NCGNE0905_COMPLETE FILE - HISTORICAL_20150223

NORTH CAROLINA
Department of Environmental Qua

0
STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
NCGNE
DOC TYPE
HISTORICAL FILE
DOC DATE
❑
YYYYMMDD

r
Pat McCrory
Governor
Al
NCDENR
North Carolina Department of Environment and Natural Resources
February 23, 2015
Giles Chemical, A Division of Premier Magnesia, LLC
ATTN_ Ms. Deborah Durbin, Director of Quality & Safety
102 Commerce Street
Waynesville, NC 28786
Donald van der Vaart
Secretary
SUBJECT: NPDES Stormwater Permit Compliance Inspection
(Status: Compliant)
Giles Chemical, A Division of Premier Magnesia, LLC, 102 Commerce Street
Permit No: NCGNE0905; No. Exposure Certificate:
Haywood County
Dear Ms. Durbin;
This letter is in follow-up to the NPDES Stormwater Permit Compliance Inspection conducted on November
6, 2014. You, Mr. Matt Haynes, Mr. Patrick Owen, and Mr. Jason Bumgarden met on -site with Fred Walker
(DEMLR), Brett Laverty (DWR), and me (DEMLR). This inspection was done as a follow-up to a complaint
concerning a release from this facility. This facility currently has a "No Exposure" certificate. The
inspection determined that this facility is in compliance with the "No Exposure" certificate. The inspection
also confirmed that Giles Chemical has implemented a Stormwater Pollution Prevention Plan (SWPPP) and
is doing required monitoring.
During the inspection we also discussed additional actions that will help prevent additional releases in the
future. Enclosed is a copy of the Compliance Inspection Report, which contains these additional items,
observations, and comments for your reference and implementation.
If I can be of any further assistance, please contact me at [phone].
Sincerely,
aura C. Herbert, PE
Regional Engineer
Land Quality Section
Enclosure: Compliance Inspection Report
Ec: Brett Laverty (DWR)
Ken Pickle, RCO Stormwater Files
Division of Energy, Mineral, and Land Resources
Asheville Regional Office, 2090 US Highway 70, Swannanoa, North Carolina, 28778-8211
Telephone [phone] Fax [phone] . One
http:I/Portal.ncdenr,org/web/lr/land-quality NorthCa.rolina
An Equal Opportunity I Affirmative Action Employer Naturally

NJ :
Permit: NCGNE0905
SOC:
County: Haywood
Region: Asheville
0 0
Compliance inspection Report
Effective: 01122/13 Expiration: Owner: Giles Chemicals
Effective: Expiration: Facility: Giles Chemicals
102 Commerce St
Contact Person: Deborah Durbin Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(sj:
On -Site Representative(s):
Related Permits:
Inspection Date: 11/06/2014 Entry Time: 10:OOAM
Primary Inspector: Fred Walker
Secondary Inspector(s):
Waynesville NC 28786
Phone: [phone] E4.33
Certification: Phone:
Exit Time: 12:OOPM
Phone: [phone]
Laura C Herbert Phone :
Reason for Inspection: Complaint Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: Compliant [] Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page: 1

LJ
u
4''. 1 .r
Permit: NCGNE0905 owner - Facility: Giles Chemicals
Inspection pate: 11706=14 Inspection Type: Compliance Evaluation Reason for Visit: Complaint
Inspection Summary:
This inspection was a follow-up to a reported release on October 4, 2014. Those present from NCDENR included Brett
Laverty (DWR), Fred Walker, and Laura Herbert, Giles Chemical (Giles) personel present included Deborah Durban, Jason
Bumgarden, Patrick Owen, and Matt Haynes. The purpose of this inspection was to determine if the facility was in
compliance and still qualified for "no explosure" status. Since the October 4, 2014 release, the facility has implemented
preventative maintenance and inspections, as well as modifying piping including shut-off valves. The facility does have a
current SWPPP and is keeping semi-annual qualitative monitoring records. The facility was in compliance with "No
Exposure" requirements. Items noted duirng the inspection that should be addressed include the following:
Backdoor to Richmond Creek walk -way out of Production Room needs a berm to prevent process water from leaving the
building and going into the creek.
Backdoor out of the Digester Room needs a berm also.
All doorsiouttlets where floors are sloped toward outlets need a ditch/grate/berm (barrier) to prevent process water from
leaving the building (have a contract to do this in the near future).
Stormwater drains outside the front door and near the railroad should have berms available in the event of a release to keep
process water out of the storm drains.
Parking lot and loading area in the back of the plant should be stabilized to prevent potential tracking on to roads/driveway
off property.
Additional housekeeping to keep the warehouse room clean is needed.
All maintenance items assoicated with spill prevention should be included in the Preventative Maintenance and Good
Housekeeping Plan.
Page: 2
r

COm113liance Inspection Report
Permit: NCGNE0905 Effective: 01/22/13 Expiration: Owner: Giles Chemicals
SOC: Effective: Expiration: Facility: Giles Chemicals
County: Maywood 102 Commerce St
Region: Asheville
Waynesville NC 28786
Contact Person: Deborah Durbin Title: Phone: [phone] Ext.33
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 11/06/2014
Primary Inspector: Fred Walker
Secondary Inspector(s):
Certification:
Phone:
EntryTime: 10WAM Exit Time: 12:OOPM
Phone: [phone]
Laura C Herbert Phone :
Reason for Inspection: Complaint Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page: 1

0 16
Permit: NCGNE0905 Owner - Facility: Giles Chemicals
Inspection Date: 11106/2014 Inspection Type : Compliance Evaluation Reason for Visit: Complaint
Inspection Summary:
This inspection was a follow-up to a reported release on October 4, 2014. Those present from NCDENR included Brett
Laverty (DWR), Fred Walker, and Laura Herbert. Giles Chemical (Giles) personel present included Deborah Durban, Jason
Bumgarden, Patrick Owen, and Matt Haynes. The purpose of this inspection was to determine if the facility was in
compliance and still qualified for "no explosure" status. Since the October 4, 2014 release, the facility has implemented
preventative maintenance and inspections, as well as modifying piping including shut-off valves. The facility does have a
current SWPPP and is keeping semi-annual qualitative monitoring records. The facility was in compliance with "No
Exposure" requirements. Items noted duirng the inspection that should be addressed include the following:
Backdoor to Richmond Creek walk-way.out of Production Room needs a berm to prevent process water from leaving the
building and going into the creek.
Backdoor out of the Digester Room needs a berm also,
All doors/outlets where floors are sloped toward outlets need a ditchlgratelberm (barrier) to prevent process water from
leaving the building (have a contract to do this in the near future).
Stormwater drains outside the front door and near the railroad should have berms available in the event of a release to keep
process water out of the Storm drains.
Parking lot and loading area in the back of the plant should be stabilized to prevent potential tracking on to roads/driveway
off property.
Additional housekeeping to keep the warehouse room clean is needed.
All maintenance items assoicated with spill prevention should be included in the Preventative Maintenance and Good
Housekeeping Plan.
Page: 2

®1
=acility:
Date: L ��
_ocation Address: /off �Sf �
COC#: NC /, Nr O %O
'ontact fume: oraf� yr
Phone #: �2 g y s, y7,S/�/ X 33
'.ontact Mailing Address: Katy ��
County: w�
)erections:
Routine Compliance Inspection
Rescission Request
Complaint investigation
Other - Explain:
A
Storm Water Pollution Prevention Plan
Yes
No
N/A
Comments
1
Is a copy of the permit and the Certificate of Coverage available
at the site?
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2
Is a copy of the signed and certified SWPPP at the facility?
3
Does the Plan include a "Narrative Description of Practices"?
4
Does the plan include a general location (USGS) map?
5
Does the plan include a detailed site map including outfall
locations and drainage areas?
6
Does the plan include a Spill Prevention and Response Plan?
SPRP
7
Does the plan include a Preventative Maintenance and Good
Housekeeping Plan?
;/
B
Does the plan include a Stormwater Facility Inspection Program?
9
Does the Plan include a BMP Summary?
10
Does the plan include a list of Responsible Party(s)?
f
11
Has the SWPPP been implemented?
B
Monitoring and Records
Yes
No
N/A
1
Does the plan include a list of significant spells occurring during
the past 3 ears?
��
2
Does the facility provide and document employee training?
3
Has the facility conducted its Qualitative Monitoring? (semi-
annual)
4
Has the facility conducted its Analytical Monitoring? (s-a)
5
Is the facility meeting all permit specified benchmark goals?
6
Is the facility following the tiered response?
7
Has the facility conducted its Analytical Monitoring from vehicle
Maintenance areas?
C
Waste Management
Yes
No
N/A
1
Does the facility provide all necessary secondary containment?
✓,
2
jAre current BMPs in material storage areas adequate?
e N W G�,L (- "t5(

3
Are appropriate spill containment and cleanup materials kept on -
site and in convenient locations?
D
Outfalls
Yes
No
N/A
1
Were all outfalls. observed during the inspection?
✓
If the facility has representative outfall status, is it properly
✓
Z
documented by the Division?
3
Dias the facility evaluated all illicit (non stormwater) discharges?
j
E
Sector specific questions
Yves
No
N/A
I
Have zinc or copper benchmarks been exceeded in the past 3
sampling periods?
2
Have potential sources for copper and zinc been evaluated at
vour facility?
3
4
5
Comments
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MAGI'l-NUM SULFATE ® Page 1 of
MAGNESIUM SULFATE
MS11S Number: M0234 -- Effective Date: 12A8196
1. Product Identification
Synonyms; Magnesium sulfate (1:1) heptahydrate; Epsom sails; sulfuric acid, magnesium salt (1:1), heptahydrate; Magnesium sulfate, 7- hydrate
CAS No.: 7487.88.9 (Anhydrous)
Molmular Weight: 246.47
Chemical Formula: MgSO4.7H2O
Product ['odes:
TT. Baker: 2500, 2503, 2504, 2505, 5588
Mallinckrudt: 4200, 5691, 6046, 6066, 7778
2. Composition/Information on Ingredients
Ingredient
Magnesium Sulfate Anhydrous
3. Hazards Identification
Emergency Overview
CAS No Percent Hazardous
------------ ------- ----""--
7487-80-9 99 - loot Yes
CAUTION! MAY BE HARMFUL IF SWALLOWED.
,I.T. Raker SAF-T-DATAtt"'l Ratings (Provided here for your convenience)
I Icalth Rating: I • Slight
Flammability Rating: 0 - None
Reuel ivity Rating: 0 - )gone
Contact Kating: 1 - Slight
Lab Protective Equip: GOGGLES; LAB COAT
Storage Color Code: Orange (General Storage)
Potential Ileahh Effects
Inhalation:
Dust may he slightly irritating_ Sore throat or coughing may occur,
Ingestion:
Since magnesium salts are slowly absorbed, abdominal pain, vomiting and diarrhea may be the only symptoms, However, ifelimination is blocked by bowel
blockage or other reasons, CNS depression, lack of reflexes, hypoculcemia (deficiency of calcium in the blood) may occur.
Skin Contact:
No udverse effects expected but may cause minor skin irritation.
Eye Con Wet:
No udverse elieets expected but dust may cause mechanical irritution,
Chronic Exposure:
No information found
Aggravation of Pre-existing Conditions:
No intmmation round,
4. First Aid Measures
Inhalation:
Remove to fresh air. Get medical attention for any breathing difficulty.
Initextinn:
Give several glasses of water to drink to dilute. If large amounts were swul lowed, ges medical advice.
Skin Contact:
Kemove any contaminated clothing. Wash skin with snap and water for at least 15 minutes. Get medical attention if irritation dcvclups ur persists.
Frye Contam
Wash thoroughly with running ~eater. Get medical advice if irritation develops,
Note to Physician:
IV administration ot'calcium glucanate will partially reverse the eliicts oraculu magnesium toxicity. Ventricular support with calcium chloride infusionand
mannilol forced diurosis has also been successful.
http://Iiazat-d.conVmsds/mf,lbaker/baker/i1les/m0234.htm 11/6/2014

