For example,the gaans pzr acre of Sonar AS. required to pro
,dde a concentration of 0 075 punt of active Ingredient In ivaar
Sonar SHP wit1%an average depth of 3 feet is calculated es^(allows:
Pounds of Sonar 5RP required par treated acre-Avera;c water 5 X 0.013 x 2.7= 1.0 quan per treated surface acre
depth or treannent site(faeU X Desired ppm Coneentrarion of
active ingredient X 54 Nate:
For et oonple,the pounds per acre of Sonar SRp required to 1)Calculated application rates for Sonar AS.and Sonar SNP
provide a concentration of 0,073 ppm of active Ingredient in should not exceed the mmdmum allowable rate per treated sur-
water with an average depth of 5 feet is caleulated'as follows', fact acre for the,aater depth,as fisted In the tablU above,
5 X 0,0. 75 X 54=20 pounds per treated surface acre 2)Split applicati0n3 using low rates under certain conditions
may inereax treatment edecavenee5.Do not exceed the rre d-
nrmu labeled rate for a overt tresclu t site per amtual growth
cycle.

AUG-23-1999 MON 05:21 PM Dy WATER QUALITY FAX NO. 1.g1 97339959 P. 09
�TWhi-phl-'199q LFl1 SE 4EPR0 CORPORRTION ) 319 5Ed E251_11 P.OL
Irrigation precautions
Ghnn;gntios Sonar A.S.
Leo not applySor,;rA,5. rhmughany type ofirrigationsystem. ,n_ysafle,appw.ltlon
Appliunon Lubllshcd E.tdblished ro0. Neal�ceded
saa treecrops crops.wrGpLfu trap:, C,ibeds
Irrigation: nr;rfr5 N bt
aced'
Irrigation«ith Sonar[reared walermay result in injury to the ponds S. 7 3030
irdgatedvegetavion.PnwFlancorecommendslnfarrningthose s;anetanas' _
who itr?gate from,Sonar treated araa3 of tha irrigation Lime Canals 7 u 14 3C
fnmee preserved fn(he following table,These time frames are --
suggestions that s1'•ould be followed ro reduce poiendal injury Lkrb,Ss, 7 10
to irdgsted vegetadnn.
i
An9I SPP I fr:ae.<,.,,
•For au7um knzr htt5¢,41:'rRling,pN:ra'sd.fi,ed z<a b�ip eru,::r in zcma;'etlr.
Drys aneP appiientlun sc,, I
�.�- 'lu 4Nc n�:�Mmu nAun nntW:i ur t^e!rht boo riarar'r -�mA.us
Application Cs'lcro s lops,ishedmw terns/wedoed :W.,: Frrw,11:1,,,:.,. srlu vo rw�nd,rd
silt cat coups craps,lu;UPlpnu eor anars;to be
nr pleas m FC
planted'
l'
Ponds C 30
sane rnnnh'
Canals - 7 30
Rivers 7 r .. _➢
I.akCs tV L. r r .•--, ` 111
tes"oa:,
Diainage ditches, irrigation canals & rivers
Euher Sunar,k.S.o;Soria;SRP friar tie applied to drainage
canals and imgn:on canals(see Irrigulon precautions"),Sonar
SRP may a1w be applied to rivers.Where tearer retention is
possible,restrict t:ater row to enhance nroclva perform nee
consider wing Sonar SRP when:yr ter tetmion is not possi.
blf,Whorl enply^.:.t SOnor:o MOVing wooer,use an applicaLlun
panetn thL t PTQ�des uniform c?'stributton and avolds concan-
tratingLhe hefb'.cide in onearta.
Split n'edtments,asrng portions that no not exceed the
nsaslmum !noei'n noe mr;nnusl growth cycle nay increaec
Lreatmenl effecLireruas. (See New York label for ryes specific so
Lhe state)
Sonar 510I"-Lrcalucl Surer A.S.per[mated
surrnce ae:a LIbi) s'rafrme or-(grsl

AUG-23-1099 MON 05:22 PM DLl WATER QUALITY FAX NO. ,;�97339959 P. 10
' SLIN-26-159c 1GL FS SEPRO cOrPORRTION 317 SOk1 E7
Atmospheric evaporation Metabolism & dissipation io water
Flundona, the ar;rve ingredient in Sona-herbicides a consul- The m:.aimum solu'o!lity of f tldone in water, is approx.nrax;y
eyed to be nonvolatile,pith a vapor pressure less char.l X 10, 12 uprn,or abcut 100 times s concentration in vater inim,
mill:never of mercury at 25`C. Therefe-z, flundone e^Il not dlzxlc after an eppl=non%-n Sonar(when applied aeeoral-
evaporate taro Gne almnsphzm�tinting er altar apnlyUtg$Door Ing to its lobe:;.That means Ccrd:me comp!rzly t!iss?Ices,
to hater. and is mid,llyaveilable foc p'sr.:uptake
Under geld conditions,Sonar gradca!ly disappzrs trom treat-
Water qualit ed stax'.T'^.e half?jie or tone'nn water averl3es 20 d�v's
but-zn,es from .ve to 6U cats,depzndmg on emironmen:al
Research shoos Ong treatments with Sonar do no;appear nofac;ars.!n lakes,resanairs,iris and ricers,vvhare often only
afiect water cherntetry o-water quilry adversely: a portion of:he wx%r body weikas{rentmem dilution
Researchers have t•cmvr¢d up io 23 dicerent uaramaer in reduces Sonar con:ennatios icc'rzr.
numerous held experiments encutrtpasmtq a variety of agwdc Sonar diaap,ear frun:aquavit zmvon:vents due to one or sev-
ennUlr.Ytenl5, Treated waters,nngec.`rCtr aUlie to alkaane, eral of the fol loving factors,.
soft to very hare;and pure to almost saline.These exoetimznts
5howzti no eppreetai)k changes ill wv.lor theT.is:n: Phorortegradarlot.Uftravio'et h=ht,a component of sunllgni,
doeomposes hundona,T::^.'s r the pnmaty process eon:cbat-
Aesean;li also shoos t:nut the herblcfdal activity of Sonar does, aae:o dlasipa:inn of nutidone uon water.Sunlight intensuy
no;resn1i in a large reduc:lon in the dissolved oa3gm content and dcraunn,plus water elrm; and depth,all'ect the raze of
of water, Sonar per nl:,the natural cedes a'decompo5mo, pporode-radatlon, in photodgnda:ion scdits conducted coo-
respiration ancl renTedon to terrain essamially in.balance. coots in natural sttnli:nt. aur.Aor.e phomdegmd^d to 30 Pcr-
Aliough attached colonies of algae have bees obierved on een.:of IS rrin;T�CO:raCRCI'dCJr.w'1f1(n fm::weeks after P, lice"
dying vegetation,ditu algae disappea-when ,teas drop ro nor to enter
the bouorn.
Plat upturhe"Uptake occurs eaPidly.and continue,until the
There is no evidence of consistent,sr.hstanu.2I ncre�,es in. flandone corcentratlon it,nla-rs cxecads that in water by sev-
❑arlent epncertradons an*ibutable to rlease ftonureered oral fold
vegetation.Ih!s nray account for the la-,k o: maiwca algal
blooms foCovcigg treatment. Hydl"osoil ahorprion. Fhu'!dane resia'ues he hydeowtI nornal.
ly reach a irnminutu 1t,&on¢ :o four vvecke after txxtment,
and ueual!y decline to:all level after 16 to 52
weeks—depending on emironmenea! factors. Fl aridona dissi-
pates from the hy'diosoll gradupl[y hy-absorption by plant Toms
and desorption back into the vvn:er,sdiere it Lt photode�rac!ed.

AUG-23-1999 MON 05:22 PM DJ-tl WATER QUALITY FAX NO, (,I�97339959 P. 11
JUN-2v0-1S34 1N:59 S:EFRD COR.PDRATSON 217 590 0'"�9 P.tty
TaXlClly C�aSSI�lCatlafl Miltagenicity.A nembcr of tit viva and in r,:+v tests^Sel'e cO:l-
duc[ed:o detenna:a IF dutidonz caused:nu;mount Or dm'raKe to
The En,irornn<ntrl Protection Agency Class es pesacdes genetit tllaterlal Follo+ving a singe Prose of 2,000 metig, flu;i
aC'toYdln,g to their scurf ioxlelt)I Ind reQ'Jirea that a 51bMPl waid dn:le did ROI eCu52 dn�om!f.ant ICIGai InUt) lni 1p rata..A iltlri.
indicating due acute tOSlCity ca[e907 Of'he pa mint he 81s- done dose of 500 rlig/t;,8td nor cat,.-","0cmaoinll damage
peyedp:octinently oil tile product label,Sonarltekdde -,ham.stern. lnanArnr�i6t forhaa_rlal:na.aoca, Auridnne
lobe's display the signal teurd CAUTIOK,The CAUTION sig• was sh.o%\T not to altiuce 1n gii8 Ions st me hishea lewd coin:
pal word is dupe iyed on pleducis classified in One leas:acuiely centration of 1,0oO ppm. In urldiV.on. Ilur:,:rnne.e n nut
tonic categorise of Ih:a rating syslem. to Interact n".th genetic maretial iDNAi when rested at a con-
ce:xration of 300 ppn In the cuCa"`d hepnocveu test fur DNa
damage and repair
Mammalian toxicology .Kemotoxicity DmE!nnca scientists have ccn,(IWzd estenmce
Reseerchm hate conducted extensive snldies with h:oora:oty toxicologic,studio in lahuratrry anlniMi ex?Osed to Iluti-
arimalS'W daletnine the tna2cd.Ogy 01 pntid0;ta.Stu, es have done.Kunz of the cosen':tints cI h qh dose ba-eis indicalrcl
included acure to.mcit),subchronic and chronic Uzcicap,:era- nen-ous s,'s:em enacts.
tology,tepmductiun, :nuragenic and 0,minogenic evaluators.
Reprddu t mt, To exainire possi'a:e eF.ects ,I,,reprocxdon,
Study results ht ;vale a low order of tox;cily to mummy fen P:uridore was odm;r.N end ur 1g to rats and Gal)jits conthnr
species follow Ina aeaa,subehtrmia or chmnie exp05"res.'n Dusty dining the ca_gnjagene ii,phaae of emb' jronle de@elap-
addition,large,repeated doses of I'lu=done did n)t esnit In the men:. r;is pl+aaa is vita period of developnwnt of specific IN'.
development oI tvators,impairment eLepruductia;_abnCr- sues and of;gaps,cad is'an t6pec'.ritly sensit_ce tree for the
Ina!deceiopurem of offsuringor ind.won of rnutaeon=. espreas:On of Cevelonntznral sateen. F''ttac!ane did not cats,:
The mammallan roxtciry profile developed though these.stud. deveiap:neaal defeCls at the raatimum donee of 200
it,support the mr•clusion that Sorer presents no unreaeer: mg('.-g/dny in tits or 7)0!ng/k?Jday in raitblls.
able risk to humans when used•according to One prnriads.*el ?..ats maintained fur Threes.:tree \a gene;ar.ons on dies Con-
direcdors And Preeeudon> taining 2,000 ppra fWrtdona(121 In g sac) shower!no
The FPA has reglsterad Sonar with rc resuict(ans on use,of intpeminenr of fete;dy,li;'e�hurn litr_r sloe,period tram'Oryenic
treated water for 3, nining or fishing.The F24 has approved devalopment,enioryo sunivel,zlir,''VPI of c.Ysprin;ar sex dls-
r uIbimon of offs rim .In additon,t'.ure ivas no ethdmce of
anacczntableresiduelzrelof0.lipp;n.or(luridane:n P 3
pntrble water Ivied for dripiing perpoes.P nere Sonar is I'uMane�induced defects In en:^nvn:C cc elnprtetu.
applied to lakes and IaRrvoirs sening as eu',t¢es 0:pot,-e shin and eye mim[ion. Sager Ale been cias:'Red�Y.alightly
,eater,the label prohibit application within one^fo•_nh miie of irritndrg to a)es.As adn any pescdde, _aL,it Ccnin".ended
PRY functioning potable water intake appt!caiion technicces and wa ety egvipmvT-1, and handle
Cardnogenidty. In lifetime feeding snldias in rats and mice pronely to mUid z_x,wstan to skin 9nd alas.
conducted over a Iwo-year test period,Sonar showed no
evidence of bein;a p)ithtial carrinogen,Fluridone is not listed
as a carcinogen or potsntial careinOSsIb}'LiRC,N:'1�"1F,
OSHA or ACG1k 1.
8

AUG-23-1099 MON 05:23 PM DL- WATER QUALITY FAX NO. ��197339959 P. 12
]uk—�%.n-113'34 11;Oq SEPI<o CORPORP710N 31^r SLO r_'C,3Li P,Oa
MAMMALIAN STUDIES'
5ludy' Organism Retiup;: Cmmnmnrs
Cm.SD„ mausu aaA00 atL/ug \'¢p•Im<te:dchv.
eq .h>AN*s/.g \tly lmv lvlaj'.
irhd,a'Jn LC rat
L. fiur h: ' �cltn;o It eon 3enh ^t .ue4
\ cFn o`
,a �t n 4n vnr
hntl I
T,srs!cnllua w gclnea ptc nexpcsz
0,I1S?da1 a
's) Mcuse .2p ay No . .tnl•re!n!w!vclws
d'^FLI 19.3 mg�;yda}9 :,b,:ani'L et Ihaec auvcs
^a sib-.Pt!t AO I«n.rrn tlu c�^cts
dLit 201ra. `da!• No toxic r 4u, trs t.os
E btm'rn..tl Aaysi :aiSir "• \v syrttr^„�;:tuv'.ci;e 'Ies:¢d at AV,selcuan oC4 eW;,l
R _ ahstn'td. ynto4;s.¢pe!sLII ..._
.r Oral '. vepr) trcusc lOtlpn:n _ �'c'�orr_•dfecutart usm'ed
nn h07pa \'o loslcoleo tltl el5rm o6sen'ed ac
t9,:rag'C en) ?Cis IV,el.
doa :Sf)c=sg/day Nacoelma;*3all tiYetu o6sdnzd at
s!avel.
Orsl ?yex), :Woos, :OU pont Ku gmee;esic elftcs:car
\;',.F,13 ill dmS'�dny) cmzn'ni:nn e+idtnr^t cf
s<inegr:.L:tffmts in surd,'.
r;11 ".'JP:oa Ra lmrel:Sicti effeas r'Iss:rr'nI
ttieas cts i 1.ne eddxnet of tnrtra. me
' !n smc'p.
i.;I
l odLt .,. mr Lnl r:rc .,.,, . . .• lhl h,''. r......
a...i' :}r SrrxenM1f....Nr:h,".'I"!.'I o l>t^cnr
J.d.:.::my.•n u.I'IL,..<.. L. U.nd:,JI&A 9A'4rLr!L .11.1;1 le=elNL!w 4:ilerevl ruo.utnl m.l:n 5. er.estt_.::ryqup a:P.:.::.rp:.nJ
Birds &other )cctarget life
.AVIAN,EARTH WORM AND HONEYBEE STUDIES'
$Cody Organism Results fppni) I comments Y
Allan 1 ocnl n01)o'hlte LO;r S'KU mutt; ]c monnBp•ebxnzd?ILhtw lOtis
.... ,$tnn P.day:Idnry hglm hNa LC ai3O.V ulan is dtt: Nom.nnlny'ahscnedi'L`.he4katlP-
rtiellani LC, 5.01 opm to dies I Xu moi.ko, ob.tr:cd at I.Ot'Ft'411,
--. .., hn;ohxc NOE,LCN Pnm 111": I \a ahscrccd cf(ale 0.t luccw.lce 61
,inn h:pn^e.c;vn u.ul¢
�(urt•yxnuxleN
.r.Iallmrd NL)Kt,S.dJd 7pm III dlcl Sou'caunmd elitVI's!n•luvenilei or
...-�__ nhb" _....
Sorvlar�,e;:nszet •., hocr7 bee 361.h µ!Awn Von^.nnnllty nb;•va¢d m!heti lcrels
Snll at thrz IactL.
Orga;:lsnt Cann„orm(14^dap) LC,> 102,6 pin Nt!m.:nslVj"Ilia ud
.r..mr uvrc ror.n:m:rl,.:...mho¢nl IlarAano.Ps nano mamiian::niwm:l:rn:::nue
9

