NC0004952_Regional Office Historical File Pre 2018 (3)

WWer Resources
GVVNC2O MENTAL.QUA!TY
February 9, 2018
Ms. PEM Carter, Sr. Environmental Engineer
CNA Holding, LLC
2525 Blacksburg Road
Grover, NC 28073
Dear Ms. Carter:
_SOY COOPER
LJ ttt� CF AEL S. REGAN
Governor
Secretary
LINDA CULPEPPER
Interim Director
Subject: Compliance Inspection
Celanese —Shelby Plant
NPDES Permit No. NC0004952
Cleveland County
Enclosed is a copy of the Compliance Sampling Inspection for the inspection conducted
at the subject facility on February 7, 2018, by Ori Tuvia and Maria Schutte. Michael Sparks,
Randy Turner's and your cooperation during the site visit was much appreciated. Please advise
the staff involved with this NPDES Permit by forwarding a copy of the enclosed report.
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact Ori Tuvia at [phone], or at
[e-mail].
Cc: NPDES Unit
MRO Files
Sincerely,
Ori Tuvia, Environmental Engineer
Mooresville Regional Office
Division of Water Resources,.DEQ
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] , Fax: [phone] Customer Service: 1-877-623-6748

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 15 1 3 I N00004952 I11 12 18/02/07 17 18I,.I 19I I I 20I I
�I
211 I I I I I I I I. I Ii. I:.I l i i I I I I I I I I I I I I I I I I I I I I I I I 11_., r6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --- Reserved --
72 � 73]74 751 I I I I I I I80
67 1.0 70 LJ 71 [itJ
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 oermit Number)
10:OOAM 18/02/07
13/11/01
Celanese -Shelby Facility
Exit Time/Date
Permit Expiration Date
NC Hwy 198
12:20PM 18/02/07
18/08/31
Shelby NC 28150
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Michael D. Sparks/ORC1704-480-5793/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Nicole Coffee,2525 Blacksburg Rd Grover NC 28073/f704480-5728/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit E Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Maria Schulte p Division of Water Quality//704-663-1699,
Ord A Tuvia d MRO WQ//704-663-1699/j J
Signature of Management Q A ev ewer Agency/Office/Phone and Fax Numbers Date
a
Andrew Pitner e.A RO WQ//704-663-1699 Ezt.21
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type
NC0004952 I11 12I 18/02/07 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On -Site Representatives:
The following Company personnel were in attendance during the inspection: Ms. PEM Carter/Sr.
Environmental Engineer; Mr. Michael Sparks/ORC; Mr. Randy Turner Lab Supervisor; and Mr. K&ehae+
Dween/Backup ORC
fl-
Page#

Permit: NC0004952 Owner -Facility: Celanese -Shelby Facility
Inspection Date: 02/07/2018 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
M
❑
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: The subject permit expires on 8/31 /2018.
The facilty permit limits are in pounds/day rather then mg/L
Record Keeping
Yes
No NA. NE .
Are records kept and maintained as required by the permit?
M
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
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?
0
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
M
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24n with a certified operator
❑
❑
0
❑
on each shift?
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
E
❑
❑
❑
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?
M
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
Comment: The records reviewed during the inspection were organized and well maintained. DMRs,
COCs Bench sheets Calibration logs and ORC visitation logs, were reviewed for the
period
February 2017 through December 2017.
Laboratory
Yes No NA NE
Page# 3

Permit: NC0004952
Inspection Date: 02/07/2018
Laboratory
Owner - Facility: Celanese -Shelby Facility
Inspection Type: Compliance Evaluation
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Comment:
Yes No NA NE
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FeCV.1 nitrogen, total phosphorus, pollutant scan) and ETT, Inc. (toxicity) have also been contracted
to provide analytical support.
The laboratory instrumentation used for field analyses appeared to be properly
calibrated/verified and documented.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Yes No NA NE
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■ ❑ ❑ ❑
Comment: The subiect permit requires both composite and grab effluent samples. Since the past
inspection the ORC and staff have begun to perform/document periodic aliquot verifications
on the composite sampler. at the time of the inspection the effluent sampler pulled 155 ml
aliquot.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable M ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The wastewater facility appeared to be properly operated and well maintained. The facility
staff incorporate a comprehensive process control program with all measurements being
Properly documented and maintained on -site.
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
Page#
4

Permit: NC0004952
Inspection Date: 02/07/2018
Bar Screens
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
Grit Removal
Type of grit removal
a.Manual
b. Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Comment:
Owner -Facility: Celanese -Shelby Facility
Inspection Type: Compliance Evaluation
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
Comment: The process wastewater flows through three equalization basins (in series) prior to
• ❑ ❑ ❑
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• ❑ ❑ ❑
❑ ❑ M ❑
❑ ❑ M ❑
❑ ❑ M ❑
❑ ❑.■ ❑
■ ❑ ❑ ❑
combining with the domestic wastewater. Sodium hydroxide (pH adjustment) is added to
the first EQ Basin and phosphoric acid (nutrient supplement) is added on an as -needed
basis at the third EQ Basin A fourth equalization tank is also available for emergency
situations.
Chemical Feed
Is containment adequate?
Is storage adequate? .
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 5

Permit: NC0004952 Owner -Facility: Celanese -Shelby Facility
Inspection Date: 02/07/2018 Inspection Type: Compliance Evaluation
Chemical Feed Yes No NA NE
Are backup pumps available? E ❑ ❑ ❑
Is the site free of excessive leaking? ❑ ❑ ❑
Comment:
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/I)
Yes No NA NE
Ext. Air
Surface
■
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❑
❑
N
❑
❑
❑
❑
❑
EEI
■
❑
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E
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N
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Comment: Both aeration basin trains were operational and in service at the time of the inspection. One
of the surface aerators was out for maintenance at the time of the inspection.
Secondary Clarifier
Yes No
NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
N
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
E
❑
❑
❑
Is the site free of excessive floating sludge?
E
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
E
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'% of the sidewall depth)
0
❑
❑
❑
Comment: Both secondary clarifiers were operational and in service.
Pumps-RAS-WAS Yes No NA NE
Are pumps in place? 0 ❑ ❑ ❑
Are pumps operational? N ❑ ❑ ❑
C
Page# 6
1

Permit: NC0004952 Owner -Facility: Celanese -Shelby Facility
Inspection Date: 02/0712018 Inspection Type: Compliance Evaluation
Pumps-RAS-WAS Yes No NA NE
I
Are there adequate spare parts and supplies on site? ❑ ❑ ❑
Comment:
Lagoons
Yes No NA NE
Type of lagoons?
Aerated
# Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
# Is a re -circulation line present?
❑
❑
M
❑
Is lagoon free of excessive floating materials?
M
❑
❑
❑
# Are baffles between ponds or effluent baffles adjustable?
❑
❑
M
❑
Are dike slopes clear of woody vegetation?
0
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
M
❑
❑
❑
Are dikes free of seepage?
0
❑
❑
❑
Are dikes free of erosion?
0
❑
❑
❑
Are dikes free of burrowing animals?
0
❑
❑
❑
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple
❑
❑
❑
locations?
# If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
M
❑
Is the lagoon surface free of weeds?
El
El
El
Is the lagoon free of short circuiting?
M
❑
❑
❑
Comment: The facility is equipped with three polishing ponds (operated in series) and two sludge
holding ponds.
Filtration (High Rate Tertiary)
Yes No NA NE
Type of operation:
Down flow
Is the filter media present?
0 ❑
❑
❑
Is the filter surface free of clogging?
z.
M ❑
❑
❑
Is the filter free of growth?
❑ ❑
❑
Is the air scour operational?
❑ ❑
0
❑
Is the scouring acceptable?
0 ❑
❑
❑
Is the clear well free of excessive solids and filter media?
❑ ❑
M
❑
Comment: All six tertiary filters were operational and in-service.
Page# 7

Permit: NC0004962 Owner -Facility:
Inspection Date: 0210712018 Inspection Type:
Celanese -Shelby Facility
Compliance Evaluation
Flow Measurement -Effluent
Yes 'No NA NE
# Is flow meter used for reporting?
M
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
N
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0,
❑
Comment: The flow meter is calibrated/verified on a quarterly basis and was last calibrated/verified on
1/9/2018 by the Company's I & E personnel.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
M
❑
Comment: Effluent pipe discharge was not examined during the inspection; however, effluent was
observed at the manhole where the effluent leave the facility, the effluent appeared
clear with
no floatable solids or foam.
Aerobic Digester
Yes No NA NE
Is the capacity adequate?
0
❑
❑
❑
Is the mixing adequate?
0
❑
❑
❑
Is the site free of excessive foaming in the tank?
M
❑
❑
❑
# Is the odor acceptable?
N
❑
❑
❑
# Is tankage available for properly waste sludge?
M
❑
❑
❑
Comment: The facility is authorized to land apply digested sludge under the authority
of Permit
WQ0011038.
Page# 8

CERTIFIED MAIL�70170040000049150588
Return Receipt to Renee Culler
RECC18:10
October 24, 2018
NCDEQ
Mooresville Regional Office
Attn.: Ori Tuvia
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Celanese
The chemistry inside innovation M
Celanese Corporation
2525 Blacksburg Road
Grover, NC 28073-9641
www.celanese.com
RECEIVED/NCDENR/DWF?
NOV 2 9 2018
WQROS
MOORESVILLE REGIONAL OFFICE
Reference: Prism Labs Inc. DO Reading for BOD Sample 2018 Wastewater Permit Analysis
Permit No. NC 0004952
Dear Mr. Tuvia:
As follow up to the conversation earlier today with Michael Sparks, Randall Turner, you, and me, this letter is
to formally notify you of the compliance issue at Prism Labs. Inc. concerning the BOD sample for the 2018
Wastewater Permit Analysis project that was collected on October 10, 2018, at 9:30 for Prism Labs. Inc. work
order number 8100194.
Celanese received a letter today notifying us that the final DO reading was performed on the sixth day (not
within five days as required). due to the Blank value and GGA results being much higher than normal. We
spoke with Terri Cole at Prism Lab. Inc., after receiving the letter. Terri explained that Prism Labs. Inc. has
purchased a second DO probe for reserve to prevent reoccurrence of this issue.
A copy of this letter along with the Prism Lab. Inc. letter will be included in the eDMR submittal next month.
C N A Holding LLC — Shelby Facility is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information, feel free to call me at
682-218-6043 (cell), 704/480-5726 (office) or via email at renee.culler(a-celanese.com
S n erely,
e Cull r
ESHA Manager
Attachments
Prism Lab. Inc. letter dated 10/24/18
Project 2018 Wastewater Permit Analysis

k
PRISM
LABORATORIES INC.
Full -Service Analytical &
Environmental Solutions
10/24/18
Celanese
Attn: Michael Sparks
2525 Blacksburg Road
Grover, NC 28073
Mr. Sparks,
Main Office:
449 Springbrook Road
P.O. Box 240543
Charlotte, NC 28224-0543
Phone: [phone]
1/800/529-6364
Fax: [phone]
www.prismlabs.com
RECEIVED/NCDENR/DWR
NOV 2 9 2018
WQROS
MOORESVILLE REGIONAL OFFICE
This letter is in reference to the BOD sample received for your 2018 Wastewater Permit Analysis project
that was collected on 10/10/18 at 09:30 for Prism Labs. Inc. work order number 8100194.
The final DO reading was performed on the sixth day. This was because the Blank value and GGA results
were much higher than normal. The analyst thought the DO probe had malfunctioned, so she performed
maintenance and let it stabilize overnight. On day 6, the results were still high. Results may have a high
bias.
We apologize for any inconvenience this may cause. We are reviewing our procedures to insure that
results are reported accurately and in a timely fashion. We now have a second probe in reserve to use
and we have cleaned our equipment to bring Blank and GGA results back into acceptable range.
Please call me at 704-529-6364 if you have further questions.
Sincerely,
PRISM LABORATORIES, INC.
(9vu uur�(' �J-
Terri Cole
Project Manager

;m Case Narrative
NC Certification No. 402
Full -Service Analytical & NC Drinking Water Cert No. 37735
`. Environmental Solutions SC Certification No. 99012 10/24/2018
I'M
.r-
.)LABORATORIES INC.
Celanese Project: 2018 Wastewater Permit Analysis
Michael Sparks
2525 Blacksburg Road Lab Submittal Date: 10/10/2018
Grover, NC 28073 Prism Work Order. 8100194
This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample
Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed
according to the referenced methods.
Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case
narrative.
Please call if you have any questions relating to this analytical report.
Respectfully,
PRISM LABORATORIES, INC.
i
Terri W. Cole
Project Manager
Data Qualifiers Key Reference:
/ 4
Reviewed By Terri W. Cole
Project Manager
A Confirmed positive.
Aa Samples read out on day 6 due to instrument issues.
BB Blank value is outside of the control limits. Validity of the data not affected.
DD Difference between sample dilutions is greater than 30%.
GH GGA result is greater than the control limit.
BRL Below Reporting Limit
MDL Method Detection Limit
RPD Relative Percent Difference
* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and
reporting limit indicated with a J.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number. 1-8001629-6364 - Fax: [phone] Page 1 of 5

Full-S
` ��k I Environmental
Analytical s
b �L"� Environmental Solutions
L, GRATORIES ING
SampleAeceipt Summary
10/24/2018
Prism Work Order: 8100194
Client Sample ID Lab Sample ID Matrix Date/Time Sampled Date/Time Received
001 EFF Comp 8100194-01 Water 10/10/18 9:30 10/10/18 15:45
001 EFF Grab 8100194-02 Water 10/10/18 11:45 10/10/18 15:45
Samples were received in good condition at 2.9 degrees C unless otherwise noted.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Spr9ngbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number 1-8001529-6364 - Fax: [phone] Page 2 of 5

,{ I Full -Service Analytical
t Environmental Solutionss
Laboratory Report
10/24/2018
Celanese Project: 2018 Wastewater Permit Client Sample ID: 001 EFF Comp
Attn: Michael Sparks Analysis Prism Sample ID: 8100194-01
2525 Blacksburg Road Prism Work Order: 8100194
Grover, NC 28073 Sample Matrix: Water Time Collected: 10/10/18 09:30
Time Submitted: 10/10/18 15:45
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Datefrime ID
General Chemistry Parameters
Biochemical Oxygen Demand 11 Aa, BB, DD, mg/L 2.0 1 •SM5210 B 10/11/18 10:46 CBP PBJ0312
GH
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240643 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number 1-8001529-6364 - Fax: [phone] Page 3 of 5

Full-
�Service
PRISMEnvironmenlal Solutions
'�' LABORATORIES LNG
Celanese
Attn: Michael Sparks
2525 Blacksburg Road
Grover, NC 28073
Project: 2018 Wastewater Permit
Analysis
Sample Matrix: Water
LaDoratory Keport
10/24/2018
Client Sample ID: 001 EFF Grab
Prism Sample ID: 8100194-02
Prism Work Order: 8100194
Time Collected: 10/10/18 11:45
Time Submitted: 10/10/18 15:45
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
Microbiological Parameters
Fecal Coliforms
4 A CFU/100 ml 2
1 'SM9222 D 10/10/18 16.68 BMS P8J0231
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240643 - Charlotte, NC 28224-0643
Phone: [phone] - Toll Free Number: 1-8001629-6364 - Fax: [phone] Page 4 of 5

14.1 RloFull-Service Analytical & WASTEWATER CHAIN OF CUSTODY
FSyt' Er1VIrOnmentAl SOIUtIOr1S PAGE —{ OF.__l_._ QUOTE N TO ENSURE PROPER BILLINGr
449 Springbrook Road • P.O. Box 240543 • Charlotte, NC 28224-0543 Project Name: —C It 1 d1E6y_%
Phone: [phone] • Fax: [phone] Short Hold Analysis: (Yes) (No) UST Project: (Yes) (No)
Client Company Name: Ce,,AAtS 'Please ATTACH any project specific reporting (QC LEVEL 1 II III IV)
Report To/Contact Name: ,(ld.�wr k Provisions and/or G]� Rgquirements
Reporting Address: 2b` 2 5' /3 roc �iJ� ddreslice : -- � , l dN+�s'e
Gov *-r A.1 C 2Q 0 7 ? Address: - - �'.� •� P
Phone.—,b i -J0 • r7 1 lax (Yes) (No)•
3 y YES
-'-Samples
NO N/
u0
INTACT upon arnval4" 2�
S
Recelved ON WET ICE? Temp . _
-
to
PROPER�PRESERVATIVES indicated? ._
Q)
Recelved WITHIN HOLDING TIMES?,
CUSTODY"SEALS INTACT?.. -
tl
VOLATILES rend W/OUT HEADSPAC
;_PROPER:CONTAINERS used?
Email (Yes) (No) Email Address Purchase Order No./Billing Reference TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL
EDD Type: PDF_ Excel _Other Requested Due Date ❑ 1 Day CI 2 Days Q 3 Days O 4Ru h work Must Be Certification: •NELAC USACE FL NC_X
Working Days ❑ 6-9 Days tandard 10 days ❑ pre -Approved Sc OTHER N/A
Site Location Name: L' ! �d� e i r Samples received after 15:00 will be processed next business day. —
Site Location Physical Address: - J"AA tQ Turnaround time Is based on business days, excluding weekends and holidays. Water Chlorinated: YES_ NOJK
(SEE REVERSE FOR TERMS & CONDITIONS REGARDING SERVICES Sample Iced Upon Collection: YES NO
RENDERED BY PRISM LABORATORIES, INC. TO CLIENT)
SAMPLE CONTAINER TYPE V
CLIENT SAMPLE
TYPE AND SIZE (MIL) PRESERVATIVES.j� ANALYSES TO BE PERFORMED ON THE SAMPLES PRISM
LAB
I.D. ID NO.
Comp Grab Plastic Glass Other None Iced HCI I HNO3 H2SO4 pH BOD TSS Cd Cr Cu Pb Ni Ag Zn O&G CN- NH3
as N t/
00 1 XC X i i I i I ivi6)
s
to the
SAMPLES ARE NOT
SHOULD BE TAPED SHUTWITH CUSUDDY SEALS FOR TRANSPORTATION TO THE
AND VERIFIED AGAINST CDC UNTIL RECEIVED AT THE LABORATORY.
❑ Fed Ex ❑ UPS ZI Hand - ' rod V Prism Field Service O Other
Composite Type: FLO.X TIME HAND (circle one)
Start Date & Time for Composite Sampler: t O / 9 / QO It 611)3 O Hrs
Stop Date & Time for Composite Sample: 10/ (0 / 2011t 69,70 Hrs
Date & Time Composite Sample Collecte,,��d:. It)/ 10 / Z 0 0 ? _A 9.7 O Hrs
-Total Hours Composite Collected Over:13Hours. End Flow: Gal / Cu Feet
Start Flow: (circle one)
Total:
Affiliation
3ve. tnnyy c angel must e
alized.
Date I tary/ our
Icy-
Date
-d Date
COO Group No.
16100�%�
Additional Comments:
01
F 4 Site ArdRX.
e:
�Slte
Feld Tech Fee
Date & Time Grab(s) Taken: to / /0 / �Q Hrs
Field pH Meter Calibrated: Yes —No —
Field pH Result: Analyst's Initials:
Field Temp. Result. Analyst's Initials:
Sampler Interrupted: Yes_ No If Yes, Why?

Water Resources
ENVIRONMLNTAL WAU'tY
February 17, 2017
Ms. PEM Carter, Sr. Environmental Engineer
CNA Holding, LLC
2525 Blacksburg Road
Grover, NC 28073,
Dear Ms. Carter:
�a R0Yz7 .DOPER
Governor
it
MICHAEL S—kEGAN
Secretary
3."JAY ZIMMERMAN
Director
Subject: Compliance Sampling Inspection
Celanese — Shelby Plant
NPDES Permit No. NC0004952
Cleveland County
Enclosed is a copy of the laboratory results for the effluent samples collected during the
Compliance Sampling Inspection performed at the subject facility on February 8, 2017, by Ori
Tuvia. The sampling results revealed that the facility complied with all applicable effluent
permit limits (see attached results). Please inform the facility's Operator -in -Responsible Charge
(ORC) of our findings by forwarding a copy of the enclosed report.
Should you have any questions concerning this report, please do not hesitate to contact
Ori Tuvia at [phone], or at [e-mail].
Cc: NPDES Unit
MRO Files
Sincerely,
Ori Tuvia, Environmental Engineer
Mooresville Regional Office -
Division of Water Resources, DEQ
Mooresville Regional Office
I nrafinn• gin Fact (:antar Ava Snita:101 Monracvilla N: 9A11S

AC35612 North Carolina Division of Water Resources Water Sciences Section Laboratory Results
Loc. Descr.:
EFFLUENT SAMPLE
County:
Cleveland-
Collector:
0 TUVIA
VisitlD
Region:
MRO
Report To
MRO
Location ID:
NC0004962
River Basin
BRD
Collect Date:
02/0812017
Priority
COMPLIANCE
Emergency -
-- - -
Collect Time:
i1_30 - -.
Sample Matrix:
WASTEWATER
COC Yes/No
Yes
Sample Depth
Loc. Type:
Effluen
Final Report
Sample ID:
AC35612
PO Number#
Date Received:
0210912017
Time Received:
08_20
Labworks LoginlD
MSWIFT
Delivery Method
NC Courler
Final Report Date:
2116117
Report Print Date:
02/1612017
If this report is labeled preliminary report, the results have not been validated. Do not use for Regulatory purposes.
Result/
Method
Analysis
CAS # Analvte Name PQL
Qualifier
Units
Reference
Date
Validated by
LAB
Sample temperature at receipt by lab
1.2
°C
2/9/17
MSWIFT
MIC
BOD, 5-Day in liquid 2.0
.4,8
mg/L
SM 5210 B-2001
2/9/17
ESTAFFORDI
WET
Residue —Suspended in liquid 6.2
13
mg/L
SM 2540 D-1997
2/14/17
-CGREEN
R ECEIV Ef; INC DEN R'DVV t'
FEB
VvQROS
�jJOORESVILL E REGIONAL OFFIC5-
WSS Chemistry Laboratory>> 1623 Mail Service Center, Raleigh, NC 27699-1623 [phone]
"Not Detected" or "U" does not indicate the sample is analyte free but that the analyte is not detected at or above the PQL.
Page 1 of 1

h
9,
Water Resources
ENVIRONMEMTAL OUAdry
February 14, 2017
Ms. PEM Carter, Sr. Environmental Engineer
CNA Holding, LLC
2525 Blacksburg Road
Grover, NC 28073
Dear Ms. Carter:
ROY COOPER
Governor
? '�rM-ICHAEL S. REGAN
Secretary
S. JAY ZIMMEkNVfXN
Director
Subject: Compliance Sampling Inspection
Celanese — Shelby Plant
NPDES Permit No. NC0004952
Cleveland County
Enclosed is a copy of the Compliance Sampling Inspection for the inspection conducted
at the subject facility on February 8, 2017, by Ori Tuvia. Michael Sparks, Michael Queen's,
Randy Turner's and your cooperation during the site visit was much appreciated. Please advise
the staff involved with this NPDES Permit by forwarding a copy of the enclosed report.
Split samples were taken during the inspection. Results of the split sampling will be
forwarded upon completion of analyses.
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact Ori Tuvia at [phone], or at
[e-mail].
Cc: NPDES Unit
MRO Files
Sincerely,
Ori Tuvia, Environmental Engineer
Mooresville Regional Office
Division of Water Resources, DEQ
Mooresville Regional Office
«, . 121n C-4 rl—+.. A— c„i+ IN Mnnmevillo Kir' �A11F

United States Environmental Protection Agency
Form Approved:
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance 1nspectipn.. Report_
Approval expires a-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN i 2 15 1 3 I NG0604952 ill 12 17/02/08' 17. 18 I C I 19 I c I 201 I
211111 1 1 I I I I II I I LI I I I I I I I I 1 I I I I I I I I I I II I I 6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA — —Reserved
67 1.0 7071 72 LN 73I 75
80
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)
10:05AM 17/02/08
13/11/01
Celanese -Shelby Facility
NC Hwy 198
Exit Time/Date
Permit Expiration Date
Shelby NC 28150
01:10PM 17/02/08
18/08/31
Name(s) of Onsite Representative(s)fritles(s)/Phone and Fax Number(s)
Other Facility Data
Michael D. Sparks/ORC/704-480-5793/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Rafael Gonzalez,2525 Blacksburg Rd Grover NC 28073/Site Director/704480-5728/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program E Sludge Handling Disposal Facility Site' Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Od A Tuvia MRO WQ//704-663-1699/ 2—1 i n 0
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger MRO WQ//704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
ip-
Page#

P
NPDES yr/mo/day Inspection Type 1
31 Nco004952 I11 12I 17/02/08 I 17 18 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On -Site Representatives:
The following Company personnel were in attendance during the inspection: Ms. PEM Carter/Sr.
Environmental Engineer; Mr. Michael Sparks/ORC; Mr. Randy Turner Lab Supervisor; and Mr. Michael
Queen/Backup ORC
Page#

[l
Permit: NC0004952 Owner -Facility: Celanese -Shelby Facility
Inspection Date: 02/08/2017 Inspection Type: Compliance Sampling
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ M ❑
application?
Is the facility as described in the permit? -❑ ❑ ❑
# Are there any special conditions for the permit?
M
❑
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
M
❑
❑
❑
Comment: The subject permit expires on 8/31/2018.
The facilty permit limits are in pounds/day rather then mg/L.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with 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?
❑
❑
M
.❑
(If the facility is = oi• > 5 MGD permitted flow) Do they operate 2417 with a certified operator
❑
❑
❑
on each shift?
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
M
❑
❑
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review? .
M
❑
❑
❑
Comment: The records reviewed during the inspection were organized and well maintained DMRs
COCs Bench sheets Calibration logs and ORC visitation logs, were reviewed for the period
January 2016 through September 2016.
Laboratory
Yes No NA NE
Page# 3

l
Permit: NC0004952 Owner -Facility: Celanese -Shelby Facility
Inspection Date: 02/08/2017 Inspection Type: Compliance Sampling
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
M,
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
M-
❑
❑
❑ -
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑ •
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
0
❑
❑
❑
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
❑
❑
E
❑
Comment: On -site effluent analyses (fecal coliform, PH, temperature. TSS) are performed under the "
Company's laboratory certification #221. Prism Laboratories. Inc. (BOD, oil &
grease, total
nitrogen, total phosphorus, pollutant scan) and ETT. Inc. (toxicity) have also been contracted
to provide analytical support.
The laboratory instrumentation used for field analyses appeared to be properly
calibrated/verified and documented. -
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
0
❑
❑
❑
Is sample collected below all treatment units?
0
❑
❑
❑
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
E
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
M
❑
❑
❑
representative)?
Comment: The subiect permit reauires both composite and Arab effluent samDles. The ORC and staff
must ensure to perform/document periodic aliquot verifications on the composite sampler.
Operations & 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: The. wastewater facility appeared to be properly operated and well maintained. The facility
staff incorporate a comprehensive process control pros m with all measurements being_
properly documented and maintained on -site.
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Page# 4

Permit: NC0004952
Owner -Facility: Celanese -Shelby. Facility
Inspection Date: 02/00/2017
Inspection Type: Compliance Sampling
Bar Screens
Yes No NA NE
Are the bars adequately screening debris?
N
❑
❑
❑
Is the screen free of excessive debris?
M
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment:
Grit Removal
Yes No NA NE
Type of grit removal
a.Manual
b.Mechanical
❑
Is the grit free of excessive organic matter?
❑
❑
❑
Is the grit free of excessive odor?
M
❑
❑
❑
# Is disposal of grit in compliance?
❑
❑
❑
Comment:
Equalization Basins
Yes No NA NE
Is the basin aerated?
0
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
E
❑
❑
❑
Is the basin free of excessive grease?
0
❑
❑
❑
Are all pumps present?
❑
❑
0
❑
Are all pumps operable?
❑
❑
0
❑
Are float controls operable?
❑
❑
0
❑
Are audible and visual alarms operable?
❑
❑-
0
❑
# Is basin size/volume adequate?
M
❑
❑
❑
Comment: The Drocess wastewater flows through three equalization basins (in series) -prior to
combining with the domestic wastewater. Sodium hydroxide (PH adjustment) is added to
the first EQ Basin and phosphoric acid (nutrient supplement) is added on an as -needed,
basis at the third EQ Basin. A fourth equalization tank is also available for emergency
situations.
Chemical Feed
Yes No NA NE
Is containment adequate?
❑
-❑
❑
Is storage adequate?
0
❑
❑
❑
Are backup pumps available?
0
❑
❑
❑
Is the site free of excessive leaking?
0
❑
❑
❑
Page# 5

P
Permit: NC0004952
Inspection Date: 02/08/2017
Chemical Feed
Comment:
Owner -Facility: Celanese -Shelby Facility
Inspection Type: Compliance Sampling
Yes No NA NE •
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
❑
❑
❑
Are surface aerators and mixers operational?
E
❑
❑
❑
Are the diffusers operational?
❑
❑
0
❑
Is the foam the proper color for the treatment process?
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
E
❑
❑
❑
Is the DO level acceptable?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
❑
0
❑
Comment:. Both aeration basin trains were operational and in service at the time of the inspection.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
N
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
N
❑
❑
❑
Is the site free of evidence of short-circuiting?
❑
❑
❑
IS scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
V
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately '/< of the sidewall depth)
0
❑
❑
❑
Comment: One of the wto secondary clarifiers was operational and in service, the second was taken
down for maintenance..
Pumps-RAS-WAS
Yes No NA NE
Are pumps in place?
0
❑
❑
❑
Are pumps operational?
0
❑
❑
❑
Are there adequate spare parts and supplies on site?
❑
❑
❑
Page# 6

Permit: NC0004952 Owner -Facility: Celanese -Shelby Facility
Inspection Date: 02/08/2017 Inspection Type: Compliance Sampling
Pumps-RAS-WAS Yes No NA NE
Comment:
Lagoons
Type of lagoons? r
.# Number of lagoonsin operation at time of visit?
Are lagoons operated in?
# Is a re -circulation line present?
Is lagoon free of excessive floating materials?
# Are baffles between ponds or effluent baffles adjustable?
Are dike slopes clear of woody vegetation?
Are weeds controlled around the edge of the lagoon?
Are dikes free of seepage?
Are dikes free of erosion?
Are dikes free of burrowing animals? '
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple
locations?
Yes No NA NE
Aerated
3
Series
❑
❑
■
❑
M.
❑
❑
❑
❑
❑
M
❑
•
❑
❑
❑
•
❑
❑
❑
■
❑
❑
❑
•
❑
❑
❑
•
❑
❑
❑
❑
❑
M
❑
# If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
❑
Is the lagoon surface free of weeds?
❑
❑
❑
Is the lagoon free of short circuiting?
M
❑
❑
❑
Comment: The facilily is equipped with three polishing ponds (operated in series)
and two sludge
holding ponds.
Filtration (High Rate Tertiary)
Yes No NA NE
Type of operation:
Down flow
Is the filter media present?
0
❑
❑
❑
Is the filter surface free of clogging?
E
❑
❑
❑
Is the filter free of growth?
❑
❑
❑
M
Is the air scour operational?
❑
❑
0
❑
Is the scouring acceptable?
0
❑
❑
❑
Is the clear well free of excessive solids and filter media?
❑
❑
M
❑
Comment: All six tertiary filters were operational and in-service.
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? ❑ ❑ ❑
Page# 7

6.
Permit: NC0004952 Owner -Facility:
Celanese -Shelby Facility
Inspection Date: 02/08/2017 Inspection Type:
Compliance Sampling
Flow Measurement - Effluent
Yes No NA NE
Is flow meter calibrated annually?
M
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?.
❑
❑
M
❑
Comment: The flow meter is calibrated/verified on a auarterly basis and was last calibrated/verified on
2/1/2017 by the Company's I & E personnel. .
Effluent Pipe
Yes No NA NE
Is right of way to the. outfall properly maintained?
❑
❑
❑
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?
❑
❑
❑
Comment: The effluent appeared clear with no floatable solids or foam.
Aerobic Digester
Yes No NA NE
Is the capacity adequate?
N
❑
❑
❑
Is the mixing adequate?
M
❑
❑
❑
Is the site free of excessive foaming in the tank?
0
❑
❑
❑
# Is the odor acceptable?
0
❑
❑
❑
# Is tankage available for properly waste sludge?
M
❑
❑
❑
Comment: The facility is authorized to land apply digested sludge under the authority of Permit
W00011038.
Page# 8

Water Resources
ENVIRONMENTAL QUALITY
Steve Olp
CNA Holdings Inc
2848 Cherry Rd
Ste 100
Rock Hill, SC 29730
RECEIVEDfNCEIENR/DWR
WORDS
MOORESVILLE R _G!ONNAL OFFICE
March 31, 2016
PAT MCCRORY
Governor
DONA`ERfE� ALpa ART
secretary
R.P7AY �Ztkrl IERMAN
Director
V,10RCIS
MOORES`JiL!.F REG:0 ! AL OFFICE
Subject: NPDES Electronic Reporting Requirements and
Sixty Day Notice of Minor Modification of the NPDES Permit
Ticona Facility
NPDES Permit Number: NC0004952
Dear NPDES Permittee:
The U.S. Environmental Protection Agency (EPA) recently published the National Pollutant Discharge
Elimination System (NPDES) Electronic Reporting Rule. The.rule requires NPDES regulated facilities to
report information electronically, instead of filing written paper reports. The rule does not change what
information is required from facilities. It only changes the method by which information is provided (i.e.,
electronic rather than paper -based).
EPA is phasing in the requirements of the rule over a 5-year period. The two phases of the rule, and their
key milestones, are:
• Phase 1—Starting on December 21, 2016, regulated entities that are required to submit Discharge
Monitoring Reports (DMRs) will begin submitting these reports electronically, instead of on
paper. If you are currently reporting your DMR data electronically using eDMR, then you simply
need to continue reporting in the same way as you are now. The key change is that, starting on
December 21, 2016, electronic reporting of DMRs will be required, instead of voluntary.
11
• Phase 2—Starting on December 21, 2020, regulated entities that are required to submit certain
other NPDES reports will begin submitting these reports electronically, instead of on paper.
Reports covered in the second phase include Notices of Intent to discharge in compliance with an
NPDES general permit, Sewer Overflow/Bypass Event Reports, and a number of other NPDES
program reports.
For more information on EPA's NPDES Electronic Reporting Rule, visit
http://www2.epa.goy/compliance/final-national-pollutant-discharge-elimination-system-npdes
electronic -reporting -rule. For more information on electronic reporting to NC DWR, visit
http://deg.nc.goy/about/divisions/water-resources/edmr/npdes-electronic-reporting or contact Vanessa
Manuel at 919-807-6392 or via email at [e-mail].
State ofNortli Carolina I Environmental Quality I Water Resources
1611 Mail service Center I Raleigh, North Carolina 27699-1611
919 707 9000

Sixty Days' Notice of Minor Modification of the Subject NPDES Permit
The NPDES Electronic Reporting Rule requires authorized NPDES programs to incorporate electronic
reporting requirements into NPDES permits beginning December 21, 2015. Under the new rule, the
electronic reporting process supersedes the paper reporting process outlined in your existing permit. To
bring your permit up-to-date with the new reporting requirements, this letter serves to notify you that in
sixty days your NPDES permit will be modified to incorporate the new electronic reporting requirements.
The modification will require electronic reporting in place of paper -based reporting. Electronic reporting
will be required beginning as indicated above for Phases 1 and 2 reporting. Please attach the enclosed
NPDES Permit Standard Conditions Part lii—Addendum to your permit. This permit modification becomes
effective on July 1, 2016.
All other terms and conditions in the original permit remain unchanged and in full effect. This
modification is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency
dated October 15, 2007.
If any parts contained in this modification are unacceptable to you, then you have the right to file a
petition for a contested case with the Office of Administrative Hearings within thirty (30) days following
receipt of this letter. This petition must conform to the requirements of Chapter 150B of the North
Carolina General Statutes. Petitions must be timely filed with the Office of Administrative Hearings, Post
Office Drawer 11666, Raleigh, North Carolina 27604. If you do not file a petition within the required time,
the agency decision shall be final and binding. If you have questions concerning this permit modification,
please contact Tom Belnick at telephone number 919-807-6390.
Sincerely,
Jef re,ij O. P&wpa rt-
forS. Jay Zimmerman, P.G.
Enclosure: NPDES Permit Standard Conditions Part III - Addendum
Cc: NPDES File
Central Files
1�oresui.IleLRggionuality¢Program

A,A
sp
pNCDENRF�LE(,�j
North Carolina Department of Environment and Natural Resources .
Pat McCrory Donald van der Vaart
Governor Secretary
April 14, 2015-
Ms. PEM Carter, Sr. Environmental Engineer
CNA Holdings, LLC
2525 Blacksburg Road
Grover, North Carolina 28073
Subject: Compliance Evaluation Inspection
Celanese — Shelby Plant
NPDES Permit No. NC0004952
Cleveland County
Dear Ms. Carter:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on April 8, 2015 by Mr. Wes Bell of this Office. Please inform the facility's Operator -in —
Responsible (ORC) of our findings by forwarding a copy of the enclosed report.
The report should be self-explanatory; however, should you have any questions concerning this report, please
do not hesitate to contact Mr. Bell at [phone], or at [e-mail].
SSippneerely, J
t = Michael L. Parker, Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, DENR
Enclosure:
Inspection Report
cc: MSC 1617-Central Files/Basement
Cleveland County Health Department
ME.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Seivice: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity \ Affirmative Action Employer — 30% Recycled110% Post Consumer paper

NPDES yr/mo/day Inspection Type
31 Nc000assz I11 121 15/04/08 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On -Site Representatives:
The following Company personnel were in attendence. during the inspection: Ms. PEM Carter/Sr.
Environmental Engineer; Mr. Michael Sparks/ORC; and Mr. Michael Queen/Backup ORC.
Page#

Permit: NC0004952 Owner -Facility: TiconaFacility
Inspection Date: 04/08/2015 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(if the present permit expires in 6 months or less). Has the permittee'submitted a new
❑
❑
M
❑
application?
Is the facility as described in the permit?
M
❑
❑
❑
# Are there any special conditions for the permit?
M
❑
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
M
❑
❑
❑
Comment: The subject permit expires on 8/31/2018.
The last compliance evaluation inspection was performed at the facility
on 8/7/2013.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
M
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
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?
M
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 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?
❑
❑
❑
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?
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
Page# 3

I
Permit NC0004952 Owner - Facility: Ticona Facility
Inspection Date: 04/08/2015 Inspection Type: compliance Evaluation
Record Keepina Yes No NA NE
Comment: The records Yeviewed during the inspection were organized and well maintained. Discharqe
Monitoring Reports (DMRs) were reviewed for the period February 2014 through January
2015. No limit violations were reported.
The 12/2/2014 effluent fecal coliform result was not transcibed on the original DMR:
however, an amended December 2014 DMR will be resubmitted to include this result.
The facility staff must ensure that only results from an effluent sampling event are reported
on future DMRs (BOD and TSS). No "0.0" lbs./day should be reported on non -sampling
days. In addition, the monthly average flow calculations on future DMRs should only include
the days a discharge/flow occurred.
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
M
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
M
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
❑
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
❑
❑
0
❑
Comment: On -site effluent analvses (fecal coliform. DH, temoerature. TSS) are Derformed under the
Company's laboratory certification #221. Prism Laboratories, Inc. (BOD, oil & grease, total
nitrogen, total phosphorus, pollutant scan) and ETT, Inc. (toxicity) have also been contracted
to provide analytical support.
The laboratory instrumentation used for field analyses appeared to be properly
calibrated/verified and documented.
Effluent Samplina
Yes No NA NE
Is composite sampling flow proportional?
0
❑
❑
❑
Is sample collected below all treatment units?
0
❑
❑
❑
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
M
❑
❑
❑
representative)?
Comment: The subject permit requires both composite and grab effluent samples. The ORC and staff
must ensure to perform/document periodic aliquot verifications on the composite sampler.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? M ❑ ❑ ❑
Page# 4