MAGNESIUM SULFATE
Page N of 4
5. Fire Fighting Measures
Fire:
Not considered to be a fire hazard.
Explosion;
Not considered to be an explosion hazard.
Fire Extinguishing Media;
Use any means suitable for extinguishing surrounding fire.
Special Information:
Use protective clothing and breathing equipment appropriate for the surrounding fire.
0. Accidental Release Measures
Ventiiale area ot'leak or spill. Wear appropriate personal protective equipment as specified in Section 8, Spills, Swecp up and containerize for reclamation or
disposal. Vacuuming or wet sweeping may be used to avoid dust dispersal,
7. Handling and Storage
Keep in a tightly closed container, stored in a cool, dry, ventilated area. Protect against physical damage. Isolate from incompatible substances. Containers of this
material may be hazardous when empty since they retain product residues (dust, solids); observe all warnings and precautions listed for the product.
8. Exposure Controls/Personal Protection
Airborne Exposure Limits:
None establ ished.
Ventilation System;
A system of local and/or general exhaust is recommended to keep employee exposures as tow as possible. Local exhaust ventilation is generally preferred because
it can control the emissions of the contaminant at its source, preventing dispersion of it into the general work area. Please refer to the ACGII l document,
lndu trial Venolution, A h1urturrl r f7,ecummendud!'rrrerieuw, most recent edition, fix details.
Personal Respirators (NIOS11 Approved):
For conditions of use where exposure to the dust or mist is apparent, a halt=face dustlmist respirator maybe worn, for emergencies or instances where the
exposure levels are not known, use a full -face positive -pressure, air -supplied respirator. WARNING: Air -purifying respirators do not protect workers in oxygen -
de ticicnt atmospheres.
Skin Protection:
Wear protective gloves and clean body -covering clothing.
Eye Protection:
Use chemical safety goggles. Maintain eye wash fountain and quick -drench facilities in work area.
9. Physical and Chemical Properties
Appearance:
Transparent crystals, or white powder.
Odor:
Odorless.
Solubility:
Very soluble in water.
Density:
1.67 g/ml @ 4C
pll:
Aqueous solution is neutral or slightly acid.
'V., Volatiles by volume Ou 2 1 C (70F):
0
Boiling Point:
Not applicable.
Melting Paint:
1124C (2055F) Decomposes. Loses all waters of hydration 04 250C (482F)
Vapor Density (Air 1):
No information found.
Vapor Pressure (mm llg):
No information found.
Evaporation Rate (HuAc-1)-
No information found.
10. Stability and Reactivity
Slabilitv:
Stable under ordinary conditions of use and storage. Loses some moisture on exposure to dry air at room temperatures.
lazardous lhcomposition Products:
Oxides of sul fur and the contained metal.
Ilarnrdous Polymerlrrdion:
http://hazard-com/msds/mflbaker/baker/F les/m0234.htm 11/6/2014

.MAGNESIUM SULFATE ® Page 3 of 4
Will not occur.
[ncompalihiliticq: ,
Ethoxy ethyl alcohois, arsenates, phosphates, tartrates, lead, harium, strontium, and calcium
Condilion% In Avoid:
Heal, moisture, incompatibles.
11. Toxicological Information
No 1.05011,00 information found relating to normal routes of occupational exposure. Investigated as a mutagen, reproductive effector
--------\Cancer Lists\------------------------------------------------------
--- NTP Carcinogen ---
Ingredient Known Anticipated IARC Category
------------------------------------ ---------------- -------------
Magnesium Sulfate Anhydrous No No None
(7487-88-9)
12. Ecological Information
Environmental Fate:
No information found.
Environmental Toxicity:
No information found.
13., Disposal Considerations
Whatever cannot be saved for recovery or recycling should he managed in an appropriate and approved waste disposal facility. Processing, use or Contamination
ofthis product may change the waste management options, State and local disposal regulations may differ from fcdcml disposal regulations. Dispose ofcontaincr
and unused contents in accordance with federal, state and local requirements,
14. Transport Information
Not regulaied
15. Regulatory Information
--------\Chemical Inventory status - Part 1\ ---------------------------------
ingredient TSCA YC Japan Australia
--------------- --------------- ---- --- ----- ------`--
Magnesium Sulfate Anhydrous (7407-09-9) Yes Yes Yes Yes
--------\Chemical Inventory Status - Part 2\ ---------------------------------
--Canada--
ingredient Korea DSL NDSL Phil.
----------------------------- `--------- ----- --- ---- -----
Magnesium Sulfate Anhydrous (7407-80-9) Yes Yes No Yes
--------\Federal, State a International Regulations - Part 1\ ----------------
-SARA 302-------SARA 313------
Ingredient RQ TPQ List Chemical Catg.
----------------------------------------- -- ----- ---- --------------
Magnesium Sulfate Anhydrous (7487-88-9) No No No No
--------\Federal, State L International Regulations - Part 2\ ----------------
-RCFLA- -TSCA-
Ingredient CERCLA 261,33 8(d)
----------------------------------------- ------ ------ ------
Magnesium Sulfate Anhydrous (7467-88-9) No No No
Chemical Weapons Convention: No TSCA 12(b): No CDTA: No
SAl¢A 311/312; Acute: Yes Chronic: No Fire: No Pressure: No
Reactivity: No (Pure / solid)
Ausiruliun Ifazchem Code: No information found.
Poison Schedule: No information found.
WIIrn5:
This MSDS has been prepared according to the hazard criteria ttf the Controlled products Regulations (CPR) and the MSDS contains all of the informmion
required by the CPR.
fly. Other information
http://hazard.com/msds/mt7baker/baker/files/m0234.litm 1 1 /6/2014

MAGNESIUM SULFATE 0 Pale e of 4 .
NFPA Ratings: I lc:alth: I Flammability: U Reactivity: 0
Label Hazard Warning:
CAUTION! MAY BE HARMFUL IF SWALLOWED.
Label Precautions:
Keep container closed,
Wash thoroughly after handling.
Label First Aid:
If swallowed, give several glasses of water to drink to dilute, If large amounts were swallowed, get medical advice.
Product Use:
Laboratory Reagent
Revision Informalion:
New 16 section MSDS format, all sections have been revised.
Disclaimer.
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Slallinckrodt Baker, Inc. provides the information contained herein in good faith but makes no representation as to its comprehensiveness or accuracy.
This document is intended only as a guide to the appropriate precautionary handling of the material by a properly trained person using this product.
Individuals receiving the information must exercise their Independent judgment in determining its appropriateness for a particular purpose.
NIA LLINCKRODT BAKER, INC. MAKES NO REPRESENTATIONS OR vvARRANTIES, F,ITHER EXPRESS OR IMPLIF,I), INCLUDING
WITHOUT IAMIT'ATION ANN' WARRANTIES OF MERCHANTABILITY, rITNESS FOR A PARTICULAR PURPOSE WITH RESPECT -1'0
THE INFORMATION SET FORTH HEREIN OR THE PROIWCT TO WHIC11 Tllr. INFORMATION RE:rERS. ACCORIIINGLY,
AfALLINCKRODT BAKER, INC. WILL NOT BE RESPONSIBLE FOR DAiMAGES RESULTING FROM LISE OF OR RELIANCE UPON THIS
IN FORMATION.
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Prepared by: Strategic Services Division
Phone Numher: [phone] (U.S.A.)
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1w
0
STORMWATER POLLUTION
PREVENTION PLAN
7,
r
NPDES General Permit: NCGNE0905 CPEES Project No. 1136-003
March 7, 2013
NO EXPUSURE CERTIFIGATIUN
Prepared for:
Prepared by:
Chalam Paikala Engineering and Environmental Solutions
10017 Allyson Park Dr.,
es
Charlotte, North Carolina 28277
Tel [phone] Fax [phone]
102 Commerce St.
Email: [e-mail]
Waynesville, North Carolina 28786
Person in charge of the facility/Title:
Ms. Deborah Durbin 1 Director of Quality and Safety
Telephone Number:
828-452-4784 ext 33

V
0
7.0 POTENTIAL POLLUTANT SOURCES
Potential stormwater pollution sources were identified during site visit and presented in Table 1.
Figure 2 shows a detailed site plan locating specific sources of potential stormwater pollution.
7.1 Facility Drainage
Drainage from the Giles Chemical Plant site ultimately reaches Richland Creek to the north of the
site. One drainage area (Figure 2) was delineated for the Giles Chemical Plant site. The
description of the drainage area, the portions of the site included in the drainage area and the
potential for equipment failure in the area are as follows.
7.1,1 Drainage Area 1
Drainage area 1 includes loading dock and parking area. The drainage area for the outfall is
provided on Figure 2. The contaminants that could be expected from the drainage area 1 are oil &
grease and particulate matter from general traffic.
7.2 Outfalls Description
Figure 2 shows a site plan of the facility delineating the drainage area and stormwater runoff routes
for the outfall. Facility drainage consists primarily of surface water runoff from paved and grassy
areas and collected runoff from the facility's roof drainage system. The surface water runoff is
routed by gravity to strategically located outfall area at the site.
For the purposes of this Plan, materials stored and used inside the main building will not be
addressed.
7.2.1 Location of Outfalls and the Activities Contributing to the Outfalls
Outfall-1: Based on the topography of the site, outfall 1 is located on the northeast corner of the
site.
Activities: Receiving dock and parking area.
7.2.2 Representative Outfall Status
Giles Chemical Plant need not request for a representative outfall status since the site has only one
outfall at this time.
7.3 Inventory of Significant Materials
This section identifies "significant materials" and their potential to contaminate stormwater at Giles
Chemical Plant.
7.3.1 Outside Storage Areas
Aboveground acid storage tank farm, loading docks and sludge storage area are exposed to
stormwater at the facility. However, several BMPs such as dikes and covers were implemented at
the site. No contaminants will be released to stormwater from these areas.
CP Engineering and Environmental Solutions 9 SWPP Plan
Tel: [phone] Giles Chemical
Email: cvpakala@carolina. rr. cam 102 Commerce St.
CPEES Project No, 1136-003 Waynesville, NC

