NCG170243_Complete File - Historical_20000601

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Glen Raven Technical Fabrics GLEN RAVEN®
T�t/ �iuuveis�try
Proud of the Past.Focused on the Future.
June 12, 2006
NCDENR JUN 15 2006
Aquifer Protection Section
2090 U.S. Highway 70
Swannanoa, NC 28778 3h,
Attn: Landon Davidson
Dear Mr. Davidson,
I have attached the documentation of an oil spill that occurred at our facility on
November 21, 2001. Kay Laws (Safety&Environmental Director)reported the spill to
NCDENR on November 21, 2001 at 9:50am. She talked with Wanda Frazier. Remedial
action was taken immediately.
Should you have any questions, please do not hesitate to contact me at 828-678-3016 or
via email at bpeterson Oenraven.com.
Sincerely,
B an Peterson
HR Manager
Glen Raven Technical Fabrics,LLC
73 East, 19E
Burnsville,NC 27814
Telephone [phone]
Fax [phone]
www.glenraven.com

EVENTS OF 11/21/01 AT GLEN RAVEN BURNSVILLE,N.0
#2 Fuel Oil Spill
00a Kevin Souther(Technical Safety Trainer)and Marie Nicholson(Training
Manager), called Bryan Peterson(Human Resource Manager)and informed him that
a#2 fuel oil spill had occurred.They immediately began efforts to contain the liquid.
We called our entire maintenance shop staff to help and sent one guy to buy all the oil
dry he could find.
• 8s00aM Kay Laws(Safety&Environmental Manager)was contacted when she
arrived at the office. She immediately went to help with the contai nmept effort.
® 9•.43am Kay called State Emergency Management(800)858-0366 to report the spill
9c50am Kay called NCDENR(828)251-6208 and reported the spill.Talked with
Wanda Frazier.
® :0 a Kay called the National Response Center(800)424-8802 to report the spi1L
(Incident Report#586603)Talked with John Flach.
CaL,olina Tank Lines,Ing was contacted and they sent their Safety Director our site,
for his:evaluation'of the spill.
O Corporation was called to clean up the spill.

#2 RW Oil Spill
Data; 1 i121/01
T1=:' 7:30 AM
Driver: C3ar7R.'OVetister
OR.AUendant: Kevin Souther and Made Nicholson.
Amount spilled: 60 gallons.
SuaMMMY:' On November 02,201 approxitnately'1%to 2 gallons of 02 fW oil•,
Was spilled when the driver unhooked lines from a now jx=p that had
Poe n irist$lled on tanker and was installed barkwa*.On November
.210 2001 the same driver d+aliverad anothet tanker of oil too our'facility
and did not wAze that the pump had not been fixed until he had
hoolmd,lines up and tried to pump ail out of tankar into Glen Raven's
fuel oil tank Wh6n driver started to pump the oil,ft lino Burst and
gTWxinnatol'y 60 gallons of#2 fuel off spilled onto the.pavement In toe
Fast End parldng lot.The oil migrated to down-gmdibnt stoi n dirain
and'appmhustply 2 0 3 gallons eatsiod the crook ftvuo the stone
&Wn.Ababibent was.Bused to promt mores 114Wd fmm migrating away
frnnn the'spill area.Down,gtadient storm ftins were sealed of with
magnet mats.The trucking company,Carolina Tmkinig,was uodfied
of the incident and their Safety Dirciotc►r gme on site+to assess spill and ;
arrwgeolaanup;'NHO Corporation wad balled to clean up the oil'spiL

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OF W ATF9 Michael F. Easley, Governor
C� Q7
r William G. Ross Jr., Secretary
p q North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Surface Water Protection Section
I
To: Bryan Peterson
Fax: [phone]
Through: Roy Davis- �
From: Wanda Frazier U
Re: Incident Information Request
Date: February 24, 2005
Per your request, I searched the incident files and found the letter that
Ms. Kay Laws mailed to the Division regarding the June 13, 2000 incident. I also
found the hand written message that one of our former Division employees, Mr.
Max Haner, made when he took the call from Ms. Laws on June 13, 2000.
Mr. Haner gave the note to me and I followed up by calling Ms. Laws.
I made notes to the effect that the discharge was probably from sizing leaking into
a storm drain at the outfall #001 .
In addition, I searched the incident files for information regarding an incident
that you said occurred on November 21 , 2001 . I was not able to find anything that
was reported to the Division on that date. You indicated that the incident was an
oil spill and was reported to the National Response Center. I understand that you
were able to obtain that information from their database.
If I can be of further help, please do not hesitate to contact me at 828-296-
4500 x 4662. Thank you for calling and following up on these incidents.
NorthCarolina
Natura!!f
North Carolina Division of Water Quality—Surface Water Protection Section
Asheville Regional Office -2090 U.S. Highway 70; Swannanoa, NC 28778
Customer Service 1-877-623-6748 Internet: h2o.enr.state.nc.us
An Equal Opportunity / Affirmative Action Employer
50% Recycled / 10% Post Consumer Paper

I
Warren Higgins Complaint
Glen Raven Mills
Yancey County
Notes to the file:
I received a note from Landon Davidson on June 7 (-2:40 pm) regarding a phone call from Tyler
Amon. Tyler is with the EPA CID (Criminal Investigation Division) out of Charlotte, NC (704-
344-6843). He wanted to discuss the Warren Higgins / Glen Raven Mills (Yancey County)
complaint.
Landon faxed him the info that he had regarding the complaint. I read what was faxed and
made a copy for SWPS files.
I called Tyler four times and was able to speak with him on 6/8 @ 11:07 pm. We discussed the
details of the complaint. He concluded that CID would not be pursuing it further, primarily due to
the statute of limitations ( this occurred five years ago), as well as other factors. I concurred
with his assessment and offered my observations and comments.
Tyler said that he would fax me his correspondence regarding this complaint.
Wanda Frazier
June 8, 2005

State of North Carol!ha
Department of Environment
and Natural Resources
Asheville Regional Cffice
� 2090 U. S. Highway 70 NCDENR'
Swannanoa, NC 28778
Telephone: [phone] NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RE SOURCES
FAX Number: [phone] .
FAX Transmittal
Date:
To:
From: L__ P N��.� �1 � ,� sQs C2 q {(0 �
Number of Pages (including cover page):
0 A ;V al Ca rl
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JuI 07 2004 10: 13AM NESBITT BIDWELL POISSON C 828 252-0511 P. 1
DAB A. CRAFT
ATTORNU AT LAW
29 North Market Succe,Svite 700
Asheville,North Carolina 28801
Lkcnwd in North Carolina Offii= i828125Z-D490
and District of Columbia Facsimik. [phone]
Email: [e-mail]
FACSIMILE COVER SHEET
FROM; ZWI//Z
DATE. Q�
COMMENTS:
The contents of the following transmission are considered confidential between
the sender and the desired recipient. If you have receive this facsimile in error,
please notify the sender at the telephone number listed on this cover sheet.
Thank you.

Jul 07 2004 10: 13AM NESBITT BIDWELL POISSON C 828 252-0511 p.2
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June 1.6,2000
9Mt2'IFl?,_ MAI
REMIJ-HEC"XIM UQUYSTER
7000.0600 00212662 547g,
Ms.Waztda.l~razier .
NCDE II Division of Water Quality
Ashcvr'lle.Regioual office
59 WoodfxnPlace
Asheville,North Carolina 28801 2482
l_tE: Reporting ofNenceliapifance
-Relea:se '&Sewage to Stormwater System
StO rmwatcr Permit Na.NCG170243
Glen Raven IVIM,Ina.-Burnsville,North Garoiiaa
Dear Ms.Frazier:•
1n accordance with candition E.8 of the current stormwater permit(Permit Number NCG 170243)for
the Glen Raven Mills, Iae. Burnsville,North Catalina facility,this letter is being provided as written
documentation of an incident of aoncomplianee at our facility. This release was verbally reparted to
You on lone 13,2000 at 2:15-PM.
On Tuesday,June-13.2000,at approximstely 0:30 AM,a non^stormwater discharge-was identified
in Outfall 001 at our facility. Based on our inspection of the discharge, it was determined to most
likely be wastewater from our facility, containing swvage and waste process waxer. our initial
suspicion was that,a sewage line from the facility had broken,resuftYng in the release of the untreated
wastewater. Based an additional investigations, this was conf fed- The sewer line leaked•into what
was previously a septic lank that tli�line crosses through. The wastewater then discharged•from the
line.and tank and eventually discharged to the swrm sewer system.
The discharge_began at some time prior to 10:30 AM and was stopped shortly thet_aft'er when the
Pump used to discharge the wastewater was shut off. The sewage line was uncovered on Tuesday,
June 13, 2000, and repairs commenced at the time. Repairs to the line have been•completed.
Replacement of the line should prevent any future discharges. In addition, the old septic tank is
being pui3tped out,the contents properly disposed, and the tank and its discharge line filled. _•
If you have any questions regarding this incident,please call me at(828) 682-2142.
Sincerely,
GLEN RAVEN iV LS,INC.
Kay Laws. ".
Safety 4&tnvironmental birector
Filament Fabrics Division.
�: ,David Cats

