NCG500244_Regional Office Physical File Scan Up To 10/14/2020

November 6, 2006
Larry Frost
Environmental Engineer
2090 U.S. Highway 70
Swannanoa, NC 28778
Subject:
October 9, 2006 - Visit
Compliance Evaluation Inspection
Waynesville Plant
Permit No: NCG500244
Dear Mr. Frost
Thank you for your visit. We have taken your findings and your suggestions and have
made many improvements already. You had requested a formal response on the issues with our
back wall. I apologize for getting this response back to you at the last minute, but we had a time
deciding what would be our best and most reliable option and then getting contractor quotes. We
will be building a short retaining wall approximately 10" high all along the back wall in the
Digester area. This will prevent any spills or daily floor wash downs from reaching Richland
Creek.
The wall will be installed by December 1st, 2006.
Let me know if you have any other questions or concerns.
Thank you,
Jason Bumgarner
Plant Manager
ijl
NOV 1 3 2006
WATER QUALITY S CTKDN
ASH V LL_..F C OFFICE.a.�._
•
P.0 Box 370
Waynesville, NC 28786
phone [phone]
mobile [phone]
fax [phone]
www.jbumgarner c tgiiescorp.com

RE: Illegal discharge
Subject: RE: Illegal discharge
From: "Jason Bumgarner" <[e-mail]>
Date: Thu, 14 Sep 2006 09:31:06 -0400
To: "'Linda Wiggs"' <[e-mail]>
Good morning Linda,
I have looked at my schedule in October, .and the 2nd or the 9th looks
good if you are available. Just let me know and we can set something up.
Thanks,
Jason Bumgarner
Giles Chemical Corp.
PO Box 370 - Waynesville, NC 28786
[e-mail]
Office - 828-452-4784-13
Fax - 828-452-4786
Cell - 828-508-4377
Original Message
From: Linda Wiggs [mailto:[e-mail]]
Sent: Friday, September 08, 2006 10:36 AM
To: Jason Bumgarner
Subject: Re: Illegal discharge
Jason,
Thank you for your response. Please send me a cc of the procedure.
I realize this is likely an innocuous substance once it has been assimilated
by Richland Creek, but it is still considered an illegal discharge. Prior
to the river assimilating, at the point of discharge, there could be
negative effects to the aquatic life. We have received complaints about
this wash water discharge as well. This discharge has to stop and I am sure
we can deal with this without making it a formal issue. There are some
other stormwater issues we may need to discuss.
I would like to schedule an appointment to visit the site in October to
further assist. Please contact me with your availability, Mondays and
Fridays are best for me
Thank you, Linda
Jason Bumgarner wrote:
Linda,
First off let me apologies for taking so long to respond. The
discharge from the plant is of course Mag-sulfate or Epsom Salt a very
inert, natural, non -hazardous material. The area where the discharge
comes from is our Filter Press room. The filter press is cleaned
daily and the entire area is washed down on a regular basis. The main
problem we face, and you saw, is that any percentage of Epsom salt
washed up will leave a white residue no matter how week the
percentage. The floor in the press room is sloped to a central drain
in the middle of the room. If an employee is washing the floor down
and keeps washing toward the door it will over run the slop causing it
to run out on to the side walk and down the street to the storm drain.
Since this is caused by wash down and the MgSO4 content is always very
diluted and it should not be considered a threat to the Richland
creek, however, I don't want anything like this to be an
issue. I will address this immediately. I have written and posted a
new procedure to assure that we always wash away from the doors toward
the sewer drain in all areas. Feel free to contact me personally if
you think there needs to be more done or this is unsatisfactory
solution.
1 of 2 9/20/2006 10:05 AM

RE Illegal discharge
I want to make sure this is not an issue in the future as well
Thank you,
*Jason** Bumgarner*
/Plant Manager /
/Giles Chemical Corp./
/PO Box 370 - Waynesville, NC 28786/
/[e-mail]/<mailto:[e-mail]>
/Office - 828-452-4784-13/
/Fax - 828-452-4786/
/Cell - 828-508-4377/
Linda Wiggs - [e-mail]
North Carolina Dept. of Environment and Natural Resources Asheville Regional
Office Division of Water Quality - Water Quality Section 2090 U.S. 70
Highway Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Content -Type: application/msword
2006-0901 - Floor Washing.doc
Content -Encoding: base64
2 of 2 9/20/2006 10:05 AM

ig-1101,

I /a-io

LOG C2
STORMWATER POLLUTION PREVENTION PLAN

ENVIRONMENTAL INCIDENT
REPORT

Facility: Giles Chemical, Waynesville, NC
Rev: 0
Date:
Page 1 of 1

Facility: Giles chemical Manufacturing Facility – 102 Commerce Street Waynesville, NC 28786

Incident Date/Time/Duration: 08/02/19 @ 13:15

Substance Involved: Magnesium Oxide

Quantity Released: 100-lbs +/-

Cause: Ruptured 3” offloading Hose

Immediate Action:
Shut system down, placed barriers in front of stormwater drain, swept street clean, and replaced offloading
hose.

Preventive Measures:
Safety and environmental precautions Investigation to follow – possible preventive measures could include:
More frequent hose testing, pressure relief valves, procedure improvements and training

Offsite Impact/Reaction:
Fire department was called to help block traffic until road was swept.
NO discharge into storm water system

Agencies/Personnel Contacted with Telephone Numbers:
Mikal Willmer
Environmental Specialist-Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ-Division of Water Resources

Office: 828-296-4686
[e-mail]

Other Comments:
Uncertain of Nonhazardous spill reporting at the time of report… email sent to Mikal Wilmer for clarification

cvA
CDENR
of Environment and Natural Resources
0002 1967 7275
1
nd NOTICE OF INTENT TO ENFORCE
ent #201401632)
3
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OD Oa 00
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bRQ Cpater occurred at the subject facility located at 102
Commerce Street, Waynesville, NC. Based upon your employee's description of the spill and
observations made by Division of Water Resources (DWR) staff, the release(s) resulted from a
failure to properly maintain your facility's wastewater piping and drains. Levels of process water
on the plant floor rose and fell multiple times resulting in an unknown volume of wastewater
discharging to a storm drain on Commerce Street and also through a back door directly above
Richland Creek. Once the blockage in the piping was removed, pooled process water entered the
floor drains and overwhelmed an open section of piping (filter box) resulting in an estimated
several hundred gallons of wastewater discharging directly to Richland Creek; a class B stream
within the French Broad River Basin. A Division of Water Resources staff member made the above -
referenced observations while onsite on October 4, 2014.
John E. Skvarla, III
Secretary
Violations
As a result of the above -referenced observations on October 4, 2014, the following violations are
noted:
(1) Illegal discharge
(2) Failure to Provide Required Notice
(3) Violation of Water Quality Standards
(4) Failure to maintain and operate sewer system
Water Quality Regional Operations — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone:[phone] FAX: [phone]
Internet htlp://portal.nedenrarglweb/wq
An Equal Opportunity I Affirmative Action Employer

Giles Chemical Spill -Waynesville
Richland Creek
October 4, 2014
Giles Chemical
Epson Salt
Manufacturer
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Domestic waste
Process water recovery Filter trap
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Octo*ir 4, 2014
T corm drain discharge

2006
MAGNESIA, LLC
October 17, 2014
nt. Division of Watts Rcsourea6
OCT 2 3 2014
Water Quality Regional Operations
Ashen➢ic Preien^'Othoe
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:
1
ES
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 'knee wall' 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 beside the sidewalk. 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
Giles Chemical, a Division of Premier Magnesia, LLC
102 Commerce Street
Waynesville, NC 28786
[phone]

AMER
MAGNESIA, LLC
discharge to be non -hazardous and 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 box on the exit side of the drain pipe
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 estimated at 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 2% solid
minerals. These consist mainly of Gypsum (Calcium Sulfate), Magnesium Oxide (non -
reactive), Sand, and Iron Sulfates. Giles processes a mined mineral and 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]

?REMIER
MAGNESIA, LLC
plant.
3. 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
dirt/dust/debris/construction materials.
The worst case assumption is that the water discharged to the creek/storm sewer on
October 4, 2014 was Filter Press Wash 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 main drain 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
1. Valves will be installed'arthe upper end of the main drain pipe (below the main sump
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 sump
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 sealed and not removed
unless valves mentioned in Action Plan item 1 are closed.
Giles Chemical, a Division of Premier Magnesia, LLC
102 Commerce Street
Waynesville, NC 28786
[phone]

e
?RETI'1IER i I E
MAGNESIA, LLC
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, LLC
102 Commerce Street
Waynesville, NC 28786
[phone]

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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
December 8, 2014
CERTIFIED MAIL — 7012 1010 0002 1965 9417
RETURN RECEIPT REQUESTED
Andy Oxy Co., Inc.
ATTN: Mr. Britt Lovin
Vice President and General Manager
PO Box 6389
Asheville, North Carolina 28816
SUBJECT: NPDES Stormwater Individual Permit Required
Andy Oxy Co., Inc.
27 Heritage Drive, Asheville
Buncombe County
Dear Mr. Lovin:
This letter is in follow-up to the NPDES Stormwater Inspection conducted on November
5, 2014 at the Andy Oxy Co., Inc. Asheville facility. Brett Laverty (Division of Water
Resources), Darlene Kucken, and I appreciate your assistance while conducting the
inspection. A review of our findings during the inspection indicates that an NPDES
individual permit is required. Note that during our inspection we observed at least two
stormwater outfalls from the facility that convey stormwater from the property to a
drainage area and stream. You are requested to complete the attached application
and to submit to our Stormwater Section in Raleigh at the following address by January
31, 2015: NCDENR; DEMLR — Stormwater Permitting Program; 1612 Mail Service
Center; Raleigh, NC 27699-1612. If you prefer you can complete this application on-
line at the following website (but still submit to our Stormwater Permitting Program):
http://cfpub.epa.gov/npdes/docs.cfm?document type id=8&view=Permit%20Applicatio
ns%20and%20Forms&program id=1 &sort=name
As we discussed on site, efforts should be made to limit stormwater exposure to any
process pollutants. A Stormwater Pollution Prevention Plan (SWPPP) and stormwater
outfall monitoring will be required as part of the permit requirements.
Division of Energy, Mineral, and Land Resources — Land Quality Section
Asheville Regional Office, 2090 US Highway 70, Swannanoa, North Carolina, 28778-8211
Telephone [phone] Fax [phone] One
http://portal.ncdenr.org/web/Ir/land-quality NorthCarolina
An Equal Opportunity / Affirmative Action Employer Naturally

Mr. Britt Lovin, VP/General Manager
December 8, 2014
Page 2 of 2
Currently the facility is out of compliance until a permit is issued. It is requested that
you submit the completed application by January 31, 2015. Please be advised that
operating your facility without the proper permit coverage could result in the issuance of
a Notice of Violation as well as the assessment of civil penalties of up to $ 25,000 per
day, per violation.
Please refer to the enclosed Compliance Inspection Report for additional comments,
observations, and recommendations made during the inspection.
If you have any questions or comments concerning this letter, please contact Darlene
Kucken or me at [phone].
Sincerely,
Laura Herbert, PE
Regional Engineer
Enclosure (Inspection Report and Application)
ec: Bethany Georgoulias, RCO
Brett Laverty

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Routine Compliance Inspection
Rescission Request
Complaint Investigation
Other - Explain: 41r4aL l AVM - S°f'd &1ts-
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?
NA./d ilti '1,?•%2ud
2
Is a copy of the signed and certified SWPPP at the facility?
,O
3
Does the Plan include a "Narrative Description of Practices"?
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4
Does the plan include a general location (USGS) map?
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5
Does the plan include a detailed site map including outfall
locations and drainage areas?
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6
Does the plan include a Spill Prevention and Response Plan?
(SPRP)
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7
Does the plan include a Preventative Maintenance and Good
Housekeeping Plan?
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Does the plan include a Stormwater Facility Inspection Program?
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9
Does the Plan include a BMP Summary?
10
Does the plan include a list of Responsible Party(s)?
y
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11
Has the SWPPP been implemented?
B
Monitoring and Records
Yes
No
N/A
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1
Does the plan include a list of significant spills occurring during
the past 3 years?
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?
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Waste Management
Yes
No
N/A
1
Does the facility provide all necessary secondary containment?
2
Are current BMPs in material storage areas adequate?

3
Are appropriate spill containment and cleanup materials kept on -
site and in convenient locations?
4J
D
1
Outfalls
Were all outfalls observed during the inspection?
Yes
No
N/A
2
If the facility has representative outfall status, is it properly
documented by the Division?
3
E
1
Has the facility evaluated all illicit (non stormwater) discharges?
Sector specific questions
Have zinc or copper benchmarks been exceeded in the past 3
sampling periods?
Yes
No
N/A
Have potential sources for copper and zinc been evaluated at
your facility?
Comments
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HES
MATERIAL SAFETY DATA SHEET
Trade Name: Epsom Salt, Magnesium Sulfate, U.S.P.
Date Prepared: 08/07/13
Page: 1 of4
1 CHEMICAI. PRODUCT AND COMPANY IDENTIFICATION
Product name: Epsom Salt, Magnesium Sulfate, U.S.P. Product
description: Magnesium sulfate, heptahydrate
Mantfacturer: Giles Chemical
102 Commerce Street
Waynesville, NC 28786 USA
Telephone: [phone]
In case of emergency call. 828-452-4784
For transportation emergency
Call CHEMT2EC: 800,424-9300
7 COMPOSITION/INFORMATION ON INGREDIENTS
Chemical and Common Name CAS Regisny Wt % OSHA PEL ACGIII TLV
Number
Magnesium sulfate, heptahydrate; 10034-99-8* 100% Not Established Not Established
Epsom salt
* Under the Toxic Substance4 Control Act (TSCA), hydrates are considered as mixtures ofthcir anhydrous salt and
water. Accordingly, the CAS Numbers 7487-88-9, 7732-18-5 are used for purposcs of TSCA.
3 HAZARDS IDENTIFICATION
Emergency Overview: White or transparent crystalline odorless powder.
Noncombustible. At very high temperatures, magnesium oxide, sulfur
dioxide, and sulfur trioxide may be generated. Causes mild eye irritation.
Eye contact: Causes mild irritation to the eyes.
Skin contact: No (mown 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, IARC or OSHA
as a carcinogen.
Physical hazards: Spilled material can be slippery.
4. FIRST AID MEASURES
E e:
Skin:
Inhalation:
In case of contact, immediately flush eyes with plenty of water for at least
15 minutes. Get medical attention if irritation persists.
Not applicable.
Remove to fresh air. If not breathing, give artificial respiration. If breathing
is difficult, give oxygen. Get medical attention.

Dade Name::
Date Prepared:
Epsom Salt, Magnesium Sulfate, U.S.P.
08/07/13
Page: 2 of 4
Ingestion:
If Imge quantities of this material are swallowed, call a physician immediately.
Do NOT induce vomiting unless directed to do so by a physician. Never give
anything by mouth to an unconscious person.
5. FIRE FIGHTING MEASURES
Flammable limits:
Extinguishing Media:
Hazards to firefighters:
Fire -fighting equipment:
This material is noncombustible.
This material is compatible with all extinguishing media.
See Section 3 for information on hazards when this material is present
in 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, self-contained
breathing apparatus.
b ACCIDENTAI REI.F.ASF MFASI;RFS
Personal protect/on: Wear chemical goggles, See section 8.
Environmental Hazards: Sinks and mixes with water. No adverse effects known. Not a listed toxic chemical
under SARA Title III, §313 40 CFR Part 372. Not a CERCLA Hazardous
Substance under 40 CFR Part 302.
Sina!l spill cleanup: Sweep, scoop or vacuum discharged material. Flush residue with water.
Observe environmental regulations.
Large spill cleanup: Keep unnecessary people away; isolatehazardarea and deny entry. Do not touch
or walk through spilled material. Sweep, scoop or vacuum discharged material.
Flush residue with water. Observe environmental regulations.
CERCLA RQ' There is no CERCLA Reportable Quantity for this material.
7. HANDLING AND STORAGE
Handling: Avoid breathing dust. Promptly clean up pills.
Storage: Keep containers closed. Protect from extremes of temperature and humidity
during storage. Recommended storage conditions 68-110° F and 54-87% relative
humidity.
$ FXPOSI IRE CONTROLS/PERSONAI. PRO'rFCTIOD(
Engineering controls:
Respiratory protection'
Skin protection:
Eye protection:
Use with adequate. ventilation. Safety shover and eyewash fountain should be
within direct access.
Use a NIOSH-approved dust respirator where dust occurs. Observe
OSHA regulations for respirator use (29 C.F.R. §I910.134)
Wear gloves if abrasion or irritation occurs.
Wear chemical goggles.