0
7.3.2 Outside Loading/Unloading Practices
The sludge is loaded to trucks and disposed of to city landfill for disposal. The sludge is non-
hazardous waste.
Magnesium Oxide is received via rail cars and unloaded to facility silos for storage and usage. No
or minimum spills were expected from this operation and none of the spills would go to the
stormwater.
Sulfuric acid is received and unloaded into the two aboveground storage tanks for plant usage. The
ASTs are contained in a dike and spills are contained should they occur.
7.2.3 Waste Handling Areas
Giles Chemical Plant handles waste streams generated at the plant in the following manner:
The facility has one dumpster with a lid for office and general plant waste. A waste hauler removes
the dumpsters as needed.
Currently, no hazardous waste is being generated at the facility.
7.3 Historical Spills and Leaks
The Giles Chemical Plant has had no "significant leak or spill" events (i.e., spills that have exceeded
their reportable quantities) within the past twelve months period. Any spills occurred and the
actions taken by the facility last 3 years are recorded in Log C1. Log C2 is a form to use in
recording the events and circumstances surrounding a spill event recorded in Log C1.
CP Engineering and Environmental Solutions 10 SWPP Plan
Teh, (704) 54 1-4042 Giles Chemical
Email: [e-mail] 102 Commerce St.
CPEES Project No. 1136-003 Waynesville, NC

f .
0
Table I
Potential Stormwater Pollution Sources
Giles Chemicals
Waynesville, North Carolina
Name of Source jDraInaje Area-DA
Source
Number'
Exposure
to Storm-
water
Risk Factor:
SARA 313
Compound
Yes]No
Typical
Contaminants
Drains to
Outfall - 00
Sulfuric Acid ASTs
01
Y .
Low
No
pH
NIA
Mgo Silo*
02
Y
Low
No
pH
NIA
Sludge Storage Shed
03
N
Low
No
TSS
N/A
Loading Dock
04
Y
Low
No
oil and TSS
1
Chiller — Repackaging area
05
Y
Low to
Medium
No
Temp
2'
N=No, Y=Yes, W W'f = Wastewater Treatment, TSS =Total Suspended Solids, BOD = Biological Oxygen Demand
1 Sources description or numbers are shown on Figure 2.
2 Selection is based on good engineering practices, experience and Criteria set forth in Section 6.a of this document

0
9
Table 2
Site Specific BMP Implementation Projects
Giles Chemicals
Waynesville, North Carolina
Source
Name of Sourcelarainage
Number
BMPs Implemented
Alternate BMPs
BMPs to be
Implementation
Area
Assessment
Implemented
Schedule
None
AC — Good
Sulfuric Acid ASTs
01
Secondary Containment
Housekeeping,
6 - 12 months
Personnel Training
None
AC — Good
MgO Silos
02
Closed
Housekeeping,
6 - 12 months
Personnel Training
None
AC — Good
Sludge Storage Shed
03
Inside a Shed
Housekeeping,
6 - 12 months
Personnel Training
None
AC — Good
Loading Dock
Oa
Secondary Containment
Housekeeping,
6 - 12 months
- - — ---I
Personnel Training
Redirect to the city
AC — Good
Chiller — Repackaging area
05
None
sewer
Housekeeping,
6 - 12 months
Personnel Training

u

PREMIER � � gi I C: S
October 17, 2014
G. Landon Davidson, P.G.
Regional Supervisor
Water Quality Regional Operations --Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Subject: Notice of Violation and Notice of Intent to Enforce
NOV-2014-DV-0211 (Incident #201401632)
Illegal Discharge
Giles Chemical —Waynesville Plant
Haywood County, NC
Dear Mr. Davidson:
We received the above mentioned notification Thursday, October 16, 2014. Please see our
response below addressing a required report and action plan.
The signed hard copy of this response will be mailed to your office followed by the lab results of
the representative sample from the filter box that will be analyzed by a N.C. certified lab.
Cause
Giles is in the process of some internal construction at the Waynesville facility. During the
course of this construction, some construction debris (sawdust and board pieces) was
inadvertently washed into the drain. The debris partially clogged the drain line, which
backed up into the plant. A contractor was called to unclog the drain for which he used an
auger and pressure washer.
The plant has a 'knell' for secondary containment at the rear (creek side). As the plant
continued to run, a small quantity of water ran out the front of the plant and into the storm
sewer besid th . As the event progressed, water also ran out the back of the
plant as a result of pressure washing to clear the blockage. This discharge occurred on
October 4, 2014. Giles consulted with the Town of Waynesville and they determined the
Miles Clwmical, a Division 4 Premier Magnesia, I,1,C
102 Commerce Street
Waynesville, NC 28786
[phone]

?REHIER
LLCg11r:S
MAGNESIA,
discharge to be non -hazardous ad -insignificant Later that same day, Brett Laverty, an
NCDENR representative observed what was left of the same release.
Later the contractor removed the cover from the filter on the exit side of the drain
to allow for pressure washing/auguring from the upper side. As the contractor worked, his
equipment would at times completely block the drain and the water would build up in the
plant. At other times the partial plug would allow some water to drain to the sewer. When
the drain clog was finally displaced, the water stored in the plant floor containment
unexpectedly surged down the drain pipe and overflowed the filter box. This resulted in a
sudden discharge to the creek esti ate� 500 gallons. Brett Laverty, an NCDENR
representative, was on site and observed this entire release. This occurred at approximately
2:30 PM on October 4, 2014 and ended immediately.
Significance and Extent
In summary, there were 3 known discharges:
1. Approximately 50 gallons from the pressure washing activities associated with cleaning
the drain blockage at the back of the building — October 4, 2014
2. Approximately 75 gallons into the storm sewer at the front of the building from the
water backing up into the plant October 4, 2014
3. Approximately 500 gallons from the sudden removal of the drain blockage and
subsequent draining of the water from the plant floor containment. October 4, 2014
Composition of Discharge
Giles has 3 main sources of process water:
1. Filter Press washing from the process
This water contains approximately 4% Magnesium Sulfate in solution and Z56 solid
minerals. These consist mainly of Gy su .-(.Calciunx3 dfat-e), Magnesium Oxide (non -
reactive), 4tes. Giles processes `mined mineral nd these are
separated when we wash the filter press as a part of normal processing.
2. Pump Seal Water
This is city water that is used to cool and flush many of the process pumps used in the
Giles Chemical, a Division of Premier Magnesia, LLC
102 Commerce Street
Waynesville, NC 28786
[phone]

?RENIER giles
MAGNESIA, LLE r
plant.
I Floor Wash Down
Giles uses city water to wash excess Epsom Salt (Magnesium Sulfate Heptahydrate)
from the floors into the drain. This water may also contain other
djrt/dust/debris construction materials.
The worst case assumption is that the water discharged to the creek/storm sewer on
October 4, 2014 was Filter P water. The sample presently being sent to the lab for
analysis was taken from the filter box while the Filter Press was being washed. This sample
would be representative of the spill/discharge.
Conclusion
The largest part of the discharge was caused by the sudden release of water that was
backed up into the rnain-&ain-pipe when the blockage was displaced. Additionally, the
backed up water hindered the drain cleaning contractor and caused the release from the
pressure washer as well. Shutting the plant down earlier could have prevented the release
from the front of the plant and minimized the other two instances in question.
Action Plan x
1. Valves will be installed at the upper end of the main drain pipe (below the main sump r/+r
discharge) and at each of the other drains/in-feeds. This way, the valves can be closed to
isolate the pipe for cleaning and the valves opened slowly so as not to overflow the filter
box.
2. Grates will be installed on the drains to prevent construction or other large debris from
entering the drain pipe(s).
3. A check will be incorporated into our SWPPP Facility & Storm water Systems Inspection
Sheet to ensure all grates are in place and all large debris removed from the grating on a
weekly/monthly basis.
4. Although the plant floor serves as a secondary containment, a,portable industrial sum
pump and sufficient hose will be kept on hand to pump process Water to one of our
holding tanks until the plant can be shut down in case of a drain back up.
5. External principal drain line filter box lids will be replaced and seTale�_and_nctr_emamed
unless salves mentioned-in-Action_P_la.q_item 1 are closed.
Giles Chemical. a Division of Premier Magnesia. 1,LC
102 Commerce Street
Waynesville. NC 28786
[phone]

SAO
PREMIER � � glIES
In closing, we have spoken with Laura Hurbert with Land Quality; her and her team are
scheduled for an inspection on October 30, 2014. We look forward to her visit and any
improvement suggestions that she can make.
Should there be any further questions, please contact me at the number and/or email below.
Sincerely,
Deborah Durbin
Director of Quality & Safety
Giles Chemical, a division of Premier Magnesia, LLC
102 Commerce Street
Waynesville, North Carolina 28751
828-452-4784 x-33
[e-mail]
Giles Chemical, a Division of Premier Magnesia. L1X
102 Commerce Street
Waynesville, NC 28786
[phone]
A. • . i—

m
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P.E. John E. Skvarla, III
Governor Director Secretary
January 22, 2013
Ms. Deborah Durbin
Giles Chemical — Waynesville
102 Commerce St.
Waynesville, NC 28786
Subject: No Exposure Certification — Approval
NCGNE0905
Giles Chemical - Waynesville
Haywood County
Dear Ms. Durbin;
The Division of Water Quality (Division) has reviewed your application for a No Exposure Certification for
Exclusion (NE) for the subject facility. Based on the information provided and a site visit conducted on January 8,
2013, the NE has been approved. However, as we discussed during the meeting, the Division requires that Giles
Chemical implement a Stormwater Pollution Prevention Plan (SWPPP) by June 30, 2013 (the requirements for the
SWPPP were sent to you via e-mail).
Please note that you are obligated to maintain no -exposure conditions at your facility. If conditions change such
that your facility can no longer qualify for a NE, you are obligated to immediately obtain NPDES permit coverage
for your stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted
discharge. Your NE does not expire. In order to help assure that your facility stays in compliance with all of the
conditions in the Certification, you mgst self -recertify your facility at least annually. Please see the attachment
for information on self -recertification.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental
permits that may be required under other federal, state, or local regulations or ordinances.
The Division appreciates Giles Chemicals' efforts to obtain No Exposure certification. If you have any questions or
need further information, please contact Susan Wilson at [phone], or at SLLsan.a.wilsoii(@ncdenj-.gov.
r
Sinc ly,
for Char es akild, P.E.
Enc.: Re -Certification Form
cc: Stormwater Permitting UnittKen Pickle, No -Exposure Files
ARO Files S:\SWP\I4aywood\Stormwater\3-No Exposures\Giles ChemicailAPRVL NE Giles Chem. 120 13.doc
Location: 2090 US. Highway 70, Swannanoa, North Carolina 28778 -
Phone: [phone]FAX: [phone] `
�na
Internet: www.ncwaterquatity.org Nor,thC".`afo