Jul 07 2004 10: 13AM NESBITT BIDWELL POISSON C 020 252—OS11 P.3
Hill
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_v. 3luefleCd. Er�gineerinr,3,. PAC: PO:.BOX r460 NC z r
_PHONE 91"4-8536
' FAX [phone]o
June 1.5,2000
F!.FED.BRA.L ZYPRFESS
PRIOR lyDVERI-1 GRT DHLB-1BRy
Me.K&Y Laws
safety&EnviwmE= l Director
Gl=Raven M ls,Tug.
Flighway 19E
I uawille,North Carolina 28714
RE: Reporting of Sewage Release
De�c'ZiTay:
AUMc114 please find a letter for you to send to the NCDENR regarding the release of
wastewater to the stOrmwatm SY9=that was identified on Tuesday,June 13,2000_ The
stn=water permit for your facility requires the written reporting of the release to the
NCDENR within five (5) days of the time you become awaae of the incident. You need
to do the following with the attached Iettec:
l. Print or copy the letter on your letterhead_
2. sign the letter. '
3. Send the letter via certified sail to the Asheville Regional Office of the NCDENR.at
the address indicated no later than Friday,June 16.
4. Keep a copy of the letter in your files.
rf you have any questions regarding the reportingrequirements, please call me at (919)
484-8536.
Smewely,
BENSINGER& GARRSSON EN -jRONi4tEi-TTAL,INC.
Tim A.Haas n,P.E.
Environmental Engineer
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GtQa Ravers�OwwvsMaI GawrrAt 03misawapp relexxa rVw trr

Jul 07 2004 10: 14AM NESBITT BIDWELL POISSON C 020 252-0511 p.4
%=i=our was©ns 4920 00 PiNEY=ROAD•0QIARLOTTE,NC 22217•(704)8Z7-1293•FAX[phone]`
n V I C CJ rT m r_ n Y t
November 6,2000 � l
Ms.Kay Laws
Glen Raven Filament Fabrics,LLC
Highway 19 East
P.O.Drawer 100
Burnsville,NC 28714
P. 828-682-2142 F. 828-682-9 10
RE: Sludge Removal Services
Burnsville,North Carolina
Proposal No. IHO.3580
Dear Ms. Laws:
Four Seasons Environmental, Inc. (Four Seasons)is pleased to submit this proposal to Glen Raven
for the above-referenced services to be performed at the Glen Raven,facility in Burnsville, North
Carolina. This proposal is bused upon information provided by Glen Raven and a recent site
inspection performed by Paul Oxendine. Our experience with similar projects enables us to meet
your goals and objectives in a professional manlier while maintaining a fxinely schedule.
SCOPE OF WQRK
Four Seasons understands that Glen Raven requires sludge removal services from a 12,000-gallon
capacity septic system. The system is composed of(4) four compadmerrts that contain thick sludge
composed of non-hazardous dirt, yam, wastewater and process materials. There is an estimated
5,0004gallons of material that rennin in the system that requires removal. The material is too thick
to be pumped utilizing ar standard vacuum.truck. A supersucker type vacuum track must be used to
corriplete pumping operations due to the nature of the sludge. Access to the system is good and
there is adequate room to temporarily stage(2)two vacuum boxes.
The material must be placed into vacuum boxes for-transportation to the disposal facility. The
weight of the suupersulcker truck does not allow for truck9s;weight. hauling very much material because of the
In order to meet Glen Raven's cleaning objectives,Four Seasons proposes the following activities:
Remove pumpable sludge fxom the pit using asupersucker vacuum truck.
o Offload the material into vacuum boxes.
• Transport the material offsite in the vacuum boxes.
• Tramport residual liquid, sludge and rinseate to Four Seasons' facility im Charlotte, North
Carolina for disposal. Waters will be treated in the bulk industrial wastewater hvaiment system
and sludges/solids will be entered into Four Seasons'bulls solidification program.
�� CORPORATE HEADQUAR7ERS; 9413 APISON PUCE.5URE 200 • MLTEWAH,IN 37363 • (4Y3)396-41 OD • 'FAX('423)396-4198

Jul 07 2004 10: 14AM NESBITT BIDWELL POISSON C 820 252-0511 P. 5
. ''YkY_•%3i-;:Fie' •. .. _ 1
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• Additional project work not specifically addressed by this proposal shall be charged at a time
and'matezials rate.Any additional work, if required, shall be authorized by Glen Raven prior to
initiation.
All Projects perfoxn>ed by Four Seasons are executed in compliance with oSHA,hazardous Waste
Operations and Emergency Response regulations, 29 Cn 1910.120.Four Seasons has a complete
safety,Ong,drug screening and medical monitoring program covering all field personnel.
Four Seasons appreciates the opportunity to provide this proposal. If you wish to accept the
proposal.,please indicate your acceptance,subject to the terms and conditions printed on the reverse,
with an authorize signature in the space provided. Return via facsimile to [phone]. If you
leave any Questions or if we may be of assistance„feel free to call us at(704)527-1293 or(800)782-
0263.Thank you for considering Four Seasons.
Sincerely, Client Acceptance
Sally Johnson
Manager,Charlotte Facility si e/date
ftinted Warne
Carrie J.Reavis � ,
Project Development Manager title L�r root/ i' ry�

Jul 07 2004 10: 14RM NESBITT BIDWELL POISSON C 828 252-0511 P. 6
Glen
190 3580
November6,2000
Page 2
PRICING SUMMARY
Four Seasons shall provide mobilization, labor and equipment to perform work as specified herein,
excluding vacuum boxes and disposal,for the following price:
Mobilization............................................................................. .$800.00%vent
Price......................................................................................................$2,640.00/day
(estimate 1 day)
Four Seasons sball provide vacuum boxes as specified herein for the following unit prices:
•Vacuum Box Delivery.............................................................................$825.00
(may deliver two empty boxes for one price)
Vacuum Box Rental.......................................................................:..........$60.00/box/day
(estimate 2-3 days)
Vacuum Box Transportation................................................................$1,285.100/box
(estimate 2 boxes)
Total Estimated Job Cost(excluding disposal)............................................$7,075.00
Four Seasons shall provide disposal of nonhazardous residual product, rinsewater, and any
associated sludge or solid material, for the following unit prices:
Nan hazardous Liquids. ............................................................. .............$0.35/gallon
(estimate 1,250-gallons*)
Non-hazardous Sludge,Solids....................................................................$0.85/gallon
(estimate 3,750-gallons*)
*estimates based on sludge containing 25°'a water,figure used for budgeting purposes only.
Total Job Estimate(includes estimated disposal).................................$10,700.00
ASSUMPTIONS
Four Seasons bas made the following assumptions in developing this proposal:
• The pricing presented herein is valid for 60 days from the date of this proposal.
• Customer shall reimburse Four Seasons its reasonable expenses and charges for handling,
analyzing, loading, preparing, transporting, storing or caring for nonconforming or off spec
waste,including costs of decontamination and cleaning of equipment.
• Advanced project planning time will be required due to vendor management of various
equipment and personnel.
• The client shall provide a water source in the vicinity of the work area.
• Unless otherwise indicated,prices provided are based.on performing work on a weekday, non-
holiday during normal working hours (8.00 AM to 5:00 PM).