AUG-23-1999 NON 05:23 PM DTIZ WATER QUALITY FAX N0: 1R,197339959 P. 13
71J1•F2O-1994 11:fn9 =EPRO CCIRPORFTIOFI
! 312 .SaG ezeo P. aa
Aquas c life Pets & livestock
Flundone 1,as been tested In acute and longer-term laborato , 'toxicological mstlnp Indicales Ihar wl, It used acenrdmg to Il e
studies in fish and other aquatic animals Fish exposed to label,Sonar poses no unreasonahk risk to pets and livismck
Web`[treated with Sonar absorb low levels of fluridone.Edible due to its law order of ncirunalmn mzi_iqt
fah tissues contain lower(:undone concentrations than inedi-
ble tissues.Residues of(luridone and its iuRahohre in fish
decease as the herbicide disappears from treated water inel s
p:undone has a law N-or[anol water partition coefficient The Liens in fnnrulattars of aonir are not an the FRM list of
(log'-iow= 1.87)that indicates it will not accumulate in the fit -Inns of Tos4cologica'.Concerti•(11sr 1)or im:cf 'Fntentially
of Fish,reptiles or mammils.the EPA hits pramed a 0.5 ppm Toxic lnerte/High Edmity for 2),
rnlerance for Ruridone and its metabolue in fish.
FISH,AQUATIC INVERTERRATE R
ESTUARINE AN➢MARINE STUDIES'
Organism Exposure 1,C„/EC,,
ppm fluridone
Freshwater Fiah
aluemll 90 hour 12.1
rainbow Dom 96 hour 4.2
dvnnel calFsh 96 hour F?
iddazad minnow 96 hour 32A
Avail,Im•enebrntes
Daphnia(daphnid) 48 h0ur 39
Oumrs.vs(a:n hi edy 96 hoar 31 1 �7 p
chuonanius Qn dga) 481rour Ls -Y, Q� /O kt. O e i o
,npnah l4day >16A �pNp
Estuarine NMmne T
pink shrimp 96 hour 4.6
hlud crab 96 hour 34.0
oynar ouihp•osdarvae •5 hour 1F.9
chezpsheod r!nnow 96 hour 10,7 Y
FISH AND AQUATIC ih'VERTER'p.ATE LIFE-CYCLE.STUDIES'
Organism Exposure NOEFFECT
CONCENTR4T10111
ppm Puddo-c
. 9rhend minnaw 30 day 0.48
<nnanel em6sh Na day 0.5
Oaphnia(daphnldlF130
21 day 0.2
Cmmmem56mPeipod) 0 day 0.6
oimnomus(midye) day 0.6
Sven•,wars rnnaundrv4h awdere:he xmu NarvOm m S,n+��buile

AUG-23-1999 MON 05:25 PM DlJ(, WATER QUALITY FAX 140, ,1Q197339959 P. 01/0-,
Oa a After Ann[!!! tion
Directions for Use: Newly seeded
II is a violation of Federal Law to use this product Ina manner inconsis. Crops/Seedbeds
lent with its[sharing, or Areas to he
Established Planted Including
Road all directions cai cally before applying. Application Established Row Crops/ Overseeded Golf
Shakewell colors using. Site Tree Cro e Turf/Plants Course Greens
1 Ponds and
STORAGE AND DISPOSAL Static Canals 7 0 30
Do not canlaminata water,food or feed by storage or disposal. - --
Storage:Stare in original container Only.Do net store near feed or Canals ] 74 30
foodstuffs.In case of leak or spill,use abso,bent materials to corI
liquids and dispose as waste. 2LAkes and
Pesticide Daposat:Washes resulting from use of this product may
Be used according to label directions or disposed of at an approved Reservoirs ] 14 14
waste disposal facility 1
Container Deposit:Triple rinse(or equivalent).Then over for Nay, For purposes of Sonar AS.abating spondisdoflnodasabodyof
cling orrecondffmhing,or puncture and dispose ofin a sanitary land- water 10 acrasor less in size.A lake or reservoiri3 grealer[Iran lO
fill,or by incineration,or if allowed by Stale Intl Local authorities,by 2lcres.
burning.If burned,slay out Of smoke. n lakes and reservoirs where one-hall or greaser of ilia body of water
Is treated,use the pond and Static canal irrigation restfollans,
General Information Weed Control Information
SonarA.S.herbicide re a selective systemic aquatic herbicide for man• Vascular Aquatic Plants Controlled by Sonar A.S, :
agement of agoalin.Vegetation in it can water pence,lakes,reservoirs,
drainage canals and Irrigation canals. Sonar A.S.is abs.,bad from Floating Plants:
water by plant shoots and from hydrosoil by the heats of aquatic vati Common duckweed(Lernna morrot
far plants.It!A Important to maintain the recommended eoncenlra lion of Emarsid Plants:
Sonar A.S.in contact with the weeds as long as possible.Rapid water,,
Spallertlock(Nuphariutcum)
� movement or any condition which results in rapid dilution of Sonar A.S.
( inhbatdd water wilrreduaefa effectivenbes.l n suscepti ble plants, Water lily(Nymphasa sop.)
Sona(A.S.Inhibits the formation of carotene.In the absence of tCon[ml,Iod only with a surface application of Sonar A.S.
car olone,chlorophyll is rapidly degraded by sunlight. Herbicidal symp• Submcrsed•Plants:
toms of Sonar A.S.appear in seven to ten days and app ear as whi to 6laddmwod(UMmtlaria spp.)
(ohlorollo)or pink g rowing poin ts.Under op him um cOnd'lions 301090 Common council(Ceratophyllum di,Is
d aye are required b store the d¢sired level of aq colic wood man ag a. Common Elodea(Eledea canaden SlS)
mentisachievedwib Sonar A.S.. Speciessusceptibilllyto Sonar A.S. E.gede,emzifian Eloise(Fgana coma)
meyvary depending on time of year sage at grpwih,and water move- Fanwod,Cabomba(Cahomba caroan:ane)
meet. For bast results,apply Sonar A.S.prior to Wasting of weed Hydrilla(Nydoln vcniciso)
growth orwhen woods begin saliva growth. Naiad(Na(asspp.)
Sonar A.S.is not eorroalve to application equipment. Poneweed(POlamogOO11 sop.,except 11100ia pondweab)
Watermiva l(Myeophyllum spp.)
Sharelino Grasses:
General Use Precautions Paragrass(orwchiona moues)
Obtain Required Permits:Consult with appropriate state or local Vascular Aquatic Plants Partially Controlled by
Water autholl balers applying title product.Porind s may be required Sonar A.S.
by state or local public agencies.
choral Orion:Do not apply Sonar A,S.through any type of l rrigalien Allllvo,r,ecd(Alrernanrh0a;phlleabladcs)
system. Amedai lotus(No/umbo h4$A)
Cattail(Typha spp.)Potable Watei In is kes:I n lakes and reservoirs,do not apply Son or r Common West meal(Wolr/in columbione)rt
A.S,within one-fourth mile(132D feel)of any functioning potable water V: Creeping Waarprimiose(Ludiigla peploidas)
.Intake. ,•�( Giant culgrass(Zleranlopsls mlllaoea)
Irrigation:Iol anon with Sonar A.S.treated wain r may rosu It in injury Illinois pondweed(PolamogDan ilfinoensis)
9 9 y Panorfcather(Mynophythim brasilionse)
to the i irrigated vegetation.Dow lance re commands In forcing those Read Canalyg rass(PhilffiiS arundinacene)
who Irrigate from Sonar A.S.lot clad areas of the frrlgatlon ll me frames Smallwood(Palygonum sple)
p rescued In the following table.These time frames are sugg eslion8
which should be followed to reduce the potential for Injury to vcgention Spikerush(Elecchsns spp.)
Irrigated with Sonar A.S.[rooted water: Southern watargrass(Hydmchloa carclinieneis)
Torpedograss(Panicurn repens)
Wolorpureane(Ludwigie palusrria)
Wale)shiold(aessama schscbep)
=''(,tpadlHl Ognil onlywltii aSGBaco application of Saner A.S)al`;
":them A ldm'Iaheled Fala., "
)
a

AUG-23-1099 MON 05:25 PM DA. WATER QUALITY FAX NO. �.1 97339959 P. 02/02
WARRANTY DISCLAIMER
CowElanco warrants that this produot conforms to the dhemlpal
description on the label and Is reasonably fit for the purposes stated on
the label when Used In strict accordance with the directions,subfect t0
the inherent risks ,At l fill below. DowElenpO makes no other
express or Impl led warranty of merchantability or fitness for a Per-
ocular purpose Cr any other express or implied warranty.
INHERENT RISKS OF USE
If is impossible to eliminate all risks associated with use of this product.
Plant injury,look of podormance,or other unintended consequsnCea
may result because of such factors as use of the product contrary to the
label Instructions(including conditions noted on the label,such as unfa
vorable temperatures,soil conditions,ate.),abnormal conditions(such
as excessive rainfall,drought,tornadoes,hurricanes),presence Of
other materials,the manner of application,or other factors,all of which
are beyond the control of DowElanco a the seller. All such risks shall
be assumed by the buyer
LIMITATION OF REMEDIES
The exclusive remedy for lassos or damages resulting from this product
(including claims based on Contract,negligence,strict liability,or other
legal theories),shall be limited to,at DowElanco's election,one of the
followin9�
(1)Rotund of purchase elite paid by buyer or user is(product bough I.
or
(2)Replacement of amount of product used.
DowElanco shall not be liable far losses or damages resulting from han-
cli0g or use at this product unless DowElanco is promptly notified al
such loss of damage in writing In no case shall DowElanco be liable for
consequential or incidental damages or losses.
The terms of the W afranty Disclaimer above and this Limitallon el
Romedias cannot be varied by any written of verbal statements or
n9reemenls. No employee or sales agent of DowElanco ar the seller is
author!%Qof to vary a exceed the terms of the Warranty Disclaimer or
this Limitation of Remedies in any manner.
-Trademark of DowElanco
Copyrighilto 1992 Dow8an00
DowElanco • Indianapolis,IN 45266,ILS.A
LABEL CODE 11336.003 DATE CODE 892
EPA APP ROVAt.07/21W REPLACES 1133 6-00 2
Revisions Inoludo'.
1.SonarrA.B,label reformatted and edited forclarity,
2..fnvifonmonlal Hazards section updated.
3.Use prohibition in areas used lof crayfish farming removed.
4.Woods(plants)controlled section revised and plants"not controlled"
by SonaM,.8,added
5.Application rate recommendations for ponds,lakes and reservoirs
rofined to provide more accurate control of herbicide concenpations
In water.
6.Precautions section revised as per EPA request.

_ BASF Corporation1. BASF
77PR01PCrE
---
ENGINEERING JOB NO.4427
KF- UPGRADE ENKA WASTEWATER TREATMENT PLANT
AUTHORIZATION NO.E-4922-4427
SITE
This project will provide for the mechanical and instrumentation upgrade of the wastewater treatment plant. This
work and all new structures will be contained within the existing physical boundaries of the present wastewater
treatment plant and the lift stations.
MAJOR EQUIPMENT
The project will purchase and install the following equipment:
1. New instrumentation that will monitor the influent streams and will provide system operational data.
2. Two (2) new subsurface aerators.
3. Three (3)subsurface mixers.
4. Two (2) variable speed drives for the existing constant speed aerator drives.
ELECTRICAL
The existing wastewater treatment plant electrical services will be reused as required.
INSTRUMENTATION
New instrumentation will be added at the lift stations and at each intermediate step of the wastewater treatment
process. The instrumentation will be tied into the existing CSI system. A personal computer will be provided for
operator interface in both the wastewater treatment plant control room and the filter plant.
UTILITIES
1. Electrical power will be provided from existing substations.
2. Air will be provided from the existing wastewater treatment plant compressors.

DEC 09 93 09t01AM O�PLANNING i-•� P.Sii
' Appropriation BASF CO md*n
�, a,�F � ' � � , L Jan BASE
Request F 60 � T
US -Project Tito
KF•DFDESNKATREATMENT
0RA WASfEWATHR PLANT
Group Location Prolaetuaragar oect Project Numb,
Ca er
NFX SNKA,NC T.R.JOHNSON 4397 &492244T..
INVESTMENT REQUIRED $
Expantlltunt capital Reanahpe. Rapaln Othaf E%pencw T¢ta1 Cxpames Total Project
Total SSO IO 10 590
ligFIVAEMM
Cost Estimate ptmemmwaunwuw mmlP9yq
The project Includes environmental spending at 590 K fEttimW hued pnpmlCareNfdmO timed )
Cast Aaeeun[ Ofsenpben
The following forms an not Prior Approvals($Iq
applicable or an not 75
Prior Approach:
❑affect, ❑Environmental This Request! 515
[:IutuweaEconomics Total: 590
I Code
enu
Coda
,s ,E
Project Description ,IdmcpnoyAppilcd nabeaadeco
Thin project will 49,rad. ch. ..fall., asswratae treatment plants?i¢rtaffe, new monitoring aquipment and rev"c'u' aartain Ptoefle
equipment. An ealineerin, study of the treatment plant was done to dstermine the ina,fumontatlen and equipment lobe Included in t
overact. proissL
Justification turewmarAppo�on AlealumlrN
An upgrade.(ch. rutenater treatment plant will insure that the Enka Plant meet, the mquiremente of the Natlonsl Pollutant Diechr
Elimination System(NPOES). The ability to rtoy within the limit.el the pamlt baeemss marginal duti.,entrant,ambient ev¢didam
Gad who¢ ......iv. Atlanta lands at, resolved(ram the mmu(wluring treat. Two saw process (Candu.tiva Fibers and A¢tiaut)hive
Introduced additional leads to the getem. The up,fad.of thersstasvat.r treatment Plant Is nqutred to handle opsew ea lneemlat
tsreame end to provide<f(ieian!eperatlee. The scene, el thin prejeet mt develeaed from a study made by an outside engineering fir
the aarpara[c 8colvgY OrovP suPPeru the P+aJmt Gad PvrtislPated I¢its dewlePmest.
Date nDate De
T. Huber /G an P J. Rawden too-
Rpyl my
Date 1D,�ate DE
V L Blalf P.Aikat Z S nartl O
Data Date Pr

� n
PROJECT ACCOUNTING SYSTEM
SOURCE DOCUMENT
AUTHORIZATION NUMBER E- L+QZZ _ +- Z.
PROJECT DESCRIPTION 4:- WASTEWAIf TR67A,-all e*1T Plat t.
PROJECT ENGINEER Grp [34 �
AUTHORIZED AMOUNT �y�S90 AUTHORIZED DATE �/ /7 c]3
DEPRECIATION COST CENTER J PROJECT TYPE
ESTIMATED COMPLETION DATE I 1Z131
START QTR. &YEAR 5 START-UP DATE
PROJECTED SPENDING BY QUARTERS:
OTR 1 $ �/I,Q . 00 K QTR 7 $ K
QTR 2 $ ZCQ.pO K QTR 8 $ K
QTR 3 $ /00 .00 K QTR 9 $ K
QTR 4. $ IC(Q o0 K QTR 10 $ K
QTR 5 $ K QTR 11 $ K
QTR 6 $ K QTR 12 $ K
COST ESTIMATE
CODE DESCRIPTION AMOUNT
eNL"�M_ .1 Cr TJ e.15"CIZu o 7 cvU
s­TC- o00
p61Z0 4w I cbU
06030 i vc Mg 41,, 1 T-
CtiY�
coO uY"1 a4i .4"TrF0 L- 1 $C J�'f' ADO
OZO e2.p A20w.y2�.r S� OOO
030 r t� u �Qw
_ U+� t?,•,��� coo
sr Lt_ ` Z0. N - t Oac
U Sr le CJZ Oac�
08070 5q OoC
nfT CrInJaZ--2T —�AZ > bOt
Z7U .1_ zo cc r Ocx
Z b Oac
�rn.,.r (2F ev4 UP UxLDt� lzt_ S .