Permit: NC0004952 Owner - Facility: Ticona Facility
Inspection Date: 04/08/2015 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable. ® ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The wastewater facility appeared to be properly
operated and well maintained. The facility
staff incorporate a comprehensive process control program with all measurements being
Properly documented and maintained on -site.
Bar Screens
Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
❑
Are the bars adequately screening debris?
M
❑
❑
❑
Is the screen free of excessive debris?
❑
❑
❑
Is disposal of screening in compliance?
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment:
Grit Removal
Yes No NA NE
Type of grit removal
a.Manual
b.Mechanical
❑
Is the grit free of excessive organic matter?
0
❑
❑
❑
Is the grit free of excessive odor?
0
❑
❑
❑
# Is disposal of grit in compliance?
M
❑
❑
❑
Comment:
Equalization Basins
Yes No NA NE
Is the basin aerated?
0
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
0
❑
❑
❑
Is the basin free of excessive grease?
❑
❑
❑
Are all pumps present?
❑
❑
0
❑
Are all pumps operable?
❑
❑
M
❑
Are float controls operable?
❑
❑
M
❑
Are audible and visual alarms operable?
❑
❑
M
❑
# Is basin size/volume adequate?
0
❑
❑
❑
Page# 5

Permit: NC0004952 Owner - Facility: Ticona Facility
Inspection Date: 04/08/2015 Inspection Type: Compliance Evaluation
Equalization Basins Yes No NA NE
Comment: The orocess wastewater flows through three equalization basins (in series) prior to
combining with the domestic. wastewater. Sodium hydroxide (PH adjustment) is added to
the first EQ Basin and phosphoric acid (nutrient supplement) is added on an as -needed
basis at the third EQ Basin. A fourth equalization tank is also available for emergency
situations.
Chemical Feed
Yes No NA NE
Is containment adequate?
0
❑
❑
❑
Is storage adequate?
0
❑
❑
❑
Are backup pumps available?
N
❑
❑
❑
Is the site free of excessive leaking?
0
❑
❑
❑
Comment:
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
0 ❑
❑
❑
Are surface aerators and mixers operational?
❑
❑
❑
Are the diffusers operational?
❑ ❑
0
❑
Is the foam the proper color for the treatment process?
0 ❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0 ❑
❑
❑
Is the DO level acceptable?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑ ❑
❑
Comment: Both aeration basin trains were operational and in service.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
E
❑
❑
❑
Is the site free of weir blockage?
.0
❑
❑
❑
Is the site free of evidence of short-circuiting?
❑
❑
❑
Is scum removal adequate?
❑
❑
❑
Is the site free of excessive floating sludge?
N
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
N
❑
❑
❑
Page# 6

Permit: NC0004952 Owner - Facility: Ticona Facility
Inspection Date: 04/08/2015 Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) ❑ ❑ ❑
Comment: Both secondary clarifiers were operational and in service.
Pumps-RASMAS
Yes No NA NE
Are pumps in place?
0
❑
❑
❑
Are pumps operational?
0
❑
❑
❑
Are there adequate spare parts and supplies on site?
❑
❑
❑
Comment:
Lagoons
Yes No NA NE
Type of lagoons?
Aerated
# Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
# Is a're-circulation line present?
❑
❑
0
❑
Is lagoon free of excessive floating materials?
0
❑
❑
❑
# Are baffles between ponds or effluent baffles adjustable?
❑
❑
M
❑
Are dike slopes clear of woody vegetation?
0
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
❑
❑
❑
Are dikes free of seepage?
0
❑
❑
❑
Are dikes free of erosion?
M
❑
❑
❑
Are dikes free of burrowing animals?
M
❑
❑
❑
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple
❑
❑
®
❑
locations?
# If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ 0 ❑
Is the lagoon surface free of weeds? 0 ❑ ❑ ❑
Is the lagoon free of short circuiting? 0 ❑ ❑ ❑
Comment: The facility is equipped with three polishing ponds (operated in series) and two sludge
holding ponds. The woody vegetation noted in the previous inspection has been removed.
This office recommends the incorporation of annual inspections around the perimeter of the
ponds to evaluate the structural integrity of the berms.
Filtration (High Rate Tertiary)
Type of operation:
Yes No NA NE
Down flow
Page# 7

2
Permit: NC0004952
Inspection Date: 04/08/2015
Owner - Facility: Ticona Facility
Inspection Type: Compliance Evaluation
Filtration (High Rate Tertiary)
Yes No NA NE
Is the filter media present?
M
❑
❑
❑
Is the filter surface free of clogging?
M
❑
❑
❑
Is the filter free of growth?
❑
❑
❑
Is the air scour operational?
❑
❑
0
❑
Is the scouring acceptable?
0
❑
❑
❑
Is the clear well free of excessive solids and filter media?
❑
❑
0
❑
Comment: All six tertiary filters were operational and in-service.
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
M
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
N
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑.
Comment: The flow meter is calibrated/verified on a auarterly basis and was last calibrated/verified on
11/13/2014 by the Company's I & E personnel.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained? .
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: The effluent appeared clear with no floatable solids or foam.
Aerobic Digester
Yes No NA NE
Is the capacity adequate?
0
❑
❑
❑
Is the mixing adequate?
0
❑
❑
❑
Is the site free of excessive foaming in the tank?
❑
❑
❑
# Is the odor acceptable?
0
❑
❑
❑
# Is tankage available for properly waste sludge?
M
❑
• ❑
❑
Comment: The facility is authorized to land apply digested sludge under the authority
of Permit No.
W00011038. Noland application events have been performed since 2010.
Page# 8

March 23, 2015
Wastewater Branch
Water Quality Permitting Section
Division of Water.Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Delegation of Signature Authority
CNA HOLDINGS, LLC - SHELBY PLANT
NPDES Permit Numbers: NC0004952
NC000064
WQ0011038
To Whom -It May Concern:
Celanese
The chemistry inside innovation`s
Celanese Corporation
2525 Blacksburg Road
Grover, NC 28073-9641
www.celanese.com
By notice of this letter, I hereby delegate signatory authority to each of the following individuals for
all permit applications, discharge monitoring reports, and other in relating to the
operations at the subject facility as required by all applicable federal, state, and local environmental
agencies specifically with the requirements for signatory authority as specified in 15 A NCAC
213.0506
Individual # 1
Name:3
Rafael Gonzalez
>Trtle_r_
Site Director
lviaYh` Addes T'
2525 Blacksburg Road
Pbys><calrAddTess
2525 Blacksburg Road
E.mailAddressr_„_
Rafael [e-mail].
Office, Phony:
704-480-5728
'Mobile Phorie
214-518-7439
If you have any questions regarding this letter, please feel free to contact me at
[e-mail].
Site Lead for Celanese - Shelby Plant
2525 Blacksburg Road
[e-mail]
704-477-2872
cc: Mooresville Regional Office, Water Quality Permitting Section

Certified Mail 7005 3110 0004 3438 6467
Return Receipt to PEM Carter
PEMC13:26
August 27, 2013
RECEIVED
LZ9°ul lea, a C,# ti P siR QUALITY �
AUG 282013 iicona
4E
Ticona
2525 Blacksburg Road
NCDENR- Mooresville Regional Grover, NC 28073-9641
Division of Water Quality
610 East Center Ave — Suite 301 Carolina Star Worksite
ISO 9001, ISO/TS 16949,
Mooresville, NC 28115 ISO 17025, and ISO 14001
Attention: Marcia Allocco
Re: Written Response to Address: Compliance Inspection of the CNA Holdings. LLC. —
Ticona Plant. NPDES Permit No. NC0004952
During the recent compliance inspection performed by Wes Bell on August 7, 2013, he noted the
following concerns with excessive vegetation. He requested that correspondences pertaining to
excessive vegetation be directed to your attention.
Finding: Excessive woody vegetation present on slopes of lagoons/ponds and excessive weeds growth
around the edge of lagoons/ponds.
Response: CNA Holdings, LLC — Ticona Facility will actively remove wood vegetation which is present .
around Polishing Ponds A, B, C and South Sludge Lagoon. Woody vegetation < 6" diameter will be
removed along with excessive weeds which will be cut back and maintained at the pond edges. Once
this activity is completed,. inspection of the slopes for erosion and burrowing animals will be performed.
CNA Holdings, LLC: Ticona Facility is committed to ensuring compliance,with all County, State, and
Federal regulations. Should there be a need for further discussion pertaining to the information
submitted with this notification letter, feel free to call meat 704/480-5726 or via email at
[e-mail] .
Sincerely,
PEM Carter
EHS Lead/Environmental Engineer
cc: Central ESHA file: 1.1.2.1.4
Ticona — ORC: Mike Sparks
� WeSep# Mat sville*R gfioraai if i�e�6�7 0 Ce lier�Av� S-ui M�., o.r vi III ,,C�7"
Celanese
Ticona
A business of Celanese

A'5 F I LEE:
I
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
August 14, 2013
Mr. Luis Mendoza
CNA Holdings, LLC
2525 Blacksburg Road
Grover, North Carolina 28073-9641
Subject: Compliance Evaluation Inspection
CNA Holdings, LLC/Ticona Facility
NPDES Permit No. NC0004952
Cleveland County
Dear Mr. Mendoza:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on August 7, 2013 by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -
Responsible Charge (ORC) of our findings by forwarding a copy of the enclosed report.
It is requested that a written response be submitted to this Office by September 6, 2013, addressing the
excessive vegetation noted on the pond dikes further discussed in the Lagoon Section in the attached report. In
responding, please address your comments to the attention of Mrs. Marcia Allocco.
The report should be self-explanatory; however, should you have any questions concerning this report, please
do not hesitate to contact Mr. Bell at [phone] or at wes.bell cimcdenr.gov.
Sincerely,
Michael L. Parker
Regional Supervisor
Surface Water Protection Section
Enclosure:
Inspection Report
cc: Cleveland County Health Department
no
Mooresville Regional Office One
Location: 610 East Center Ave., Suite 301 Mooresville, MC 28115 NOrthCarohna
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 /ga
Internet: www.ncwaterquality.org )V till ogjlff
An Equal Opportunity 1 Affirmative Action Employer— 30% Recycled110% Post Consumer paper

F
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water CompluAnce InspPctoon 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 INI 2 15 I 31 NC0004952 111 121 13/08/07 117 181 C I 19I S I 20I
Remarks
211 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 I I I I I I I I I I I I I I I I I I I I I I 11 Jill I _I_ 16
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -------------------- —----- Reserved -------- -------
67I 1.5 169 70141 711 NJ 721 NJ 73I I f 74 751 I I I I I I 180
u_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)
12:30 PM 13/08/07
09/06/01
Ticona Facility
Exit Time/Date
Permit Expiration Date
NC Hwy 198
Shelby NC 28150
03:00 PM 13/08/07
13/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Michael D. Sparks/ORC/704-482-9582/
Pem Carter/Engineer Env Sr/704-480-4900 /
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Luis Mendoza,2525 Blacksburg Rd Grover NC 280739641/Site Leader/704-480-5728/
No
;
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Wes Bell,t.� iY j� ,'tf MRO WQ//704-663-1699 Ext.2192/
Si ture of Management Q A rvii L�er Agency/Office/Phone and Fax Numbers Date
Marcia Allocco MRO WQH704-663-1699 Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES
yr/mo/day
31 NC0004952 111 12I 13/08/07 117
Inspection Type
18ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

Permit: NC0004952 Owner - Facility: Ticona Facility
Inspection Date: 08/07/2013 Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ■ n n Cl
Is the facility as described in the permit? ■ ❑ fl n
# Are there any special conditions for the permit? n n ■ n
Is access to the plant site restricted to the general public? ■ n n n
Is the inspector granted access to all areas for inspection? ■ n n n
Comment: The subject permit expires on 8/31/2013. The Division received the permit
renewal package on 2/28/2013.
The last compliance evaluation inspection was performed on 9/20/2011.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
n
n
n .
Is all required information readily available, complete and current?
■
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
n
n
Are analytical results consistent with data reported on DMRs?
■
n
n
n
Is the chain -of -custody complete?
■
n
n
n
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?
■
n
n
n
Has the facility submitted its annual compliance report to users and DWQ?
n
n
■
n
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
n
n
■
n
Is the ORC visitation log available and.current?
■
n
n
n
Is the ORC certified at grade equal to or higher than the facility classification?
■
n
n
n
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
n
n
Is a copy of the current NPDES permit available on site?
■
n
n
n
Facility has copy of previous year's Annual Report on file for review?
n
n
■
o
Page # 3

Permit: NC0004952
Inspection Date: 08/07/2013
Record Keeping
Owner - Facility: Ticona Facility
Inspection Type: Compliance Evaluation
Comment: The records reviewed during the inspection were organized and well
maintained. Discharge Monitoring Reports (DMRs) were reviewed for the period June
2012 through May 2013. No effluent limit violations were reported and all monitoring
frequencies were correct.
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Comment: On -site effluent analyses (pH, temperature, total suspended solids, fecal
coliform) are performed under the facility's laboratory certification #221. Prism Labs and
ETS, Inc. have also been contracted to provide analytical support.
The pH meter appeared to be properly calibrated and documented.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set,for sample storage (kept at less than or equal 'to 6.0 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: The ORC and staff must ensure to perform and document periodic aliquot
verifications (100 mis. at a minimum) on the composite sampler.
V...- !1.- \IA \IC
Yes No NA NE
■nnn
■nnn
■nnn
■nnn
■nnn
nn■n
V. P11— AIA AIC
■nnn
■nnn
■nnn
■nnn
■nnn
■nnn
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ n n n
Comment:
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Ve Kf— MA AIC
■ n n n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n
Judge, and other that are applicable?
Page # 4

Permit: NC0004952
Inspection Date: 08/07/2013
Owner - Facility: Ticona Facility
Inspection Type: Compliance Evaluation
Operations & Maintenance
Comment: Overall, the facility appeared to be properly operated and well maintained;
however, concerns regarding excessive vegetation on the pond dikes were noted (See
Lagoon Section for further details).
The facility staff incorporate a comprehensive process control program with all
measurements being properly documented and maintained on -site.
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
■
b.Mechanical
Are the bars adequately screening debris?
■
n
n
n
Is the screen free of excessive debris?
■
n
n
n
Is disposal of screening in compliance?
■
n
n
n
Is the unit in good condition?
■
n
n
n
Comment:
V__
AI-
I.IA
Mc
Type of grit removal
a.Manual
■
b.Mechanical
n
Is the grit free of excessive organic matter?
■
n
n
n
Is the grit free of excessive odor?
■
n
n
n
# Is disposal of grit in compliance?
■
n
n
n
Comment:
Equalization Basins
Yes No
NA
NE
Is the basin aerated?
■
n
n
❑
Is the basin free of bypass lines or structures to the natural environment?
■
❑
n
n
Is the basin free of excessive grease?
■
n
n
n
Are all pumps present?
n
n
■
n
Are all pumps operable?
n
n
■
n
Are float controls operable?
❑
n
■
❑
Are audible and visual alarms operable?
n
n
■
n
# Is basin size/volume adequate?
■
n
n
n
Page # 5

5
Permit: NC0004952
Inspection Date: 08/07/2013
i �rrr-re
Owner - Facility: Ticona Facility
Inspection Type: Compliance Evaluation
Comment: The facility is equipped with three polishing ponds and two sludge holding
ponds. Excessive vegetation was noted on the dikes of one of the sludge holding
ponds. The vegetation should be removed and periodically maintained (on all dikes) to
allow the operations staff to evaluate the dikes for any potential leakages, burrowing
animals, etc. and prevent the establishment of rooted vegetation. Please also be
advised that the subject permit requires that the facility be properly maintained at all
times.
Filtration (High Rate Tertiary)
Yes
No
NA
NE
Type of operation:
Down flow
Is the filter media present?
■
n
n
n
Is the filter surface free of clogging?
■
n
n
Is the filter free of growth?
■
n
n
n
Is the air scour operational?
n
n
■
n
Is the scouring acceptable?
■
n
n
n
Is the clear well free of excessive solids and filter media?
n
n
■
n
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
F1
n
n
Is flow meter calibrated annually?
■
❑
n
n
Is the flow meter operational?
■
n
n
n
(If units are separated) Does the chart recorder match the flow meter?
n
n
■
n
Comment: The flow meter is calibrated/verified on a quarterly basis and was last
calibrated/verified on 5/23/2013 by the Company's I & E personnel.
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
❑
❑
❑
■
Are the receiving water free of foam other than 'trace amounts and other debris?
n
n
n
■
If effluent (diffuser pipes are required) are they operating properly?
n
n
■
o
Comment: The. effluent appeared clear with no floatable solids or foam.
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
■
n
n
n
Is the mixing adequate?
■
n
n
n
Is the site free of excessive foaming in the tank?
■
n
n
n
Page # 8

Permit: NC0004952
Inspection Date: 08/07/2013
Owner - Facility: Ticona Facility
Inspection Type: Compliance Evaluation
Aerobic Digester
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment: The facility is authorized to land apply digested sludge under the authority,
of Permit No. WQ0011038. No land application events have been performed in
approximately two years.
Yes No NA NE
■ n n n
■nnn
Page # 9

CERTIFIED MAIL 7009 2680 0003 1602 1252
Returned Receipt to PEM Carter
May 23, 2013
PEMC13:17
NC Department of Environment and Natural Resources
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
i icona
Performance Driven Solutions'
PE.CE:IVED
DIVIC,C?I\; ()F 1IV, .I"EHR 014ALITY
MAY 2 8 2013
Re: FINAL Report of the Overflow of Process Water Tank Discharge to Sorth Stormwater
Outfall — 4/30/13 (CNA Holdings, LLC., Shelby Plant; Stormwater Permit No. NCS0000641
Dear Mr. Bou-ghazale:
OFFICE
This report serves as the final written notification of the release of process waters from overfilling the tank which
occurred at between 8:30 a.m. — 9:15 a.m. on April 30, 2013. These process waters consist of potable water with
1.7 — 2.0 ppm of a corrosive control chemical. It was thought that the gauge, showing tank volume, was
unreliable. It was also thought, that it would take a significant amount of time to fill the tank. Both of these were
found to be incorrect. The tank was relatively full prior to opening the fill valve and the individual left the scene
under the impression that it would take a long time to fill. The release was reported to you by phone around
4:30 p.m. that same day. Samples of this water were immediately obtained and analysis begun. See chart
below:
CNA Holdings, LLC— Ticona's stormwater contingency plan, stipulates that we maintain pumping stations
at our outfalls to ensure no waters leave the site, except approved waters as listed in our permit. In the
event, waters other than approved waters leave by way of the permitted outfalls, sampling for all
benchmark parameters will be conducted. Both COD and BOD5 were analyzed by outside contract
laboratory, Prism Laboratories, Inc. The actual volume of unapproved waters is unknown due to a heavy
rain event.
Discharge Volume: junknown
Test Parameters:
pH: 6.7
COD: BRL
BOD& BRL
TSS: 4.5 mg/I
Color: clear
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
CNA Holdings, LLC. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-5726 or via email at Pem.carter(@ticona.com
Sincerely,,�
�Pmdi
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona — A Business of Celanese

CERTIFIED MAIL 7009 2680 0003 1602 1245
Returned Receipt to PEM Carter
May 3, 2013
PEMC13:
NC Department of Environment and Natural Resources
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
i icona
Performance Driven Solutions -
RECEIVED
DIVISION OF WATER QUALITY
MAY 9) 6 2013
' . ��C-TJON
MOOstE8*11,° LLE: ;i''.GONAL OFFICE
Re: Report of the Overflow of Process Water Tank Discharge to Sorth Stormwater Outfall —
4/30/13 (CNA Holdings, LLC., Shelby Plant: Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as a written notification of the release of process waters from overfilling the tank which
occurred at between 8:30 a.m. — 9:15 a.m. on April 30, 2013. These process waters consist of potable water with
1.7 — 2.0 ppm of a corrosive control chemical. It was thought that the gauge, showing tank volume, was
unreliable. It was also thought, that it would take a significant amount of time to fill the tank. Both of these were
found to be incorrect. The tank was relatively full prior to opening the fill valve and the individual left the scene
under the impression that it would take along time to fill. The release was reported to you by phone around
4:30 p.m. that same day. Samples of this water were immediately obtained and analysis begun. See chart
below:
CNA Holdings, LLC— Ticona's stormwater contingency plan, stipulates that we maintain pumping stations
at our outfalls to ensure no waters leave the site, except approved waters as listed in our permit. In the
event, waters other than approved waters leave by way of the permitted outfalls, sampling for all
benchmark parameters will be conducted. Both COD and BOD5 are pending and have been sent to an
outside contract laboratory, Prism Laboratories, Inc. The actual volume of unapproved waters is unknown
due to a heavy rain event.
Discharge Volume: junknown
Test Parameters:
pH: 6.7
COD: pending
BOD& pending
TSS: 4.5 mg/I
Color: clear
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
CNA Holdings, LLC. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-5726 or via email at pem.carter(a)-ticona.com
(--S'ince ly, ll
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona — A Business of Celanese

L 131
�q �m� A
WDENR
North Gar&ina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
October 18, 2011
Ms. PEM Carter, Environmental Engineer
CNA Holdings, Inc.
Shelby Plant
2525 Blacksburg Road
Grover, NC 28073
Subject: Compliance Evaluation Inspection
CNA Holdings, Inc.-Ticona Facility WWTP
NPDES Permit No. NC0004952
Cleveland County, North Carolina
Dear Ms. Carter:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on September 20, 2011 by Ms. Donna Hood of this Office. Please inform the facility's Operator -in -
Responsible Charge of our findings by forwarding a copy of the enclosed report.
The report should be self-explanatory; however, should you have any questions concerning this report, please
do not hesitate to contact Ms. Hood or me at [phone].
Sincerely,
, - 7 � n c-,,-, � �u �,
4;� Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure
DH
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NO 28115
Phone: [phone] Fax: [phone] t Customer Service: 1-877-623-6748
Internet: ww.v.ncwaterquality.org
Nne
orthCarolina
An Equal Opportunity', Aitirmalive Action Employer — 50% Recyc'edil O% Past Consumer paper

United States Environmental Protection Agency
Form Approved
EPA Washington, D.C. 20460
1 . _
OMB No. 20�0-005
Approval. expires 3-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 INI 2 15 I 31 NC0004952 111 121 11/09/20 117 18I C I 19I S I 201 I
Remarks
211 1 1 1 I I I I I I I 1 I I I I I l I I I I I I I l I I l I I I I I I I I I I l I I I I l 116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --------------------------- Reserved ----------------------
67 I 2.0 169 70141 711 I 72 I N I 73I I 174 751 I I I I I I 180
I —I —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)
10:00 AM 11/09/20
09/06/01
Ticona Facility
Exit Time/Date
Permit Expiration Date
NC Hwy 198
Shelby NC 28150
02:30 PM 11/09/20
13/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Michael R. Queen/ORC/704-480-4692/
Pem Carter/Engineer Env Sr/704-480-4900 /
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Charles Thomas,2525 Blacksburg Rd Grover NC 280739641/Site Manag er/704-480-4980/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit ® Flow Measurement ® Operations & Maintenance ® Records/Reports
Self -Monitoring Program ® Sludge Handling Disposal ® Facility Site Review is Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Donna od MRO WQ9704-663-1699 Ext.2193/
V
Management Q A Reviewer Agency/Office/Phone and Fax Numbers Datelocco
:re,of
E
MRO WQ//704-663-1699 Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type 1
3I NC0004952 , 11 12, 11/09/20 117 181
CI
Section D:, Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

Permit: NC0004952 -facility: Ticona Facility
Inspection Date: 09/20/2011 Anspection Type: Compliance Evaluation
Pprmit. Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
n
C3
■
0
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?
®
n
n
n
Is the inspector granted access to all areas for inspection?
■
n
n
n
Comment: The facility has been reclassified to Grade 3 Biological treatment system
on June 22, 2011.
Operations & Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
®
n
n
n
Does the facility analyfe process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ®n
n
n
Judge, and other that are applicable?
Comment: The facility was well maintained and operated at the time of the inspection.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
®
n
n
n
Is all required information readily available, complete and current?
lig
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
®
n
n
n
Are analytical results consistent with data reported on DMRs?
®
n
n
n
Is,the chain -of -custody complete?
®
n
n
n
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?
®C1
n
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
N ❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
ri
n
E n
Is the ORC visitation log available and current?
®❑
❑ n
Is the ORC certified at grade equal to or higher than the facility classification?
®❑
❑ n
Is the backup operator certified at one grade less or greater than the facility classification?
®
n
n n
Page # 3

Permit: NC0004952
Inspection Date: 09/20/2011
Owner -Facility: Ticona Facility
Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Is a copy of the current NPDES permit available on site? a n n n
Facility has copy of previous year's Annual Report on file for review? ❑ fl
Comment: DMRs for August 2010-July 2011 were reviewed for the inspection. No
violations were reported for the review period. All necessary records were well
organized and easily accessible during the inspection.
Laboratory Yes NO NA N[
Are field parameters performed by certified personnel or laboratory? ❑ n n
Are all other parameters(excluding field parameters) performed by a certified lab? p n n n
# Is the facility using a contract lab? n n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? n n n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ Ell Em n
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? n n M n
Comment: A laboratory inspection was performed concurrent to the NPDES
inspection. Please refer to the report by Mr. Chet Whiting, of this Office, for any
laboratory recommendations.
Type of bar screen
a.Manual
b.Mechanical
n
Are the bars adequately screening debris?
❑
❑
Is the screen free of excessive debris?
n
n
n
Is disposal of screening in compliance?
f
❑
❑
❑
Is the unit in good condition?
®
❑
❑
❑
Comment:
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
n
n
n
Is the basin free of bypass lines or structures to the natural environment?
n
n
n
Is the basin free of excessive grease?
®
❑
❑
n
Are all pumps present?
n
n
®
n
Are all pumps operable?
n
n
In
n
Are float controls operable?
n
n
®
n
Page # 4

„ug 2 Owner - Facility: Ticona Facility
{nspc,.. Oa,t _: '_^11 Inspection Type: Compliance Evaluation
Equaiiza?ion Basins
Yes No NA
NE
Are audio le and visuai alarms operable?
4 Is bas r: sJ-e/vG.um_m adequate?
❑
�
fi
Comment: Thi,ree equalization basins are used for pH adjustment of the wastewater.
Each basin appeared well maintained at the time of the inspection.
Aeration Basins
Yes No
NA
NE
Mode of operation
Type of aeration system
Surface
Is the basin free of dead spots?
fl
0
f1
Are surface aerators and mixers operational?
❑
11
n
Are the diffusers operational?
Ea?
n
n
rl
Is the foam the proper color for the treatment process?
Iks
n
n
Does the foam cover less than 25% of the basin's surface?
C
n
0
1 iy
Is the DO level acceptable?
r!
fl
1 1
Is the DO level acceptable?(1.0 to 3.0 mg/1)
l_1
n
Comn-,::nt: The hasins appeared well mixed. at the time of the inspec_ion.
Secondiz.-y Clarifier
Yes No
Igk NE
Is the clarifier free of black .md odorous wastewater?
n
0
i
Is the site free of excessive buildup of solids in center well of circular clarifier?
t-3
0 -
n
n
Are weirs level?
`"°
r..1
D
-- it
f"E,1
Is the site free of weir blockage?
l '
0-1
D
l
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
ff-
n
r1
r
Is the drive unit operational?
Is the return rate acceptable (loan turbulence)?
❑
U
n
Is the ov,:rflow clear of excessive solids/pin floc?
i<i
[l
n
Is the sludge blanket ; vel acceptable? (Approximately'/t of the sidewall depth)
N
Q
❑
Cl
Comment: The facility was using one of two clarifiers at the time of the irspection.
With the current low flow conditions at the facility, only one is neces!•!�Iry for proper
treatment of the viaste stream.
Page #t 5

�W.yp.'i
permit: PICOCC4952 owner - Facjjity-. Ticona Facility
inspection date: flg/2C/2G11 Inspection Type: Compliance Evaluation
Yes No NA NE
Fiitration (High Rate Tertiary)
Down flow
Type of operation:
00
Is the filter media present?
�n00
Is the filter surface free of clogging?
nnn01
Is the filter free of growth?
0 0 0 M
Is the air scour operational?
000
Is the scouring acceptable?
nn�n
_
Is the c!gar well free of excessive solids and filter media?
Comment:
Yes No INA NE
--
Lagoons
Type of lagoons?
3
# Number of lagoons in operation at time of visit -
Series
Are lagoons operated in?
nnn
# Is a re -circulation line present?
nnn
Is lagoon free of excessive floating materials?
nnn
# Are baffles between ponds or effluent baffles adjustable?
ro nnn
Are dike slopes clear of woody vegetation?
nnn
Are weeds controlled around the edge of the lagoon?
��nnn
Are dikes free of seepage?
nnnn
Are dikes free of erosion?
n 0, rl
Are dikes free of burrowing animals?
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple'locations?
# If excessive algae is present, has barley straw been usad to heip control the growth?
❑nVn
.000
Is the lagoon surface free of weeds?
Is the lagoon free of short circuiting?
Comment:
Yes No NA NE
PrIrnps-RAS-WAS
n
Are pumps in place? 11
00
Are pumps operational?
nL
Are there adequate spare parts and supplies on site?
Page # 6

Permit: NC0004952
Inspection Date: 09/20/2011
Pumps-RAS-VITAS
Comment:
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment:
Flow Measurement - Effluent
Owner - Facility: Ticona rac,iit i
Inspection Type: Compliance =iaivaron
Yes No NA NE
# Is flow meter used for reporting?
0
n
n
n
Is flow meter calibrated annually?
®
n
n
n
Is the flow meter operational?
n
n
n
(If units are separated) Does the chart recorder match the flow meter?
n
n
®
n
Comment: The effluent flow meter is calibrated quarterly.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
n
n
n
Is sample collected below all treatment units?
®
❑
❑
❑
Is proper volume collected?
®
n
n
n
Is the tubing clean?
®
❑
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
M
n
n
n.
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
n
n
n
Comment:
Upstream / Downstream Sampling
Yes
No
NA
NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)?
®
n
n
n
Comment:
Page # 7

O� 'NAT�9 Beverly Eaves Perdue, Governor
Dee Freeman, Secretary
y North Carolina Department of Environment and Natural Resources
r'
Paul E. Rawls, Chairman
Water Pollution Control System Operators Certification Commission
June 22, 2011
PEM Carter, Sr. Environmental Engineer
CAN Holdings, Inc. — Ticona
2525 Blacksburg Road, Grover, NC 28073
Subject: Re-classification of Water Pollution Control System
CNA Holdings, Inc. Ticona WWTP
Permit No. NC0004952
Cleveland County
Dear Ms. Carter:
This is to advise you about a change in the classification of the subject facility, as we
discussed this morning on the telephone.
Regional office staff pointed out that the current classification was not accurate and
recommended it be changed to Grade 3 Biological.
Based on that recommendation, the Water Pollution Control System Operators Certification
Commission has determined that the subject facility is classified as a Grade 3 Biological
Water Pollution Control Treatment System.
As required by 15A NCAC 8G .0202 and your permit, you must designate a Grade 3 or
higher Biological Operator in Responsible Charge (ORC) and a Back-up Operator with at
least a Grade 2 Biological certification.
If you wish to make changes to your designated operators for this facility, please complete
and submit the enclosed ORC Desisnation Form to this office within 120 days.
If you have any questions concerning this classification or the designation of operators,
please contact me at 919.733.0026 ext. 314, or via email at [e-mail].
Sincerely,
Extension Education & Training Specialist
Cc: Mooresville Regional Office — Barbara Sifford, via email
TACU File
Central Files
Technical Assistance & Certification Unit
1618 Mail Service Center, Raleigh, NC 27699-1618
DENR Customer Service Center
An Equal Opportunity Action Employer
Ki)E.s ��
Internet http://ncwaterquality.org/tacu
Telephone [phone] Fax [phone]
Telephone [phone]
50% recycled/10% post -consumer paper

\Q��� Beverly Eaves Perdue, Governor
Dee Freeman, Secretary
7 North Carolina Department of Environment and Natural Resources
Paul E. Rawls, Chairman
O Water Pollution Control System Operators Certification Commission
June 22, 2011
PEM Carter, Sr. Environmental Engineer
CAN Holdings, Inc. — Ticona
2525 Blacksburg Road, Grover, NC 28073
Subject: Re-classification of Water Pollution Control System
CNA Holdings, Inc. Ticona WWTP
Permit No. NC0004952
Cleveland County
Dear Ms. Carter:
This is to advise you about a change in the classification of the subject facility, as we
discussed this morning on the telephone.
Regional office staff pointed out that the current classification was not accurate and
recommended it be changed to Grade 3 Biological.
Based on that recommendation, the Water Pollution Control System Operators Certification
Commission has determined that the subject facility is classified as a Grade 3 Biological
Water Pollution Control Treatment System.
As required by 15A NCAC 8G .0202 and your permit, you must designate a Grade 3 or
higher Biological Operator in Responsible Charge (ORC) and a Back-up Operator with at
least a Grade 2 Biological certification.
If you wish to make changes to your designated operators for this facility, please complete
and submit the enclosed ORC Desiznation Form to this office within 120 days.
If you have any questions concerning this classification or the designation of operators,
please contact me at 919.733.0026 ext. 314, or via email at [e-mail].
Sincerely,
Extension Education & Training Specialist
Cc: Mooresville Regional Office — Barbara Sifford, via email
TACU File
Central Files
Technical Assistance & Certification Unit
1618 Mail Service Center, Raleigh, NC 27699-1618
DENR Customer Service Center
An Equal Opportunity Action Employer
Internet http://ncwaterquality.org/tacu
Telephone [phone] Fax [phone]
Telephone [phone]
50% recycled/10% post -consumer paper
ENR

0� �1A Beverly Eaves Perdue, Governor
4 Dee Freeman, Secretary
fly North Carolina Department of Environment and Natural Resources
r
Paul E. Rawls, Chairman
Water Pollution Control System Operators Certification Commission
June 22, 2011
PEM Carter, Sr. Enviromnent4l Engineer
CAN Holdings, Inc. — Ticona
2525 Blacksburg Road, Grover, NC 28073
Subject: Re-classification of Water Pollution Control System
CNA Holdings, Inc. Ticona WWTP
Permit No. NC0004952
Cleveland County
Dear Ms. Carter:
This is to advise you about a change in the classification of the subject facility, as we
discussed this morning on the telephone.
Regional office staff pointed out that the current classification was not accurate and
recommended it be changed to Grade 3 Biological.
Based on that recommendation, the Water Pollution Control System Operators Certification
Commission has determined that the subject facility is classified as a Grade 3 Biological
Water Pollution Control Treatment System.
As required by 15A NCAC 8G .0202 and your permit, you must designate a Grade 3 or
higher Biological Operator in Responsible Charge (ORC) and a Back-up Operator with at
least a Grade 2 Biological certification.
If you wish to make changes to your designated operators for this facility, please complete
and submit the enclosed ORC DesiF-nation Form to this office within 120 days.
If you have any questions concerning this classification or the designation of operators,
please contact me at 919.733.0026 ext. 314, or via email at [e-mail].
Sincerely,
Extension Education & Training Specialist
Cc: Mooresville Regional Office — Barbara Sifford, via email
TACU File
Central Files
Technical Assistance & Certification Unit
1618 Mail Service Center, Raleigh, NC 27699-1618
DENR Customer Service Center
An Equal Opportunity Action Employer
Internet http://ncwaterquality.org/tacu
Telephone [phone] Fax [phone]
Telephone [phone]
50% recycled/10% post -consumer paper

11c®na
Certified Mail 7005 1160 0004 9234R6�_,.>_
kc
Return Receipt to PEM Carter �` Ft 4
Ticona
2525 Blacksburg Road
APR 2 7 2009 Grover, NC 28073-9641
April 22, 2009
Carolina Star Worksite
ISO 9001, ISO/TS 16949,
ISO 17025,and ISO 14001
PEMC09:16f d`�i _ :? '.t : ` . l,,. `' ,' €on
NC Department of Environmental and Natural Resources
Division of Water Quality — Mooresville Office
610 East Center, Suite 301
Mooresville, NC 28115
Dear Mr. Parker:
Subject: Stormwater NPDES- NCS 000064 and Wastewater NPDES NC0004952
CNA Holdings, Inc,: Ticona Polymers, Shelby Plant
2525 Blacksburg Road, Grover, NC 28073
This is to inform you that the following communications pertaining to the above EPA Permit
should be directed as follows:
Facility/Technical Contact
PEM Carter, Env. Eng.
704-480-4900
[e-mail]
Authorized / Invoice Contact
Lanny Duvall, Site Director
704-480-4980
Ian ny.duvalla-celanese.com
Please correct your records, and communicate to others in need of this information. We request
the removal of all previous contacts for they are no longer employed at this facility. Thank you for
prompt attention to this request and if you should have any further questions, please feel free to
contact me at [phone], or via email at pem.carter( ticona.com .
In rely,
PEM Carter
Sr. Environmental Engineer
Ticona
Celanese
Ticona
A business of Celanese

i icona
CERTIFIED MAIL 7004 2510 0002 9276 6197
Returned Receipt to PEM Carter
December 29, 2008 Ticona
2525 Blacksburg Road
PEMC08:44 Grover, NC 28073-9641
NC Department of Environment and Natural Resources Carolina Star Worksite
Division of Water Quality 1509001,I5olrS 16949,
610 East Center Avenue — Suite 301 ISO 17025,and ISO 14001
Mooresville, NC 28115
Attn: Ms Donna Hood
Re: Report of the Pump Failure at North Stormwater Outfall—12/29108
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as a written notification of the brief pump failure at the North Stormwater Outfall which failed at
9:35 a.m. today (12/29/08) and was repaired and operating by 2:00 p.m, today. "Benchmark" parameters per
NCS000064 have been performed on the waters leaving the North outfall, except for BOD5. The pump failure
was initially reported to Sumar Boughazale's voicemail at 3:25 p.m. and then to you, at 3:37 p.m. Based on the
below results, no waters leaving our site will impact receiving streams/tributaries. The quantity of waters
discharged during this timeframe: 289 gallons
Discharge Volume: 1289
Test Parameters:
pH: 7.2
COD: < 50 mg1l
BOD& pending
TSS: 3.4 mg1l
Color: clear
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
A BOD5 sample is being analyzed by outside contract laboratory, Prism Laboratories, Inc.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at [e-mail]
Sinc ely,
PEM Carter ;q
Sr. Environmental Engineer
Cc: Sumar Boughazale, Mooresville Regional NCDENR
JH N'-. - �-- pnnq,
Celanese
Ticona.
A business of Celanese

A
Am .
D .
North Carolina Department of Environment and Natura
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
January 29, 2010
Mr. Lanny Duvall, Site Manager
CNA Holdings, Inc.
2525 Blacksburg Road
Grover, North Carolina 28073
Resources
Subject: Compliance Evaluation Inspection
CNA Holdings, Inc. — Ticona Facility
NPDES Permit No. NC0004952
Cleveland County, N.C.
Dear Mr. Duvall:
Dee Freeman
Secretary
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on January 14, 2010, by Mr. Wes Bell of this Office. Please
inform the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the
enclosed report.
The report should be self-explanatory; however, should you have any questions concerning
this report, please do not hesitate to contact Mr. Bell at [phone].
Sincerely, j
I '
-�-� Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure:
Inspection Report
cc: Cleveland County Health Department
ow
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One L' 1
Phone: [phone] Fax: [phone] Customer Service:1-877-623-6748 NOl tll�ai01111c`l
Internet: hffp://portal.ncdenr.org/web/wq An Equal Opportunity1 Affirmative Action Employer - 50% Recycled110% Post consumer paper Na " tl ma ly