Trade Name: Epsom Salt, Magnesium Sulfate, U.S.P.
Date Prepared 08/07/13
Page: 3 of 4
9 PHYSICAL AND CHEMICAI. PROPERTIF„K
Appearance: Crystalline odorless powder.
Co/or: White or transparent.
Odor: Odorless.
PH: Approximately 6-7
Specific gravity: 1.76 g/cm°, Bulk Density Approximately 1.05 g/cm3
Sohrbiliry in water: 71g/100 ml at 20° C, 91g/100 ml at 40° C
10. STABILITY AND REACTIVITY
Stability: This material is stable under all conditions of use and storage.
Conditions to avoid: None.
Materials to avoid Metal hydrides and other water reactive materials.
Hazardous decomposition
products At very high temperatures, magnesium oxide, sulfur dioxide, and sulfur trioxide
may be generated.
II.TOXICOI,OGICAL INFORMATION
Acute Data: When tested for primary irritation potential, this material caused mild eye
irritation. RTECS reports Oral TDLo= 428 mg/kg in man 351 mg/kg in women
12 FCOJOGICAL INFORMATION
Eco toxicity:
Environmental Fate:
Physical/Chemical:
Data not available.
This material is not persistent in aquatic systems and does not contribute to BOD. It
does not bioconeentrate up the food chain. -
Sinks and mixes with water.
ji DISPOSAL CONSIDERATIONS
Classification: Disposed material is not a hazardous waste.
Disposal Method.' Landfill according to local, state, and federal regulation
not a RCRA Hazardous waste.
Disposed material is
14. TRANSPORT INFORMATION
DOT UNStatus: This material is not regulated hazardous material for transportation.
15 REGULATORY INFORMATION
CERCLA: No CERCLA Reportable Quantity has been established for this material.

Dade Name: Epsom Salt, Magnesium Sulfate, U.S.P.
Date Prepared: 08/07/13
Page: 4 of 4
SARA TITLE III: Not an Extremely Hazardous Substance under §302. Not a Toxic
Chemical under §313. Hazard Categories under §§311/312: Acute
TSCA: All ingredients of this material are listed on the TSCA inventory.
FDA: Magnesium sulfate is an FDA GRAS substance pursuant to 21 CFR
184.1443.
16 OTHER INFORMATION
Prepared by: Mark A. Shand
Date of Preparation. 08/07/13
THE INFORMATION ON THIS SA MTV DATA SHEET IS BELIEVED TO BE ACCURATE AND IT IS TIIE BEST
INFORMATION AVAILABLE TO Giles Chemical. THIS DOCUMENT IS INTENDED ONLY AS A GUIDE TO THE
APPROPRIATE PRECAUTIONS FOR HANDLING A CHEMICAL BV A PERSON TRAINED IN CHEMICAL HANDLING.
Giles Chemical MAKES NO WARRANTY OF MERCHANTABILITY OR ANT OTHER WARRANTY, EXPRESS OR
IMPLIED WITH RESPECT TO SUCH INFORMATION OR THE PRODUCT TO WHICH 1I RELATES, AND WE ASSUME
NO LIABILITY RESULTING FROM THE USE OR HANDLING OF THE PRODUCT TO WHICH 'MIS SAFETY DATA
SHEET RELATES. USERS AND HANDLERS OE THIS PRODUCT SHOULD MAKE THEIR OWN INVESTIGATIONS TO
DETERMINE THE SUITABILITY WIRE INFORMATION PROVIDED HEREIN FOR THEIR OWN PURPOSES.

PREMIER
MAGNESIA, LLC
March 6, 2020
Mikal Willmer
Environmental Specialist II -Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ-Division of Water Resources
2090 US Highway 70
Swannanoa, NC 28778-8211
RE: NC EM Report 226420 — release to storm drain
Dear Mikal:
On February 28, at approximately 7:50 AM, Giles Chemical unintentionally released an estimated 200
gallons of nonhazardous magnesium sulfate brine solution to the storm water drain at 102 Commerce
St, Waynesville NC. The event occurred when a leaking filter press was operated incorrectly, causing a
release of the magnesium sulfate solution and solids that were being filtered. The employee involved
failed to follow operating procedures and ignored specific verbal instructions. The process was stopped,
and barricade materials/ sandbags were placed at the roll up door to stop the flow of solution was to
the street at the curb. The street was then cleaned, and residue was removed by approximately 9:00
AM,
To prevent recurrence, we have:
- terminated the employee responsible for the event,
- examined the filter press for possible mechanical issues,
- reviewed our maintenance procedures for the press,
- reviewed our operating procedures,
- re-trained our operators,
- planned purchased of "throw down" drain covers, and
- are evaluating our internal curbing
We appreciate your help in responding to this event. Please call me if I can provide any additional
information.
Sin -re y
VP Manufacturing
Giles Chemical, a Division of Premier Magnesia

AwA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
October 14, 2014
CERTIFIED MAIL
RETURN RECEIPT REQUESTED - 7012 1010 0002 1967 7275
Giles Chemical
c/o Ms. Debra Durbin
102 Commerce Street
Waynesville, NC 28786
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 Ms. Durbin:
John E. Skvarla, III
Secretary
On October 4, 2014, release(s) of wastewater occurred at the subject facility located at 102
Commerce Street, Waynesville, NC. Based upon your employee's description of the spill and
observations made by Division of Water Resources (DWR) staff, the release(s) resulted from a
failure to properly maintain your facility's wastewater piping and drains. Levels of process water
on the plant floor rose and fell multiple times resulting in an unknown volume of wastewater
discharging to a storm drain on Commerce Street and also through a back door directly above
Richland Creek. Once the blockage in the piping was removed, pooled process water entered the
floor drains and overwhelmed an open section of piping (filter box) resulting in an estimated
several hundred gallons of wastewater discharging directly to Richland Creek; a class B stream
within the French Broad River Basin. A Division of Water Resources staff member made the above -
referenced observations while onsite on October 4, 2014.
Violations
As a result of the above -referenced observations on October 4, 2014, the following violations are
noted:
(1) Illegal discharge
(2) Failure to Provide Required Notice
(3) Violation of Water Quality Standards
(4) Failure to maintain and operate sewer system
Water Quality Regional Operations - Asheville Regional 0ffce
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet: hllp://portaI.ncdencorgM1veb/wq
An Equal Opportunity 1 Affirmative Action Employer

Ms. Debra Durbin
October 14, 2014
Page 2 of 3
Violation I. Discharge Without a Valid Permit
G.S. 143-215.1 (a) states that no person shall do any of the following things or carry out any of the
following activities unless that person has received a permit from the Commission and has
complied with all conditions set forth in the permit: G.S. 143-215.1(a)(1) - Make any outlets into
the waters of the State.
Violation II. Failure to Provide Required Notice
The failure to notify the Division of Water Resources of the discharge of process wastewater
represents violations of N.C.G.S. 143 215.85 (a), which states except as provided in. G.S. 143
215.94E(a1) and subsection (b) of this section, every person owning or having control over oil or
other substances discharged in any circumstances other than pursuant to a rule adopted by the
Commission, a regulation of the U. S. Environmental Protection Agency, or a permit required by
G.S. 143 215.1 or the Federal Water Pollution Control Act, upon notice that such discharge has
occurred, shall immediately notify the Department, or any of its agents or employees, of the
nature, location and time of the discharge and of the measures which are being taken or are
proposed to be taken to contain and remove the discharge.
Violation III. Violation of Water Quality Standard
A large volume of brown -colored process wastewater was observed discharging from an open
filter box by DWR staff on October 4, 2014. The resulting plume in Richland Creek discolored the
water column and coated the bottom of the stream with a white precipitate in violation of water
quality standards set forth 15A NCAC 02B .0211:
• (3)(c) - Floating solids, settleable solids, or sludge deposits: only such amounts attributable
to sewage, industrial wastes or other wastes as shall not make the water unsafe or
unsuitable for aquatic life and wildlife or impair the waters for any designated uses
• (3)(f) - Oils, deleterious substances, colored or other wastes: only such amounts as shall not
render the waters injurious to public health, secondary recreation or to aquatic life and
wildlife or adversely affect the palatability of fish, aesthetic quality or impair the waters for
any designated uses.
• (3)(k) - The turbidity in the receiving water shall not exceed 50 Nephelometric Turbidity
Units (NTU) in streams not designated as trout waters.
Violation IV. Failure to Maintain and Operate Sewer System
The unpermitted discharge of wastewater to Richland Creek represents a violations of 15A NACA
02T .0403 (1), which states the sewer system is effectively maintained and operated at all times to
prevent discharge to land or surface waters, and to prevent any contravention of groundwater
standards or surface water standards and (3) an operation and maintenance plan including pump
station inspection frequency, preventative maintenance schedule, spare parts inventory and
overflow response has been developed and implemented.

Ms. Debra Durbin
October 14, 2014
Page 3 of 3
Required Response
This Office requests that you respond to this letter in writing within 30 days of receipt of this
Notice. Your response should be sent to this Office at the letterhead address. Your response
should address the following items:
1. Please submit a report assessing the cause, significance, and extent of the release. In
this report, include when you ceased discharging to the waters of the State. The report
should contain details of estimated wastewater released, conditions under which the
wastewater was released and chemical composition of the wastewater. To determine
chemical composition of the wastewater, you are required to take a representative
sample from the filter box and have it analyzed by a N.C. certified lab. You are also to
submit a timeline of events that occurred on October 3, 2014 and October 4, 2014
associated with the release.
2. Please submit a plan listing all actions you will take to prevent future releases. Your
comments should address but are not limited to the following issues: secondary
containment issues within the plant, spill response plan, preventative maintenance on
your piping system and floor drains, lack of secondary containment around outside
piping, and lack of enclosure for piping, etc.
These violations and any future violations are subject to civil penalty assessments. The
violations are subject to civil penalties up to $25,000.00 per day for each violation as per G.S.
143-215.6A.
This office requires that the violations, as detailed above, be abated immediately and properly
resolved. Thank you for your attention to this matter. This Office is considering sending a
recommendation for enforcement to the Director of the Division of Water Resources regarding
these issues and any future/continued violations that may be encountered. Your above -
mentioned response to this correspondence will be considered in this process.
Should you have any questions regarding these matters, please contact Brett Laverty at (828) 296-
4500.
Sincerely,
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations
Asheville Regional Office
cc: DWRCentral Files
PERCS Unit — Deborah Gore

From:Jason Bumgarner
To:Willmer, Mikal
Cc:Billy Brackett; Matt Haynes
Subject:RE: [External] Jason with Giles Chemical
Date:Monday, September 2, 2019 6:53:47 PM
Attachments:image001.png
2019-0802 - MgO spill Report.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]
Mikal,
Giles had a incident today where an offloading hose ruptured and Magnesium Oxide was
discharged onto the public road near our offloading site. All proper precautions were taken and
clean up has been completed.

NO stormwater drains were involved with this incident

But we are needing some direction on reporting.

We have procedures for hazardous material reporting but nothing for nonhazardous.

Can you help point Giles in the right direction on who we would need to talk with or who would
need this report or if another report is more appropriate for this type incident

Thank you for your help
Jason Bumgarner
Giles Chemical

From: Willmer, Mikal <[e-mail]>
Sent: Tuesday, May 07, 2019 8:41 AM
To: Jason Bumgarner <[e-mail]>
Cc: Billy Brackett <[e-mail]>
Subject: RE: [External] Jason with Giles Chemical

Hi Jason,

Not a problem. I left you another voicemail before I saw your email. Let me see if I can answer some
of your questions.

Below is guidance regarding what is allowed, permitted and best practices under the Division of
Water Resources Water Quality (WQ). I would suggest contacting the Division of Energy, Mineral,
and Land Resources (DEMLR) also, since they oversee your no exposure stormwater permit and its
management.

The only wastewater you are permitted to discharge under your permit with the Water Quality
Section is the non-contact cooling water.
Washing sidewalk: I would advise against washing down the sidewalk since there is the
potential for process and final material to end up on the sidewalk and enter the storm drain
and Richland Creek. If the sidewalks are getting debris on them from the facility, then that
would be something to assess as a preventative measure. If the sidewalk is owned by the
Town and the trash/debris is coming from residents, then I would discuss with the Town
about maintaining debris along the road.
Remove Trash Blocking Drain: The Water Quality Section does not have oversite over
maintenance of the storm drains and/or debris (Check with DEMLR). Unless the trash is
holding back a known substance that has the potential to negatively impact the stream, a
sudden rush of storm water from a drain should not constitute a violation of water quality
standards (this is strictly from a water quality standpoint not what is required with no
exposure stormwater).
Floor Washings: If any water from inside of the building migrates outside, immediate action
should be taken to abate the discharge and prevent any from entering the creek either
directly or through the storm drains. If it does reach surface waters or a storm drain you
should immediately notify DWR and DEMLR and monitor the stream for any visual impacts.
Field parameters of the stream should also be monitored.

The goal is to have zero product leaving the facility and migrating off site. No product should be
entering surface waters. Again, also check with DEMLR to ensure you are maintaining the facility in
compliance with your No Exposure Permit requirements.

If you need to report any discharges, you can call our office 828-296-4500 during business hours or if
on a weekend, holiday or after hours you can call 800-858-0368.

The DEMLR regional supervisor is Stan Aiken ([e-mail] ) and industrial stormwater
contact is Isaiah Reed ([e-mail]).

Please let me know if you have any additional questions.
Regards,

Mikal Willmer
Environmental Specialist-Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ-Division of Water Resources

Office: 828-296-4686
Fax: [phone]
[e-mail]

2090 US Hwy. 70
Swannanoa, NC 28778

cid:image003.png@01D1AAB0.14A552C0

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Jason Bumgarner <[e-mail]>
Sent: Friday, May 03, 2019 3:26 PM
To: Willmer, Mikal <[e-mail]>
Cc: Billy Brackett <[e-mail]>
Subject: [External] Jason with Giles Chemical

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]

Mikal,
Sorry for the phone tag.
I will be out of the office for the next two weeks but I should still have limited access to email so
thought it would be easier to just introduce myself and ask a few questions via email and if you don’t
mind you could answer when you have time.

I have taken a new positions with Giles – EHS and Lean. I am working with OSHA and taking classes
for the Health and Safety aspects but wanting to get more comfortable with the Environmental
components of the new job.

I have been looking through the NCDENER and EPA websites as well as Giles’s existing programs for
both NC and our Indiana plant.

Giles is clear with the rules and regulations of Spills but we have to many opinions, theories and
hearsay in the plant of what to do if any type of a minor nonhazardous spill or discharge was to
happen…

The typical areas that everyone is scared of but needs clarification revolve around:
1. Can we wash regular dirt and debris off the side walk in front of plant?
2. If there is trash blocking our storm drain is it ok just to remove trash and let all the water rush
at once?
3. What if we have floor washing from inside the plant make it to the sidewalk? ( non-
hazardous/non-petroleum )
·         We wash our floors down on a regular basis, and floor drains take everything to the
sanitary sewer drains.
It is a big issue in this plant that NOTHING leaves this plant except sewer
So I don’t mind keeping it as a major scare for employees but just for my
knowledge
·         But If we had some Epsom salt or non-haz floor washings or even a drain issue what
do we do?
We have and will use spill kits, spill berms etc. but
a. Can we wash down the sidewalk or any residue?
b. What should be reported/notified and when/how should we notify someone?
c. Giles would document in our SWPPP manual but when do we notify NCDENR of a
minor non-haz discharge?
d. Is there any level/amount of nonhazardous that can go to the storm drain without it
being an issue?

Thank you for your time, We take our footprint and contribution to the environment very serious,
and I want to make sure we are not only observing all the “rules” but also being a good
environmental neighbor with everything we do and to be educated about these type scenarios
moving forward

Jason Bumgarner
EHS and Lean Coordinator
Giles Chemical
828.452.4784.13

Water Resources
■MMONt"TAL QUALITY
March 7, 2017
Giles Chemical
Deborah Durbin
102 Commerce St.
Waynesville, NC 28786
SUBJECT: Compliance Evaluation Inspection
Giles Chemical
Permit No: NCG500244
Haywood County
Dear Ms. Durbin:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary,
S. JAY ZIMMERMAN
Director
On February 13, 2017, I conducted a Compliance Evaluation Inspection of the General
NPDES Discharge Permit that serves the Giles Chemical Plant. Based on records reviewed
and the on -site evaluation, the system was determined to be in compliance with Permit No.
NCG500244. The system and its components appear to be well maintained and operated.
Your assistance in conducting the inspections was greatly appreciated. Please refer to the
enclosed inspection report for additional observations and recommendations. If there are any
questions or additional information is needed, please feel -free to contact me at 828-296-4500
Sincerely,
Mikal . Imer
Environmental Specialist
Asheville Regional Office
Enclosure: Inspection Report
cc: MSC 1617-Central Files
WQ Asheville Files
G:\WR\WQ\Haywood\Wastewater\General\NCG50 Non-Contact\NCG500244 Giles\lnspect. February 13, 2017\CEI Letter 2-13-
2017.doex
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-2964500