Jul 07 2004 10: 15AM NESBITT BIDWELL POISSON C 820 252-0511 p. 7
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Jul 07 2004 10: I5RM NESBITT BIDWELL POISSON C 826 252-0511 p. 8
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•P, O. BOX 1-9198, CHARLOTr , N. C. 28219
TEL [phone]
FAX"#:704 394-6382
Client Glen Raven Mills Client Number: 3432
P O BOX 100 Work Order: 2009-M
Burnsville,NC 28714-0100 Sample Data: 06-21-00
Attu: Kay Laws Report Date: 06.26-40
Certifkate of Anilysis
#1 #2
Tutai Petroleum
Hydrocarbons 0101 % 9.95%(Petmieum-Based
QiI&}
heavy Mpg ports per million(ppm)
Aisenic <05 <,05
Barium <.I 0 <110
Cadmium <.05 <.05
Cluo"tim <.05 <.05
Lcad .11 2.40
Melmug <.10 <.10
Seicaium <.05 <.OS
Myer <.05 <.n5
Volatile Oraaanic Compounds
(1hcrgeables:GUM) putts per million(ppm)
B=z=c: <,Oiu <.010
Bmmadichloromedwe <.010 <.010 � 1 C
Bromoform. , <.U10 <,010
Sromamethaae <.010
Carbon Tctrarhloride <.010 z.010
Clilorobe=ne <.010 <.010
chlomethane <.0 10 <.010
2-01himeUryl Vinyl Ether <.U10 <•010 r, �(2 ~' 'l
CI1larofOrm <.O 10 <.010 o ' �
CIilprometE;ane <.010 <.014
Dibromocll[onornethane <.010 <.010 1,00
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1,1-Dicilloroetl <010 <.014
1,2-Dichloroethaue <.010 <,010
cis-1,1-Dichloroethane <.010 <.010
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Jul 07 2004 10: 16RK NESBITT BIDWELL POISSON C 820 252-0511 p.9
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water was observed leaking from an air washerichiller located an the roofof the
.facility. The water was draining to the gutter and into the stormwater. system It is
not kmawn whether the watercontained any treatment chemicals. Photo ml
Recommandatf6n` msure that chillers are in ¢ood repair. rf treattnent
clletnicals are present in-chiller water, the potential release should be considered
. in the MCC P laatt
�r 1 ,f"'.�
s' tal discrarpng to Ray Creek.
Rec0mn:4rr&zdi2rr,* Determine all points of entry for this outfall and make
corrections as needed- Photo ii'!
IT16.',1 The used oil regulations require all tanks and containers used to store used oil be
labeled witE the words "Used Oil"• rat: facility, has an oiliwater separator that
collects used oil from wastewater. The oilrwa.[mr separator qualifies as a tank or
container,but is not labeled. '
Reconmendarion: Mark the oil/water separator with the wards"Used Oil."
,,•) 4 ,��.�,P ��-$ P 01 4& a Pam;
1-13 A groundwater supply.well is located at the facility near U.S. Highway 19. The
well is no longer being used as a.water source.
Recommendation: Because groundwater wells can a= as conduits for the
migration of contarriinants to gioundmarer, the facility: should consider closing the
well in accordance with North Carolina sta•ldards_
rz —
JL �
r?r l;[IC2r3 'Were obse:veed On d1G�GIIiD:=SSoIS. tIlt.:S are :lot properly drained'. then.
are �onsi(lZ,L-d 3 used oii waste. .
Rtcorlmendauon: Ensure that=tltars ara properly drained;prior to disposal.
r:t`: Containers were seen throughout the facili:v bearing slipping labels idenii v ilg•••
Glen Raven Mils. V111ile itis is in no way a regulatory or compliance problem_
the facility should be aware thm responsible games, for the contaminated sites
e rs lanea,lls) are ortzn idenwie^ and iocmed b4 container; bearing these tapes of'....
labels.
Re­_ot7tm-lendstion, 'The facility mould consider rerncvina all labels identit-;11411Z
Glen Raven, Mills from em=v containers berore then are•gel t off site for disposal.
i Open slots in breaker, box. utility: room next to,. otz;ce manage: s of-ice. �.letal
ladder at same locatiop poses shock•risk if used around electrical components.
Photo
?3 Gate opdn to transformer ring behind plahc. Photo 5
f' "— Blade guard on table sau in Shop held back by nylon ties_ Photo ,=6'

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JY� ' JUN 10 2005
WATER OUAUTY SECTION
U.S. ENVIRONMENTAL PROTECTION AG N .`f�eCIaNA�OFFICE
J s OFFICE OF CRIMINAL ENFORCEMENT
CRIMINAL INVESTIGATION DIVISION
u- w CHARLOTTE RESIDENT OFFICE
z?i Q 521 East Morehead Street
per' Suite 420
� P 0���' Charlotte, NC 28202 ,
R Telephone [phone]
Fax[phone]
June 8, 2005
VIA US MAIL
Ms. Wanda Fraser '
North Carolina Department of Environment and Natural Resources
Surface Water Protection
2090 US Highway 70
Swannanoa, NC 28778
RE: EPA CID Lead 0408-A744, Glen Raven Mills
Dear. Ms. Fraser,
Per our discussion this morning concerning Glen Raven Mills and allegations
furnished by Hershel Warren Higgins, Jr., a letter addressed to the U.S. Department of
Labor is enclosed. Based upon an initial review, this office will not be pursuing a
criminal investigation at this time.
have also mailed a copy of this letter to Mary Wilk, U.S. EPA Region IV
Environmental Accountability Division, for her review.
Sincer y,
I
Tyler . Amon
Special Agen
cc. Case file (letter only)
Mary Wilk, EPA RIV
Richard Glaze, EPA RIV
CID Form CID.3FX

U.S.DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
Atlanta Area Office
61 Forsyth Street,SW
Atlanta,Georgia 30303
� d
FED 14 2005
William D. Anderson
U.S. Environmental Protection Agency
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SW 13th Floor "
Atlanta, GA 30303
Re: Glen Raven Mills, Inc./Higgins
Case#4-5070-05-014
EPA Whistleblower Complaint
Dear Mr. Anderson:
The above-referenced matter is a complaint of discrimination under the Compensation, and Liability Act,42 U.S.0 9610;
Section 507(a) of the Federal Water Pollution Control Act, 33 U.S.0 1367; Section 1450(i)(1)(A-C) of the Safe Drinking
Water Act,42 U.S.0 300j-9; Section 7001(a)of the Solid Waste Disposal Act,42 U.S.0 6971discrimination under
Enclosed is a copy of the complaint in the above-captioned matter for your information and assistance.
Complainant and Respondent are being notified of the investigative procedures of this office under separate
cover.
If I can be of further assistance to you,please do not hesitate to contact me.
Sincerely,
s , erdlta
Acting Regional Supervisory Investigator
Enclosure

To: Billy Bright U.S. Dept. of Labor OSHA From: Warren Higgins Jr.
24 Ashlynn Lane
Burnsville N.C.
28714
(828)-682-2727
Until July 2nd 2004 I Warren Higgins had worked for Glen Raven Nulls for nearly 25
years.My job title was Plant Engineer. My responsibilities included building maint.
electrical installations and repairs, machine maint, and installations, plumbing etc.
In April of this year several positions at Glen Raven was eliminated, including the safety
and environmental director;a few days later Brian Peterson(personnel mgr.) brought the
environmental files and records out to.my office and told me that management had decided
to give the responsibility of environmental record keeping and reporting to me. I told
Brian Peterson that I didn't have any experience or training in filling out reports, he told
me that other parts of the Safety and Environmental directors job had been given to other
people in the plant and this job had to be covered.
I started going through the environmental records to try to determine what I was
suppose to do. I found a copy of a report to the NCDENR that had been filed back in
2000(copy attached)this report had been falsified it was reported as if this release had
been found and corrected in a short period of time, this is not true, the septic tank
contained lead, zinc and a high content of oil(lab report included). The report to the
NCDENR is dated 6-16-00 samples from the septic tank were taken a few days later on
6-21-00 and on 8-9-00. The report to the NCDENR stated that the release contained
sewage and waste water. It was not known at the time of the report to the NCDENR what
the contents of the septic tank were except for the oil that was visible inside the tank. I
a�:i�!e. n�cm fro��e=�+ es�tc+�' ►��C' cs�tie�++�a�s�#�� ��d,,tiie
other was written up as a cloudy liquid sited in Ray Creek by David Cates(Corporate
Safety and Environmental Director). These releases were not reported at all. Their was a
lot of other information in these files that clearly indicated that the responsibility of this job
was to falsify reports in the event of a release or cover it up by not reporting it at all. I
found letters and fax messages that indicated that consultants had been used to cover up
the release.involving the septic tank.
I talked to Brian Peterson on several occasions about the files and the report to the
NCDENR he copied the report and told me that he would talk to David Cates about it.
After several days with no response from Brian I copied the report and other information
from the files, I then called the North Carolina Bar Association and ask them to
recommend a lawyer in my area that knew about environmental regulations, they
recommended David Craft in Asheville N.C.
I took the files to him and discussed the situation with him, he told me that if I accepted
this responsibility that I could be held responsible for not reporting what I had found in
these files. David Craft recommended that I write a letter to management and explain what
I had found.
After thinking about this for sometime I decided not to write a letter, because it was
clear that management already knew about the falsified report and the other releases to