•
r., . �, ,,
North Carolina
Pat McCrory
Governor
January 22, 2013
Ms. Deborah Durbin
Giles Chemical — Waynesville
102 Commerce St.
Waynesville, NC 28786
NCDENR
Department of Environment and
Division of Water Quality
Charles Wakild, P-E,
Director
Subject: No Exposure Certification — Approval
NCGNE0905
Giles Chemical - Waynesville
Haywood County
Dear Ms. Durbin:
Natural Resources
John E. Skvaria, III
Secretary
The Division of Water Quality (Division) has reviewed your application for a No Exposure Certification for
Exclusion (NE) for the subject facility. Based on the information provided and a site visit conducted on January 8,
2013, the NE has been approved. However, as we discussed during the meeting, the Division requires that Giles
Chemical implement a Stormwater Pollution Prevention Plan (SWPPP) by June 30, 2013 (the requirements for the
SWPPP were sent to you via e-mail). .
Please note that you are obligated to maintain no -exposure conditions at your facility. If conditions change such
that your facility can no longer qualify for a NE, you are obligated to immediately obtain NPDES permit coverage
for your stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted
discharge. Your NE does not expire. In order to help assure that your facility stays in compliance with all of the
conditions in the Certification, you must self -recertify your facility at least annually. Please see the attachment
for information on self -recertification.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental
permits that may be required under other federal, state, or local regulations or ordinances.
The Division appreciates Giles Chemicals' efforts to obtain No Exposure certification. If you have any questions or
need further information, please contact Susan Wilson at [phone], or at susan.a.wilsott n,nedenr;gov.
Since ly,
for Charles akild, P.E.
Enc.: Re -Certification Form
cc: Stormwater Permitting Unit/Ken Pickle, No -Exposure Files
ARO Files SAS WP\HaywooMtormwaterl3-No ExposureslGiles ChemicaRAPRVLNE Giles Chem.t 2013-doc
Location: 2090 U.S. Highway 70, Swannanoa North Carolina 28778
Phone: [phone]M FAX: [phone]
Internet: www.ncwaterquality.org
An Equal opportunity S Affirmative Aclkm Employer
NorthCarvlina
:Aatur 11

c

MATERIAL SAFETY DATA SHEET
Trade Name: Epsom Salt, Magnesium Sulfate, U.S.P.
Dare Prepared, 08007/13 Page: 1 of 4
1. C'HFMICAI. PAObIlCI' AND
Product name:
COMPANY IbFh'TjFICATIO!Y
Epsom Salt, Magnesium Sulfate, U.S.P. Product
description:
Magnesium sulfate, heptahydrate
Manufacturer:
Giles Chemical
102 Commerce Street
Waynesville, NC 28786 USA
Telephone:
823-452-47M
In care ofentergency call:
828.452-4784
For trontportation emrgenry
Call CHF.MTRW
i
W"24-9300
Chendral and Common Nanre CAS Registry idt. % OSHA PL-'L ACGIII TLV
Nam1Kr .
Magnesium sulfate, heptahydrate; 10034-99-81 1001% Not Established Not Established
Epsom salt
' Under the Tozic Substances Coatrul Act (TSCA), hydrates are considered us mixtures ot'thcir anhydrous salt and
water. Accordingly, the CAS Numbers 7487.8&9, 7732-18-5 are used for Ptupasos ot'TSCA.
3. HAZARDS IDENTIFICATION
I
Lnrergency Overview
White or transparent crystalline odorless powder.
Noncombustible. At very high remperatures, magnesium aside, sulfur
dioxide, and sulfur trioxide may be generated. Causes mild eye Irritation.
F'yr contact:
Causes mild Irritation to tine eyes.
Skin contact:
No known adverse effects. .
Inhalation:
Causes nausea, vomiting, abdominal cramps, and diarrhea.
Ingestion.
Causes nausea, vomiting, abdominal cramps, and diarrhea.
Chronic hazards:
®
No known chronic hazards. Not listed by NTP, [ARC or OSHA
a, s carcinogen.
Phtaicol hurardr:
Spilled material can be slippery.
4- FIRST Alb MEASURF_S
Stir:
'
In case of contact, immediately Ilush eyes with plenty of water for. at least
.
15 minutes. Get medical attention if irritation persists.
SkLn:
Not ahplicahk-.
Inhalation:
Remove to fresh air. If not breathing, give artificial respiration. If breathing
is diflleuIt, give oxygen. Get medical attention.

TradeNmur: Epsom Salt, Magnesium Sulfate, U.S.P.
Dttte Prepared WM7113 Page. 2 of 4
fngestion: If large quantities of this material are swallowed, toll it physician immediately.
Da NOT induce vomiting unless directed to do to by a physician. Never gin'e
anything by mouth to an unconscious person. ,
S. FIRF FIGHTING MEASURES
Flamnvbte lWts: This material is noncombustible.
®
Ectinglrishing Media:
Narardr !o Jlre-�Ighler's:
Fire -fighting equiµttem:
L ACCI IIFNTA I - R Ft
- Puson& protection:
Emironotenta Hazards:
Svmll spill clstmup:
Large spill cleanup:
CERCLA RAJ:
7. HANDLING ANn S"
. Handling:
Storage:
8- EXPOSURE C0-\7P
E*necring comrolz,
Respiratory protection:
Skin protection:
4V protection
This material Is compatible with nil extinguishing media,
See Section 3 for information on hazards when this material is present
is the area of a fire.
The following protective equipment for fire fighters is
recommended when this material Is present in the area of a fire:
chemical goggles, body -covering protective clothing, scMcontained
breathing apparatus.
ML=ASueEs
Wear chemical gaggks, See section V.
Ssnks and mixes with water. No adverse effects known. Not a listed toxic chemises
under SARATitle 111,§3t340CFRPart372. Not a CERCLA Hazardous
Su bstance u nder 40 CFR Part 30L
Sweep, scoop or vacuum discharged material. Flush residue will) water.
Observe environmental regulations.
Keep unnecessary people away; isolate -hazard area and deny entry. Do not touch
or walk through spilled material. Sweep, scoop or vacuum discharged material.
Flush residue with water. Observe environmental regulations.
There is no CERCLA Repartahk Quantity for this material.
)RAGE
Avoid breathing dust. Promptly clean up pills.
Keep containers closed. Protect from extremes of temperature and humidity
during storage. Recommended storage conditions 68-t I V F and 54-87% relative
humidify.
it SYPFftSf1NA 1. PEL0TFCrtnN
Use with adequate ventilation. Safety shower and eyewash fbuntain should be
within direct access.
Use a NOSH -approved dust respirator where dust occurs. Observe
OSHA regulations for rt spirator use (29 C.F.R. §1910.134)
Wear gloves if abrasion or irritation occurs.
Wear chemical goggles.

r
Tram Naaw: Epsom Salt, Magnesium ,Sulfate, U.S.P.
Dkare Prepared. OM7113 Page: 3 of 4
.4ppearance: Crystalline odorless powder.
Calar: White or transparent.
Odar: Otloruss,
pH: Apprnxittsately 0-7
Speeiftcgr-ity' 1.76 glcm°, Bulk Density Approximattly 1.05 gfem'
Solubility in water: 71 g/10D ml m 10• C. 91q/100 ml at 40, C
• 10. STABIIJTY AND RFACTIXITY
&ability This material is stabir trader all candaiaas of use and staiaga.
Candlhaw to OvoidNone,
i ,bfaierlals io avoid' Metal hydrides and other water reactive materinla.
Ilazordour drev11;vWilron
producrs: At very bigh temperatures, magr esiam oxide, sulfur dioxide, and sulfur trioxide
may be generated.
[1. Ti1X 1('OLOGICA[. ENFt1RMATFE3N
Acute Dara: Whee tested for primary irritation potential, this material caused mild eye
irritation. RTECS reports Ural TDLo= 428 mgtkg In man 351 mg/kg in women
12. FCOIIIC:ICAI. INFORM.yT10N
Eco iancifw Data not available.
Enviromrne"14i Fate: This msterlal it not persistent in aquatic systems and does not contribute to ROD. It
does not bioconcentrate up the food chain.
Ph}slcal/Chemieal: Sinks and mixes with water.
11. 0111;PORA I. CONS11yFRATIONS
Classiftearforr' Dhposed material is not a hazardous waste
Disposal Method' Landfill according to local, state, and federal regulations. Disposed matarfal is '
not a RCRA Hazardous waste.
M. TRANSPORT INFORMATION
DOT UNSlaiw: . This material is not regalattd hazzrdous material tar transportation.
1C RF(:111ATORY 1NEORMAT1ON
CERCL.f: No CERCLA Reportable Qnanthy has been establlshM for this material,

CJ
1r04 Xv,W: Epsom Salt, Magnesium Sulfate, U.S.P.
Date Prepar f, OU7113 Page; 4 of 4
SARA T1TL£ 111: fool an Extremely Hazardoas SubAsoce under §302. Not a Toxic
Chemical under §313, Hara„d Categorics under §§3[ 1/312s Acute
TWA: All ingredients of this material are listed an the TSCA inventory.
FDA: Magnesium sulfate is an FDA GRAS substance pursuant to 21 CFR
184.1443.
^l;./YTHRH �' MwTIf11V
Pmprred by; Mark A. Shand
Date ofPrepa,wlran: 09/07/13
Tim INFORMATION ON TUIS SAI£TY DATA SHEET IS BELIEVED TO BE ACCURATH AND IT IS711 F. BEST
INFORMATION AVAILABLE TOGites Chemital.THIS DOCUMENT IS IWENDED ONLY AS A CHID$ TOTHE
APPROPRIATEPRECA[rTSONS ►0R HANDLINC A LHL"ICALBY A PERSONTRAINEU IN CHEMICALMANDLING.
Giles CheMICAl MAM NO WARRANTY OF MERCHANTABILITY Ott ANV OTHER WARRAN CY, 8XPRESS OR
IMPLIED WITH RESPECT TO SUCH INFORMATIONOR TH£ PRODOCTTO WHIC111 IT RELATES, AND WE ASSUME
NO I.IABILtTV RESULTING FROeI THE USE OR HAN03ANG OFTHE FRODUCPTO WHICH THIS SAPETY Ow FA
SHEET RELATES. USEILSAND HANDI.XASOETIMS PRODUCTSHOULDMAI(E'1'I[EIR ONVN INV I:S111GATIONSTO
DI:T ERMINFE THE SUITABILITY OF TH IK INFORMATION PROVIDED HEREIN FOR T11E1 R OWN PURPOSFS.