United stales Environmental Protection Agency
Form Approved.
EPA Washington, D.C.20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type
Inspector Fee Type
1 IN 1 2 Is I 3 I NCG500244 I11 12 17/02/13 17 18 I C I
19 I c I 201 I
211IIIII IIIIIIII1IIIIIIIII11IIIII IIIIII11III
f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating 81 CA —
Reservetl —
67I.........
70LJI 71 I 72 L731 74 75L L L L �80
Section B: FacilityData
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
01:45PM 17/02/13
15111119
Waynesville plant
Exit Time/Date
Permit Expiration Date
102 Commerce St
Waynesville NO 28786
02:15PM 17/02/13
20/07/31
Names) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
ru
Name, Address of Responsible Officiat/Title/Phone, and Fax Number
Deborah Durbin,102 Commerce St Waynesville NO 267ti6/1628-052-4784/ Contacted
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
-M-Petwit ::-:_<•�.-..:..>...0 Flow Measurement ' ® Operations &Maintenance 0 Records/Reports
Self -Monitoring Program E Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) or Inspector(s) Agency/Office/Phone and Fax Numbers
Date
Mikal Willmar +ARO WO//828-296-4686/
r /�,
'3 - �
Signature o anagement q A Reviewer Agency/Office/Phone and Fax Numbers
Date
3l 7-.Ir
EPA Farm 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES
31 Nco500244 I11 1
yr/mo/day Inspection Type
17/02/13 17 18 ICI
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Inspector, Mikal Willmar with the Asheville Regional Office conducted a Compliance Evaluation
Inspection of Giles Chemical's Non -Contact Cooling Water system that supplies the barometric
condenser on February 13, 2017. Deborah Durbin, Director of Quality and Safety for Giles Chemical,
was present and assisted in the inspection.
The non -contact cooling water storage tank is showing signs of rust and age, but there were no visible
leaks around the tank. The PVC influent and effluent pipes to and from Richland Creek were well
maintained. There appeared to be some water leaking just inside of the building, however, not in
sufficient quantity to reach the back door. Giles chemical has placed a berm just outside of the door
leading to Richland Creek to help minimize the chance of runoff. A catwalk has been installed along the
backside of the building to allow safe access from the side of the building. The pipe running along the
creek behind the building was also recently replaced.
All monitoring data was readily available for review and was within permit limits. Giles Chemical is only
required to monitor flow, temperature and pH semi-annually. Richland Creek appeared to be free of any
visual impairments from the permitted discharge.
There did not appear to be any violations of the NCG500000 Permit at the time of the inspection. A
previous inspection indicated it was acceptable for Giles Chemical to only monitor upstream and
downstream. They have added effluent monitoring at all outfalls to satisfy all permit conditions.
Giles Chemical should label all of the discharge pipes exiting the backside of the building. Currently
only three discharge pipes directly below the non -contact cooling water storage tank are labeled. There
are three additional discharge pipes exiting the backside of the building. Also, please clarify in any
future permit renewals the number of separate discharge points. The most recent renewal only
indicated three ouffalls.
Page#

Permit: NCG500244 Owner -Facility: Waynesville plant
Inspection Date: 02/13/2017 Inspection Type: Compliance Evaluation
Operations Sr Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? M ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑. ❑ M ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Process control testing not performed. No associated wastewater treatment plant. This
system is non -contact cooling water discharge only.
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment:
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical -results consistentwi&data.reported on DMRs?...
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
Yes No NA NE
❑ ❑ M ❑
❑ ❑ M ❑
❑ ❑ ■ ❑
❑ ❑ ❑
■ ❑ ❑ ❑
Yes No NA NE
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
❑
❑
■
❑
ED
❑
❑
M
❑
❑
❑
M
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator ❑ ❑ 0 ❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
M
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
0
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
0
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Page#
3

G
Permit: NCG500244
Inspection Date: 02/13/2017
Record Keeping
Facility has copy of previous year's Annual Report on file for review?
Owner • Facility: Waynesville plant
Inspection Type: compliance Evaluation
Yes No NA NE
Comment: A copv of the most recent Non -Contact Cooling Water General NPDES Permit is kept onsite
and filed with monitoring data.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
0
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: The PVC effluent and influent pipes for the non -contact cooling water to and from Richland
Creek appear to be in good condition. Some of the effluent pipes are labeled, however, there
a three pipes to the right of the backdoor which are unlabeled.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
❑
❑
M
❑
Is proper volume collected?
❑
❑
0
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
❑
❑
❑
representative)?
Comment: There is a continuous discharge from the plant. Giles Chemical uses upstream and
downstream data to meet effluent temperature requirements. Provided monitoring data did
not show effluent specific data. Giles was informed by our office in a previous inspection that
only sampling upstream and downstream was acceptable. They have added effluent
monitoring at all outfalls to satisfy all permit conditions.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑
sampling location)?
Comment: The past three years of upstream and downstream sampling were available for review.
Monitoring data reviewed was within compliance of permit limits.
Page# 4

`ter
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Ms. Deborah Durbin
Giles Chemical Company
102 Commerce St.
Waynesville, NC 28751
Donald van der Vaart
Secretary
January 7, 2015
CERTIFIED MAIL 7013 2630 0001 8998 1499
RETURN RECEIPT REQUESTED
SUBJECT: Assessment of Civil Penalties for Making an Outlet without a Permit
Giles Chemical Company
Haywood County
File No. DV-2014-0029
Dear Ms. Durbin,
This letter transmits notice of a civil penalty assessed against Giles Chemical Company in the
amount of $4,000.00 plus $374.22 in enforcement costs. Attached is a copy of the assessment
document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the Secretary
of the Department of Environment and Natural Resources and the Director of the Division of
Water Resources. Any continuing violation(s) may be the subject of a new enforcement action,
including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following three items:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural
Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Please submit payment to the
attention of:
Mr. Steve Lewis
DWR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 919A07-6492
Internet vrvnv.ncwateraualitv.oro
l
aosuumes
JAN 1 3 2015
Water Quality Regional Operations
Asheville Renone.l OFP .e
An Equal Opportunity 1Atfinnative Action Employer

2. Submit a written request for remission including a detailed justification for such request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as
they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission
is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the
factual statements contained in the civil penalty assessment document. Because a remission request
forecloses the option of an administrative hearing, such a request must be accompanied by a waiver of
your right to an administrative hearing and a stipulation and agreement that no factual or legal issues are
in dispute. Please prepare a detailed statement that establishes why you believe the civil penalty should
be. remitted, and submit it to the Division of Water Quality at the address listed below. In determining
whether a remission request will be approved, the following factors shall be considered: '
(1) whether one or more of the civil penalty assessment factors in NCGS 14313-282.1(b) were
wrongfully applied to the detriment of the violator;
(2) whether the violator promptly abated continuing environmental damage resulting from the
violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator has been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please note that all evidence presented in support of your request for remission must be submitted in
writing. The Director of the Division of Water Quality will review your evidence and inform you of his
decision in the matter of your remission request. The response will provide details regarding the case
status, directions for payment, and provision for further appeal of the penalty to the Environmental
Management Commission's Committee on Civil Penalty Remissions (Committee). Please be advised
that the Committee cannot consider information that was not part of the original remission request -
considered by the Director. Therefore, it is very important that you prepare a complete and thorough
statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Waiver of Right to an
Administrative Hearing and Stipulation of Pacts" form within thirty (30) days of receipt of this notice.
The Division of Water Quality also requests that you complete and submit the enclosed "Justification for
Remission Request." Both forms should be submitted to the following address:
Please submit this information to the attention of:
Mr. Steve Lewis
DWR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

OR
3. File a petition for an administrative hearing with the Office of Administrative Hearings.
If you wish to contest any statement in the attached assessment document, you must file a petition for an
administrative hearing. You may obtain the petition form from the Office of Administrative Hearings.
You must file the petition with the Office of Administrative Hearings within thirty (30) days of receipt
of this notice. A petition is considered filed when it is received in the Office of Administrative Hearings•
during normal office hours. The Office of Administrative Hearings accepts filings Monday through
Friday between the homy of 8:00 a.m. and 5:00 p.m., except for official state holidays. The original and
one (1) copy of the petition must be filed with the Office of Administrative Hearings. The petition may
be faxed provided the original and one copy of the document is received in the Office of Administrative
Hearings within five (5) business days following the faxed transmission. The mailing address for the
Office of Administrative Hearings is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Telephone [phone] Facsimile: [phone]
AND
Mail or hand -deliver a copy of the petition to:
And to:
Mr. John Evans
NCDENR
Office of General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
Mr. Steve Lewis
DWR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced
by an internal date/time received stamp (not a postmark), will result in this matter being referred to the
Attorney General's Office for collection of the penalty through a civil action. Please be advised that
additional penalties may be assessed for violations that occur after the review period of this assessment.

]f you have any questions, please contact Mr. Steve Lewis at [phone] or via email at
[e-mail] or Ms. Deborah Gore at [phone].
Sincerely,
'' MM^^
y,,
��`-I
Deborah Gore, Supervisor
Pretreatment, Emergency Response and
Collection Systems Unit
Division of Water Resources, NCDENR
DAG/scl
ATTACHMENTS
cc: Landon Davidson, Asheville Regional Office Supervisor
Brett Laverty, ARO
Enforcement File DV-2014-0029
Central Files

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
COUNTY OF HAYWOOD
IN THE MATTER OF
GILES CHEMICAL CORPORATION
FILE NO. DV-2014-0029
FINDINGS AND DECISION
FOR MAKING AN OUTLET TO THE ) AND ASSESSMENT OF
WATERS OF THE STATE OF ) CIVIL PENALTIES
NORTH CAROLINA )
WITHOUT A PERMIT )
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources, I, Deborah Gore, Environmental Programs Supervisor for
the Pretreatment, Emergency Response and Collection System (PERCS) Unit of the Division of
Water Resources (DWR), make the following:
I. FINDINGS OF FACT:
A. Giles Chemical Corporation, a Division of Premier Magnesia, LLC (also known
as Giles Chemical Industries, Inc.) is a corporation organized and existing under
the laws of the State of North Carolina.
B. On October 4, 2014, DWR staff observed a discharge of industrial wastewater
from Giles Chemical Corporation located at 102 Commerce Street in
Waynesville, NC, Haywood County, to Richland Creek, which are Class B waters
of the State within the French Broad River Basin.
C. Giles Chemical Corporation had no valid permit for the above -described activity.
D. The cost to the State of the enforcement procedures in this matter totaled $374.22.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Giles Chemical Corporation is a "p6rson" within the meaning of G.S. 143-215.6A
pursuant to G.S.'143-212(4)..

C. The above -cited discharge constituted making an outlet to waters of the State for
purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S. 143-
215.1.
D. Giles Chemical Corporation may be assessed civil penalties in this matter
pursuant to G.S. 143-215.6A(a)(2), which provides that a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) per violation may be
assessed against a person who is required but fails to apply for or to secure a
permit required by G.S. 143-215.1.
E. The State's enforcement costs in this matter may be assessed against Giles
Chemical Corporation pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-
282.1(b)(8).
F. The Environmental Program Supervisor for the Pretreatment, Emergency
Response and Collection System Unit, pursuant to delegation provided by the
Secretary of the Department of Environment and Natural Resources and the
Director of the Division of Water Resources, has the authority to assess civil
penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION:
Accordingly, Giles Chemical Corporation -is hereby assessed a civil penalty of:
$ 4,000.00 for making an outlet to the waters of the State without! a
permit as required by G.S. 143-215.1.
$ 4,000.00 TOTAL CIVIL PENALTY
$ 374.22 Enforcement costs
$ 4,374.22 TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.143B-282.l(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage; I
(5) The amount of money saved by noncompliance;

(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
(8) The cost to the State of the enforcement procedures.
(Date) Deborah Gore
PERCS Unit Supervisor
Division of Water Resources

STATE OF NORTH CAROLINA
COUNTY OF HAYWOOD
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
GILES CHEMICAL COMPANY
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. DV-2014-0029
Having been assessed civil penalties totaling $4,374.22 for
violation(s) as set forth• in the assessment document of the Director of the Division of Water
Resources dated January 7, 2015 , the undersigned, desiring to seek remission of
the civil penalties, does hereby waive the right to an administrative hearing in the above -stated matter
and does stipulate that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director of the Division of Water Quality within thirty
(30) days of receipt of the civil penalty assessment. No new evidence in support of a remission
request will be allowed after thirty (30) days from the receipt of the civil penalty assessment.
This the
day of
ADDRESS
TELEPHONE
SIGNATURE

JUSTIFICATION FOR RENIISSION REQUEST
DWR Case Number: DV-2014-0029 County: Haywood
Assessed Party: Giles Chemical Company
Permit No. (if applicable): N/A Amount Assessed: $4,374.22
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission. Waiver of Right to an Administrative Hearing„ and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)
were wrongfullyapplied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a result of an accident (Le., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance).
EXPLANATION (attach additional pages as necessary):

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.14� D
9' I E S MATERIAL SAFETY DATA SHEET
Trade Name- Epsom Salt, Magnesium Sulfate, U.S.P.
Date Prepared. 08/07/13 Page: I ut
1. CHEMICAL PROD[ ICT AND
COMPANY IDENTIFICATION
Epsom Salt, Magnesium Sulfate, U.S.P. Product
Product name:
description:
Magnesium sulfate, heptahydrate
Manufacturer:
Giles Chemical
102 Commerce Street
Waynesville, NC 28786 USA
Telephone:
828-452-4784
In case of emergencv call:
828452-4784
For transportation emergencv
Call CHFAITRFC:
800-424-9300
Chemicai and Common Name CAS Registry
Number
Magnesium sulfate, heptahydrate; 10034-99-8*
Epsom salt
W1. % OSHA PEL ACGIH TLI'
100% Not Established Not Established
* Under the Toxic Substances Control Act (TSCA), hydrates are considered as mixtures of their anhydrous salt and
water. Accordingly, the CAS Numbers 7487-88-9. 7732-18-5 are used for purposes of TSCA.
3. HAZARDS IDENTIFICATION
Emergenev Overview:
White or transparent crystalline odorless powder.
Noncombustible. At very high temperatures, magnesium oxide, sulfur
dioxide, and sulfur trioxide may be generated. Causes mild eye irritation.
Eye contact:
Causes mild irritation to the 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, IARC or OSHA
as a carcinogen.
Phvsical hazards:
Spilled material can be slippery.
4. FIRST AID MEASURES
Eve: In case of contact, immediately Rush eyes with plenty of water for at least
15 minutes. Get medical attention if irritation persists.
Skin: Not applicable.
Inhalation. Remove to fresh air. If not breathing, give artificial respiration. If breathing
is difficult, give oxygen. Get medical attention.

Trade Name: Epsom Salt, Magnesium Sulfate, U.S.P.
Date Prepared: 08/07/13 Page: 2 of 4
Ingestion:
If large quantities of this material are swallowed, call a physician immediately.
Do NOT induce vomiting unless directed to do so by a physician. Never give
anything by mouth to an unconscious person.
5. FIRF. FIGHTING MEASURES
Flannnable limits:
This material is noncombustible.
Extinguishing Media:
This material is compatible with all extinguishing media.
Hazards to fire-fighters:
See Section 3 for information on hazards when this material is present
in the area of a fire.
Fire -fighting equipment:
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, self-contained
breathing apparatus.
6. ACCIDFNTAL RELEASE
Personal protection:
MEASURES
Wear chemical goggles, See section 8.
Environmental Hazards:
Sinks and mixes with water. No adverse effects known. Not a listed toxic chemical
under SARA Title 111, §313 40 CFR Part 372. Not a CERCLA Hazardous
Substance under 40 CFR Part 302.
Small spill cleanup:
Sweep, scoop or vacuum discharged material. Flush residue with water.
Observe environmental regulations.
Large spill cleanup:
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.
CERCLA RQ:
There is no CERCLA Reportable Quantity for this material.
7. HANDLING AND STORAGE
Handling:
Avoid breathing dust. Promptly clean up pills.
Storage:
Keep containers closed. Protect from extremes of temperature and humidity
during storage. Recommended storage conditions 68-110' F and 54-87% relative
humidity.
S. F.XPOSI IRE CONTROLS/PERSONAL PROTECTION
Engineering controls: Use with adequate ventilation. Safety shower and eyewash fountain should be
within direct access.
Respiratory protection: Use a NIOSH-approved dust respirator where dust occurs. Observe
OSHA regulations for respirator use (29 C.F.R. §1910.134)
Skin protection: Wear gloves if abrasion or irritation occurs.
Ejv protection: Wear chemical goggles.

A UIA
NCDENR
North Carolina Department of Environment and Natural
Pat McCrory
Governor
October 14, 2014
CERTIFIED MAIL
RETURN RECEIPT REQUESTED - 7012 1010 0002 1967 7275
Giles Chemical
c/o Ms. Debra Durbin
102 Commerce Street
Waynesville, NC 28786
�..iL.,y
Resources
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 Ms. Durbin:
John E. Skvarla, III
Secretary
On October 4, 2014, release(s) of wastewater occurred at the subject facility located at 102
Commerce Street, Waynesville, NC. Based upon your employee's description of the spill and
observations made by Division of Water Resources (DWR) staff, the release(s) resulted from a
failure to properly maintain your facility's wastewater piping and drains. Levels of process water
on the plant floor rose and fell multiple times resulting in an unknown volume of wastewater
discharging to a storm drain on Commerce Street and also through a back door directly above
Richland Creek. Once the blockage in the piping was removed, pooled process water entered the
floor drains and overwhelmed an open section of piping (filter box) resulting in an estimated
several hundred gallons of wastewater discharging directly to Richland Creek; a class B stream
within the French Broad River Basin. A Division of Water Resources staff member made the above -
referenced observations while onsite on October 4, 2014.
Violations
As a result of the above -referenced observations on October 4, 2014, the following violations are
noted:
(1) Illegal discharge
(2) Failure to Provide Required Notice
(3) Violation of Water Quality Standards
(4) Failure to maintain and operate sewer system
Water Quality Regional Operations — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: 828-296A500 FAX: [phone]
Internet: http:l/portal.nodenr.org/webAvq
An Equal Opportunity 1 Affirmative Action Employer
L,

Ms. Debra Durbin
October 14, 2014
Page 2 of 3
Violation I. Discharge Without a Valid Permit
G.S. 143-215.1 (a) states that no person shall do any of the following things or carry out any of the
following activities unless that person has received a permit from the Commission and has
complied with all conditions set forth in the permit: G.S. 143-215.1(a)(1) - Make any outlets into
the waters of the State.
Violation II. Failure to Provide Required Notice
The failure to notify the Division of Water Resources of the discharge of process wastewater
represents violations of N.C.G.S. 143 215.85 (a), which states except as provided in G.S. 143
215.94E(al) and subsection (b) of this section, every person owning or having control over oil or
other substances discharged in any circumstances other than pursuant to a rule adopted by the
Commission, a regulation of the U. S. Environmental Protection Agency, or a permit required by
G.S. 143 215.1 or the Federal Water Pollution Control Act, upon notice that such discharge has
occurred, shall immediately notify the Department, or any of its agents or employees, of the
nature, location and time of the discharge and of the measures which are being taken or are
proposed to be taken to contain and remove the discharge.
Violation Ill. Violation of Water quality Standard
A large volume of brown -colored process wastewater was observed discharging from an open
filter box by DWR staff on October 4, 2014. The resulting plume in Richland Creek discolored the
water column and coated the bottom of the stream with a white precipitate in violation of water
quality standards set forth 15A NCAC 02B .0211:
• (3)(c) - Floating solids, settleable solids, or sludge deposits: only such amounts attributable
to sewage, industrial wastes or other wastes as shall not make the water unsafe or
unsuitable for aquatic life and wildlife or impair the waters for any designated uses
• (3)(f) - Oils, deleterious substances, colored or other wastes: only such amounts as shall not
render the waters injurious to public health, secondary recreation or to aquatic life and
wildlife or adversely affect the palatability of fish, aesthetic quality or impair the waters for
any designated uses.
• (3)(k) - The turbidity in the receiving water shall not exceed 50 Nephelometric Turbidity
Units (NTU) in streams not designated as trout waters.
Violation IV. Failure to Maintain and Operate Sewer System
The unpermitted discharge of wastewater to Richland Creek represents a violations of 15A NACA
02T .0403 (1), which states the sewer system is effectively maintained and operated at ail times to
prevent discharge to land or surface waters, and to prevent any contravention of groundwater
standards or surface water standards and (3) an operation and maintenance plan including pump
station inspection frequency, preventative maintenance schedule, spare parts inventory and
overflow response has been developed and implemented.