United States Environmental Protection Agency
Form Approved.
E P /� Washington, D.C. 20460
/`1
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 15I 31 N00004952 111 121 10/01/14 117 18I CI 19I SI 20III
Remarks
21IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA -----------------Reserved- --------- --- ---- -
67 I 1.5 169 70 14 I 71 I N I 72I N I 13 I I 174 711 I I I I I I 180
w
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)
Ticona Facility
09:50 AM 10/01/14
09/06/01
Exit Time/Date
Permit Expiration Date
NC Hwy 198
Shelby NC 28150
01:50 PM 10/01/14
.13/08/31
Name(s) of Onsite Represent ative(s)/ritles(s)/Phone and Fax Number(s)
Other Facility Data
Michael R. Queen/ORC/704-480-4692/
Pem Carter/Engineer Env Sr/704-480-4900 /
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Lanny Duva11,2525 Blacksburg Rd Grover NC 280739641/Site
Manager/704-480-4980/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit ' Flow Measurement ® Operations & Maintenance ® Records/Reports
Self -Monitoring Program Sludge Handling Disposal. Facility Site Review ® Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment. summary)
Name(s) and Signature(s) of Inspector(s))' Agency/Office/Phone and Fax Numbers Date
Wesley N Bell � � o [/ // MRO WQ//704-663-1699 Ext.2192/ A2,
gnat of ManagemenhQ A Rev war Agency/Office/Phone and Fax Numbers , Pate
Marcia Allocco MRO WQ//704-663-1699 Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

t
NPDES yr/mo/day Inspection Type 1
3I NC0004952 I11 12I 10/01/14 1
17 18ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

I
Permit: NC0004952 Owner -Facility: Ticona Facility
Inspection Date: 01/14/2010 Inspection Type: Compliance Evaluation
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
010
■
n
Is the facility as described in the permit?
■
n
n
# Are there any special conditions for the permit?
n
n
0
Is access to the plant site restricted to the general public?
®
n
n
n
Is the inspector granted access to all'areas for inspection?
■
n
n
n
Comment: The subject permit expires on 8/31/13.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
n
n
n
Is all required information readily available, complete and current?
®
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
n
n
Are analytical results consistent with data reported on DM Rs? ..
®
n
n
n
Is the chain -of -custody complete?
®
n
n
n
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?
®n
n
n
Has the facility submitted its annual compliance report to users and DWQ?
n
n
®
n
(If the facility is = or > 5 MGD permitted flow) Do they operate. 24/7 with a certified operator on each shift?
n
ONO
Is the ORC visitation log available and current?
®
n
n
n
Is the ORC certified at grade equal to or higher than the facility classification?
®
n
n
n
Is the backup operator certified at one grade less or greater than the facility classification?
®n
n
n
Is a copy of the current NPDES permit available on site?
®n
n
n
Facility has copy of previous year's Annual Report on file for review?
n
ONO
Page # 3

t
Permit: NC0004952
Inspection Date: 01/14/2010
Owner -Facility: Ticona Facility
Inspection Type: Compliance Evaluation
V__ AI- KIA AIC
Record Keeping
Comment: The facility's records were organized and well maintained. Discharge
Monitoring Reports (DMRs) were reviewed for the period November 08 through October
09. No limit violations were reported and all monitoring frequencies were correct. The
same upstream and downstream sampling times were documented on the chain of
custody (COC) forms and DMRs. The facility staff must ensure separate upstream and
downstream sampling times are documented on future COC forms and DMRs.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? ® n n n
Are all other parameters(excluding field parameters) performed by a certified lab? ■ I_l n n
# Is the facility using a contract lab? ® ❑ n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ® ❑ n n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? n n n
Incubator.(BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? n n ® n
Comment: Effluent analyses (pH, dissolved oxygen, temperature, fecal coliform, total
suspended solids) are performed by the on -site laboratory (Certification #221). Prism
Laboratories, Inc. and ETT Environmental, Inc. have also been contracted to provide
analytical support. The laboratory instrumentation used for field analyses appeared to
be properly calibrated (and documented).
Effluent Sampling
Yes No
NA
NE
Is composite sampling flow proportional?
®
❑
❑
n
Is sample collected below all treatment units?
®
❑
Is proper volume collected?
n
n
n
Is the tubing clean?
®
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
®
n
n
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
®n
n
n
Comment: The subject permit requires effluent composite and grab sampling.
Upstream Downstream Sampling
Yes
No
NA
NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ®n
n
n
Comment:
Operations & Maintenance
Yes
No
NA NE
Is the plant generally clean with acceptable housekeeping?
®n
n
n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge
®n
n
n
Judge, and other that are applicable?
Page # 4

Permit: NC0004952
Inspection Date: 01/14/2010
Owner - Facility: Ticona Facility
Inspection Type: Compliance Evaluation
Operations & Maintenance
Comment: The facility appeared to be properly operated and well maintained. The
facility staff incorporate a comprehensive process control program.
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment: Screenings and grit are transported and disposed by a contracted
company (currently Veolia).
Equalization Basins,
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Comment: The facility uses three equalization basins for the pH adjustment of the
process/chemical wastestreams. An emergency 500,000 gallon equalization tank
(normally empty) is also available for the isolation of spills and/or the collection/storage
of high COD influent wastestreams.
. (`hnmirol Gonrl .
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment: A small leakage was observed adjacent to the secondary containment.
structure for the phosphoric acid. The. facility staff indicated that the leakage would be
immediately repaired.
Yes No NA NE
■nnn
■nnn
® n n n
rin®n
nna
nn■n
n F1
®nnn
Yes No NA NE
®nnn
® n n n
nnn
®nnn
Page # 5

Permit: NC0004952 Owner -Facility: Ticona Facility
Inspection Date: 01/14/2010 Inspection Type: Compliance Evaluation
Aeration Basins
Yes No NA
NE
Mode of operation
Surface
Type of aeration system
Is the basin free of dead spots?
■
n
n
n
Are surface aerators and mixers operational?
®
n
❑
■
fl
❑
❑
Are the diffusers operational?
Is the foam the proper color for the treatment process?
■
rl
❑
Does the foam cover less than 25% of the basin's surface?
■
0
❑
❑
■
n
n
n
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
®
❑
❑
Comment: The facility has two aeration basins equipped with mechanical and surface
aeration. A mechanical aerator in one of the aeration basins has been removed and
replaced with a section of air diffusers...
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
❑
0
0
Is the site free of excessive buildup of solids in center well of circular clarifier?
®
fl
Are weirs level?
®
0
MOOD
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
MOO
Is scum removal adequate?
■
❑
fl
fl
Is the site free of excessive floating sludge?
®
❑
fl
fl
®
❑
❑
rl
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
®n
n
n
Is the overflow clear of excessive solids/pin floc?
®
n
00
Is the sludge blanket level acceptable? (Approximately '/4 of the sidewall depth)
® L
fl n
Comment: The.facility is equipped with two secondary clarifiers; however, one of the
clarifiers has been temporarily taken off-line to repair a sludge pump.
Lagoons
Type of lagoons?
# Number of lagoons in operation at time of visit? 3
Series
Are lagoons operated in?
# Is a re -circulation line present? ❑ ❑ ® El
Page # 6

Permit: NC0004952 Owner -Facility: Ticona Facility
Inspection Date: 01/14/2010 Inspection Type: Compliance Evaluation
Lagoons
Yes
No
NA
NE
Is lagoon free of excessive floating materials?
■
❑
❑
n
# Are baffles between ponds or effluent baffles adjustable?
❑
❑
■
Are dike slopes clear of woody vegetation?
®
n
❑
❑
Are weeds controlled around the edge of the lagoon?
■
❑
❑
n
Are dikes free of seepage?
Are dikes free of erosion?
®
❑
❑
n
Are dikes free of burrowing animals?
®
❑
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
❑
❑
0
n
# If excessive algae is present, has barley straw been used to help control the growth?
❑
n
■
❑
Is the lagoon surface free of weeds?
®
n
n
ri
Is the lagoon free of short circuiting?
®
n
n
n
Comment: The facility is equipped with three polishing ponds that are operated in
series. Overall, the polishing ponds were well maintained; however, the facility staff
must ensure to appropriately address the small stand of vegetation and the hole
(potentially a burrowing aninmal) observed near the base of the berm• at the final
polishing pond (EQC).
Filtration (High Rate Tertiary)
res
no
nH
nC
Type of operation:
Down flow
Is the filter media present?
■
n
n
n
Is the filter surface free of clogging?
®
n
n
n
Is the filter free of growth?
❑
n
❑
Is the air scour operational?
❑
n
❑
Is the scouring acceptable?
®
❑
n
❑
Is the clear well free of excessive solids and filter. media?
■
n
n
❑
Comment: The facility's tertiary filtration system consists of six downflow filter tanks.
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
n
n
n
Is flow meter calibrated annually?
®
n
00
Is the flow meter operational?
M
❑
❑
n
(If units are separated) Does the chart recorder match the flow meter?_
❑
Q
■.
n
Page # 7

Permit: NC0004952
Inspection Date: 01/14/2010
Owner - Facility: Ticona Facility
Inspection Type: Compliance Evaluation
Flow Measurement - Effluent
Yes no NA nt
Comment: The flow meter is calibrated on a quarterly basis and was last calibrated on
11/17/09 by the Company's I & E Department.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
■ ❑ ❑ n
Are the receiving water free of foam other than trace amounts and other debris?
■ ❑ ❑ fl
If effluent (diffuser pipes are required) are they operating properly?
n n ■ n
Comment: The'effluent appeared clear with no foam. The receiving stream did not
appear to be negatively impacted.
Aerobic Digester.
Yes No NA NE
Is the capacity adequate?
■ n
Is the mixing adequate?
■
Is the site free of excessive foaming in the tank?
® ❑ ❑ fl
# Is the odor acceptable?
® ❑ fl Q
# Is tankage available for properly waste sludge?
■
Comment:. The aerobic digester is equipped with two mechanical aerators. In
addition, the facility uses two sludge storage ponds. The staff must ensure to
appropriately address the small stand of woody vegetation observed near the base of
the berm at the second sludge storage pond.
Page # 8

William G. Ross Jr., Secreta vl�
North Carolina Department of Environment and Natural Resourc s
i'
Coleen H. Sullins, Director
Division of Water Quality '
May 28, 2008
CERTIFIED MAIL #70071490 0004 4509 5232
RETURN RECEIPT REQUESTED
Ms. PEM Carter, Environmental Engineer
CNA Holdings, Inc.
2525 Blacksburg Road
Grover, North Carolina 28073-9641
Subject: Notice of Violation - Effluent Limitation
Tracking #: NOV-2008-LV-0241
Ticona Facility WWTP
NPDES Permit No. NC0004952
Cleveland County
Dear Ms. Carter:
A review of the February 2008 self -monitoring report for the subject facility revealed a
violation of the following parameter at Outfall 001:
Date
Parameter
Reported -Value
Permit Limit
2/6/08
BOD
174.4 lbs/day
164.0 lbs/day (Daily maximum)
Remedial actions, if not already implemented, should be taken to correct any problems.
Since the comments section on the reverse of the relevant Discharge Monitoring Report provided
an explanation for the noted effluent limit violation, it is not requested that a response be
submitted; however, should you have additional information concerning the violations or
comments which you wish to present, please submit them to the attention of Ms. Marcia Allocco.
The Division of Water Quality may pursue enforcement actions for this and any
additional violations. If the violations are of a continuing nature, not related to operation and/or
maintenance problems, and you anticipate remedial construction activities, then you nay wish to
consider applying for a Special Order by Consent. You may contact Ms. Allocco of this Office
for additional information.
NCDENR
NorthCarolina
Aa&rally
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: wwtiv.ncwaterquality.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal OpportunitylAffirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Ms. PEM Carter, Ticona Facility
NOV-2008-LV-0241, Page 2
May 28, 2008
If you have questions concerning this matter, please do not hesitate to contact Ms.
Allocco or me at 704/663-1699.
Sincerely,
Robert B. Krebs
Regional Supervisor
Surface Water Protection
cc: Point Source Branch
Cleveland County Health Department

NCDENR
North Carolina. Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
November 21, 2007
Steve Olp ,
CNA Holdings, Inc.
2848 Cherry Rd
Rock Hill, SC 29730
William G. Ross, Jr., Secretary
Coleen.H. Sullins, Director
Subject: Renewal Notice
NPDES Permit NC0004952
Ticona Facility
Cleveland County
Dear Permittee:
Your NPDES permit expires on August 31, 2008. 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 your renewal application, you may
disregard this notice.
To satisfy this requirement, your renewal package must, be sent to the Division postmarked no later
than March 4, 2008. Failure to request renewal by this date may result in a civil assessment of at least
$500.00. Larger penalties may be assesseddepending upon the delinquency of the request.
If any wastewater discharge will occur after August 31, 2008, the current permit 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 wastewater discharge has ceased at your facility and you wish to rescind this permit, contact
me at the telephone number or address listed below.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you
must submit with the permit renewal application. If you have any questions, please contact me at the.
telephone number or e-mail addresslisted below.
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
NPDES
1617 Mail Service Center, Raleigh, North Carolina.27699-1617 One
512 North Salisbury Street, Raleigh, North Carolina 27604 No thCarohna
Phone: [phone], extension.511 / FAX [phone] / [e-mail] Natzmally
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

NPDES PERMIT NC0004952
TICONA FACILITY
CLEVELAND COUNTY
The following items are REQUIRED for all renewal packages:
o A cover letter requesting renewal of the permit and documenting any changes at the facility since
issuance of the last permit. Submit one signed original and two copies.
O The completed application form (copy attached), signed by the permittee or an Authorized
Representative. Submit one signed original and two copies.
o If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
the renewal package, written documentation must be provided showing the authority delegatedto any
such Authorized Representative (see Part II.B.1 Lb of the existing NPDES permit).
O A narrative description of the sludge management plan for the facility. Describe how sludge (or other
solids) generated during wastewater treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed
original and two copies.
The following items must be submitted by any Municipal or Industrial facilities discharging
process wastewater:
Industrial facilities classified as Primary Industries (see Appendices A-D .to Title 40 of the Code of Federal
Regulations, Part 122) and ALL Municipal facilities with a permitted flow >_ 1.0 MGD must submit a
Priority Pollutant Analysis (PPA) in accordance with 40 CFR Part 122.21.
The above requirement does NOT apply to privately owned facilities treating 100%
domestic wastewater, or facilities which discharge non process wastewater (cooling
water, filter backwash, etc.)
PLEASE NOTE:
Due to a change in fees effective January 1, 1999, there is no renewal fee required with your
application package.
Send the completed renewal package to:
Mrs. Dina Sprinkle
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

IRA&
-®
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins d
i * Dee�F,r�ema
Jl
Governor Director z T Sec tary 5 �l
May 21, 2009 20,09
Mr. Charles Long, CMI
Executive Director DW -`° 3u&.`C1r'E) R
100 N Tryon St, Suite 3800 � f ion
Charlotte, NC 28202
Subject: Return of Application
Tax Certification for Pollution
Abatement Equipment
Real and Personal Property
CNA Holdings, Inc.
Cleveland County
Dear Mr. Long:
On May 20, 2009, our office received a phone call from Mr. Brad Sparks. At his request, we
are returning the incomplete application for the subject facility. If you would like to resubmit this
application, you may do so as soon as you are able to provide a complete application. If there is a need
for any additional information or clarification, please do not hesitate to contact Ms. Pam Whitley of our
staff at [e-mail] / 919-715-6204 or myself at [e-mail] / 919-715- .
6224. Application materials can be found at http://www.nccgl.net/TaxCertification.html.
Attachment
Cc: Cleveland County Assessor's Office
SWPS Central Files
Mooresvil!lezRogional-7 ffice --s
Construction Grants & Loans Section
Construction Grants and Loans Section
1633 Mail Service Center Raleigh NC 27699-1633
Phone: [phone] FAX: [phone] Internet: www.nccgl.net
Mark L. Hubbard, P.E., Assistant Chief
Construction Grants and Loans Section
NorthCarolina
An Equal Opportunity 1 Affirmative Action Employer

FFV
Beverly Eaves Perdu
Governor
4•�
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
e Coleen H. Sullins Dee Freeman
Director qPr renf5ir%/
June 10, 2010
P E M CARTER
CNA HOLDINGS INC
2525 BLACKSBURG RD
GROVER NC 280739641
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Ticona Facility
Permit Number: NC0004952
Case Number: LV-2010-0148
Cleveland County
Dear Mr. Carter:
This letter is to acknowledge receipt of check number 2000151462 in the amount of $835.37 received from you
dated May 27, 2010. This payment satisfies in full the above civil assessment levied against the subject facility,
and this case has been closed. Payment of this penalty in no way precludes future action by this Division for
additional violations of the applicable Statutes, Regulations, or Permits.
If you have any questions, please call Robert L Sledge at 919-807-6398.
cc: Central Files
� �� WQ 1!!T���suri�l>Ire71ional��Jlff`�����u�ez�-r�sor�
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] \ FAX: [phone] \ Customer Service: 1-877-623-6748 Nofth Ccar011llc`l
Internet: www.ncwaterquality.org � �9����
An Equal Opportunity \ Affirmative Action Employer � �/

4D4-110
'Y�
Beverly Eaves Perdue
Governor
NC®NR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
May 11, 2010
CERTIFIED MAIL 7009 2250 0004 3265 6339
RETURN RECEIPT REQUESTED
Ms. Pem Carter
Senior Environmental Engineer
CNA Holdings, Inc. - Ticona Facility
2525 Blacksburg Road
Grover, North Carolina 28073-9641
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215. 1 (a)(6) and NPDES Permit No. NC0004952
CNA Holdings - Ticona WWTP
Cleveland County
Case No. LV-2010-0148
Dear Ms. Carter:
Dee Freeman
Secretary
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $835.37
($750.00 civil penalty + $85.37 enforcement costs) against CNA Holdings-Ticona.
This assessment is based upon the following facts: A review has been conducted of the self -monitoring
data reported for February 2010. This review has shown the subject facility to be in violation of the discharge
limitations found in NPDES Permit No. NC0004952. The violations are summarized in Attachment A to this
letter.
Based upon the above facts, I conclude as a matter of law that CNA Holdings-Ticona violated the terms,
conditions, or requirements of NPDES Permit No. NC0004952 and North Carolina General Statute (G.S.) 143-
215. 1 (a)(6) in the manner and extent shown in Attachment A. A civil penalty may be assessed in accordance
with the maximums established by G.S. 143-215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the Director of the
Division of Water Quality, I, Marcia Allocco, Acting Surface Water Protection Regional Supervisor for the
Mooresville Region, hereby make the following civil penalty assessment against CNA Holdings-Ticona:
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 2811 j One
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748 NortbCarolina
Internet. Ditto:IJooral.ncdenr.orohrjebhrjq vVattarally
An Equal Opportunity \ Affirmative Action Employer— 50% Recycled/10% Post Consumer paper

$ 750.00 For 1 of the one (1) violation of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0004952, by discharging waste into the
waters of the State in violation of the permit monthly average
effluent limit for BOD.
$ 750.00
$ 85.37
$ 835.37
TOTAL CIVIL PENALTY
Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the
Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violations;
(2) The duration and gravity of the violations;
(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 violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural
Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s).
Please submit payment to the attention of.
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
no
2. Submit a written request for remission including a detailed justification for such request:

r -
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 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 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 G.S. 143B-282. I (b) were
wrongfully applied to the detriment of the petitioner;
(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 had 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 information 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 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
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:
Point Source Compliance/Enforcement Unit
Division of Water Quality
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

4
Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The petition may
be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided the signed
original, one (1) copy and a filing fee (if a filing fee is required by NCGS § 15013-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic
transmission. You should contact the Office of Administrative Hearings with all questions regarding the
filing fee and/or the details of the filing process. The mailing address and telephone and fax numbers
for the Office of Administrative Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DENR as follows:
Mary Penny Thompson, General Counsel
DENR
1601 Mail Service Center
Raleigh, NC 27699-1601
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 the violations are of a continuing nature not related to operation and/or
maintenance problems and you anticipate remedial construction activities then you may wish to consider
applyingfor or a Special Order by Consent. If you have any questions about this civil penalty assessment or a
Special Order by Consent please contact the Water Quality Section staff of the Mooresville Regional Office at
704/663-1699.
(Date) Marcia Allocco
Acting Regional Supervisor
Surface Water Protection
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
jl

V"
Outfall Date Parameter
001 2/2010 ' BOD
* Denotes civil penalty assessment
ATTACHMENT A
CASE NO. LV-2010-0148
Reported Value Permit Limit
* 108.8 lbs/day 87.0 lbs/day

STATE OF NORTH CAROLINA
COUNTY OF CLEVELAND
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTY AGAINST
CNA HOLDINGS, INC. TICONA
PERMIT NO. NC0004952
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. LV-2010-0148
Having been assessed civil penalties totaling $ 835.37 for violation(s) as set forth in the assessment
document of the Division of Water Quality dated May 11, 2010, 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 30 days of receipt of the notice of assessment. No new evidence in support of
a remission request will be allowed after 30 days from the receipt of the notice of assessment.
This the day of , 2010
BY
ADDRESS
TELEPHONE

V,
JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: LV-2010-0148
Assessed Party: CNA Holdings, Inc. Ticona
County: Cleveland
Permit Number: NC0004952
Amount Assessed: $835.37
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: (use additional pages as necessary)

r
NORTH CAROLINA DIVISION OF WATER QUALITY
Violator: CNA Holdings, Inc. Ticona
Facility: CNA Holdings Ticona WWTP
County: Cleveland
Case Number: LV-2010-0148
Permit Number:. NC0004952
ASSESSMENT FACTORS
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;
No damage has been documented. BOD in excess of the effluent monthly average permit limit would be
predicted to cause lowered dissolved oxygen downstream of the discharge.
2) The duration and gravity of the violation;
The monthly average effluent limit violation occurred during the month of February 2010. The reported
value was 25% over the permit limit.
3) The effect on ground or surface water quantity or quality or on air quality;
No effect is expected on ground water or air quantity or quality. Surface water impacts due to lowered
available dissolved oxygen and subsequent stress on aquatic life would be predicted.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
No money appears to have been saved by the noncompliance.
6) Whether the violation was committed willfully or intentionally;
The violation does not appear to be willful or intentional.
7) The prior 'record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
The facility has a good compliance record. No enforcement actions have been taken in the previous 12-
month period.

8) The cost to the State of the enforcement procedures.
Date
Staff preparation of enforcement package: 1 hour at $32.54/hour
SWP Regional Supervisor review: 1 hour at $37.83/hour
Clerical Support: 1 hour at $15.00/hour
Total: $85.37
RO Supervisor
Division of Water Quality

4
1
MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 05/06/10 Page: 7 of 26
I Permit: %
MRs Between: 2-2010 and 2 2010 Region: Mooresville
Violation Category: Limit Violation Program Category: NPDES WW I
,Facility Name: %
Param Name: % County: %
Subbasin: %
Violation Action: %
Major Minor: %
f
PERMIT: NCO081370
FACILITY: City of Claremont - McLin Creek WWTP
COUNTY: Catawba
REGION: Mooresville
Limit Violation
MONITORING OUTFALL /
VIOLATION UNIT OF
CALCULATED
REPORT PPI
LOCATION PARAMETER DATE FREQUENCY MEASURE
LIMIT
VALUE % OVE�LIMITIOLATION
TYPE VIOLATION ACTION
02-2010 001
Effluent Nitrogen, Ammonia Total (as 02/27/10 Weekly mg/I
12
15.1 25.ly
Average Exceeded None
N) - Concentration
02 -2010 001
Effluent Nitrogen, Ammonia Total (as 02/28/10 eekly mg/I
4
10. 152.9
Monthly Average Exceeded None
N) - Concentration
PERMIT: NC0004685
FACILITY: PPG Industries Fiber Glass Products Inc -R �Sh
COUNTY: Cleveland
REGION: Mooresville
facility
Limit Violation
MONITORING
OUTFALL/
VIOLATION
REPORT
PPI
LOCATION PARAMETER
02 -2010
001
Effluent Nitrogen, Ammonia Total (as
0
N) - Concentration
ZOWeekly
02 -2010
001
Effluent Nitrogen, Ammonia Total (as
0
N) - Concentration
UNIT OF CALCULATED
MEASURE LIMIT VALUE %OVER LIMIT
mg/I 9 9. 8.89
mg/I 6 6.33 5.42
VIOLATION TYPE VIOLATION ACTION
Daily Maximum Exceeded None
Monthly Average Exceeded None
PERMIT: NC0004952 FACILITY: CNA Holdings Inc - Ticona Facility COUNTY: Cleveland REGION: Mooresville
Limit Violation L% - ZDID d� P
MONITORING OUTFALL / VIOLATION UNIT OF CALCULATED
REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE % OVER LIMIT VIOLATION TYPE VIOLATION ACTION
02 -2010 001 Effluent BOD, 5-Day (20 Deg. C) - 02/28/10 5 X week Ibs/day 87 108.83 25.09 Monthly Average Exceeded None � 75D
Quantity Daily
37

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
TO: File
FROM: M. Allocc
Z1101W
DATE: October 14, 2008
SUBJECT: CNA Holdings Ticona Plant W WTP
Ms. PEM Carter reported a failure in the effluent discharge pumps from the facility at 5:00 pm
on October 13, 2008. She stated that the 24-hr composite sampler did not collect sample after 5:00 pm
on October 13, 2008, when the discharge pumps failed ceasing a discharge from the WWTP. Ms. Carter
was advised to make a note on the October DMR of the discharge pump failure and its effect on the
composite sample collected on October 14, 2008.
NCDENR
No thCarolina
Natural�1ff
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: www.ncwaterquality.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Ms. PEM Carter, Environmental Engineer
CNA Holdings, Inc.
2525 Blacksburg Road
Grover, North Carolina 28073
Dear Ms. Carter:
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Coleen H. Sullins, Director
AUG 2 8 2008
r
Subject: Draft NPDES Permit
Permit NC0004952
Ticona Facility
Cleveland County
Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft
carefully to ensure thorough understanding of the conditions and requirements it contains.
Changes to your existing permit are summarized below.
• Effluent limitations for BOD, TSS, and OCPSF parameters have been updated in
accordance with the most current 40 CFR and the flow information .reported in your
application- package.
_ Please submit any comments to me no later than thirty days following your receipt of the draft.
Comments should be sent to the address listed at the bottom of this page. If no adverse
comments are received from the public or from you, this permit will likely be issued in late
October, with an effective date of December 1, 2008.
If you have any comments, questions, or concerns regarding this draft permit, call me at (919)
807-6393.
Sincerely,
tSer.gei Chernikov
ironmental Engineer II
NPDES-West
cc: NPDES Unit
Poo" R "FRor al K.t'+� ffa /Surface Water Protection (draft permit, fact sheet)
Atic Toxicol'o�" ni raft permit)
EPA Region 4 (draft permit, fact sheet, .permit application)
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE [phone]
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES

Permit NC0004952
STATE OF NORTH CAROLINA
DEPARTMENT OF- ENVIRONMENT AND NATURAL RESOURCES
. DIVISION OF WATER QUALITY.
Draft PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, .
CNA Holdings, Inc.
is hereby authorized to discharge wastewater and stormwater from a facility located at
CNA Holdings, Inc. - Ticona Facility
On NC Highway 198
South of Shelby
Cleveland County
to receiving waters designated as Buffalo Creek in the Broad River Basin in accordance with effluent
limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof.
The permit shall become effective
This permit and the authorization to discharge shall expire at midnight on August 31, 2013.
Signed this day
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

1
Permit NC0004952
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
per-mit-eonditions, : requir—emen -s, to-r-ms—and-provisions-ineludec--he-rein.
CNA Holdings, Inc.
Ticona Facility
is hereby authorized to:
1. Continue to operate an existing 0.8 MGD activated sludge wastewater treatment facility
located at on NC Highway 198, south of Shelby in. Cleveland County, consisting of:
• comminutor;
• bar screen & grit chamber;
• three (3) equalization basins utilizing pH adjustment;
• two (2) aeration basins with chlorine added on an as -needed basis;
• two (2) secondary clarifiers with polymer addition;
• dual media tertiary treatment system;
• ultraviolet disinfection;
• a waste activated sludge digester;
• two (2) sludge ponds; and ,
• three (3) polishing ponds.
2. Discharge groundwater, process and domestic wastewaters, and first -flush stormwater
from the treatment works described in item. one above and boiler water make-up and
blowdown, clarifier blowdown, cooling tower make-up and blowdown, fire lagoon water,
and non -process spin -finish and Vectra wastewaters at the location specified on the
attached map through outfall 001 into Buffalo Creek, a class C water in the Broad River
Basin.

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,CNA Holdings - Ticona Facility' NC0004952
Facility.
-Location'
USGS Quad. Name: Blacksburg North ..-
Receiving Stream: Buffalo Creek , ' ;
Laf: 35011'15"
Long:: 81°30'37"
Stream Class: C
SuYadkin 60805
;
Not t0 SCALE
/��bbasin: d rth

Permit NC0004952
A (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until permit expiration, the Permittee is authorized to
discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below:
3 PARAMETER
T TIQN
x
RING-R-EQUIRFMENT
Monthly
Daily
Mazamum, ,
Measurement
; - Fre uenc''
Sample
e, ..-
Sample
. Locations `
Flow (MGD)
0.8
Continuous
Recording
Effluent
BOD, 5-day, 200C
87.0 lbs/day
215.0 lbs/day
Daily
Composite
Effluent
Total Suspended Solids
138.0 lbs/day
382.0 lbs/day
Daily
Composite
Effluent
Fecal Coliform (Geometric Mean)
200 / 100 mL
400 / 100 mL
Weekly
Grab
'Effluent
Oil and Grease
Quarterly
Grab
Effluent
Total Copper
Monthly
Composite
Effluent
Total Nitrogen (NO2+NO3+TKN)
Semi -Annually
Composite
Effluent
Total Phosphorus
Semi -Annually
Composite
Effluent
Chronic Toxicity2
Quarterly
Composite
Effluent
Pollutant Analysis
See Note 3
Composite
Effluent
PH
Between 6.0 and 9.0 Standard Units
Daily
Grab
Effluent
40 CFR 414 Subpart I Monitoring
See Section A (2.)
Notes:
1 Effluent is defined as final effluent from the polishing ponds.
2 Chronic Toxicity. (Ceriodaphnia) P/F @ 5.8%; March, June, September, December; see Part I, Section A (3.) of
this permit.
3 _ The priority pollutant analysis shall be conducted during the month prior to submittal of the permit renewal _
application. See Section A (4.) of this permit.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE
AMOUNTS.

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Permit NC0004952
A (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - CONTINUED
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply
with the limitations and monitoring frequencies established below at outfall 001:
PARAMETER
EFFLUENT LIMITATIONS ,
_
MONITORING REQUIREMENTS"
'
Monthly
& .Avers el"
Daily
Maxamuml.
:Measurement'
Fre " ueiic' , ,
Sample
Ty a
Sample
Location
2,6-Dinitrotoluene
0.798
2.005
Annually
Grab
Effluent
Ethylbenzene
0.100
0.338
Annually
Grab
Effluent
Fluoranthene
0.078
0.213
Annually
Grab
Effluent
Fluorene
0.069
0.185
Annually
Grab
Effluent
Hexachlorobenzene
0.051 µ /L
Annually
Grab
Effluent
Hexachlorobutadiene
0.063
0.153
Annually
Grab
Effluent
Hexachloroethane
0.066
0.169
Annually
Grab
Effluent
Methyl Chloride
0.269
0.594
Annually
Grab
Effluent
Methylene Chloride
0.125
0.278
Annually
Grab
Effluent
Naphthalene
0.069
0.185
Annoy
Grab
Effluent
Nitrobenzene
0.084
0.213
Annually
Grab
Effluent
2-Nitrophenol
0.128
0.216
Annually
Grab
Effluent
4-Nitrophenol
0.225
0.388
Annually
Grab
Effluent
Phenanthrene
0.069
0.185
Annually
Grab
Effluent
Phenol
0.047
-0.081
Annually
Grab
Effluent
Pyrene
0.078
0.210
Annually
Grab
Effluent
Tetrachloroethylene
0.069
0.175
Annually
Grab
Effluent
Toluene
0.081
0.250
Annually
Grab
Effluent
1,2,4-Trichlorobenzene ..
0.213
0.438
Annually.
Grab
Effluent
1,1,1-Trichloroethane
0.066
6.169
Annually
Grab
Effluent
1,1,2-Trichloroethane
0.066-
0.169
Annually
Grab
Effluent
Trichloroethylene
0.066
0.169
Annually
Grab
Effluent
Vinyl Chloride
0.325
0.838
Annually
Grab
Effluent
Notes-
1 All units are lbs/day unless otherwise noted.
2 Where the limit of detection of an approved analytical method utilized by the Permittee is greater than the
stated effluent limitation, an analytical result below the limit of detection shall constitute compliance with the
effluent limitation.

Permit NC0004952
A (3.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) — OUTFALL 001
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia
dubia at an effluent concentration of 5.8%.
The permit holder shall perform at a minimum, quarterl monitoring using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase
II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of March, June, September, and December. Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit,
then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described
in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration -
having no detectable impairment of reproduction or. survival and the lowest concentration that does have a detectable
impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes,
and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form
(MR-1) for the months in which tests were performed. If reporting pass/fail results using the parameter code TGP3B, DWQ
Form AT-1(original) is sent to the below address. If reporting Chronic Value results using the parameter code THP313, DWQ
Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the
end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response
data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the
effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee
will complete the infoimation located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit
number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the
form. The report shall be submitted to the Environmental Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required
during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality
indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring
requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the results -of such monitoring shall be
included in the calculation & reporting of the data subinitted on the DMR & all AT Forms submitted..
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival,
minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial
monitoring.

Permit NC0004952
A (4). POLLUTANT ANALYSIS CONDITION
The Permittee shall conduct a test for pollutants once every five years at the effluent from the treatment plant.
The discharge shall be evaluated as follows:
A. oiiutarrt analysis-ouent- must -bE-completed-usirrg-E-PA--approved-methods-for-the-foilowin
analytic fractions:
• purgeables (i.e. volatile organic compounds);
• acid extractables;
• base/neutral extractables;
• organochlorine pesticides and PCBs;
• herbicides; and
• metals and other inorganics.
The Pollutant Analysis Monitoring (PAM) Requirement Reporting Form A and accompanying memo, to be
provided to all discharges impacted by this monitoring requirement, describes the sampling and analysis
requirements and lists chemicals to be included in the pollutant analysis.
B. Other significant levels of synthetic organic chemicals must be identified and approximately quantified. For -
the purposes of implementing this requirement, the largest 10 GC/MS peaks in the purgeable,
base/neutral extractable, and acid extractable fractions (or fewer than 10 if less than 10 unidentified peaks -
occur) for chemicals other than those specified on the PAM reporting form should be identified and
approximately quantified as stated in the aforementioned reporting form. This part (item B) of the PAM
requirement is to be referred to as the "10 significant peaks rule".
A (5). GROUNDWATER TREATMENT AND REPORTING CONDITION
The Permittee shall submit to the Division a copy of its Semi -Annual Reports on Operable Unit 1 at the same time
that it submits such reports to U.S. EPA Region IV and the North Carolina Division of Waste Management. The
Permittee shall not be required to submit a Semi -Annual Report to the Division for any period in which there- was
no flow of groundwater from Operable Unit 1 to the wastewater treatment plant.
The Permittee shall maintain the sequencing batch reactor treatment system previously used to treat extracted
groundwater in an idled, but standby, mode such that it can be employed in the event the groundwater has an
adverse impact on the activated sludge treatment, system.