t
C.
Incident Report
Report Number. 201400378
Incident Type: Complaint
Category: Surface water
Incident Started; 0=512014
County: Haywood
City:
Farm #:
Responsible Party:
Owner;
Perm it;
Facility;
First Name:
Middle Name:
Last Name:
Address
City/State/Zip:
Phone:
Material Category: Estimated Oty: UOM
On -Site Contact:
First/tAkYLasi Name: Deborah Durbin
Company Name:
Phone: (82"52-4784
PagerlMobile Phone: 1
Reported By:
FirstiMidlLast Name:
Company Name:
Address:
CitylSlalefLip:
Phone:
PagerlMobile Phone:
Chemical Name Reportable City. lbs. Reportable Oty. k9s.
DD:MMtSS Decimal Position Method: Rcmotc Sensing
Latitude: +35°29-33" 35.492500 Position Accuracy: Unknown
Longitude:—B2°59'33"-82.992500 Position Datum: Unknown
Location of Incident: Giles Chemical
Address: l02 Commence Sv
citylStatefhp Waynescilk INC 28786
Report Created 04102/14 07:58 AM Page I

CauselObservatlon:
The NCo>=NR Help Desk received a customer environmental
complaint concerning the release of some unknown liquid from a
large bulk storage tank located in town limits of Waynesville, NC.
A summary email of the complaint was sent to the Division of
Water Restri Water Quality Program staff in the Asheville
Regional Office on 2/2512014. In making the complaint, the
person who called stated that they were just passing through the
area and noticed something was not right. They did not spend
much time there and Could not provide many details- The
complainant observed a dear liquid coming out of the top of a
cylindrical tank that is about 10 to 20 feet in diameter. It was
coming out or overflowing from it at a significant rate
Complainant said that building was placarded as Giles Chemical
Company. The liquid was flowing out of the tank and going into
an unnamed or unknown creek that runs through the center of
Waynesville, NC. The complainant could not say what the
substance was. There was no placard-ing on the tank to show
what was stored there. There was no observable penetration of
the tank, just liquid streaming out the lop, No fish kill was
observed in the creek itself but the course of it was not followed
for a significant distance either.
Action Taken:
Landon Davidson with the DWR Water Quality Regional
Operations Called Giles Chemical at approximately 2:45 on
212512014 to determine what the cause of the release was.
Landon spoke with Matt Haynes of Giles who reported the
overflowing liquid was water that is stored for nonCOotaet
Woli« g water. Andrew Moore with the DWR Water Quality
Regional Operations made a site visit to Giles Chemical and
arrived at approximately 4:00 on 212572014, Andrew met with
Deborah Durbin, the Director of Quality and Safety, and Patrick
Owen, an engineer, both with Giles Chemical.
Incident Questions:
Did the Material reach the Surface Water? Unknown
Surface Water Name?
Did the Spill result in a Fish Kill? Unknown
If the Spill was from a storage tank indicate type.
Containment? Unknown
Cleanup Complete? Unknown
Directions:
From US 74, take exit 102 toward WaynesvillelBrevard. Right on US
2761Russ Avenue. Right on Deilwood Road. Left on Depot. Right on
Commerce Street. Facility is located at 102 Commerce Street.
Comments:
Giles Chemical has an NPDES permit NCG500244) to discharge
non -contact cooling water to Richland Creekr Mr. Owen reported that they
had to temporarily shut down cooling operations on 2/25/2014 for
maintenance. During the shutdown, the pumps pulling water from
Richland Creek were not shut down. Giles has an approximately 3,000
gallon storage tank to hold the cooling water prior to use and for extra
capacity. During normal operations, when the pumps removing water
from Richland Creek exceed the need of plant operations and the
capacity of the storage tank, the excess is directly discharged from the
Lank back into the creek. During the shut down of coaling operations on
2125M14, the water being pumped from the creek exceeded both the
capacity of the storage tank and the tank's capacity to expel the water,
resulting in overtopping of the storage tank. It appears that the
overtopping of the storage tank with unused water was observed by the
complainant. Richland Creek was inspected downstream of the discharge
by Andrew Moore and no visual or odor impacts were observed.
Conveyance:
Estimated Number of fish?
(Above Ground or Under Ground)
Water Supply Wells within 151: Unknown Groundwater Impacted : Unknown
Report Created 04102114 07:58 AM
Page 2

40
Event Type
Event Date
Incident closed
Requested Additional Information
Report Entered
2014-02-27 09:53:00
Inspection or Site Visit Conducted
2014-02-25 04:00:00
Referred to Regional Office - Primary Contact
2014-02-25 03:00:00
Incident Start
2014-02-25 02:41:00
Report Received
2014-02-25 02:41:00
Standard Agencies Notified:
Agency Name Phone
First Name
Due Date Comment
M.I. Last Name Contact Date
Other Agencies Notified:
Agency Name Phone First Name M.I. Last Name Contact Date
DWQ Information:
Report Taken By: Report Entered By: Regional Contact:
Landon Davidson Andrew W Moore Andrew W Moore
Phone:
Datefrime: 2014-02-25 02:41:00 PM 2014-02-27 09:53:00 AM 2014-02-25 03:00:00 PM
Referred Via: email email
Did DWQ request an additional written report?
If yes, What additional information is needed?
Report Created 04t02I14 07:58 AM Page 3

0
E
DWRIncident Report
Division Di Water Ilesatnes Report Number:. 201401632
Incident Type: Spill (Oil, Chemigl, non -sewage)
OttSim Contact :
Category Indent
First/Mid/Last Name
Incident Started: 10104t2014
Company Name:
Country: Haywood
Phone
City:
Pager/Mobile Phone: 1
Farm 0 :
Responsible Party:
Owner
Reported By
Permit:
FirstlMidlLast Name
Facility
Company Name
First Name: Jason
Address
Middle Name
Last Name: Bumgarner'
CitylSsatelZip
Address: 102 Commerce St
Phone
Page Mc,laile Phone : I
CitylStateop : Waynesville NC 28786
Phone : [phone]
Material Category: Estimated City: UOM:
Chemical Name Reportable Oty.lbs. Reportable Oty.kgs.
Chemical 300 gal
DD:MM:SS Decimal
Position Method :
Latitude :
35' 29' 35" 35.492970
Position Accuracy:
Longthude :
-B2" 59' 31" •82.991900
Position Datum
Location of Incident :
Giles Chemical
Address :
102 Commerce St
citylstatemp :
Waynesville
NC 28786
Remote Sensing
Nearest 10th Of A Second
Unknown
Report Createa 1 1014114 6:29 pm Page: 1

Cause/Observation :
Directions
0
: I (Brett Laverty) received a call from the Division of Emergency
Management on Saturday October 4, 2014 at 11:01 AM. I returned the
call at 12:13 PM. The dispatch said a call was received about a
release of an unknown liquid from Giles Chemical in Waynesville
(Haywood County)_ The dispatch initially nctitied the Waynesville
Wastewater Treatment Plant. I called the wastewater treatment plant
and spoke with Jeff Evans (828-452.4685), Mr. Evans said Marvin
Crawford with the Waynesville Street Department followed up on the
call and reported a broken pipe at the plant which resulted in
approximately 50 gallons of an unknown liquid entering a nearby
storm water drain in front of the plant on Commerce Street.
Action Taken
Get on 1-40 W Continue on 1-40 W to Waynesville. Take exit 102 from
US-74 W. Turn right onto US-275 S1Russ Ave and continue on US-276
S1Russ Ave. Dellwood Rd turns slightly left and becomes Depot St.
Turn right onto Commerce Street.
Comments
Repon Created 1014114 6:29 pm
Pago: 2

so
11
I (Brett Laverty) left the Asheville Regional Office at 1:10 PM and
arrived at Giles Chemical at approximately 2',00 PM,
Incident Qtiestlons :
Upon arriving at Giles Chemical, I observed the flooll the plant
nearest the brine tanks was ankle deep in a brown liquid. Additional
liquid was discharging from the base of one of the brine tanks at a
fairly high rate and spilling on to the plant floor. The street
(Commerce Street) in front of the plant was damp for approximately
50 feet until it reached a storm drain. The damp area also appeared
to be ooated with a whrta preaptil
I spoke with severer workers that were trying to contain the brown
liquid, I asked one worker what the blquid was and he responded by
saying it was municipal water. I asked why it was brown_ He
responded by saying 0. was the magnesium in the cooling water. As
they were busy. t requested to speak to someone who could explan
what was happening. One of the workers called plant manager
Jason Bumgamer who said he would be there in about 20 minutes_
While waiting for me plant manager (approximately 2,15 PM), the
water level inside the plant began to rise and discharge onto
Commerce Street and into the storm drain. I proceeded to take
pholos of the discharge. I also drove around the back of the plant and
observed the brown liquid discharging through a Closed door and
directly into Richland Creek. I took several photos of the discharge.
The plant manager arrived at approximately 2:30 PM. He identified
the brown liquid as magnesium sulfate or Epson Salt, which is a
mix of magnesium and sulfuric acid- The pH of the liquid is in the
range of &0 C 7.5. Mr. Bumgamer provided me with an MSDS sheet.
He said the plant had been shut down since yesterday at noon_ He
said a buildup of magnesium precipitate and recent construction
debris had partially clogged the pfantrEls drain system to the
municipal sewer, The pumps Circulating the magnesium suifate
cannot be shut down without damaging the equipment, which
resulted in the cornttrlual flood of process water on the plant floor.
Apparertlry, the drain system became fully clogged this morning
resulting in continuous discharges to Richland Creek via the storm
drain and back door.
A plumbing contractor had been orsite all night trying to dear the
clog. The plumbing Contractor returned with additional equipment
(auger) while I was speaking with the plant manager. We walked to
the hack of the plant to watch the plumbing contractor remove the
clog. Once the clog was removed all of the stored water on the plant
floor overwhelmed the drainage system and several hundred gallons
of process water discharged into Richland Creek. I took several
photos of the discharge f watched the plume move downstream and
tried to observe any stressed aquatic ide. None were observed_ Once
the plume had passed a white coating covered the bottom of the
creek, which the plant manager. identified as silicates,
The plant manager felt the dog had been removed and normal flow
had fetuineo to lino drain system. I encouraged him to develop a
maintenance plan so that precipitate buildup within the drain could
be dealt with in a timely manner, We walked to the from of the
building and observed a substantial reduclion in water levels within
the plant. Workers were ustng squeegees to move the remaining
water to the floor Grains. OischorrJes along Commerce Street and in
the back of the plan[ had Ceased. I then proceed to the Depot Street
bridge (just downstream at the plant) to observe the rendition of the
stream. There was ao stressed aquatic Ice and no discoloration on
the stream bottom or in the water column, I left the site at
approximately 3'45 PM,
Repon Created 1014f14 629 pm
Page: 3