Ivls. Debra Durbin
October 14, 2014
Page 3 of 3
Required Response
This Office requests that you respond to this letter in writing within 30 days of receipt of this
Notice. Your response should be sent to this Office at the letterhead address. Your response
should address the following items:
1. Please submit a report assessing the cause, significance, and extent of the release. In
this report, include when you ceased discharging to the waters of the State. The report
should contain details of estimated wastewater released, conditions under which the
wastewater was released and chemical composition of the wastewater. To determine
chemical composition of the wastewater, you are required to take a representative
sample from the filter box and have it analyzed by a N.C. certified lab. You are also to
submit a timeline of events that occurred on October 3, 2014 and October 4, 2014
associated with the release.
2. Please submit a plan listing all actions you will take to prevent future releases. Your
comments should address but are not limited to the following issues: secondary
containment issues within the plant, spill response plan, preventative maintenance on
your piping system and floor drains, lack of secondary containment around outside
piping, and lack of enclosure for piping, etc.
These violations and any future violations are subject to civil penalty assessments. The
violations are subject to civil penalties up to $2S,000.00 per day for each violation as per G.S.
143-21S.6A.
This office requires that the violations, as detailed above, be abated immediately and properly
resolved. Thank you for your attention to this matter. This Office is considering sending a
recommendation for enforcement to the Director of the Division of Water Resources regarding
these issues and any future/continued violations that may be encountered. Your above -
mentioned response to this correspondence will be considered in this process.
I
Should you have any questions regarding these matters, please contact Brett Laverty at (828) 296-
4500.
Sincerely,
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations
Asheville Regional Office
cc: DW R Central Files
PERCS Unit —Deborah Gore

TradeNanne: Epsom Salt, Magnesium Sulfate, U.S.P.
Date Prepared: 08/07/13 Page: 3 of 4
Appearance:
Crystalline odorless powder.
Color:
White or transparent.
Odor:
Odorless.
p1h
Approximately 6-7
Specific grm'it"w
1.76 g/cm', Bulk Density Approximately 1.05 glen'
Solubility in water: 71g/100 ml at 20' C, 91 g/100 ml at 40' C
,,. �T.... .'.' ..1., I...1,.1'T%'
Stabi/iry• This material is stable under all conditions of use and storage.
Conditions io avoid.- None.
dlaterials io avoid.- Metal hydrides and other water reactive materials.
Hn_ardoets decomposition
products: At very high temperatures, magnesium oxide, sulfur dioxide, and sulfur trioxide
may be generated.
Acute Data: When tested for primary irritation potential, this material caused mild eye
irritation. RTECS reports Oral TDLo= 428 mg/kg in man 351 mg/kg in women
12. ECOLOGICAL INFORMATION
Eco toxicitu' Data not available.
Enviromnentol Fate: This material is not persistent in aquatic systems and does not contribute to BOD. It
does not bioconcentrate tip the food chain.
Pirysical/Chendcal: Sinks and mixes with water.
Classification: Disposed material is not a hazardous waste.
Disposal ,b/ethod• Landfill according to local, state, and federal regulations. Disposed material is
not a RCRA Hazardous waste.
DOT UA'8tants. This material is not regulated hazardous material for transportation.
CERCLA: No CERCLA Reportable Quantity has been established for this material.

Trade Nanle: Epsom Salt, Magnesium Sulfate, U.S.P.
Date Prepared' 08/07/13 Page: 4 of 4
SARA TITLE III: Not an Extremely Hazardous Substance under §302. Not a Toxic
Chemical under §313. Hazard Categories under §§311/312: Acute
TSCA: All ingredients of this material are listed on the TSCA inventory.
FDA: Magnesium sulfate is an FDA GRAS substance pursuant to 21 CFR
184.1443.
16. OTHER INFORMATION
Prepared by: Mark A. Shand
Date of Preparalion: 08/07/13
THE INFOR\IATION ON TIIIS SAFETY DATA SI IEET IS BELIEVED TO BE ACCURATE AND IT IS THE BEST
INFORMATION AVAILABLE TO Giles Chemical. THIS DOCUMENT IS I\TENDED ON LY AS A GUIDE TO TH E
APPROPRIATE PRECAUTIONS FOR IIANDLINGA CHEMICAL BY PERSON TRAIN ED IN CHEMICALHANDLING.
Giles Chemical MAKES NO WARRANTY OF xIERCHANTARILITY OR ANY OTHER WARRANTY, EXPRESS OR
IMPLIED WITH RESPECT TO SUCH INFORMATION OR THE PRODUCT TO WHICH IT RELATES, AND WE ASSUME
NO LIABILITY RESULTING FROM TIIE USE OR HANDLING OF THE PRODUCT TO WHICH TIIIS SAFETY DATA
SHEET RELATES. USERS AND HANDLERS OF III IS PRODUCT SHOULD MAKE THEIR OWN INVESTIGATIONS TO
DETER\TINE TIIE SUITABILITY OF'I'IIE INFORMATION PROVIDED IIEREIN FOR THEI It OWN PURPOSES.

w�y
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
January 30, 2015
Ms. Deborah Durbin
Giles Chemicals
102 Commerce St
Waynesville NC 28786
SUBJECT: Remission Request
Civil Penalty Assessment
Haywood County
DV-2014-0029
Dear Ms. Durbin,
Donald R. van der Vaart
Secretary
This letter is to acknowledge receipt of your request for remission of the civil penalty levied against the subject
facility. This request will be reviewed by the Director and you will be notified about the Division's decision
concerning remission. If you have any questions, please call me at [phone].
Sincerely,
:� ze"
Steve Lewis
Pretreatment, Emergency Response and
Collection Systems Unit
cc: Enforcement File DV-2014-0029
Landon Davidson, Asheville Regional Office Supervisor
Brett Laverty, ARO
Central Files
FEB - 3 2015
w8w"tity Ftegtonat ooeradons
eehevinn Pr"�D�'�I U"''32
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Ralegh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-M-6748
Internet v .ncwateroualitv.oro
An Equal Opportunity 1 Affirma6ve Action Employer

■
I
IAl
ES
November 6, 2006
Larry Frost
Environmental Engineer
2090 U.S. Highway 70
Swannanoa, NC 28778
Subject:
October 9, 2006 - Visit
Compliance Evaluation Inspection
Waynesville Plant
Permit No: NCG500244
Dear Mr. Frost
Thank you for your visit. We have taken your findings and your suggestions and have
made many improvements already. You had requested a formal response on the issues with our
back wall. I apologize for getting this response back to you at the last minute, but we had a time
deciding what would be our best and most reliable option and then getting contractor quotes. We
will be building a short retaining wall approximately 10" high all along the back wall in the
Digester area. This will prevent any spills or daily floor wash downs from reaching Richland
Creek.
The wall will be installed by December I st, 2006.
Let me know if you have any other questions or concerns.
Thank you,
Jason Bumgarner
Plant Manager
L NOV 13 2006
f WP.TGF :il.�0.LrIY S CT'
.. 11�HF\/�, i_I-- rrgr`:i:'. s•,L ^� ICE
P_0 Box 370
Waynesville_ NC 2878E
phone 928.452,4794.13
mobile 828.508A377
fax 828.452.478E
,o �% .ihumnamerfii gileseorp.com

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
February 20, 2015
Ms. Deborah Durbin
Giles Chemicals
102 Commerce St
Waynesville, NC 28786
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Haywood County
DV-2014-0029
Dear Ms. Durbin,
Donald R. van der Vaart
Secretary
This letter is to acknowledge receipt of check No. 29106 in the amount of $4,374.22 received
from you dated 2/12/2015. This payment satisfies in full the civil assessment levied against the
subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable statutes, regulations, or permits.
If you have any questions, please call Steve Lewis at 919-807-6308.
Sincerely,
/-S. Jay Zimmerman, Acting Director
Division of Water Resources
cc: Enforcement File # DV-2014-0029
Landon Davidson, Asheville Regional Office Supervisor
Brett Laverty, ARO R!"
Central Files oims:on
FEB 2 5 2015
Water Quality nepionat ooeratlons
1617 Mail Service Center, Ralegh, Nort Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: 919807MM I FAX: [phone]
Internet www.ncwatergualiN.org
An Equal Opportunity 1 Affinnatire Action Empoyer

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
February 20, 2015
Ms. Deborah Durbin
Giles Chemicals
102 Commerce St
Waynesville, NC 28796
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Haywood County
DV-2014-0029
Dear Ms. Durbin,
Donald R. van der Vaart
Secretary
This letter is to acknowledge receipt of check No. 29106 in the amount of $4,374.22 received
from you dated 2/12/2015. This payment satisfies in full the civil assessment levied against the
subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable statutes, regulations, or permits.
If you have any questions, please call Steve Lewis at 919-807-6308.
Sincerely,
Jay Zimmerman, Acting Director
Division of Water Resources
cc: Enforcement File # DV-2014-0029
Landon Davidson, Asheville Regional Office Supervisor
Brett Laverty, ARO
Central Files
FEB 2 5 2015
Water Qualltv Regional operations
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX [phone]
Internet:w .ncwateroualityora
An Equal Opportunity 1 Affirmative Action Employer

Q
I�CDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Ms. Deborah Durbin
Giles Chemical Company
102 Commerce St
Waynesville NC 28786
SUBJECT: Remission Request
Civil Penalty Assessment
Haywood County
DV-2014-0029
Dear Ms. Durbin,
Donald R. van der Vaart
Secretary
February 6, 2015
CERTIFIED MAIL 7013 2630 000189981420
F E B 1 1 2015
Water ouality Regional Onemftns
In accordance with North Carolina General Statute 143-215.6A(f), the Director of the North Carolina Division
of Water Quality considered the information you submitted in support of your request for remission and did not
find grounds to modify the civil penalty assessment of $4,374.22. A copy of the Director's decision is attached.
Two options are available to you at this stage of the remission process:
1) You may pay the penalty.
If you decide to pay the penalty please make your check payable to the Department of Environment and
Natural Resources (DENR). Send the payment within thirty (30) calendar days of your receipt of this letter
to the attention of:
Mr. Steve Lewis
Pretreatment, Emergency Response, Collection Systems Unit
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
2) You may decide to have the Environmental Management Commission's (EMC) Committee on Civil Penalty
Remissions make the final decision on your remission request.
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Ralegh, North Carolina 27604
Phone: [phone] FAX: 9IM07-64921 Customer Service: 1-877-623-6748
Internet: www.ncwaterouality.oro
An Equal Opportunity 1 Affirmative Action Employer

If payment is not received within 30 calendar days from your receipt of this letter, your request for
remission with supporting documents and the recommendation of the Director of the North Carolina
Division of Water Quality will be delivered to the Committee on Civil Penalty Remissions for final agency
decision.
If you or your representative would like to speak before the Committee, you must complete and return the
attached Request for Oral Presentation Form within thirty (30) calendar days of receipt of this letter. Send
the completed form to:
Mr. Steve Lewis
Pretreatment, Emergency Response, Collection Systems Unit
Division of Water Resources
1417 Mail Service Center
Raleigh, NC 27699-1617
The EMC Chairman will review the supporting documents and your request for an oral presentation (if you
make the request). If the Chairman determines that there is a compelling reason to require a presentation,
you will be notified of when and where you should appear. If a presentation is not required, the final
decision will be based upon the written record.
If you have any questions, please call me at [phone].
Sincerely,
:f �,"
Steve Lewis
Pretreatment, Emergency Response and
Collection Systems Unit
Division of Water Resources, NCDENR
cc: Enforcement File DV-2014-0029
Landon Davidson, Asheville Regional Office Supervisor
Brett Laverty, ARO
Central Files

a
DIVISION OF WATER RESOURCES
CIVIL PENALTY REMSSION FACTORS
Case Number: DV-2014-0029 Region: ARO County: Haywood
Assessed Entity: Giles Chemical Permit: N/A
❑ (a) Whether one or more of the civil penalty assessment factors were wrongly applied to the
detriment of the petitioner:
® (b) Whether the violator promptly abated continuing environmental damage resulting from
the violation:
• Giles states that the discharge occurred as abruptly as it ended. Giles has made a number of
corrective actions to prevent a reoccurrence of this instance as well as other possible discharges.
One of these actions was to install a 100 ft. long trench at the bay doors at a cost of $14,000 to
prevent any discharge from the door area.
• The Region recommends denial of remission.
® (c) Whether the violation was inadvertent or a result of an accident:
• Giles states the violation was inadvertent. The discharge was the result of a water backup from
an unexpected blockage in the main drain pipe. The blockage was cause by construction debris
(saw dust and wood pieces) that had been swept into the drain.
• The Region recommends denial of remission because the company has had releases in at least
two prior instances. Staining outside the rear door of the facility also indicates prior releases to
the creek.
® (d) Whether the violator had been assessed civil penalties for any previous violations:
• Giles states that they have not been assessed for any previous violations.
• The Region concurs that Giles has not been assessed previously.
❑ (e) Whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions:
DECISION (Check One)
Request Denied 'J
Full Remission `❑ Retain Enforcement Costs? Yes ❑ No ❑
Partial Remission❑ $ (Enter Amount)
.yam �S
. ay Zimmerman Date
rev 1.0-8.31.09

STATI; OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF HAYWOOD
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST:
GILES CHEMICAL COMPANY
DWR Case Number DV-2014-0029
REQUEST FOR ORAL PRESENTATION
I hereby request to make an oral presentation before the Environmental Management Commission's Committee On Civil Penalty
Remissions in the matter of the case noted above. In making this request, I assert that I understand all of the following statements:
• This request will be reviewed by the Chairman of the Environmental Management Commission and may be either granted or
denied.
• Making a presentation will require the presence of myself and/or my representative during a Committee meeting held in Raleigh,
North Carolina.
• My presentation will be limited to discussion of issues and information submitted in my original remission request, and because
no factual issues are in dispute, my presentation will be limited to five (5) minutes in length.
The North Carolina State Bar's Authorized Practice of Law Committee has ruled that the appearance in a representative capacity at
quasi-judicial hearings or proceedings is limited to lawyers who are active members of the bar. Proceedings before the Committee on
Remissions are quasi-judicial. You should consider how you intend to present your case to the Committee in light of the State Bar's
opinion and whether anyone will be speaking in a representative capacity for you or a business or governmental entity. If you or your
representative would like to speak before the Committee, you must complete and return this form within thirty (30) days of receipt of
Us letter.
Depending on your status as an individual, corporation, partnership or municipality, the State Bar's Opinion affects how you may
proceed with your oral presentation. See www.ncbar.com/ethics, Authorized Practice Advisory Opinion 2006-1. and 2007 Formal
Ethics Opinion 3.
• If you are an individual or business owner and are granted an opportunity to make an oral presentation before the Committee,
then you do not need legal representation before the Committee; however, if you intend on having another individual speak
on your behalf regarding the factual situations, such as an expert, engineer or consultant, then you must also be present at the
meeting in order to avoid violating the State Bar's Opinion on the unauthorized practice of law.
• If you are a corporation, partnership or municipality and are granted an opportunity to make an oral presentation before the
Committee, then your representative must consider the recent State Bar's Opinion and could be considered practicing law
without a license if he or she is not a licensed attorney. Presentation of facts by non -lawyers is permissible.
If you choose to request an oral presentation, please make sure that signatures on the previously submitted Remission Request form
and this Oral Presentation Request form are: 1) for individuals and business owners, your own signature and 2) for corporations,
partnerships and municipalities, signed by individuals who would not violate the State Bar's Opinion on the unauthorized practice of
law.
Also, be advised that the Committee on Civil Penalty Remissions may choose not to proceed with hearing your case if the Committee
is informed that a violation of the State Bar occurs.
This the day of _ 120
SIGNATURE
TITLE (President, Owner, etc.)
ADDRESS
TELEPHONE