BASF Corporation
BASF
CAPITAL PROJECT COMPLETION NOTICE
AUTHORIZATION NO.E¢9y2 - ¢¢87 AUTHORIZED AMOUNTO$g Qop
PROJECT TITLE (fpSegaE nACq /.r/as�c„rgrF � ,or� .ur Pt grJr
LOCATION NK.c. A/ C
COST CENTER ¢38,� COST CENTER LEADER J,<a . .�ae.taer..I
All work authorized on this project has been completed and a final
operating type safety review has been performed. The project, as
installed, meets or exceeds all Federal, State and BASF Corporation
safety and loss prevention regulations and standards, except as
stated below. Effective this date it is released to the owner for
operation and maintenance.
Exceptions:
PROJECT ENGG(INNEER DATE
ENGINEERING SUPERINTENDENT DATE
��� � ,Z_ /`1 -/19-9J
MAINTENANCE/CONSTRUCTION DATE
ZkZ - 12
DEPAARRTTM(EfNTp REPRESENTATIVE DATE
SAFETY REPRESENTATIVE DATE
'ENV NTAL/INDUS. HYGIENE DATE
Enka.North Carahm 26726 J7U)667-7110 -
-7

_ - ..
riecluest 7 BASFC')rporatlon
ECR ❑ SAFETY ❑ EIT r7�" '''`" COMM
Department r-a G a rt Dept.. Acct. r//0-wk Auth. No.t�FNA—lll L¢�9a 5 - SQ 8 3
Date Issued 9 -. /z* - 9S Account No.
Date Required Eng. Job No. 5 O i5 3
Title: sI?-I#Irl : la IHI Intl 1 IAIIa I071 '1 PI I.-I" lAl
Description of Project Q [ 2 L L Z"NST wM e. a ,-a s/
Economic Life Tax Depreciation Life
Description of Disposal p erc / 6 SS STi
Disposal Asset No. Original Cast$ NBV S
Estimated Loss on Disposal (Net of Estimated Proceeds of$ I is.................................................$
Estimated Cost of Dismantling and Disposing of Assets..........................................................................................$
ACTION TAKEN BY ENGINEERING
Assignedao - Priority. / Safety Review Complete _Yes —No
Project Engineer Date Completed e-' -/G - q
AUTHORIZATION COST ESTIMATE z Signat Date ure
CAPITAL EXPENSE F O Requested By %
U -
EQUIPMENT $ •fj�Q $ Q , Q Superintendent
LL O _ Or Area Coordinator
� 1_
MATERIAL $ 306 O $ a" Z Manager
LABOR $ .i 6 o a $
AlENGINEERING $ 10 a a $ z Controller (10�L.
O
J H J Manager re
CONTINGENCY $ ;L a a a $ t j /
G — O Plant Engr.
SUB-TOTAL $ $
OLL O o_
z 1- Gen.Gen.Manager
AUTH. TOTAL $ so a D
Q
DISPOSAL AMT. S

PROJECT ACCOUNTRI SYSTEM
SOURCE DOCUMENT
AUTHORIZATION NUMBER 9 0 - .J o B9
PROJECT DESCRIPTION
PROJECT ENGINEER O C G G i L HAL G
AUTHORIZED AMOUNT AUTHORIZED DATE
DEPRECIATION COST CENTER p/f 3 PROJECT TYPE
ESTIMATED COMPLETION DATE - 9
START QTR. & YEAR F-JT7 START-UP DATE
PROJECTED SPENDING BY QUARTERS:
OTR. I $ / / K QTR 7 $ K
QTR 2 S S S K QTR 8 $ K
QTR 3 $ K QTR 9 $ K
QTR 4 S K QTR 10 $ K
QTR 5 $ K QTR II $ K
QTR 6 S K QTR 12 S K
COST ESTIMATE
CODE DESCRIPTION AMOUN-
000 FLcu, SNS
7fao
90 7o 5 GL4 5'000
7.
O / !r

PROJECT OBJECTIVES MEMO �
Ilk APPROVED
Date Written: 7/3/96
To: M. A. Mc CALL COMBED
From: C. E. Hall IIIvJ' IUVAII 115
Location/Extension: ENKA/7867 l2-i! 9, /�
Subject: REPLACE SP2 AND SP3 EFFLUENT PUMPS
Copies:
Action Requested When Completed PLEASE APPROVE THIS POM AND FORWARD TO
ELAINE SCARBOROUGH IN PLANNING & CONTROLLING. CHARLOTTE.
This is a request for Scope Development Funding ❑ Project Appropriation
Project Statement REPLACE SP2 AND SP3 EFFLUENT PUMPS BY OCTOBER 1996 AT A
COST NOT TO EXCEED $25,000.
Proiect Objectives PROVIDE RELAIBLE EFFLUENT SUMP PUMPS IN THE EFFLUENT
HANDLING SYSTEM FROM THE EVAPORATOR BUILDING AND LACTAM FARM BUILDING.
Technical Description of Project INSTALL FOUR (4) DEMING TYPE A SIMPLEX VERTICAL
SUMP PUMP ASSEMBLIES IN SP2 AND SP3 SUMP PITS REPLACING EXISTING PUMPS.
Justification EXISTING PUMPS ARE WORN OUT AND REPLACEMENT IS MORE
ECONOMICAL THAN TRYING TO REPAIR EXISTING PUMPS.
Funding Requested ($K) Prior Approvals: $ 0
This Request: $25,000
Total Project: $25,000
Approval
Approver Name: Tony McCall Date: _July 9, 1996
Property Accounting Information
Appropriation Number !34419
06 Project Manager C. E. HALL
Bus./Mfg. Representative . McCALL Location Enka
Site Number Local Project Number 6048
Engineering Res . Code Environmental Percentage 0%
Cost Center Estimate Accurac % 10%
Ready for Start-Up ember 30,
Expenditure Breakdown
Z:\WINWORD\TEMPI TMPOM.DOC
REV.V96

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ELpj-ect Request BASF C' oration
❑ ECR ❑ SAFETY ❑ EIT D
Department jElel 65Y Depr. Acct. /v-Lpj Auth. No. E— 4-90$ — ,$662-
Date Issued �'— ,(f, 9 S Account No.
Date Required Eng. Job No. _50 8 2.
Title: IRW ell 1,44c1c1 I'/'I wli Ikl SI dl 7171X1 I91el✓111�1,1 1417-I IBIOIDI I
Description of Project
Economic Life Tax Depreciation Life
Description of Disposal
Disposal Asset No. C' l/ ° J ° Original Cost S QJ/. 9F. /7 NBV$ ) Z 16 . IvO
Estimated Loss on Disposal (Net of Estimated Proceeds of$ I is.................................................$ '1 - G
Estimated Cost of Dismantling and Disposing of Assets....................................................................I.....................S
ACTION TAKEN BY ENGINEERING
Assigned to Priority I Safety Review Complete Ves _No
Project Engineer Date Completed. 0 -
AUTHORIZATION COST ESTIMATE Z Signature Date
CAPITAL EXPENSE 1— O Requested By 9_
U —
Superintendent
EQUIPMENT S .9660 $ OLL 0 Q Or Area Coordinator
R ~
MATERIAL $ l 0 o 0 $ a. Z Manager
LABOR S 4000 $
Controller
ENGINEERING S 1 06 O $ O
CONTINGENCY S l ° o O $ < Q > Manager i o/
N O Plant Eng'. IU G /
SUB—TOTAL S $ Q.
Q.
AUTH. TOTAL S 0 0 0 z I=— Q Gen.Manager C
O
Q
DISPOSAL AMT. S -2 16 .oe
-11nb 1191-112-11 V11 IAIP IRMGTIn Ki ON PFVFFSF SIIIF RF(LIIFFn

Wy 21 '97 14:42 243 'rblil"i
Peat-M Fax Note 7a/1 0i1°,��/-97 p;pes► 7
TO�s1✓9y.✓i. H[4S rm nh..:s^.ydre .
C°'o° -,c ta.r/.av tPuerw.+
.. Flo° vnnna.3�o2cPn6�/-Y.2�8
Memo �. -73aP FUY3ra sTT
To: Mr. Dewayne Mills-BASF Corporation -Enka, North Carolina
From. Tom Snyder-National Bureau
Date: May 21, 1997
Re: Personal Property Tax Valuation Service
Dear Dewayne.
First,thanks for the data on the proceeds from the sale of abandoned equipment. I would hope that the
assessor finds that$61,000 pmceeds from the sale of equipment having a first cost of$4 million
compelling. Let's hope this issue is put to bed.
As we discussed on the phone lest week,they continue to raise other issues, however. 1'd appreciate
your response to the following Inquiries or requests at the soonest convenient time.
1. Re: Exempt Pollution Control Equipment
The assessor maintains-and correctly so-that they cannot exempt properly not
Covered by a TAX CERTIFICATION. She has four certifications on file-copies of these follow.-which
cover assets through 1995.
A) Regardless of date or what equipment Is involved,do you have env other
CERTIFICATIONS In your files anywhere on site? If so.please provide me copies.
B) Machinery capitalized in 199E with a cost or$574,902 was for pollution control.-See
list which follows. Was a tax exemption application filed for any or all of these hems? If so, please
provide me a copy of the application.
C) Concerning this$574,902 new pollution control equipment-Can a case be made
that this wasn't a new installation,that it wasni additional facilities,but rather was unfitting,rebuilding,
repairing, revising,replacing, improving what was already there and Covered by one of the existing
CERTIFICATIONS? .
2. 1 need a list of leased or rented equipment that was on site at January 1, 1997. The list should slow a
brief description of the item.the name and address of the owner.and the amount of either the monthly or
annual rental or lease payment.
3. 1 need another listing-the same thing as in question two-except for January 1, 19%. .
4. 1 need a copy of the Capital acquisitions request((Appropriation 33609M which supports 1996 asset
number 00045320000*Fire Riser Monitor System for Enka She with a Capitalized Cost of 5259,849.
There is an Issue as to whether this is a real property or a personal property asset What I'm looking for
is the most Complete description of what was acquired andfor constructed forthis$259.549.
Thanks,Deyrayne. Sony to have to keep coming back for more data. I hope this is the end of the
requests but keep In mind that the questions come from Shidie Ford-so this Is a prime example of
-Don't Id0 the messengerP
Please call if you have any questions Concerning these requests. baenp7d3.sam

N. C . DEPARTMENT OF PIVIRONMENT AND
STAa NATURAL RESOURCES
M.� DIVISION OF WATER QUALITY
7. 9 WATER QUALITY SECTION
.-/ - ASHEVILLE REGIONAL OFFICE
59 WOODFIN PLACE
ASHEVILLE, NORTH CAROLINA 28801
Y�QWMv�w
///PHONE : [phone] FAX: [phone]
TO: 610
A� - Fld-
FAX #: 55r5' ® 7
FROM:
DATE:
# OF PAGES INCLUDING THIS COVER
MESSAGE: If cuestions. nleaBe call 828 251-6208 .
p(c,ke ACC T=r�
dc. L' Vax
l &u C )aA �" �

NORrO CAROLINA DEPARTMENO
ENVIRONMENT AND NATURAL RESOURCES
p,�DIVISION OF WATER QUALITY I� WATER QUALITY SECTION HEVILLE REGIONAL OFFICE
i
June 3, 1999
°-� Mr. Jack A. Dellinger, PhD
s'3MIESe.xvNTJ.- General Manager
t r�oYEnNon c BASF Corporation
< Sand Hill Road
Enka, North Carolina 28728
�9
n3v
^. ; . Subject: Amended NPDES Compliance
Inspection Report
Performance Audit Inspection
BASF Corporation
NPDES Permit Number NC0000299
Buncombe County, North Carolina
Dear Mr. Dellinger:
The NPDES compliance inspection report form included as
part of the February 18, 1999 Performance Audit Inspection
(PAI) report sent to you on March 15, 1999, did not include
effluent zinc data. Also, even though the Vday calculations
for total suspended solids (TSS) are correct, review shows
that the correct effluent TSS concentration was not entered
?` on the form. The attached compliance inspection report has -
been amended to include zinc data and the correct TSS
concentration. The results and conclusions for this
(� inspection are unchanged.
'^
Please insert this amended report form in the PAI report
prepared for BASF. Should you have for questions or wish to
"- discuss this report in more detail, do not hesitate to
contact me at (828) 251-6208
I Yo truly, -
m++
L. Han r 1
Environmental Chemist
Enclosure
cc: Melinda Greene, EPA
p+� Forrest R. Westall
iNTewcrvprvcE e��Lo Na, se waoor N PLpce, ns..........
sv L , xc 2e.o1-gala
PX 8382318203 FFX 828-231-8942
AN EoupL OvnowiuHlTY / AVT wMgT Ve Ao oN EMvwvew 60% wecY0.eolt0% POST-CONSUMER p
ER

United States Envi(4gental Protection Agency Form OMB Apprmed
Washh , D.C.20460
EPA NPDES Compliance Inspection Report Approval Expires 7-3"5
Section A:National Data System Coding
Transaction Cade - NPDES yr/m May Inspection Type InspectoIr Fac Type
1 IN I 2 u 3 NC0000299 11 12 99/02/18 17 18 L'J 19 I" I 2012 LI
u Remarks
R d Facility bl lu twn Rating BI CA
u L R eseJrvId
67 69 70 71 L 72u 7I I ' I 74 75L I�
BO
Section B:Facility Date
Name and Location of Facility In,acted - Entry BASF CORPORATION Time Permit EBettive Date
US HWY 19/23 & NC 112 0830 Hp
S 90/10/01
ENKA, INC, BUNCOMBE COUNTY Exit Time/Date Permit Expiration Date
1530 HR$ 95/09/30
Name(s)of On-Site Repmsentative(s)/Tltie(s) Phone No(s)
RAY C. ACKERMAN, ORC (Bone 667-7277
MANAGER, ENVIRONMENTAUSAFETY/QUALITY
Name,Address of Responsible Official Title
JACK A. DELLINGER GENERAL MANAGER
BASF CORPORATION
ENKA, N.C. 28728 Phone No. Contacted
[phone] NO
Section C:Areas Evaluated During Inspection CODES .y S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated/Not applicable
$ Permit $ Flow Measurem:LLa N Pretreatment $ Operations b Maintenance
$ Records42epom $ Laboratory N Compliance Schedules $ Sludge Disposal
S Facility Site Review $ EffluenVReceivin;Waters 5 Self-Monitoring Program Other.
Section D:Summary of Fir, ings/Cumments ((Attach additional sheets if nernssary)
EFFLUENT DATA( (COMPOSITE) PERMIT .!,b1ITS (MO AVU DAILY MAX)
FLOW - 0.632 MOD 1.25 MGD
BOD,5-DAY - 137 8/D.4Y(26 MG/q 136#/DAY / 291 #/DAY
TS5 - 527 #/DAY H00MG/L) 209#/DAY / 565 #/DAY
FECAL COLIFORM -<10 /100ML (GRAB) 20U100MU 400/100ML
D.O. - 8.9 MCA G 11-C NOT LIMITED
pH - 7.90 6.0 / 9.0.(RANGE) _..
ZINC -- - 0.34 WDAV(64 UG/D - - 3.65 #/DAY/643.5 UGA
THE W WPP WAS IN FULL OPERATION.WITH ALL UNITS APPEARING IN GOOD WORKING ORDER.. ONE OF THE TWO CLARIFIERS(SOUTH CLARIFIER)
WAS OUT OF SERVICE FOR ROUTINE CLEANING AND WEIR LEVELING, NO PROBLEMS WERE NOTED.SLUDGE WAS BEING HANDLED VIA THE FRAME
FILTER PRESS. WASTING IS BASED ON THE F/M RATIO AND THE VOLATILE SOLIDS(AERATION)WHICH IS MAINTAINED IN THE RANGE OF 1100-1200
MG/L. THE FACILITY WAS PRODUCING AN EFFLUENT WHICH WAS EXTREMELY CLOUDY WITH HIGH TSS THOUGHT DUE TO FINISHING OILS BEING
-CHLORO-DIMETHYDMITO TABLET
IL
INTRODUCED BY THE MANUFACTURING PROCESS). DISINFECTION IS BEING PERFORMED BY USE OF A BROMO
SYSTEM WHICH WAS PLACED IN USE THIS PAST YEAR. THE DISCHARGE WAS IN COMPLIANCE WITH DAILY MAXIMUM PERMIT LIMITS.
Names)and Signature(s)of Ins c1L Agency/Office/Telephone Date i
MAXL HA
DWQ/ARO 828-251-6208 917
Signature viewe Agency/Office Date
DWQ/ARO 828-251-6208
- Regulatory Office Use Only
Action Taken Date
Compliance Status
D Noncompliance
Compliance

DMR REVIEW RECORD
Facility:_ Permit/Pipe No. : NCCM02!1 Month/Year: S
Monthly Average Violations
Parameter Permit Limit DMR Value r Over Limit
T
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value %Overr Limit
BCnZ� #,! Y5 Pn
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported # of Violations
Other Violations
Completed by: Date :

(� EFFLUENT � � All ApR
99
.DES PERMIT NO: NC 0000299 DISCHARGE NO: 001 MONTH: MARCH YEAR: 8'99Tpp
1999
FACILITY NAME: BASF Fibers Enka Plant CLASS: 3 COUNTY: Buncombe i
OPERATOR IN RESPONSIBLE CHARGE IORCI: RAYMOND L.ACKERMAN GRADE: IV PHONE [phone]
CERTIFIED LABORATORY BASF Fibam PERSON COLLECTING SAMPLES: ROSS PEEBLES
CHECK BOX IF ORC HAS CHANGED
OONI01NAL.YIOIM OPYti '.'
M, Dl:6nNMNnQMPI frYaCa9RnaYM t l l l l (t SIGNATURE OF OPERATOR IN RESPONSIBLE CHARGE: DATE
CEHNR I A IIIIII ( IIII BY THIS SIGNATURE.I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
41�.0,eaa 2963 II. IIIIII
D OPEN OPER ORC 50D50 00010 DOM 50060 00310 00010 00530 31616 00600 ODS05 01092 00720 32730 TGP38
A ARRIVAL TIME ON SEE TEMP Im RESIDUAL B005 AMMONIA TOT.SUS FECAL TOTAL TOTAL TOTAL TOTAL PHENOL BIO-
T TIME ON SITE FLOW Da8'a Cl 9200 NITROGEN RE610UE COLIFORM NRROG. PHO6. ZINC CYANIDE ASSAY
E 2400CLK SITE Y/N MGo C un ut man Ib1d., Ibl IEIEeY /100 m1 mB/1 mBll INURY lb/day 16/tley P/F
`+I 't IIII IIIIILL�Z F
1 24Hr 0.46
2 TOSS Lim IIII a I.III1¢'I ;.0 301' � 7:••••.1 7
3 1140 24Hr 0.48 9 8.0 55 88
4 e4�461 Iu 9H II IIII b I II Ii$;9 III 9 all '0�10 75. 0.4 10�.4 .•:» : ''.,_ .'.': U
5 24Hr 0.49
0 " II r IIIfII III LLO.SO ,".: A . x 11 IA
T 24Hr 0.49
8: s 2aMr. IJIIIII x:#.40 ra°eac., '» 031k 3 : IAA (IIIIII
9 1 1130 1 24Hr 0.42 T M8.2 66 1 197 63
III IVI
it 1030 24Hr 0.45 8 8.1 0.10 22 233
z 2qE I!IV'I, 6,5? a a Hill IN I
13 24Hr 0.49
241 .<.'� . 0.$ :A� III IIIII II p
15 2411r- 0.50
AS 11Pa6�6NMA, I III 0'"qj I d
iT 1100 24Hr 0.48 10 7.9 96 1.2 384
10`. 5 §4 AI ° tiA IIIIII III10,5 VIdA IA 9,1 7-56
19 24Hr 0.47
I13a All IIIII AI 01 AI 'a *: . L.x .e';xi"
21 24Hr 0.59
23 1040 24Hr 0.46 11 7.9 65 96 510
24 +» 1100 24H1 Ol 72 14
26 1030 24Hr 0.43 13 ED 0.10 53 230
is IIII 91'+Y�+r' 'IIIIIIL, III IIAAIIIIII "' A s LIL
77 24Hr 0.47
2q 24Hr0 II III I
29 29Hr 0.47
130 1050; " +r 2'0.46 iaui '�, 1 44»I 707 t:., 20 IIIIII IIII
31 1110 2aHr 0.46 12 7.9 90 4.6 345
;1 aleal A,'I IIIllIl11 III A IIIII AI 111' =====I
AVBnaa 0.47 10 \\\\\\\\\\\\ 0.10 72 2.2 240 22 .... --. 0.20 -- .... ....
0v$ 13 9'2 II10 IIII A,6 -'':'$xti lUk,l III 4P IIIII A � Irrn+lii uI IJ,a
No 0.37 2 ZB 0.10 39 0.4 Ti 1
CoRa fovaral iGl >:..i' 1NM1\7Yttid\4 A G G A ,G IIIII G I0 IAIII II m',i (IIIIII G G to IIIIII . Ik ''c
Monthly Ur It 1.25 6 9 136 209 1 2601 3.65 1 1Pesa