8/15/2008
NCDENR/ DW - -
_- FACT SHEET FOR NFDES PERMIT DEVELOPMENT--- -
CNA Holdings, Inc.
Icona Faci i y
NPDES Permit Number NC0004952
�h•� ,. "rt#. �atX'
��x a •.�nrFacilx
a �:. 1 ... � '4'S F �'tiw'��'J,'�` � ,a`'.- t--s-c'�,+'a;€= .b. `'"ate+-�a''c '-
=Information , f, .v,.�.e.tx
(1.) Facility Name:
CNA Holdings, Inc. — Ticona Facility
(2.) Permitted Flow GD :
0.8
6.) County.
Cleveland
3.) Facility Class:
III
7.) Regional Office:
Mooresville
Pretreatment Pro ram:
NA
8. USGS To o Quad:
G12NE
_4.
(5.) Permit Status:
Renewal
1 (9.) USGS Quad Name:
Blacksburg North
g�
'Strearri Char"a_ cteristicsk t f; `
(1.) Receiving Stream:
Buffalo Creek(7.)1Drainage
Area (ft
1 154 -
(2.) Sub -basin:
03-08-05
(8.) Summer 7Q10 cfs):
20
3. Stream Index Number:
9.) Winter 7Q10 (cfs):
46
(4.) Stream Classification:
(5.) 303(d) Status: I
C
Impaired
(10.) 30Q2 (cfs):
(11.) Average Flow (cfs):
NA
216
(6.) 305(b) Status:
Sup orting .
(12.) IWC %:
5.8%
PROPOSED CHANGES
• Effluent limitations for BOD, TSS, and Subpart I parameters have been modified to
reflect actual production for the previous three years.
BACKGROUND
This is a permit renewal for a major industrial wastewater treatment facility with a current
facility design and permitted flow of 0.8 MGD with a discharge to Buffalo Creek in the Broad
River Basin. Buffalo Creek is a 303(d) listed stream on North Carolina's 2008 impaired streams
list. This listing was the result of violating turbidity standard.
FACILITY INFORMATION
The subject facility manufactures thermoplastic resins and then extrudes a portion of those
resins into synthetic fibers. As such, 40 CFR 414.30 and 414.40 are applicable. Information
regarding guideline load allocations is presented in the Permit Development portion of this
document.
In addition to manufacturing operations, this facility has operated a pump -and -treat
groundwater remediation facility regulated by North Carolina's Superfund program for some
time. During the last permit renewal DWQ (after consultation with NC Hazardous Waste
Program and EPA) allowed the facility to idle the pump -and, -treat system, thus directing pumped
groundwater to the headworks of the activated sludge treatment system.
PERMIT DEVELOPMENT -
Limitations for BOD, TSS, and OCPSF parameters have been updated using appropriate process
wastewater flow information and the appropriate federal effluent guidelines (sed attached
spreadsheet). =-

NPDES Permit Fact Sheet - August 14, 2008 CNA Holdings, Inc - Ticona Facility
Page 2 NC0004952
TOXICITY TESTING
Current Requirement: Quarterly Chronic Toxicity @ 5.8% MAR, JUN, SEP, DEC
Recommended Requirement: Quarterly Chronic Toxicity @ 5.8% MAR, JUN, SEP, DEC
''' ze ae t3�-has�een-ecrosister�tly pass tests-with-one-exception-irrSeptember-of
2006, the subsequent tests passed.
COMPLIANCE SUMMARY
DMRs have been reviewed for the period January 2004 through June 2008. Facility has a
mixed good compliance record. During the review period, the following NOVs (notices of .._
violation) have been issued: 5/28/08 - BOD; 03/27/07 - BOD, 12/ 18/08 WET, 3/22/06 -
BOD, 11/9/05 - failure to report copper, 12/2/04 - TSS..
A compliance evaluation inspection conducted on July 2, 2008 determined that the facility is in
compliance.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: August 27, 2008
Permit Scheduled to Issue: October 20, 2008
STATE CONTACT
If you have any questions on any of the above information or on the attached permit, please
contact Sergei Chernikov at [phone].
REGIONAL OFFICE COMMENTS:
Name: Date:

Whole Effluent Toxicity Testing�Self-Monitoring
Summary
July 14, 20(
FACILITY
QUIREMENT
YEAR JAN
FEB MAR
APR
MAY JUN JUL
AUG SEP OLT_ NOV DEC
CMUD-Sugar Cr. WWTP
chr lira: 90%
Cee7dChV
2004 —
Pass —
—
>100 — —
>100 — — 97.5,>100(P) —
NCO024937/001 Begin:6/1/2005 Frequency,
Q Feb May Aug Nov
+ NonComp:Single
2005 —
>100 —
—
>loot — —
97.6 — — >100 —
County. Mecklenburg Region: MRO
Subbasin: CfB34
2006'—
78.3,>100(P) >100
>100
,>100 —
>100 — — >100" —
PF: 20.0 - sped
1
2007 —
>100 —
—
>100 — —
>100,>100(P) — — >100 —
7Q10:3.4 IWC(%)90 Or
2008 —
>100 — -
—
>100
CNA Holdings / Needmore Rd Landfill
chr Gm: 0.42%
- Ceri7dPF
2004 H
— —
H
— — H
— - H — —
NC0079898/001 Begin:6/1/2004 Frequency.
Q Jan Apr Jul Oct
+ NonComp:SINGLE
2005 H
— —
H
— — H
— — H — —
County Rowan Region: MRO
Subbasin: YAD06
2006 H
— —
H
— — H
— — H — —
PF: 0.288 sped
1
2007 H
_ _
H
— — _ H
— — H — —
7Q10: 106 IWC(%) 0.42 Orde
2008 H
— -
H
—
CNA Holdings, Inc.
chr lira: 5.8 %
Ceri7dPF
2004 —
— Pass
—
— Pass —
— Pass — — Pass
NC00049521001 Begin:6/l/2004 Frequency,Q
Mar Jun Sep Dec
'+ NonComp:Single
2005 —
— Pass
—
— Pass —
— Pass — — Pass
County. Cleveland Region: MRO
I Subbasin: BRD05
2006 —
— Pass
—
— Pass —
— Fall >23.2 >23.2 Pass
PF: 0.8 Sped
1
2007 —
Pass
—
— Pass —
— Pass — — Pass
7QI0: 20.0 IWC(%) 5.8 ' Ord
.
2008 —
— - Pass
—
—
.
Coats American -Sevier Plant
chr lim: 15%
Ceri7dPF
2004' —
Pass —
—
Pass — —
Fail <7.5 38.7. Fall 12.2
NC0004243/001 Begin:9/l/2005 Frequency.
Q Feb May Aug Nov
+ NonComp:Single
2005 21.2
Pass >50
>50
>60 >100 83.7
>100 — — >50 —
County: McDowell Region ARO
Subbasin: CTB30
2006 —
>50 —
—
NPJ>50 — —
>50 — — Pass —
PF: 2.0 Spmi1
2007 _
Pass —
—
Pass — —
Pass — — Pass —
7QI0: 18.0 IWC(%) 14.7 Ordc
2008 —
Pass —
—
Pass ..
"
Colonial Pipeline- RDU/001
24hr LC50 an monit epic fthd .
Fthd24Ac
2004 —
1100—
NCO0814691001 Begin:6/l/2008 . Frequency.
A
NonComp:
2005 —
>100 —
—
— — —
— — — — —
County Wake Region: RRO
Subbasin: NEU02
2006 —
— —
—
— — >100
— — — — —
PF: N/A Sped
1
2007 —
— —
—
— — >100
— — — — —
7Q10:.NA IWC(%) 100 Ord
2008 —
— >100
—
—
Colonial Pipeline-Charlatte
24hr LC50 ac monit epis fthd
Fthd24Ac
2004 —
— —
—
>100 — —
— — — — —
NC0031038/001 Begin:3/1/2006 Frequency
A
NonComp:
2005 —
— —
>100
— — —
— — — — —
County. Mecklenburg Region MRO
Subbasin CTB34
2006 —
— —
—
>100 — —
— — — — —
PF: N/A Sped
1
2007 —
— —
—
>100-
7QI0: 0 IWC(%) 100.0 Ord
2008 —
— —
—
—
Colonial Pipeline Selma,
24hr LC50 ac monit epis fthd
Fthd24Ac
2004 —
>100—
NC00310111001 Begm:6/l/2008 Frequency
A
NonComp:
2005 —
>100—
County: Johnston Region: RRO
Subbasin: NEU02
-
2006 —
—
PF: VAR sped
1
-
2007 —
— —
—
— — >100
—. — — — —
7Q10: 0.0 IWC(%) 100.0 Orde
2008 —
— ">100
—
—
Colonial Pipeline/001
24hr LC50 ac monit epic flhd
Fthd24Ac
2004 —
>100 —
—
— — —
— — — — —
NC0031046/001 Begin:2/1/2007 Frequency,
A
NonComp:
2005 >100
——
County Guilford Region: WSRO
Subbasin: CPF08
2006 .—
— >100
--
— — —
— — — — —
.PF: NA spai
1
2007 _
— —
>100
— — —
— — — — —
7Q10: 0.0 IWC(%) 100 Ord
..
2008 —
— —
>100
—
Colonial PlpcUne/002
24hr LC50 ac monit epis fthd
Fthd24Ac
2004 —
>100 —
—
— — —
— — — — —
NC0031046/002 Begin:2/1/2007 Frequency
A
NonComp:
2005 >100
——
County: Guilford Region WSRO
Subbasin CPF08
2006 —
— >100
—
— — —
— — — — —
PF: NA ' sped
1 -
_
2007 —
— —
>100-
7Q10: 0.0 iWC(%) 100 Ord
:
2008 —
— >100
>100
Colonial PipeRne/003
24hr LC50 ac monit epic fthd
Fthd24Ac
2GO4 —
>100 —
—
— — —
— — — — —
NC0031046/003 Begin:2/l/2007 Frequency.
A
NonComp:
2005 >100
——
County Guilford Region: WSRO
Subbasin: CPF08
2006 —
— >100
—
PF: NA sped
1
2007 —
— —
>100-
7Q10: 0.0 IWC(°/a) 100.0 Ord
:
2008 —
— >100
>100
—
Colonial Pipeline/004
24hr LC50 so monit epic fthd
Fthd24Ac
2004 —
>100—
NC0031046/004 Begin:211/2007 Frequency
A
NonComp:
2005 >100
. ——
County. Guilford Region: WSRO
Subbasin: CPF08
2006 —
— >100
——
PF: NA sped
1
2007 _
— —
>100
—
7Q10: 0.0 1WC(%) 100.0 Ord
2008 —
— >100
>100
—
¥ Pre 2004 Data Available
-
LEGEND:
PERM - Permit Requirement LET - Admin'
trative Letter - Target Frequency - Monitoring frequency: Q- Quarterly; M- Monthly, BM- Bimonthly, SA-
Semiannually,
A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement
Begin -First month required 7Q I0 = Receivit
g stream low flow criterion (cfs)
• +— quarterly monitoring
increases to monthly upon failure or NR Months
that testing must occur -ex. Jan, Apr, Jul, Oct
NonComp — Current Compliance Requirement
PF — Permitted flow (MGD) f WC%- Instrea
m waste concentration
P/F - Pass/Fad test
AC — Acute
CHR — Chronic
Data Notation: f- Fathead Minnow;' - Ceria
hnia sp.; my - Mysid shrimp; ChV -
Chronic value; P - Mortality of stated percentage at
highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reporting Notation -- - Data not required; N
- Not reported Facility Activity Status: I - inactive, N - Newly Imued(To construct);
H - Active but not discharging, t-More data available for month in question; D - ORC signature needed
10
8 .

CNA Holdings, Inc..
NC0004952
orma on provideproyided by A wiln Uus pe-m-u-1 renewalm cdi`ates tha of tlfe- flow scharged tlir�ugtio
outfall 001, approximately 0.375 MGD is process. wastewater. Of the process wastewater, approximately 0.0621 MGD
is attributable to 414 Subpart C manufacturing with the remaining 0.313 attributable to Subpart D.
Subpart C flow: 0.0621 MGD
Subpart D flow: 0.313 MGD
Domestic flow: 0.052 MGD
40 CFR 414.31 (Subpart C - All units are mg/L)
Daily Max Mon. Avg.
BOD5 48 18
TSS 115 1 36
40 CFR 414.41 (Subpart D - All units are mg/L)
Daily Max Mon. Avg.
IBOD5 64 24
TSS 130 40
Subpart C Allocation - lbs/day
Daily Max Mon. Avg.
IBOD5 24.9 9.3
TSS 59.6 18.6
Subpart D Allocation - lbs%day
Daily Max Mon. Avg.
IBOD5 167.1 62.7
TSS 300.2 104.4
Domestic Allocation (Q = 52,000 gpd) - Assuming secondary limits - lbs/day
Daily Max Mon. Avg.
IBOD5 .22.7 15.1
TSS 22.7 15.1
--Total Allocation (Sum of C, D, and Domestic) - lbs/day
Daily Max Mon. Avg.
BODS''`:,SST:
SsY "$ w382b=`;:Y:-138 t.9
Mark McIntire
8/15/2008 ,

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August 15, 2008
PEMC08:31
Additional Information Request
ATTN: Sergei Chernikov, Ph.D.
Environmental Engineer II
NPDES-West
Phone: [phone] ext. 594, fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
In response to the email request on August 14, 2008 for additional information pertaining to our
OCPSF review.
Ticona has quantified which wastewater streams are subject to the categorical standards or
Organic Chemicals, Plastics, and synthetic fibers (OCPSF) Subparts. Based upon the water
balance diagram submitted with the permit renewal package, the streams subject to the OCPSF
regulations with respect to manufacturing processes are delineated as follows:
Process
SIC Code
Subpart C
WIC code
Subpart D
Water Stream
2824 Percent
Volume of
2821 Percent
Volume of
of Flow
Flow GPD
of Flow
Flow GPD
Invista Spin
finish
100%
100
0%
0
Process Cooling
306,000 (max)
Water
0%
0
100%
108,000 min
Misc. Process
Waters
80%
52,000
20%
13,000
CT Mk -up/
Blowdown
. 24%
10,000
75%
30,000
CNA Holdings, Inc. — Ticona Facility is committed to ensuring compliance with all County, State,
and Federal regulations. Should there be a need for further discussion pertaining to the
information submitted with this notification letter, feel free to call me at 704/480-4900, or via email
at pem.carterCaD-ticona.com .
Sincerely,
PEM Carter
Sr. Environmental Engineer
CNA Holding Inc. — TICONA
2525 Blacksburg Road
Grover, NC 28073
21 5 ra '

th:-question from DWQ
Subject: RE: question from DWQ
From: "Carter, PEM, Ticona/US" <[e-mail]>
Date: Fri, 15 .Aug 2008 10:42:19 -0500 .
To: "Sergei Chermkov" <[e-mail]>
1. Cooling Tower Make up and Blowdown
.2. approximately 270,000
3. 52,000
PEM
-----original message -----
From: Sergei Chernikov[mailto:[e-mail]]
Sent: Friday, August 15, 2008 11:23 AM
To: Carter,PEM, Ticona/US
Subject: Re: question from DWQ
Pem,
Thank you! I have a few more questions:
1) What is CT Mk -up/ Blowdown?
2) What is average Process Cooling Water flow? You provided minimum and
maximum only.
3) What is sanitary flow?
Sergei
Carter, PEM, Ticona/US wrote:
Sergei Chernikov, Ph.D.
Environmental Engineer II
NPDES-West
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
l of 1 8/15/2008 11:49 AM

Michael F. Easley, Gov e fla
3 r—
William G. Ross Jr., Secretary l7 v
North Carolina Department of Environment and Natural Resources
Coleen Sullins., Director
Division of Water Quality
July 2, 2008
Ms. PEM Carter, Environmental Engineer
CNA Holdings, Inc.
Shelby Plant
Highway 198
Shelby, NC 28152
Subject: Compliance Evaluation Inspection
CNA Holdings, Inc.-Ticona Facility WWTP
NPDES Permit No. NC0004952
Cleveland County, North Carolina
Dear Ms. Carter:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on April 17, 2008 by Ms. Donna Hood of this Office. Please inform
the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed
report.
The report should be self-explanatory; however, should you have any questions concerning this
report, please do not hesitate to contact Ms. Hood or me at [phone].
Sincerely,
Q
Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure
cc: Cleveland County Health Department
oil
N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

United States 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 Fac Type
1 I NI 2 151 31 NC0004952 ill 121 08/04/17 117 181 cl 191sl 201 1
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --------------------------- Reserved ----------------------
671 3.0 169 701 1 711 1 721 NJ 73 I I 174 751 I I I 1 1 1 180
t_u
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)
01:00 PM 08/04/17
04/06/01
Ticona Facility
Exit Time/Date
Permit Expiration Date
NC Hwy 198
Shelby NC 28150
04:30 PM 08/04/17
08/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Michael R. Queen/ORC/704-480-4692/
P Carter///
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Edward J McKinley,NC Hwy 198 Shelby NC 28151//704-480-4700/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory ,
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Donn HIi' d / MRO WQ//704-663-1699 Ext.2193/
Signature of Management Q A W0061 Agency/Office/Phone and Fax Numbers Date
1/1l°
Marcia 'Allocco ��s
/ MRO WQ//704-663-1699 Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

Permit: NC0004952 Owner -Facility: Ticona Facility
Inspection Date: 04/17/2008 Inspection Type: Compliance Evaluation
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
■
n
n
n
Is the facility as described in the permit?
■
❑
Q
# Are there any special conditions for the permit?
n
■
n
n
Is access to the plant site restricted to the general public?
■
n
n
n
Is the inspector granted access to all areas for inspection?
■
n
n
n
Comment: CNA Holdings permit expires on 8.31.2008. A renewal package was
submitted to the Division 03.04.2008.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ 0
Does the facility analyze process control parameters, for ex: IVILSS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ Cl 0
Judge, and other that are applicable?
Comment: The facility had several deteriorating catwalks at the time of the inspection.
Maintenance and repairs should be performed to ensure the safety of the staff. The
facility has had an ongoing problem with algal blooms in the polishing ponds. Please be
aware that barley straw can be used for algae control. A water leak was observed at
the time of the inspection. Please repair this as soon as possible.
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 consistent with 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?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
Is the ORC visitation log available and current?
Page # 3

Permit: NC0004952
Inspection Date: 04/17/2008
Owner - Facility: Ticona Facility
Inspection Type: Compliance Evaluation
Record Keeping
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment: DMRs of January 2007-December 2007 were reviewed for the inspection.
The oil and grease sampling result was omitted on the December 2007 DMR. Please
submit an amended DMR for 12/2007 that includes the results.
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
11
Yes No NA NE
■nnn
■nf_1n
■nnn
■nnn
nn■n
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? n n ■ n
Comment: A field laboratory inspection was performed concurrently with the NPDES
inspection. Please refer to the report by Mr. Chet Whiting, of this Office, for any
laboratory recommendations.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
n
n
■
n
Is sample collected above side streams?
■
n
n
n
Is proper volume collected?
■
n
n
n
Is the tubing clean?
■
n
n
n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
n
n
n
Is sampling performed according to the permit?
■
n
n
n
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
■
n
n
n
Is sample collected below all treatment units?
■
n
n
n
Is proper volume collected?
■
n
❑
n
Is the tubing clean?
■
n
n
n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
n
n
n
Page # 4

Permit: NC0004952 Owner -Facility: Ticona Facility
Inspection Date: 04/17/2008 Inspection Type: Compliance Evaluation
Effluent Sampling Yes
No
NA
NE
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ®
❑
n
n
Comment:
Upstream / Downstream Sampling Yes
No
NA
NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■
n
n
0-
Comment:
Bar Screens Yes
No
NA
NE
Type of bar screen
a.Manual
■
b.Mechanical
n
Are the bars adequately screening debris?
®
n
n
n
Is the screen free of excessive debris?
■
n
n
n
Is disposal of screening in compliance?
■
n
n
n
Is the unit in good condition?
■
n
n
n
Comment: Veola Environmental properly disposes of screenings.
Grit Removal
Yes
No
NA
NE
Type of grit removal
a.Manual
■
b. Mechanical
n
Is the grit free of excessive organic matter?
■
n
n
Is the grit free of excessive odor?
■
n
n
n
# Is disposal of grit in compliance?
■
n
n
n
Comment:
:qualization Basins
Yes
No
NA
NE
Is the basin aerated?
®
n
n
n
Is the basin free of bypass lines or structures to the natural environment?
®
n
n
n
Is the basin free of excessive grease?
■
n
n
n
Are all pumps present?
■
n
n
n
Are all pumps operable?
■
n
n
n
Are float controls operable?
■
n
n
n
Are audible and visual alarms operable?
■
n
n
n
Page # 5

Permit: NC0004952
Inspection Date: 04/17/2008
Owner - Facility: Ticona Facility
Inspection Type: compliance Evaluation
,11
Equalization Basins Yes No NA NE
# Is basin size/volume adequate? ■ n fl n
Comment: PH adjustment is made in EQ A with sodium hydroxide. EQ B provides
aeration. In EQ C phosphoric acid is added to enhance the treatment process. The
facility is considering the addition of ferric chloride to enhance settling during the
treatment process.
r_hamiral Fnnrl Yes No NA NE
Is containment adequate?
■
n
❑
n
Is storage adequate?
■
n
n
n
Are backup pumps available?
■
n
n
n
Is the site free of excessive leaking?
■
❑
❑
n
Comment:
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext.
Air
Type of aeration system
Surface
Is the basin free of dead spots?
■
n
n
In
Are surface aerators and mixers operational?
■
n
n
n
Are the diffusers operational?
n
In
■
n
Is the foam the proper color for the treatment process?
■
n
00
Does the foam cover less than 25% of the basin's surface?
■
n
n
n
Is the DO level acceptable?
❑
n
n
■
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
n
n
■
Comment:
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
®
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
n
n
n
Are weirs level?
■
❑
n
171
Is the site free of weir blockage?
■
n
n
n
Is the site free of evidence of short-circuiting?
■
n
n
n
Is scum removal adequate?
■
n
n
n
Is the site free of excessive floating sludge?
■
n
n
n
Is the drive unit operational?
®
n
n
n
Page # 6

Permit: NC0004952 Owner -Facility: Ticona Facility
Inspection Date: 04/17/2008 Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the return rate acceptable (low turbulence)? ■ n n n
Is the overflow clear of excessive solids/pin floc? ❑ ■ n n
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) n n n ■
Comment: The facility had recently experienced an upset and was diligently working
to restore normal settling to the clarifiers.
Lagoons
Yes
No
NA
NE
Type of lagoons?
# Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
# Is a re -circulation line present?
n
n
■
n
Is lagoon free of excessive floating materials?
■
n
n
n
# Are baffles between ponds or effluent baffles adjustable?
n
n
■
n
Are dike slopes clear of woody vegetation?
■
❑
n
n
Are weeds controlled around the edge of the lagoon?
■
n
n
n
Are dikes free of seepage?
■
n
n
n
Are dikes free of erosion?
■
n
n
n
Are dikes free of burrowing animals?
■
n
n
n
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
n
n
■
n
# If excessive algae is present, has barley straw been used to help control the growth?
n
n
n
■
Is the lagoon surface free of weeds?
■
n
n
n
Is the lagoon free of short circuiting?
■
n
n
n
Comment: The facility is considering using barley straw to control algal growth in the
summer months. In additional to barley straw, additional aeration may enhance
treatment process and inhibit algal growth in the ponds.
Filtration (High Rate Tertiary)
Yes
No
NA
NE
Type of operation:
Down flow
Is the filter media present?
■
❑
n
n
Is the filter surface free of clogging?
®
❑
n
❑
Is the filter free of growth?
n
n
n
■
Is the air scour operational?
n
n
®
n
Is the scouring acceptable?
■
n
n
n
Page # 7

Permit: NC0004952
Inspection Date: 04/17/2008
Owner -Facility: Ticona Facility
Inspection Type: Compliance Evaluation
C
Filtration (Nigh Rate Tertiary)
Yes
No
NA
NE
Is the clear well free of excessive solids and filter media?
❑
❑
n
■
Comment:
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
■
n
n
n
Is the mixing adequate?
■
n
n
n
Is the site free of excessive foaming in the tank?
■
n
n
n
# Is the odor acceptable?
■
n
n
n
# Is tankage available for properly waste sludge?
■
n
n
n.
Comment: EMA Resources, Inc disposes of sludge from the facility.
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
■
n
n
n
Are the receiving water free of foam other than trace amounts and other debris?
n
❑
❑
■
If effluent (diffuser pipes are required) are they operating properly?
n
n
■
n
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
n
n
n
Is flow meter calibrated annually?
■
❑
❑
Is the flow meter operational?
■
n
n
n
(If units are separated) Does the chart recorder match the flow meter?
❑
n
■
13
Comment: The flow meter was last calibrated on 02.28.2008 by Ticona's internal I&E
Department.
Page # 8

CERTIFIED MAIL 7002 0860 0006 3968 4986 ' I®n
Returned Receipt to PEM Carter
Afl 27 2008
N�Mq MT74I;� Ticona
,©©©
aWSW" 3 � q CVW 2525 Blacksburg Road
March 27, 2008d Grover, NC 28073-9641
n
PEMC08:13 Carolina Star Worksite
ISO 9001, ISO/TS 16949,
NC Department of Environment and Natural Resources ISO 17025,and ISO 14001
Division of Water Quality
610 East Center Avenue —Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Final Report of the Pump Failure at South Stormwater Outfall — 2/08/08
(CNA Holdings, Inc., Shelby Plant: Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This final report provides an update and the pending analysis of the BOD5 which was collected at the time of the
pump failure at the South Stormwater Outfall which was discovered around 10:20 a.m., Feb 08, 2008 and was
reported to you by phone around 1:00 p.m. that same day. The South Outfall is designed with gate to cease all
waters from leaving by way of the South Outfall. Only during significant rain events, is the gate lifted, but be
assured all waters entering the South Outfall ditch are approved waters per NCS000064. This also allows us the
opportunity to collect and analyze the "Benchmark" parameters listed in our permit to ensure no waters will
impact receiving streams/tributaries. The quantity of waters reported in this write up, reflects a worse case
scenario. The South outfall pump was last observed operating Feb.07, 2008 around 10:00 a.m. For this report
Ticona assumed the release began on 2/0708 at 10:00 a.m. — 2/08/08 ending at 2:00 p.m. See chartbelow:
CNA Holdings, Inc — Ticona's stormwater contingency plan, stipulates that we maintain pumping stations
at our outfalls to ensure no contaminated waters leave the site, only approved waters as listed in our
permit. The red font represents the pending data point in the first report. BOD5 sample was analyzed by
outside contract laboratory, Prism Laboratories, Inc..
Discharge Volume: 1657 gallons 1.4 gal/min
Test Parameters:
pH: 6.6
COD: 119 mg/i
BOD5: <BRL
TSS: 11 mg/i
Color: clear
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(cDticona.com
czlet-
PEM Carter
Sr. Environmental 'Engineer
Celanese
Ticona
A business of Celanese

icona
j F
i _A
j
Certified Mail: 7002 0860 0006 3968 49 9
Return Receipt to PEM Carter Ticona
2525 Blacksburg Road
Grover, NC 28073-9641
�c�+ a�,�Fpp��ey Carolina StarWorksite
QiyrDER I R10"' ISO 900 1, ISO/TS 16949,
March 7, 2008 ISO 17025,and ISO 14001
Dviourface Wafer P rokdlan
PEMC08:11
NC Department of Environment and Natural Resources
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Recording of Flow Over Weekends and Holidays, CNA Holdings, Inc., Shelby Plant;
NPDES: Permit No. NC0004952
Dear Mr. Bou-ghazale:
This report reflects our conversation today pertaining to the recording of flow over weekends and holidays. As
explained: We were under the impression that we had to bring in our wastewater operators every weekend and
over every holiday in an effort to read the continuous flow meter and to record it on our worksheets. This
information would then be submitted on our monthly DMR. But as you and John Lesley explained: we can
record the flow on Friday, then Monday, calculate the average flow over the Saturday and Sunday timeframe.
This average flow would be reflected on the DMR, without having an ORC or BackUp ORC column filled in.
If I have misunderstood your guidance above, please notify me immediately. We are planning to implement the
above changes next weekend.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carterO-ticona.com
Sincerely,
C�U K dj�
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona
A business of Celanese

Rv P,� E C E'l E D
iic®na
Certified Mail: 7004 2510 0002 9276 5800 MAR 3 2008
Return Receipt to PEM Carter
NO DDIR MRO
DWQ-Surface Water Protection
February 28, 2008
PEMC08:10
NC Department of Environment and Natural Resources
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Daily Exceedance of BOD5 — 2/6/08 for CNA Holdings, Inc., Shelby Plant;
NPDES: Permit No. NC0004952
Dear Mr. Bou-ghazale:
Ticona
2525 Blacksburg Road
Grover, NC 28073-9641
Carolina Star Worksite
ISO 9001, ISO/TS 16949,
ISO 17025,and ISO 14001
This report serves as the written requirement for the incident reported by telephone on February 6, 2008.
BOD5 results both before and after 2/6, were well within the permit parameters. However Prism
Laboratory Inc. reported that the 2/6/08 BOD5 was 51 mg/I BOD with a flow of 410,000 gallons, resulting in
174.9 Ibs, exceeding our daily discharge limits by 10.9 lbs. At this time, we have not identified why this
occurrence happened nor have we seen a repeat.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(cD-ticona.com
eiy,
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona
A business of Celanese

Michael F. Easley, Governor
State of North Carolina
y William G. Ross, Jr., Secretary
i— Department of Environment and Natural Resources
OColeen H Sullins, Director
Division of Water Quality
July 10, 2007
y -^ � tt J' '
Ms. Pem Carter ,- `30URCES
CNA Holdings, Inc_':
921 QFF6'CE
2525 Blacksburg Rd
,
Grover, North Carolina 28073
Subject: Draft NPDES Stormwater PermiUUL 1 2007
Permit No. NCSO00O64
CNA Holdings, Inc.
Cleveland County
Dear Ms. Carter: �J `TER'
E o ((IIh/11 TV UP),,
MOP
with. Enclosed this letter is a copy of the draft stormwater permit for your facility. Please review the draft �J it i�
very carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from this facility's current permit:
• TKN, MBAS, Phenols, Total Lead, and Bis (2-Ethylhehyl) phthalate have been removed from
analytical monitoring. _...._
• pH has been added to the analytical monitoring requirements.
• All analytical monitoring has changed from annual to semi-annual (once in the spring and once
in the fall). This change is based on the Division's revised strategy for stormwater monitoring in
renewal permits and makes stormwater discharge sampling frequency consistent with qualitative
monitoring. Please note that analytical monitoring must still be performed during a
representative storm event (whereas qualitative does not).
• Instead of "cut-off concentrations;' the Division has incorporated benchmark values into the
permit. These benchmarks are not permit limits but should be used as guidelines for your
facility's Stormwater Pollution Prevention Plan (SPPP). If any measurements exceed benchmark
values, your facility should evaluate the effectiveness of its Best Management Practices (BMPs),
review and/or update its SPPP, and document any efforts to address stormwater contamination
(see Part II, Sections B and D).
• Total Flow monitoring has been removed. The permit still requires Total Rainfall amount and
Rainfall Event Duration be recorded for each sampling event. This change is also based on the
Division's revised strategy for stormwater monitoring in renewal permits. Please note that the
Stormwater Pollution Prevention Plan (SPPP) site map must include drainage area for each
outfall in acres and the percentage of each drainage area that is impervious (see Part II, Sec. A).
Please submit any comments to me no later than thirty (30) days following your receipt of the draft.
Comments should be sent to the address listed at the bottom of this page. If no adverse comments are
received from the public or from you, this permit will be issued in approximately two months.
North Carolina Division of Water Quality [phone]
1617 Mail Service Center FAX [phone]
Raleigh, North Carolina 27699-1617 On the Internet at http://h2o.enr.state.nc.us/

y leis Pem Carter
CNA Holdings, Inc.
Permit No. NCS000064
Page 2
If you have any questions or comments concerning this draft permit, contact me at [phone] x 376 or
[e-mail]
6Sincerely,
y son
Environmental Engineer
Stormwater Permitting Unit
cc: coo esvill glorta *=ic tileragie''fcpre (w/attachment)
Stormwater Permitting Unit
Central Files
Attachments
2

CERTIFIED MAIL 7003 0500 0000 9651 4765
Returned Receipt to PEM Carter
V : a 9. Ui- �fVvltiCf6tll�5 q„_,�
AND NATUIPAL RESOURCES
OOI1ES1 ILLS P} OiG'1 L OFEiOE
iico a
JUL G ' 2007 Ticona
June 29, 2007 Shelby Plant
Highway 198
PEMC07:26 ur,S , NC 281-� Z ?31,
Telephone [phone]
NC Department of Environment and Natural Res o`lurce5- ;
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Report of the Pump Failure at North Stormwater Outfall — 6/28/07
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as a written notification of the pump failure at the North Stormwater Outfall which occurred at
10:05 p.m., June 28, 2007 and was reported to you by phone at 10:00 a.m. June 29, 2007. The waters leaving
through the North Stormwater Outfall, due to pump failure, are approved waters (spring & HVAC condensate
waters) under our Stormwater Permit No. NCS000064 and did not impact any receiving bodies of water. The
release began 6/28/07 at 10:05 p.m. and ended 6/29/07 at,8:15 a.m.
CNA Holdings, Inc — Ticona's stormwater contingency plan, stipulates that we maintain pumping stations
at our outfalls to ensure no waters leave the site, except during rain events. Samples were collected during
the pump failure incident and are being analyzed by Prism Laboratories, Inc.
Discharge Volume: 3,7611 gal
6.2 gal/min
Test Parameters:
pH: 7.5
Bis(2-ethylhexyl)phthaIate: pending
MBAS: pending
BOD& pending
TSS: pending
Total Lead: pending
Phenol: pending
COD: pending
Total Nitrogen: pending
Color: clear
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(cDticona.com
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona
A business of Celanese AG

pre 7
o�0 � w A rF,�QG
O `C
Mr. E. J. McKinley, Plant Manager
CNA Holdings, Inc. - Ticona Plant
2525 Blacksburg Road, Hwy. 198
Shelby, North Carolina 28151
Dear Mr. McKinley:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins Director
Division of Water Quality
June 25, 2007
Subject: Compliance Evaluation Inspection
CNA Holdings, Inc. - Ticona Plant
Stormwater Permit No. NCS000064
Cleveland County
Enclosed is a copy of the Compliance Evalution Inspection (CEI) report for the inspection
conducted at the subject facility on June 21, 2007, by Mr. Michael L. Parker with this Office.
The report should be self-explanatory, however, if you have any questions, please contact
Ms. Marcia Allocco, Mr. Parker or me at [phone].
Sincerely,
�.,� Robert B. Krebs 6rl
Water Quality Regional Supervisor
Attachment
/mlp
h:\cei\CNA.doc
U 'A"
NCDENR
Noe Carolina
Ntura!!y
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: www.ncwaiterquality.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

Permit: NCS000064
SOC:
County: Cleveland
Region: Mooresville
Compliance Inspection Report
Effective: 06/16/00
Effective:
Expiration: 07/31/05 Owner: Cna Holdings Inc
Expiration: Facility: CNA Holdings, Inc. Ticona Plant
2525 Blacksburg Rd Hwy 19
Contact Person: Jerry L McMurray Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0004952 CNA Holdings Inc - Ticona Facility
Inspection Date: 06/21/2007 Entry Time: 10:30 AM
Primary Inspector: Michael L Parker
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater. Discharge, Individual
Facility Status: ■ Compliant Q Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Cleveland NC 27013
Phone: [phone]
Certification:
Exit Time: 11:45 AM
Phone:
Phone: [phone]
Ext.223
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000064 Owner - Facility: Cna Holdings Inc
Inspection Date: 06/21/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
D
D
D
# Does the Plan include a General Location (USGS) map?
■
D
D
D
# Does the Plan include a "Narrative Description of Practices"?
■
D
D
D
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
D
D
D
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
D
D
D
# Has the facility evaluated feasible alternatives to current practices?
■
D
D
D
# Does the facility provide all necessary secondary containment?
■
D
D
D
# Does the Plan include a BMP summary?
■
D
D
D
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
D
D
D
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
D
D
# Does the facility provide and document Employee Training?
®
D
D
D
# Does the Plan include a list of Responsible Party(s)?
■
0
❑
# Is the Plan reviewed and updated annually?
■
❑
❑
D
# Does the Plan include a Stormwater Facility Inspection Program?
■
fl
D
fl
Has the Stormwater Pollution Prevention Plan been implemented?
■
D
❑
D
Comment:
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
D
D
D
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
■
❑
D
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
D
D
■
D
Comment: Vehicle maintenance is conducted inside a covered building.
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■
❑
Cl
D
# Were all outfalls observed during the inspection?
■
D
❑
❑
# If the facility has representative outfall status, is it properly documented by the Division?
❑
D
■
❑
# Has the facility evaluated all illicit (non stormwater) discharges?
■
D
D
Comment: Non-stormwater discharges will be added as outfalls to the facilities
NPDES permit (NC0004952), which authorizes the discharges of process wastewater.
Page: 3

CERTIFIED MAIL 7002 0860 0006 3968 4535
Return Receipt to PEM Carter
i APs<s�Y
i icona
May 2, 2007 AWAY 0 .I
PEMC07:17
NC Department of Environment and Natural ResourcesXq.�� .. ; . , 1 _ r� j u,Qr
Division of Water Quality ' , ; d , +., ,
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Release of Cooling Water into North Stormwater Drainage Ditch — 5/2/07
(CNA Holdings, Inc., Ticona Plant, Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
Ticona
2525 Blacksburg Road
Grover, NC 28073-9641
Carolina Star Worksite
ISO 9001,ISO rS 16949,
ISO 17025, and ISO 14001
This report serves as the written requirement for the incident reported by telephone today, May 2, 2007.
Per this telephone message, CNA Holdings, Inc — Ticona reported to you the incident whereas Invista, a leasing
tenant, while performing repairs, damaged a section of the Ticona's cooling water return line, which released waters,
byway of the north stormwater outfall. Waters began leaving byway of the north outfall at 2:10 p.m. By 3:59 p.m.
repairs were completed and the incident was over. By 4:30 p.m., all waters ceased leaving the site by way of the
north outfall. Based on the duration of this incident, approximately 56,707 gallons of cooling water flowed through
the north stormwater ditch leaving the site.
An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo Creek. There
were no observed environmental impacts to Buffalo Creek Samples of this water have been collected and
submitted to a contract lab, Prism Laboratories, Inc. Th3 results will be submitted under a separate cover when
received.
Discharge Volume: 56,7071 gal
Test Parameters:
pH: 7.6
Bis(2-ethylhexyl)phthalate: pending
MBAS: pending
BOD5: pending
TSS: pending
Total Lead: pending
Phenol: pending
COD: pending
Total Nitrogen: pending
Color: slightly dingy
Floating Solids: none
Odor: none
Clarity:slightly dingy
Oil sheen: none
Foam: none
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal regulations.
Should there be a need for further discussion pertaining to the information submitted with this notification letter, feel free to
call me at 704/480-4900, or via email at pem.carter(3-ticona.com
1--shw"erely,
PEM Carter
Sr. Environmental Engineer
-:rN c, �"� gcxD 4-C)I L,
Celanese
Ticona
A business of Celanese

Michael F. Easley, Governor
William G Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources
Alan W Mimek, P E Director
Division of Water Quality
March 20, 2006
221
Mr. Pem Carter
CNA Holdings, Inc. - Ticona Facility
2525 Blacksburg Road
Grover, NC 28073-9641
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr. Carter:
Enclosed is a report for the inspection performed on January 19, 2005 by Mr. Chet Whiting.
Where deficiencies are cited in this report, a response is required as well as for all lettered comments
and/or recommendations. Within thirty days of receipt, please supply this office with a written item for
item description of how these deficiencies, comments and/or recommendations were corrected. If the
deficiencies cited in the enclosed report are not corrected, enforcement actions will be recommended.
For certification maintenance, your laboratory must continue to carry out the requirements set forth in
15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from this office.
Thank you for your cooperation during the inspection. If you wish to obtain an electronic copy of this
report by email, or if you have questions or need additional information please contact us at 919-733-
3908.
Sincerely,
James W. Meyer
Laboratory Section
Enclosure
cc: Chet Whiting
Mooresville Regional Office
Nne
orthCawlina
Natmally
Lnboratory Section 1623 Mail Service Center; Raleigh, NC 27699-1623
4405 Reedy Creek Road; Raleigh, NC 27607
Phone [phone] / FAX [phone] / Internet: www.dwglab org
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

1
LABORATORY NAME:
ADDRESS:
CERTIFICATE NO:
DATE OF INSPECTION:
TYPE OF INSPECTION:
EVALUATOR:
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
On -Site Inspection Report
Ticona Shelby WWTP Lab
P.O.. Box 87, Shelby NC 28150
221
January 19, 2005
Maintenance
Chet Whiting
Ms, PEM Carter
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory continues to do a good job. No deficiencies were observed during the inspection.
III. DEFICIENCIES, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
A. COMMENT: Instrument calibration times are not documented.
REQUIREMENT: Instrument calibration times must be documented to verify that the instruments were
calibrated prior to sample analysis.
B. COMMENT: The automatic temperature compensation (ATC) feature of the pH meter was not verified
on an annual basis.
REQUIREMENT: (New Policy) Automatic Temperature Compensator Check (ATC) for pH meter
and Conductivity meter: (Check every 12 months)
1. Take a buffer or standard solution and cool to below 10°C and read the temperature. Analyze the
buffer or standard solution at that temperature.. Document the temperature and the measured pH or
standard solution value obtained on the log sheet.
2. Raise the temperature of the buffer or standard solution to approximately 25°C, Document the
temperature and the measured pH or standard solution value on the log sheet.
3. Raise the temperature of the buffer or standard solution to approximately 35°C. Document the
temperature and the measured pH or standard solution value on the log sheet.
4. Repeat with additional temperature adjustments and ,pH or standard solution readings as necessary
to ensure the temperature usually measured for samples has been bracketed. As the temperature
increases or decreases the value of the buffer or standard solution should remain approximately the
same.
Note: This item was not a requirement at the time of the last. inspection.