�A���
RUd NR
North Carolina Department of Environment
Pat McCrory
Govemor
Ms. Deborah Durbin
Giles Chemical Company
102 Commerce St
Waynesville NC 28786
SUBJECT: Remission Request
Civil Penalty Assessment
Haywood County
DV-2014-0029
Dear Ms. Durbin,
February 6, 2015
EE9 1 1 ` o'LldR.
Water Ou^ RectImat Operations
_,Asheville Rrgionsl Cffice.
CERTIFIED MAIL 7013 2630 000189981420
RETURN RECEIPT REQUESTED
der Vaart
In accordance with North Carolina General Statute 143-215.6A(f), the Director of the North Carolina Division
of Water Quality considered the information you submitted in support of your request for remission and did not
find grounds to modify the civil penalty assessment of $4,374.22. A copy of the Director's decision is attached.
Two options are available to you at this stage of the remission process:
1) You may pay the penalty.
If you decide to pay the penalty please make your check payable to the Department of Environment and
Natural Resources (DENR). Send the payment within thirty (30) calendar days of your receipt of this letter
to the attention of:
Mr. Steve Lewis
Pretreatment, Emergency Response, Collection Systems Unit
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
2) You may decide to have the Environmental Management Commission's (EMC) Committee on Civil Penalty
Remissions make the final decision on your remission request.
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwateroualitv.oro
An Equal Opportunity 1 AfinnaUve Action Employer

If payment is not received wiWn 30 calendar days from your receipt of this letter, your request for
remission with` supporting documents and the recommendation of the Director of the North Carolina
Division of Water Quality will be delivered to the Committee on Civil Penalty Remissions for final agency
decision.
If you or yourrepresentativerweuld like to speak before the Committee, you must complete and return the
attached Request for Oral Presentation Form within thirty (30) calendar days of receipt of this letter. Send
the completed form to:
Mr. Steve Lewis
Pretreatment, Emergency Response, Collection Systems Unit
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
The EMC Chairman will review the supporting documents and your request for an oral presentation (if you
make the request). If the Chairman determines that there is a compelling reason to require a presentation,
you will be notified of when and where you should appear. If a presentation is not required, the final
decision will be based upon the written record.
If you have any questions, please call me at [phone].
Sincerely,
Steve Lewis
Pretreatment, Emergency Response and
Collection Systems Unit
Division of Water Resources, NCDENR
cc: Enforcement File DV-2014-0029
Landon Davidson, Asheville Regional Office Supervisor
Brett Laverty, ARO
Central Files

DIVISION OF WATER RESOURCES
CIVIL PENALTY REMISSION FACTORS
Case Number: DV-2014-0029 Region: ARO County: Haywood
Assessed Entity: Giles Chemical Permit: N/A
❑ (a) Whether one or more of the civil penalty assessment factors were wrongly applied to the
detriment of the petitioner:
® (b) Whether the violator promptly abated continuing environmental damage resulting from
the violation:
• Giles states that the discharge occurred as abruptly as it ended. Giles has made a number of
corrective actions to prevent a reoccurrence of this instance as well as other possible discharges.
One of these actions was to install a 100 ft. long trench at the bay doors at a cost of $14,000 to
prevent any discharge from the door area.
• The Region recommends denial of remission.
® (c) Whether the violation was inadvertent or a result of an accident:
• Giles states the violation was inadvertent. The discharge was the result of a water backup from
an unexpected blockage in the main drain pipe. The blockage was cause by construction debris
(saw dust and wood pieces) that had been swept into the drain.
• The Region recommends denial of remission because the company has had releases in at least
two prior instances. Staining outside the rear door of the facility also indicates prior releases to
the creek.
® (d) Whether the violator had been assessed civil penalties for any previous violations:
• Giles states that they have not been assessed for any previous violations.
• The Region concurs that Giles has not been assessed previously.
❑ (e) Whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions:
DECISION (Cheek One)
Request Denied �J
Full Remission !❑ Retain Enforcement Costs? Yes ❑ No ❑
Partial Remission❑ $ (Enter Amount)
-yam !S
ay Zimmerman Date
/`l-
rev 1.0 — 8.31.09

STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF HAYWOOD
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST:
GILES CHEMICAL COMPANY
DWR Case Number DV-2014-0029
REQUEST FOR ORAL PRESENTATION
I hereby request to make an oral presentation before the Environmental Management Commission's Committee On Civil Penalty
Remissions in the matter of the case noted above. In making this request, I assert that I understand all of the following statements:
• This request will be reviewed by the Chairman of the Environmental Management Commission and may be either granted or
denied.
• Making a presentation will require the presence of myself and/or my representative during a Committee meeting held in Raleigh,
North Carolina.
• My presentation will be limited to discussion of issues and information submitted in my original remission request, and because
no factual issues are in dispute, my presentation will be limited to five (5) minutes in length.
The North Carolina State Bar's Authorized Practice of Law Committee has ruled that the appearance in a representative capacity at
quasi-judicial hearings or proceedings is limited to lawyers who are active members of the bar. Proceedings before the Committee on
Remissions are quasi-judicial. You should consider how you intend to present your case to the Committee in light of the State Bar's
opinion and whether anyone will be speaking in a representative capacity for you or a business or governmental entity. If you or your
representative would like to speak before the Committee, you must complete and return this form within thirty (30) days of receipt of
this letter.
Depending on your status as an individual, corporation, partnership or municipality, the State Bar's Opinion affects how you may
proceed with your oral presentation. See www.ncbar.com/ethics, Authorized Practice Advisory Opinion 2006-1 and 2007 Formal
Ethics Opinion 3.
• If you are an individual or business owner and are granted an opportunity to make an oral presentation before the Committee,
then you do not need legal representation before the Committee; however, if you intend on having another individual speak
on your behalf regarding the factual situations, such as an expert, engineer or consultant, then you must also be present at the
meeting in order to avoid violating the State Bar's Opinion on the unauthorized practice of law.
• If you are a corporation, partnership or municipality and are granted an opportunity to make an oral presentation before the
Committee, then your representative must consider the recent State Bar's Opinion and could be considered practicing law
without a license if he or she is not a licensed attorney. Presentation of facts by non -lawyers is permissible.
If you choose to request an oral presentation, please make sure that signatures on the previously submitted Remission Request form
and this Oral Presentation Request form are: 1) for individuals and business owners, your own signature and 2) for corporations,
partnerships and municipalities, signed by individuals who would not violate the State Bar's Opinion on the unauthorized practice of
law.
Also, be advised that the Committee on Civil Penalty Remissions may choose not to proceed with hearing your case if the Committee
is informed that a violation of the State Bar occurs.
This the day of 20
SIGNATURE
TITLE (President, Owner,
ADDRESS
TELEPHONE

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
January 30, 2015
Ms. Deborah Durbin
Giles Chemicals
102 Commerce St
Waynesville NC 28786
SUBJECT: Remission Request
Civil Penalty Assessment
Haywood County
DV-2014-0029
Dear Ms. Durbin,
Donald R. van der Vaart
Secretary
This letter is to acknowledge receipt of your request for remission of the civil penalty levied against the subject
facility. This request will be reviewed by the Director and you will be notified about the Division's decision
concerning remission. If you have any questions, please call me at [phone].
Sincerely,
Steve Lewis
Pretreatment, Emergency Response and
Collection Systems Unit
cc: Enforcement File DV-2014-0029
Landon Davidson, Asheville Regional Office Supervisor
Brett Laverty, ARO
Central Files
F F B - 3 2015
Water Ouality Reglonal Operations
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 18778238748
Internet www.ncwaterguality.org
An Equal Opportunity 1 Affirmative Action Employer

AF;"�
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Ms. Deborah Durbin
Giles Chemical Company
102 Commerce St.
Waynesville, NC 28751
Donald van der Vaart
Secretary
January 7, 2015
CERTIFIED MAIL 7013 2630 0001 8998 1499
RETURN RECEIPT REQUESTED
SUBJECT: Assessment of Civil Penalties for Making an Outlet without a Permit
Giles Chemical Company
Haywood County
File No. DV-2014-0029
Dear Ms. Durbin,
This letter transmits notice of a civil penalty assessed against Giles Chemical Company in the
amount of $4,000.00 plus $374.22 in enforcement costs. Attached is a copy of the assessment
document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the Secretary
of the Department of Environment and Natural Resources and the Director of the Division of
Water Resources. Any continuing violation(s) may be the subject of a new enforcement action,
including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following three items:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural
Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Please submit payment to the
attention of:
Mr. Steve Lewis
DWR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet .ncwateroualitv.om
JAN 1 3 2015
Water Duality Regional
An Equal Opportunity 1 Alfirmative Action Employer

2. Submit a written request for remission including a detailed justification for such request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as
they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission
is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the
factual statements contained in the civil penalty assessment document. Because a remission request
forecloses the option of an administrative hearing, such a request must be accompanied by a waiver of
your right to an administrative hearing and a stipulation and agreement that no factual or legal issues are
in dispute. Please prepare a detailed statement that establishes why you believe the civil penalty should
be remitted, and submit it to the Division of Water Quality at the address listed below. In determining
whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) were
wrongfully applied to the detriment of the violator;
(2) whether the violator promptly abated continuing environmental damage resulting from the
violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator has been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please note that all evidence presented in support of your request for remission must be submitted in
writing. The Director of the Division of Water Quality will review your evidence and inform you of his
decision in the matter of your remission request. The response will provide details regarding the case
status, directions for payment, and provision for further appeal of the penalty to the Environmental
Management Commission's Committee on Civil Penalty Remissions (Committee). Please be advised
that the Committee cannot consider information that was not part of the original remission request.
considered by the Director. Therefore, it is very important that you prepare a complete and thorough
statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Waiver of Right to an
Administrative Hearing and Stipulation of Facts" form within thirty (30) days of receipt of this notice,
The Division of Water Quality also requests that you complete and submit the enclosed "Justification for
Remission Request." Both forms should be submitted to the following address:
Please submit this information to the attention of:
Mr. Steve Lewis
DWR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

3. File a petition for an administrative hearing with the Office of Administrative Hearings. -
If you wish to contest any statement in the attached assessment document, you must file a petition for an
administrative hearing. You may obtain the petition form from the Office of Administrative Hearings.
You must file the petition with the Office of Administrative Hearings within thirty (30) days of receipt
of this notice. A petition is considered filed when it is received in the Office of Administrative Hearings•
during normal office hours. The Office of Administrative Hearings accepts filings Monday through
Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The original and
one (1) copy of the petition must be filed with the Office of Administrative Hearings. The petition may
be faxed provided the original and one copy of the document is received in the Office of Administrative
Hearings within five (5) business days following the faxed transmission. The mailing address for the
Office of Administrative Hearings is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Telephone [phone] Facsimile: [phone]
AND
Mail or hand -deliver a copy of the petition to:
Mr. John Evans
NCDENR
Office of General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
Mr. Steve Lewis
DWR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced
by an internal date/time received stamp (not a postmark), will result in this matter being referred to the
Attorney General's Office for collection of the penalty through a civil action. Please be advised that
additional penalties may be assessed for violations that occur after the review period of this assessment.

If you have any questions, please contact Mr. Steve Lewis at [phone] or via email at
[e-mail] or Ms. Deborah Gore at [phone].
Sincerely,
Deborah Gore, Supervisor
Pretreatment, Emergency Response and
Collection Systems Unit
Division of Water Resources, NCDENR
DAG/scl
ATTACHMENTS
cc: Landon Davidson, Asheville Regional Office Supervisor
Brett Laverty, ARO
Enforcement File DV-2014-0029
Central Files

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
COUNTY OF HAYWOOD
IN THE MATTER OF
GILES CHEMICAL CORPORATION
FILE NO. DV-2014-0029
FINDINGS AND DECISION
FOR MAKING AN OUTLET TO THE ) AND ASSESSMENT OF
WATERS OF THE STATE OF ) CIVIL PENALTIES
NORTH CAROLINA )
WITHOUT A PERMIT )
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources, I, Deborah Gore, Environmental Programs Supervisor for
the Pretreatment, Emergency Response and Collection System (PERCS) Unit of the Division of
Water Resources (DWR), make the following:
I. FINDINGS OF FACT:
A. Giles Chemical Corporation, a Division of Premier Magnesia, LLC (also known
as Giles Chemical Industries, Inc.) is a corporation organized and existing under
the laws of the State of North Carolina.
B. On October 4, 2014, DWR staff observed a discharge of industrial wastewater
from Giles Chemical Corporation located at 102 Commerce Street in
Waynesville, NC, Haywood County, to Richland Creek, which are Class B waters
of the State within the French Broad River Basin.
C. Giles Chemical Corporation had no valid permit for the above -described activity.
D. The cost to the State of the enforcement procedures in this matter totaled $374.22.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Giles Chemical Corporation is a "person" within the meaning of G.S. 143-215.6A
pursuant to G.S. 143-212(4).

C. The above -cited discharge constituted making an outlet to waters of the State for
purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S. 143-
215.1.
D. Giles Chemical Corporation may be assessed civil penalties in this matter
pursuant to G.S. 143-215.6A(a)(2), which provides that a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) per violation may be
assessed against a person who is required but fails to apply for or to secure a
permit required by G.S. 143-215.1.
E. The State's enforcement costs in this matter may be assessed against Giles
Chemical Corporation pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-
282.1(b)(8).
F. The Environmental Program Supervisor for the Pretreatment, Emergency
Response and Collection System Unit, pursuant to delegation provided by the
Secretary of the Department of Environment and Natural Resources and the
Director of the Division of Water Resources, has the authority to assess civil
penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION:
Accordingly, Giles Chemical Corporation is hereby assessed a civil penalty of:
$_ 4,000.00 for making an outlet to the waters of the State without a
permit as required by G.S. 143-215.1.
$ 4,000.00 TOTAL CIVIL PENALTY
$ 374.22 Enforcement costs
$ 4,374.22 TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.14313-282.I(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;

(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
(8) The cost to the State of the enforcement procedures.
(Date) Deborah Gore
PERCS Unit Supervisor
Division of Water Resources

COUNTY OF HAYWOOD
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
GILES CHEMICAL COMPANY
ENVIRONMENTAL MANAGEMENT
COMMISSION
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. DV-2014-0029
Having been assessed civil penalties totaling $4,374.22 for
violation(s) as set forth in the assessment document of the Director of the Division of Water
Resources dated January 7.2015 , the undersigned, desiring to seek remission of
the civil penalties, does hereby waive the right to an administrative hearing in the above -stated matter
and does stipulate that the facts are as alleged in the assessment document.
The undersigned Rather understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director of the Division of Water Quality within thirty
(30) days of receipt of the civil penalty assessment. No new evidence in support of a remission
request will be allowed after thirty (30) days from the receipt of the civil penalty assessment.
This the
day of
ADDRESS
TELEPHONE
SIGNATURE

JUSTIFICATION FOR RENIISSION REQUEST
DWR Case Number: DV-2014-0029 County: Haywood
Assessed Party: Giles Chemical Company
Permit No. (if applicable): N/A Amount Assessed: $4,374.22
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of to an Administrative Hearing, and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor -applies (attach
additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something -you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance). .
EXPLANATION (attach additional pages as necessary):

?RENIER
MAGNESIA, LLC
October 17, 2014
G. Landon Davidson, P.G.
OCT 2 3 2014
Wgtx QuPsIY R" 1 Rnr^'!cros
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 'knee wall' 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 beside the sidewalk. 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
Giles Chemical, a Division of Premier Magnesia, LLC
102 Commerce Street
Waynesville, NC 28786
[phone]

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?REHIER g i I Es
MAGNESIA, LLC
discharge to be non -hazardous and 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 box on the exit side of the drain pipe
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 estimated at 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 2% solid
minerals. These consist mainly of Gypsum (Calcium Sulfate), Magnesium Oxide (non -
reactive), Sand, and Iron Sulfates. Giles processes a mined mineral and 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]

?REHIER
MAGNESIA, LLC
plant.
3. Floor Wash Down
giles
Giles uses city water to wash excess Epsom Salt (Magnesium Sulfate Heptahydrate)
from the floors into the drain. This water may also contain other
dirt/dust/debris/construction materials.
The worst case assumption is that the water discharged to the creek/storm sewer on
October 4, 2014 was Filter Press Wash 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 main drain 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
1. Valves will be installed at the upper end of the main drainpipe (below the main sump
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 sump
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 sealed and not removed
unless valves mentioned in Action Plan item 1 are closed.
Giles Chemical, a Division of Premier Magnesia, LLC
102 Commerce Street
Waynesville, NC 28786
[phone]

?REHIER giles
MAGNESIA, LLC
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, LLC
102 Commerce Street
Waynesville, NC 28786
[phone]

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October 14, 2014
CERTIFIED MAIL
RETURN RECEIPT REQUESTED - 70121010 00021967 7275
Giles Chemical
c/o Ms. Debra Durbin
102 Commerce Street
Waynesville, NC 28786
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 Ms. Durbin:
John E. Skvarla, III
Secretary
On October 4, 2014, release(s) of wastewater occurred at the subject facility located at 102
Commerce Street, Waynesville, NC. Based upon your employee's description of the spill and
observations made by Division of Water Resources (DWR) staff, the release(s) resulted from a
failure to properly maintain your facility's wastewater piping and drains. Levels of process water
on the plant floor rose and fell multiple times resulting in an unknown volume of wastewater
discharging to a storm drain on Commerce Street and also through a back door directly above
Richland Creek. Once the blockage in the piping was removed, pooled process water entered the
floor drains and overwhelmed an open section of piping (filter box) resulting in an estimated
several hundred gallons of wastewater discharging directly to Richland Creek; a class B stream
within the French Broad River Basin. A Division of Water Resources staff member made the above -
referenced observations while onsite on October 4, 2014.
Violations
As a result of the above -referenced observations on October 4, 2014, the following violations are
noted:
(1) Illegal discharge
(2) Failure to Provide Required Notice
(3) Violation of Water Quality Standards
(4) Failure to maintain and operate sewer system
Water Quality Regional Operations— Asheville Regional Of e
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet http:llportal.ncdencorg/webAvq
An Equal Opportunity %Affirmative Action Employer