Facility Stetue:IPlease check one of the following)
All monitoring date and sampling frequencies meet permit requirements.
Compliant
All monitoring date and sampling frequencies do NOT meat permit requirement.
Noncompliant
Comment.: On 3123/99 the fecal cogiorm was high due to maintenance work on aeration basin;the monthly average.was well In
compliance.
°I partly,under penalty of law,that this document and all attachments were prepared under my direction Or supervision In
accordance with a system designed to assure that qualified personnel properly gather and evaluate the Information submitted.
Based an my Inquiry of the pemon or persona who manage the system,or those parsons directly respOmible for gathering the
information,the information submitted Is,to the best of my knowledge and belief,two,accurate,and complete. I am aware
that there am significant Genelties for submitting false Information,Including the possibility Of fines and Imprisonment
for knowing violations.-
Name of Permittee: Raymond L.Ackerman
Signature of Permittee: K z
Date:
BASF Corporation Send Hill Rd.-Enka,NC 1 [phone] 11/30/00
Permilee Address Phone Number Permit Exp. Date
The monthly average for more coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
ORC must visit facility and document visitation Of facility as required per 1 BA NCAC 9A.0202(b)(b)(8).
••If signed by other then the permlRu,delegation of signatory authority must be on file with the state per 15A NCAC 2B
.10506(b)(2)ID).
66 03 8dV
nr 7y trl >> All c

em�esmm�r�_-a®
mmmm
im
� ���mm

Fa...fty Status: (Please ebeck one of the following] {
All monitoring data and sampling frequencies meet permit requirements
Compliant i.
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
If the facility is noncompliant,please comment on corrective actions being taken in respect to equipment,operation,maintenance,etc.,
and a time table for improvements to be made.
"1 certify,under penalty of law,that this document and all attachments were prepared under my direction or supervision in accordance
III
with a system designed to assure that qualified Pe. �°ee q personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system,or those persons directly responsible for gathering the information,the
information submitted is,to the best of my knowledge and belief,true,accurate,and complete. I sin aware that there are significant
penalties for submitting false information,including the pos ' ility of fines and imprisonment for knowing violations."
violations."" t or typ y
e)
rm
ze-s3
��or mmuttee•• Date
Pertnittele Address rr ,/ Phone Number Permit Exp. Date
Sa v<� SFr l Qd. �n N RC '�87� (ff2-.K) 6 7 717-7
PARAMETER CODES
00010 Temperature 00556 Oil&Grease 00951 Total Fluoride 01067 Nickel - 5001 Total
00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
00080 Color(Pt-Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine
00082 Color(ADMq 00625 Total Kjeldhal 01027 Cadmium 01105 Aluminum -
- Nitrogen.. . - _
00095 Conductivity 00630 Nitrates/Nitrites 01032 Hexavalem Chromium 01147 Total Selenium 71880 Formaldehyde
00300 Dissolved Oxygen 01034 Chromium 31616 Fecal Coliform 71900 Mercury
00310 BODs 00665 Total Phosphorous 32730 Total Phenolics 81551 Xylene
00340 COD 00720 Cyanide 01037 Total Cobalt 34235 Benzene
00400 pH 00745 Total Sulfide 01042 Copper 34481 Toluene
00530 Total Suspended 00927 Total Magnesium 38260 MBAS
Residue 00929 Total Sodium 01045 Iron 39516 PCBs
00545 Settleable Matter 00940. Total Chloride 01051 Lead 50050 Flow
Parameter Code assistance may obtained by calling the Water Quality Compliance Gmup at(919)733-5083,extension 581 or 534.
The monthly average for fecal colifonn is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data. ff�� y
'ORC must visit facility and document visitation of facdiGty V1r tied per 15A NCAC 8A.0202(b)(5)(B).
•• If signed by other than the pemunce,delegatibti7�OsiiWAir'i luiSDfiY#;lbust be on file with the state per 15A NCAC 2B.0506(b)
(2)(D).

BASF Corporation BASF
June 14, 1999
Central Files
NC Department of EHNR
Division of Environmental Management
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Dear Sir:
REFERENCE: NPDES Permit No. NC0000299
Quarterly Monitoring Report May 1999
Attached are the results of the 2nd Quarter Priority Pollutant Analyses for the BASF, Enka
site.
Sincerely,
A,- e
Ray(Ackerman
Environmental Manager
Attachment
r a5
Sand Hill Road,P.O.Box 669,Enka,North Carolina 28728-0669 [phone]

n <1
QUARTERLY EFFLUENT MONITORING REPORT
June 14, 1999 FACILITY NAME: BASF Fibers Enka Plant
NPDES PERMIT NO: NC 00002DO
lip
Acrylonitdle 1.41 < 2 < 0.008
Carbon Tetrachloride 0.22 < 1 < 0.004
1,2,4Trichlorobenzene 0.81
1,2-Dichloroethene 1.23 < 1 < 0.004
Hexachloroethane 0.32 - < 10 < 0.039
1,1,2-Tdchloroethane 0.32 < 1 < 0.004
Chloroform 0.27 < 1 < 0.004
1,2-Dichlorobenzene 0.95 < 10 < 0.039
1,4-Dichlorobenzene 0.16 < 10 < 0.039
1,2-trans-Dichlaroeth lene 0.32 < 1 < 0.004
1,2-Dichloropropane 1.34 < 1 < 0.004
2,4Dimethylphenol 0.21 < 10 < 0,039
2,6-Dinitrotoluene 3.74 < 10 < 0,039
Fluoranthene 0.40 < 10 < 0.039
Methyl Chloride 1.11 < 1 < 0.004
Naphthalene 0.016 < 1 < 0.004
2-Nitrophenol 0.40 < 10 < 0.039
2,4-Dinitro henol 0.72 < 52 < 0.201
Bis 2-eth the I)phthalate 1.63 12 O.m

ft,2
Dimethyl phthalate 0.27 < 10 < 0.039
Benzo a)pyrene 0.016 < 10 < 0.039
Benzo(k)fluoranthene 0.016 < 10 < 0.039
Acenapthylene 0.016 < 10 < 0.039
Fluorene 0.015 < 10 < 0.039
Pyrene 0.016 < 10 < 0.039
Toluene 0.47 < 1 < 0,004
Vinyl Chloride 1.57 < 1 < 0,004
Total Copper 19.7 < 5 0.019
Total Nickel 13.81 < 50 < 0.193
Total Cyanide 0.78 < 2 < 0.008
11
Note:
All samples are grab samples taken on May 18th,by Glenn Howell;the flow for that day was 0.464MGD.
I certify that this report is accurate and complete to the beat of my knowledge.
Raym&nd L.Ackerman
Operator in Responsible Charge

n
Pace Analytical Services,Inc.
54 Ravenscrolt Drive
Pace 4nalytocal Asheville,NO 28801
Tel:[phone]
Fax:[phone]
DATE: 06/04/99
PAGE: 1
BASF Corporation Pace Project Amber; 935705
Send Nill Road Client Project ID: Quarterly Pollutant Analysis
Enka, INC 28728
Attn: Mr. Ray Ackerman
Phone: [phone]
Solid results are reported on a Met weight basis
Pace Semple No: 93260214 Date Collected: 05/18/99 Matrix: Meter
Client Sari ID: 001 WTFALL Date Received: 05/18/99
Parameters Results Units PRL Analyzed Analyst CAB# Footnotes
................................. .......... ......... .......... ........ ..... .......... ..........
Natal.
ICP Metals, trace-leveI Method: EPA 200.7 Prep Method: EPA 301D
Chromiun ND ca l 0.005 05/21/99 KEK 7440-47-3
Copper ND ag/l 0.005 05/21/99 KEK 7440-50-8
Lead ND mg/l 0.01 05/21/99 KEK 7439-92-1
Nickel ND ire/1 0.005 05/21/99 KEK 7440-02-0
Data Digested 05/19/99
Net Chemistry
Cyanide, Total, Water Method: EPA 335.4 Prep Method: EPA 335.4
Cyanide ND me/l 0.002 05/27/99 NNB 57-12-5
Total Kjeldahl Nitrogen Method: EPA 351.2 Prep Method: EPA 351.2
Nitrogen, Kjeldahl, Total 3.2 all 0.1 05/27/99 We
Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Prep Method: EPA 353.3
Nitrogen, NO2 plus NO3 9.4 mg/l 5 05/28/99 TRW 7
Phosphorus, Total Method: EPA 365.2 Prep Method: EPA 365.2
Phosphorus 3.6 sg/t 0.1 05/21/99 MPS 7723-14-0
Nitrogen, Total Method: Standard Methods Prep Method:
Nitrogen 13 mg/t 1 06/01/99 TRW 7727-37-9
Laboratory Certification IDS I aboro ory Certficaton IDS
NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980
NC Drinking Water 37712 This report shall not be reproduced,except in full, SC Environmental 99030
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services,Inc.
54 Ravenscr0lt Drive
Pace Analytical Asheville,NC 28801
—— Ter.828-254-7176
Fax [phone]
DATE: 06/04/99
PAGE: 2
Pace Project Number: 035705
client Project ID: Quarterly Pollutant Analysis
PARAMETER FOOTNOtES
NO Not Detected
INC Not Calculable
PRL Pace Reporting Limit
L11 All QC requirements were not met. Acceptable m othod performance based upon ream thing batch QC.
Laboratory G nlflcafon IDs I aborator,Certification IDs
NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980
INC Drinking Water 337712 This report shall not be reproduced,except in full, SC Environmental 99030
without the written consent of Pace Analytical Services,Inc.

n n
Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
Pace Analytocal Minneapolis,MN 55414
Tel:[phone]
DATE: 06/03ga9612-617-6444
PAGE: 1
BASF CORPORATION Pace Project Nuiber: 1014585
Send Hill Road Client Project To: 5705
Enka, NC 28728
Attn: Mr. Rey Ackerman
Solid results are reported on a Met xeight basis
Pace Semple No: 101276897 Date Collected: 05/18/99 Matrix: Meter
Client Senile to: 001 OUTFALL Date Received: 05/19/99
Parameters Results Units PRL Analyzed Analyst CAS# Footnotes
-
-------------------------------- ---------- --------- ---------- -------- ----- ---------- ----------
GC/MS Volatiles
8260 Low Level H2O Method: EPA 8260 Prep Method: EPA 8260
Methyt Chloride ND ug/t 1 05/26/99 74-87-3
Vinyl Chloride ND ug/t 1 05/26/99 75-01-4
Chloroethane ND ug/1 1 05/26/99 75-00-3
Methylene Chloride NO Wt. 1 05/26/99 75-09-2
1,1-Dichloroethytene ND ug/t 1 05/26/99 75-35-4
1,2-trans-DichLor0elhylene ND ug/t 1 05/26/99 156-60-5
1,1-Dichloroethane ND ug/t 1 05/26/99 75-34-3
Chloroform ND ug/l 1 05/26/99 67-66-3
1,1,1-Trichloroethane ND ug/l 1 05/26/99 71-55-6
carbon Tetrechlori de ND ug/l 1 05/26/99 56-23-5
Benzene ND ug/l 1 05/26/99 71-43-2
1,2-Dichloroethene ND ug/l 1 05/26/99 107-06-2
Trichloroethylene ND ug/l 1 05/26/99 79-01-6
1,2-Djchloropropane ND ug/l 1 05/26/99 78-87-5
Toluene ND ug/l 1 05/26/99 108-88-3
1,3-Dichloropropylene ND ug/l 1 05/26/99 10061-01-5
1,1,2-Trichloroethane ND ug/t 1 05/26/99 79-OD-5
Tetrechlcroethylene ND ug/t 1 05/26/99 127-18-4
Chlorobenzene ND ug/1 1 05/26/99 108-90-7
Ethylbenzene ND ug/L 1 05/26/99 IOD-41-4
1,3-Dichlorobenzene ND ug/l 1 05/26/99 541-73-1
1,4-Dichlorobenzene ND ug/l 1 05/26/99 106-46-7
1,2-Dichlorobenzene No ug/t 1 05/26/99 95-50-1 -
1,2,4-Trichlorobenzene No ug/t 1 05/26/99 120-82-1
Naphthalene ND ug/t 1 05/26/99 91-20-3
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc

n
Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
Pace Analytical Minneapolis,MN 55414
Tel:[phone]
Fax.[phone]
DATE: 06/03/99
PAGE: 2
Pace Project Nuclear: 1014585
Client Project to: 5705
Pace SaspLe No: 101276897 Date Collected: 05/18/99 Matrix: Water
Client Semple to: Opt OUTFALL Date Received: 05/19/99
Peremeters Results Units PAL Analyzed Analyst CAS# Footnotes
................................. .......... ......... .......... ........ ..... .......... ..........
AcrylanitriLe NO ug/t 10 05/26/99 107-13-1
Oibramofluoromethane (S) 115 % 05/26/99 1868-53-7
toluene-d8 (S) 123 % 05/26/99 2037-26-5
4-Broneflucrobenzene (S) 112 % 05/26/99 460-00-4
1,2-Dichtoroethane-d4 (S) 112 % 05/26/99 17060-07-0
GC/MS Semivolati Les
SemivoLatiLe Organics Method: EPA 8270 Prep Method: EPA 3520
Phenol No ug/L 10 05/27/99 LAN 108-95-2
2-ChlorophenoL ND u9/L 10 05/27/99 LAM 95-57-8
1,3-Dichlorobenzene ND u9/1. 10 05/27/99 LAN 541-73-1
1,4-Dichtorobenzene ND ug/L 10 05/27/99 LAN 106-46-7
1,2-Dichlarobenzene ND ug/t 10 05/27/99 LAN 95-50-1
2-MethylphenoL ND ug/L 10 05/27/99 LAN 95-48-7
Nitrobenzene ND ug/t 10 05/27/99 LAN 98-95-3
2-Nitrophenol ND ug/t 10 05/27/99 LAN 88-75-5
2,4-Di methylphenoL NO ug/1 10 05/27/99 LAM 105-67-9
2,4-Dichlorophenol NO ug/L 10 05/27/99 LAN 120-83-2
1,2,4-Trichlarobenzene NO ug/t 10 05/27/99 LAN 120-82-1
Naphthalene NO ug/t 10 05/27/99 LAN 91-20-3
Nexachlorobutediene No ug/l 10 05/27/99 LAM 87-68-3
DimethyLphthalate RD ug/1 10 05/27/99 LAN 131-11-3
2,6-Dinitrotoluene ND ug/1 10 05/27/99 LAM 606-20-2
Acenaphthylene ND ug/L 10 05/27/99 LAN 83-32-9
2,4-Dinitrophenol ND ug/l 51 05/27/99 LAN 51-28-5
4-Nitrophenol ND ug/L 51 05/27/99 LAN 100-02-7
2,4-DfnitrotoLuece ND ug/L 10 05/27/99 LAM 121-14.2
DiethyLphthaLate ND ug/L 10 05/27/99 LAM 84-66-2
FLuorene ND ug/L 10 05/27/99 LAM 86-73-7
4,6-Dinitro-o-cresol ND ug/t 51 05/27/99 LAM 534-52-1
MexechLorobenzene ND ug/L 10 05/27/99 LAM 118-74-1
Phenenthrene ND ug/L 10 05/27/99 LAN 85-01-8
Anthracene ND ug/l 10 05/27/99 LAM 120-12-7
Di-n-butyLphthalate 1.7 ug/L 10 05/27/99 LAM 84-74-2 1
FLuoranthene ND ug/L 10 OS/27/99 LAM 206-44-0
Pyrene ND ug/L 10 05/27/99 LAM 129-00-0
Senzo(a)anthracene ND ug/L to 05/27/99 LAM 56-55-3
Chrysene ND ug/L 10 05/27/99 LAN 218-01-9
b1s(2-EthylhexyL)phthalete 12 ua/L 10 05/27/99 LAN 117-81-7
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except to full,
without the written consent of Pace Analytical Services,Inc.

Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
' Pace Analytical Minneapolis,MN 55414
Tel:[phone]
Fax [phone]
DATE: 06/03/99
PAGE: 3
Pace Project Number: 1014585
Client Project ID: 5705
Pace Sasple No: 101276897 pate collected: 05/18/99 Matrix: Water
client Saaple t0: 001 WTFALL Date Received: 05/19/99
Parameters - Results Units PRL Analyzed Analyst CASH Footrxltes
--------------------------------- ---------- --------- ------'--- -------- ----- ......... ----------
3,4-Benzofluorenthene ND uB/l 10 05/27/99 LAN 205-99-2 2
eenzo(k)fluoranthene ND u5/l 10 05/27/99 LAN 207-08-9 2
eenzo(a)pyrene ND u5/l 10 05/27/99 LAN 50-32-8
Hexachloroethane ND u5/l 10 05/27/99 LAN 67-72-1
Nitrobenzene-d5 (S) 105 % 05/27/99 LAN 4165-60-0
2-Fluorobiphenyl (S) 634 X 05/27/99 LAN 321-60-8 3
TerphenyL-d14 (S) 529 % 05/27/99 LAN 1718-51-0 3
Phenol-d6 (S) 27 % 05/27/99 LAN 13127-88-3 3
2-Fluorophenot (S) 102 it 05/27/99 LAN 367-12-4
2,4,6-Tribromophemwl (a) 410 % 05/27/99 LAN 118-79-6 3,4,5
Date Extracted 05/25/99
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the whiten consent of Pace Anayfical Services,Inc.

Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
' Pace Analytical Minneapolis,MN 55414
Tel:[phone]
Fax [phone]
DATE: 06/03/99
PAGE: 4
Pace Project Number: 1014585
Client Project to: 5705
Pace senate No: 101276905 Date Collected: 05/18/99 Matrix: water
Client Senate 10: TRAVEL BLK Date Recei Ved: 05/19/99
Parameters Results Units PRL Analyzed Analyst CAS# Footnotes
................................. .......... ......... .......... ........ ..... .......... ..........
GC/MS Volatiles
8260 Lou Level M20 Method: EPA 826D Prep Method: EPA 826D
Methyl Chloride ND ug/L 1 05/26/99 74-87-3
Vinyl Chloride ND ug/t 1 05/26/99 75-01-4
Ch Loroethane ND ug/( 1 05/26/99 75-00-3
Methylene Chloride No ug/L 1 05/26/99 75-09-2
1,1-DichLoroethylene ND ug/L 1 05/26/99 75-35-4
1,2-trans-DichLoroethytene ND ug/L 1 05/26/99 156-60-5
1,1-Dich Loroethene ND ug/t 1 05/26/99 75-34-3
Chloroform ND ug/L 1 05/26/99 67-66-3
1,1,1-Trichloroethane ND ug/t 1 05/26/99 71-55-6
Carbon Tetrachloride ND ug/L 1 05/26/99 56-23-5
Benzene ND ug/L 1 05/26/99 71-43-2
1,2-D1chLoroethane ND ug/L 1 05/26/99 107-06-2
Trichloroethyl me NO ug/L 1 05/26/99 79-01-6
1,2-Dich Loropropene ND ug/L 1 05/26/99 78-87-5
Toluene ND ug/L 1 05/26/99 108-88-3
1,3-Dichlorapropylene ND ug/L 1 05/26/99 10061-01-5
1,1,2-Trichloroethane ND ug/L 1 05/26/99 79-00-5
Tetrachloroethy(me ND ug/L 1 05/26/99 127-18-4
Chlorobenzene ND ug/t 1 05/26/99 108-90-7
Ethy Lbenzene ND ug/l 1 05/26/99 10D-41-4
1,3-Dichlorabanzene ND ug/L 1 D5/26/99 541-73-1
1,4-Dichlorobenzene ND ug/1 1 05/26/99 106-46-7
1,2-Dichlorobenzene No ug/L 1 05/26/99 95-50-1
1,2,4-Trichlorobenzene ND ug/L 1 05/26/99 120-82-1
Naphthalene ND ug/L 1 05/26/99 91-20-3
Acrylonitri Le ND ug/L 10 05/26/99 107-13-1
Dibromofluorosethene (S) 114 % 05/26/99 1868-53-7
Toluene-de (S) 116 % 05/26/99 2037-26-5
4-Bramofluorobenxene (S) 108 % 05/26/99 460-00-4
1,2-Dichloroethane-d4 (S) 111 % 05/26/99 17060-07-0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc.

n n
Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
Paco Analytical Minneapolis,MN 55414
Tel:[phone]
Fax:[phone]
DATE: 06/03/99
PAGE: 5
Pace Project N..be,: 1D14585
Client Project ID: 5705
PARAMETER FOOTNOTES
ND Not Detected
NC Not Calculable
PRL Pace Reporting Limit
(a) Surrogate
[1) Detected but below the PRL; therefore, result is an estimated concentration (CLP J-Flag).
[2I No internal standard response observed for this compound.
133 The surrogate recovery was outside QC acceptance limits due to matrix interference.
143 Internal standard recoveries confrimed by reanalysis.
[51 Internal standard recoveries outside of method criteria. Not enough sample for re-extraction to prove matrix effect.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services, Inc.

n n
Pau Analytical Services,Inc.
1700 Elm Street-Suite 200
Pace Analytical Minneapolis,MN 55414
Tel:[phone]
Fax:[phone]
QUALITY CONTROL DATA DATE: 06/03/99
PAGE: 6
BASF CORPORATION Pace Project Nutter: 10145BS
Sand Hill Road Client Project ID: 5705
Enka, NC 28728
Attn: Mr. Ray Ackerman
QC Batch 10: 25111 OC Batch Method: EPA 352D
Analysis Method: EPA 8270 Analysis Description: Seal Organics
Associated Pace Seri 101276897
METHOD BLANK: 101286300
Associated Pace Samples:
101276897
Method
Blank
Parameter Units Result PRL Footnotes
.......... .......... .......... ..........
Phenol ug/l ND 10
2-Chlorophenol ug/l ND 10
1,3-Dichlorobenzene ug/t ND 10
1,4-0ichlorobenzene ug/t ND 10
1,2-Dichloroberi ug/l ND 10
2-Methylphenol Wt. NO 10
Nitrobenzene ug/l No 10
2-Nitrophenol ug/1 ND 1D
2,4-Diaethylphenol ug/1 NO 10
2,4-Dichlorophenol ug/l ND 10
1,2,4-Trichlarobenzone ug/l ND 10
Naphthalene ug/l No 10
Hexechlorobutediene ug/l ND 10
Dfeethylphthalate ug/l ND 10
2,6-Dinitrotolume ug/l No 10
Acenephthytene u9i NO 10
2,4-Dinitrophenol ug/1 No 50
4-Nitrophenol ug/l ND 50
2,4-Dinitrat0l uene ug/l No 10
Diethylphthetate ug/l ND 10
Fluorene ug/1 ND 10
4,6-Dinitro-o-cresol ug/t ND 50
Hexachlarobenzene ug/l No 10
Phenenthrene ue/l No 10
Anthracene ug/l ND 10
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc.

n (�
Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
Para Analytocal Minneapolis,MN 56414
Tel:[phone]
Fax:[phone]
DUALITY CONTROL DATA DATE: 06/03/99
PAGE: 7
Pace Project Number: 1014585
Client Project ID: 5705
METHOD BLANK: 101286300
Associated Pace Samples:
101276897
Method
Blank
Parameter Units Result PRL Footnotes
------------------------------ ---------- ---------- ---------- ----------
Di-n-butylphthalate ug/t ND 10
Fluoranthene ug/t ND 10
Pyrene ug/l ND To
Benzo(a)enehracene ug/L ND 10
Chrysene ug/t ND 10
bis(2-Ethylhexyl)phthalate ug/l NO 10
3,4-Senzofluoranthene ug/l ND 10
Benzo(k)fluoranthene ug/l ND 10
Renzo(a)pyrene ug/l ND 10
Nexachloroethene ug/l ND 10
Nitrobenzene-d5 (S) % 86
2-FWorobiphenyl (S) % 97
TerphenyL-d14 (S) % 116
Phenol-d6 (5) % 99
2-Fluorophenol (S) % 110
2,4,6-Tribr.phenol (5) is 123
LABORATORY CONTROL SAMPLE 8 LCSD: 101286318 101286326 Spike
Spike LCS Spike LCSD Dup
Parameter Units Con.. Result % Re. Result % Rec RPD Footnotes
------------------------------ ----- ---- ------- ---------- ----- ---------- ---I- ----- ..........
Phenol ug/t 50 35.24 70.5 41.98 84.0 17
2-Chlorophenol ug/t 50 37.75 75.5 43.39 86.8 14
1,3-Dichtorobenzene ug/l 50 36.97 73.9 43.10 86.2 15
1,4-Dichlorobenzene ug/l 50 36.69 73.4 42.96 85.9 16
1,2-Dichlorobenzem ug/t 50 36.69 73.4 42.85 85.7 15
2-11ethylphernot ug/t 50 39.54 79.1 42.93 85.9 8
Nitrobenzene ug/t 50 38.33 76.7 44.95 89.9 16
2-Nitrophenol ug/t 50 40.48 81.0 48.46 96.9 18
2,4-Dimethylpheoot call. Su 36.98 74.0 17.88 35.8 70 1
2,4-Dichlorophenot ug/1 50 42.76 85.5 48.73 97.5 13
1,2,4-Trichlorobenzene ug/t 50 40.34 80.7 47.25 94.5 16
Naphthalene us/t 50 39.92 79.8 46.24 92.5 15
Rexachlorobutediene ug/t 50 40.44 80.9 47.22 94.4 15
DinethytphthaLate ug/t 50 42.67 $5.3 46.09 92.2 8
2,6-Dinitrotoluene ug/t 50 42.73 85.5 46.52 93.0 8
Acenaphthene ug/t 5D 42.71 85.4 47.02 94.0 10
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc.

Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
Pace Analytical Minneapolis,MN 55414
Tel:[phone]
Fax:6*617-6444
QUALITY CONTROL DATA DATE: 06/03/99
PAGE: 8
Pace Project Nurber: 1014585
Client Project IDz $705
LABORATORY CONTROL SAMPLE 8 LCSD: 101286318 101286326 Spike
Spike LCS Spike LCSD Dup
Parameter Units Conc. Result x Rec Result % Rec RPD Footnotes
........I..................... .......... ....... .......... ..... .......... ..... ..... ..........
2,4-Dinitrophenol ug/l 50 46.06 92.1 52.17 104 12 2
4-Nitrophenol ug/1 50 38.12 76.2 42.19 84.4 10 2,2
2,4-Dinitrotoluene ug/l 50 42.03 84.1 46.14 92.3 9
Viethylphthalete ug/L 50 43.02 86.0 46.64 93.3 8
Fluorene ug/l 50 42.66 85.3 47.25 94.5 To
4,6-Dinitro-o-cresol ug/l 50 47.85 95.7 52.54 105 9 2
Nexachlorobenzene ug/l 50 44.60 89.2 48.15 96.3 8
Phenonthrene ug/l 50 45.11 90.2 48.68 97.4 8
Anthrecene ug/l 50 43.57 87.1 47.78 95.6 9
Di-n-butylphthalate ug/l 50 46.34 92.7 48.21 96.4 4
FLuorenthene ug/l 50 43.29 86.6 46.14 92.3 6
Pyrene ug/l 50 48.63 97.3 49.82 99.6 2
Benzo(e)enthrocene ug/t 50 45.15 90.3 49.46 98.9 9
Chrysene ug/t 50 48.53 97.1 48.44 96.9 0
bis('-Ethylhexyl)phthalate ug/t 50 48.05 96.1 52.74 105 9
3,4-Benzofiuoranthene ug/t 50 41.96 83.9 47.92 95.8 13
Benzo(k)fluoranthene ug/l 50 44.16 66.3 48.68 97.4 10
Senzo(e)pyrene ug/l 50 42.64 85.3 46.77 93.5 9
Nexachloroethane ug/l 50 38.30 76.6 44.17 88.3 14
Nitrobenzene-d5 (S) 81 90
2-Fluorobiphenyl (S) 90 97
Terphenyl-dl4 (S) 96 100
Phenol-d6 (S) 95 105
2-Fluorophenol (S) 102 112
2,4,6-Tribramophenol (S) 121 123
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except In full,
without the written consent of Pace Analytical Services,Inc.

Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
Pace Analytical Minneapolis,MN 55414
Tel:[phone]
Fax:[phone]
QUALITY CONTROL DATA DATE: 06/03/99
PAGE: 9
BASF CORPORATION Pace Project Nvnber: 1014585
Sand Fill Road Client Project 1O: 5705
Enka, NC 28728
Attn: Mr. Ray Ackermen
OC Batch ID: 25160 GC Batch Method: EPA 8260
Analysis Method: EPA 8260 Analysis Description: 8260 Lou Level H2O
Associated Pace Sartples: 101276897 101276905
METHOD BLANK: 101288231
Associated Pace Ronales:
101276897 ID1276905
Method
Blank
Parameter Units Result PRL Footnotes
------------------------------ ---------- ---------- ---------- ----------
MathyL Worlds ug/L ND 1
Vinyl Chloride ug/L ND 1
Chloroethane ug/L ND 1
Methylene Chloride ug/L NO 1
1,1-Dichloroethylene ug/t NO 1
1,2-trans-DichLoroethylene ug/l ND 1
1,1-Dichloroethane ug/L ND 1
Chloroform ug/L ND 1
1,1,1-Trichloroethane ug/L ND 1
Carbon Tetrachloride ug/l NO i
Benzene ug/L ND 1
1,2-DichLorcethane ug/L ND 1
Trichloroethylene ug/L ND 1
1,2-Dich Loropropene ug/L ND 1
Toluene ug/L ND 1
1,3-Dichloropropene u9/1 ND 1
1,1,2-Trich Loroethane u9/1 ND 1
Tetrachloroethylene ug/t ND 1
Chlorobenzene ug/l NO 1
Ethytbenzene ug/l NO 1
1,3-DichLorobenzene ug/t NO 1
1,4-Dichlorobenzene ug/L NO i
1,2-Dichlorobenzene ug/L ND 1
1,2,4-Trich Lorobenzene ug/L ND 1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc.

Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
Pace Analytoral Minneapolis,MN 55414
Tel:[phone]
Fax:[phone]
QUALITY CONTROL DATA DATE: 06/03/99
PAGE: 10
Pace Project Number: 1014585
Client Proj act ID: 5705
METHOD BLANK: ID12SB231
Associated Pace 5e110es:
101276897 101276905
Method
Blank
Parameter Units Result PRL Footnotes
.............................. .......... .......... .......... ..........
Naphthalene ug/l ND 1
Acrytonitrile ug/t ND 10
Dibromofluoromethene (5) % 113
Toluene-& (S) % 123
4-Bromofluorobenzene (5) % Ito
1,2-Dichloroethane-d4 (S) % 112
LABORATORY CONTROL SAMPLE B LCSD: 101288249 101288256 Spike
Spike LCS Spike LCSD Dup
Parameter Units Conc. Result % Rae Result % Rae RPD Footnotes
------------------------------ ---------- ------- ---------- ----- ---------- ----- ----- ----------
Methyl Chloride ug/t 5.000 4.101 82.0 4.796 95.9 16
Vinyl Chloride ug/l 5.000 4.124 82.5 4.882 97.6 17
Chtoroethene ug/l 5.000 4.773 95.5 5.724 114 18
Methylene Chloride ug/l 5.000 4.459 89.2 5.227 105 16
1,1-Dichloraethylene ug/l 5.000 3.719 74.4 4.544 90.9 20
1,2-trans-Dichlorcethylene ug/t 5.000 3.684 73.7 4.457 89.1 19 3
1,1-Dichloroethane ug/l 5.000 4.217 84.3 4.931 98.6 16
Chloroform ug/l 5.000 4.285 85.7 5.160 1D3 18
1,1,1-Trfchloroethene u9/1. 5.000 4.221 84.4 5.109 102 19
Carbon Tetrachloride ug/l 5.000 4.038 $0.8 5.003 100 21
Benzene ug/l 5.000 4.061 81.2 4.878 97.6 18
1,2-Dichloroethane ug/l 5.000 4.375 87.5 4.991 99.8 13
Trichtoroethylene ug/l 5.000 3.961 79.2 4.850 97.0 20
1,2-Dichioropropane ug/l 5.000 4.184 83.7 4.932 98.6 16
Toluene ug/l 5.000 4.D88 81.8 4.904 98.1 18
1,3-Dichtorepropylene ug/l 5.000 4.004 80.1 4.810 96.2 18
1,1,2-Trichloroethane ug/i 5.000 5.144 103 6.145 123 18
Tetrachlorcethylem ug/l 5.000 4.156 83.1 4.903 98.1 17
Chlorobenzene us/1 5.000 4.148 83.0 4.937 98.7 /7
Ethylbenzene u9/1. 5.000 4.192 83.8 5.079 102 20
1,3-Dfchlorobenzme ug/l 5.000 4.156 83.1 5.003 100 18
1,4-Oichlarobenzene ug/l. 5.000 4.033 80.7 4.912 98.2 20
1,2-Dichtorobenzene ug/l 5.000 4.082 81.6 4.904 98.1 18
1,2,4-Trichlorobenzene ug/l 5.000 3.036 60.7 3.885. 77.7 25 3
Naphthalene ug/l 5.000 2.806 56.1 3.745 74.9 29
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc.