,r�
Page 2
Ticona Shelby WWTP Lab
SOLIDS:
C. COMMENT (TSS): The time in and out of the drying oven(s) are not recorded for the drying cycle
verification..
REQUIREMENT: Record the time in and out of the drying oven for the initial and secondary time. ref; 15A
NCAC 2H .8085 (7). & (7) (A).
NOTE 3: If the laboratory is confirming a 1-hour drying cycle: Record the time in and out of the oven (1
hour). Place the sample in the desiccator, cool and weigh, Return the sample to the drying oven for 1
hour, record time in and out. Place the sample In the desiccator, cool and weigh. Evaluate weights to
assure that they pass criteria. If the criteria (change in weight of 0.5mg or 4% whichever is less) is met a
1-hour drying cycle has been verified.
IV. PAPER TRAIL INVESTIGATION:
At least six sets of data and DMRs were reviewed in conjunction with the Division of Water Quality Plant
Inspection review. No items other than those specified in the above report were observed.
V. CONCLUSIONS:
Correcting the above cited comments and implementing the recommendations will help this lab to
produce quality data and meet certification requirements. Please respond to all lettered comments.
Report prepared by: Chet Whiting Date: March 17, 2006

Incident Report
Report Number: 200700785
Incident Type: Other
Category: Incident
Incident Started: 01/09/2007
County: Cleveland
City: Cleveland
Farm #: -
Responsible Party:
Owner: Cna Holdings Inc
Permit: NCS000064
Facility: CNA Holdings, Inc. Ticona Pla
First Name: Jerry
Middle Name: L
Last Name: McMurray
Address PO Box 87
City/State/Zip: Shelby NC. 28151
Phone:
Material Category: Estimated Qty: UOM
Other 10440 gal
DD:MM:SS Decimal
Latitude:
Longitude:
Location of Incident:
Address:
City/State/Zip
On -Site Contact:
First/Mid/Last Name:
Company Name:
Phone:
Pager/Mobile Phone: /
Reported By:
First/Mid/Last Name: Pem Carter
Company Name:
Address:
City/State/Zip:
Phone: [phone]
Pager/Mobile Phone: /
Chemical Name Reportable Qty. lbs. Reportable Qty. kgs.
Position Method:
Position Accuracy:
Position Datum:
CNA Holdings, Inc. - Ticona Palnt
2525 Blacksburg Rd
Grover NC 27013
Report Created 02/27/07 09:25 AM Page 1

Cause/Observation: Directions:
Pump failure resulted in the release of spring and HVAC
condensate water through north stormwater outfall. Release did
not affect any surface waters. Release begain at 09:30 AM and
stopped at 2:30 PM. Facility released 10,440 gallons (6 gal/min.),
Per the facility's stormwater contingency plan pumping stations
at the outfalls ensure that no waters leave the site except during
rain events.
Action Taken: Comments:
Facility sampled water to determine water quality. Analytical results:
MBAS - < MDL
Phenol - < MDL
Color - Clear
Clarity - Clear
BOD-5 - 5.7 mg/I
COD - <MDL
Floating solids - None
Oil Sheen - None
pH - 6.9
TSS - 3.3 mg/I
Odor - None
Foam - None
Total lead - < MDL
Total nitrogen - 1.1 mg/I
Bis(2-ethylhexyl)phthalate - < MDL
Incident Questions:
Did the. Material reach the Surface Water? No Conveyance:
Surface Water Name?
Did the Spill result in a Fish Kill? Unknown Estimated Number offish?
If the Spill was from a storage tank indicate type.
(Above Ground or Under Ground)
Containment? Unknown
Cleanup Complete? Yes
Water Supply Wells within 1500ft : Unknown
Event Type
Incident closed
Groundwater Impacted : Unknown
Event Date Due Date Comment
2007-02-27 09:19:00
Report Created 02/27/07 09:25 AM Page 2

Report Entered
Report Received
Referred to Regional Office - Primary Contact
Requested Additional Information
Incident Start
Standard Agencies Notified:
Agency Name Phone
2007-02-27 09:16:00
2007-02-09 03:30:00
2007-02-09 03:30:00
2007-01-09 03:30:00
2007-01-09 09:30:00
Follow-up to release
First Name M.I. Last Name Contact Date
Other Agencies Notified:
Agency Name Phone First Name M.I. Last Name Contact Date
DWQ Information:
Report Taken By: Report Entered By: Regional Contact:
Samar E Bou Ghazale Marcia Allocco Samar E Bou Ghazale
Phone:
Date/Time: 2007-02-09 03:30:00 PM 2007-02-27 09:16:00 AM 2007-02-09 03:30:00 PM
Referred Via: Phone Phone
Did DWQ request an additional written report? 2007-01-09 03:30:00 PM
If yes, What additional information is needed? Follow-up to release
Report Created 02/27/07 09:25 AM Page 3

CERTIFIED MAIL 7002 0860 0006 3968 4511
Returned Receipt to PEM Carter
February 15, 2007
PEMC07:08
U- -
d6i aiJi Bp 2
NC Department of Environment and Natural Resources
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Final Report of the Pump Failure at North Stormwater Outfall — 1/09/07
(CNA Holdings, Inc., Shelby Plant, Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
i ico a
Ticona
2525 Blacksburg Road
Grover, NC 28073-9641
Carolina Star Worksite
ISO 9001, ISOfTS 16949,
ISO 17025, and ISO 14001
This report serves as a confirmation that the waters leaving through the North Stormwater Outfall, due to pump
failure, were approved waters (spring & HVAC condensate waters) under our Stormwater Permit No.
NCS000064 and did not impact any receiving bodies of water. The release began 1-09-07 at 9:30 a.m. and
ended 1/10/007 at 2:30 p.m.
CNA Holdings, Inc — Ticona reported to you on January 9, 2007, the release of waters through our North
Stormwater ditch, which were identified as spring waters. Per to the site's stormwater contingency plan,
we maintain pumping stations at our outfalls to ensure no waters leave the site, except during rain events.
Samples were collected during the pump failure incident and analyzed by Prism Laboratories, Inc.
Discharge Volume: 10,4401
gal
6gal/min
Test Parameters:
pH: 6.9
Bis(2-ethylhexyl)phthaIate: BRL ug/I
MBAS: BRL mg/1
BOD5: 5.7 mg/1
TSS: 3.3 mg/1
Total Lead: BRL mg/1
Phenol: BRL ug/l
COD: BRL mg/1
Total Nitrogen: 1.1 mg/1
Color: clear
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(cDticona.com
cerel
PEM Carter
Sr. Environmental Engineer
_Celanese
Ticona
A business of Celanese

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
April 24, 2007
Steve Olp
CNA Holdings Inc
2848 Cherry Rd
Ste 100
Rock Hill, SC 29730
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Ticona Facility
Permit Number: NC0004952
Case Number: LV-2007-0124
Cleveland County
Dear Mr. Olp:
Alan W. Klimek, P.E. Director
Division of Water Quality
APR 2 E 2,907
Uu�]�i
This letter is to acknowledge receipt of check number 2000074783 in the amount of $831.50
received from you dated April 17, 2007. This payment satisfies in full the above civil assessment
levied against the subject facility, and this case has been closed. Payment of this penalty in no way
precludes future action by this Division for additional violations of the applicable Statutes,
Regulations, or Permits.
If you have any questions, please call Robert L Sledge at 919-733-5083 Ext.547.
Sincerely,
Misti Martin
cc: rplie ega'onalGlffce,Superwdisa
Central Files
1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
Customer Service
1 800 623-7748
Noce hCarolina
vVaturally

celanese
'16011NWESTLLBJRFREEWAY
DALLAS,
TX 75234
PAY TO THE POINT SOURCE COMPLIANCE
ORDER OF ENFORCEMENT UNIT DIV OF WATER QUALI
Eight Hundred Thirty One and 501100 Dollars
POINT SOURCE COMPLIANCE
CNA HOLDINGS, INC.
CITIBANK, N.A.
ONE PENN'S WAY, NEW CASTLE „DE 19720
62-20 N0.2000074783
311
LV -e 007- DQ+
11' 20000 74 78 31i' 1:0 3 i L00 20 91: 38 5 7 5 504i1'
04/17/2007
AMOUNT IN US DOLLARS
$$$$$$$$$$$$$831.50
NOT VALID AFTER 1 YEAR
AUTHORIZED IGNATuRE
AUTHORIZED SIGNAT E

Michael F. Easley, ovemor I
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
March 27, 2007
CERTIFIED MAIL 7006 2760 0001 8493 7392
RETURN RECEIPT REQUESTED
Ms. PEM Carter
Sr. Environmental Engineer
CNA Holdings, Inc. Ticona Facility
Highway 198
Shelby, North Carolina 28152
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215.1(a)(6) and NPDES Permit No. NC0004952
CNA Holdings, Inc. WWTP
Cleveland County
Case No. LV-2007-0124
Dear Ms. Carter:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount
of $831.50 ($750.00 civil penalty + $81.50 enforcement costs) against CNA Holdings, Inc..
This assessment is based upon the following facts: A review has been conducted of the
self -monitoring data reported for November 2006. This review has shown the subject facility to
be in violation of the discharge limitations found in NPDES Permit No. NC0004952. The
violations are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that CNA Holdings, Inc.
violated the terms, conditions, or requirements of NPDES Permit No. NC0004952 and North
Carolina General Statute (G.S.) 143-215.1(a)(6) in the manner and extent shown in Attachment
A. A civil penalty may be assessed in accordance with the maximums established by G.S. 143-
215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural. Resources
and the Director of the Division of Water Quality, I, John Lesley, Acting Regional Supervisor
Surface Water Protection for the Mooresville Region, hereby make the following civil penalty
assessment against CNA Holdings, Inc.:
ANA NorthCarolina
MCDENR NaturallY
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: www.ncwaterquality.orn 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

$ 750.00 For 3 of the three (3) violation(s) of G.S.
143-215.1(a)(6) and NPDES Permit No.
NC0004952, by discharging waste into the waters of
the State in violation of the permit daily maximum
effluent limit for BOD.
$ 750.00 TOTAL CIVIL PENALTY
$ 81.50 Enforcement costs.
$ 831.50 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(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 violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty will
not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of.
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
I

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
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 sand a
stipulation 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 G.S. 143B-
2 82. 1 (b) were wrongfully applied to the detriment of the petitioner;
(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 had 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 information 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 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:

Point Source Compliance/Enforcement Unit
Division of Water Quality
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, North Carolina 27699-6714
Telephone: [phone] Facsimile: [phone]
A copy of the petition must also be served on DENR as follows:
Ms. Mary Penny Thompson, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
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 the violations are of a continuing- nature, not related to

operation and/or maintenance problems. and you anticipate remedial construction activities then
you may wish to consider applyingqpplying for a Special Order by Consent. If you have any questions
about this civil penalty assessment or a Special Order by Consent please contact the Water
Quality Section staff of the Mooresville Regional Office at [phone].
(Date) �6& Lesley
Acting g p Regional Su ervi;br
Surface Water Protection
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
MA

ATTACHMENT A
CASE NO. LV-2007-0124
Outfall
Date
Parameter
Reported Value
001
11/20/06
BOD
203.3 lbs/day *
001
11/21/06
BOD
221.5 lbs/day *
001
11/22/06
BOD
216.0 lbs/day *
* Denotes civil penalty assessment
164 lbs/day (Daily maximum)
164 lbs/day (Daily maximum)
164 lbs/day (Daily maximum)

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF CLEVELAND
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTY AGAINST ) ADMINISTRATIVE HEARING AND
CNA HOLDINGS, INC. ) STIPULATION OF FACTS
PERMIT NO. NC0004952 )
FILE NO. LV-2007-0124
Having been assessed civil penalties totaling $831.50 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated March 27, 2007, 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 30 days of receipt of the notice of assessment. No new evidence in support
of a remission request will be allowed after 30 days from the receipt of the notice of assessment.
This the day of , 2007
BY
ADDRESS

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: LV-2007-0124
Assessed Party: CNA Holdings, Inc.
County: Cleveland
Permit Number: NC0004952
Amount Assessed: $831.50
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver ofRight to an Administrative Hearing, and Stipulation of Facts"
form to request remission of this civil penalty. You should attach any documents that you believe
support your request and are necessary for the Director to consider in evaluating your request for
remission. Please be aware that a request for remission is limited to consideration of the five factors
listed below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or
the accuracy of any of the factual statements contained in the civil penalty assessment document.
Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only when one or
more of the following five factors applies. Please check each factor that you believe applies to your
case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282.1(b) were
wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civil
penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a result of an accident (i. e., explain why the violation
was unavoidable or something you could not prevent or prepare for);
(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: (use additional pages as necessary)

Ir O�oF WA T FRQG
c
o -c
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
JJ L
Michael F. Easley, G error
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
March 22, 2006
Ms. PEM Carter, Sr. Environmental Engineer
CNA Holdings, Inc. Shelby Plant
Highway 198
Shelby, North Carolina 28152
Dear Ms. Carter:
7003 2260 0001 3493 8606
Subject: Notice of Violation - Effluent Limitations
Tracking #: NOV-LV-0120
CNA Holdings, Inc. WWTP
NPDES Permit No. NC0004952
Cleveland County
A review of the November 2005 self -monitoring report for the subject facility revealed a
violation of the following parameter:
Pipe Parameter Reported Value Permit Limit
001 BOD 217.7 lbs/day .164.0 lbs/day (daily maximum)
Remedial actions, if not already implemented, should be taken to correct any problems. The
Division of Water Quality may pursue enforcement actions for this and any additional violations. If the
violations are of a continuing nature, not related to operation and/or maintenance problems, and you
anticipate remedial construction activities, then you may wish to consider applying for a Special Order
by Consent. You may contact Mr. John Lesley of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or me
at 704/663-1699.
Sincerely, /
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
cc: Point Source Branch
Cleveland County Health Dept.
'V . NofthCarolina
NCDENR ,Naturally
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: www.ncwaterquality.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]-62j-6748
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
January 11, 2007
221
Mr. Pem Carter
CNA Holdings, Inc. - Ticona Facility
2525 Blacksburg Road
Grover, NC 28073-9641
SUBJECT: Wastewater/Groundwater Laboratory Certification Renewal
Dear Mr. Carter:
Alan W. Klimek, P.E. Director
Division of Water Quality
JAI\ E
The Department of Environment and Natural Resources, in accordance with the provisions of NC GS
143-215-.3 (a) (10), 15 NCAC 2H .0800, is pleased to renew certification for your laboratory to perform
specified environmental analyses required by EMC monitoring and reporting regulations 15 NCAC 2B
.0500, 2H .0900 and 2L .0100, .0200, .0300, and 2N .0100 through .0800.
Enclosed for your use is a certificate describing the requirements and limits of your certification. Please
review this certificate to insure that your laboratory is certified for all parameters required to properly meet
your certification needs.
Please contact your assigned inspector Chet Whiting at [phone], if you have questions or need
additional information.
Sincerely,
Pat Donnelly
Branch Manager
Enclosure
cc: Chet Whiting
Mooresville Regional Office
No�rthCarolina
NllturalllJ
Laboratory Section 1623 Mail Service Center Raleigh, NC 27699-1623 Phone [phone] Customer Service
Internet: www.dwqlab.or Location: 4405 Reedy Creek Rd. Raleigh, NC 27607 Fax [phone]
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Certificate No.
6 L
STATE OF NORTH CAROLINA DEPARTMENT OF THE
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
LABORATORY CERTIFICATION PROGRAM
In accordance with the provisions ofN.C.G.S. 143-215.3 (a) (1), 143-215.3 (a)(10) and NCAC 2H.0800:
r ti 4 SrAT GO
Mh:f 20
, i. n
w
CNA HOLDINGS, INC. - TICONA FACILITY
Is hereby certified to perform environmental analysis as listed on Attachment I and report monitoring data to DWQ for
compliance with NPDES effluent, surface water, groundwater, and pretreatment regulations.
By reference 15A NCAC 2H .0800 is made a part of this certificate.
This certificate does not guarantee validity of data generated, but indicates the methodology, equipment, quality control procedures,
records, and proficiency of the laboratory have been examined and found to be acceptable.
This certificate shall be valid until December31, 2007
221 _ ~�
Pat Donnelly

Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
-ab Name: CNA Holdings, Inc. - Ticona Facility Certificate Number: 221
Nddress: 2525 Blacksburg Road Effective Date: 01/01/2007
Grover, NC 28073-9641 Expiration Date: 12/31/2007
Date of Last Amendment:
fhe above named laboratory, having duly met the requirements of 15A NCAC 21-1.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
NORGANICS
'OD
Std Method 5220D
'OLIFORM FECAL
Std Method 9222D (MF)
DISSOLVED OXYGEN
Std Method 4500 O C
)H
Std Method 4500 H B
RESIDUE SUSPENDED
Std Method 2540D
TEMPERATURE
Std Method 2550E
'his certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are
ubject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 21-1.0807.

May 3, 2006
Ms. PEM Carter, Sr. Environmental Engineer
CNA Holdings, Inc., Shelby Plant
Highway 198
Shelby, North Carolina 28152
Subject:
Dear Ms. Carter:
Michael F. Easley, Govem �( i
William G. Ross Jr., Secretary✓/�
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Results from Effluent Sampling Analyses
CNA Holdings, Inc. WWTP
NPDES Permit No. NC0004952
Cleveland County, N.C.
Enclosed please find the results from the laboratory analyses performed on the effluent samples
from the CNA Holdings, Inc. wastewater treatment plant (WWTP). The samples analyzed were composite
and grab samples collected during the Compliance Sampling Inspection performed by Mr. Wes Bell on
March 9, 2006.
The results of the sampling analyses show compliance with the permit limits. Please attach this
letter to the inspection report dated March 22, 2006 to complete your records on the inspection.
The report should be self-explanatory; however, should you have any questions concerning the
report, please do not hesitate to contact Mr. Bell or me at [phone].
Sincerely,
1100
D. Rex Gleason, P.E.
151-IL Surface Water Protection Regional Supervisor
Enclosure
cc: Cleveland County Health Department
MW
os�e am NClina
NCDEWR Naturally
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: www.ncwaterqualit�org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

ANALYTICAL RESULTS SHEET
NAME OF FACILITY: CNA Holdings, Inc. WWTP
Grab: X Composite:
X
Sample Date(s): 3/9/06
NPDES Permit No. NC0004952
Sample Location: Effluent
County: Cleveland
BODS, mg/1 5.0
Phenols, ug/l
COD: High, mg/l
Sulfate, mg/l
COD: Low, mg/l
Sulfide, mg/1
Coliform: Fecal, #/100 ml 1
Biomass: Dry Weight
Coliform: Total, #/100 ml
Biomass: Peri Ash Free
Coliform: Tube Fecal, MPN
NH3-N, mg/1
<0.02
Coliform: Tube Total, MPN
TKN, mg/I
1.5
Residue: Total, mg/l
NO, + NO, mg/1
6.0
Volatile, mg/1
PO" mg/l
Fixed, mg/1
P: Total, mg/1
0.21
Residue: Suspended, mg/1 12
P: Dissolved, mg/I
Volatile, mg/1
Ag-Silver, ug/1
<5.0
Fixed, mg/1
luminum, ug/1
120
Settleable Solids-, ml/1
rsenic, ug/l
<5.0
pH, s.u. 9.4*
rCa-Calciurn,ug/l
Color, True 80, c.u.
admium, ug/l
<2.0
Color (pH) 83, c.u. pH = 7.8
obalt, ug/1
Color, pH 7.6 82, c.u.
Cr-Chromium: Total, ug/l
<25
Oil and Grease, mg/1 <10
Cu-Copper, ug/l
12
Cyanide, mg/I
Fe -Iron, ug/l
93
Fluoride, mg/I
Pb-Lead, ug/l
<10
Hardness: Total, mg/l
Hg-Mercury, ug/1
<0.2
MBAS, ug/1
Zn-Zinc, ug/l
18
Conductivity, umhos/cm
Ni-Nickel, ug/1
<10
Total Residual Chlorine, ug/l
VOC
Temperature, °C 12.8
* the pH of the secondary clarifiers 30-days prior to this date was approximately 7.0 s.u.

Michael F. Easley, Govern i,
William G. Ross Jr., Secretary 1/
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
March22, 2006
Ms. PEM Carter, Sr. Environmental Engineer
CNA Holdings, Inc., Shelby Plant
Highway 198
Shelby, North Carolina 28152
Subject: Compliance Sampling Inspection
CNA Holdings, Inc. WWTP
NPDES Permit No. NC0004952
Cleveland County, N.C.
Dear Ms. Carter:
Enclosed is a copy of the Compliance Sampling Inspection Report for the inspection
conducted at the subject facility on March 9, 2006, by Mr. Wes Bell of this Office. Please inform
the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the
enclosed report. The results of the effluent sampling will be forwarded to you under separate
letter.
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact Mr. Bell or me at [phone].
Sincerely,
� l,l
Rex Gleason' P.E.
Surface Water Protection Regional Supervisor
Enclosure
cc: Cleveland County Health Department
AW
4CDENR
Mooresville Regional Office Division of Water Quality Phone [phone]
Internet: www.ncwaterquality.or2 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
One
NCarolina
Aawrally
Customer Service
1-877-623-6748
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United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 2046o
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 INI 2 LI 31 NC0004952 111 121 06/03/09 117 181 SI 19I SI 20II
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --------------------------- Reserved ----------------------
67I 1.5 169 70 14 I 711 NJ 72 I NJ 73 L U, 74 751 I I I I I I 180
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)
Ticona Facilyty
10:00 AM 06/03/09
04/06/01
Exit Time/Date
Permit Expiration Date
NC Hwy 198
Shelby NC 28150
01:00 PM 06/03/09
08/08/31
Name(s) of Onsite Representative (s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Johnny L Ledford/ORC/704-480-4692/
Pem Carter///
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Edward J McKinley,NC Hwy 198 Shelby NC 28151//704-480-4700/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Find in /Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Wesley N Bell MRO WQ//704-663-1699 Ext.231/ /
Signature of Managemgpt Q A Reviewer Agency/Office/Phone and Fax Numbers Date
John
E Lesley If MRO WQ//704-663-1699 Ext.270/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

Pr
NPDES yr/mo/day Inspection Type
3I NC0004952 I11 12I 06/03/09 1
17 18IS1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
RECORD KEEPING SECTION cont'd:
DMRs were reviewed for the period January 05 through December 05. A daily maximum effluent BOD
violation was reported on 11/23/05. The Division will separately address this violation by an issuance of
either an NOV or NOV/civil penalty assessment.
The facility staff must ensure all ORC and/or Backup ORC visitations are documented on future DMRs.
Overall, the facility staff incorporate a commendable record keeping system.
Page # 2

Permit: NC0004952
Inspection Date: 03/09/2006
Owner -Facility: Ticona Facility
Inspection Type: Compliance sampling
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: The facility's effluent pH will be required to be within the 6.0 S.U. - 9.0 S.U.
permit limit range by May, 1, 2006.
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 consistent with 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
❑ ❑ ■ ❑
■❑❑❑
❑ ❑ ■ ❑
■❑❑❑
■❑❑❑
Yes No NA NE
■ ❑ ❑ ❑
■❑❑❑
■❑❑C1
■❑❑❑
■
❑
❑
❑
■
■
■
■
■
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification? -
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment: See "Summary" Section for additional comments.
Laboratory
Are field parameters performed by certified personnel or laboratory?
■
❑
❑
❑
❑❑■❑
❑
❑
■
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑'
❑
❑
■
❑
Yes
No
NA
NE
■
❑
❑
❑
Page # 3

PV
Permit: NC0004952
Inspection Date: 03/09/2006
Owner -Facility: Ticona Facility
Inspection Type: Compliance Sampling
Laboratory
Yes
NO
NA N
Are all other parameters(excluding field parameters) performed by a certified lab?
■
n
n ❑
# Is the facility using a contract lab?
■
n
❑ n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
n
Cl
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
n
n
n ■
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
n
❑ ■
Comment: On -site effluent analyses are performed under laboratory certification
#221. Please refer to Mr. Chet Whiting's (Division's Laboratory Certification Unit)
inspection report regarding the facility's on -site laboratory practices.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
■
n
n
n
Is sample collected below all treatment units?
■
❑
n
n
Is proper volume collected?
■
n
n
n
Is the tubing clean?
■
❑
n
n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ■ n ❑ n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ ❑ n Cl
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ n n n
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ n n n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ ❑ Q
Judge, and other that are applicable?
Comment: The facility staff incorporate a comprehensive process control program.
The facility appeared to be properly operated and well maintained at the time of the
inspection. The UV disinfection system is currently not in -use due to equipment
malfunctions.
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
■
Cl
Page # 4

Permit: NC0004952
Inspection Date: 03/09/2006
Owner -Facility: Ticona Facility
Inspection Type: Compliance Sampling
'NI
Bar Screens
Yes No
NA
NE
Is the screen free of excessive debris?
■ n
Q
n
Is disposal of screening in compliance?
■ n
n
n
Is the unit in good condition?
■ n
❑
n
Comment:
Type of grit removal
a.Manual
■
b.Mechanical
n
Is the grit free of excessive organic matter?
■
❑
n
n
Is the grit free of excessive odor?
■
n
# Is disposal of grit in compliance?
■
n
n
n
Comment:
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
n
❑
■
n
Is the basin free of bypass lines or structures to the natural environment?
■
n
n
n
Is the basin free of excessive grease?
n
n
■
❑
Are all pumps present?
❑
❑
■
n
Are all pumps operable?
n
❑
■
Are float controls operable?
n
n
■
n
Are audible and visual alarms operable?
❑
❑
■
# Is basin size/volume adequate?
■
n
n
n
Comment: The pH of the process wastewater is adjusted in the equalization basins
prior to the confluence with the influent domestic wastewater.
Chernical Feed
Yes
No
NA
NE
Is containment adequate?
■
n
n
Is storage adequate?
■
❑
❑
Q
Are backup pumps available?
■
Is the site free of excessive leaking?
■
❑
n
n
Comment:
Aeration Basins
Yes
No
NA
NE
Page # 5

PV
Permit: NC0004952
Inspection Date: 03/09/2006
Owner -Facility: Ticona Facility
Inspection Type: Compliance Sampling
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
■
❑
❑
❑
Are surface aerators and mixers operational?
■
❑
❑
❑
Are the diffusers operational?
❑
❑
■
❑
Is the foam the proper color for the treatment process?
■
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
■
❑
❑
❑
Is the DO level acceptable?
■
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
■
❑
❑
❑
Comment:
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
❑
❑
❑
Are weirs level?
■
❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
❑
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
■
Cl
❑
❑
Is the site free of excessive floating sludge?
■
❑
❑
❑
Is the drive unit operational?
■
❑
❑
❑
Is the return rate acceptable (low turbulence)?
■
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
■
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
■
❑
❑
❑
Comment:
Lagoons
Yes
No
NA
NE
Type of lagoons?
# Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
# Is a re -circulation line present?
❑
❑
■
❑
Is lagoon free of excessive floating materials?
■
❑
❑
❑
Page # 6

Permit: NC0004952
Inspection Date: 03/09/2006
Owner - Facility: Ticona Facility
Inspection Type: Compliance Sampling
Niq
Lagoons
Yes
No
NA
NE
# Are baffles between ponds or effluent baffles adjustable?
❑
❑
■
❑
Are dike slopes clear of woody vegetation?
■
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
■
❑
❑
❑
Are dikes free of seepage?
■
❑
❑
Are dikes free of erosion?
■
❑
❑
❑
Are dikes free of burrowing animals?
■
❑
❑
❑
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
❑
❑
■
❑
# If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
■
❑
Is the lagoon surface free of weeds?
■
❑
❑
❑
Is the lagoon free of short circuiting?
■
❑
❑
❑
Comment: The clarified effluent flows through three polishing ponds prior to tertiary
filtration.
Filtration (High' Rate Tertiary) Yes No NA NE
Type of operation: Down flow
Is the filter media present?
■
❑
❑
❑
Is the filter surface free of clogging?
■
❑
❑
❑
Is the filter free of growth?
❑
❑
❑
■
Is the air scour operational?
❑
❑
■
❑
Is the scouring acceptable?
■
❑
❑
❑
Is the clear well free of excessive solids and filter media?
❑
❑
❑
■
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow, meter calibrated annually? _
®❑
❑
❑
Is the flow meter operational?
■
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
■
❑
Comment: The flow meter is calibrated/verified on a quarterly basis. The flow meter
was last calibrated/verified on 12/29/05 by the facility's I & E Department.
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
❑
❑
❑
■
Page # 7

r� r
CERTIFIED MAIL 7002 0860 0006 3968 4252 l�
Return Receipt to PEM Carter
March 3, 2006
PEMC06:14
NC Department of Environment and Natural Resources
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
fiEPT. CF'EN%qP,je,
9 OFFICE
.1
1
MAR 0 6 2006
. al l
Attn: Mr. Samar Bou-ghazale`"
Wes �dn�
Re: Release of FireWater into Stormwater Drainage Ditch — 2/27/06
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
i cona
Ticona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
This report serves as the written requirement for the Incident reported by telephone on February 27, 2006
Per this telephone message, CNA Holdings, Inc — Ticona reported to you the incident whereas Invista, a leasing
tenant, released fire water, while performing repairs to their fire suppression system, by way of the north stormwater
outfall. The repair required purging the firewater manifold which is designed of a 3" pipe running approximately 45
feet and releasing to the outside. It was discovered at 2:25 p.m. on February 27, 2006. Invista and CNA Holding
Inc. immediately closed all PIV valves, which discontinued the release of firewater. The following table represents
the duration of the overall incident:
Incident Time Time Duration
Start End (min)
14:05 14:25 20.00
Based on the duration of this incident, approximately 4000 gallons of firewater flowed through the north stormwater ditch
leaving the site. At present, all repairs have been postponed until an acceptable discharge point is identified.
An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo Creek. There
were no observed environmental impacts to Buffalo Creek Samples of this water have been collected and submitted
to a contract lab, Prism Laboratories.
Discharge Volume: 40001 gal
Test Parameters:
pH: 7.6
Bis(2-ethylhexyl)phthalate: pending
MBAS: pending
BOD5: pending
TSS: pending
Total Lead: pending
Phenol: pending
COD: pending
Total Nitrogen: pending
Color: clear
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal regulations.
Should there be a need for further discussion pertaining to the information submitted with this notification letter, feel free to
call me at 704/480-4900, or via email at pem.carter a�ticona.com
-Sincerely,
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona
A business of Celanese AG

077-7. 0�= t°.0l1KCN6'/3ibW I ' c®n
6iGWD F ;'.?" 3tlRCES
February 6, 2006^' ~` +° °L OFFICE
I
PEMC06:07
NC Department of Environment and Natural Resources FEB 0 8 2006 Ticona
Division of Water Quality
610 East Center Avenue — Suite 301 Shelby Plant
Mooresville, NC 28115 Highway 198
Shelby, NC 28152
Attn: Mr. Samar Bou-ghazale App q� �®lephone [phone]
Re: Final Report of the Release of Firewater into Stormwater Drainage Ditch — 12/27/05
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as the final written requirement for the incident reported by telephone on December 28, 2005
CNA Holdings, Inc — Ticona reported to you the release of fire water by way of the north stormwater outfall,
which was discovered at 4:50 p.m. on December 27, 2005. Immediate efforts to isolate the affected PIV
failed after several attempts, leaving the plant with no option other than to shut off the fire pumps. The
following table represents duration of the overall incident of December 27, 2005:
Incident Time
Start
16:50
.17:07
17:43 .
17:43
17:56
17:58
18:21
Pumps
Time
Duration
(on or
End
(min)
off)
17:07 -
17.00
On
II T43 __ -_ _
36.00 -
Off
17:43:30
0.50
On,
17:56
12.50
Off
17:58
2.OQ
On'
18:21 ' '
23.00
Off
18:25
4.00
On
Based on the duration of this incident, 390,705 gallons of firewater flowed through the stormwater ditches
leaving the site:
Max
Flow
GPM
Maximum makeup rate to
Firewater Lagoon:
347
GPM
Makeup volume from Creek:
32,986
gallons, max
Lagoon never emptied, but came
close.
250,000
gallons, max
Lake Pumps never turned on to
refill Lagoon.
0
gallons, max
Some water came from Firewater
Piping
107,719,
gallons, max (assuming 5 miles of 10" diameter
piping drained)
Most Probable Case
390,705
gallons
An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo
Creek. A large section of soil was washed out, affecting the TSS and color of the waters leaving the site.
Celanese
Ticona
A business of Celanese AG

.e" I
However, the silted red -clay was greatly reduced by naturally settling out before it reached Buffalo Creek.
Therefore we feel there were no observed environmental impacts to Buffalo Creek. Samples were
analysed by Prism Laboratories.
Discharge Volume: 390,7051 gal
Test Parameters:
pH: 7.5
Bis(2-ethylhexyl)phthalate: BRL
MBAS: BRL ug/1
BOD5: 9.1 mg/1
TSS: 1100 mg/1
Total Lead: 0.033 mg/1
Phenol: BRL mg/1
COD: 63 mg/1
Total Nitrogen: BRL mg/1
Color: red due to
Floating Solids: none
Odor: none
--clay
Clarity: muddy/red
Oil sheen: none
Foam: none
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carteraticona.com
Sincerely,
PEM Carter
Sr. Environmental Engineer

Certified Mail 7004 2510 0002 9276 5169
Return Receipt to PEM Carter
February 6, 2006
FEB ( 8 20.rY
"c®na
Ticona
Shelby Plant
PEMC06:08 Highway 198
Shelby, NC 28152
n l ;: Telephone [phone]
NC Department of Environment and Natural ResourcAlATER 0�',,`; . P � � �
Division of Water Quality �WJ �� e�N
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Release of FireWater into Storrwater Drainage Ditch — -il-11105
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as the final written report for the release of approximately 75 gallons of a A Triple
F/ATC Firefighting foam as 3% in water( 97%). Simultaneously, a storm event occurred which impeded
our abilities -to capture -the "escaped" foam/water mixture, thus it entered into our stormwater distribution
system.
An examination of the drainage ditch indicated that the visible sign of foam was seen during the first 30
minutes of the storm event. Total Suspended Solids is made up of fine red -clay silt as a result of a fire -
main rupture which washed out a large section of soil in December. Both the fine red -clay silt and the
foam/water material was washed to the north storm water outfall during a rain event. These waters
released flowed to Buffalo Creek. Samples of this water were analyzed by Prism Laboratories, Inc. and
are as follows:
Discharge Volume:
75 gallons
Foam/firewater mixture diluted by a
stormevent.
Test Parameters:
pH: 6.5
Bis(2-ethyIhexyl)phthaIate: BRL ug/1
MBAS: 0.24 mg/1
BOD5: 61 mg/1
TSS: 450 mg/1
Total Lead: 0.027 mg/1
Phenol: BRL mgn
COD: 280 m9/1
Total Nitrogen: 0.73 mg/1
Color: orange from
red clay.
Floating Solids: none
Odor: none
Clarity: muddy/red
Oil sheen: none
Foam: YES
First 30 minutes
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(a-)-ticona.com
rely .
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona
A business of Celanese AG

Certified Mail: 7002 0860 0006 3968 4597
Return Receipt to PEM CarterF
,
`1����Svv��imi.§ �zr*i iJu�ti�i3. mJ8I
October 13, 2005
PEMC05:41
8 ()GT 1 7 2005
NC Department of Environment and Natural Resources
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
I1c®na
Ticona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Re: Final Report: Release of Cooling Water into East Stormwater Drainage Ditch — 8/17/05
(CNA Holdings, Inc., Ticona Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as the final written notification for the August 17, 2005 incident. At the time of our
conversation, CNA Holdings, Inc — Ticona reported waters were being released at the East Outfall at the rate of
0.4 GPM from an unknown origin. During the investigation, Ticona discovered these waters were from the main
Firewater line. A permanent repair required a full plant shut down with the cooperation of all site residents (ie:
Invista ). The repair was scheduled for August 24 and was completed on August 25, 2005. Waters continued to
weep at the rate of 570 gallons/day between August 17, 2005 — August 23, 2005.
Although efforts had been put in place to reduce and minimize the release, removing soils in preparation of the
repair revealed catastrophic failure of the fire water main line. This resulted in approximately 20,000 gallons
immediately being released by way of the East Outfall. By August 26, 2005, all repairs were completed.
Shaded cells represent new information such as final flow and the analytical results of these waters submitted
and analyzed by outside contract laboratory, Prism Laboratories, Inc. .
e Volume:
I I Test Parameters: IpH: 7.5 I IRs.2-ethYlhex�l[)pt,thalate.=..�6RL: I
Color: water white IFloating Solids: none Odor: none
Clarity: clear jOil sheen: none Foam: none
BRL : Below Reporting Limits
An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo
Creek. There were no observed environmental impacts to Buffalo Creek. Results from Prism Laboratories,
Inc. will be forthcoming.
This is the same water, which was characterized and requested for approval in the permit renewal
package submitted January 2005.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information. submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carterp—ticona.com
cerely,
Z
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona
A business of Celanese AG

1 i6GCW aVIO p;o'nvs-aa,.'Y'srwVv+lJri6iC�
1 I c ®n a
January 13, 2006 JA1 2'01?'
PEMC06:02
NC Department of Environment and Natural Resources Vol C ,Tit ona
Division of Water Quality "RUAUTY
610 East Center Avenue — Suite 301 helby Plant
Mooresville, NC 28115 Highway 198
Shelby, NC 28152
Attn: Mr. Samar Bou-ghazale Telephone [phone]
Re: Release of Firewater into Stormwater Drainage Ditch—12/27/05
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as the written requirement for the release of approximately 2 gallons of aqueous film -forming
foam (a.k.a. A Triple F/ATC Fire fighting foam) which is diluted down to the concentration of 3% f02m/97%
firewater. Foam/water mixture was used in response to a small leak within a secondary containment basin. The
majority of the foam/water mixture was contained, however approximately 75 gallons of this mixture splattered
off of the walls of tanks leaving the containment area. Simultaneously, a storm event occurred which impeded
our abilities of capture the "escaped" foam/water mixture and it entered into our stormwater distribution system. .
The storm event measured 0.7 inches and continued throughout the day, finally ceasing around 8:00 p.m. The
release of foam/water mixture was reported by telephone on January 12, 2006.
Per my message to you, CNA Holdings, Inc — Ticona reported to you the release of A Triple F/ATC in
solution which occurred on January 11 beginning at 10:05 a.m. and due to a rain event, the waters
continued to leave through the established stormwater outfall until 8:00 p.m.
An examination of the drainage ditch indicated that the visible sign of foam was seen during the first 30
minutes of the stormevent. These waters released did flow to Buffalo Creek. There were no observed
environmental impacts to Buffalo Creek. Samples of this water have been collected and submitted to a
contract lab, Prism Laboratories.
Discharge Volume:
75 gallons
Foam/firewater mixture diluted by a
stormevent.
Test Parameters:
pH: 6.5
Bis(2-ethylhexyl)phthalate: pending
MBAS: pending
BODS: pending
TSS: pending
Total Lead: pending
Phenol: pending
COD: pending
Total Nitrogen: pending
Color: orange from
red clay.
Floating Solids: none
Odor: none
Clarity: muddy/red
Oil sheen: none
Foam: YES
First 30 minutes
Results from Prism Laboratories, Inc. will be forthcoming.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(cb-ticona.com
cerely6��
.
PEM Carter
Sr. Environmental Engineer
ID Celanese
Ticona
A business of Celanese AG

AMU NATI.IR�
pppppp
900RESViLU
i icona
January 3, 2006 JAN 1 1 2006
PEMC06:01
NC Department of Environment and Natural Resour Ticona
Division of Water Quality QUAL
610 East Center Avenue —Suite 301��; Shelby Plant
Mooresville, NC 28115 Highway 198 Shelby, NC 28152
Attn: Mr. Samar Bou-ghazale Telephone [phone]
Re: Release of FireWater into Stormwater Drainage Ditch—12/27/05
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as the written requirement for the incident reported by telephone on -December 28, 2005
Per our telephone conversation, CNA Holdings, Inc — Ticona reported to you the release of fire water by
way of the north stormwater outfall. It was discovered at 4:50 p.m. on December 27, 2005. Immediate
efforts to isolate the affected PIV failed after several attempts, leaving the plant with no option other than to
shut off the fire pumps. The following table represents duration of the overall incident of December 27,
2005:
Pumps
Incident Time
Time
Duration
(on or
Start
End
(min)
off)
-..1,6:50,
17:07-
-17.00
On
- -17:07,
17:43
36.00
Off
:_ 17:43 -
17:43:30
0.50
On _.
17:43 ..
17:56
12.50
Off
17:56
17:58
2.00
On
17:58
18:21
23.00
Off
18:21
18:25
4.00
On
Based on the duration of this incident, 390,705 gallons of firewater flowed through the stormwater ditches
leaving the site:
Max
Flow
(GPM)
Maximum makeup rate to
Firewater Lagoon:
347
GPM
Makeup volume from Creek:
32,986
gallons,'max
Lagoon never emptied, but came
close.
250,000
gallons, max
Lake Pumps never turned on to
refill Lagoon.
0
gallons, max
-Some water came from Firewater
Piping
107,719
gallons, max (assuming 5 miles of 10" diameter
piping drained
Most Probable Case
390,705
gallons
�]Jl- Celanese
Ticona
A business of Celanese AG