Ray Creek. I went to my supervisor and requested a meeting with David Cates he told me
that the next time David was up here he would see that I got to talk to him
On July 1 st 2004 Nelson Silvers told me that we would meet with David that afternoon.
Nelson Silvers, David Cates, Brian Peterson,Rodney Deyton and myself attended this
meeting. We discussed the report on the release that involved the septic tank and the lab
reports from the samples taken from the septic tank that had not been reported. I asked
Brian Peterson about the fuel oil spill on the east end of the plant, he said that it did enter
Ray Creek and they had used straw to try to get it off the water. When he was ask if it was
reported he said that they had called the Coast Guard. I ask about the local emergency
response and Tierl 1 reporting I told them that there was no record on file that indicated
that anything had ever been reported to them.
David Cates told me that we needed to start over fresh on this and that he would send
me some information on reporting and that.he would help me with the reports. I ask David.
how I could start over fresh when I believed that the ground around the septic tank was
most likely contaminated. I told him that the report stated that the release had come from
a broken sewer line, but everyone in the room knew that the release come from a partially
blocked sewer line in a man hole inside the plant and that it was obvious that waste from
the plant had been going into Ray Creek from the time that the septic tank was abandoned
and the waste water connection was made to the city sewer. I told him that I thought the
people in the community had a right to know about this,I told him and Nelson Silvers that
I was not taking on this responsibility even if they fired me. Nelson said we need to talk
with Randy Blackston(plant mgr.)tomorrow, the meeting ended.
July 2nd 2004 my mother called and said she was sick and needed to go to the doctor. I
called in to the plant and talked to Rodney Deyton, I told him to tell Nelson that I would
be late. I arrived at the plant at approximately 10:00 am. Nelson Silvers came into my
office and told me that he had.already met with Randy Blackston and he had said that the
r=0V4jCe4*Ug:and:fiulling:att&�rave�ec�s �tss d�hcc�nq�spa��dit�; told
Nelson that I had not changed my mind that I was not going to take the responsibility that
required me to violate laws and peoples rights. Nelson said I guess we need to go talk
with Mr. Blackston I took the files with me that we had discussed the day before. When
we arrived at Randy's office he ask what the problem was.Nelson told him that I had
problems with the environmental reports and records. I told Randy that I was refusing to
take over this responsibility Randy looked at the files for a few minutes and said that this
didn't happen under his management and as far as he was concerned the case was closed
and that I would be keeping the environmental records,reporting and what ever was
necessary for plant operation. I told Randy that if this was his final decision the only thing
I knew to do was to report what was in the files. Randy then told me that he was going to
fire me but he wanted to tell me a few things first, he started telling me that I didn't want
to work for Glen Raven and that I didn't want to be on the Glen Raven team, this went on
and on,to make a long story short on July 2nd 2004 Randy Blackston fired me.
Complaint:
On July 2nd 2004 I was fired because I refused to violate the law.
I refused to take the responsibility's of Environmental Coordinator because I believe that a
hazard to the public and the environment still exists.

1-25-05
Warren Higgins

�'HU ,11 :42 AM WRAY WARD LASETER FAX N0, 7043755971 P. 01 '
'Wray Ward Laseter -
- Fax Transmittal
CONFMENTIAL
Date: June 15,2000
To: Kay Laws
Amanda.Williams
Company: Glen Raven
Pax Number: 828/682-4911
336/586-1163
Prom: Heather Tamol
Our Fax Number: 704/375-5971
Total number of pages including this cover sheet: 2
Message:
Kay and Amanda,
I am attaching a brie€ 8 skeet t naught prgve helpful in,aswering questions or in.
J g9„ �r.'�ax« x 4t '- -WTu '6u=Lrfz r3,*per
Pp o iate.s ion€ sj eQple`on ex its=a F�laiileii# abrics. .As you learn more,
you can update appropriately. This is only a precaution, as some curiosities might be
aroused by the activity around the facility.
Clearly,the inspection system works,and this is an example of Glen Raven's safety and
environmental activities at work.
Amanda-Kay told me that any phone calls to the plant would be directed to .., =.tt
dt ,,,L end,if necessary,he would ask Kay for her assistance. Kay—please call
Amanda or me if you have any questions.
Thank you.

fHU 11 :43 AM WRAY WARD LASETER F,!X NO. 7043755971 P. 02
22
� J
Glen Raven Filament Fabrics
Q&A,June 2000
What happened at Filament Fabrics?
Filament Fabrics conducts regular Storm Water Inspections, and this week's inspection
detected a very small leak on a lisle from one of the sump pumps. We immediately turned
the sump pump off and are in the process of replacing the line_ Our inspection did not
find any other leaks or problems.
What was leaking? Is this considered hazardous to the environment?
The line carries starches used for coating the yarns woven at the facility as well as
wastewater. The small leak occurred only when the sump pump was running,which is
not continuous.We found the leak quickly and immediately turned off the pump; we
don't believe this has harmed Ray Creek and Crabtree Creek,into which the crater
empties.
How are you repairing the damage?
The sump pump has been termed off to prevent leafage to the creeks, and we have tiled a
report with the State Regulatory Office explaining our course of action. We are replacing
the lime and were assured by the Office that we are following;proper procedures.
How does this reflect your environmental policy?
Glen Raven Filament Fabrics is.very committed to the environment and has been an
exvironmental steward in Burnsville_ Our Safety fir,Environmental Director conducts
safety and environmental audits at our facility every quarter. We also have annual audits
by our corporate Safoty&Environmental Director as well as an independent auditor to
assure that our activities are safe for our employees and the environment.
Our regular Storm Water Inspections are an example of how these audits work
successfully.

Bensinger. & Garrison
ENVIRONENTAL, INC.
Bluefield Engineering, R.C. P.O. BOX 14609 • RTP, NC27709
PHONE [phone]
FAX [phone]
June 15, 2000..
VIA FEDERAL EXPRESS
PRIORITY OVERNIGHT DELIVERY
Ms. Kay Laws
Safety&Environmental Director
Glen Raven Mills, Inc.
Highway 19E
Burnsville,North Carolina 28714
RE: Reporting of Sewage Release
Dear Kay:
Attached, please find a letter for you to send to the NCDENR regarding the release of
wastewater to the stormwater system that was identified on Tuesday, June 13, 2000. The
stormwater permit for your facility requires the written reporting of the release to the
NCDENR within five (5) days of the time you become aware of the incident. You need
to do the following with the attached letter:
1. Print or copy the letter on your letterhead.
2. Sign the letter.
3. Send the letter via certified mail to the Asheville Regional Office of the NCDENR at
the address indicated no later than Friday, June 16.
4. Keep a copy of the letter in your files.
If you have any questions regarding the reporting requirements, please call me at (919)
484-8536.
Sincerely,
BENSINGER& GARRISON ENVIRONMENTAL,INC. _.
Tim A. Hans n,P.E.
Environmental Engineer
TAH/gb
Attachment
cc: David Cates
Glen RavenlBurnsvillelGeneralll037961sewage release report Ur