;
RECEIVED
JUN 16 1999
CENTRAL FILES

Pace Analytical Services,Inc.
1700 Elm Street-Suite 200
Para Analytical MlnneapDIIS,MN 55414
Tel:[phone]
Fax:[phone]
QUALITY CONTROL DATA DATE: 06/03/99
PAGE: 11
Pace Project Number: 1014585
Client Project ID: 5705
LABORATORY CONTROL SAMPLE 8 LCSD: 101288249 101288256 Spike
Spike LCS Spike LCSD Dup
Parameter Units Cont. Result % Roe Result It See RPD Footnotes
-------------------_ ----------____------ .-..... ----. ---- ----- --........ ..... ----- _____.-.--
AcrytoniSrile ug/t 25 43.06 172 49.36 197 14
Dibr one,Fluor one there (5) 1% 113
Toluene-d8 (S) 120 120
4-Broroftuorobenxene (S) 111 110
1,2-Dichloroethane-d4 (S) 108 109
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except In full,
without the written consent of Pecs Analytical Services,Inc.

RECEIVED
JUN 16 1999
CENTRAL FILES
i

Pace Analytical Services,Inc.
A 1700 Elm Street-Suite 200
A Pace �ytical Minneapolis,MN 55414
Tel:[phone]
Fax:[phone]
DATE: 06/03/99
PAGE: 12
Pace Project Number: 1014585
Client Project ID: 5705
DUALITY CONTROL DATA PARAMETER FOOTNOTES
Consistent with EPA guidelines unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
ND Not Detected
NC Not Calculable
PRL Pace Reporting Limit
RPD Relative Percent Difference
(a) Surrogate
[1) The surrogate and/or spike recovery was outside acceptance limits.
[2) Detected but below the PRL; therefore, result is an estimated concentration (CLP J-Fleg).
[31 Spiked sample recovery is not within control limits.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except In full,
without the written consent of Pace Analytical Services,Inc.

t
RECEIVED
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r

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
m� ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION -
NCDENR ,; March 15, 1999
fl ; ' 2dA
DAME B I{ NTJR
GOVERNOR � � Mr. Jack A. Dellinger, PhD
General Manager
. , BASF Corporation
Sand Hill Road
wwYN¢iipoeV„ Enka, North Carolina 28728
9E RETARY I
Subject : Performance Audit Inspection
( Inspection Rating "B-Minus"
UWastewater Treatment Program
I,FPE'YDIRe� R
BASF Corporation
NPDES Permit Number NC0000299
Buncombe County, North Carolina
Dear Mr. Dellinger: \�f1'—
fr The Performance Audit Inspection (PAI) that Gary
Francies and I conducted on February 18, 1999, of BASF' s
N wastewater treatment program resulted in an overall rating of
)� B-Minus relative to the evaluation of sampling, flow
measurement, and laboratory procedures. Regulatory and
1 methodology violations were..identified in the laboratory
( '') portion of the inspection which basically centered around
handling of chlorinated samples for ammonia and fecal
coliform analysis. Additionally, documentation of drying
times for the total suspended residue analysis together with
BCD seed correction and dilution problems need to be
addressed. Comparison of results of split sample analysis
between the BASF laboratory and the NCDENR Water Quality
' laboratory show concerns which need to be further evaluated.
The results of this PAI should not be interpreted to
question compliance with terms and conditions contained in
-,r- the NPDES permit. Sample analysis showed the discharge to be
meeting effluent limitations and the evaluation of the
wastewater treatment facility showed proper operation and
control. The high total suspended residue concentration
tentatively attributed to the presence of finishing oils in
-0�1i . the wastewater stream is of concern as it approached the
' lgl- daily maximum effluent limitation. The source of the high
total suspended residue concentration should be located and
addressed.
r' 1 'y'.9k:'ml Y INTdCNANO¢BVILO NOBB WOOD FIN PIP..,pBN¢VILL0.NC 1880T 2414
'T'1L' PNONA 82828/ 8208 FAX 828.251 E482
AN EQUAL OPPORTUNITY/AFPI RM/SIVB ACTION EMPLOYER 50%RECYCLED/I 0%P09T CONEU MKR PAPER
.4dL.
Euyll a' �3�IiE�ia

C"9 �
Page 2
Mr. Dellinger
j_
A copy of the report is attached for your review. If you have
questions regarding this report, please do not hesitate to contact
Mr. Francies or me at (828) 251-6208 !'
Y uo tr ly
G A
Environmental Chemist
Enclosure
cc: Melinda Greene, EPA
Forrest R. Westall
Gary Francies

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A United States nmental Protection Agency Form Approved
W-D.-n, D.C.20460 OMB No. 2040-0003
CPA NPDES Compliance Inspection Report Approval Expires 7-31-85
Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Far,Type
1 IN 1 215 1 3 1 NC0000299 11 12 99/02/18 17 18 Lq j 19 $ 20[Zj
uu a Remarks u u
II .-I I I I I I I I I I I I I I I I I
Reserved Facility Evaluation Rating BI CA
Reserved
67 69 70 In 71 on 72u 73 74 75 LLL-LLJ
80
Section B:Facility Date
Name and Location of Facility Inspected. Entry Time Permit Effective Date
BASF CORPORATION 0830 HRS 90/10/01
US.HWY 19/23 & NC 112
ENKA, NC, BUNCOMBE COUNTY Exit Time/Date Permit Expiration Date
1530 HRS 95/09/30
Name(s)of On-Site Representative(sT/Title(s) Phone N.B)
RAY C. ACKERMAN, ORC [phone]
MANAGER, ENVIRONMENTAUSAFETY/QUALITY
Name,Address of Responsible Official Title
JACK A. DELLINGER GENERAL MANAGER
BASF CORPORATION
E Congaed
[phone] NONKA, N.C. 28728 Phone No.
Section C:Areas Evaluated During Inspection CODESv S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluatedsNot applicable
S Permit S Flow Measurement L4S
Pretreatment $ Operations &Maintenance
S Records/Repoas $ Laboratory Compliance Schedules $ Sludge Disposal
S Facility Site Review S Effluent/Receiving Were. Self-Monitoring Program Other:
Section D:Summary of Findings/Commests (Anach additional sheets it necessary)
EFFLUENT DATA (COMPOSITE) PERMIT LIMITS (MO AVE/WEEKLY AVE)
FLOW — 0.632 MGD 1.25 MGD
BOD,5-DAY — 137 #/DAY(26 MG/q 136 #/DAY / 291 #/DAY
TSS — 527 #/DAY(6 MG/D 209 #/DAY / 565 #/DAY
FECAL COLIFORM —<10 /100ML (GRAB) 2001100MU 400/100ML
D.O. — 8.9 MG/L @ Il-C NOT LIMITED
pH 7.90 6.0 / 9.0 (RANGE)
ZINC — NS 3.65 #/DAY/643.5 UCJL -
THE W WTP WAS IN FULL OPERATION.WITH ALL UNITS APPEARING IN GOOD WORKING ORDER. ONE OF THE TWO CLARIFIERS (SOUTH CLARIFIER)
WAS OUT OF SERVICE FOR ROUTINE CLEANING AND WEIR LEVELING. NO PROBLEMS WERE NOTED.SLUDGE WAS BEING HANDLED VIA THE FRAME
FILTER PRESS. WASTING 15 BASED ON THE FM RATIO AND THE VOLATILE SOLIDS(AERATION)WHICH IS MAINTAINED IN THE RANGE OF 1100-1200
MCA. THE FACILITY WAS PRODUCING AN EFFLUENT WHICH WAS EXTREMELY CLOUDY WITH HIGH TSS(THOUGHT DUE TO FINISHING OILS BEING
INTRODUCED BY THE MANUFACTURING PROCESS). DISINFECTION 15 BEING PERFORMED BY USE OF A BROMO-CHLORO-DIMETHYDANTOIN TABLET
SYSTEM WHICH WAS PLACED IN USE THIS PAST YEAR. THE DISCHARGE WAS IN COMPLIANCE WITH DAILY MAXIMUM PERMIT LIMITS.
Names)and Signature(s) o Imp torts) Agency/Offce/Telephone Date
MAX L. HANER .-7
DWQ/ARO 828-251-6208
Sig ture of Rev ver Agency/Office Datgy
DWQ/ARO 828-251-6208 . . 9 i
Regulatory Office Use Only
Action Taken ' Date Compliance Status
Noncompliance
Action Taken 7;
Compliance

PERFORMANCE AUDIT INSPECTION
WASTEWATER TREATMENT FACILITY (NC0000299 )
BASF CORPORATION
ENKA, NORTH CAROLINA
FEBRUARY, 1999
INTRODUCTION
On Thursday, February 18, 1999, the North Carolina Division of
Water Quality conducted an on-site inspection of BASF' s
wastewater treatment program including evaluation of the
laboratory and sample collection procedures.
The Performance Audit Work with the Company' s laboratory was
conducted by Gary Francies and Max Haner of the Division' s
Asheville Regional Office. Personnel from BASF Fibers were Ray L.
Ackerman, Manager, Environmental/Safety/Quality and Operator in
Responsible Charge (ORC) of the wastewater treatment facility;
Kay Crowder, Maintenance Superintendent and backup operator; Don
Canipe & Don Wilkey, electrician; Ross Peebles, laboratory; and
Eric Barbour, Site Facilities .
The purpose of this inspection was to determine the quality of
the self-monitoring program being conducted by BASF Fibers
Corporation and assess the reliability of its reported data.
The inspection consisted of evaluation of the flow monitoring
equipment and data handling, evaluation of sample collection and
preservation techniques and evaluation of laboratory and
analytical techniques, record keeping and data reporting.
procedures. . NPDES-permit number NC0000299 provides for a
discharge (001) from the Company' s wastewater treatment facility;
two equalization basins (series) ,an aeration basin, dual final
clarifiers, achlorine contact chamber, a mixing lagoon, sludge
handling and disposal (thickener, conditioner, filter press, BASF
landfill as cover) with discharge to Hominy Creek, Class "C"
waters in the .French Broad River Basin. . Additionally, . the permit
provides for a discharge (002) of non-contact cooling water from
a barometric condenser into Hominy Creek via the east ditch on
BASF property.
BASF Fibers Corporation is conducting the self-monitoring part of
this program in accordance with monitoring requirements contained
in NPDES Permit Number NC0000299 . Flow measurement, composite
sampling and collection of samples is satisfactory. Violations were found, however, with the laboratory methodology which
addressed sample preservation (and documentation) for chlorinated
samples for ammonia and fecal coliform analysis. Additional
violations were noted in documentation of drying,times. for total
suspended residue sample analysis and seed correction and
dilution practices in the SOD sample analysis. As result,
the overall PAI rating for this facility is B-Minus. A PAI
rating sheet is attached.

Page 2
1999 PAI Report
BASF Corporation Wastewater Treatment Facility
FINDINGS AND RECOMMENDATIONS
Recommendations contained in this section ill appear as
regulatory requirements to correct deviations or as suggestions
to strengthen the self-monitoring and laboratory program.
A. FIELD EVALUATION
1 . - FLOW MEASUREMENT: Flow is measured at the 001
discharge structure in the final mixing lagoon using a
30-inch cipolletti weir with a Miltronic ultrasonic
depth probe and Honeywell Recorder. Accuracy of this
unit including the integrity of the work is checked
weekly, The unit is checked for accuracy during zero
flow periods when the level of the final basin is
lowered for maintenance. Last calibration by Law
Engineering on 1/28/99 . A check of the weir showed it
to be plumb, level, and meeting requirements for a
properly installed cipolletti weir. Additionally,
instantaneous flow measurement at the weir compared
with instrumentation recordings showed a difference of
approximately 7. 6%, well within the allowable 10%
difference .
a. RECORDS : Records are maintained in a hardbound
notebook by Don Canipe, maintenance (electrician) .
Mr Canipe was assisted by Don Wilkey.
b. DATA HANDLING: Flow totalizer measurements are
handling properly.
2 . SAMPLING PROCEDURES : The effluent composite
sampling device for discharge 001 is an ISCO model
371OR unit with refrigeration. The permit requires no
monitoring of discharge 002 .
a. Effluent 24 hours composite samples are collected
proportional to flow with a setting of 125 ml per
cycle. Each sampling cycle is approximately 5, 000
gallons . Two separate measurements showed the actual
sample aliquot to be . 124 ml and 120 ml.
b. Pump and sample tubing last was replaced in
October, 1998 . Tubing is checked routinely and
replaced as necessary. The. sample strainer was in need
of cleaning.

Page 3
1999 PAI Report
BASF Corporation Wastewater Treatment .Facility
C. Records: The volume of each composite sample is
I_
measured and recorded. . These records also should
include the temperature of each composite sample upon -
collection.
3 . FIELD MEASUREMENTS :
a. The effluent dissolved oxygen (D.O. ) measurement
is measured daily during the time the composite
sample is collected for analysis using a D.O. meter
and probe. D.O. measurement of the discharge was
8 . 9 mg/l ® 11° C (NCDWQ) .
b.. The effluent pH measurement is performed in the
laboratory from a grab sample collected from the
discharge during sample pickup. The pH was measured at
7.90 s .u. (NCDWQ) .
C. The effluent total residual chlorine concentration
is measured in the laboratory from a grab sample
collected from the discharge during sample pickup.
The total residual chlorine was measured at 0 . 11 mg/l i.
(NCDWQ) .
j.
4 . SAMPLE HANDLING : The composite sample (carboy)
was properly handling with the sample being thoroughly
mixed prior to transfer to the sample container(s) .
5 . RECORD MAINTENANCE : Preventative maintenance
work performed on the system was in accordance with.
needs addressed in the weekly computer printout .
Calibration records for the dissolved oxygen sensors in
the aeration basin should be maintained. Time of
operation records for the solids handling system need
to be maintained.
6 . OPERATION & MAINTENANCE : O&M is being performed
in a satisfactory with interest on preventative. The
south clarifier was being cleaned and its weir was
being leveled duringthis inspection. Wasting of
solids based on F/M ratio and volatile solids in the
system (target 1100-1200 mg/1).. _
7 . PERMIT VERIFICATION: The facility is operating
in compliance with terms and conditions contained in
the NPDES permit (NC0000299) . The permit accurately
reflects the existing wastewater treatment facility and
discharge location.
_ . ,.... _ . _ . . .. . .. . _ ..... III

Page 4
1999 PAI Report
BASF Corporation Wastewater Treatment Facility
B . LABORATORY EVALUATION
1 . PERSONNELL : All NPDES testing performed at this
facility is under supervision of Ray Ackerman. The manager
of the laboratory is Jack Dellinger, PhD. -
2 . FACILITIES AND EQUIPMENT : The laboratory is
spacious and adequately equipped for testing performed at
this location of this faciltiy. The laboratory routinely
conducts tests for pH, SOD, Total Suspended Residue, Fecal
Coliform, Ammonia, Zinc, Total Residual Chlorine, and
Temperature. The BASF laboratory is state certified for the
above parameters. Pace Laboratories, Inc. , performs the
remaining NPDES analyses including Aquatic Toxicity.
A new spectrophotometer has been obtained by BASF since the
last inspection for ammonia analysis.
3 . METHODOLOGY : All testing procedures are based upon
EPA' s approved methodology or the Laboratory Certification
Regulation; 15A NCAC 2H. 0800 . Violations are entered as
follows:
a. Violation - Sample Preservation
Dechlorination of both the ammonia sample or the fecal
coliform sample is not documented and therefore
considered as not being performed>
Requirement: 15A NCAC 2H. 0805 (a) (1) & (7) (M) & (N)
requires in part that samples containing chlorine must
be dechlorinated at the time of sample collection and
treated according to the requirements of the anaklysis
to be performed. Upon receipt in the laboratory, _
samples treated for chlorine must be checked and
documented to be free of chlorine.
b. Violation - Total Suspended Residue
The time that the sample is placed in the oven for
drying and the time that the sample is taken from the -
oven is not being documented.
Requirement: 15A NCAC 2H. 0805 (a) (7) & (a) (7) (D)
. requires drying times be documented. -

Page 5
1999 PAI Report r
BASF Corporation Wastewater Treatment Facility
C. Violation - BOD
The seed correction factor must be in the range of
0. 6 mg/l to 1. 0 mg/l. Records indicate the seed
correction factor for this analysis was below thisI
range.
Requirement: STANDARD METHODS, 18TH Edition, Method
5210B. 4d 2 .
d. Violation - BOD �(
The dilutions used for seed control have been too low
to yield proper D.O. depletion and residual
requirements.
Requirement: STANDARD METHODS, 18TH Edition, Method
5210B. 5 - requires that seed controls and samples must
have at least 2. 0 mg/l D.O. depletion plus a residual
D.O. of 1. 0 mg/l.
e. Violation - Method Quality Control requirements
not being met must be noted on the discharge monitoring
report (DMR) .
Requirement: 15A NCAC. 2H. 0805 (a) (7) & (a) (7) (D) . .
4 . RECORDS KEEPING :
Laboratory record keeping was consistent with good �.
laboratory practice. Records were complete and. well
detailed.
5 . QUALITY CONTROL :
Effluent samples split with the BASF laboratory showed
the following comparison: j
BASF LABORATORY DWQ LABORATORY
BODS 17 . 9 mg/l 26.2 mg/1 ,
TSS 85 mg/l 102 mg/1
Non-efflesint . sample split only for compadtive purposes
FECAL COLT 520/100 ml 270/100 ml _

Page 6
1999 PAI Report
BASF Corporation Wastewater Treatment Facility.
6 . DATA HANDLING & REPORTING :
A review of discharge monitoring report (dmr) and
supporting data for August, October, and November,
1998, showed no data entry or dmr transfer problems .
The facility was transcribing data in a satisfactory
manner.