Ms. Debra Durbin
October 14, 2014
Page 2 of 3
Violation I. Discharge Without a Valid Permit
G.S. 143-215.1(a) states that no person shall do any of the following things or carry out any of the
following activities unless that person has received a permit from the Commission and has
complied with all conditions set forth in the permit: G.S. 143-215.1(a)(1) - Make any outlets into
the waters of the State.
Violation II. Failure to Provide Required Notice
The failure to notify the Division of Water Resources of the discharge of process wastewater
represents violations of N.C.G.S. 143 215.85 (a), which states except as provided in G.S. 143
215.94E(al) and subsection (b) of this section, every person owning or having control over oil or
other substances discharged in any circumstances other than pursuant to a rule adopted by the
Commission, a regulation of the U. S. Environmental Protection Agency, or a permit required by
G.S. 143 215.1 or the Federal Water Pollution Control Act, upon notice that such discharge has
occurred, shall immediately notify the Department, or any of its agents or employees, of the
nature, location and time of the discharge and of the measures which are being taken or are
proposed to be taken to contain and remove the discharge.
Violation III. Violation of Water Quality Standard
A large volume of brown -colored process wastewater was observed discharging from an open
filter box by DWR staff on October 4, 2014. The resulting plume in Richland Creek discolored the
water column and coated the bottom of the stream with a white precipitate in violation of water
quality standards set forth 15A NCAC 02B .0211:
• (3)(c) - Floating solids, settleable solids, or sludge deposits: only such amounts attributable
to sewage, industrial wastes or other wastes as shall not make the water unsafe or
unsuitable for aquatic life and wildlife or impair the waters for any designated uses
• (3)(f) - Oils, deleterious substances, colored or other wastes: only such amounts as shall not
render the waters injurious to public health, secondary recreation or to aquatic life and
wildlife or adversely affect the palatability of fish, aesthetic quality or impair the waters for
any designated uses.
• (3)(k) - The turbidity in the receiving water shall not exceed 50 Nephelometric Turbidity
Units (NTU) in streams not designated as trout waters.
Violation IV. Failure to Maintain and Operate Sewer System
The unpermitted discharge of wastewater to Richland Creek represents a violations of 15A NACA
02T .0403 (1), which states the sewer system is effectively maintained and operated at all times to
prevent discharge to land or surface waters, and to prevent any contravention of groundwater
standards or surface water standards and (3) an operation and maintenance plan including pump
station inspection frequency, preventative maintenance schedule, spare parts inventory and
overflow response has been developed and implemented.

Ms. Debra Durbin
October 14, 2014
Page 3 of 3
Required Response
This Office requests that you respond to this letter in writing within 30 days of receipt of this
Notice. Your response should be sent to this Office at the letterhead address. Your response
should address the following items:
1. Please submit a report assessing the cause, significance, and extent of the release. In
this report, include when you ceased discharging to the waters of the State. The report
should contain details of estimated wastewater released, conditions under which the
wastewater was released and chemical composition of the wastewater. To determine
chemical composition of the wastewater, you are required to take a representative
sample from the filter box and have it analyzed by a N.C. certified lab. You are also to
submit a timeline of events that occurred on October 3, 2014 and October 4, 2014
associated with the release.
2. Please submit a plan listing all actions you will take to prevent future releases. Your
comments should address but are not limited to the following issues: secondary
containment issues within the plant, spill response plan, preventative maintenance on
your piping system and floor drains, lack of secondary containment around outside
piping, and lack of enclosure for piping, etc.
These violations and any future violations are subject to civil penalty assessments. The
violations are subject to civil penalties up to $25,000.00 per day for each violation as per G.S.
143-215.6A.
This office requires that the violations, as detailed above, be abated immediately and properly
resolved. Thank you for your attention to this matter. This Office is considering sending a
recommendation for enforcement to the Director of the Division of Water Resources regarding
these issues and any future/continued violations that may be encountered. Your above -
mentioned response to this correspondence will be considered in this process.
Should you have any questions regarding these matters, please contact Brett Laverty at (828) 296-
4500.
Sincerely,
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations
Asheville Regional Office
cc: DWR Central Files
PERCS Unit— Deborah Gore

Incident Report
yaoFwnrFgo>,
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ReportNumber: 201200033
Incident Type:
Complaint
On -Site Contact:
Category:
Surface Water
First/Mid/Last Name:
Incident Started:
01/05/2012
Company Name:
County:
Haywood
Phone:
City:
Pager/Mobile Phone:
Farm #:
Responsible Party:
Owner:
Permit:
Facility:
First Name:
Middle Name:
Last Name:
Address
City/State/Zip:
Phone:
Material Category: Estimated Qty: UOM
DD:MM:SS Decimal
Latitude:
Longitude:
Location of Incident: Giles Chemical
Address: Frog Level
City/State/Zip Waynesville
Reported By:
First/Mid/Last Name:
Company Name:
Address:
City/State/Zip:
Phone:
Pager/Mobile Phone:
i
Chemical Name Reportable Qty. lbs. Reportable Qty. kgs.
Position Method:
Position Accuracy:
Position Datum:
NC 28786
Report Created 05/01/12 03:34 PM Page 1

Cause/Observation
employees are washing down floor into storm drain that goes to
Richland Creek. They are cleaning up white dust/residue.
Complainant has witnessed white, milky liquid discharging
through storm drain.
Directions:
plant is located adjacent to Richland Creek in the Frog Level Community
near downtown Waynesville.
Action Taken: Comments
referred to surface water. Site visit 4/25/2012 - see site inspection notes and NCG500244 notes.
SAW notified Deborah Durbin and Patrick Owen of the
complaint - also discussed the need for a SW permit (or NE
coverage). Sent application info (and previous inspection report)
via mail 1/20/12 and will schedule site visit mid -Feb.
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
Water Supply Wells within 1500ft : Unknown
Event Type
Requested Additional Information
Incident closed
Inspection or Site Visit Conducted
Phone call
Event Date
2012-05-01 03:22:00
2012-04-25 01:30:00
2012-01-19 01:30:00
Conveyance:
Estimated Number of fish?
(Above Ground or Under Ground)
Groundwater Impacted: Unknown
Due Date Comment
closing out this incident. further in
site visit conducted (SAW and TF)
SA Wilson spoke with Deborah Du
Report Created 05/01/12 03:34 PM Page 2

Report Entered
Referred to Regional Office - Primary Contact
Incident Start
Report Received
Standard Agencies Notified
Agency Name Phone
Other Agencies Notified:
Agency Name Phone
DWQ Information:
Report Taken By:
Edward M Williams
2012-01-05 02:41:00
2012-01-05 02:30:00
2012-01-05 10:00:00
2012-01-05 10:00:00
First Name M.I. Last Name Contact Date
First Name M.I.
Report Entered By:
Edward M Williams
Last Name Contact Date
Regional Contact:
Susan A Wilson
Phone:
Date/Time: 2012-01-05 10:00:00 AM 2012-01-05 02:41:00 PM 2012-01-05 02:30:00 PM
Referred Via: Phone email
Did DWQ request an additional written report?
If yes, What additional information is needed?
Report Created 05/01/12 03:34 PM Page 3

Incident Report
Report Number: 201100805
Incident Type: Complaint
Category: Surface Water
Incident Started: 03/23/2011
County: Haywood
City:
Farm #:
Responsible Party:
Owner:
Permit:
Facility:
First Name:
Middle Name:
Last Name:
Address
City/State/Zip:
Phone:
Material Category: Estimated City: UOM
On -Site Contact:
First/Mid/Last Name:
Company Name:
Phone:
Pager/Mobile Phone: /
Reported By:
First/Mid/Last Name: Earl Bradley
Company Name:
Address:
City/State/Zip:
Phone: [phone]
Pager/Mobile Phone: /
Chemical Name Reportable Qty. lbs. Reportable City. kgs.
DD:MM:SS Decimal Position Method:
Latitude: Position Accuracy:
Longitude: Position Datum:
Location of Incident: Giles Chemical - warehouse area
Address: 396 Smathers St
City/State/Zip Waynesville NC 28786
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Report Created 04/29/11 04:59 PM Page I

Cause/Observation:
Complainant said springlwetland will be affected by new 9000 sq
ft building - wants DWQ to check it out.
Action Taken:
SAW and JM met Matt Haynes
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 lank indicate type.
Containment? Unknown
Cleanup Complete? Unknown
Water Supply Wells within 1500ft: Unknown
Directions:
through waynesville - Giles Chemical warehouse (next to main plant).
New building will be placed on existing gravel parking lot.
Comments:
Their engineer (Patrick Bradshaw - CDC) called me. I told him (as well
as Matt) - they needed to get jurisdictional determination on if it was a
stream wetland. They are planning for post construction SW controls, via
Waynesville. Clement Riddle - ClearWater- then contacted me. He will
get with Tyler (Corp) and do call. Regardless - Giles will likely apply for
impacts. Will be under DWQ criteria - can just go through Corp.
Corp said not a juridictional stream or wetland - Giles will not have to get
impact permitted. I called Mr. Earl Bradley and spoke to him about it
(4/19/11).
Conveyance:
Estimated Number of fish?
(Above Ground or Under Ground)
Groundwater Impacted : Unknown
Event Type
Event Date Due Date
Report Entered
2011-04-11 02:09:00
Inspection or Site Visit Conducted
2011-03-24 02:00:00
Referred to Regional Office - Primary Contact
2011-03-23 01:15:00
Report Received
2011-03-23 01:14:00
Comment
SAW and JM did site visit. Met on
Report Created 04/29/11 04:59 PM Page 2

Incident Start 2011-03-23 01:00:00
Standard Agencies Notified:
Agency Name Phone First Name M.I.
Other Agencies Notified:
Agency Name Phone First Name M.I.
DWQ Information:
Report Taken By:
Landon Davidson
Report Entered By:
Susan A Wilson
Last Name Contact Date
Last Name Contact Date
Regional Contact:
Susan A Wilson
Phone:
DatelTime: 2011-03-23 01:14:00 PM 2011-04-11 02:09:00 PM 2011-03-23 01:15:00 PM
Referred Via: email
Did DWQ request an additional written report?
If yes, What additional information is needed?
Report Created 04/29/11 04:59 PM Page 3

Wilson, Susan A
From: Crumbley, Tyler SAW [[e-mail]. mill
Sent: Tuesday, April 19, 2011 10:16 AM
To: Wilson, Susan A
Subject: RE: Fortner Site (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Yeah. Not a stream, not a wetland. Only input was stormwater from building, and no nexus to
TNW, kinds just petered out into a puddle of standing water.
-----Original Message -----
From: Wilson, Susan A [mailto:[e-mail]]
Sent: Tuesday, April 19, 2011 10:14 AM
To: Crumbley, Tyler SAW
Subject: RE: Fortner Site (UNCLASSIFIED)
Sounds good - I had no idea about that one!
Susan A. Wilson - [e-mail] North Carolina Dept. of Environment and Natural
Resources Asheville Regional Office Division of Water Quality - Surface Water Protection 2090
U.S. 70 Highway Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed to third parties.
-----Original Message -----
From: Crumbley, Tyler SAW [mailto:[e-mail]]
Sent: Tuesday, April 19, 2011 10:13 AM
To: Wilson, Susan A
Subject: RE: Fortner Site (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Nothing on Barber Orchard.
That's fine on the Evers.
Giles Chemical: I found that ditch non -jurisdictional. I'm making a file with a memo
regarding my findings and photos, in case there is any other issues that arise from the
project.
Thanks.
-Tyler
1

--4:•.. ,
-----Original Message -----
From: Wilson, Susan A [mailto:[e-mail]]
Sent: Tuesday, April 19, 2011 10:07 AM
To: Crumbley, Tyler SAW
Subject: RE: Fortner Site (UNCLASSIFIED)
Anyone contact you guys about Barber Orchard?
Other than a bunch of sediment in streams....
The Evers over in Hendersonville - they'll be submitting an "after the fact permit app." I'm
making them do a planting plan as resolution of the stabilization and we'll keep an eye on
it. Not a very good stabilization but it would cause too much damage to take it out at this
point. It's a minor one - just rubber stamp it when it comes in and I'll take care it.
Just let me know when Giles sends in the app (if you guys required them to).
Spoke with Clement briefly on Friday re. DWQ comments - he didn't have any problem with that
and would be sending something in soon.
That's all I can think of right now!
Susan A. Wilson - [e-mail] North Carolina Dept. of Environment and Natural
Resources Asheville Regional Office Division of Water Quality - Surface Water Protection 2090
U.S. 70 Highway Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed to third parties.
-----Original Message -----
From: Crumbley, Tyler SAW [mailto:[e-mail]]
Sent: Tuesday, April 19, 2011 10:02 AM
To: Wilson, Susan A
Subject: RE: Fortner Site (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
I hear ya! Unfortunately, the feds are available on Friday. Sorry bout that.
I still haven't heard from Clement on the Cashier's dam... I'll wait to issue that until I
do. I got your add -info though.
Anything else?
-Tyler
-----Original Message -----
From: Wilson, Susan A [mailto:[e-mail]]
Sent: Tuesday, April 19, 2011 9:58 AM
To: Crumbley, Tyler SAW; McHenry, David G.
Cc: [e-mail]
Subject: RE: Fortner Site (UNCLASSIFIED)
2

Incident Report
Report Number: 200801015
Incident Type: Complaint
Category: Surface Water
Incident Started: 03/2512008
County: Haywood
City:
Farm #:
Responsible Party:
Owner:
Permit:
Facility:
First Name:
Middle Name:
Last Name:
Address
City/State/Zip:
Phone:
Material Category: Estimated Oty: UOM
DD:MM:SS Decimal
Latitude
Longitude:
Location of Incident: Giles Chemical
Address:
City/State/Zip Waynesville
On -Site Contact:
First/Mid/Last Name:
Company Name:
Phone:
Pager/Mobile Phone: !
Reported By:
First/Mid/Last Name: Ron Moser
Company Name:
Address:
City/State/Zip:
Phone:
Pager/Mobile Phone: /
Chemical Name Reportable Oty. lbs. Reportable Oty. kgs.
Position Method:
Position Accuracy:
Position Datum:
Report Created 04/22/08 10:57 AM Page 1

Cause/Observation:
milky discharge to Richland Creek
Action Taken:
Incident Questions:
Directions:
Comments
Spoke with Jason Bumgarner, Plant Mgr. Upon investigation he found
that emplyees hadnot infromed him of problems they were having with
floor pump. Therefore it is possible they had a loss. However problem has
been fixed and employees informed on SOP
Did the Material reach the Surface Water? Yes
Surface Water Name? Richland Creek
Did the Spill result in a Fish Kill? Unknown
If the Spill was from a storage tank indicate type.
Containment? Unknown
Cleanup Complete? Unknown
Water Supply Wells within 1500ft : Unknown
Event Type
Referred to Regional Office - Primary Contact
Report Entered
Incident Start
Report Received
Event Date
2008-03-31 08:57:27
2008-03-25 05:00:00
2008-03-25 05:00:00
Conveyance:
Estimated Number offish?
(Above Ground or Under Ground)
Groundwater Impacted: Unknown
Due Date Comment
Report Created 04/22/08 10:57 AM Page 2

Standard Agencies Notified:
Agency Name Phone
Other Agencies Notified:
Agency Name Phone
First Name M.I. Last Name Contact Date
First Name M.I. Last Name Contact Date
DWQ Information:
Report Taken By: Report Entered By:
Roger C Edwards Chuck Cranford
Phone:
Datefrime: 2008-03-25 05:00:00 PM 2008-03-31 08:57:27 AM
Referred Via: email
Did DWQ request an additional written report?
If yes, What additional information is needed?
Regional Contact:
Linda S Wiggs
Report Created 04/22/08 10:57 AM Page 3

-1-, ,..)
Ai .,
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
NOTICE OF RENEWAL INTENT
Application for renewal of existing coverage under General Permit NCG500000
Existing Certificate of Coverage (CoC): NCG500-a
(Please print or type)
1) Mailing address` of facility owner/operator:
Company Name
Owner Namem
Street Address ii z). i2cirn�r-0 e— ep�C
City d ��1 tLDf�I 1!\ State �i _ ZIP Code
Telephone Number %G� `"�� — y % Fax:<9 R 'D, yce-3 D, —'A 7S IQ
Email address
' Address to which all permit correspondence should be mailed
2) Location of facility producing discharge:
Facility Name C(l
Facility Contact
Street Address
City
County \�i�li'Vif»
• ch Number
Email address
3) Description of Discharge:
State _L — ZIP Code %Qs
a) Is the discharge directly to the receiving stream? NCYes ❑ No
(If no, submit a site map with the pathway to the potential receiving waters clearly marked. This includes tracing the pathway of the
storm sewer to the discharge point, d the storm sewer is the only viable means of discharge,).... - ... . .
b) Number of discharge outfalls (ditches, pipes, channels, etc. that convey wastewater from the -property):
S
c) What type of wastewater is discharged? Indicate which discharge points,
3�Non-contact cooling water Outfall(s) #:
❑ Boiler Blowdown Outfall (a) #:
oath% o%. 1 L : DD
J L F E B 1 9 2007
ASHEVIl_LE RF.C;ON
Page 1 of 3