;C.-H E M B A C 20og-00
I •R 0.BOX 19198•CWRLOTE,N.C.28219
TEL 394-Ml FAX:[phone] g
Client: 06-2.6-00
Glen Raven Mills Inc Date:
P 0 Box 100
Burnsville, NC 28714-0100
Attn: Kay Laws
Terms: 10 Days Net.
Client's No. I Chem-Sac No. _
DESCRIPTION Amount
(I/Client Numbez: 3432
Purchase Order:
Chem Bac 'Nark Order: 2009-00
Sam-le(s) Received: 05-21-00
sample ID: (2) 41 & (2) 42 Samples : Haz Matzls & Petrc Pro ucts
$1,700.00
91
INDEPENDENT LABORATORIES + CHEMISTS ® BACTERIOLOGISTS
TESTING INSPECTION s DEVELOPMENT QUALITY CONTROL �l

t
t H E 'M B A C Za&maou-w, lac.
• P. O. BOX 19198, CHARLOTTE, N. C. 28219
TEL.[phone]
FAX#:[phone]
Client: Glen Raven Mills Client Number: 3432
P O Box 100 Work Order: 2009-00
Burnsville,NC 28714-0100 Sample Date: 06-21-00
Attn: Kay.Laws Report Date: 06-26-00
Certificate of Analysis
#1 #2
Total Petroleum
Hydrocarbons 0.01 % 8.85%(Petroleum-Based
Oils)
Heavy Metals parts per million(ppm)
Arsenic <.05 <.05
Barium <.10 <.10
Cadmium <.05 <.05
Chromium <.05 <.05
Lead .11 2.40
Mercury <.10 <.10
Selenium <.05 <.05
Silver <.05 <.05
Volatile Organic Compounds
(Purgeables:GCFID) parts per million(ppm)
Benzene <.0i0 <.010
Bromodichloromethane <.010 <.010
Bromoform <.010 <,010
Bromomethane <.010 <.010
Carbon Tetrachloride <.010 <.010
Chlorobenzene <.010 <.010
Chloroethane <.010 <.010
2-Chloroethyl Vinyl Ether <.010 <.010
Chloroform <.010 <.010
Chloromethane <.010 <.010
Dibromochloromethane <.010 <.010
1,1-Dichloroethane <.010 <•010
1,2-Dicliloroethane <.010 <.010
cis-1,1-Dichloroethane <.010 <.010
INDEPENDENT LABORATORIES CHEMISTS • BACTERIOLOGISTS CONSULTANTS
TESTING • INSPECTION • DEVELOPMENT • QUALITY CONTROL

s.
AUK.- r0 FRL 1. 1. :' 2.6 C.1--EM B.AG t_ABS 2MC :P: 01 r ,
H Mw B A
•P. O, BOX 19198, CNARLOT T E, N, C, 28219
TEL [phone]
FAY.M.704 394.6382
Ccrriticatc of AjtalvsiS
Clicnt: Gicn Pavca Mills Client Number: 3432
P 0 Box 100 Work Order: 2306.00
Burnsville,NC 28?14-0100 Sample Onto: 08,49-00
Attn: ,Miranda Evans Report Date: 08-17-00
Chc nkal?+"Psis of Submitted Sample
Glca Raven Pnrchwe Order!#6003308
Piramete Result(Ppm) c�-- — ... .......
oil&crMse 3,714
PCB < 1.0
L--3d 29,6
Zino 4.2•7
Respectfully Sub►nittcd,
Chcm-Bac Laboratories. Inc
loscp C Hubbel
Supervising Chclt+.ist
111D8PEHDENT LA80RAT0RIfS C91MI3r3 3ACTIIA10L0g15T5 � CONSULTANTS
TESTING • INSPICT10N 9EYrL0P?AINT - QUALITY CONTROL ''

it
Ma'qg
+
F•
v +� ,fi i"Y szu j "�,:
i�^�:+a°'�r✓.'` �^h^-y"rv� ^ '4M�w"�'- x�'..r,,, i ,�...-ji.�`.� , ..,F��s'.� � '=
5.
S
afetu&.Environrmentai 4.udit
.August 9 ' :11, I999 :.
(�_ '' Water was observed le6d-nz from an air washerichiller located on the roof'of the
facility. The water was draining to the gutter and into the stormwater system. It is
not known whether the watercontained any treatment chemicals. Photo -I
Recornmendato17: Ensure that chillers are in good repair: If treatment
chemicals are present in chiller water, the potential release should be considered
- in the SP,CC Plan. tj
r� ­-1;oudvdischarQe from outfall discharging to Rav Creek.
Recormendation. Determine all points of entry for this outfall and make
corrections as needed. Photo r,2
t=6: TLe used oil regulations recuire all taiLks and containers used to store used oil be
labeled with the words "Used Oil". The facility has an oil/water separator that
collects used oil from wastewater. The oiUwater separator oualines as a rani; or
container, but is not labeled.
Recommendation: Marl: tnhee oiliwater, separatorrwinth the words "Used Oil."
F13 A groundwater supply well is located at the facility near U.S. Highway 19. The
well is no longer being used as a water source.
Recommendation: Because eroundwater wells can act as conduits for the
migration of Contaminants to zround,yater, the faCllit' should consider" closing the
well :n accordance with North Carolina standard.
�e
r.. r 1,a �r,,ec � c er - .mod.
I'ii�e S' '�'..: ObS.., on t,?? OTi1D:?SSOrS. att...a are IIoi DrOp�.;�' Q,cii.., they
are consld-r-d a usdd ol1 \Waste.
Recommendaticn: Ensure that filters are properly drained prior w disposal.
P i- Containers were seen throughout the facility bearing shipping labels identifying
Glen raven Mills. 'While this is in no way a regulatory or compliance problem.
¢,€ the facility should be aware that responsible aartles for the contaminated Sites
(e.g. landfills) are often identified and located by containers bearing these types of
labels.
Recommendation: The iaciiity should consider removinz all labels idenciiv1112
filer: Raven Mills from -m^ry contain-,- before they are se t off site for disposal.
i Open Slots in break---,- box. utdir roonn next w office manager'S oFliice. Metal
ladder at same location: ooses shock- `Issi; if used around -Iecmical components.
Photo_� _ „
Gate open to transformer area behind plant. Photo -
/?� Blade ward on table saw In Shop held back.by nylon ties. Photo --,','5

05
Complaint and Request for investigation
Re:Report to the NCDENR on June 16,2000.
PtioNe 72 7
Due to the fact that this falsified report was sent to Ms. Wanda Frazer with the
NCDENR,by Kay Laws, Safety and Environmental Director at Glen Raven Mills
Burnsville N.C. There was never an investigation by the NCDENR or any other authority
on the high content of lead, oil and zinc found in the septic tank a few day's after this
report was sent to the NCDENR. This(was not)reported to the local Emergency
Management people, the N.C. Emergency Response Commission or the NCDENR. This
release was not found and corrected in a short period of time as stated in the report. A
sewer line was found coming from a manhole inside the plant that went directly into the
septic tank, it was found that this line had never been sealed off. It was also determined
that there was a direct line(pipe)leaving the septic tank going into Ray Creek. It was also
found that an overflow had been installed in the east end sewage pumping station,this
pumping station had been installed sometime in 1984.
Reasons for investigation:
It is easy to determine that industrial waste and raw sewage has been going into Ray
Creek for a long time. The lab analysis on the samples taken from the septic tank on
8-9-2000 and sent to CBEM-BAC Lab indicated 3,714 PPM oil and grease 29.6 PPM
lead and 42.7 PPM zinc.
Most septic tanks has some kind of drain field, so most likely the ground around the septic
tank is contaminated. � V
El
Could there be more sewer lines going into Ray Creek or Crabtree Creek
DD
JA N 18 2005
Where did the lead, zinc and oil come from?
WATER QUALITY SECTION
What damage has been done to the environment? ^A`'HEVILLE REGIONAL OFEICE
I believe the environment and the people down stream from Glen Raven Mills are still at
risk.
I believe that the people in the Community has the right to know about this release,and
the fact that they were not informed.
I believe that the people has the right to know about other releases to Ray Creek from
Glen Raven Mills, one was described as a cloudy liquid sited by David Cates in August
1999 and another#2 fuel oil release that happened on 11-21-01.
I am furnishing the following information to substantiate my complaint and justification for
investigation.
Sec ATfac-kINAerJ4 Q