PAI RATING SCALE
Ra in General Description
A The facility has no problems with flow monitoring,
sampling, analyses or data calculating and reporting
procedures. The overall self-monitoring program and
the quality and reliability of the data reported to
state/federal agencies are excellent. The general
operation of the entire facility is also very good.
B _ The facility has a few minor problems in one or more
areas of flow monitoring, sampling, analyses or data
calculating and reporting procedures. Examples include
infrequent calibration of flow monitoring equipment,
improper refrigeration of samples, slight discrepancies
in oven or incubator temperatures and not keeping
thorough records. The self-monitoring program is good
and the problems have no major impact on data
reliability. The overall operation of the facility is
very good.
C The facility has a major or several minor problems with (_
flow monitoring, sampling, analyses or data calculating
and reporting procedures. Examples include
malfunctioning flow monitoring equipment, improper
sampling site, not dechlorinating fecal coliform samples,
unacceptable oxygen depletions and improper seed
correction factors in BOD analyses. The problems noted
at .the facility cause the reliability of some of the data
to be questionable. The general operation of the overall
facility is good.
D - - There are -major- problems with flow monitoring, sampling
analyses or data calculating and reporting procedures .
Examples include estimating flow, collecting samples at
wrong locations, using improper glassware or equipment,
malfunctioning laboratory equipment, poor laboratory
techniques, or errors in data calculations . The problems
cause the reliability of the self-monitoring data to be
highly questionable. The overall operation of the
facility is fair.
E Severe problems with flow monitoring, sampling, analyses
or data calculating and reporting procedures cause the
self-monitoring data to be unreliable. Examples include
no flow monitoring capabilities, wrong sampling
frequencics and procedures, using unacceptable analytical
techniques or fabrication of information. The self-
monitoring program and the general operation of the
facility is poor. _

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State of North Carolina
Department of Environment �t, 00
and Natural Resources
Asheville Regional Office `s �
Division of Water Quality NCDENR
James B. Hunt, Jr., Governor NORTH CAROLINA DEPARTMENT OF
Wayne McDevitt, Secretary ENVIRONMENT AND NI Ri RE OOR`es ,
WATER QUALITY SECTION
March 9, 1998
Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Subject: Performance Audit Inspection
Inspection Rating "A-Minus"
Wastewater Treatment Program
BASF Corporation
NPDES Permit Number NC0000299
Buncombe County, North Carolina
r
Dear Mr. Dellinger:
The Performance Audit Inspection (PAI) that Mr. Gary Francies and I
conducted on February 19, 1998, of BASF' s wastewater treatment program
resulted in an overall rating of A-Minus relative to the evaluation of
sampling, flow measurement, and laboratory procedures. A minor violation
of the laboratory certification regulations (15A NCAC 2H. 0600) was noted
during the inspection.Specifically, the BOD bench worksheets should show
the time that each BOD set is removed from the incubator and each
worksheet should be initialed by the analyst. A copy of the report is
attached for your review.
The wastewater treatment facility is considered in full compliance
with terms and conditions contained in NPDES Permit Number NC0000299.
If you have questions regarding this report, please do not hesitate to
contact Mr. Francies or me at (704) 251-6208.
Yqurh trul 2 xy, -,
L. Haner / i
Environmental Chemist
Enclosure iIII Naund,
ege 1=10 cc: A , EPA
Forrest R. Westall
Gary Francies
59 WDodtin Place, Asheville, North Carolina 28801
Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer

United State^ ironmental Protection Agency Form Approved
Washington, D.C.20460 OMB No. 2040-0003
EPA NPDES Compliance Inspection Report Approval Expires 7-31-85
Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fan Type
1 u 2 3 NC0000299 11 12 98/02/19 17 18 LJ 19 u 20 u u I�I Remarks
Reserved Facility Evaluation Rating BI QA Reserved
67' I69 70 1u a ' 71 I KI 72 I KI u I 73 �74 75 �80
I Sectioonn B:Facility Date
Name and Location of Facility Inspected Entry Time Permit Effective Date
BASF CORPORATION 0850 HOURS 95/12/01
US HWY 19/23 & NC HWY 112 (SAND HILL RD)
ENKA, NC (BUNCOMBE COUNTY) Exit Time/Date Permit Expiration Date
1545 HOURS 00/09/30
Name(s)of On-Site Representative(s)/Title(s) Phone No(s)
RAY C. ACKERMAN, ORC & MGR OF ENVIRONMENTAL SAFETY & QUALITY [phone]
KAY CROWDER/DON CANIPE
Name,Address of Responsible Official Title
DR.JACK A DELLINGER GENERAL MANAGER
BASF CORPORATION
ENKA, N.C. 28728 Phone No. Contacted
(704) 667- 7110 YES
Section C:Areas Evaluated During Inspection CODES m S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated/Not applicable
$ 7�Rup.ftb
S Flow Measurement N Pretreatment $ Operations &Maintenance
S S Laboratory N Compliance Schedules $ Sludge Disposal
$ ew S Effluent(Receiving Waters S Self-Monitoring Program Other:
Section D:Summary of Findings/Comments (Attach additional sheets if necessary)
EFFLUENT DATA 1 (COMPOSITE) PERMIT LIMITS (MO AVEIWEEKLY AVE)
FLOW — 0.434 MGD 1.25 MGD
BOD,5-DAY — 32.2 #/DAY(8.9 MG/H 136 #/DAY / 291 #/DAY
T55 — 21.7 #/DAY(6 MUL) 209 #/DAY / 565 #/DAY
FECAL COLIFORM — 8 /100ML (GRAB) 200/100MU 400/100ML
D.O. — 8.65 MG/L®12-C NOT LIMITED
AMMONIA — <0.1 MG/L NOT LIMITED
PH — 7.45 6.0 / 9.0 (RANGE)
ZINC — NS 3.65 #/DAY/643.5 UG/L
THE WWTP WAS IN FULL OPERATION.WITH ALL UNITS APPEARING IN GOOD WORKING ORDER., ONE OF THE TWO CLARIFIERS WAS OUT OF
SERVICE FOR ROUTINE O&M. NO PROBLEMS WERE NOTED.SLUDGE WAS BEING HANDLED VIA THE FRAME FILTER PRESS. WASTING 15 BASED ON THE
F/M RATIO AND THE VOLATILE SOLIDS(AERATION)WHICH 15 MAINTAINED IN THE RANGE OF 1300 -1500 MCA. THE FACILITY WAS PRODUCING AN
EFFLUENT IN COMPLIANCE WITH PERMIT CONDITIONS. COMPLIANCE NOTED.
Name(,)and Sign" s of I pector(s Agency/Offce/Telephone Date
MAX L. HAN
DWQ/ARO 704-251-6208
Si o ie r Agency/Office Dale
DWQ/ARO 704-251-6208
Regulatory Office Use Only
Anion Taken Data Compliance Status
D Noncompliance
Compliance

PERFORMANCE AUDIT INSPECTION
WASTEWATER TREATMENT FACILITY (NC0000299)
BASF CORPORATION
ENKA, NORTH CAROLINA
FEBRUARY, 1998
INTRODUCTION
On Thursday, February 19 , 1998 , the North Carolina Division
of Water Quality conducted an on-site inspection of BASF' s
wastewater treatment program including evaluation of the
laboratory and sample collection procedures .
The Performance Audit Work with the Company' s laboratory was
conducted by Gary Francies and Max Haner of the Division' s
Asheville Regional Office . Personnel from BASF Fibers were
Ray L . Ackerman, Manager, Environmental/Safety/Quality and
Operator in Responsible Charge (ORC) of wastewater treatment
facility; Kay Crowder, Maintenance Superintendent and backup
operator; Don Canipe, Electrician; and Ross Peebles ,
laboratory.
The purpose of this inspection was to determine the quality
of the self-monitoring program being conducted by BASF Fibers
Corporation and assess the reliability of its reported data .
The inspection consisted of evaluation of the flow monitoring
equipment and data handling, evaluation of sample collection
and preservation techniques, and evaluation of laboratory
analytical techniques, record keeping and data reporting
procedures . NPDES Permit Number NC0000299 provides for a
discharge (001) from the Company' s wastewater treatment
facility; two equalization basins (series) , an aeration
basin, dual final clarifiers, a chlorine contact chamber
(disinfection currently not necessary) , a mixing lagoon,
sludge handling and disposal (thickener, conditioner, filter
press, BASF landfill as cover) and a discharge (002) of non-
contact cooling water from a barometric condenser into Hominy
Creek, Class "C" waters in the French Broad River Basin via
the east ditch on BASF property.
BASF Fibers Corporation is conducting its self-monitoring
program in accordance with monitoring requirements contained
in NPDES Permit No . NC0000299 . A minor regulatory violation
noted in the BOD procedure centered around failure of the
analyst to initial the bench worksheet and record the times
the samples were removed from the incubator . No other
violations were found during this inspection.
The overall PAI rating for this facility is "A-Minus" . A PAI',
rating sheet is attached.

Page 2
1998 PAI Report
BASF Corporation Wastewater Treatment Facility
FINDINGS AND RECOMMENDATIONS
Recommendations contained in this section will appear as
REGULATORY REQUIREMENTS to correct deviations or as
SUGGESTIONS to strengthen the self-monitoring and laboratory
program.
A. FIELD EVALUATION
1 . FLOW MEASUREMENT: Flow is measured at the 001
discharge structure in the final mixing lagoon using a
30-inch Cipolletti weir with a Miltronic ultrasonic
depth probe and Honeywell Recorder. Accuracy of this
unit including the integrity of the weir is checked
weekly. The unit is checked for accuracy during zero
flow periods when the level of the final basin is
lowered maintenance . Lastcalibration by outside firm
(Law Engineering) 1/17/96 . -
a. RECORDS : Records are maintained in a hardbound
notebook by Don Canipe, maintenance (electrician) .
b. DATA HANDLING: Flow totalizer measurements are
handled properly.
2 . SAMPLING PROCEDURES : The effluent composite sampling
device for discharge 001 is an ISCO model 3710R unit
with refrigeration. The permit requires no monitoring
for discharge 002 .
a. Effluent 24 hour composite samples are
proportional with setting to collect an aliquot of
approximately 125 ml per cycle ; approximately 20 , 000
gallon intervals . Actual measurement of this aliquot
was 120 ml .
b . SAMPLE EQUIPMENT - Pump and Sample Tubing was
replaced three times since the previous PAI inspection
(April , 1997) .
c . RECORDS : The volume of each composite is measured
and recorded for preventative maintenance purposes .

n
Page 3
1998 PAI Report
BASF Corporation Wastewater Treatment Facility
2 . SAMPLING PROCEDURES CONTINUED:
c . The temperature of the refrigeration unit is
checked regularly by measurement of the composite
sample during the time it is collected. Measurement is
performed via use of a dissolved oxygen meter with
records maintained in laboratory. A thermometer was
present in the refrigerator proper and a second
thermometer was present in the sample carboy.
The temperature of composite sample was 4°C . A
previous problem with warm-weather temperature
variations in this unit apparently was solved by using
a glass carboy.
3 . FIELD MEASUREMENTS :
a. The effluent dissolved oxygen (D.O. ) measurement
is measured daily during the time the composite
sample is collected for analysis with D .O. meter and
probe . D .O. measured 8 . 65 mg/l @ 120C (NC DWQ)
b. The effluent pH measurement is performed in the
laboratory from a grab sample collected from the
discharge during the time the composite sample is
collected. The pH measured 7 . 45 s .u.@ 13 . 2°C (NC DWQ)
4 . SAMPLE HANDLING: The composite sample (carboy)
was properly handled. The sample was thoroughly mixed
prior to transfer to the sample container .
5 . RECORD MAINTENANCE : Preventive maintenance work
preformed on system in accordance with weekly computer
printout . Records of all adjustments and corrections
to the sampling or flow measuring equipment are being
properly maintained.
6 . OPERATION AND MAINTENANCE : O&M for all units of this
facility is satisfactory. The equalization basin and
digester were cleaned and repainted since previous PAI
inspection. Wasting of solids is based on the F/M
ratio and volatile solids in system (target : 1300 to
1400 mg/1) . One of the two clarifiers were down for
routine repairs .

Page 4
1998 PAI Report
BASF Corporation Wastewater Treatment Facility
A. 7 . PERMIT VERIFICATION: The facility is operating in
compliance with terms and conditions contained in
NPDES permit No . NC0000299 . The permit accurately
reflects the existing wastewater treatment facility
and discharge location (001) .
B . LABORATORY EVALUATION
1 . PERSONNEL : All NPDES testing performed at this
facility is under supervision of Joann Henderson as
Administrative Supervisor and Ray Ackerman, Functional
Supervisor . The manager of the laboratory is Jack
Dellinger, PhD .
2 . FACILITIES AND EQUIPMENT: The laboratory is spacious
and adequately equipped for testing performed at this
location for this facility. The laboratory routinely
conducts tests for pH, BOD 5 Total Suspended Residue,
Fecal Coliform, Ammonia, Zinc, and Temperature . The
BASF laboratory is state certified for these
parameters . The remaining NPDES analyses including
Chronic Toxicity are performed by Pace Laboratories,
Inc . (certified commercial laboratory) . Lab equipment
appears well maintained.
3 . METHODOLOGY: . All testing procedures are based upon
EPA' s approved methodology the Laboratory
Certification Regulation; 15A NCAC 2H . 0800 . '
A minor regulatory violation was noted in the
procedure for handling bench worksheets during the
DOD analysis . (see below)
Of the 53 most recent BOD sets, 17 sets failed to show
the initials of the laboratory person analyzing the
sample and 22 failed to record the time the sample was
removed from the incubator .
The bench worksheet prepared during the BOD analysis
should include a record of the time that the sample
was removed from the incubator as well as the initials
of the analyst . REGULATORY REQUIREMENT-LABORATORY
CERTIFICATION REGULATION 15A NCAC 2H . 0805 (a) (7) (H)

Page 5
1998 PAI Report
BASF Corporation Wastewater Treatment Facility
4 . RECORDS KEEPING : Laboratory record keeping was
consistent with good laboratory practice .
Review showed data to appear accurate .
5 . SAMPLE HANDLING AND PRESERVATION: All samples were
found to be collected and preserved and in accordance
with standard procedures .
6 . QUALITY CONTROL :
Samples were split with BASF for comparative analysis
showed the following results :
BASF Laboratory State Laboratory
BOD, * 4 . 7 mg/1 8 . 9 mg/1
TSS * 5 . mg/1 15 mg/1
Ammonia * 0 . 1 mg/1 <0 . 1 mg/1
Fecal 83/100 ml 57/100 ml
* Effluent Sample
7 . DATA HANDLING AND REPORTING: A comparison of laboratory
bench sheets and contract laboratory reports for the
months of March, May, and November, 1997 , were made to
the monthly discharge monitoring reports (DMRs) . No
problems were found in data transfer.

PAI RATING SCALE
Ratina General Description
A The facility has no problems with flow monitoring,
sampling, analyses or data calculating and reporting
procedures . The overall self-monitoring program and
the quality and reliability of the data reported to
state/federal agencies are excellent. The general
operation of the entire facility is also very good.
B The facility has a few minor problems in one or more
areas of flow monitoring, sampling, analyses or data
calculating and reporting procedures . Examples include
infrequent calibration of flow monitoring equipment,
improper refrigeration of samples, slight discrepancies
in oven or incubator temperatures and not keeping
thorough records . The self-monitoring program is good
and the problems have no major impact on data
reliability. The overall operation of the facility is
very good.
C The facility has a major or several minor problems with
flow monitoring, sampling, analyses or data calculating
and reporting procedures . Examples include
malfunctioning flow monitoring equipment, improper
sampling site, not dechlorinating fecal coliform samples,
unacceptable oxygen depletions and improper seed
correction factors in BOD analyses . The problems noted
at the facility cause the reliability of some of the data
to be questionable. The general operation of the overall
facility is good.
D There are major problems with flow monitoring, sampling
analyses or data calculating and reporting procedures. -
Examples include estimating flow, collecting samples at
wrong locations, using improper glassware or equipment,
malfunctioning laboratory equipment, poor laboratory
techniques, or errors in data calculations . The problems
cause the reliability of the self-monitoring data to be
highly questionable . The overall operation of the
facility is fair.
E Severe problems with flow monitoring, sampling, analyses
or data calculating and reporting procedures cause the
self-monitoring data to be unreliable. Examples include
no flow monitoring capabilities, wrong sampling
frequencics and procedures, using unacceptable analytical
techniques or fabrication of information. The self-
monitoring program and the general operation of the
facility is poor.