An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo
Creek. There were no observed environmental impacts to Buffalo Creek Samples of this water have been
collected and submitted to a contract lab, Prism Laboratories.
Discharge Volume: 390,7051 gal
Test Parameters:
pH: 7.5
Bis(2-ethylhexyl)phthaIate: pending
MBAS: pending
BOD5: pending
TSS: pending
Total Lead: pending
Phenol: pending
COD: pending
Total Nitrogen: pending
Color: red due to
clay
Floating Solids: none
Odor: none
Clarity: muddy/red
Oil sheen: none
Foam: none
Repairs to the plant fire suppression system continued through the New Years Holiday. It was discovered
that the buried firewater line had separated partially at a 45 degree junction. During the investigation and
repairs, plant fire pumps were locked out and a Plant -wide Fire Watch was underway. Due to holiday
vacations, engineering support with the above calculations were not available until this time. Thank you
for allowing additional time to report accurately the quantity. Results from Prism Laboratories, Inc. will be
forthcoming.
CNA Holdings, Inc. - Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(a)ticona.com
Sincerely,
(:3D&Xc�
PEM Carter
Sr. Environmental Engineer

j'!/
.l. ���u
iic®na
January 3, 2006
J alb 1 C' 2006
PEMC06:01
NC Department of Environment and Natural Resources Ticona
Division of Water Quality Shelby Plant
610 East Center Avenue —Suite 301
Mooresville, NC 28115
Highway 198
a :' ` '- Shelby, NC 28152
Attn: Mr. Samar Bou-ghazale Telephone [phone]
Re: Release of Firewater into Stormwater Drainage Ditch—12/27/05
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as the written requirement for the incident reported by telephone on December 28, 2005
Per our telephone conversation, CNA Holdings, Inc — Ticona reported to you the release of fire water by
way of the north stormwater outfall. It was discovered at 4:50 p.m. on December 27, 2005. Immediate
efforts to isolate the affected PIV failed after several attempts, leaving the plant with no option other than to
shut off the fire pumps. The following table represents duration of the overall incident of December 27,
2005:
Incident Time Time Duration
Start .
End
(min)
16:50
17:07
17:00
17:07
17:43
36:00
17:43
1743:30
0.50
17:43
17:56 -'
12.50
17:56
17:58
2.00
17:58
18:21
23.00
18:21
18:25
4.00
Based on the duration of this incident, 390,705 gallons of firewater flowed through the stormwater ditches
leaving the site:
Max
Flo::
GPM
Maximum makeup rate to
Firewater Lagoon:
347
GPM
Makeup volume from Creek:
32,986
gallons,'max
Lagoon never emptied, but came
close.
250,000
gallons, max
Lake Pumps never turned on to
refill Lagoon.
0
gallons, max
Some water came from Firewater,
Piping
107,719
gallons, max (assuming 5 miles of 10". diameter
piping drained
Most Probable Case
390,705
gallons
rl,'31 Celanese
Ticona
A business oFCelanese AG

An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo
Creek. There were no observed environmental impacts to Buffalo Creek Samples of this water have been
collected and submitted to a contract lab, Prism Laboratories.
Discharge Volume: 390,7051 gal
Test Parameters:
pH: 7.5
Bis(2-ethylhexyl)phthalate: pending
MBAS: pending
BOD5: pending
TSS: pending
Total Lead: pending
Phenol: pending
COD: pending
Total Nitrogen: pending
Color: red due to
Floating Solids: none
Odor: none
--clay
Clarity: muddy/red
Oil sheen: none
Foam: none
Repairs to the plant fire suppression system continued through the New Years Holiday. It was discovered
that the buried firewater line had separated partially at a 45 degree junction. During the investigation and
repairs, plant fire pumps were locked out and a Plant -wide Fire Watch was underway. Due to holiday
vacations, engineering support with the above calculations were not available until this time. Thank you
for allowing additional time to report accurately the quantity. Results from Prism Laboratories, Inc. will be
forthcoming.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(o)-ticona.com
Sincerely,
Cztl
PEM Carter
Sr. Environmental Engineer

AT-TWAA
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 9, 2005
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ms. PEM Carter, Sr. Environmental Engineer 7003 2260 00013492 7235
CNA Holdings, Inc.
Hwy. 198
Shelby, NC 28152
Subject: Notice of Violation — Monitoring Requirements
NOV-2005-MV-0065
CNA Holdings, Inc. — Shelby Plant WWTP
NPDES Permit No. NC0004952
Cleveland County
Dear Ms. Carter:
A review of the July 2005 self -monitoring report for the subject facility revealed the following
violations:
Pine Parameter Required Monitoring Frequency Failures to Report
001 Total Copper Monthly 1
Remedial actions, if not already implemented, should be taken to corrdct any problems. The
Division of Water. Quality may pursue enforcement actions for these and any additional violations.
If you have questions concerning this matter, please do not hesitate to contact Mr. Richard
Bridgeman or me at 704/663-1699.
Sincerely,
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
cc: Point Source Branch
D
Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Phone: [phone] / Fax: [phone] / Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
NorthCarolina
naturally

Certified Mail: 7002 0860 0006 3968 0896
Return Receipt to PEM Carter
August 29, 2005
PEMC05:38
NC Department of Environment and Natural Resources
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115 _
Attn: Mr. Samar Bou-ghazale
IICOna
Tieona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Re: Final Followup to the Release of Extrusion/Contact and Wash Waters into Stormwater
Drainage Ditch : (CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as the final follow up with analytical results for the written notification submitted on July
19, 2005. At this time, CNA Holdings, Inc. reported the release of extrusion/contact and wash waters into
the North Stormwater Outfall. This incident occurred when the temporary water transfer system was
incapable of handling the short surges of water from extrusion and the wash waters, allowing 7,200 gallons
to exit by way of the north stormwater.
Below are the results from the sample obtained during the incident. Analytical results provided by Prism
Laboratories, Inc, NC Certification No. 402.
Calculations are based on a worse -case scenario.
Discharge Volume: 7,2001 gal
Test Parameters:
pH: 7.29
Bis(2-ethylhexyl)phthalate: < 9.7 ug/1
MBAS: < 0.10 mg/I
BOD5: > 200 mg/I
TSS: 3.6 mg/I
Total Lead: < 0.0050 mg/I
Phenol: 1.5 mg/1
COD: 410 mg/l
Total Nitrogen: 0.62 mg/l
Color: water white
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo
Creek. There were no observed environmental impacts to Buffalo Creek_ Results from Prism Laboratories,
Inc. will be forthcoming.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(aD-ticona.com
Sincerely,
PEM Carter
Sr. Environmental Engineer
Celanese
Tirana
A business of Celanese AG

Certified Mail: 7004 2510 0002 9276 5107
Return Receipt to PEM Carter G
July 19, 2005 �V3'
PEMC05:25
FR
JUL 2 C 200'i
NC Department of Environment and Natural Resources a
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
i'e®na
Ticona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Re: Release of Extrusion/Contact and Wash Waters into Stormwater Drainage Ditch — 7/15105
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as the written requirement for the incident reported by telephone on July 19, 2005.
Per our telephone conversation, CNA Holdings, Inc — Ticona reported to you the release of
extrusion/contact and wash waters by way of the north stormwater outfall. It was discovered at 9:30 a.m.,
that the temporary water transfer system, had failed intermittently during the night.
The temporary system was incapable of handling the short surges of water from extrusion and the wash
waters, allowing the waters to exit by way of the north stormwater. The temporary water transfer system
was implemented, Thursday 16:30. Using this as the starting point, the ending time is when the frac tanks
were in operations, Friday 16:30. This 24-hr period produced approximately 7,200 gallons and is reported
as the release by way of the North Outfall. Between the time of discovery and the end of the release,
several contingency plans were implemented. These were voluntary unit reduction of water generation,
temporary discharge lines to another wastewater treatment drain and lastly mobilization of Frac tanks for
100% collection and containment. Although these plans reduced the amount released, the reduction is not
reflected in the amount reported. Samples of this water have been collected and submitted to a contract
lab, Prism Laboratories.
Calculations are based on a worse -case scenario.
Discharge Volume: 7,2001 gal
Test Parameters:
pH: 7.29
Bis(2-ethylhexyl)phthalate: pending
MBAS: pending
BOD5: pending
TSS: pending
Total Lead: pending
Phenol: pending
COD: pending
Total Nitrogen: pending
Color: water white
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo
Creek. There were no observed environmental impacts to Buffalo Creek. Results from Prism Laboratories,
Inc. will be forthcoming.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(a),ticona.com
Crely,
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona
A business of Celanese AG

O� W A l-� Michael F. Easley, Governor
O� RpG William G. Ross Jr., Secretary
0 7 North Carolina Department of Environment and Natural Resources
j r Alan W. Klimek, P. E., Director
—i
Division of Water Quality
January 24, 2005
Ms. PEM Carter, Environmental Engineer
CNA Holdings, Inc.
Shelby Plant
Highway 198
Shelby, NC 28152
Subject: Compliance Evaluation Inspection
CNA Holdings, Inc.
Ticona Facility WWTP
NPDES Permit No. NC0004952
Cleveland County, North Carolina
Dear Ms. Carter:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on January 19, 2005 by Ms. Donna Hood of this Office. Please
inform the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the
enclosed report.
The report should be self-explanatory; however, should you have any questions concerning this
report, please do not hesitate to contact Ms. Hood or me at [phone].
Sincerely,
- -=�- _; -.. = :... � : _. - ::. _ - � ► �Ji..o,,, � M . �nn�''� cal � . _ � , � . _ . - - � -:,
n D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
Enclosure
cc: Cleveland County Health Department
M
N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

7N
United States Environmental Protection Agency
Form Approved,
EPA Washington.
OMB No. 2040-0057
Water Qompliance 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 U 2 U 31 NCOOD4952 I11 121 05/01/19 117 18ICI 19 Li20 U
u_
Remarks
21[1111111Jill Jill 111111111111111111111111111111166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -----------Reserved--
67 L 169 70 U 71 U 72 U 73 L _j 74 751 I I I I I I 18D
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)
Ticona Facility
10:00 AM 05/01/19
04/D6/01
Exit Time/Date
Permit Expiration Date
NC Hwy 198
Shelby NC 28150
12:15 PM 05/01/19
OB/05/31
Name(s) of Onsite Representative(s)/rilles(s)/Phone and Fax Number(s)
Other Facility Data
Johnny L Ledford/ORC/704-480-4692/
Michael R. Queen/ORC/704-480-4691/
Name, Address of Responsible Official/title/Phone and Fax Number
Pem Carter,PO Box. 87 Shelby NC 28151/Env Engineer/704-480-4900/ Contacted
Yes
Section C: Areas Evaluated During inspection (Check only those areas evaluated)
® Permit ® Flow Measurement ® Operations & Maintenance ® Records/Reports
Self -Monitoring Program ® Sludge Handling Disposal ® Facility Site Review ■ Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Donna., Hood.-,.;r,;,`__- � :'1 - - _, MRO WQ//704-663-1699/704-663-6040
I 2 Ll1a
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Richard M Bridgeman 704-663-1699/704-663-6040
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

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Permit: NC0004952 Owner - Facility: CNA Holdings Inc - Ticona Facility
Inspection Date: 01/19/05 Inspection Type: Compliance Evaluation
LannoIIs
Are dikes free of burrowing animals?
Yas
❑
No
❑
NA
❑
NE
0
Are sludge levels appropriate?
❑
❑
❑
■
Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
❑
!
❑
❑
If excessive algae is present, has barley straw been used to help control the growth?
❑
❑.
0
❑
Is the lagoon surface free of weeds?
❑
❑
❑
Is the lagoon free of short circuiting?
❑
❑
❑
Comment: Ticona's polishing ponds have had some algae problems in the past that have affected effluent pH. Outfall
pH is regularly over 10 in the summer months. Ms. Carter is considering her options on pH adjustment, including the
addition of barley straw to control algae, so the pH requirement can be met when the permit dictates.
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
Is the facility using a contract lab?
Are analytical results consistent with data reported on DMRs?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Comment: When confirming the pH reading of the continuous recorder against a calibrated meter please record all
necessary information.
Is flow meter used for reporting?
Is flow meter calibrated annually?
Is flow meter operating properly?
(If units are separated) Does the chart recorder match the flow meter?
Comment:
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 consistent with data reported on DMRs?
Are sampling and analysis data adequate and include:
Dates, times and location of sampling
Name of individual performing the sampling
Results -of analysis and calibraflon .
Dates of analysis
Name of person performing analyses
Transported COCs
Plant records are adequate, available and include
O&M Manual
As built Engineering drawings
Schedules and dates of equipment maintenance and repairs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
Yes No NA NF
®❑❑❑
® ❑ ❑ ❑
® O ❑ ❑
O ❑ ■ O
Yes_ No
® ❑
NA
❑
NF
❑
❑
❑
❑
■ ❑
O
❑
® ❑
❑
❑
0000
❑' .
® ❑
❑
❑
0000
0000
❑ ❑
E
❑

Permit: NC0004952 Owner - Facility: CNA Holdings Inc - Ticona Facility
Inspection Date: 01/19/05 Inspection Type: Compliance Evaluation
Is the ORC visitation log available and current?
® ❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
M ❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
® ❑
❑
❑
Is a copy of the current NPDES permit available on site?
® ❑ 1
❑
❑
Is the facility description verified as contained in the NPDES permit?
® ❑
❑
❑
Does the facility analyze process control parameters, for example: MLSS, MCRT, Settleable Solids, DO, Sludge
® ❑
❑
❑
Judge, pH, and others that are applicable?
Facility has copy of previous year's Annual Report on file for review?
❑
❑
N
❑
Comment: The inspection of the continuous chart recorder for pH showed the instrument misreading. Time was off by
a few hours and pH was off by .3 as compared against the digital read out. Because the chart is submitted for
compliance when necessary, the recorder should be serviced to correct any problems.
Aeroh'tc Digester
Yes
No
NA
NP
Is the capacity adequate?
®
❑
❑
❑
Is the mixing adequate?
®
❑
❑
❑
Is the site free of excessive foaming in the tank?
0
❑
❑
❑
Is the odor acceptable?
®
❑
❑
❑
Comment:

OEPT. OF RESOURCES ENVIRON
' '
Certified Mail: 7004 2510 0002 9276 5091 D NAT [ R,g-4L • �~° }c�L OFFItu
Return Receipt to PEM Carter 000RESV "'h �"
July 18, 2005
t
PEMC0524: S f JUL 1 9 200"
NC Department of Environment and Natural Resources
Division of Water Quality 'w
610 East Center Avenue — Suite 301 WATER
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Release of Process Waters into Stormwater Drainage Ditch — 6/8/05
(CNA Holdings, -Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
Ikons
ilieona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
This report serves as a followup with analytical results for the incident reported by telephone on June 8, 2005
and an initial written notification on June 13; 2005 where CNA Holdings, Inc — Ticona reported to you the release
of process water by way of the north stormwater outfall due to the failure of the Solid State scrubber not closing
in conjunction with pump failure. This resulted in the overfilling of the tank and exceedance of its secondary
containment. Calculations indicate approximately 6,000 gallons of process water were released. A sample of
this water was analyzed by the contract lab, Prism Laboratories, Inc. (New data in RED.)
6/8/05 North Outfall Discharge Due to SSP Scrubber & Pump Failure
Discharge Volume:
6000 gallons
MBAS: 0.45 mg/L
(see note below)
Phenol: *BRL
Total Nitrogen: 1.1 mg/L
(TKN)
TSS: 98 mg/L
Total Lead:
0.011 m /L
Bis(2-ethylhexy- phthalate:
BRL
Test Parameters:
COD: BRL
BOD5: 14 mg/L
pH: 7.4
Odor: none
I Foam: none
Color: water white
Clarity: clear
10il sheen: none
IFloating Solids: no
Legend:
BRL — Below Reporting Limits
NOTE: Analysis Note for MBS: Analysis performed outside of hold time. Sample taken at 15:20 6/8/05, analyzed 16:30 6/10/05.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(a-).ticona.com
Sincerely,
PEM Carter
Sr. Environmental Engineer
Celanese
Ticona
A business of Celanese AG

rpppp
u
Certified Mail: 7004 2510 0002 9276 5459d AND g�jiti,�A�bRESO�� 1
1�
Return Receipt to PEM Carter
CFF
R��r4` °r«�='�(
August 19, 2005Ali
G On 20
PEMC05:35
v ;;
NC Department of Environment and Natural Resources
Division of Water Quality
610 East Center Avenue — Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Release of Cooling Water into East Stormwater Drainage Ditch — 8/17/05
(CNA Holdings, Inc., Ticona Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
1ICOna
Ticona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
This report serves as the written notification requirement for the incident reported by telephone on August 18,
2005. Per our telephone conversation, CNA Holdings, Inc — Ticona reported to you the discovery of waters
weeping from a graveled/soil roadbed. At the time of the phone notification, it was unknown as to the origin of
this water, but it was released at the East Outfall at the rate of 0.4 GPM. Efforts to retain these waters were
implemented immediately. Closure.of.the contingency gated valve, has reduced and maintained the release at
570 gallons/day.
A team is actively developing an isolation plan, allowing for a cautious but safe repair to the cooling water supply
and/or return line. Implementation of the isolation plan will begin next week, August 22, 2005. Pressure on
these lines will be reduced to < 10 PSI; careful excavation, preventing catastrophic failure, will expose the area
for repair, and a temporary fix will be implemented to stop further release. This area will remain open and
protected for a permanent repair in the fall. A permanent repair will require a full plant shut down with the
cooperation of all site residents (ie: Invista ). Notification will be made once the release has ceased
Although efforts have been put in place to reduce and minimize the release until repairs are made, it is
anticipated that releases will continue through August 26, 2005 at the rate of 570 gallons/day. If catastrophic
failure occurs, then an additional notification will be made to your attention. At present, a sample of this water
has been collected and submitted to a contract lab, Prism Laboratories.
Discharge Volume: 1 570 gal
I Period: 8/17-8/18, 2005
Test Parameters:
pH: 7.5
Bis(2-ethylhexyl)phthaIate: pending
MBAS: pending
BOD5: pending
TSS: pending
Total Lead: pending
Phenol: pending
COD: <50 mg/I
Total Nitrogen: pending
Color: water white
Floating Solids: none
Odor: none
Clarity: clear
Oil sheen: none
Foam: none
An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo
Creek. There were no observed environmental impacts to Buffalo Creek. Results from Prism Laboratories,
Inc. will be forthcoming.
Celanese
Ticona
A business of Celanese AG

0
This is the same water, which was characterized and requested for approval in the permit renewal
package submitted January 2005.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at [e-mail]
rely,
PEM Carter
Sr. Environmental Engineer

il�. �Sa'��i"•OO..i�ti—k,"..-.. �f:a6nc,::3t�Ixq 3.
PV FAX to Attn: Samar Bou-ghazale
704-663-6040
' ' C ®n a
Certified Mail: 7004 2510 0002 9276 5398
Return Receipt to PEM Carter
��� :> 2005 _
N
June 13, 2005"
"
'I,
av .
Ticona
PEMC05:22
��' � ° nla �
%''`��
Shelby Plant
NC Department of Environment and Natural
Resources
Highway 198
Shelby, NC 28152
Division of Water Quality
Telephone [phone]
610 East Center Ave. Suite 301
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Release of Process Waters into Stormwater Drainage Ditch — 618/05
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ahazale:
This report serves as the written requirement for the incident reported by telephone on June 8, 2005.
Per our telephone conversation, see attached Record of Agency Contact, CNA Holdings, Inc — Ticona
reported to you of the process waters which supplies the Solid State scrubber did not close as expected
and the pump failed, allowing these waters to fill the tank and exceed the containment with approximately
6000 gallons. Efforts to recover these waters were implemented but unsuccessful due to the rain/storm
event. The release of waters began at 3:10 p.m. and ended 3:35 p.m. Samples of this water have been
collected and submitted to a contract lab, Prism Laboratories, Inc. These results will be forthcoming.
An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo
Creek. There were no observed environmental impacts to Buffalo Creek.
Discharge
Volume:
6,000
gal
Pending Analysis
MBAS
Phenol
COD
Bis(2ethylhexyl)phthalate
TSS
Total Lead
BOD5
Total Nitrogen
Test Parameters:
pH: 7.5
Odor: none
Foam: none
Color: water white
Clarity: clear
Oil sheen: none
Floating Solids: no
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(abticona.com
Sincerely,
C
PEM Carter
Sr. Environmental Engineer
Attachment: Ticona Record of Contact
Celanese
Ticona
A business of Celanese AG

SHEI,BY, NC.P.I.ANT Ym.
RECORD OF AGENCY CONTACT
AGENT & TITLE: COMPANY PERSONNEL CONTACTED & TITLE
Samar Bou-ghazale PEM Carter — Sr. Env. Engineer
Inspector - DWQ Ticona - Shelby
AGENCY/PHONE/FAX DATE OF CONTACT: TIME OF CONTACT:
NCDENR: Division of Water Quality 6/8/05 4:49 P.M.
Mooresville, NC
704-663-1699
CONTACT INITIATED BY: TYPE OF CONTACT BY AGENT:
X TICO;`-TA Company Representative X Telephone
Regulatory Agency _ Agency Visit to Site
Other interested external party _ Company Visit to Agency
_Other Interested Party Visit to Site
Fax E-mail
Letter
REGULATORY PURPOSE OF CONTACT:
( ) upset notification:
( ) maintenance notification:
(X) release / excursion notification:
( ) perinit work:
( ) agency inspection:
EXTERNAL PARTY PURPOSE OF CONTACT:
( ) complaint
( ) request for EHS information
( ) public policy issue
( ) Other
( ) other: 24 hr. Notification to Mooresville, per Stormwater Permit No. NCS 000064 on
6108!05, discovered at 3:10 p.m. — Solid State scrubber waters which had entered into the North
Stormwater system were released at the outWl. Efforts to recover these waters were
implemented but unsuccessful due to a rain/storm event, causing these waters to leave the site.
The incident occurred due to pump failure, allowing scrubber waters to overfill tank and
containment. Waters overflowed the containment to North stonnwater outfall. The incident was
over approximately 3:35 p.m. Quantity is unknown at this time but will be reported along with
analytical results. Outfall pH 7.5. Sampling of questionable waters per NCS000064 has been
initiated and submitted to contractor lab, Prism Laboratories.
Comments: Centralized ESHA Files cc: E. McKinley, R. Jolley, H. McCord, M..Allen
Required Followed up: (X) YES () NO Additional notes: 5 day written report due 6/13/05
7o�-GG3'Go�v
TICONA - SIIELBY
P. O. BON 87, HIGHWAY 198
S1-.itiLt3Y, NC 28151
REV. 2
10/02

PV
** TX;CONFIRMATION REPORT** AS OF JUN 13,.'05'16 53 PAGE.01.
CELANESE'-SHELBY
DRTE, TIME TO/FROM MODE MIN/SEC PGS CMD# STATUS
27 0613 16:52 817046636040 G3--S 00'48" 002 180 OK
5
r FAX to Attn:"Samar Bou.ghazale
704 663-6040 ' icon a
Certified'Mail; 7004 2510 0002 9276 5398
Return Receipt to'PEM Carter
June 13, 2005
Ticona
PEMC05:22
Shelby Plant
NC Department of Environment and Natural Resources Flighway 198
Shelby, NC 28152
Division of Water Quality Tel• -phone (704 ' 480-47oo
919 North Main Street
Mooresville, NC 28115
Attn- Mr. Samar Bou-ghazale
Re: Release of Process Waters into Stormwater Drain"e Ditch — 618105
(CNA Holdings, Inc.. Shelby Plant', Storinwater Permit No: NCS0000641
Dear Mr. Bou-ghazale:
This report serves as the written requirement for the incident reported by telephone on June 8, 2005.
Per our telephone conversation, see attached Record 'of Agency. Contact, CNA Holdings, Inc — Ticona
reported to you'of the process waters which supplies the Solid State scrubber did not close as expected
and the pump failed, allowing these waters to fill the tank and exceed the containment with approximately
6000 gallons. Efforts to recover these waters were implemented but unsuccessful due to the rain/storm
event. The release of waters began at 3:10 p.m. and ended 3:35 p.m:.Samples of this water have been
collected and submitted to a contract lab, Prism Laboratories. Inc. These results will be forthcoming.
An examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo
Creek. There were,no observed environmental impacts to Buffalo Creek.
Discharge,V,olume:_..
61000
gal
Pending Anblysis
'' ° MBAS
` Phenol
COD "`'`
Bis(2ettiylhexyl)phthalate'`
TSS
Total Lead
BOD5
Total Nitrogen
Test Parameters:
_
pH: 7.5
Odor: none
Foam: none
Color. water white
Clarity: clear
Oil sheen: none
Floating Solids: no
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this �l
notification letter, feel free to call me at 704/480-4900, or via email at pem.carteroc ticona.com tip
Sincerely,
ft-
PEM Carter
Sr. Environmental Engineer
Attachment: Ticona Record of Contact
Celanese{y1�yJ

y ,J
Pem Carter
CNA Holdings Inc.
P.O. Box 87
Shelby, NC 28151
April 6, 2005
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Ticona Facility
Permit Number: NC0004952
Case Number: LV-2004-0587
Cleveland County
Dear Pem Carter:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
This letter is to acknowledge receipt of check number 2000023921 in the amount of $335.04 received from you
dated March 23, 2005. This payment satisfies in full the above civil assessment levied against the subject
facility, and this case has been closed. Payment of this penalty in no way precludes future action by this
Division for additional violations of the applicable Statutes, Regulations, or Permits.
If you have any questions, please call Robert L. Sledge at 919-733-5083 Ext.547.
Sincerely,
Cole+Sullins
cc: Enforcement File #: LV-2004-0587
c DW M6-6re sville-Regional Office Supervisor
Central Files
`; `
No e� 4Camlinatura!!y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
Phone [phone]
Customer Service
Internet: h2o.emstate.nc.us 512 N. Salisbury St Raleigh, NC 27604
FAX [phone]
1-877-623-6748

Ce ' a n e w 1601 DALTLAS, TXL75234EEWAY
PLYMERS INC.
62-20
311
PAY -TO THE NCDENR-DIV OF WATER QUALITY
ORDER OF, 1617 MAIL SERVICE CTR
Three Hundred Thirty Five and 04f100 Dollars
NCDENR-DIV OF WATER QUALITY
CNA HOLDINGS, INC,-T1lomA �►QZJES ►a0000'i952.
CITIBANK DELAWARE,,_AA\SUBSIDIARY OF CITICORP
ONE PENN'S WAY, NEW CASTLE, DE 19720
20000 239 2 1110 1:0 3 1 100 20.911: 38 5 7 5 5041.1'
No.2000023921
03/23/2005
AMOUNT IN US DOLLARS
'P$$$$$$$$$$�V@@$
NOT VALID AFTER 1 YEAR
AUTHORIZED SIGNATURE
�7 IZE SI RE

40
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
MAR 0 9 2005
CERTIFIED MAIL 7003 0500 0002 6814 3953
RETURN RECEIPT REQUESTED
Ms. Pem Carter
CNA Holdings Inc.
P. O. Box 87
Shelby, NC 28151
Dear Ms. Carter:
William G. Ross, Jr., Secretary
Alan W. KliAdkCRIT. Direct011R0,'VU
M;�,l� y � . � �5�0RCEO
q OFFIc1
NAR 1 C 200.1
WATER 3n�
Subject: Remission Request of Civil Penalty Assessment
NPDES Permit Number NC0004952
CNA Holdings Inc.-Ticona Facility
Cleveland County
Case Number LV-2004-0587
I have considered the information submitted in support of your request for remission in
accordance with G.S. 143-215.6A(f) and have decided to modify the initial civil penalty
assessment of $835.04 to the total amount of $335.04.
If you choose to pay the modified penalty, send payment to me at the letterhead address within
thirty (30) days of receipt of this letter. Please make your check payable to the Department of
Environment and Natural Resources (DENR).
If payment is not received within thirty (30) days of receipt of this letter, in accordance with
N.C.G.S. § 143-215.6A(f), your request for remission of the civil penalty (with supporting
documents) and my recommendation to deny the request (with supporting documentation) will
be delivered to the North Carolina Environmental Management Commission's (EMC)
Committee On Civil Penalty Remissions (Committee) for final agency decision.
If you desire to make an oral presentation to the Committee on why your request for remission
meets one or more of the five statutory factors you were asked to address, you must complete
and return the attached form within thirty (30) days of receipt of this letter. Please mail the
completed form to the attention of Bob Sledge at the following address:
Point Source Branch
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
512 N. Salisbury St., Raleigh, North Carolina 27604 NorthCarolina
Phone: [phone] / FAX [phone] / Internet:: h2o.enr.state.nc.us o
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper Aaturally

Ms. Pem Carter
LV-2004-0587
p.2
Your request for an oral presentation and the documents in this matter will be reviewed by the
EMC Chairman and, if it is determined that there is a compelling reason to require an oral
presentation from you, you will be notified by certified mail of the date, time, and place that your
oral presentation can be made. Otherwise, the final decision on your request for remission will
be made by the Committee based on the written record.
Thank you for your cooperation in this matter. If you have any questions about this letter, please
contact Bob Sledge at [phone], extension 547.
Sincerely,
&"' m `
Alan W. Klimek, P.E.
attachment
cc: ooresille_Regi.onall _Offce
Enforcement file
Central Files

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor VI`
Ms. PEM Carter
CNA Holdings, Inc.
Highway 198
Shelby, NC 28152
Dear Ms. Carter:
January 5, 2005
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
G9� 0Er-T. 0r_ E",,r, `RC:1I9�' G- ,'Tr
b'a1InO
ice
Subject: Remission Request of Civil Penalty Assessment
CNA Holdings, Inc. — Ticona/Shelby Plant vi
NPDES Permit NC0004952
Cleveland County
Case Number LV-2004-0587
JAB! 0 E. 21`� 15
This letter is to acknowledge your request for remission of the civil penalties levied against the
subject entity. Your request will be placed on the agenda of the Director's next scheduled
enforcement conference and you will be notified of the result.
Also received with your remission request was your check number 2000016915 in the amount of
$835.04. This check will be held pending the outcome of the appeal process.
If you have any questions about this matter, please contact me at [phone], extension 547.
Sincerely,
Bob Sledge, Environmental Specialist
Point Source Branch
cc: N�looresville Regional -Office -w/attachments -
Enforcement File w/originals
Central Files w/attachments
Enforcement File w/3 attachments
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
512 N. Salisbury St., Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Internet:: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
NorthCarohna
Naturallff

Y
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF Cleveland
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING
AND STIPULATION OF FACTS
CNA Holdings, Inc. )
PERMIT NO. NC0004952 ) FILE NO. LV-2004-0587
Having been assessed civil penalties totaling $835.04 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated December 2.2004, 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 30 days of receipt of the notice of assessment. No new evidence in support of a remission
request will be allowed after 30 days from the receipt of the notice of assessment.
This the 29 day of _11e ee-m bey p �_
BY
ADDRESS
TELEPHONE
%J'�- 4u-'(.14

-14
JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: LV-2004-0587
Assessed Party: CNA Holdings, Inc.
Permit No. (if applicable): NC0004952 (Ticona Facility WWTP)
County: Cleveland
Amount Assessed: $835.04
Please.use this form when requesting remission of this civil penalty. You must also complete the
"Waiver of Right to an Administrative Hearin and nd 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 inN.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:
doe., a.lf ahcd-

CERTIFIED MAIL 7001 1940 0000 2032 0908
Return Request to PEM Carter
December 29, 2004
PEMC04:44
Point source Branch
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Ticorra
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Re: Request for Remission for Notice of Violation and assessment of civil Penalty for
Violation of NC General Statute 143.215.1(a)(6) for CNA Holdings, Inc. (NPDES
Permit NC0004952)
Earlier this month, CNA Holdings, Inc. — Shelby Facility received a Notice -of -Violation letter from
Mr. D. Rex Gleason, Surface Water Protection Regional Supervisor for the Mooresville Regional
Office of the Water Quality Division. This letter transmitted a NOV and an assessment of a
proposed civil penalty in the amount of $835.04 against CNA. Per the letter, CNA is submitting
this written request for remission/mitigation of this proposed penalty.
On behalf of CNA Holdings, Inc. the following is enclosed:
1. Waiver of Right to an Administrative Hearing and Stipulation of Facts form.
2. Justification for Remission Request form.
3. Check
CNA Holding Inc — Shelby Facility is committed to ensuring compliance with all County, State, and
Federal regulations. Should there be a need for further discussion pertaining to this information or on
the attached forms, feel free to call me at 704/480-4900, or via email at pem.carter(cDticona.com.
With Kind Regards,
PEM Carter
Sr. Environmental Engineer
Attachments
Celanese
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Explanation:
CNA Holding, Inc.—Ticona Plant 'icon®
Permit No. NC0004952 Shelby Plant
File No. LV-2004-0587 Highway 198
Shelby, NC 28152
Telephone [phone]
( c ) The violation was inadvertent or a result of an accident:
As you are aware, the month of September posed many challenges for wastewater treatment
throughout the state and we were no exception. As reference in PEMC04:37 letter, unavoidable
rain events from Hurricane Frances, Ivan and Jeanne brought significant volumes of water
increasing flow, impacting clarifier performance, causing turbidity in the existing polishing ponds, and
causing the tertiary filtration system to foul. During these rain events, all efforts to minimize the
impact of this act of Nature by containing and controlling the waters were implemented by utilizing:
• the emergency EQ tank having 500,000 gallon capacity,
• "freeboard" capacity associated with the three (3) polishing ponds, and
• "freeboard" capacity of the three (3) equalization basins
Unfortunately the turbidity, from such rain events, entering into the tertiary filtration system exceeded
the engineered design thus allowing elevated total suspended solids to leave the filter in excess of
the daily permit. CNA Holding, Inc. — Shelby Facility had utilized all "freeboard" capacity and could
not cease discharging without jeopardizing the integrity of the polishing ponds which could have
resulted in failure.
Celanese
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Certified Mail 7001 1940 0000 2032 0861
Return to PEM Carter
PEMC04:37
October 29, 2004
NCDENR
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ATTN: Central Files
Ticona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Reference: Notes Concerning September, 2004 DMR for CNA Holdings Inc Shelby
Plant Permit No. NC 0004952
To Whom It May Concern:
In accordance with the facility's NPDES Permit, duplicate copies of the signed DMR report has been
submitted.
As you are aware, the month of September posed many challenges for wastewater treatment throughout
the state and we were no exception. Rain events from Hurricane Frances, Ivan and Jeanne brought
significant volumes of water increasing Flow, impacting clarifier performance, causing turbidity in the existing
polishing ponds, and causing the tertiary filtration system to foul. On September 10, 2004, the Total
Suspended Solids Daily maximum effluent limitation was exceeded by 32.8 lb/day, with the daily total of
360.8 Ibs/day. Due to this exceedance, the monthly maximum effluent limitation was exceeded by 25
lb/day, with the monthly average of 139 Ibs/day. Both of these exceedances were reported to NC DENR:
Mooresville Regional Office.
During the present month, routine maintenance in the replacement of new filtration media for the tertiary
filtration system was completed and other operational aspects of the filter system are under review. We
anticipate this review to be completed by the end of November, which will improve their performance and
will ensure compliance with our permit discharge limits.
In addition to these, the following note applies to the attached DMR:
1. On 9/2/04, 9/3/04, and 9/29/04: BODS results needs to be qualified due to the seed correction
value were outside the method defined acceptance criteria. All other quality assurance measures
were within acceptable ranges. Prism Laboratories of Charlotte, NC, continues to perform thp. GODS
analysis, as our contract laboratory.
CNA Holding Inc — Shelby Facility is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information on these forms, feel
free to call me at 704/480-4900, or via email at pem.carter(a)ticona.com.
rely,
PEM Carter
Sr. Environmental Engineer
Attachments
� Celanese
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A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
December 2, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. John Groves, Plant Manager
CNA Holdings, Inc.
NC Highway 198
Shelby, NC 28152
Dear Mr. Groves:
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
7003 2260 00013551 7718
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215. 1 (a)(6) and NPDES Permit No. NC0004952
CNA Holdings, Inc. — Ticona Facility WWTP
Case No. LV-2004-0587
Cleveland County
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$835.04 ($750.00 civil penalty + $85.04 enforcement costs) against CNA Holdings, Inc.
This assessment is based upon the following facts: A review has been conducted of the
discharge monitoring report (DMR) submitted by CNA Holdings, Inc. for the month of
September 2004. This review has shown the subject facility to be in violation of the discharge
limitations found in NPDES Permit No. NC0004952. The violations are summarized in
Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that CNA Holdings, Inc.
violated the tenors; eonditions'or regniremenfs of NPDES Permit No: NCO004952 and North
Carolina. General Statute (G.S.) 143-215.1(a)(6) in the manner and extent shown in Attachment
A. A civil penalty may be assessed in accordance with the maximums established by G.S. 143-
215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural Resources and
the Director of the Division of Water Quality, I, D. Rex Gleason, Surface Water Protection
Regional Supervisor for the Mooresville Region, hereby make the following civil penalty
assessment against CNA Holdings, Inc.:
Mooresville Regional Office One
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 Nol iCarolllla
Phone: [phone] / Fax: [phone] Internet: h2o.enr.state.nc.us )UMMIlff
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

$ 750.00 For 1 of the one (1) violation of G.S. 143-
215. 1 (a)(6) and NPDES Permit No. NC0004952, by
discharging waste into the waters of the State in
violation of the permit monthly average effluent limit
for Total Suspended Solids.
$ 0 For 0 of the one (1) violation of G.S. 143-
215. 1 (a)(6) and NPDES Permit No. NC0004952, by
discharging waste into the waters of the State in
violation of the permit daily maximum effluent limit
for Total Suspended Solids.
$ 750.00
$ 85.04
$ 835.04
TOTAL CIVIL PENALTY
Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(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 violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Mana-aement Commission has re-aulatory authority:
and -
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty will
not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:

Point Source Branch
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
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 fisted below as they may ielate to the reasonableness of the amount of the
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 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 reauest will be annroved. the followin_a factors
shall be considered:
(1) whether one or more of the civil penalty assessment factors in G.S. 143B-
- 282.1(b) were wrongfully applied to the detriment of the petitioner,
(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 had 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 information presented in sup ort of your request for remission
P.
must be submitted in wasting ..The Duector'oftheDnnsion 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 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:
Point Source Branch
Division of Water Quality
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 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
L11V vua:c vt riLunnUbUtXLivc izvaitiigs wjmun.uve (5) business (lays tohowmg the
mkvu transmission. ine mailing address for the Office of Administrative Hearings
is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
Telephone [phone] Facsimile [phone]
A copy of the petition must also be served on DENR as follows:
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
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 the violations are of a continuing nature, not related to
operation and/or maintenance problems, and you anticipate remedial construction activities, then
you may wish to consider applying for a Special Order by Consent. If you have any questions
about this civil penalty assessment or a Special Order by Consent, please contact the Surface
Water Protection Section staff of the Mooresville Regional Office at 704/663-1699.
(Date) D. Rex eason, P.E.
Surface Water Protection Regional Supervisor
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Surface Water Protection Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments

Attachment A
'CNA Holdings, Inc.
Ticona Facility
NPDES Permit No. NC0004952
Case Number LV-2004-0587
Limit Violations, September 2004
Monthly Average Limit Violations
Parameter Reported Value Limit
Total Suspended Solids 139.0 * 114.0
Parameter
Total Suspended Solids
Daily Maximum Limit Violations
Reported Value Limit
360.8 328.0
* denotes assessment of civil penalty.
Units
lbs/day
Units
lbs/day

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF Cleveland
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING
AND STIPULATION OF FACTS
CNA Holdings, Inc. )
PERMIT NO. NC0004952 ) FILE NO. LV-2004-0587
Having been assessed civil penalties totaling $835.04 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated December 2.2004, 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 30 days of receipt of the notice of assessment. No new evidence in support of a remission
request will be allowed after 30 days from the receipt of the notice of assessment.
This the
day of
ADDRESS
TELEPHONE