1.A Blue Print of Glen Raven Mills that indicates the location of the septic tank,Ray
Creek and the storm drains in that area.
2.Photographs that were taken when the source of the release was discovered,these
photographs show the east end sewage pumping station-the septic tank-the sewage
collection point(man hole)inside the plant and the pipes leading to Ray Creek.
3.Copy's of fax messages from Environmental Consultants that were used to provide
instructions on the handling of the release and preparing the letter of noncompliance sent
to.NCDENR-(Wanda Frazer)on June 16,2000,
4.Copy's of bills of laden from Four Seasons Environmental that states that the contents
of the septic tank was non-regulated and non RCRA hazardous.
5.Copy of a quote from Four Seasons Environmental for the removal and disposal of the
contents of the septic tank. This quote is for the removal of thick sludge composed of non
hazardous dirt yarn waste water and process materials. There is no evidence that they
were told about the lab reports that indicated 29.6 PPM LEAD AND 42.7 PPM zinc.
6.Copy of a quote from Palmetto Environmental, This quote states that Pahnetto
understands that the material contains metals but are below regulatory levels for UST'S.
7.Copy of an authorization to pay Palmetto Environmental,this authorization to pay is
written on an invoice and states that this was an environmental emergency.
8.Copy's of lab reports from CBEM BAC Lab. that states the lead, zinc and oil content of
the septic tank.
9.Copy of a report from David Cates that states he sited a cloudy liquid in Ray Creek.
IO.Information on the fuel oil release on 11-21-01
I LAn investigation would reveal that the pipes(sewer line) leaving the man hole inside
the plant going into the septic tank and leaving the septic tank going directly to Ray Creek
are still in the ground and could act as conduits to Ray Creek for existing or future
ground water contamination.
12.An investigation would reveal that several thousand sq. ft. of pavement was replaced in
the east end parking lot because it was saturated with#2 fuel oil to the point that it was
coming apart. This came from the#2 fuel oil release on 11-21-01 there are two storm
drains inside the area where the pavement was replaced that goes directly to Ray Creek.
After reviewing this information I hope you will agree that this situation warrants quick
attention and a through investigation Warren Higgins

�N.
_. 1.
June 16, 2000
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7000 0600 0021 2662 5474
Ms.Wanda Frazier
NCDENR.Division of Water Quality
Asheville Regional Office
59 Woodfin Place
Asheville,North Carolina 28.801-2482
RE: Reporting of Noncompliance
Release of Sewage to Stormwater System
Stormwater Permit No. NCG170243
Glen Raven Mills,Inc.. Burnsville,North Carolina
Dear Ms. Frazier,
In accordance with condition E.8 of the current stormwater permit(Permit Number NCG 170243) for
the Glen Raven Mills, Inc. Burnsville, North Carolina facility, this letter is being provided as written
documentation of an incident of noncompliance at our facility. This release was verbally reported to
you on June 13, 2000 at 2:15 PM.
On Tuesday, June 13, 2000, at approximately 10:30 AM, a non-stormwater discharge was identified
in Outfall 001 at our facility. Based on our inspection of the discharge, it was determined to most
likely be wastewater from our facility, containing sewage and waste process water. Our initial
suspicion was that.a sewage line from the facility had broken, resulting in the release of the untreated
wastewater. Based on additional investigations, this was confirmed. The sewer line leaked into what
was previously a septic tank that the line crosses through. The wastewater then discharged from the
line and tank and eventually discharged to the storm sewer system.
-The discharge began at some time prior to 10:30 AM and was stopped shortly thereafter when`the
pump used to discharge the wastewater was shut off. The sewage line was uncovered on Tuesday,
June 13, 2000, and repairs commenced at the time. Repairs to the line have been completed.
Replacement of the line should prevent any future discharges. In addition, the old septic tank is
being pumped out, the contents properly disposed, and the tank and its discharge line filled.
If you have any questions regarding this incident, please call me at(828) 682-2142.
Sincerely,
GLEN RAVEN MILLS, INC.
Kay Laws
Safety & Environmental Director
Filament Fabrics Division
cc David Cates ,

r
GLEN RAVEN MILLS, INC.
o
FILAMENT FAsxic!i DWISION • P.O. Drzat _
BuRNSviLLL, N.C. 28714 6'1'1ccX °t
[phone] • FAX(704)682 Lt(,Q-)5 .115 L
s
:3 -(, VA ,,nn�
l
lie V1�J
June 16, 2000
CERTIFIEI --
RETURN RECEIP'
7000 0600 0021
lY
Ms. Wanda Frazier
NCDENR Division of Water Quality
Asheville Regional Office _--
59 Woodfin Place
Asheville,North Carolina 28801-2482
RE; Reporting of Noncompliance (�
Release of Sewage to Stormwater System 0
III
Stormwater Permit No.NCG170243 .
Glen Raven Mills,Inc.-Burnsville,North Carolina
Dear Ms. Frazier:
In accordance with condition E.8 of the current stormwater permit p (P
the Glen Raven Mills, Inc. Burnsville, North Carolina facility, this b
documentation of an incident of noncompliance at our facility. This. l
you on June 13, 2000 at 2:15 PM.
On Tuesday, June 13, 2000, at approximately 10:30 AM, a non-stormwater discharge was identified
in Outfall 001 at our facility. Based on our inspection of the discharge, it was determined to most
likely be wastewater from our facility, containing sewage and waste process water. Our initial
suspicion was that a sewage line from the facility had broken, resulting in the release of the untreated
wastewater. Based on additional investigations,this was confirmed. The sewer line leaked into what
was previously a septic tank that the line crosses through. The wastewater then discharged from the
line and tank and eventually discharged to the storm sewer system.
The discharge began at some time prior to 10:30 AM and was stopped shortly thereafter when the
pump used to discharge the wastewater was shut off. The sewage line was uncovered on Tuesday,
June 13, 2000, and repairs commenced at the time. Repairs to the line have been completed.
Replacement of the line should prevent any future discharges. In addition, the old septic tank is
being pumped out,the contents properly disposed, and the tank and its discharge line filled.
If you have any questions regarding this incident, please call me at(828) 682-2142.
Sincerely,
GLEN RAVEN MILLS,INC.
(; z
KayTaws l 9 2000
SUN
Safety&Environmental Director
Filament Fabrics Division �
„M1 pit"��VfLtl�[�11,10i (1�ies
CC. David Cates
QUALITY TEXTILE PRODUCTS . . . CRAFTED WITH PRIDE IN THE U.S.A.
1

SENDING CONFIRMATION
DATE FEB-24-2005 THU 17:05
NAME WAT
TEL [phone]
PHONE : [phone]
PAGES : 2/2
START TIME : FEB-24 17:03
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�p�•WnTFR Michael F.Easley,Governor
William G.Rose Jr.,Secretary
-t North Carolina Department of Enviromnant and Natural Resourcos
Alan W.Klimek,P.E.Director
Division of water Quality
Surface Water Protection Section
"i o: Bryan Peterson
Fax: [phone]
Through: Roy Daviss��
From: Wanda Frazier
Re: Incident Information Request
Date: February 24,2005
Per your request,I searched the incident files and found the letter that
Ms.Kay Laws mailed to the Division regarding the June 13,2000 incident. I also
found the hand written message that one of our former Division employees,Mr,
Max Haner,made when he took the call from Ms.Laws on June 13,2000.
Mr.Haner gave the note to me and I followed up by calling Ms.Laws.
I made notes to the effect that the discharge was probably from sizing leaking into
a storm drain at the ouffall#001.
In addition,I searched the incident files for information regarding an incident
that you said occurred on November 21,2001. 1 was not able.to find anything that
was reported to the Division on that date. You indicated that the incident was an j
oil spill and was reported to the National Response Center. I understand that you
were able to obtain that information from their database.
If I can be of further help,please do not hesitate to contact me at 828-296-
4500 x 4662. Thank you for calling and fallowing up on these incidents.
I
No�hCuroma
atuea�l�
North Carolina Division of Water Quality—Surface Water Protection Section
Asheville Regional Office-2090 U.S.Highway 70;Swannanea,NC 28778
Customer Service 1.877-823.8748 Internet: h2o.enr.state.ne.us
An Equal Opportunity! Affirmative Action Employer
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*--m u r f 5 m a 5 On 5 4920 OLD PINEVILLE ROAD•CHARLOTTE,NC 28217 •[phone] •Fax(704)`527-1297
November 6, 2000
f 0
Ms. Kay Laws
Glen Raven Filament Fabrics, LLC
Highway 19 East
P.O. Drawer 100
Burnsville,NC 28714
P: 828-682-2142 F: 828-682-9710
RE: Sludge Removal Services
Burnsville,North Carolina
Proposal No. IHO-3580
Dear Ms. Laws:
Four Seasons Environmental, Inc. (Four Seasons) is pleased to submit this proposal to Glen Raven
for the above-referenced services to be performed at the Glen Raven facility in Burnsville, North
Carolina. This proposal is based upon information provided by Glen Raven and a recent site
inspection performed by Paul Oxendine. Our experience with similar projects enables us to meet
your goals and objectives in a professional manner while maintaining a timely schedule.
SCOPE OF WORK
Four Seasons understands that Glen Raven requires sludge removal services from a 12,000-gallon
capacity septic system. The system is composed of 4) four compartments that contain thick sludge
aromp6sed no'rn=h �orriausftdirt yin, was-tewa er d mcesgzrnat lV There is an estimated
5,000-gallons of material that remains in the system that requires removal. The material is too thick
to be pumped utilizing a standard vacuum truck. A supersucker type vacuum truck must be used to
complete pumping operations due to the nature of the sludge. Access to the system is good and
there is adequate room to temporarily stage (2) two vacuum boxes.
The material must be placed into vacuum boxes for transportation to the disposal facility. The
weight of the supersucker truck does not allow for hauling very much material because of the
truck's weight.
In order to meet Glen Raven's cleaning objectives, Four Seasons proposes the following activities:
• Remove pumpable sludge from the pit using a supersucker vacuum truck.
• Offload the material into vacuum boxes.
• Transport the material off site in the vacuum boxes.
• Transport residual liquid, sludge and rinseate to Four Seasons' facility in Charlotte, North
Carolina for disposal. Waters will be treated in the bulk industrial wastewater treatment system
and sludges/solids will be entered into Four Seasons'bulk solidification program.
Ca CORPORATE HEADQUARTERS; 9413 APISON PIKE,SUITE 200 • OOLTEWAH,TN 37363 • [phone] • 'FAX[phone]