Did the Material reach the surface Water? Yes Conveyance: Other
Surface Water Name '? Richland Creek
Did the Spill result in a Fish Kill? No Estimated Number of fish? 0
If the Spill was from a storage lank indicate type : (Above Ground or Under Ground)
Containment? Yes
Cleanup Complete? Yes
Water Supply Weiis within 1500ft : Unknown Groundwater Impacted : Unknown
Event Type
Incident closed
Requested Additional Information
Report Received
Referred to Regional Office - Primary Contact
Report Entered
Incident Start
Standard Agencies Notified
Agency Name Phone
Other Agencies Notified
Agency Name Phone
D Q Infomtadon
Report Taken By:
Event Date Due Date
2014/10/04 6:23:00
2014110/04 11:10:00
First Name M.1, Last Name
First Name
Report Entered By:
M.I. Lest Name
Comment
Contact pate
Contact Date
Regional Contact:
Report Created 1 U4114 6.29 pm page : 4

Brett Laverty Brett
Phone:
Brett
11
Galcmme:
Referred via:
Did DWQ request an addltlonal written report?
If yes, What addHional information is needed?
2014110104 06,2100PM
Report Created IOM04 629 pm
Page: 5

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j Chalam Pakala Engineering and Environmental Solutions
i A Cost Eflwove Solution Provider for Manufacturing Industries
1
Chalam ("Chuck") Pakala, RE.
Managing Principal
10017 AUyson ?ark Dr. Tel: [phone]
Charlotte, NG 28277 Fax: [phone]
E-mail: [e-mail]
U

Chalam Pakala Engineering and Environmental Solutions
rrnnrw nmi .ice .
10017 A1lyson Park Dr., Charlotte, NC 28277 "fel [phone], Fax: [phone]
November 5, 2012
Ms. Bethany Georgoulias, Environmental Engineer I1
NC DENR — Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27669-1617
[phone]
[e-mail]
ncdenr.gov
Re: Request for NPDES Stormwater No Exposure General Permit
Giles Chemicals
102 Commerce Dr.
Waynesville, North Carolina 28786
CPEES Project No. 1136-002
Dear Ms. Georgoulias:
On behalf of Giles Chemicals located at 102 Commerce Dr., Waynesville, Haywood County,
North Carolina, CP Engineering and Environmental Solutions (CPEES) is pleased to submit "No
Exposure General Permit" (NCGNE0000) request to the State for a NPDES' Stormwater No
Exposure Permit for the subject facility operations. The facility conducts their operation under
the SIC code 2819 (Industrial Inorganic Chemicals). Therefore, the applicable NPDES
Stormwater Permit for this SIC code is an individual stormwater permit. However, Giles
Chemicals is very diligent in controlling the exposure of facility oil/chemical storages and
loading/unloading operations to stormwater. Thus, Giles Chemicals had requested CPEES to
review the facility operations and assess the NPDES Stormwater General Permit Exemption
criteria and No Exposure certification.
SITE REVIEW
On October 24, 2012, CPEES had conducted a site review for the facility operations exposed to
stormwater. During the facility review, the following areas were reviewed for the stormwater
exposure:
• Oil and Chemical storage areashanks out side the plant building;
• Materials storage outside the plant operations;
• Loading and unloading at the docks;
• Roof discharges;
• Best Management Practices (BMPs) implemented at the site;
• General site erosion and sediment transport; and
• General leaks from the building.

Chalam Pakala U ineering and Environmental Solutions
10017 Allyson Park Dr., Charlotte, NC 28277 Tel [phone], Fax: [phone]
FINDINCS
Eased on the site review, CPEES believes Giles Chemicals had implemented several controls
(BMPs) to mitigate the exposure of oil/chemical storage areas, transfer practices and general
operations from stormwater. Some of our observations include:
• All aboveground storage tanks are secondary contained with NO discharge pipe in the
dike;
• The waste sludge from the facility operations is contained in a roofed building/shed and
the entrance of the structure is directed towards the building in order to control any
stormwater run-on and run-off from the storage area;
• The waste sludge conveyor from the facility is covered on the top and the return
conveyor belt is covered at the bottom to control the stormwater exposure. Any
stormwater falls into the bottom tray/cover is routed back into the facility;
• All empty oil/chemical drums are kept inside facility building in order to prevent
exposure to the precipitation;
• The rail transfer station is well maintained in order to control raw materials exposure to
stormwater,
• No bulk oils are received at the facility;
• No underground storage tanks exist at the site;
• Two trash dumpsters, containing general trash from the operations, had lids and were
controlled from the exposure to stormwater;
+ No soil erosion was observed at the facility, and
• The overall facility yard appeared to be well maintained with no materials exposed to
stormwater.
NO EXPOSURE APPLICATION
CPEES has completed the State NCGNE0000 "No Exposure Certification" application package
to meet the State requirements. The package includes the application, a Ste Location Map
(Figure 1) and an Aerial View Map.
CONCLUSIONS AND RECOMMENDATIONS
Based on our site review and findings, CPEES believes that the subject facility should be
exempted from the NPDES Stormwater Individual/General Permit at the present time.
However, should the facility decides to change the operations in the future and could potentially
impact the stormwater, then the facility should apply for the NPDES Stormwater Permit at that
time to meet the NC DENR Division of Water Quality Requirements.

Chalarn Pakala Engineering and Environmental Solutions
10017 Allyson Park Dr., Charlotte, NC 29277 Tel [phone], Fax: [phone]
CLOSING
It is my pleasure to complete this important project for Giles Chemicals and please call me at
704-541-4042 should you have any questions on this permit exemption request.
Respectfully submitted,
CP Engineering and Environmental Solutions
(A Cost Effective $elution Provider for Atanxf acluring)
,\\\-\ \A CAR
o %
?a SEAL. 'P �
19807
Chalam V. Pakala, P.E. =.
Managing Principal q
'?'GIN�� Q �. tt 1'Y
CC: i�,�� 1V.1 PR`�P� �.
Ms. Susan Wilson, Permit Engineer
Asheville Regional Office-DWQ
2090 U.S. 70 Highway, Swannanoa, NC 28778
[phone]

*W
AL 4 Division of Water Quality 1 Surface Water Protection
�ra��
NCDER National Pollutant Discharge Elimination System
�a —G�­E­�..�. Oe NO EXPOSURE CERTIFICATION for Exclusion
Fwv m. r.- mn HxrLow. RrM7.. r6
NCGNE0000
NO EXPOSURE CERTIFICATION
FOR AGENCY USE ONLY
Date Received
Year
Month
Da
Ceniricale of Covcra
P,
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DWQ must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling; and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
You are required to self re -certify your No Exposure Exclusion annually_
For questions, please contact the DINO Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of ownerloperator (address to which all certification correspondence will be mailed):
Name GILES CHEMICALS
Contact MS. DEBORAH DURBIN
Street Address 102 COMMERCE ST.
City WAYNESVILLE State NC ZIP Code 28786
Telephone No. 828 452-4784 X 33 Fax: [phone]
Email [e-mail]
Page 1 of 7
SWU-NE-12Aug2010

NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name GILES CHEMICALS
Facility Contact MS. DEBORAH DURBIN
Facility Street Address 102 COMMERCE ST.
City WAYNESVILLE State NC ZIP Code 28786
County HAYWOOD
Telephone No. 828 452-4784 X 33 Fax: [phone]
Email [e-mail]
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). SEE ATTACHED USGS TOPO MAP
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes 1A No
5) is this a Federal facility? ❑ Yes 0 No
6) Latitude 35 29' 35.2"E Longitude 82 59' 29.7" W (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
© Existing
Date operation began 1950
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes G No
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 2 8 1 9
10) Provide a brief description of the types of industrial activities and products produced at this facility:
MANUFACTURER OF EPSUM SALT
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
❑ No
13 Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility: NCG500244
Page 2 of 7
SW U-NE-12Aug2010

NCGNEOOOO No Exposure Certification
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes AO
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks ❑ Yes VNo
c. Materials or products from past industrial activity ❑ Yes VNo
d. Material handling equipment (except adequately maintained vehicles) ❑ Yes GAo
e. Materials or products during loading/unloading or transporting activities ❑ Yes CINo
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes VNo
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes VNo
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes Olo
the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes R/No
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes VNo
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not
❑ Yes VNo
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored
❑ Yes C/No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers
❑ Yes 5AO
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, or
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
C�(Yes ❑ No ❑ N/A
91Yes ❑ No ❑ N/A
Page 3 of 7
SWU-NE-12Aug2010

NCGNE0000 No Exposure Certification
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for all single above ground storage
ID/Yes ❑ No ❑ NIA
containers (including drums, barrels, etc.) with a capacity of more than 660-
gallons?
b. Is secondary containment provided for above ground storage containers stored
G�Yes ❑ No ❑ NIA
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund
❑ Yes ❑ No G/N/A
Amendments and Reauthorization Act (SARA) water priority chemicals*?
d. Is secondary containment provided for hazardous substances"* designated in 40
❑ Yes ❑ No R(N/A
CFR §116?
VYes
e. Are release valves on all secondary containment structures locked?
❑ No ❑ NIA
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes t(No
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste ❑ Yes I/No
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes 12/No
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
Footnotes to Questions 14) c. & d.
*Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some,exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR
§372.38.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities
of the hazardous substances listed in 40 CFR §117.3.
Page 4 of 7
SWU-NE-12Aug2010

NCGNE0000 No Exposure Certification
1 6) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes ENo
b. Does your facility have coal piles on site? ❑ Yes &(No
c. Does your facility store other fuel sources outside in piles, such as wood chips,
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g.,
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity: M0-1 vn.e.c_i oyy% OAAA f, 51,10t 0 MM v��S i t�►n
e. If you answered yes to d., are those emissions permitted by an Air Quality Permit?
Please specify:
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: o S 9 b 7 A o 5", , Program: 5 TA T E
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
❑ Yes lid No
lilies ❑ No
Z D* z e,
R(YEs ❑ No ❑ NIA
Page 5of7
swU-NE-12Aug2010