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number. LV-2004-0587
Assessed Party: CNA Holdings, Inc.
Permit No. (if applicable): NC0004952 (Ticona Facility WWTP)
County: Cleveland
Amount Assessed: $835.04
Please .use this form when requesting remission of this civil penalty. You must also complete the
"Waiver of Right to an Administrative Hearing and Stipulation of Facts" form to request
remission of this civil penalty. You should attach any documents that you believe support your
request and are necessary for the Director to consider in evaluating your request for remission.
Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred
or the accuracy of any of the factual statements contained in the civil penalty assessment
document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted
only when one or more of the following five factors applies. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting
documents, as to why the factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-2821�b)
were wron fg_ully 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);
. .. 4 _..-_. � ... J.� ';:.: • '> `fit
=:(d) the violator had not`been'"asse`ssed crvr� penalties for any Pievrous violations•=
(e) payment of the civil penalty will prevent payment for the remaiming necessary
remedial actions (I.e., explain how payment of the civil penalty will prevent you from
per the activities necessary to achieve compliance).
EXPLANATION•

Y•.
-DV
EFFLUENT
;RMIT NC NC 0004952 Discharor
Ne 001
Monu, September
,• 2004
�! N4ME! CNA Holdinas.lnc.
Class 1\' ;.:•.
Clcvelnnd
70R Ifs' P,ESPONSI6LE CHARGE (ORC)
Johnny L. Ledford
Grad, I\'
LABORATORIES 1) CNA Holdings.lnc . - Shelh\' Plant
(2) Prism Lalloratories,tnc
/IFIED
FC>% lF ORC HAS CHANGED
Persons) Collecting Samples:
Johnny Ledford , Mike Blanton. h41e(, Queen, MICtlao' Spark:,
rr: .
ail ORIGINAL and ONE COPYto:
✓' _
x
I
>TT: CENTRAL FILES
:)Ivision of Water Quality
/ /
(SI . 1 lure of operator in resp .ible charge)
pc,u'
1617 Mail Service Center
V
By this signature. I certify that this• report is
�\aleioh• North Carolina 27699-1617
accurate
and complete to the best of my knowledge
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1 PASS 1 10- 1
PASS 172 I < I 1
PASS 1 6 < i G
I C I C I
j Ave. aee
Maximum
1 0.7550
MinimumC
1 0.1700
Como.('-) Grab(G)
I
-
C
Ivionthly Limli 1 .800 j
I 60 o 0
I 6E C 1 1' 14 0 I 200
DV,K!. Form kIP-1 (OWOD)

Facility Status: (Please check one of the following)
Compliant
All monitoring data and sampling frequencies meet permit requirements [J
Noncompliance
All monitoring data and sampling frequencies do NOT meet permit requirements
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
SEE ATTACHED SHEETS
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
John Groves
Permitt(PI se print e)�
UrL---
Signare of Permittee ` Da
(Req ire )
CNA Holdings Inc.,Hwy 198,Shelby,NC 28152 704-480-4692 8:'31,'2008
Permittee Address Phone Number Permit Exp. Date
00010 Temperature
00076 Turbidity
00080 Color(Pt-Co)
00082 Color(ADMI)
00095 Conductivity
00300 Dissolved Oxgyen
00310 BOD5
00340 COD
00400 pH
00530 Total Suspended
Residue
00545 Settleable Matter
00556 Oil & Grease
00600 Total Nitrogen
00610 Ammonia Nitrogen
00625 Total Kjeldhal
Nitrogen
00630 Nitrates/Nitrites
00665 Total Phosphorus
00720 Cyanide
00745 Total Sulfide
00927 Total Magnesium
00929 Total Sodium
00940 Total Chloride
Parameter Codes
00951 Total Fluoride
01067 Nickel
50050 Total
01002 Total Arsenic
01077 Silver
Residual
01092 Zinc
Chlorine
01027 Cadmium
01105 Aluminum
01032 Hexavalent Chromium
01147 Total Selenium
71880 Formaldehvde
01034 Chromium
31616 Fecal Coliform
71900 Mercury
32730 Total Phenolics
81551 Xv_ lene
01037 Total Cobalt
34235 Benzene
01042 Copper
34481 Toluene
01045 Iron
38260 MBAS
01051 Lead
39516 PCBs
01062 Molybdenum
50050 Flow
Parameter Code assistance may obtained by calling the Point Source Compliance/Enforcement Unit at [phone] or by visiting
the Water Quality Section's web site at h2o.enr.state.nc.us/was and linking to the Unit's information pages.
Use only units designated in the reporting facility's permit for reporting data.
ORC must visit facility and document visitation of facility as required per 15A NCAC 8G.0204.
" If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B_0506 (b) (2) (D)

Certified Mail 7001 1940 0000 2032 0861
Return to PEM Carter
PEMC04:37
October 29, 2004
NCDENR
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ATTN: Central Files
9-/
1icon
vrcfj- . ":, , %-
P..
01 'ICE Tecon®
Shclby Plant
Highway 198
NOV 2 2��� Shclby. NC 28152
Tcicphane (70A) 480-4700
Reference: Notes Concerning September, 2004 DMR for CNA Holdings, Inc., Shelby
Plant Permit No. NC 0004952
To Whom It May Concern:
In accordance with the facility's NPDES Permit, duplicate copies of the signed DMR report has been
submitted.
As you are aware, the month of September posed many challenges for wastewater treatment throughout
the state and we were no exception. Rain events from Hurricane Frances, Ivan and Jeanne brought
significant volumes of water increasing flow, impacting clarifier performance, causing turbidity in the existing
polishing ponds, and causing the tertiary filtration system to foul. On September 10, 2004, the Total
Suspended Solids Daily maximum effluent limitation was exceeded by 32.8 lb/day, with the daily total of
360.8 Ibs/day. Due to this exceedance, the Monthly maximum effluent limitation .was exceeded by 25
lb/day, with the monthly average of 139 Ibs/day. Both of these exceedances were reported to NC DENR:
Mooresville Regional Office.
During the present month, routine maintenance in the replacement of new filtration media for the tertiary
filtration system was completed and other operational aspects of the filter system are under review. We
anticipate this review to be completed by the end of November, which will improve their performance and
will ensure compliance with our permit discharge limits.
In addition to these, the following note applies to the attached DMR:
1 On 9/2/04, 9/3/04, and 9/29/04 BODS results needs to be qualified due to the seed correction
value- were outside the methoddefined acceptance -criteria.: All other quality assurance "measures
were within acceptable ranges. Prism Laboratories of Charlotte, NC, continues to perform the BOD-5
analysis, as our contract laboratory.
CNA Holding Inc — Shelby Facility is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information on these forms, feel
free to call me at 704/480-4900, or via email at [e-mail].
PEM Carter
Sr. Environmental Engineer
Attachments
Celanese
6-...._.. n:-un_sc AG

P�.J-t��lt Ncaoo-�9s2
PPI -Section A
1. EFFLUENT LIMITATIONS AND MONITORING REgUIREMENTS
Beginning on the effective date of this permit and lasting through April 30. 2006. the Pcrmittee is auUtorized to
discharge from OutfaU 001. Such discharges shall be limited and monitored by the Permitlee as specified below:
PARAMETER
EFFLUENT LIMITATIONS
MONITORING REgUIREMENTS
Monthly
Averse
Daily
Maximum
Measurement
Frequency
Sample
a
Sample
Location[
Flow (MGD)
0.8
Continuous
Recording
Effluent
BOD, 5-day, 20"C
68.0 lbs/day
164.0 lbs/day
Daily
Composite
Effluent
Total Suspended Solids
114.0 lbs/day
328.0 lbs/day
Daily
Composite
Effluent
Fecal Coliform (Geometric Mean)
200 / 100 nil
400 / 100 ml
Weekl3,
Grab
Effluent
Oil and Grease
Quarterly
Grab
Effluent
Total Copper
Alontlily
Composite
Effluent
Total Nitrogen (NO2+NO3+TKN)
Semi Annually
Composite
Effluent
Total Phosphorus
Semi -.Annually
Composite
( Effluent
Chronic Toxicit}''
Quarterly'
Composite
I Effluent
Pollutant Analysis
See Note 3
Composite Effluent
pHs
Between 6.0 and 9.0 Standard Units
Daily
Grab I Effluent
40 CFR 414 Subpart I Monitoring
See Part 1, Secrion .A, Number 3 of this permit.
Notes:
1 Effluent is defined as final effluent from the polishing ponds.
2 Chronic Toxicity (Ceriodaphnia) P/F ® 5.8%; March, June, September, December; see Part 1, Section A,
Number 4 of this permit.
3 The priority pollutant analysis shall be conducted during the month prior to submittal of the permit renewal
application. See Part I, Section A. Number 5 of this permit.
4 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored
daily at the effluent by grab sample. The effluent pH of the wastewater is defined and limited at a point
between the final clarifiers and final polishing pond, such a point being after the combination of all potential
influents to the polishing pond. If the pH of the effluent from the polishing pond exceeds 9.0, there will be no
effluent violation if the wastewater from the final clarifier has not exceeded 9.0 during the thirty (30) days
preceding the measurements of the pH above 9.0 at the effluent from the polishing pond. The pH of the
wastewater from the clarifiers and the pH of the effluent from the polishing ponds (final discharge) will be
monitored by continuous recorder: Upstream and downstream monitoring shall be conducted weekly in any
week the pH of the effluent from the polishing pond is outside the 6.0 — 9.0 range.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER TrLAN TRACE
AMOUNTS.

Certified Mail 7002 0860 0006 3968 0612
Return Receipt to PEM Carter
PEMC: 03:46
November 8, 2003
E01P
L_ ,003
pp AND,°L�..,p:=_SOURCES`;
North Carolina Department of Environment and
Natural Resources
Mooresville Regional Office — Division of Water Quality
919 North Main Street
Mooresville, North Carolina 28115
ATTN; Mr. Richard M. Bridgeman
iic®na
icona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Re: Response to Laboratory Compliance Inspection of the CNA Holdings, Inc. —
Ticona Plant, NPDES Permit No. NC0004952
Dear Mr. Bridgeman
This memorandum summarizes the written responses concerning comments identified in the
WWTP Laboratory Compliance Evaluation Inspection, which occurred at the CNA Holdings, Inc —
Ticona Plant on October 16, 2003, conducted by Mr. Chester Whiting and Mr. Wes Bell. As per
the cover letter accompanying the report, a written item. description has been prepared for each
deficiency noted in sections Facility Site Review/Operations & Maintenance, Laboratory and the
Self -Monitoring Section of the report.
Vegetation observed within the concrete basin (liner) of the aeration basins.
Permit requires that the facility be properly operated and maintained at all times.
Response: Unwanted vegetation surrounding all WWTP components, (aeration basins, grit
chamber, equalization basins, clarifiers, polishing ponds, sludge ponds), will be maintained to
ensure integrity is not jeopardized. These WWTP components have been placed on the plant
"Preventive Maintenance" schedule to ensure the facility is maintained at all times.
The facility must properly calibrate (daily basis) the continuous pH recording
device when it is being utilized for compliance purposes.
Response: Daily verification of calibration for the laboratory pH meter will be utilized in
monitoring pH at Pipe 001 and Final Clarifier per Permit Section A (1): Measure Frequency: Daily,
Sample Type: Grab. Per the footnote: The continuous pH/temperature recording device
associated with both of these locations will continue to be maintained with quarterly calibration.
Response acceptance pending Wes Bell — NC DENR.
Dissolved Oxygen and temperature measurements are collected and transported
to on -site laboratory for analysis ....this should be performed within the effluent
discharge or collected with proper preservation and only if the Winkler Method is
utilized.
Response: Laboratory personnel have revised their practice of collecting dissolved oxygen
and temperature data but maintains the pH measurement for measurement within the fifteen
minute timeframe. Dissolved oxygen and temperature will be measured at Pipe 001. This will be
Celanese
Ticona
A business of Celanese AG

obtained by the use of a calibrated, portable DO / Temperature meter, thus eliminating
preservative usage. Winkler Method may be the calibration of the portable meter.
Sunday's composite samples should be modified to reflect compliance with "daily"
measurements performed five days per week excluding weekends and legal
holidays (Federal Holidays).
Response: Compliance reporting times were modified at the beginning of the month,
November 1, 2003 and will be reflected on DMR report for daily measurements. "Daily" is defined
as Monday through Friday. Although North Carolina adopted "as a minimum" the Federal
regulations; NCDENR— Mooresville has given the directive: State holidays are to be used for
compliance reporting. NC State holidays will be incorporated into the sampling and reporting
schedule.
Representative and accurate pH values at the Final Clarifier must reflect both
clarifier discharges. Documented pattern of problems associated with entrained
air impeding the device's accuracy/performance must be addressed.
Response: Further phone discussions with Mr. Wes Bell: utilizing the existing location, a "still
well" for the pH and temperature probe may eliminate the entrained air and maintenance
problems. A study will be conducted to ensure both clarifiers are represented. Based on the
results from this study, the new method will be used for the compliance probe of the final
clarifiers.
The final clarifier pH and recording chart was observed as inaccurate for both pH
and actual time reflected on the chart.
Response: Maintenance/I&E determined that the Final Clarifier pH probe had a slope error and
replaced probe and calibrated, however pH "grab" daily samples reflect full compliance per
permit. The chart was replaced beginning Sunday and aligned with proper time.
The preset gallon interval between composite sample should be checked to ensure
that it does not exceed 1/24 of the expected total daily flow.
Response: The composite sample does not exceed 1/24 of the expected total daily flow.
CNA Holdings, Inc. — Shelby Facility is committed to ensuring compliance with all County, State,
and Federal regulations. Should there be a need for further discussion pertaining to the
information submitted with this notification letter, feel free to call me at 704/480-4900, or via email
at pem.carter(d)-ticona.com .
incerely,
eaxAx-
PEM Carter
Sr. Environmental Engineer
cc: Ir—�Vleselll-- Mooresville Regional Office (Cert. Mail: 7002 0860 0006 3968 0629)
Central ESHA file: 1.1.2.1.4

1�
Certified Mail 7001 1940 0000 2032 0892
Return Receipt to PEM Carter 5
o^;_
PEMC04:41 m e.
December 22, 2004
DEC 2 8 2004
NCDENR
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
ATTENTION: Mr.. Mark D. McIntire
I Iona
Ticona
1 Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Reference: Change in Signatory Approval for CNA Holdings, Inc — Ticona Plant
NPDES Permit NC0004952, NCS000064 and WQ 0011038
Dear Mr. McIntire:
This letter is to notify your agency of a change in signatory approval for all
NPDES and WQ permits and reports. Signatory authority for CNA .
Holdings, Inc. has been delegated to Mr. Darrell Fisher; Interim Plant
Manager and Mr. Rick Jolley; ESHA and Site Services Manager. Both may sign
submissions as they pertain to Ticona permits.
Please make a note in your files of these changes. Should you have any
questions, please do not hesitate to call me at 704.480.4900 or email at
pem.carter(@@ticona.com.
Sincerely,
PEM Carter
Sr. Environmental Engineer
Cc: Mr. D. Rex Gleason
NCDENR — Mooresville Regional Office
Celanese
Ticona
A business of Celanese AG

Certified Mail: 7001 1140 0002 88 3 41/
Return Receipt to PEM Carter
December 2, 2004
PEMC04:40 t
NC Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street
r
Mooresville, NC 28115�',`
Attn: Mr. Samar Bou-ghazale
Peons
Ticona
Shelby Plant
Highway 198
" Shelby, NC 28152
Telephone [phone]
Re: Release of Fire Waters into Stormwater Drainage Ditch — 11/29/04
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
This report serves as the written requirement for the incident reported by telephone on November 30, 2004.
Per our telephone conversation, see attached Record of Agency Contact, CNA Holdings, Inc — Ticona
reported to you the release of firewater by way of the north stormwater outfall. Failure of the plant's
instrument air at 2A 0 p.m. caused the fire deluge system of the Solid State Polymerization unit to release
firewater, where it entered into the stormwater system and left the plant by way of the north outfall. The
release of waters ended at 4:30 p.m.. Calculation indicate approximately 4,900 gallons of firewater was
released. Samples of these water have been collected and submitted to a contract lab, Prism
Laboratories, Inc.
Based on the triangular notch weir, height and time of the discharge, approximately 4900 gallons were
released during the timeframe depicted in this table. An examination of the drainage ditch indicated that
the quantity of water released did flow to Buffalo Creek. There were no observed environmental impacts
to Buffalo Creek.
Triangular Notch Weir Water Flow Calculation
Description: 11/29/04 North Outfall Discharge Due to SSP Fire Deluge Failure
Variable
Value
Units ISource
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
3.0
in.
Measured
Date and Time at Begin.of
Discharge:
11/29/04 2:10
p.m.
Measured
Date and Time at End of
Discharge:
11/29/04 4:30
p.m.
Measured
Discharge
Volume:
Discharge Rate:
34.9
gpm
Calc.
Total Discharged:
4,883
gal.
Calc.
Test Parameters:
pH: 7.4
Odor: none
Foam: none
Color: water white
COD: pending
TSS: pending
Clarity: clear
Oil sheen: none
IFloating Solids: no
� Celanese
Ticona
A business of Celanese AG

Vn
addition to the above test parameters: samples of the released water were submitted to outside contract
laboratory (Prism Laboratory) for the following tests: MBAS, BOD5, phenol, total lead, bis(2-
ethylhexyl)phthalate and total nitrogen. These results will be forthcoming.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(ja�ticona.com
Sincerely,
G;i4a4yu-
PEM Carter
Sr. Environmental Engineer
Attachment: Ticona Record of Contact

TICONA
SHELBY, NC PLANT
RECORD OF AGENCY CONTACT
AGENT & TITLE: COMPANY PERSONNEL CONTACTED & TITLE
Samar Bou-ghazale PEM Carter — Sr. Env. Engineer
Inspector - DWQ CNA Holding - Ticona - Shelby
AGENCY/PHONE/FAX
NCDENR: Division of Water Quality
Mooresville, NC
704-663-1699
CONTACT INITIATED BY:
X TICONA Company Representative
_ Regulatory Agency
Other interested external party
REGULATORY PURPOSE OF CONTACT:
( ) upset notification:
( ) maintenance notification:
(X) release / excursion notification:
( ) permit work:
( ) agency inspection:
DATE OF CONTACT: TIME OF CONTACT:
11 /30/04 11:06 A.M.
TYPE OF CONTACT BY AGENT:
X Telephone
Agency Visit to Site
Company Visit to Agency
_Other Interested Party Visit to Site
Fax E-mail
Letter
EXTERNAL PARTY PURPOSE OF CONTACT:
( ) complaint
( ) request for EHS information
( ) public policy issue
( ) Other
( ) other:
24 hr. Notification to Mooresville, per Stormwater Permit No. NCS 000064
On 11/29/04, at 2:30 p.m., — The North Stormwater Outfall was observed releasing waters during a
non-stormwater event. Failure of the instrument air (2:10 p.m.) caused the fire deluge system on the
Solid State Poly. Unit to release fire waters which entered into the stormwater system and left the
plant by way of the north outfall. The release of waters ended at 4:30 p.m 11/29/04. Calculations
indicate approximately 4,900 gallons of firewater was released. Sampling of released waters per
NCS000064 has been initiated and submitted to contractor lab, Prism Laboratories. Reported the
waters pia 7.4, no foam, clear color, no visible sign of contamination.
Comments: Centralized ESHA Files cc: D.Fisher, R. Jolley, M. Blanton
REQUIRED FOLLOWED UP: (X) YES ( ) NO ADDITIONAL NOTES: 5 DAY WRITTEN REPORT DUE 12/03/04
TICONA — SHELBY
1). O. BOX 87, HIGHWAY 198
SHELBY, NC: 28151
REV. 2
10/02

December 2, 2004
221
Mr. Pem Carter
CNA Holdings, Inc. - Ticona Facility
P.O. Box 87
Shelby, NC 28152-0087
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
pna o
CES
OFFICE
SUBJECT: Wastewater/Groundwater Laboratory Certification Renewal DEC 0 6 2004
Dear Mr. Carter:
The Department of Environment and Natural Resources, in accordance wifh the provisions of NC G,S:143-215-
.3 (a) (10), 15 NCAC 2H .0800, is pleased to renew certification for your laboratorys°to• performs J, pecified
environmental analyses required by EMC monitoring and reporting regulations 15 NCAC 2B .0500, 2H .0900 and
2L .0100, .0200, .0300, and 2N .0100 through .0800.
Enclosed for your use is a certificate describing the requirements and limits of your certification. Please review
this certificate to insure that your laboratory is certified for all parameters required to properly meet your
certification needs.
Please contact us at 919-733-3908 if you have questions or need additional information.
Sincerely,
James W. Meyer
Laboratory Section
Enclosure
cc: Chet Whiting
Mooresville Regional Office
NorthCarolina
Naturally
Laboratory Section 1623 Mail Service Center; Raleigh, NC 27699-1623
4405 Reedy Creek Road; Raleigh, NC 27607
Phone [phone] / FAX [phone] / Internet: www,dwqlab.org
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Certificate No. 221
STATE OF NORTH CAROLINA DEPARTMENT OF THE
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
LABORATORY CERTIFICATION PROGRAM
In accordance with the provisions ofN.C.G.S. 143-215.3 (a) (1), 143-215.3 (a)(10) and NCAC 214.0800:
!�,4 STATEOP
tA
w
la
...� -a
FSSEE Q[1AM V V01...
CNA HOLDINGS, INC. - TICONA FACILITY
Is hereby certified to perform environmental analysis as listed on Attachment I and report monitoring data to DWQ for
compliance with NPDES effluent surface water, gro4ndwater, and pretreatment regulations.
By reference 15A NCAC 2H .0800 is made a part of this certificate.
This certificate does not guarantee validity of data generated, but indicates the methodology, equipment, quality control procedures,
records, and proficiency of the laboratory have been, examined and found to be acceptable.
This certificate shall be valid untiljDecember 31, 2005
James W, Meyer

Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
PF Certified Parameters Listing
Lab Name: CNA Holdings, Inc. - Ticona Facility Certificate Number: 221
Address: P.O. Box 87 Effective Date: 01/01/2005
Shelby, NC 28152-0087 Expiration Date: 12/31/2005
Date of Last Amendment:
The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANICS
BOD
Sid Method 5210E
COD
Std Method 5220D
COLIFORM FECAL
Std Method 9222D (MF)
DISSOLVED OXYGEN
Std Method 4500 O C
pH
Std Method 4500 H B
RESIDUE SUSPENDED
Std Method 2540D
TEMPERATURE
Std Method 2550B
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are
subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 21-1.0807.

OF, WA;T�c'Q
r
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
�n rJ
i� RJR [i717'rj f 7 ` '"'1 Alan W %,�imek, P.E., Director
.Division of Water Quality
iv
February 4, 2004
Ms. PEM Carter, Environmental Engineer
CNA Holdings, Inc.
Shelby Plant
Highway 198
Shelby, North Carolina 28152
Dear Ms. Carter:
FEB 0 6 2004
Subject: Draft NPDES Permit
Permit NC0004952
Ticona Facility
Cleveland County
x
Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft
carefully to ensure thorough understanding of the conditions and requirements it contains.
Changes to your existing permit are summarized below.
• Effluent limitations for BOD, TSS, and Subpart I parameters have been updated in
accordance with the most current 40 CFR and the flow information reported in your
application package.
• The compliance point for TSS and pH has been moved downstream of the polishing ponds.
These ponds are part of the wastewater treatment system and, as such, their effluent is
subject to the requirements codified in the federal effluent• guidelines for OCPSF
manufacturers. As was indicated in the January 17, 2000 issuance letter for the KOSA
Facility in Salisbury, NC (NC0004944), the Division is phasing out intermediate compliance
points as permits with such come up for renewal.
• This permit renewal acknowledges the idling of the pump -and -treatment groundwater
remediation system. It is the Division's understanding that the groundwater will be treated
in the activated sludge system. Part I, Section A, Number 5 has been added to the permit
requiring the submittal of CERCLA generated groundwater data. Furthermore, the permit
requires the facility to reactive the pump -and -treat system should the introduction of the
groundwater negatively impact the activated sludge system.
• The Supplement to Permit Cover Sheet has been modified to include reference to the
discharge of first -flush stormwater to the activated sludge treatment system.
Submit any comments to me no later than thirty days following your receipt of the draft.
Comments should be sent to the address listed at the bottom of this page. If no adverse
comments are received from the public or from you, this permit will likely be issued in late
March, with an effective date of May 1, 2004.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-161 7 - TELEPHONE [phone]/FAX [phone]
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES

Permit No. NC0004952
CNA Holdings - Ticona
Page 2
If you have any comments, questions, or concerns regarding this draft permit, call me at (919)
733-5083, extension 508.
Sincerel ,
Mark D. McIntire, P.E.
NPDES Unit
enclosures
cc: NPDES Unit
tM,00r-esville-RegionahOM-Ce—/-Water Quality Section (draft permit, fact sheet)
Aquatic Toxicology n t tdraft permit)
Roosevelt Childress, EPA Region 4 (draft permit, fact sheet, permit application)
Ken Lucas, EPA Region 4 Superfund Program (draft permit, fact sheet)
Dave Mattison, DENR Hazardous Waste Program (draft permit, fact sheet)
Jerry Kubal, Kubal-Fury & Associates, P.O. Box 273210, Tampa, FL 33688-3210 (draft permit, fact
sheet)

a
Permit NC0004952
1
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compli,
and regu
Commissi
is hereby
standards
anagement
to receiving waters designated as Buffalo Creek in the Broad River Basin in accordance with effluent
limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof.
The permit shall become effective
This permit and the authorization to discharge shall expire at midnight on August 31, 2008.
Signed this day
DRAFT
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0004952
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
CNA holdings, Inc.
Ticona Facility
is hereby authorized to:
1. Continue to operate an existing 0.8 MGD activated sludge wastewater treatment facility
located at on NC Highway 198, south of Shelby in Cleveland County, consisting of:
• ,-comm inutor;
• ; ;bar screen & grit chamber;
• three (3) equalization basins ut hzmg �pH adjustment
• two O aer:.ation basins with chorine added, on an as -needed basis
• :two (2) sec}ondaryclatifier's with polymer addition;
• a waste activated s..ludge :digester
• two (2)` sludge ponds; and
• three (3) polishing ponds.
f
2. Discharge groundwater pros-essF: and domestic wastewaters, and first -flush stormwater
from the :treatment works described im 'item;, one aPove and boilerwater make-up and
blowdoWh,' clarifier biowdown cooling tower make-up and blowdown, fire lagoon water,
and',:nQa,-process spin-finish,:_and;:,Vectra-,wastewaters at the location specified on the
attached map through outfall 001 into Buffalo Creek, a class C water in the Broad River
Basin.

071
Ell-
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�}4 �i 1 •YF
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222
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' ✓ 7
•_.f� O ,d►lif/`/ }� / fJ r'l_t11 b�a��l
77.
oil
CNA Holdings — Ticona Facility - NC0004952 Facility
Location
USGS Quad Name:: Blacksburg North Lat.: 35'11'15"
Receiving Stream: Buffalo Creek Long.: 81030'37"
Stream Class- C Not to SCALE
Subbasin: Yadkin - 030805 4orth]

Permit NC0004962
Part I - Section A
1. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge
from OutfaU 001. Such discharges shall be limited and monitored by the Permittee as specified below:
Flow (MGD)
0.8
Continuous
Recording
Effluent
BOD, 5-day, 200C
68.0 lbs/day
164.0 lbs/day
Daily
Composite
Effluent
Total Suspended Residue
114.0 lbs/day
328.0 lbs/day
Daily
Composite
Effluent
Fecal Coliform (Geometric Mean)
200 100 nil
400 100 ral
Weekly
Grab
Effluent
Oil and Grease
fa b
Effluent
Total Copper
z. z'
", dily
Monthly ,
e
Effluent
Total Nitrogen (NO4+
ua
Effluent
Total Phosphorus iz
Semi-Annuallye
"'Posit
Effluent
Chronic Toxicity2
Composite
Effluent
Pollutant Analysis
See Note 3
Composite
,C
Effluent
PH
et�V,defi & 4n d
d 9 .,.� Standard nits
Daily
::",: Grab
Effluent
Ft.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE
AMOUNTS.

1
Part I - Section A
Permit NC0004952
2. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I
Beginning on the effective date of this permit and lasting through' the expiration date, the Permittee shall comply
with the limitations and monitoring frequencies established below at outfall 001:
IFFLUENT LIMITATIONS
NONYTCjRING REQi1IREMENT5
PESRAMETER.
Monthly
p
Mea'suremerxt
Sample
5axnpls
AveraMatn`wxml
Fre uenc
e,
Locatixo►: `:
Acenaphthene
0.058•
0.156
Annually
Grab
Effluent
Acenaphthylene
0.058
0.156
Annually
Grab
Effluent
Acrylonitrile
0.255
43.798
Annually
Grab
Effluent
Anthracene
0.058
0.156
Annually
Grab
Effluent
Benzene
0,098
0.361
£Annuay i
' Grab
Effluent
Benzo(a)anthracene
- 3.2g/l
Annually
GYab
Effluent
3,4-Benzofluoxanthene
5.4 /I� ?
Annually
Grab .....
Effluent
Benzo(k)fluoranthene
3 2 rW
Annually
£Grab
Effluent
Benzo(a)pyrene x
j:
_ 5.4f Y '
;Annually .'
Grab
Effluent
Bis(2-ethylhexyl) phthalate
Q 273
Q 74Q
Annually .. _
[ Gfab
Effluent
Carbon Tetrachloride. . , i
0 048 ';
0.101
Annxall Y
Grab
Effluent
Chlorobenzene
Y 0.046
JAQ74
Annually
Gxati
Effluent
Chloroethane
0 276
Q,7 1
Annually
Grab
Effluent
Chloroform
0 056'
0.12
Annually
Graft
Effluent
2-Chlorophenol
0.082
0.260
Annually
Grab
Effluent
Chrysene
3.2 µg/I,
Annually
Grab
Effluent
Di-n-butyl phthalate
0.072
0.151
Annually
Grab
Effluent
1,2-Dichlorobenzene
0.204
0.432
Annually
Grab
Effluent
1,3-Dichlorobenzene
0.082
0.117
Annually
Grab
Effluent
1,4-Dichlorobenzene
0.040
0.074
Annually
Grab
Effluent
1,1-Dichloroethane
6.058
0.156
Annually
Grab
Effluent
1,2-Dichloroethane
0.180
0.560
Annually
Grab
Effluent
1,1-Dichloroethylene
0.042
0.066
Annually
Grab
Effluent
1,2-trans-Dichloroethylene
0.056
0.143
.Annually
Grab
Effluent
2,4-Dichlorophenol
0.103
0.297
Annually
Grab
Effluent
1,2-Dichloropropane
0.406
0.610
Annually
Grab
Effluent
1,3-Dichloropropylene
0.077
0.117
Annually
Grab
Effluent
Diethyl phthalate
0.215
0.538
Annually
Grab
Effluent
214-Dimethylphenol
0.048
0.095
Annually
Grab
Effluent
Dimethyl phthalate
0.050
0.125
Annually
Grab
Effluent
416-Dinitro-o-cresol
0.207
0.735
Annually
Grab
Effluent
2,4-Dinitrophenol
0.188
0.326
Annually
Grab
Effluent
2,4-Dinitrotoluene
0.300
0.756
Annually
Grab
Effluent

C
Permit NC0004952 V
Part I Section A
2. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I CONTINUED
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply
with the limitations and monitoring frequencies established below at outfall 001:
` - � _ ;
. "
EFFLUENT L#1�ITATIONS` '
� MONITO1�iNG REQUIREMENTS
PARAMETER
Monthly
I�ay
Measurepe�tt
Sagleampie
i ,
Anera e1 .,
Masx#humi
Fire uetc
a
Locat�czn
216-Dinitrotoluene
0.676
1.700
Annually
Grab
Effluent
Ethylbenzene
0.085
0.286
Annually
Grab
Effluent
Fluoranthenc
0.066
0.180
Annually
Grab
Effluent
Fluorene
0.058
0.156
Annually
Grab
Effluent
Hexachlorobenzene #
0.05 pg/L
Annually
Grab
Effluent
Hexachlorobutadiene
0 Q53.
s 0.130
;Annually ;
Grab
Effluent
Hexachloroethane
0056
0143
=Annually
Grab
Effluent
Methyl Chloride
02504
Annually
Gran
Effluent
Methylene Chloride }
0106
0236
Annuall Y
Graff
Effluent
Naphthalene
0 058 =
0.15C
'Annually
£ Grab
Effluent
Nitrobenzene
_ 0 072
01;80 .
Annally
Gra}
Effluent
2-Nitrophenol
010
0.183
Annually
i Grab
Effluent
4-Nitrophenol
01913
0`329
Annually
Gtal
Effluent
Phenanthrene
0 058
0.156
Annually
Grali
Effluent
Phenol
0.040
0.069
Annually
Grab
Effluent
Pyrene
0.06G
0.178
Annually
Grab
Effluent
Tetrachloroethylene
0.058
0.149
Annually
Grab
Effluent
Toluene
0.069
0.212
Annually
Grab
Effluent
1,2,4-Trichlorobenzene
0.180
0.371
Annually
Grab
Effluent
1,1,1-Trichloroethane
0.056
0.143
Annually
Grab
Effluent
1,1,2-Trichloroethane
0.056
0.143
Annually
Grab
Effluent
Trichloroethylene
0.056
0.143
Annually
Grab
Effluent
Vinyl Chloride
0.276
0.711
1 Annually
Grab
Effluent
Notes:
1 All units are lbs/day unless otherwise noted.

WIiiHiM111113 •UM
PART I - SECTION A
3. CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) — OUTFALL 001
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 5.8%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of March, June, September, and December. Effluent
sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months
as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998)
or subsequent versions.
The chronic value for !i
concentration having '
have a detectable imp,
methods, exposure,regi
Whole Effluent Toxicity,
All toxicity testing
Monitoring Form (]
pass/fail results a
following address:
for
Ad
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include
alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Permit NC0004952
u
PART I - SECTION A
4. POLLUTANT ANALYSIS CONDITION
The Permittee shall conduct a test for pollutants once every five years at the effluent from the treatment plant.
The discharge shall be evaluated as follows:
A. A pollutant analysis of the effluent must be completed using EPA approved methods for the following
analytic fractions:
• purgeables (i.e. volatile organic compounds);
• acid extractables;
• base/neutral extractables;
• organochlorine pesticides and PCBs;
• herbicides; and
• metals and other inorganics.
The Pollutant Analysis Monitoring (PAM) Requirement Reporting Form A and accompanying memo, to be
provided to all discharges impacted by this monitoring requirement describes the sampling and analysis
requirements and lists chemicals to be included in the pollutant analysis
B. Other
the r
occur) for c
approximate
requirement
F
i
tiiied acid approximately quantified. For
10 GC/Ms i peaks in the purgeable,
an..1,0 if lessthan 10 unidentified peaks
io'rtirig foriru should be identified and
�g> form. This part (item B) of the PAM

Permit NC0004952
PART I - SECTION A
5. GROUNDWATER TREATMENT AND REPORTING CONDITION
The Permittee shall submit analytical results of groundwater monitored in accordance with CERCLA
requirements. Submittal shall be made with the discharge monitoring report (DMR) for the month during which
the subject monitoring occurred.
The Permittee shall maintain the pump -and -treat system in an idled, but standby, mode such that it can been
employed in the event the groundwater has an adverse impact on the activated sludge treatment system.

1/30/2004
NCDENR®DWQ
FACT SKEET FOR NPDES PERMIT DEVELOPMENT
CNA Moldings, Inc.
Ticona Facility
NPDES Permit Number NC0004952
(1.) Facility Name:
CNA Holdings, Inc.
- Ticona Facility _
(2.) Permitted Flow (MGD):
0.8 -
(6.) County:
;Cleveland
(3.) Facility Class:_
III
(7.) Regional Office:
I Mooresville
4.) Pretreatment_Pr_ooram:
_
NA
_
(8.) USGS T_po Quad:
_
G12NE _
(5.) Permit Status:
;Renewal
(9.) USGS Quad Name:
Blacksbur North
,
{�yp p ■/��,/^�yr !��1 pql�y.f
5CY1614�YSaS,�
(1.) Receiving Stream:
i Buffalo Creek —
(7.) Drainage Area (mi2):
154
(2.) Sub -basin: _
03-08-05
1 (8.) Summer 7Q10 (cfs):
? 20
_
(3.) Stream Index Number:
_
' (9.) Winter 7Q10 cfs)_
_
46 —
(4.) Stream Classification:
C
30Q2 (cfs):
NA
(5.) 303(d) Status:-
Not Listed
_ _(10.)
(11.) Average Flow (cfs):
216
(6.) 305(b) Status:
Supporting
(12.) IWC %:
5.8%
1.0 - PROPOSED CHANGES
Effluent limitations for BOD, TSS, and Subpart I parameters have been modified to
reflect actual production for the previous three years.
Effluent limitations and monitoring requirements for TSS and pH will be implemented at
the final effluent from the polishing ponds with this renewal. This is consistent with
federal guidelines and recently issued permits that have addressed alternate compliance
points for said parameters.
A special condition has been added to the permit requiring the facility to submit
groundwater data collected in accordance with CERCLA requirements as the
groundwater remediation system will be idled. All pumped groundwater will be treated in
the activated sludge facility.
2.0 BACKGROUND
This is a permit renewal for a major industrial wastewater treatment facility with a current
facility design and permitted flow of 0.8 MGD with a discharge to Buffalo Creek in the Broad
River Basin. Buffalo Creek was a 303(d) listed stream on North Carolina's 1998 impaired
streams list. This listing was the result of a Fair bioclassification resulting from
macroinvertebrate data collected in 1990. Resampled in 2000, Buffalo Creek received a Good
bioclassification and was therefore delisted in 2002. That being said, Buffalo Creek still exhibits
water quality and habitat impacts associated with agriculture and clear lands.

NPDES Permit Fact Sheet - January 29, 2004
Page 2
3.0 FACILITY INFORMATION
CNA Holdings, Inc - Ticona Facility
NC0004952
The subject facility manufactures thermoplastic resins and then extrudes a portion of those
resins into synthetic fibers. As such, 40 CFR 414.30 and 414.40 are applicable. Information
regarding guideline load allocations is presented in the Permit Development portion of this
document.
In addition to manufacturing operations, this facility has operated a pump -and -treat
groundwater remediation facility regulated by North Carolina's Superfund program for some
time. On Thursday, January 22, 2004, the writer met with Dave Mattison with North Carolina's
Hazardous Waste program, Ken Lucas with USA EPA Region 4, and Jerry Kubal, the hazardous
waste consultant for the Ticona Facility to discuss CNA .Holding's proposal to idle the pump -
and -treat system, thus directing pumped groundwater to the headworks of the activated sludge
treatment system. It was agreed that with this renewal, the NPDES permit would reflect such
operation and require the facility to submit CERCLA related groundwater data to the Division of
Water Quality with it's monthly discharge monitoring reports (DMRs).
This facility's compliance history was reviewed for the previous permit period. The facility
appears to be operated well and has little difficulty meeting effluent limitations. The facility had
two chronic toxicity test failures during that timeframe. The failures occurred in December of
1999 and 2000 and were each followed up immediately with a pass.
4.0 PERMIT DEVELOPMENT
• Effluent Limitations: limitations for BOD, TSS, and Subpart I parameters have been updated
using appropriate process wastewater flow information and the appropriate federal effluent
guidelines (see attached spreadsheet).
TSS and pH compliance point: the previous permit incorrectly established a compliance
point for TSS and pH between the secondary clarifiers and the polishing ponds. These
polishing ponds are part of the treatment system. As such, compliance with limitations for
solids and pH should be judged at a point downstream of them. The permit has been
updated accordingly.
• Groundwater Special Condition: a special condition has been added requiring the facility to
submit CERCLA data for groundwater. Furthermore, the condition requires the facility to
reinstate use of the idled pump -and -treat system in the event the groundwater. causes
problems in the activated sludge system.
5.0 PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: February 11, 2004
Permit Scheduled to Issue: March 29, 2004
6.0 STATE CONTACT
If you have any questions on any of the above information or on the attached permit, please
contact Mark McIntire at [phone], extension 508.