Glen Raven ,.
IHO-3580
/Lf' e
Nov-mb„ er 6.200G .
Page 3
• Additional project work not specifically addressed by this proposal shall be charged at a time
and materials rate. Any additional work, if required, shall be authorized by Glen Raven prior to
initiation.
All projects performed by Four Seasons are executed in compliance with OSHA Hazardous Waste
Operations and Emergency Response regulations, 29 CFR 1910.120. Four Seasons has a complete
safety, training, drug screening and medical monitoring program covering all field personnel.
Four Seasons appreciates the opportunity to provide this proposal. If you wish to accept the
proposal,please indicate your acceptance, subject to the terms and conditions printed on the reverse,
with an authorized signature in the space provided. Return via facsimile to [phone]. If you
have any questions or if we may be of assistance, feel free to call us at [phone] or(800) 782-
0263. Thank you for considering Four Seasons.
Sincerely, Client Acceptance
r /Y-0
Sally Johnson sign e/date
Manager, Charlotte Facility
printed name
Carrie J. Reavisavy-
Project Development Manager title
-,r

U�liaJ. to l0yva�bb.itV any r , N. iS1vv 1111J1v °- --
_i._
Quot A
.-% '' ti 11++ �f .1.,■M�� '' r R. ,it rLS! J uT'.�`Ct{4'F k 7 1! �o
_ JIn 2
a.:
lon
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s ice
. s
.i
s Ila
Contact_ Vic Nettles
Phone: [phone]
Fax [phone] j
E-Mail vnwaste@lowcountzy_com
L�
Deacripcion:
We have priang available
volume hazardous or non-
se
�' u► S 4�aSCc. .. �!' ;� �: hazardous waste. Plea
call for more information.
= .-%
These prices includes: Transportation, bisposal,Manifest Labels,Profiles, and necessarypaper-
work. In some Cases, closed top rums,plastic, or fiber may not be acceptable. We are not.responsi-
ble for off-spec material. We are also not:responsible for waste consistency That,s different-that pro-
filed or shipping of unapproved waste seams.. State-waste taxes will apply if applicable.

PALMETTO ENVIR.UNNffiN'TAL
7775
Pon Office Box 793
Waltarboro,SC 29488
[phone] 0 Fax: [phone] Mobile. [phone]
E-mail:[e-mail]
Palmetto has made the following assumptions in developing taus proposal:
• The pricing presented herein is valid for 60 days from the date ofthis proposal
• Customer shall reimburse Palmetto its reasonable expenses and cbm-ges for handling,analyzing,
loading,preparing,trampordog,storing or caring foe nonconforming or of spec waste,including
costs of decorrtatnination and cleaning equipment.
• Unless otherwise indicated,prices provided are based on performing work on a weekday,non-
holiday during normal working hours(8:OOAM to 5:00 PK.
• Additional project work not specifically addressed by this proposal shall be charged at a time and
materials rate. Any additional work,if required,shall be authorized by Glen Raven Mills prior to
initiation.
All projects performed by Palmetto are executed in compliance with OSHA Hazardous Waste Operations
and Emergency Response regulations,29 CFR 1910.120. Palmetto has a complete safety,training,drug
screening and medical monitoring program covering all field personnel.
Palmetto appreciates the oppornwity to provide this proposal. If you wish to accept the proposal, please
indicate you acceptance,subject to the terms and conditions printed on the reverse,with an authorized
Signature in the space provided. Return via facsinAU to(843)549-9326. If you have Emy questions or if
we may be assistance,feel free to call us at(843)549-5976. Thank you for considering Palmetto
Environmental-
S. Client Acceptance
A.
Conte 1 �
Printed T4we
.5' e'� E SiLVi rO� ftice� a
Title

UG.JL 1'ilal 104JJ'tUUJrU idL.LLG11U L'1vY 111U1Y air, UL
PALMETTMENVIRONMENTAL
Post Office Box 793
WalLerbo ,SC.29488
[phone] •Fax. [phone] *Mobile: [phone]
[e-mail]
Kay Laws
Glen Raven Mills
#19 E.By Pass
Burnsville,NC 29714
Dear lots.Kay 1..aws:
Palmetto Emvirornnental is pleased to submit this proposal to Glen Raven Mills for the above-referenced
services to be performed at Glen Raven 1�Ui s client facility ib Bumssville North Carolina. This proposal is
based solely upon information provided by Gien Raven Mills. No site inspection has been performed. D4u
experience with similar projects enables us to meet your goals and objectives in a professional manner
while maintaining a timely schedule.
PE OF�QRK
Palmetto understands that Glen Raven Mills requires pumping services to remove nonhazardous oil,
Smm and sludge from a 4,000-gallon capacity underground storage tank(UST). There is,an estQnated
3,300-gallons of liquids and 700-gallons of slud8Wsolids in the tank.
IIi- egu�,y�llfcg The UST has a visible and easy
aecessble sway which may be used to access the interior of the tank Palmetto assumes that truck
access is within 75-fleet from the tank and that the material in the tank is readily pu mpable.
Palmetto shall provide a conical vacuum tanker with an operator to pump the material from the tank. Based
on information provided by Glen Raven MNs,no power washing services or confined space
tank is necessary to complete tank pntml=g activities. entry into the
Palmetto will transport residual liquid,sludge and rft. e to Four Seasons'facility in Charlotte,North.
Carolina for disposal. Recoverable fuels will be recycled via fuels bl ending,riirsewater will be treated in
the baulk industrial wastewater treatment system and sludges/solids will be entered into Palmettos bulls
solidification progmm-
g.,Summary
Palmetto shall provide mobilization.,labor and equipment to perform work as specified herein, excluding
disposal,for the following price_
P'um*g Services...................... ..........$325.00/2 hrs.pump time
$163.001a8er 2 hours
Liquid........................
---•............................................S.S&gallon
Sludge........................................................................$3.50-gslkm
o �
_TWO -

Palmetto Environmental Invoice
Post Office Box 793 _
Walterboro, SC 29488 DATE INVOICE#
11/02/2000 3058
BILL.TQ
Glen Raven Mills
Kay Laws ✓��" /
PO Drawer 100
Burnsville NC 28714
P.O,NO. TERMS PROJECT
6004026 Net30
QUANTITY DESCRIPTION RATE AMOUNT
Pumping Services 21-Irs Included 32525.00 325.00
6 Hrs Pump Time 00 325
800 Gal Liquid 163.00
978.00
.00
61475 Gal Sludge .3.50 22,662.50
A4
Total $24,429.50
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and ma Tangy .fines, Inc.
All Your.; Transportation Needs" 7�.,.. �
Post Office 'Box 2827 �0
.0`3 — -"" Burlington; N.C, 1�72.16
Phone (336) R6-7039
_--F-A X# (3 3 6) 2 2 6 k 8155
Company: I<Vct0-mot.. 1� i �\ i N�C
Fax#
Fro n7: --.
Total# Pages ___ including covert sheet) Date. 1
,Message: In an attempt to meet your reques•k for proof of_i�,sltz, --
statement of disposal for the asphalt, we nave een una sr K&S_pav;ng r
respond, Therefore; cc, Thursday, i0/0" 02�n*� chcse to con�,s.cr ono hPr _ci�mn�!�.
Applachian Pw,7ing & gradiiM, to complete the_reR air. Oa--Friday, 10/04/02
gplachia.n Paving responded with the fe:l� i3ig 2r_f_arularion. (5e We are expecting further information from A lach,ian Pavine pn -Mond , 1Gj Q2
t -