State of North Carolir� �
Department of Environment � � �
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor KRNR
Wayne McDevitt, Secretary OLINq DEPARTMENT OF
Kerr T. Stevens, Director2
ENVIRONMENT FNG Nftffs _ReE OURCE5
_ _MaP10, 999 ?/ II
CLENKA,
AIKA
n ,
ORATION
ROAD
27928
Subject: NPDES Stormwater Permit Renewal
BASF Corporation
_ Permit Number NCS000179 -�
Buncombe County
Dear Permiltee:
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000179. This permit expires
on November 30, 1999. In order to assure your continued coverage under your permit,you must apply to the
Division of Water Quality(DWQ)for renewal of your permit To make this renewal process easier,we are
informing you in advance that your permit will be expiring. Enclosed you will find an individual permit renewal
application form,supplemental information request,and Stormwater Pollution Prevention Plan certification. Filing
the application form along with the requested supplimental information will constitute your application for renewal
of your permit. The application form must be completed and returned along with all requested information by June
14, 1999 in order to constitute a timely renewal filing.
Recent legislation modified the fee structure for DWQ permits. Renewal fees have been eliminated and annual fees
have been changed. The new annual fee for your permit is now$715.00(you will be invoiced later this year for
your annual fee.) A copy of the new fee schedule is enclosed in this package.
Failure to request renewal by June 14, 1999 may result in a civil assessment of at least$250.00. Larger penalties
may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penalties of up to$10,000 per day.
If you have any questions regarding the permit renewal procedures please contact Aisha Lau of the Stormwater and
General Permits Unit at(919)733-5083,ext.578.
Sincerely, -
Bradley Bennett,Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Files
Asheville 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

E4'. M
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
AASHEVILLE REGIONAL OFFICE
NCDENR
�s
March 23, 1999
x
�J ME56.HUNTJR 4v+��11
GOVE.NOR Kry "1
239
uWwrn["INao[vvrr11M, MR. RAY ACKERMAN
L S[CR[TARY eE BASF CORP — FIBERS DIV
SAND HILL ROAD
ENKA, NO 28728
E �
'A 1P0.L OWARO,
�PE FYIy 6ROR�
Dear Mr. Ackerman:
rok
Your letter dated March 23, 1999 that describes
corrective actions for your analytical procedures has been
- received and reviewed. The actions taken are acceptable for
your North Carolina Wastewater/Groundwater laboratory
certification. If a future inspection should reveal that the
` violations cited in the inspection report were not corrected,
enforcement actions will be recommended.
"^ Thank you again for your cooperation. Contact us at
I (828) -251-6208 extension 285 if you have. questions.
Sincerely,
60V
Gary Francies
Laboratory Section
do
t
FYIu
F = cc: James W. Meyer
"� .1 1 Asheville Regional Office
rlp5� mX
�ryp ti�3)- INTERCHANUE EUILPIND,[O WOOOVIN PLACE,ASHeVILLD,NC 20RO1-2414
2 aIn - PXON¢82E 2518208 FA%E204616G[2
A✓kM1 + ,y?p = AN EQUAL OPPORTUNTY/AFFIRMATIVE ACTION EMPLOYER-EO%RECYCLED/lO%POST-CONZUMER PAPER

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality A74,2
-
James B.M Hunt, Jr., Governor NCDENR
Wayne McDevitt, Secretary
Kerr T. Stevens, Director NORTH CIROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
3/31/99
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
PPy AIKAT
BASF CORPORATION
SAND HILL ROAD
ENKA NC 27828 'NR
SUBJECT: NOTICE OF VIOLATION AND REVOCATION FOR NON PAYMENT gSf��E 19
PERMIT NUMBER NCS000179
BASF CORPORATION
BUNCOMBE COUNTY
Dear Permittee:
Payment of the required annual administering and compliance monitoring fee of$450.00 for this year has not
been received for the subject permit. This fee is required by Title 15 North Carolina Administrative Code 2H.0105,under
the authority of North Carolina General Statutes 143.215.3(a)(1), (is)and(lb). Because this fee was not fully paid within
30 days after being billed,this letter initiates action to revoke the subject permit,pursuant to 15 ncac 2H.0105(b)(2) (k)
(4),and G.S. 143-215.1 (b)(3).
Effective 60 days from receipt of this notice,subject permit is hereby revoked unless the required Annual
Administering and Compliance Monitoring Fee is received within that time. Discharges without a permit are subject to the
enforcement authority of the Division of Water Quality. Your payment should be sent to:
N.C. Department of Environment and Natural Resources
Division of Water Quality
Budget Office
P.O.Box 29535
Raleigh, NC 27626.0535
If you are dissatisfied with this decision,you have the right to request an administrative hearing within Thirty(30)
days following recipt of this notice,identifying the specific issues to be contended. This request must be in the form of a
written petition conforming to Chapter 150B of the North Carolina General Statutes,and filed with the Office of Administrative
Hearings,Post Office Drawer 27447, Raleigh, North Carolina,27611-7447. Unless such request for hearing is made or
payments received, revocation shall be final and binding. If you have any questions,please contact:
Mr. Forrest Westali,Asheville Water Quality Regional Supervisor,(704)251-620B.
'Sincerely,
J- ' Kerr T.Stevens
cc: Supevisor,Water Quality Permits and Engineering Unit
Asheville Regional Office
County Health Department
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

BASF Corp to � BASF
March 23, 1999 Sy SECTION
MAR 2
Mr. James W. Meyer
9a�
Laboratory Section
Division of Environmental Management EABORAl IONAl IO FIOE
North Carolina DEHNR ASHEVIId
4405 Reedy Creek Road
.Raleigh, NO 27607-6445
Re: Laboratory Certification Inspection Response
Dear Mr. Meyer:
In response to your written request dated March 1, 1999, I am
Pleased to inform you that all the deviations identified during our
laboratory inspection have been corrected. Cited below are the
corrections made to the referenced deviations.
Sample Preservation
DEVIATION: The ammonia samples are not de-chlorinated and the fecal
coliform samples and the ammonia samples are not
verified to have been de-chlorinated.
Corrective Action: Both ammonia and fecal coliform samples are
now de-chlorinated when we are chlorinating
the WWTP effluent. Documentation is being done
to reflect these preservation steps. We have
not needed to chlorinate our effluent in
several years and omitting these sample
preservation steps was just an oversight by
our lab technician.
TSS
DEVIATION: The time in and out of the oven is not being documented.
Corrective Action: These times are now being recorded.
Santl HIII Road.P.O.Box 669,Enka,North Carolina 28728-0669 [phone]

� n
30D
DEVIATION: The seed correction factor is too low.
Corrective Action: We have traditionally gotten our seed sample
from our lift station with the highest
sanitary load. This source is apparently not.
of sufficient bacterial strength to produce a
quality seed sample. We have ordered "Polyseed
BOD Seed Inoculum" from VWR Scientific with
which we will prepare our seed samples in the
future. This should eliminate this problem. -
DEVIATION: The dilutions used to analyze the seed controls have
been too low since the last batch of seed has been
used.
Corrective Action: The correction action above should correct
this deviation.
DEVIATION: When all method quality control requirements are not
met, the reported data are not qualified.
Corrective Action: It is our intention to meet all quality
control requirements and if I am aware that we
have not done so, I will so qualify the data
reported on the DMR "
I trust that these actions satisfy .the correction of the deviations
cited. -
Sincerely,
Rarj Ackerman
- Environmental Manager

Report : PE005
Performance Evaluation Report Page : 1
ln 1�5- DMRQA Study Number 018 Date : 31DEC98
Permittee : NC0000299 BASF CORP ENKA PLANT
_________________________ _--__--------------------------_-----
Conc. V Reported True Acceptance Warning Performance
No. A Value Value* Limits Limits Evaluation
------------------------------------------------------------------------------
TRACE METALS IN MICROGRAMS PER LITER:
015-ZINC
O1 618 631 563- 709 581- 690 Accept .
MISCELLANEOUS ANALYTES:
019-PH-UNITS i
O1 8 .59 8 . 60 8 .31- 8 . 92 8 . 38- 8 . 84 Accept.
071-TOTAL CYANIDE (IN MG/L)
01 0 . 158 0 . 140 0 . 089-0 .184 0 .101-0 .172 Accept.
072-NON-FILTERABLE RESIDUE (IN MG/L)
01 32 . 2 64 .0 12 .4- 80 .7 20 .9- 72 .1 Accept .
097-TOTAL PHENOLICS (IN MG/L)
O1 0. 066 0 . 0668 0 . 0261-0 .108 0 . 0367-0 . 097 Accept .
098-TOTAL RESIDUAL CHLORINE (IN MG/L)
O1 1 . 04 0 . 930 -0 . 811- 1.32 0 . 878- 1 .25 Accept .
NUTRIENTS IN MILLIGRAMS PER LITER:
031-AMMONIA-NITROGEN
O1 4 . 85 4 . 80 3 .89- 5 .84 4 . 13- 5 .6 Accept.
032-NITRATE-NITROGEN
O1 11. 7 12 . 0 10�.1- 13 .9 10 . 6- 13 .4 Accept .
034-KJELDAHL-NITROGEN
02 6 . 00 5 .40 4 . 02- 6 .79 4 .35- 6 .45 Accept .
035-TOTAL PHOSPHORUS
02 3 . 99 4 . 00 3 .3- 4 . 68 3 .47- 4 .52 Accept .
DEMANDS IN MILLIGRAMS PER LITER:
038-5-DAY BOD
O1 40 . 8 37 . 6 17 . 7- 57 .2 22 . 6- 52 . 2 Accept .
CERIODAPHNIA CHRONIC DATA AS % OF SAMPLE:
766-SURVIVAL, NOEC - MHSF - -
O1 025 . 0 25 12 . 5- 50 NA Accept .
767-REPROD. , IC25 - MHSF
O1 025 . 8 17. 6 0 .31- 34 . 8 NA Accept .
768-REPROD. , NOEC - MHSF
O1 012 .5 12 . 5 6 .25- 25 NA Accept.
********** END OF DATA FOR NC0000299 **********
NOTE: FOR LIMITS AND TRUE VALUES, ASSUME THREE SIGNIFICANT DIGITS .
********** END OF REPORT FOR NC0000299 **********
* Based on gravimetric calculations, or a reference valJSE0
cessary.
D.L. Means detection limit . �'O "'ORr

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
NCDENR March 1, 1999
239 MAR - 2 19999�
Mr. Ray Ackerman
JAM[!9.NVRTJR BASF Corporation - Enka Plant
GOVERNOR r EABORATORV SECTION
Sand Hill Road ASTIVITTE REG OVAL orrice
Enka;n '4 , NC 28728 — -- ---
wArdEn,ebpM1TTNM1e SUBJECT: Laboratory Certification Maintenance Inspection
SHCIIClMY
Dear Mr. Ackerman:
"1
A.PpEdfOp XOWMO �� Enclosed is a report for the inspection performed on February 18,
1999 by Mr. Gary W. Francies. Within thirty days, please supply this office
Gweena with a written item for item description of how these violations were
1^ , corrected. A response is not required comments or recommendations
a unless specifically requested. If the violations cited in the enclosed report
=:4 are not corrected, enforcement actions will be recommended. For
1 , i certification maintenance, your laboratory must continue to carry out the
r t requirements set forth in 15A NCAC for 2H .0800.
1
r `x S Copies of the checklists completed during the inspection may be
I l fy - requested from this office. Thank you for your cooperation during the
a inspection. Please contact us at 919-733-3908, if you have questions or
1 need additional information.
Sincerely,
1 !
w
t x ii=ames . Meyer
F e Laboratory Section
R
' Enclosure
cc: Marilyn O. Deaver
Gary W. Francies
•��" "` Asheville Regional Office;
„, r• ,.
J 4adl. M, LABORATORY
4 u¢ SECTION
905 R66DVCR66R ROFO, 1ON,NORTH GP LINA 27607-6445
PXONE99 733-3908 FAX[phone]
...E6an t.Jb..Yi.L +icr-w AN EQUAL OPPORTUNITY/APPIRMATVEACi.N EMPLOVBR-SO%RECYCLED/10%POST-CONSUMER PAPER

n
ON-SITE INSPECTION REPORT
LABORATORY NAME: BASF Corp.-Enka Plant
ADDRESS: Sand Hill Road
Enka, NC 28728
CERTIFICATE* 239
DATE OF INSPECTION: 2/18/99
TYPE OF INSPECTION: Maintenance
EVALUATOR(S): Gary Francies
LOCAL PERSON(S) CONTACTED: Ray Ackerman, Ross Peebles
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of
environmental samples.
It, GENERAL COMMENTS:
The laboratory is spacious and well equipped. All equipment is well maintained. A new spectrophotometer has been
obtained since the last inspection. Records are well kept and most data appeared accurate. Some further quality control
procedures need to be implemented.
A Fecal Coliform sample was split with the following results:
BASF Laboratory State Laboratory
520/100 ml 270/100 ml
Effluent samples were split with the following results:
BASF Laboratory State Laboratory
BOD, mg/I 17.9 26.2
TSS, mg/I 85 102
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
Sample Preservation
1.. VIOLATION: Sample preservation is not properly performed and documented. The ammonia samples are not
declorinated. Neither the ammonia nor fecal coliform samples are verified to have been dechlorinated.
REQUIREMENT: Samples received for analysis must be verified and documented to have been properly preserved.
Because a preservation method for one analytical method may interfere with another one, samples for multiple
determinations may need to be split and preserved separately. Sample container identification must be associated with the
analytical method(s) used. Each sample container must be checked upon receipt in the laboratory for the effectiveness of
any required pH adjustment solutions and the results documented. A two hour limit to chemically preserve samples by pH
adjustment is allowed, except for metals samples reported to the Groundwater Section which must be acidified at the time
of collection. The temperature of a temperature blank, or of a representative sample, if the second choice does not
compromise the integrity of the samples, from each cooler must be recorded upon receipt in the laboratory. Samples are
sometimes received above 6(C where transport time is less than two hours from the time of collection. For these samples,
temperature at the time of collection must be compared to temperature upon receipt to document a downward trend in
temperature. Samples containing chlorine must be dechlorinated at the time of sample collection and treated according to

ram,
rage 2
the requirements of the analysis to be performed. Upon receipt in the laboratory, samples must be checked and
documented to be free of chlorine. A variety of testing kits are considered to be adequate for most chlorine interference
checks and a maximum detection limit of 0.2 mg/L is allowed. When samples are received out of compliance, the lab must
inform the client and the State of NC in writing. Ref: 15A NCAC 2H .0805(a)(1)and (7)(M) and (N).
COMMENTS: Chlorination of the effluent was begun in November 1998.
TSS
2.VIOLATION: The time samples are placed in the oven and the time samples are removed are not documented.
REQUIREMENT: If each sample is not redried and reweighed, the laboratory may verify that a specific drying time is
adequate to dry samples to constant weight. This verification may be performed annually by drying representative samples
for a determined time period and verifying that this time period is adequate with additional drying and weighing cycles. This
annual check must be documented. Additionally, the times samples are placed in the oven and the times samples are
removed from the oven must be recorded for each analysis thereafter. Ref: 15A NCAC 2H .0805(a) (7)and (a) (7) (D).
BOD
3.VIOLATION: The seed correction factor is too low.
REQUIREMENT: Sufficient seed material must be used to yield a seed correction of 0.6 to 1.0 mg/I. Ref: Standard
Methods, 18th Edition -Method 5210 B. 4d 2.
COMMENTS: A new batch of seed was obtained in December 1998. Since then, only one set of samples has had an
acceptable correction factor.
4. VIOLATION: The dilutions used to analyze the seed controls have been too low since the last batch of seed has been
used. The final result of the seed correction factor is not always properly determined.
REQUIREMENT: Seed controls and all samples must have a DO usage of at least 2 mg/1 and a residual of at least 1 mg/I
in order to be acceptable for use. All dilutions that meet this criteria are averaged to obtain the final result. Ref: Standard
Methods, 18th Edition-Method 5210 B 5.
COMMENTS: In most cases, neither dilution depletes the required 2.0 mg/I. When one does, both dilutions are still used to
calculate the final seed correction factor. Only the acceptable dilution can be used in that case.
5.VIOLATION:When all method quality control requirements are not met,the reported data are not qualified.
REQUIREMENT: Whenever any of the method quality control requirements are not met, the data must be qualified on the
Discharge Monitoring Report(DMR). The qualifying statement should indicate that all QC requirements were not met. Ref:
15A NCAC 21-1 .0805 (a)(7 and (a) (7)(D).
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory bench sheets and contract lab reports to DMRs
submitted to this Division. Data were reviewed for the W NTP for these months: August, October, and November, 1998.
Data were reviewed for the four groundwater monitoring wells for 6113198. No errors were noted. It appears the facility is
doing a good job of accurately transcribing data.
V. CONCLUSION:
This laboratory is doing a good job overall. Correcting the above violations should help to produce quality data and meet
certification requirements.
Report prepared by: Gary Francies Date: 2124199