NCGNE0000 No Exposure Certification
17) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to annually self re -certify No Exposure and, if requested, submit the re -certification to
DWQ or the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where
applicable). I understand that I must allow the North Carolina Division of Water Quality, or MS4 operator where the
discharge is into the local MS4, to perform inspections to confirm the condition of no exposure and to make such
inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any Qoint source discharge of stormwater from the facilit . Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
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.
Printed Name of -Person Signing: DEBORAH DURBIN
Title: DIRECTOR OF QUALITY AND SAFETY
(Signature of Applicant) (Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars ($10,000).
There is currently no fee for a No Exposure Exclusion.
Page 6 of 7
SWU-NE-12Aug2010

NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
This completed application and all supporting documentation.
C� A map with the location of the facility clearly marked.
l/ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWO Regional Office for your area.
DWQ Regional Office Contact Information:
Asheville Office ...... [phone]
Fayetteville Office
... [phone]
Mooresville Office
... [phone]
Raleigh Office ........
[phone]
Washington Office ...[phone]
Wilmington Office
... [phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 7 of 7
SWU-NE-12Aug2010

S7b Si~e vti"r
Chalam Pakala Engineering and Environmental Solutions
10017 Allyson Park Dr., Charlotte; NC 28277 Tel [phone], Fax: [phone]
November 5, 2012
Ms. Bethany Georgoulias, .Environmental Engineer II
NC DENR — Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27669-1617
[phone]
bethany.georgoulias a ncdenr.gov
Re: Request for NPDES Stormwater No Exposure General Permit
Giles Chemicals ED l02 Commerce pr.{1
Waynesville, North Carolina 28786 u
CPEES Project No. 1136-002
Dear Ms. Georgoulias:
On behalf of Giles Chemicals located at 102 Commerce Dr., Waynesville, Haywood County,
North Carolina, CP Engineering and Environmental Solutions (CPEES) is pleased to submit "No
Exposure General Permit" (NCGNE0000) request to the State for a NPDES Stormwater No
Exposure Permit for the subject facility operations. The facility conducts their operation under
the SIC code 2819 (Industrial Inorganic Chemicals). Therefore, the applicable NPDES
Stormwater Permit for this SIC code is an individual stormwater permit. However, Giles
Chemicals is very diligent in controlling the exposure of facility oiilchemical storages and
loading/unloading operations to stormwater. Thus, Giles Chemicals had requested CPEES to
review the facility operations and assess the NPDES Stormwater General Permit Exemption
criteria and No Exposure certification.
SITE REVIEW
On October 24, 2012, CPEES had conducted a site review for the facility operations exposed to
stormwater. During the facility review, the following areas were reviewed for the stormwater
exposure:
• Oil and Chemical storage areas/tanks out side the plant building;
• Materials storage outside the plant operations;
• Loading and unloading at the docks;
• Roof discharges;
• Best Management Practices (BMPs) implemented at the site;
• General site erosion and sediment transport; and
• General leaks from the building.

0 0 r
r ��

El
•
Chalam Pakala Engineering and Environmental Solutions
10017 Allyson Park Dr., Charlotte, NC 28277 Tel [phone], Fax: [phone]
FINDINGS
Based on the site review, CPEES believes Giles Chemicals had implemented several controls
(BMPs) to mitigate the exposure of oil/chemical storage areas, transfer practices and general
operations from stormwater. Some of our observations include:
• All aboveground storage tanks are secondary contained with NO discharge pipe in the
dike;
• The waste sludge from the facility operations is contained in a roofed building/shed and
the entrance of the structure is directed towards the building in order to control any
stormwater run-on and run-off from the storage area;
• The waste sludge conveyor from the facility is covered on the top and the return
conveyor belt is covered at the bottom to control the stormwater exposure. Any
stormwater falls into the bottom tray/cover is routed back into the facility;
• All empty oil/chemical drums are kept inside facility building in order to prevent
exposure to the precipitation;
• The rail transfer station is well maintained in order to control raw materials exposure to
stormwater,
• No bulk oils are received at the facility;
• No underground storage tanks exist at the site;
• Two trash dumpsters, containing general trash from the operations, had lids and were
controlled from the exposure to stormwater;
• No soil erosion was observed at the facility, and
The overall facility yard appeared to be well maintained with no materials exposed to
stormwater.
NO EXPOSURE APPLICATION
CPEES has completed the State NCGNE0000 "No Exposure Certification" application package
to meet the State requirements. The package includes the application, a Ste Location Map
(Figure 1) and an Aerial View Map.
CONCLUSIONS AND RECOMMENDATIONS
Based on our site review and findings, CPEES believes that the subject facility should be
exempted from the NPDES Stormwater Individual/General Permit at the present time.
However, should the facility decides to change the operations in the future and could potentially
impact the stormwater, then the facility should apply for the NPDES Stormwater Permit at that
time to meet the NC DENR Division of Water Quality Requirements.

0 0
Chalam Nakala Engineering and Environmental Solutions
10017 Allyson Park Dr.. Charlotte, NC 28277 Tel [phone], Fax: [phone]
CLOSING
It is my pleasure to complete this important project for Giles Chemicals and please call me at
704-541-4042 should you have any questions on this permit exemption request.
Respectfully submitted,
CP Engineering and Environmental Solutions
0 Cost Effective Solution Provider for Alanaafacturingd
A R p
Esssoy
4-
_ ;Q SEAL 9
19807
Chalam V. Pakala, P.E.
Managing Principal
CC:
AM V
Ms. Susan Wilson, Permit Engineer
Asheville Regional Office-DWQ
2090 U.S. 70 Highway, Swannanoa, NC 28778
[phone]

FOR AGENCY USE ONLY
. Dale Received
Division of Water Quality /Surface Water Protection , ,+,�Y,ear� >�•�Qd,hri ,c+Day;rn ,
W s e ifi to of Covbrtse
National Pollutant Discharge Elimination Sys in , !,
NCDENR NO EXPOSURE CERTIFICATION for Exclu �• o I I ; t�
'k,Klw y.v..—su l:lHx,wE VT O. {!�s 1 "•
�wJSY.�Vwf•.VT +<n N,srtnu. RF:i0..1!I NC V �0000 � �1",,,,, �".': .�
DEC 1 1 2012
NO EXPOSURE CERTIFICATION F
National Pollutant Discharge Elimination System application for exclusio Fr
m a Stormwater:Perrrlitibbsed
i i
WA fEH l;'JW y 1 ,cam• I'.•,v 71
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification tha#, your facility does not require a
permit for stormwater discharges associated with industrial activity in tiie State}ofNorfh;Carolinii;becausi
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DWQ must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities Include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product,'final product or waste product. A storm resistant shelter is not
required for the following Industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling; and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual
outfalls. if any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
You are reouired to self re-certifv vour No Exposure Exclusion annually.
For questions, please contact the DWQ Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of owner/operator {address to which all certification correspondence will be mailed]:
Name GILES CHEMICALS
Contact MS. DEBORAH DURBIN
Street Address 102 COMMERCE ST.
City WAYNESVILLE State NC ZIP Code 28786
Telephone No. 828 452-4784 X 33 Fax: [phone]
Email [e-mail]
Page 1 of 7
SW U-N E-12Aug2010

NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name GILES CHEMICALS
Facility Contact MS. DEBORAH DURBIN
Facility Street Address 102 COMMERCE ST.
City WAYNESVILLE State NC ZIP Code 28786
County HAYWOOD
Telephone No. 828 452-4784 X 33 Fax. [phone]
Email [e-mail]
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). SEE ATTACHED USGS TOPO MAP
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes Q No
5) Is this a Federal facility? ❑ Yes D No
6) Latitude 35 29' 35.2"E Longitude 82 59" 29.7" W (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility
0 Existing
Date operation is to begin
Date operation began 1950
❑ . Renewal.of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? Yes --­ [E-No
_ �If yes, what is the NPDES Permit Number?
9) Standard.industr€aLClassification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 2 8 1 9
10) Provide a brief description of the types of industrial activities and products produced at this facility:
MANUFACTURER OF EPSUM SALT'
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
❑ No
o Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility: NCG500244
Page 2 of 7
SWU-NE-12Aug2010

0
NCGNE0000 No Exposure Certification
n
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where D Yes WNO
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks ❑ Yes Gm(No
c. Materials or products from past industrial activity ❑ Yes 1Ao
d. Material handling equipment (except adequately maintained vehicles) © Yes GAo
e- Materials or products during loading/unloading or transporting activities ❑ Yes tiNo
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes GAo
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes t(No
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑-Yes G610
the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) 0 Yes Gallo
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes VNo
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes CINo
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
1. Empty containers that previously contained materials that are not properly stored D Yes VNo
(i.e., not closed and stored upside down to prevent precipitation. accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes 540
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, or
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
IdYes ❑ No a N/A
WYes ❑ No ❑ N/A
Page 3 of 7
SWU-NE-12Aug2010

0
NCGNE0000 No Exposure Certification
0
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for all single above ground storage
7'Yes ❑ No ❑ NIA
containers (including drums, barrels, etc.) with a capacity of more than 660-
gallons?
b. Is secondary containment provided for above ground storage containers stored
I/Yes ❑ No ❑ NIA
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund
❑ Yes ❑ No VNIA
Amendments and Reauthorization Act (SARA) water priority chemicals`?
d. Is secondary containment provided for hazardous substances" designated in 40
❑ Yes ❑ No A/A
CFR §116?
/
e. Are release valves on all secondary containment structures locked?
C Yes ❑ No ❑ NIA
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
O Yes dNo
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste
a Yes ®(No
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste
© Yes G?lNo
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport I disposal vendor:
Vendor address:
Footnotes to Questions 14) c. & d.
`Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements,of Title III SARA 313 in 40 CFR
§372.38.
*Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities
of the hazardous substances listed in 40 CFR §117.3.
SW U-NE • 12Aug2010
Q.
Page 4 of 7

NCGNEOOQQ No Exposure Certification
16) Other information: if you answer "Yes" to any of the following Items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? []Yes Ii/No
b. Does your facility have coal piles on site?
❑ Yes 62(No
c. Does your facility store other fuel sources outside in piles, such as wood chips, ❑ Yes i(No
sawdust, etc-?
d. Does your facility have air emissions associated with its industrial activity (e.g., I(Yes ❑ No
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity: Mao-JyN4,s e' gm0 AAA4f 5('191 _9 Mn t �',�r�_ �..AL P, 4-
e. If you answered yes to d., are those emissions permitted by an Air Quality Permit? Yes ❑ No ❑ NIA
Please specify:
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: 4 13 9 1, 7 � b _1r_ , Program: 5 TA T l;
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: , Program:
Permit: , Program:
Page 5 of 7
swu-NE-t 2Augzoi o