NCG500000 renewal application
❑ Cooling Tower Blowdown Outfall (s) #:
❑ Condensate Outfall (s) #:
❑ Other Outfall (s) #:
(Please describe "Other")
d) Volume of discharge per each discharge point (in GPD):
#001:.oQ,DDD #002: #003: L` #004
4) Please check the type of chemical [s] added to the wastewater for treatment, per each separate discharge
point (if applicable, use separate sheet):
❑ Chlorine ❑ Biocides ❑ Corrosion inhibitors ❑ Algaecide O Other
None
5) If any box in item (4) above [other than None] was checked, a completed Biocide 101 Form and
manufacturers' information on the additive must be submitted to the following address for approval:
NC DENR / DWQ / Environmental Sciences Section
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699-1621
6) Is there any type of treatment being provided to the wastewater before discharge (i.e., retention ponds,
settling ponds, etc.)? ❑ Yes A No
(If yes, please include design speafics (i.e., design volume, retention time, surface area, etc.) with submittal package. Existing
treatment facilities should be described in detail. )
7) Discharge Frequency:
a) The discharge is: C Continuous ❑ Intermittent ❑ Seasonal*
i) If the discharge is intermittent, describe when the discharge will occur:
ii) *Check the month(s) the discharge occurs: ❑ Jan ❑ Feb ❑ Mar. ❑ Apr ❑ May ❑ Jun ❑ Jul
❑ Aug. ❑ Sept. ❑ Oct. ❑ Nov. ❑ Dec.
b) How many days per week is there a discharge?
c) Please check the days discharge occurs:
8) Receiving stream[s]:
❑ Sat. ❑ Sun. ❑ Mon. ❑ Tue. ❑ Wed. ❑ Thu. ❑ Fri.
a) To what body or bodies of water (creek, stream, river, lake, etc.) does the facility discharge
wastewater? If the site discharges wastewater to a separate storm sewer system (4S), name the
operator of the 4S (e.g. City of Raleigh). % (, crz
b) Stream Classification: CAo0.na
Page 2 of 3

NCG500000 renewal application
Additional Application Requirements:
The following information must be included in triplicate [original + 2 copies] with this application or it will
be returned as incomplete.
➢ Site map. If the discharge is not directly to a stream, the pathway to the receiving stream must
be clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point.
➢ Authorization for representatives. If this application will be submitted by a consulting
engineer (or engineering firm), include documentation from the Permittee showing that the
consultant submitting the application has been designated an Authorized Representative of the
applicant:
Certification
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:
iI
(Dale Signed)
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 Article 21 or regulations of the Environmental Management Commission implementing that Article, or who
falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintalned under
Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by
a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine
of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.)
This Notice of Renewal Intent does NOT require a separate fee.
The permitted facility already pays an annual fee for coverage under NCG500000.
Mail the original and two copies of the entire package to:
Mr. Charles H. Weaver
NC DENR / DWQ / NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617.
Page 3 of 3

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
November 15, 2006
Richard N Wrenn
Giles Chemical Corporation
P.O. Box 370
Waynesville, NC 28786
Subject: NPDES Permit NCG500000 renewal
Certificate of Coverage (CoC) NCG500244
Waynesville plant
Haywood County
Dear Permittee:
The facility listed above is covered under NPDES General Permit NCG500000. NCG500000 expires
on July 31, 2007. Federal (40 CFR 122.41) and North Carolina (15A NCAC 2H.0105(e)) regulations require
that permit renewal applications must be filed at least 180 days prior to expiration of the current permit. If
you have already mailed a renewal request, you may disregard this notice.
To satisfy this requirement, the Division must receive a renewal request postmarked no later than
February 1. 2007. Failure to request renewal by this date may result in a civil penalty assessment. Larger
penalties may be assessed depending upon the delinquency of the request. This renewal notice is being sent
well in advance of the due date so that you have adequate time to prepare your application.
If any discharge previously covered under NCG500000 will occur after July 31, 2007, the
CoC must be renewed. Discharge of wastewater without a valid permit would violate North Carolina
General Statute 143-215.1; unpermitted discharges of wastewater may be assessed civil penalties of up to
$25,000 per day.
If all discharge has ceased at your facility and you wish to rescind this CoC for if you have other
questions], contact me at the telephone number or e-mail address listed below.
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
NPDES File j
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
512 North Salisbury Street, Raleigh, North Carolina 27604 NorthCarolina
Phone: [phone], extension 511 / FAX [phone] / charles.weaver0ncmail.net Natura��y
An Equal Opportunity/Affirmative Action Employer— 50% RecyclecVl0% Post Consumer Paper L L !d`L

O
1
� Y
Michael F. Easley, Governor
William G. Ross Jr.. Secretary
North Carolina Departm nt of Environment and Naturol Fksources
�nV Klimek, P.Ex Director
a Di ' of VVatef Quality
Asheville Regional Office
SURFACE WATER PROTECTION
October 12, 2006
Mr. Jim Hill, President
Giles Chemical Corporation
Post Office Box 370
Waynesville, North Carolina 28786
SUBJECT: Compliance Evaluation Inspection
Waynesville Plant
Permit No: NCG500244
Haywood County
Dear Mr. Hill:
Enclosed please find a copy of the Compliance Evaluation Inspection form from
the inspection conducted on January 9, 2006, Ms. Linda Wiggs and I of the Asheville
Regional Office conducted the Compliance Evaluation Inspection. The facility was found
to be in Compliance with permit NCG500244.
Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff have any questions, please call me at [phone].
Sincerely,
rry Frost
Environmental Engineer
Enclosure
cc: Central Files
Asheville Files
2090 U.S. Highway 70, Swannanoa, NC 28778 Telephone: [phone] Fax: [phone] Customer Service 1 877 623-6748
N'p�thCarolina
Naturally

United States Environmental Protection Agency
Form Approved.
Washington, D.C. 20460
EPA
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCs)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NI 2.1 51 31 NCc500244 Ill 12I 06/01/09 117 181 rl 191 SI 201
IJ L:J• L J
Remarks
21IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CA ---- -----------Reserved----------------
67I 169 70J_j 71 I I 721 NJ 731 I 174 75I I I I I 180
I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also Include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
Waynesville plant
11:00 AN 06/01/09
02/08/0.1
Exit Time/Date
Permit Expiration Date
102 co,mnerce at
Waynesville NC 28786
01:00 Ph] 06/01/09
07/07/31
Name(s) of Onsite Representative(s)Tlles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Officiallritle/Phone and Fax Number
Richard N Wrenn,PO Box 370 Wayynesville NC Contacted
28786/President/828-452-4784/8284524786 Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit E Operations & Maintenance E Facility Site Review
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signatures) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Larry Frost ARO WQ//828-296-4500 Ext.4658/
`/-
Signature of Management Q,i ,Reviewer Agency/Office/Phone and Fax Numbers Date
Roger C Edwards ARO WQ//828-296-4500/ 10/y 96
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
NCG500244 I11 12106/01/09 I17 18'-'
(cont.)
Section D: Summary of Finding/Comments (Attach additional sheets Of narrative and checklists as necessary)
This facility has the NCG50 permit for non -contact cooling water taken from Richland Creek, it is used in the
plants barometric condenser and returned to Richland Creek, there is no product contact.
This inspection was scheduled as a result of a staff member, of the Asheville Regional Office, noticing an
unpermitted discharge from the front of the building. The leaking material was the result of a floor with a low
spot, that would gather water from the tank area and overflow to the front of the building. A sump was cut
into the floor and pump inserted, the pump now pumps to the sewer. This was an excellent solution to
eliminate the discharge.
It was noted during the inspection that there are drums and buckets of chemicals stored throughout the
facility and property. It is the inspector's recommendation that all chemicals be stored under cover and on or
within secondary containment. The reason for this recommendation is prevention of spills and the proximity
to Richland Creek.
During the inspection it was noted that the wall/floor junctures in the processing area had separated and
that there was evidence that spills from this area had reached Richland Creek at some point. The facility is
expected to supply the Asheville Regional Office with information, in the next 30 days, regarding a proposed
schedule for the repair to this area. The repairs should be done in such a manner to prevent spills to the
Creek.
The facility's permit requires flow, temperature and pH monitoring, these must be done semi-annually.
Furthermore, the resulting monitoring data must be kept on site for a minimum of three (3) years.
It was noted during the inspection of the boiler room that there is a hole cut in the wall that allows pump seal
water and misc. leaks to discharge toward the Creek. The hole should be filled and another method should
be found to eliminate this problem.
It is the recommendation of the inspector that the facility establish a formal/written pollution prevention plan
and spill reponse plan, because of the proximity to the Creek of both dry and liquid chemicals, including
sulfuric acid. The establishment of these plans may prevent spills in the future.
This permit is scheduled for renewal in the next year. The Division will notify you with further information, by
mail, as this time approches. When you receive your renewal notification please update your contact
information.
The inspectors were very concerned about the pipe rack and the filtrate conveyor that span the Creek.
Neither the rack nor the conveyor have drip pans under them, to prevent spills to the stream. The inspectors
recommend that you consider the installation of drip pans to contain spills from reaching the Creek.
Many thanks to the staff and management for your time and cooperation during the inspection.
Page # 2

Permit: NCG500244
Inspection Date: 01/09/2006
Owner -Facility: Waynesville plant
Inspection Type: Compliance Evaluation
Operations & Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
■
❑
Cl
❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑
❑
■
❑
Judge, and other that are applicable?
Comment:
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
❑
■
❑
Is the facility as described in the permit?
■
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
■
❑
Is access to the plant site restricted to the general public?
■
❑
❑
❑
Is the inspector granted access to all areas for inspection?
■
❑
❑
❑
• 1il'ni_i I
0
Page # 3

RE: Illegal discharge
+~
Subject: RE: Illegal discharge
J g
From:. "Jason Bumgarner" <[e-mail]>
Date: Thu, 14 Sep 2006 09:31:06-0400j�,sJ
To: "'Linda Wiggs"' <[e-mail]>
Good morning Linda, V'G ��� ✓ "" "',
I have looked at my schedule in October,.and the 2nd or the 9th looks +, D
good if you are available. Just let me know and we can set something up.
Thanks,
Jason Bumgarner
Giles Chemical Corp.
PO Box 370 - Waynesville, NC 28786
[e-mail]
Office - 828-452-4784-13
Fax - 828-452-4786
Cell - 828-508-4377
-----Original Message -----
From: Linda Wiggs [mailto:[e-mail]]
Sent: Friday, September 08, 2006 10:36 AM
To: Jason Bumgarner
Subject.: Re: Illegal discharge
Jason,
Thank you for your response. Please send me a cc of the procedure.
I realize this is likely an innocuous substance once it has been assimilated
by Richland Creek, but it is still considered an illegal discharge. Prior
to the river assimilating, at the point of discharge, there could be
negative effects to the aquatic life. We have received complaints about
this wash water discharge, as well. This discharge has to stop and I am sure
we can deal with this without making it a formal issue. There are some
other stormwater issues we may need to discuss.
I would like to schedule an appointment to visit the site in October to
further assist. Please contact me with your availability, Mondays and
Fridays are best for me.
Thank you, Linda '
Jason Bumgarner wrote:
Linda,
First off let me apologies for taking so long to respond. The
discharge from the plant is of course Mag-sulfate or Epsom Salt a very
inert, natural, non -hazardous material. The area where the discharge
comes from is our Filter Press room. The filter press is cleaned
daily and the entire area is washed down on a regular basis. The main
problem we face, and you saw, is that any percentage of Epsom salt
washed up will leave a white residue no matter how week the
percentage. The floor in the press room is sloped to a central drain
in the middle of the room. If an employee is washing the floor down
and keeps washing toward the door it will over run the slop causing it
to run out on to the side walk and down the street to the storm drain.
Since this is caused by wash down and the MgSO4 content is always very
diluted and it should not be considered a threat to the Richland
creek, however, I don't want anything like this to be an
issue. I will address this immediately. I have written and posted a
new procedure to assure that we always wash away from the doors toward
the sewer drain in all areas. Feel free to contact me personally if
you think there needs to be more done or this is unsatisfactory
solution.
1 o12 9/20/2006 10:05 AM

RE Illegal discharge
I want to make sure this is not an issue in the future as well
Thank you,
*Jason** Bumgarner*
/Plant Manager /
/Giles Chemical Corp./
/PO Box 370 - Waynesville, NC 28786/
/[e-mail]/ <mailto:[e-mail]>
/Office - 828-452-4784-13/
/Fax - 828-452-4786/
/Cell - 828-508-4377/
Linda Wiggs - [e-mail]
North Carolina Dept. of Environment and Natural Resources Asheville Regional
Office Division of Water Quality - Water Quality Section 2090 U.S. 70
Highway Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
2006-0901 -Floor Washing.doContent-Type: application/mmord
c
Content -Encoding: base64
2 o1'2 9/20/2006 10:05 AM

rk

�i,Les ��zemi.eaC eoz�.o'taElorz
TELEPHONE: [phone] FAX: [phone]
P.O. BOX 370 214COMMERCE STREET
WAYNESVILLE. NORTH CAROLINA28786
1
1 _
July 31, 1990
Mr. Roy M. Davis
NC Dept, of Environmental, Health &
Natural Resources
59 Woodfin Place
Asheville, NC 28801
Dear Mr. Davis:
For your information here is our synopsis of the sulfuric
acid leak at Giles Chemical Corp. Friday morning, July 27, 1990.
- We were unloading 93.4% H2SO4 from rail car UTLX 15088 to
our storage tank #1.
- Unloading started around 9:30 a.m. and the leak was detected
about 10:15 to 10:30 a.m., sameday.
- Leak occured in a 2" diameter flexible hose - the crack
was approximately 1" horizontally across the hose.
- Unloading pressure - about 35 PSI.
- H2S0 storage tank #1 contained approximately 14,251 gallons
before we started to unload UTLX 15088 which contained 12,578
gallons of the acid.
- When we finished unloading UTLX 15088 into our sulfuric acid
storage tank #1, we had 27,493 gallons of stored acid.
- Measurement error with our tank calibration ± 2.5 - 3%.
- We will cooperate with the authorities, and continue to_
police the area until no more dead fish appear.
The conclusion is we cannot precisely determine the amount
of acid lost. Our best guesstimate is less than 150 gallons
were lost based on the enclosed calculations.
Sic el�_ /
chard N. Wrenn, 7r.
Vice President,
Giles Chemical Corp.
RW/ch 1` E.
cc: Mr. Eddie Singleton
Haywood County Emergency Management
State Emergency Response Commission
Ache:^Ile oe:�i;x . ;;tice
A0e'01;e, North CarcGna
PRODUCERS OF MAGNESIUM SULFATE SINCE 1950

#1 ACID STORAGE TANK
Hemispherical Head = 513"
Tank Diameter = 10'6"
Length, weld to weld = 36'4"
Tank volumn full = 28,054 gallons
Measurement error = 2.5 - 3% estimated
Volumn before unloading acid = 64/126 = 50.89% = 14,251.4 gallons
Volumn after unloading acid = 120/126 = 95%, = 27,493 gallons
Volumn of UTLX 15088 = 12,578 gallons
14,211.4
27,493.0
+12,578.0
-26,789.4
26,789.4
703.6
28,054 X 37 = 842
- 703
139

go
CILES CHENUCAL 0DRPORATION
COMPANY PROCEDURE
FLOOR WASHING
Page : 1 oft
ReDatevision 09/01/06 1
Author: JasonBumgarner Report#:
Personnel responsible:
All
Safety:
Safety shoes and safety glasses are required when working in the plant.
Summary:
To eliminate what the town considered an illegal discharge into the storm drain. When washing up
floors or cleaning up after a press run, we should always wash the floors toward the floor drain to always
avoid brine going out on to the street.
Procedure
1. In all areas, when washing down the floors, wash toward a floor drain and away from outside doors.
2. If there is a spill or leak, immediately wash toward floor drains and away from the outside doors.
3. If for any reason weak brine makes it to the side walk / street, wash down thoroughly to eliminate
any residue
A copy of the letter from North Carolina Dept. of Environment and Natural Resources Asheville Regional Office
Division of Water Quality - Water Quality
To Giles Chemical,
On August 28, 2006, I observed and photographed .a discharge from Giles
Chemical, Smathers Street facility. At the time of the photos the discharge
was basically finished, however remnants of liquid and, salt residue were
apparent with a trail to the storm drain. Attached are two photos. The
discharge reached the storm drain, which ultimately flows to Richland Creek.
The photos reveal an illegal discharge from that facility or a spill. Please
respond with appropriate actions taken to avoid this in the future.
Thank you, Linda