�GN"iNu� rRCM
t�11d��► F OcOV a47os
8a
pPcnc 82 1b88.3810
pax t28;698.3844
p tober 04,2002
.. Cirolfn%,Cattle frinms
Attest:Mr.Chris tyslin
rtr:fsylti, ,ifs on or before M22/02,phis is Wneathcx
We have a proposed date of starting hte work at Glen fZaven M
is a Possibility we oats start sootter but at the time that is the date we are going for.
permitting,Them p
Thank You,
Alan Atkins
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-

CCINTlNLE FROM °REV:0 S FADE 3L1 ;
ospallowlen Fmft ft iN,Inc.
v SskersviUgNC 1.t90!
Phone 828J688-3610 6
Per 82916893944
t
i
October 04,2002
Y
;.. Carolina Tank Lies m
Arten:Mr.Chris lyslin
RE:removal of old asphalt
r
The asphalt that is removed from Glen)Zgvep Mills will be transported back to and dLxuded at the A,pplacbain
Paving asphalt plash. t
If you need any additonal information please feel free to call usl at the numbers listed above.
{
DATE: ZI!— Ol RE: /G lcG .
I d
J/3
� AY
SIGNED:
TOPS*FORM 4150•,: 0 PLEASE REPLY I]NO.REPLY NEEDS.

; AX
. . .COVER SHEET
APPALACHIAN PAVING & GRADING INC,
P.a. Box 607 !.
SPRUCE PINE NG 26777
PHONE # [phone]
PAX# 828-688-384 4 �.
SEND TO 7AP&G
CorrpdnY ne►r,9 ,
I
i t7Clhaered loinc
pate
asYtiO R Ue
Atterto AW-
Mr.Cris
Fox hUm I hOae A
33$27S.7179 A
fJrg¢n! R l A5AA ❑ ROM cOmwf )Plaeae/e�ew �j iot ya(N 7n1o1»wdon
L_J �Y
7 rodw Cover. 3
otatva�as, ►rr9
COMMENTS
., ..... „. .... ....................
We are.w iting.pn,ih0 iriqurance,cett;irom.ou�e� ency I vwll to itto,you ss soon...J?Al.—.
le.
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PAVING
GRADING Route 1,Box 795•Burnsville,NC 28714•[phone] �
MAX FOX Home(828)682-3286
LANDFILL 5
BACKHOE (_
aRAYM!4
' �7 "7 le c 4•(828)682-232.0
TRUCKING f f-i v I Ci r!C! r 1 ,2-3286
DATE JOB AMOUNT ws
300 � / 8 .5yoo
l - � �z 400 �req
• AMOUNT
5 yoo
l000
Le
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I

-Vs Regulation on Lead Waste"treatment and Handling t http://www.sspe.org/site/regricws/EPA\yASTERULE.html
1
65) SSPC Online
Search
the society for protective coatfts . _._.._._._ .
About SSPC Contact SSPC
EPA Reas ! OSHA Rees St to Reas j Other Items of Interest Penalty Box
Books &Videos
t.
Standards
Conferences EPA's Regulat'on on Lead Waste
Certification Treatment and,Handling
Training by Bernie Appleman, E ecutive Director of SSPC
Membership On May 26, 1998, two final regulations dealing with the
treatment and testing of dead containing waste appeared in.the
Chapters Federal Register. 1
Committees Part A: Treatment Standards for Lead Containing Waste
Ask SSPC 1. New Treatment.Stanilards fox Treated Versus Untreated (see
Table 1)
Sponsors
Previously, the requirer4qnt for determining if an untreated waste
Links is hazardous was the saie as for a treated waste. This level was
5.0 mg/1 as deterriiined 1 y TCLP. The untreated waste is known
as a TC (toxicity charac enstic) waste.
I
` The present rule changed the criteria for disposal of a treated
waste but not for an unheated waste. For an untreated waste, the
u
TC level is unchanged at 5.0 mg/l. If untreated waste contains
lead at less than 5.0 mg/­per TCLP test it is considered
nonhazardous. f
However, for waste which is to be treated (e.g., by portland
cement) the leachable lead level(per TCLP) must be less than
1 0.75 mg/1 to be classified as a nonhazardous waste and be
eligible for landfilling.
Table 1: Summary Table for Treated and Untreated Wastes
ntreated Wastes Treated
i Was
rious threshold level for. 5.0 mg/1 5.0 mg/l
1eavd (per TCLP)
�ew threshold level for lead 5.0 mg/1 0.75 mg/1
f
IT r TCLP). .... — - - --

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` `. .. NQZT I'CAT.10 SPILL_'EVENTS
6.1 ' 'IN PLANT NOTIACATION
Any spill of fuel oil beyond routine drippings or due to equipment or procedural failured
must be reported to the appropriate authority or.;agency.
ALL fuel oil releases must be reported: to the following plant personnel in the. order <`
given:
NAME TITLE WORK PHONE EXT. HOME PHONE
Kay Laws* SPCC Plan 678-3066 3066 682-9668
Coordinator
Warren
�
Higgins-_Jr. Plant Engineer 678-3094 3094 682-2727
Plant Manager 2;5�
*See Section 5.2.1(A)3 for SPCC Plan Coordinator backup contacts.
&2 .REGULATORY AGENCY NOTIFICATION'
Reportable releases must be immediately reported to federal and state agencies. All releases of
toxic or hazardous chemicals, except for small, routine spills, are reported to Mr. David Cates,
Corporate Safety & Environmental Director, at [phone] to determine whether the release
exceeds the reportable quantity(RQ), and therefore must be reported.
Releases that meet the following requirements must be reported to the appropriate agencies.
ALL OIL RELEASES THAT:
• ENTER ANY WATERWAYS
ARE WITHIN 100 FEET OF ANY WATER BODY
• CANNOT BE CLEANED UP WITHIN 24 HOURS, OR
• RELEASES TO THE GROUND >25 GALLONS
ALL CHEMICAL RELEASES THAT:
• EXCEED THE REPORTABLE QUANTITY (RQ)
• RESULT FROM EXPOSURES TO STORMWATER
North Carolina Department of Environment&Natural Resources
[phone]-Asheville Regional Office during work hours (8:00-5:00)
Monday-Friday
19
_0P.

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ORNM.
PI) SsTOR1YIE
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SECTION A: COMPLIANCF.AND LUBEUTY
1.. CgMiiiance Schedule
The permitter shall comply witti.f imitations'and Controls specified for storrawater
discharges in,accordance with the following schedule.-
Existing Facilities: The Stormwater Pollution Prevention Plan shall be developed and
implemented within 12 months of the effective date of the initial certificate of coverage
issued pursuant to this general permit and updated thereafter on an annual basis.
Secondary containment, as specified in Part II, Section A.Paragraph 2(b) of this per it,
shall be accomplished.within IZ months of the effective date-of the initial ceft flcate of
coverage
.Proposed Facilities: The Stormwater pollution Prevention Plan shall be developed and
implemented prior to the beginning of discharges from the operation of the'industrial
activity and-be updated thereafter on an annual basis. Secondary containment, as
specified in Part II,Section ArParagraph 2(b) of this permit shall be accomplished prior
to the beginning of discharges from.the operation of the industrial activity,
2.
Duty to Comply f
The permittee must comply with all conditions of this general permit. Any permit
noncompliance constitutes a violation of the Clean Water Act and is grounds for
enforcement action; for certificate of coverage termination, revocation and reissuance, or
n!odir.cation; or denial of a ce dficate of coverage upon renewal application.
a. Tlie permittee shall comply with standards or prohibitions established under
section 307(a) of the Clean Water Act for toxic pollutants within the time
provided in the regulations that establish these standards or prohibitions, even if
the permit has not yet been modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition is
subject to a civil penalty not to exceed$25,000 per day for each violation. Any
person who negligently violates any permit condition is subject to criminal
penalties of 32,500 to $25,000 per day of violation, or imprisonment for not more
than 1 year, or both. Any person who knowingly violates permit conditions is
subject to criminal penalties of$5,000 to $50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also, any person who violates a
permit condition may be assessed an administrative penalty not to exceed 310,000
per violation with the maximum amount not to exceed$125,000. [Ref: Section
309 of the Federal Act 33 USC 1319 and 40 CFR 122.41(a).]
Parts III Page 1 of 11