0 •
NCGNE0000 No Exposure Certification
17) Certitication:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of `no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
i certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to annually self re -certify No Expos and, if requested, submit the re -certification to
DWO or the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where
applicable). I understand that I must allow the North Carolina Division of Water Quality, or MS4 operator where the
discharge is into the local MS4, to perform inspections to confirm the condition of no exposure and to make such
inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that 1 must obtain coverage under
an NPDES permit prior to any goint source dischar of stormwater from the facili . Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
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.
Printed Name of Person Signing: DEBORAH DURBIN
Title: DIRECTOR OF QUALITY AND SAFETY
(Signature of Applicant) (Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material tact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars ($10,000).
There is currently no fee for a No Exposure Exclusion.
Page 6 of 7
SWU-NE•12Aug2010

0 0
NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
This completed application and all supporting documentation.
t� A map with the location of the facility clearly marked.
t/ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question S.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWQ Regional Office for your area.
DWQ Regional Office Contact information:
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 7 of 7
SWU-NE-Mug2010

NCDENR
North Carolina Department of Environment and
Division of ,Water Quality
Beverly Eaves Perdue Charles Waklld, P.E.
Governor Djrector
May 1, 2012
Ms. Deborah Durbin
Giles Chemical Corporation
102 Commerce Street
Waynesville, NC 28786
SUBJECT: NPDES Stormwater Permit Compliance Inspection'
Giles Chemical - Waynesville Plant
Permit No: NCG500244
Haywood County
Dear Ms. Durbin:
0
Natural Resources
Dee Freeman
Secretary
This letter is in follow-up to the NPDES Permit Compliance Inspection conducted on April 25,
2012. The Division of Water Quality (represented by Tim Fox and 1) appreciates your assistance,
along with Mr. Owen and Mr. Willis, during the site inspection.
Enclosed is a copy of the Inspection Report (for both the NCG500244 and the stormwater site
inspection); which contains additional observations and comments for your reference.
The DWQ will continue to work with Giles Chemical to determine the best course of action for
compliance with stormwater regulations.
Please contact me at [phone] or Susan. A.Wilsotlncdenr.go_v, if 1 can be of any further
assistance.
Sincerely,
Susan A. Wilson
`Environmental Engineer
Surface Water Protection
Enclosures
NCG500244 Inspection
Site Inspection (non -DOT) Report
cc: Central Files
ARO Files
S:ISWPII[aywond\WastewaterlGenerallNCG50 Non-ContactWCG500244 GilesUnspection LttcGiles.4 2012.doc
Location: 2090 U.S. Highway 70. Swannanoa, North Carolina 28778
Phone: s2aa96A50 Fax: 828-294aOne�a3 North Carafi n ��
Internee: www.ncwaterquality,org �
An Equal Oppohunity, , Atfirmalive Action Employer �atLLrallif

FJ
•
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.G. 20460
OMB No. 2040.0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type
1 I N 1 2 I� I 31 NCG500244 111 121 12/04/25 117 181 C I 191 S I 201 1
U
Remarks
21I I__ 1 1 _LI l L_I �L I I 1 I I I I I I 1 1 I I I I I III 16
,I.
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA-
671 169 701 1 71 1 1 72 Ll 73 I ' 174 751 1 1_ „I 1 I� 80
W
Section B3 Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effect';ve Date
POTW name and NPDES permit Number)
01:30 PM 12/04/25
07108/01
Waynesville plant
Exit Time/Dale
Permit Expiration Date
102 Commerce St
Waynesville NC 28786
03:00 PM 12/04/25
12/07/31
Name(s) of Onsite Rep resenlative(s)1Titles(s)IPhone and Fax Numbers)
Other Facility Data
1!!
Name, Address of Responsible Officiaf/Till elPhone and Fax Number
Contacted
Stacy Howell,102 Commerce St Waynesville NC 28786/1828-452-478419284524786 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Records/Reports Facility Site Review EffluentfReceiving Waters
Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Susan A Wilson ARO W011828-294-45001
Timothy R Fox ARO WQlf828-296-45001
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9.94) Previous editions are obsolete
Page# 1

NPDES yrtmo/day Inspection Type (cont. i 1
3I NCG500244 11 "1 12/04/25 t 17 18L
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Susan Wilson and Tim Fox (DWQ) met Deborah Durbin (ES&H), Patrick Owen, and Robert Willis (of Giles
Chemicals) on April 25, 2012. Giles Chemicals makes epsom salts for bulk and retail sales. Magnesium
oxide and sulfuric acid are shipped by truck or rail to be used in the process.
The facility discharges blowdown from the process. The facility is also tied -in to the Waynesville WWTP for
some process wastewater and domestic wastewater. Floor drains in the plant go to Waynesville. Per
Patrick Owen, air compressor condensate also goes to the municipal sewer system.
The facility has been monitoring for temperature and pH - as required (and has been in compliance). ,They
have not been monitoring for total residual chlorine as required (and this was discussed during the
inspection - they were not aware they had to). They expressed a desire to become certified for total
residual chlorine. After speaking with Gary Frances, Laboratory Certification, since the facility is not
"classified" due to the general permit status, and DMRs do not have to be submitted to DWQ, Giles will not
have to be certified for TRC (they plan to use their in-house instrument).
The non -contact cooling water inspection was prompted mainly due to the inspection for stormwater. The
facility is essentially compliant with this permit (with the exception of the TRC monitoring). No adverse
water quality impacts were noted at the facility during the time of inspection.
(See additional notes under Giles Chemical - site inspection).
Page # 2

Permit: NCG500244 Owner - Facility: Waynesville plant
Inspection Date: 0412512012 Inspection Type; Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? n n ■ ❑
Is the facility as described in the permit? ■ n ❑ n
ft Are there any special conditions for the permit?
n ■
n
n
Is access to the plant site restricted to the general public?
n
Cl
■
n
Is the inspector granted access to all areas for inspection?
■
n
❑
n
Comment: This inspection was for a standard Non -contact cooling water general
permit. There is no wastewater treatment plant associated with the plant.
Record Keeping
Yes No
NA
NE
Are records kept and maintained as required by the permit?
■
n
n
n
Is all required information readily available, complete and current?
■
o
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
n
n
Are analytical resuits consistent with data reported on DMRs?
n
■
n
Is the chain -of -custody complete?
n
n
■
n
Dates, times and location of sampling
n
Name of individual performing the sampling
❑
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
n
Are DMRs complete: do they include all permit parameters?
n
n
■
n
Has the facility submitted its annual compliance report to users and DWQ?
n
Cl
■
Cl
(If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator on each shift?
n
❑
■
❑
Is the ORC visitation log available and current?
n
n
■
n
Is the ORC certified at grade equal to or higher than the facility classification?
n
�!
■
n
Is the backup operator certified at one grade less or greater than the facility classification?
❑
n
■
Is a copy of the current NPDES permit available on Site?
❑
■
n
n
Facility has copy of previous year's Annual Report on fife for review?
n
n
■
13
Page # 3

0
Permit: NCG500244 Owner • Facility: Waynesville plant
Inspection Date: 0412512012 Inspection Type: Compliance Evaluation
Record Keeping
Comment: This is a general permit, there is no WW treatment plant and no required
ORC. Records are maintained on -site (as required). The facility has not performed
total residual chlorine monitoring 2/year as required by the permit (this was discussed
during the inspection).
Temperature and pH are measured upstream and downstream of the plant (which is
fine).
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
if effluent (diffuser pipes are required) are they operating properly?
Comment: The NCCW outfall is located mid -plant at an access/transfer "bridge"
across Richland Creek,
Yes
No
NA
N€
Yes No FAA NE
Page # 4

r
•
Facility Name: Waynesville plant
Facility Address: 102 Commerce St
Waynesville NC 28786
County: Haywood
Directions.,
Latitude: +35°29'34"
Compliance inspection Report
Facility Owner Name: Giles Chemical Corporation
Inspection Date: 04125/12
Reason for Inspection: Routine
Inspection Type: Site Inspection (non -DOT)
Inspection Contact Person:
On -Site Representative(s):
Primary Inspector: Susan A Wilson
Secondary Inspector(s):
Facility Compliance Status:
Program Areas: NPDES SW- Industrial
Question Areas:
0 Failure to Secure NPDES SW Permit
Region: Asheville
Longitude:-82'59'33"
Phone:
Phone: [phone]
E Compliant n Not Compliant
Inspection Summary:
Susan Wilson and Tim Fox (DWQ) met with Deborah Durbin, Patrick Owen, and Robert Willis (Giles Chemical Corp) to determine if
a stormwater permit is necessary.
DWQ reviewed the entire site and had some suggestions to reduce exposure. DWQ will continue to work with Giles Chemicai to
determine the need for a stormwater permit. The facility makes epsom salts - this process does not fall under any SW General
permit. Should a SW permit be necessary - it would have to be an individual permit. Due to the limited exposure - DWQIARO does
not believe that an individual permit will be warranted. DWQIARO may require the facility to produce and implement a Stormwater
Pollution Prevention Plan.
The facility has some exposure loadinglunloading materials at the RR track (however, there is no stormwater pathway for this to
leave the area unless the spill is extremely large). The facility also has some exposure at the filter cake conveyer belt over Richland
Creek. Giles is now getting bids to put a "catch guard" in place under the conveyer belt to prevent loss of filter cake,
There is also exposure at the sulfuric acid tanks (which have secondary containment). Their procedure is to take pH readings in the
basin, if neutral - pump out via sump pump to the storm drain. We discussed documenting this procedure each time it is done as
part of a SWPPP.
Page: 1

0 ,
Facility: Waynesville plant Owner - Facility: Giles Che nical Corporation
Inspection Dale: 04/25/12 Inspection Type: Site Inspection (non -DOT) Reason for Visit: Routine
Failure to Secure NPDES SW Permit
Does the site have a NPDES Industrial Stormwater Permit?
Comment: DWQ is working with Giles Chemical to determine if a stormwater permit is
necessary. The company is taking steps to reduce its exposure and will apply for a No
Exposure permit.
DWQ may require Giles to maintain a Stormwater Pollution Prevention Plan even it No
Exposure applies.
Yes No NA NE
0000
Page: 2

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Scale: 1 inch = 2,000 ft. Horizontal Datum: NAD27
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SCALE 1:24000
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GILES CHEMICALS
WAYNESVILLE, NC
FIGURE 1 JOB NO. 1136-002

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FIGURE 2
GILES CHEMICALS - AERIAL MAP
1

SCALE 1:24000 SITE LOCATION MAP
GILES CHEMICALS
1000 2000 3000 4000 5000 6000 700
- - -� -=r -� WAYNESVILLE, NC
FEET 1 FIGURE 1 JOB NO. 1136-002

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meters: 200
FIGURE 2
GILES CHEMICALS - AERIAL MAP