Re: Illegal discharge
Subject: Re: Illegal discharge
From: Linda Wiggs <[e-mail]>
Date: Fri, 08 Sep 2006 10:35:59 -0400
To: Jason Bumgarner <[e-mail]>
Jason,
Thank you for your response. Please send me a cc of the procedure.
I realize this is likely an innocuous substance once it has been assimilated by
Richland Creek, but it is still considered an illegal discharge. Prior to the
river assimilating, at the point of discharge, there could be negative effects to
the aquatic life. We have received complaints about this wash water discharge as
well. This discharge has to stop and I am sure we can deal with this without
making it a formal issue. There are some other stormwater issues we may need to
discuss. I would like to schedule an appointment to visit the site in October to
further assist. Please contact me with your availability, Mondays and Fridays are
best for me.
Thank you, Linda
Jason Bumgarner wrote:
Linda,
First off let me apologies for taking so long to respond. The discharge from
the plant is of course Mag-sulfate or Epsom Salt a very inert, natural,
non -hazardous material. The area where the discharge comes from is our Filter
Press room. The filter press is cleaned daily and the entire area is washed
down on a regular basis. The main problem we face, and you saw, is that any
percentage of Epsom salt washed up will leave a white residue no matter how week
the percentage. The floor in the press room is sloped to a central drain in
the middle of the room. If an employee is washing the floor down and keeps
washing toward the door it will over run the slop causing it to run out on to
the side walk and down the street to the storm drain. Since this is caused by
wash down and the MgSO4 content is always very diluted and it should not be
considered a threat to the Richland creek, however, I don't want anything like
this to be an issue. I will address this immediately. I have written and
posted a new procedure to assure that we always wash away from the doors toward
the sewer drain in all areas. Feel free to contact me personally if you think
there needs to be more done or this is unsatisfactory solution.
I want to make sure this is not an issue in the future as well
Thank you,
*Jason** Bumgarner*
/Plant Manager /
/Giles Chemical Corp./
/PO Box 370 - Waynesville, NC 28786/
/[e-mail]/ <mailto:[e-mail]>
/Office - 828-452-4784-13/
/Fax - 828-452-4786/
/Cell - 828-508-4377/
Linda Wiggs - [e-mail]
1 ot2 9/8/2006 10:38 AM

a
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6132***** 04/23/91
ALLEN LANG
PT
Prep NC DEPT OF INRCD
all;OOD
59'.WOODFIN PLACE
xf EASHEUILLE NC 28801
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o 1'.By,DAN
lResou
gist
al Corp.- sp6nd
nesville '.',fisb'o,
14jfday,mornirig' jpifigout fish all the s$Jr i
,4
way to La I ke junaluska., �the!company's .,trar
president -said Monddy.r,v! !)0" .Tall
-iLake Eicidity!,levelsixeturned,to nor- -pre
mEil overlilieweekeri0l.,bui state offi-'-, ',inju
cials collected- water' samples Friday
afternoon,ivhich-were,1;000,times more inoi
acidic than normal lakewater. Wel
About 40,000 fish&werb, killed as the , Y the
6cid moved downstream, N.C. Wildlife .Ilif
1
'gin.
omi�issfldrffsh&i6i' bioi :,pure
solution of
,lemhj�ifis estimated after
.-,manvfa`ctureof e
weekend skimming dead
'Welch, said he
with Wildlif6offii
re
1-,'fiornjh6,spillz killing fish as if
r,nbt,d6t6r'tn.ih,ethat' if,",y�s "said Roy M."Davis, AshbOle rei
i 100:'gall6fis ;of material,':'supervisor for', the N.C: 'Divisi
I Monday. He estimated that Environmental Management—,"
it was Ies§'than 50 gallons:
uses)'�Jict
�pany,ffl-4 percent (See GILES on Page 2A).,,'
' ,-,
1.
%
�/ t� � k \I/���n J' r a i....,� bJu
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pabs.
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i ,tV� �Pl "?"i,
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Wij
V(704) 452-0661 UAR�Popy;l`;
henuc ai- sl-', I'
ll t { a
77-
Tuts
brown., trout was one Qf. 10,000 fish', Wled, ay
shot to leg end's' brothers
squabble
over ,family garden
ByGREG COOK owned by their mother, Lois Wil-
Staff Reporter liamson, not on Jack William
-
A Canton man shot his brother son's property.
in the leg Friday afternoon dur- "He didn't get permission to

, 2A—The MOUNTAINEER, Waynesville, N C ,14Ionday,rJuly, 30; 1990
t, �.
Giles, spills - �ti e �I
u
S�
sulfuric acid t$ ; 4�
r G t
i , i w�Fr" F t6 F`'�' 1 V'7. •h ' a •b ' { i L ws '"4` s" 'n „ , ,t A�-d
I creel��
Us:fill
'- (Continued from,Pagef72,')�
"As of noon todaywe're.seemg
a otr of dead fish bavis? said
Friday as he and anottier,�DEM'+`P9
'Official collected watensamples,
:at fake Junaluska. `tWe're_see, +° ,
mg live fish here but (closer t0
the spill) we're�aeei6g W4`at(apMN �
pears,,to;be a total kiQX of.rtje
fish.,,, i' irey`�> a ..q ^ra". A„ ..�,•e.:$«;H "*R ,.�
1 By about 3 p.in 'Frido, after ^ `
noon the worst7xof `xthe spill
leached, Lake'Junaluska,.=.where
Davis collected:,a water sample
with a PH. of 4.0 at the' U S
Highway 19-23 bridge#
, The pH of. 'typical mountain
water 'is normally between 6'0� M- -
and i ; Davis.said nrn a
The PH scale'- measures the
'acidity ,;and alkalmittyyof sub
�. „a
,stances from 0' t0 14 Wlth 7.b d le d y d=' a 4tye�, ax w- n
4 . .� , , Y""i� , ,.k t Y > 'Ny'k�" n .ram.; t lE• 'ip g .t .NICE .o�'t ,. f .k s i'Hx S r.. i
y F R , { My "4r{ �, 7 rW' x� +��.f f 'i'..' $� �• E `q: '%k
being :neutral.° Lower fiuinbers�
11
t �S A :' y4u A 4 li ,1x 3 t %i' i•+^',f9'"`fi» °y f t a yfrv..� y. n •.x Y4 Y:` ,.
'are°:acidic; higher''numb'ers,aFeh r
121
alkaline and each value„, is 10 � ,r r �3 . 3a� � to
times as lntensL thefl?.reYl0u5;��'r*, a„ a .t ° f �ju r; ' L{. �`'�5p; asYa; `?w"3` ' p,�ahm� t„� ��,
one A"pH of 9°Udls rab0lt 1,000i; �i n � as „ t` i t)' z cj z3G s .1r + c
imes.. more aciaic,,thanl a a * „°r; a +: ' Y- 4 s hx 't` `,'t Rat r ?„'', ° `v?L# 1"kl �' i*' ts� t'{ n '.15 na ,tjW, 'I
ter aidfDr`3R_ick Maasf'dr e�et0 ; yf i4 kzaz�`fyr�"mJS� "+spe g �� a
x
+ �13x f':" ry a+,a"' A' k , ,�,,�tYF h°}A"4 5k "^^. �'SJ T„ i Y 7 +. 9.N , v.
tal @ual ty Insti$ute v,r$ 1k i f i J Dan Conover Ph
w } Y N '�>� 'Wildltfe�$esour s ents collet£ s�Cmple,$, nday,, m Lake Junaluska
s.,Zsh�cannot live= in glow H v r t W r�
�# i-•c 1. t, Ile G: v� 4t' ��.K� I�y,FE
water�because their gills cannorf ; i nk !gyp 4 p{ J FS, 3: ';k✓` i l ,1t !n ar• .! „krrce Sr.. as
rrbeessY ap d andmtenseoshock e skill' >D� sion"oME: kit`6"m t'alYMan
ie,othhi ways,as well Miss saidyi gage >�entm`.shyevlllg S:dl(f'7lealth'�
ISM tn,',this case you;lia've a very; inspe 'or'Ca
ri
e�itretne*,shock�aud>t� eireaa�e �r� ^�
'=Datvis, aid:�ie recei ed WWord of �• � � '
numlersJn 3Potentiall�effe t5�`40n y� "•'`" n^. emr{ax � J'., q �,:' - *r niy � � �" � i�� rb ?"�rz"�'` ac � `:�
fish; Maas said"The`fish�ooulit and„fellow-,. El1TwoM'r.Mike,
have'ilied abruptly ,due toy th
#paarykOn,�@xriv�edri�i°o-°�aY,�0,2dt�� `.�.
shock to their'.iiervous systems, Cpuny a little more than an hour
or .they could:h'ave died:=:more later, +'
+F�>.t �a �" 4,Y ;Rxt�•cy v <� �y-t x # c '�#`'a��-'� + c: r•.•
slowly from lack of oxygen >he ' 'i to iday Fftern ozix r n
said-. 4 i !u � ,
4_'GTgs Chemical Company RresiT
Und&j4state'law, "e;s ,ws re -dent Howard Splilt:s confirmed. �t ' v n ;` % T hid ` >^ • _, �
P „ p ether had been a spill_that morn
s onsble for the�cost of re lacing
the dead fish a danaust pay�ttie An '8t�thq'glant;abktfsai tYwa ti "' 4, p 1' ,•
B R
bill 'for the sta'iq�sliijves i a}�ion" 'pothmg"Seriou `s ,S"'�+ a,M
Davis.said'The"'company:mpy �It wasn't anythingao'worry`,i�, r
also: be'liablemfor fines under about, =Splittdaid +'Itwas just? r i i , v� .-•�
state water 1prptgetio la , h
'said ii r� f4 i� 'u riwllthi P R,ff1e•r1
'°+State law provi$es�penal-ies as '�� Glenn Ml er `LakesTunaluska �„ � ,^ �
high a's $10 OOO.per day fOr'yiola !Assembl 'direntgr and Jay-, "
tion"s -of its water qualttyhstan' Langford,_ A'e.iAss�mb y s main;'
dards, and eWidence of pH as low ten�tcg ;S?eix�;go`ri, ,erel 0n
as 4 0' is m clear violatton';of the hand a ' 1 is Parker
state standard of 6 0 Davis�said , «a bh { Y du, <srT,
from e` mlipjife,Iri es�urces.
.Thernormalrfinetis sulistan, t„ i„ u.<f> ^' _
tlallyless he said t,lys�ro;�issnst C6mmission'iand�pr.Haywgp{t
cWelch�saidhe'waslaWareyof$ihe`' Shn{1fiiside'utmdij a+eted6kT)e t! �-
,penalties `andrtl atstheicoiiip v `'noi�t f,:R chlandeCreek vher`eii *•
;viouldifulfill ;its
+±till!' e'tt#e�e�i6i yam" lee Jtinalusk` rg.4d;i �� v _a,$v%zn�wy`S( ,x ,t ,�d *srrie,,l_.,- r,;,r,,i, :
'added; that rhea " ��«'OU11Inia`riirdoncesna:s+'ho�tv'fai?' �d?"?iuska'Asembly t fficial�-tfrom'� spill Freday�afternoonr by -,thy �,5. I Na;
` np �" • `' ` p - left' AandallkDills;'asec+q t ,: officer,$ Glenn' { 19 $3, bridge, �-;,where state,:Wficial_ ..,un
vorlcto�fmd adedrsafegatirdst0tfiSh7Ciz�i ht god and loq. ,, tiA i- ,= i7,X� r�,
prevent trhe acci,'denttJr0I"Lreoci can ,up.;after�arcSlnM,ar in: artlri dire��ort an day,Langfords, amte, water,1,000 times'mor' acidic.than normal.
CllI'ring rJ) d ? il.r, �sflt YtPTttLia[trh�;S3Ybw 3�.fy, , f �; r3,7a1, S Rt R:- ce superisor,vdls''eu s the`effe, t�of the i
'T111515 the.fllst time: -we've:"' + f '
S✓c+n3,h's fylvf .,,
hadSi:a`„problem'1 likes this eland ti.• 1xo, y a111r�* Ali zrpsa iiu ?i ,. aj,_ihw a P �, r n r, tr,yrs°r;
We.ve;ibeenr here islneei 950�'i{ 5 t�Yf1; Ali147 liu#i , H , Mill
�i F ¢xita }}'}nrk i� S•t }5 ?�k; if=y tl ,i',:y1 xpo • p x. :•
WelchJsaidi.I:mr:cnrrenti "
>� g.
ing on finding a>betten andsaferi11> s i "z{` " _ ?,o{ i v it i �� •mot rm n:' ��
ivay; Up' 'untilYy+this "`ointi we ,"" 18}iNICOL�E�STERGHOSisr`" h} p01 to ca£ehMany $sh-= atr+ ons eXyplamed , Only species fled bvany reassurances.
thought ouri,•iiiamtenan¢:e?land , . �x rl''taffReporte'E+e}`n,; �d$ has il0usilnds, washedon`toyxfhatuhave�,gillstvqul3be,.affected* Clemmons'saidithe Wildlil
checking procedures=' eTe3suffi` _ �: ;'rns i, �hitt� rs `r 1 4 s��is "� ell?aiiks o>, i1C and Creek.' "1?Y#t3i{s iIs'sr]ikdisoalung;them m .Commission has talked with tt
ayw�gtla,ountyb";ryes)flegig,Offictalsye"stiMate;1p00Qifish rinGgar,,W,hats itzsr doneEs -town of��_Waynesville`about se
3Samplestaken=fromoLrakes,Ju3t.efishermen-pnd rseyshow<parti diedl iFridaY,srspiil" �ti`' burned„them _� :, ting:up"the creekas a stocker.
nalnskaFthiS��weekend!)';indicate"','repasis. "sioo�d'at�,'th riles%iota, i) razferpicked(a�tiff native Bnt Don"Skehy, a Waynesville-?locataon:for troaf, but thewatE
that thei'spill<no 'longer::poses a `,-Richland sCreelE?= rid y pisialy � brown touWfrom ahe v t@rs pf .rwres dent Who entered his horse In ;has not yet tested clean enough l
threat=to'fish;,=Davisrsaid2 ,' }'? a� : dismaydd andlcorieei?nggd`as 4nasy. tbgycregFCg,pehitjci; lie Aygesi@le�_ the,+ eekend`s shpw� wasn't sates, ,austain>a trout population.
; ';Ttie acid•is bY,now diluted,by` ,'tsesidf �e d £ish,floa,ed by�beli egeatio'}i 13 ks�
theaar e',,voluine'of wateii':in` the- .; upC}n th`RW646Wi V ter ri k u,= 4a ' a out `'two acs. of �'anr mea! }� > , ' .•. ��s.:..
g .7:p ��. r • ,zr. nur , -s <tf„x: s.. .,•,.r�.xw ^mt`aa� e ! „Y,ati ,/� ,, i ,„,� s•/`is/bs.l i..,U..c.;. t
lake;lf.,he-isaidR`iWateti saiiples+ t;,^ScThe fuilie`dongteamy{iu s re�•18�me11es;Fpaziez said as a ors
tale'en�fromHthe�lake indicated;�a°;"P go; �the�4vo„%se rit; ge`tsNbecaus? he pointe our` ifssdisc0loiation} ' ;
pH!leuel of 6 9; he'sa{d G d t ;d1„s�thg e',4T,ej ,?llgen isti;"concentra,', yandjack'kof�protective c%ating
yWoidofthefishkillreached'they`, ;,tto sdoyt�ftheee`�l,(obsgriiedz.Bobj ",Whatever"s .done this .has ? ;t"
Haywood�CountyHealtN?I)Eparti' F�z>�ifaynesvllUefresiderlt wapedo'ufeverythirig,'causeZve '+Still, a eha'nc°e off, showers
merit's envir`oninCntal }iealth Seca ' whgjtaokristtishepg •pole toYLakex been up°and down;this creekaand s ` °
lion. -Friday moimng and, ithe= StjnaluskaFaearlien,li&�theiaftenr-, IhavenSE senanythmgmpvmg, _i; Again there;,is not a'lot'of change to. report about the
section's''secretary passed the noon , k, �iesaid _ ; g weather. The forecast is much the'same as it has been for
information along,,to the hj C He soonpfound+he didnrt need 'The+fish diG�lgfolJawing+aFF,rt,fri ;seYer''al,weeks:,
z r 'wf, 7 tt i ' g y partly cloudy with a': slight chance of
°s 1 ,day mornm industrial accident tern will be
AT f•Giles,G�hemieal`Corp on -Coin afternoon! hoovers and thunderstorms. The high will be in
yr ,
Y erne Street, where ar load of the 80s Tonight willbe,partly cloudy,with the'low expected
I percent, pure sulfuric ;acid r t in the mid=80s , t • ` a ? F
r, Calen arof =v��Yl "solution. spilled into Richland Thursday will be partly cloudy with a90'percent chance
w n, t 0f afternoon and;evenin showers or thunderstorms. High
�k _ j�Cree}i co tam�wating tk waters g
froma lippant to, LakeJuna 6 ri3ilibelin:e`upper80s , .•':.
/.� ,n V ihe' extended forecast for Wednesday through Friday
M t ;Yirw*,..,t -' ` , t la+zn� „i"d eR '"! luska,; ut P rt1es,Say r .2i tip a
O1tC]ay� Jil t' y3Qi ly )', L+1, „C,9ltntwr ypattan acjlr, i njer. x,� Althou `authoiittes would not calls for'partly cloudy skies on Wednesday and Friday with
VJ
T ru ; iHazelwaod `Plannin f end! ep�e� nlFlosp eerOfficfe # ��j l nJ conflrm� thg pill un(11 Monday afternoon showers or thunderstorms. .
P. g, rC ^Nrntvf`vaP.ig` 'morning,Fumors'spreadr5pidly
Zoning Board `r will',meet at, ,noon, Silver,Bluff`Nursing,Ilome Fridav'and'ove the weekend.

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Giles Chemical - Waynesville Plant NOV-2014-DV-0211 NoV
h irli11tl11'11'lllll llp ll11111i Ili 6161,11 oil I 10111 i,1,,u'll

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