NPDES Permit Fact Sheet - January 29, 2004 CNA Holdings, Inc - Ticona Facility
Page 3 NC0004952
Copies of the following are attached to provide further information on the permit development:
• Limit calculations
• Permit application
• Draft Permit
NPDES
Signature Date
W
REGIONAL OFFICE OOMAMNTS:
f b LG b�✓; �J �, ' Two CZ %
DLG /,��� U v/Sim%Ci�6i✓
REGIONAL
BY: <�c,
Signature
Date

CNA Holdings, Inc.
NC0004952
Average Flow for 2001 - 2003: 0.445 MGD
Information provided by CNA with this permit renewal indicates that of the flow discharged through outfall
outfall 001, approximately 71.4% is process wastewater. Of the process wastewater, approximately 0.215 MGD
is attributable to 414 Subpart C manufacturing with the remaining 0.103 attributable to Subpart D.
Subpart C flow:
0.215 MGD
Subpart D flow:
0.103 MGD
Domestic flow:
0.0605 MGD
40 CFR 414.31 (Subpart C - All units are mg/L)
Daily Max Mon. Avg.
BOD5 1 48 18
TSS 115 36
40 CFR 414.41 (Subpart D - All units are mg/L)
Daily Max Mon. Avg.
BOD5 1 64 24
TSS 130 40
Subpart C Allocation - lbs/day
Daily Max Mon. Avg.
BOD5 86.1 32.3
TSS 206.2 64.6
Subpart D Allocation - lbs/day
Daily Max Mon. Avg.
BOD5 55.0 20.6
TSS 98.8 34.4
The Difference between the average flow and
the sum of the flows to left are attributed to
water treatment blowdown and NCCW.
Domestic Allocation (Q = 60,500 gpd) - Assuming secondary limits - lbs/day
Daily Max I Mon. Av .
BOD5 22.7 15.1
TSS 1 22.7 15.1
Total Allocation (Sum of C, D, and Domestic) - lbs/day
Daily Max Mon. Avg.
BOD5 1 164 68
TSS 328 114
Mark McIntire
1 /29/2004

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1
Certified Mail 7002 0860 0006 3968 0612
Return Receipt to PEM Carter
PEMC: 03:46
November 8, 2003
R E C, 0, V E D
N � 2 2003
North Carolina Department of Environment and
Natural Resources
Mooresville Regional Office — Division of Water Quality
919 North Main Street
Mooresville, North Carolina 28115
ATTN; Mr. Richard M. Bridgeman
iieona
Ticowa
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Re: Response to Laboratory Compliance Inspection of the CNA Holdings, Inc. —
Ticona Plant, NPDES Permit No. NC0004952
Dear Mr. Bridgeman
This memorandum summarizes the written responses concerning comments identified in the
WWTP Laboratory Compliance Evaluation Inspection, which occurred at the CNA Holdings, Inc —
Ticona Plant on October 16, 2003, conducted by Mr. Chester Whiting and Mr. Wes Bell. As per
the cover letter accompanying the report, a written item description has been prepared for each
deficiency noted in sections Facility Site Review/Operations & Maintenance, Laboratory and the
Self -Monitoring Section of the report.
Vegetation observed within the concrete basin (liner) of the aeration basins.
Permit requires that the facility be properly operated and maintained at all times.
Response: Unwanted vegetation surrounding all WWTP components, (aeration basins, grit
chamber, equalization basins, clarifiers, polishing ponds, sludge ponds), will be maintained to
ensure integrity is not jeopardized. These WWTP components have been placed on the plant
"Preventive Maintenance" schedule to ensure the facility is maintained at all times.
The facility must properly calibrate (daily basis) the continuous pH recording
device when it is being utilized for compliance purposes.
Response: Daily verification of calibration for the laboratory pH meter will be utilized in
monitoring pH at Pipe 001 and Final Clarifier per Permit Section A (1): Measure Frequency: Daily,
Sample Type: Grab. Per the footnote: The continuous pH/temperature recording device
associated with both of these locations will continue to be maintained with quarterly calibration.
Response acceptance pending Wes Bell — NC DENR.
Dissolved Oxygen and temperature measurements are collected and transported
to on -site laboratory for analysis ....this should be performed within the effluent
discharge or collected with proper preservation and only if the Winkler Method is
utilized.
Response: Laboratory personnel have revised their practice of collecting dissolved oxygen
and temperature data but maintains the pH measurement for measurement within the fifteen
minute timeframe. Dissolved oxygen and temperature will be measured at Pipe 001. This will be
� Celanese
Tm
A business of Celanese AG

obtained by the use of a calibrated, portable DO / Temperature meter, thus eliminating
preservative usage. Winkler Method may be the calibration of the portable meter.
Sunday's composite samples should be modified to reflect compliance with "daily"
measurements performed five days per week excluding weekends and legal
holidays (Federal Holidays).
Response: Compliance reporting times were modified at the beginning of the month,
November 1, 2003 and will be reflected on DMR report for daily measurements. "Daily" is defined
as Monday through Friday. Although North Carolina adopted "as a minimum" the Federal
regulations; NCDENR — Mooresville has given the directive: State holidays are to be used for
compliance reporting. NC State holidays will be incorporated into the sampling and reporting
schedule.
Representative and accurate pH values at the Final Clarifier must reflect both
clarifier discharges. Documented pattern of problems associated with entrained
air impeding the device's accuracy/performance must be addressed.
Response: Further phone discussions with Mr. Wes Bell: utilizing the existing location, a "still
well" for the pH and temperature probe may eliminate the entrained air and maintenance
problems. A study will be conducted to ensure both clarifiers are represented. Based on the
results from this study, the new method will be used for the compliance probe of the final
clarifiers.
The final clarifier pH and recording chart was observed as inaccurate for both pH
and actual time reflected on the chart.
Response: Maintenance/I&E determined that the Final Clarifier pH probe had a slope error and
replaced probe and calibrated, however pH "grab" daily samples reflect full compliance per
permit. The chart was replaced beginning Sunday and aligned with proper time.
The preset gallon interval between composite sample should be checked to ensure
that it does not exceed 1/24 of the expected total daily flow.
Response: The composite sample does not exceed 1/24 of the expected total daily flow.
CNA Holdings, Inc. — Shelby Facility is committed to ensuring compliance with all County, State,
and Federal regulations. Should there be a need for further discussion pertaining to the
information submitted with this notification letter, feel free to call me at 704/480-4900, or via email
at pem.carter(aD_ticona.com .
Sincerely,
PEM Carter
Sr. Environmental Engineer
cc: Mr. Wes Bell — Mooresville Regional Office (Cert. Mail: 7002 0860 0006 3968 0629)
Central ESHA file: 1.1.2.1.4

Q
O� W A%9 Michael F. Easley, G error
�� QG William G. Ross Jr., Secretary V
co
North Carolina Department of Environment and Natural Resources
r
Alan W. Klimek, P. E., Director
-� Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
October 22, 2003
Mrs. PEM Carter, Sr. Environmental Engineer
CNA Holdings, Inc.
Post Office Box 87
Shelby, North Carolina 28151
Subject: Notice of Deficiency
Compliance Evaluation Inspection
CNA Holdings, Inc. W WTP
NPDES Permit No. NC0004952
Cleveland County, N.C.
Dear Mrs. Carter:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on October 16, 2003, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -
Responsible Charge of our findings by forwarding a copy of the enclosed report
Although the operation of this facility is commendable, it is requested that a written response be
submitted to this Office by November 12. 2003, addressing the deficiencies noted in Facility Site
Review/Operations & Maintenance, Laboratory, and the Self -Monitoring Sections of the report. In
responding, please address your comments to the attention of Mr. Richard Bridgeman.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact Mr. Bell or me at [phone].
r
Sincerely,
V , � m_ (3J�J
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Cleveland County Health Department
WB
NCDEPIR
Mooresville Regional Office, 919 North Main Street, Mooresville, North Carolina 28115
Phone [phone] Customer Service
Fax [phone]

United States Environmental Protection Agency
FormApproved.
EPA Washington, D.C. 20460
OMB
OMB Na. 2040-0057
Water Compflance 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 LJ 2 W 31 NC00049.52 11 121 03/10/16 117 18 u 19lSl 20 Lj
Remarks
211111111111111111111111111111111111111111111111166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------Reserved------
67 I 1.5 169 70 L:J 71 U 72 L'J 73 W 74 751 I I I I I Li
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)
0:50 AM 03/10/16
99/05/01
Shelby plant
Exit Time/Date
Permit Expiration Date
NC Highway 198
Shelby NC 2815C
02:23 PM 03/10/16
03/08/31
Name(s) of Onsite Representative(s)Mtles(s)/Phone and Fax Number(s)
Other Facility Data
Johnny L Ledford/ORC/704-480-4692/
PEM Carter//7C4-480-4900/
Name, Address of Responsible Official/Title/Phone and Fax Number
John Groves,PO Box 87 Shelby NC 28151//704-480-4850/ Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
SEE ATTACHED PAGE (S) .
Name(s) and Signature(s) Inspectors) Agency/Office/Phone and Fax Numbers Date
/oaf
Wesley N Bell W y// MRO WQ//704-663-1699/704-663-6040 0
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

PERMIT:
V
The facility has installed tertiary filters and an UV disinfection system (via Authorization
to Construct dated 4/20/00); therefore, the permit description does not adequately describe the
facility.
The Division issued permit modifications on 3/29/99 and 5/7/01 regarding a
name/ownership change and a revision of the effluent limitations page. The facility currently
operates under the requirements of the expired permit (as of 8/31/03). The facility has submitted
the appropriate documentation for a permit renewal.
RECORDS AND REPORTS:
Records and reports consisting of monthly monitoring reports, chain of custody forms,
laboratory analyses, calibration data, process control data, Operator -in -Responsible Charge
(ORC) visitation log, operation and maintenance logs, and flow charts are kept in accordance with
permit requirements. The records were organized and well maintained.
FACILITY SITE REVIEW/OPERATIONS & MAINTENANCE:
The process units appeared to be operating properly and the surrounding grounds were
well maintained. The tertiary filters and UV disinfection system are operational; however, only
the tertiary filters are currently in -use. The mixed liquor suspended solids were well mixed and
adequately oxygenated. Urea is added to the aeration basins to enhance microbial treatment.
Polymer additions are added prior to clarification to enhance settling. Both clarifiers appeared
green due to the abundant accumulation of algae. The backwash discharge (containing algae,
etc.) associated with the tertiary filters is piped directly into the sludge holding pond. The
supernate (in the sludge pond) appeared green (due to algae, etc) and is decanted back into the
treatment system prior to aeration. The green appearance of the clarifiers could be attributed to
the recycling of the supernate from the sludge holding pond. Screenings are disposed at the
county landfill. The facility is staffed with appropriately certified operators. The ORC and staff
were very knowledgeable of all treatment units and processes utilized at the facility.
A comprehensive process control program consists of pH, DO, ammonia, phosphorus,
COD, SRT, F/M ratios, microscopic examination, MLSS, MLVSS, SVI calculations, and sludge
blanket measurements. Sludge wasting is based on the SRT measurements.
An abundant amount of vegetation was observed within the concrete basin (liner) of the
aeration basins.. The ORC and staff must insure that the vegetation is removed from the concrete
structure to prevent any structural defects (cracking, etc.) from occurring. In addition, the Permit
requires that the facility be properly operated and maintained at all times.
LABORATORY:
The on -site laboratory (Certification # 221) and the contract services of Prism
Laboratories, Inc. (Certification # 402 ) of Charlotte, N.C., Davis & Floyd, Inc. (Certification #
25) of Greenwood, S.C. and ETT Environmental of Greenville, S.C. provide analytical support.
The laboratories were not evaluated during this inspection. Please refer to Mr. Chet Whiting's
(Division's Laboratory Certification Unit) inspection report regarding the facility's Iaboratory
practices.

LABORATORY cont'd•
In addition to Mr. Whiting's report, the facility must properly calibrate (daily basis) the
continuous pH recording device when it is being utilized for compliance purposes.
EFFLUENT/RECEIVING STREAM:
The effluent discharge was clear with no floatable solids or foam. The receiving stream
was not evaluated at the time of the inspection.
The effluent was analyzed at the time of the inspection for the following:
- pH 10.41 s.u. - temperature 19.8°C
SELF -MONITORING PROGRAM:
Self -monitoring reports were reviewed for the period August 2002 through July 2003,
inclusive. No limit violations were reported. All monitoring frequencies and sampling locations
appeared correct.
The dissolved oxygen and temperature measurements are collected and transported to the
on -site laboratory for analysis. Please be advised that the dissolved oxygen and temperature
measurements should be performed within the effluent discharge. According to Mr. Chet Whiting
(Division's Laboratory Certification Unit), dissolved oxygen measurements may be collected and
transported (including proper preservation) to the laboratory if the Winkler Method is utilized.
Note: The Winkler Method is not used at this facility.
The facility currently reports effluent composite values (on the DMRs) from Sunday
through Thursday. Please be advised that "daily" measurements must be performed five days per
week excluding weekends and legal holidays [Reference: 15A NCAC 2B .0503(5)]. The
commencement time of Sunday's composite samples should be appropriately modified to reflect
compliance with the above -noted requirement.
The continuous pH measuring device is located in a manhole where the effluents of both
clarifiers are combined. The effluents discharge at different locations within the manhole. This
office is concerned whether the sample location reveals a representative and accurate pH value.
The attached pH chart recordings (to the DMRs) and maintenance logs have documented a
pattern of problems associated with air bubbles/entrained air impeding the device's
accuracy/performance. At the time of the inspection, an instantaneous pH value (performed by
this Office) was recorded at 7.71 s.u. while a 6.95 s.u. was observed on the continuous pH
recording device. In addition, the continuous pH recording chart was 1-2 hours behind the actual
time. Please be advised that the Permit requires that the facility be properly operated and
maintained at all times.
All samples appeared to have been properly preserved and meet the required holding
times. Composite samples are collected flow proportionately. The ORC and staff must insure that
the preset gallon interval between composite sample collection does not exceed 1/24 of the
expected total daily flow.

FLOW MEASUREMENT:
Effluent flow is measured by a continuous recording flow meter with totalizer and circular
chart recording. The flow meter is calibrated on a quarterly basis by the facility's I & E
Department. The flow meter was last calibrated on 6/27/03.
SLUDGE DISP®SAL:
The facility is authorized to land apply sludge according to Permit #WQ0011038. The
facility has not land applied sludge within the last two years. The contracted services of Synagro
were utilized during the previous land application event.

PPPP
Certified Mail: 7002 0860 0006 3968 1725
Return Receipt to John Kuhn -
July 22, 2003
JBK 03:11
NC Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
Attn: Mr. John Lesley
Re: Release of Firewater and Cooling Waters into Stormwater Drainage Ditch
July 18 and July 20 , 2003
(CNA-Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Lesley:
iieona
Tieona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
This report serves as the written requirement for the two incidents listed below, which have already been
reported via telephone to your office.
Incident # 1:
Per the voicemail message I left you at 11:50 a.m. on July 19th, 2003 (and also reported to Jimmy Ray at
the DENR emergency number at noon on July 19th), a power outage at our plant caused the release of
firefighting waters, some of which entered two stormwater outfalls. At approximately 9:30 p.m. on July 18,
lightning from a severe thunderstorm caused a power outage at our plant. Our plant contains several
firefighting "deluge" systems, which are triggered when system (instrument) air pressure drops below 10
psi. The power outage affected our compressors that provide instrument air. Three deluge systems were
triggered, and although they were valved out as soon as possible, some of the firewater escaped
containment and entered the stormwater collection systems that discharge through the north and south
stormwater outfalls. We measured the flow rate at each outfall during the release event, and
conservatively assumed that all the water was composed of the firefighting water, and that this maximum
flow occurred for the entire event duration. Flow was calculated using notch weir flow rate equations, with
measured height of flow. Based on these conservative assumptions, we estimate that approximately
48,606 gallons were released to the North Outfall, and 15,010 gallons were released to the South Outfall.
There were no observed environmental impacts to Buffalo Creek. We sampled the waters from each
outfall during the event. The pH of the waters is indicated on the following tables: other analytical results
are pending and will be forwarded to your office when received.
HC DEPT.
AM IATUR4L F,E8,00,CES
=RESal1U,—:: ir-70101NAL OFF -ICE
Celanese
Ticona
A business of Celanese AG

Triangular Notch Weir Water Flow Calculation Tool:
Description: 7/18/03 North Outfall Discharge Due to Power Failure/Deluge System Activation
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
8.0
in.
Measured
Date and Time at Begin.of
Discharge:
7/18/03 10:00
p.m.
Measured
Date and Time at End of
Discharge:
7/19/03 12:00
a.m.
Measured
Discharge
Volume:
Discharge Rate:
405.1
gpm
Calc.
Total Discharged:
48,606
gal.
Calc.
Test Parameters:
pH: 7.1
MBAS: pending
Odor: none
Foam: none
Color: water white
COD: pending
TSS: pending
Clarity: clear
Oil sheen: none
Floating Solids: no
Triangular. Notch Weir Water Flow Calculation Tool:
Description: 7/18/03 Sorth Outfall Discharge Due to Power Failure/Deluge System Activation
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
5.0
in.
Measured
Date and Time at Begin.of
Discharge:
7/18/03 10:00
p.m.
Measured
Date and Time at End of
Discharge:
7/1.9/03 12:00
a.m.
Measured
Discharge
Volume:
Discharge Rate:
125.1
gpm
Calc.
Total Discharged:
15,010
gal.
Calc.
Test Parameters:
pH: 6.9
MBAS: pending
Odor: none
Foam: none
Color: water white
COD: pending
TSS: pending
Clarity: clear
Oil sheen: none
Floating Solids: no
In addition to the above test parameters: samples of the released waters were submitted to outside
contract laboratory (Prism Laboratory) for the following tests: BOD5, phenol, total lead, bis(2-
ethylhexyl)phthalate and total nitrogen.

Pppinpcident#2:
Per our conversation of 7/20/03, at approximately 1:00 pm on 7/20/03, a pipe containing chilled water in
the KoSa facility ruptured. The chilled water eventually entered our stormwater drainage system. The
rupture was valved out and repaired expeditiously, but waters were observed flowing out of the North
Outfall until 3:45 p.m. that day. We were unable to define the exact starting time of this release, so we
used a "worse case" time of 1:00 p.m. (the time the rupture was reported) to calculate the volume
released. Based on the triangular notch weir, height and time of the discharge, approximately 324 gallons
were released during the timeframe depicted in this table. An examination of the drainage ditch indicated
that the quantity of water released did flow to Buffalo Creek. There were no observed environmental
impacts to Buffalo Creek.
Triangular Notch Weir Water Flow Calculation Tool:
Description:
7/20/03 North Outfall Discharge Due to Chilled Water Pipe Rupture
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
In.
Measured
Notch Length at Top:
26
In.
Measured
Notch Depth:
13
In.
Measured
Notch Angle.
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
1.0
In.
Measured
Date and Time at Begin.of Discharge:
7/20/03 1:00
p.m.
Measured
Date and Time at End of Discharge:
7/20/03 3:45
p.m.
Measured
Discharge Volume:
Discharge Rate:
2.2
gpm
Calc.
Total Discharged:
324
gal.
Calc.
Test Parameters:
pH: 7.0
MBAS: pending
Odor: none
I Foam: none
Color: water white
COD: pending
TSS: pending
Clarity: clear
jOil sheen: none
IFloating Solids: no
In addition to the above test parameters: samples of the released water were submitted to outside contract
laboratory (Prism Laboratory) for the following tests: BOD5, phenol, total lead, bis(2-ethylhexyl)phthalate and
total nitrogen.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at [phone], or via email at [e-mail].
Sincerely,
ohn Kuh
Sr. Environmental Engineer

Certified Mail 7002 0860 0006 3968 0711
Return to PEM Carter
PEMC03:36
September.4, ,2003
NCDENR
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ATTN: Mr. Mark McIntire
Ticona
WC DEPT. Or, Eii VIRONiifJ `�
AND NATURAL RESOURCES
Ticona
SEP 0 5 2003 Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Reference: Preventive Maintenance Proiect — Grit Chamber —
NPDES Permit No. NC0004952, - CNA Holdings, Inc — Ticona Plant,
Dear Mr. McIntire:
As we discussed over the phone on August 25, 2003, CNA Holdings, Inc — Ticona Plant underwent an
internal Preventive Maintenance audit. During this audit, the grit chamber of the Ticona wastewater
treatment plant was identified for concrete repairs. This letter is to officially inform NCDENR - DWQ of this
project, repairing. the concrete basin associated with the grit chamber of the wastewater treatment plant.
In summary, all process wastewaters will be re -directed, around the grit chamber, into the first equalization
basin where the waters will begin treatment. In order to re -direct these waters, additional piping with
valves will be installed. Ticona will continue to minimize all grit/solids from entering the wastewater system.
The overall timing to complete this project is projected at three (3) weeks.
CNA Holding Inc — Shelby Facility is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information on these forms, feel
free to call me at 704/480-4900, or via email at pem.carter(aticona.com.
Sincerely,
Cin e�
PEM Carter
Sr. Environmental Engineer
Attachments
✓cc: Mr. Richard ridges Mooresville Regional Office —
Fedex: 7002 60 0006 3968 1152
Celanese
Ticona
A busincss of Celanese AG

Certified Mail: 7001 1140 0002 8843 5077
Return Receipt to John Kuhn
December 30, 2003
JBK 03:16
NC Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Laboratory Analysis Results
November 21, 2003 Stormwater Discharge
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
iicona
Ticona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
This letter serves as a follow up to our initial report (my phone call and letter of November 21, 2003) of the
releases to stormwater referenced above. As we indicated in our November 21st letter, we collected samples for
the stormwater discharges and had sent them to Prism Laboratories for analysis. The following presents the
complete results of the analyses. As our initial report indicated, the release consisted primarily of rainfall runoff.
11-21-03
Total Kjeldahl N: < 0.5 mg/i
North Outfall
COD: < 50 mgn
Bis(2-ethylhexyl)phthalate: not detected ugn
Test Parameters:
Lead, Total:< 0 .005 mg/i
Phenol: < 0.05 mgn
MBAS: <0.1 mg/m3
BOD5: 2.0 mg/I
TSS: 3 mg/I
Clarity: clear
Based on these results, there was no observed environmental impact on Buffalo Creek (the receiving water body
for the stormwater discharge).
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this letter,
feel free to call me at-[phone], or via email at [e-mail].
Sincerely,
dhn� n
Sr. Environmental Engineer
; DER. OF ENVIRONMENT."
h MD-NATURALRESOURCES : \
GDOMVIU-P :7'. _-,A001JAL OFFICE
F l ,I
DEC 31 2003
Celanese
Ticona
A b.-- of Cdan— AG

Ticona
Certified Mail 7002 0860 0006 3968 0674
Return to PEM Carter
PEMC03:50
December 16, 2003
NCDENR
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ATTN: Mr. Mark McIntire
t4c CoFr 6
AND ikAWRAL RESOURCES
p��RES I(vl ` ': 'aAIAL OFFICE
®EC. 1 9"2003 ,
Ticona
'Shelby Plant _
Highway -0'9
Shelby, NC-28152
Telephone [phone]
Reference: Follow up: Completion of the Preventive Maintenance Project — Grit
Chamber — NPDES Permit No. NC0004952, - CNA Holdings, Inc — Ticona
Plant,
Dear Mr. McIntire:
As we discussed over the phone on August 25, 2003, CNA Holdings, Inc — Ticona Plant underwent an
internal Preventive Maintenance audit. During this audit, the grit chamber of the Ticona wastewater
treatment plant was identified for concrete repairs. A letter outlining the details of the repairs was
.submitted September 2003 to your attention with a request from your office to notify you of its completion.
This letter is to officially inform NCDENR - DWQ of the completion of this project.
CNA Holding Inc — Shelby Facility is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information on these forms, feel
free to call me at 704/480-4900, or via email at [e-mail].
cerely,.
X fiL
PEM Carter
Sr. Environmental Engineer
Attachments
V/cc: Mr. Richard Bridges — Mooresville Regional Office —
Certified Mail: 7002 0860 0006 3968 0681
f� Celanese
Ticona
A business of Celanese AG

Certified Mail: 7002 0860 0006 3968 1824,.
Return Receipt to John Kuhn Ivy
November 21, 2003
JBK 03:14
AND NATURAi RESOURCES
NOORESVILI-L7�-RIONAL OFFICE
t;.
Y.�
-.
NOV 2 62003
NC Department of Environment and Natural Resource �CT11
Division of Water QualityQUAM rl
919 North Main Street
Mooresville, NC 28115
Attn: Mr. Samar Bou-ghazale
Re: Release of Firewater and Cooling Waters into Stormwater Drainage Ditch
July 18 and July 20 , 2003
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Bou-ghazale:
IICOna
Ticonai
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
This report serves as the written requirement for the incident described below, which has already been reported
via telephone to your office.
Per our conversation at.1:00 pm on November 21 st, 2003, a pump that normally directs low flows of water
from our north stormwater discharge to our onsite wastewater treatment plant failed, causing the release of
a small amount of water through the outfall. The pump failed sometime after midnight, Friday, November
21 st and was repaired by 11:30 am that day. Flow was calculated using notch weir flow rate equations,
with measured height of flow. Based on these conservative assumptions, we estimate that approximately
1,544 gallons were released to the North Outfall. We sampled the water from the North Outfall during the
event: analytical results are pending and will be forwarded to your office when received.
Triangular Notch Weir Water Flow Calculation Tool:
Description: 11/21/03 North Outfall Discharge Due to Pump Failure
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
1.0
in.
Measured
Date and Time at Begin.of
Discharge:
11/21/03 12:00
a.m.
Measured
Date and Time at End of
Discharge:
11/21/03 11:30
a.m.
Measured
Discharge
Volume:
Discharge Rate:
2.2
gpm
Calc.
Total Discharged:
1,544
gal.
Calc.
Test Parameters:
pH: pending
MBAS: pending
Odor: none
Foam: none
Color: water white
COD: pending
TSS: pending
Clarity: clear
Oil sheen: none lFloating
Solids: no
� Celanese
Ticona
A busincss nl Celanese AG
L'

In addition to the above test parameters: samples of the released waters were submitted to outside
contract laboratory (Prism Laboratory) for the following tests: pH, BOD5, phenol, total lead, bis(2-
ethylhexyl)phthalate and total nitrogen.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at [phone], or via email at [e-mail].
Sin rely,
i
ohn Ku n
Sr. Environmental Engineer

Certified Mail: 7002 0860 00 6 39 8 1800 IBC DEPT. OF ENVIRGMMEsm T
Return Receipt to John Kuhn pyAidp5d7 %P,T?-t0e1_ EeFMdhCEB
OFFICE -
August /�[' IBC®d'i vi( _ jE FF
August 14, 2003
JBK 03:12
AUG 18 2003
NC Department of Environment and Natural Resources j
Division of Water Quality ;
919 North Main Street
Mooresville, NC 28115
Attn: Mr. John Lesley AKs
btl
Re: Laboratory Analysis Results
July 18 and July 20 , 2003 Fire and Chilled Water Discharqes
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Lesley:
'ieona
Ticona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
This letter serves as a follow up to our initial report (my letter of July 22, 2002) of the releases to stormwater
referenced above. As we indicated in our July 22"d letter, we collected samples for the stormwater discharges
and had sent them to Prism Laboratories for analysis. The following presents the complete results of the
analyses. As our initial report indicated, the July 18th releases consisted of firefighting water combined with
rainfall runoff, and the July 20th release consisted of chilled water, also combined with rainfall runoff.
7-18-03
Total Kjeldahl N: < 0.5 mg/I
North Outfall
COD: < 50 mg/I
Bis(2-ethylhexyl)phthalate: not detected ugn
Test Parameters:
Lead, Total:< 0 .005 mg/I
Phenol: < 0.05 mg/I
MBAS: 0.1 mg/m3
Outside of holding times.
BOD5: 7.5 mg/I
Outside of holding times.
TSS: 11 mg/I
Clarity: clear
7-18-03
Total Kjeldahl N: < 0.5 mg/i
South Outfall
COD: < 50 mg/I
Bis(2-ethylhexyl)phthalate: not detected ugn
Test Parameters:
Lead, Total:< 0 .005 mg/i
Phenol: < 0.05 mg/I
MBAS:< 0.1 mg/m3
Outside of holding times.
BOD5: 7.1 mg/I
Outside of holding times.
TSS: 9 mg/I
Clarity: clear
7-20-03
Total Kjeldahl N: < 0.5 mg/I
North Outfall
COD: < 50' mg/I
Bis(2-ethylhexyl)phthalate: not detected ugn
Test Parameters:
Lead, Total:< 0 .005 mg/I
Phenol: < 0.05 mg/I
MBAS: 0.1 mg/m3
Outside of holding times.
BOD5: 5.6 mg/I
Outside of holding times.
TSS: 3 mg/I
Clarity: clear
,j Celanese
Tic —
A business of Celanese AG

Based on these results, there was no observed environmental on Buffalo Creek (the receiving water body for the
stormwater discharges.)
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this letter,
feel free to call me at [phone], or via email at [e-mail].
Since ely,
G
J h Ku
Sr. nvironmental Engineer

Certified Mail: 7001 1140 0002 8843 4544
Return Receipt to PEM Carter
April 10, 2003
PEMC03:09
NC Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
Attn: Mr. John Lesley
ABC DEFT. OF E04ROHPAENT
AMD NATURAL RESaJRCES
MOORESVILt E PF-M NAL OFFICE
F7 17
iicona
Ticona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Re: Second and Final Follow Up to the Release of Contact Waters into Stormwater Drainage
Ditch — 2/24/03 and 2/25103
(CNA Holdings Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Lesley
This report is a followup to the initial report (see attachment) which will provide the analytical results of the
stormwater parameters which we conducted per Permit No. NCS000064.
Incident # 1:
Reported on February 25, 2003 at 9:30 a.m. CNA Holdings, Inc — Ticona reported to you the release of
contact process waters by way of the north stormwater outfall. There were no observed environmental
impacts to Buffalo Creek. The addition to this table has been shaded in yellow. These parameters are
required under the permit issued to C N A Holdings, Inc.
Triangular Notch Weir Water Flow Calculation Tool:
Description: 2/24/03 North Outfall Discharge Due to Pump Breaker Trip
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calculated.
Discharge Details:
Liquid Height Above Notch:
1.5
in.
Measured
Date and Time at Begin.of
Discharge:
2/24/03 3:30
a.m.
Measured
Date and Time at End of
Discharge:
2/24/03 10:45
a.m.
Measured
Discharge
Volume:
Discharge Rate:
6.2
gpm
Calculated
Total Discharged:
2,682
gal.
Calculated
Test Parameters:
pH: 6.8
MBAS: 0.2 mg/m3
Odor: none
Foam: none
Color: water
white
COD: 50 mg/I
TSS: 22 mg/I
Clarity: clear
Oil sheen: none
Floating Solids:
no
Additional Tests
BOD5: 2.5 mg/I I Phenol: < 0.05 mg/l
ITotal N: 4.1 mg/I
Itotal Lead: < 0.005
mg/I
bis(2-ethylhexyl)phthalate: <10 ug.l
� Celanese
Ticona
A business of Celanese AG

5
_ �;:T �.

Incident # 2:
Reported on 2/26/03, information pertaining to the failure of the pump again releasing contact water
through the north stonnwater outfall. There were no observed environmental impacts to Buffalo Creek.
The addition to this table has been shaded in yellow. These parameters are required under the permit
issued to C N A Holdings, Inc.
Triangular Notch Weir Water Flow Calculation Tool:
Description:
2/25/03 North Outfall Discharge Due to Second Pump Breaker Trip
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
1.5
in.
Measured
Date and Time at Begin.of Discharge:
2/25/03 3:30
a.m.
Measured
Date and Time at End of Discharge:
2/25/03 15:35
p.m.
Measured
Discharge Volume:
Discharge Rate:
6.2
gpm
Calc.
Total Discharged:
4,470
gal.
Calc.
Test Parameters:
pH: 6.8
MBAS: 0.3 mg/m3
Odor: none
Foam: none
Color: water white
COD: 30 mg/I
TSS: 2 mg/I
Clarity: clear
Oil sheen: none
Floating Solids: no
Additional Tests
BOD5 < 2.4 mg/1
(Phenol: < 0.05 ,mgll
Total N: '3.6 mg/I
Total Lead: < 0.005 mg/1
bis(2-ethylhexyi)phthalate: <10 ug.1
Attached are copies of the Lab Report from Prism Laboratories, Inc. supporting the above information.
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carterMicona.com
Sincerely,
PEM Carter
Sr. Environmental Engineer

Lab, Report
PRISM
LABORATORIES, INC.
Full Service Analytical & Environmental Solutions
3/6/03 Page 1 of 8
Ticona Regional Dist. Center Customer Project ID: SW Ouffall
Attn: Johnny Ledford Customer Sample ID: N.OUTFALL 1
PO Box 87 Prism Sample ID: AC73927
Shelby, NC 28150 Login Group: 6320K8
Sample Collection Date/Time: 2/24/03 10:50
Lab Submittal Date/Time: 2/25/03 15:45
The following analytical results have'been obtained for the indicated sample which was submitted to this laboratory
TEST
TEST
REPORTING
METHOD
DATE/TIME
PARAMETER
RESULT
UNITS
LIMIT
REFERENCE
STARTED ANALYST
BIOCHEMICAL OXYGEN DEMAND, 5D
2.5
mg/L
2.4
SM 5210B
2/26/03 09:25 LC2
MBAS, SURFACTANTS
0.2
mg/L
0.10
SM 5540 C
2/26/03 07:18 CVM
Sample Comments:
Angela D. Overcash, V.P. Laboratory Services
NC Certification No. 402 - SC Certification No. 99012 - NC Drinking Water Cert. No. 37735 - FL Certification No. E87519
449 Springbrook Road A P.O. Box 240543 A Charlotte, NC 28224-0543
Phone: 704 / 529-6364 A Toll Free Number: 1-800 / 529-6364 A Fax: 704 / 525-0409

Lab -Report
PRISM
LABORATORIES, INC.
Full Service Analytical & Environmental Solutions
3/6/03 Page 2 of 8
Ticona Regional Dist. Center Customer Project ID: SW Outfall
Attn: Johnny Ledford Customer Sample ID: N.OUTFALL 2
PO Box 87 Prism Sample ID: AC73928
Shelby, NC 28150 Login Group: 63201<8
Sample Collection Date/Time: 2/24/03 10:50
Lab Submittal Date/Time: 2/25/03 15:45
The following analytical results have been obtained for the indicated sample which was submitted to this laboratory
TEST TEST REPORTING METHOD DATETTIME
PARAMETER RESULT UNITS LIMIT REFERENCE STARTED ANALYST
PHENOL DISTILLATION Completed EPA 420.1 3/3/03 18:15 AJR
PHENOL Less than mg/L 0.05 EPA 420.1 3/4/03 21:10 AJR
Sample Comments:
Samples appropriately preserved when received by laboratory.
Angela D. Overcash, V.P. Laboratory Services
NC Certification No. 402 - SC Certification No. 99012 - NC Drinking Water Cert. No. 37735 - FL Certification No. E87519
449 Springbrook Road A P.O. Box 240543 A Charlotte, NC 28224-0543
Phone: 704 / 529-6364 A Toll Free Number: 1-800 / 529-6364 A Fax: 704 / 525-0409

Lab- Report
PRISM
L.S LABORATORIES, INC.
Full Service Analytical & Environmental Solutions
3/6/03
Page 3 of 8
Ticona Regional Dist. Center
Customer Project ID: SW Outfall
Attn: Johnny Ledford
Customer Sample ID: N.OUTFALL 3
PO Box 87
Prism Sample ID: AC73929
Shelby, NC 28150
Login Group: 6320K8
Sample Collection Date/Time: 2/24/03 10:50
Lab Submittal Date/Time: 2/25/03 15:45
The following analytical results have been obtained
for the indicated sample which was submitted to this laboratory
TEST
TEST
REPORTING METHOD DATElrIME
PARAMETER _
RESULT
UNITS LIMIT REFERENCE STARTED ANALYST
TOTAL NITROGEN
4.1
mg/L 0.1 3/6/03 08:49 TAR
METALS DIGESTION
Completed
EPA 200.7 3/3/03 09:45 MBS
LEAD, TOTAL
Less than
mg/L 0.005 EPA 200.7 3/4/03 16:20 MSC
NITRITE AND NITRATE
2.8
mg/I 1.0 EPA 300.0 2/28/03 05:06 TAR
TOTAL KJELDAHL NITROGEN
1.3
mg/L 0.5 EPA 351.2 3/4/03 18:24 BCF
TKN DIGESTION BY EPA 351.2
Completed
EPA 351.2 2/28103 18:20 BCF
Sample Comments:
Samples appropriately preserved when received by laboratory.
Angela D. Overcash, V.P. Laboratory Services
NC Certification No. 402 - SC Certification No. 99012 - NC Drinking Water Cert. No. 37735 - FL Certification No. E87519
449 Springbrook Road A P.O. Box 240543 A Charlotte, NC 28224-0543
Phone: 704 / 529-6364 A Toll Free Number: 1-800 / 529-6364 A Fax: 704 / 525-0409

Lab ° Report
PRISM
LABORATORIES, INC.
Full Service Analytical & Environmental Solutions
3/6/03 Page 4 of 8
Ticona Regional Dist. Center
Customer Project ID: SW Outfall
Attn: Johnny Ledford
Customer Sample ID: N.OUTFALL 4
PO Box 87
Prism Sample ID: AC73930
Login Group: 63201<8
Shelby, NC 28150
Sample. Collection Date/Time: 2/24/03 10:50
Lab Submittal Date/Time: 2/25/03 15:45
The following analytical results have been obtained
for the indicated sample which was submitted to this laboratory
TEST
TEST
REPORTING METHOD DATE/TIME
PARAMETER
RESULT
UNITS LIMIT REFERENCE STARTED ANALYST
PREP. METHOD 625
Completed
EPA 625 2/28/03 12:00 SM
BIS-2-ETHYL HEXYL PHTHALATE
Less than
ug/L 10 SW846-8270 2/28/03 23:16 WAD
Sample Comments:
Angela D. Overcash, V.P. Laboratory Services
NC Certification No. 402 - SC Certification No. 99012 - NC Drinking Water Cert. No. 37735 - FL Certification No. E87519
449 Springbrook Road A P.O. Box 240543 A Charlotte, NC 28224-0543
Phone: 704 / 529-6364 ♦ Toll Free Number: 1-800 / 529-6364 A Fax: 704 / 525-0409

Lab 'Report
3/6/03
PRISM
LABORATORIES, INC.
Full Service Analytical & Environmental Solutions
Page 5 of 8
Ticona Regional Dist. Center
Customer Project ID: SW Outfall
Attn: Johnny Ledford
Customer Sample ID: N.OUTFALL 5
PO Box 87
Prism Sample ID: AC73931
Shelby, NC 28150
Login Group: 63201<8
Sample Collection Date/Time: 2/25/03 09:00
Lab Submittal Date/Time: 2/25/03 15:45
The following analytical results have
been obtained for the indicated sample which was submitted to this laboratory
TEST
TEST REPORTING METHOD DATE/TIME
PARAMETER
RESULT UNITS LIMIT REFERENCE STARTED ANALYST
BIOCHEMICAL OXYGEN DEMAND, 5D
Less than mg/L 2.4 SM 5210B 2/26103 14:20 LC2
MBAS, SURFACTANTS
0.3 mg/L 0.10 SM 5540 C 2/26/03 08:20 CVM
Sample Comments:
Angela D. Overcash, V.P. Laboratory Services
NC Certification No. 402 - SC Certification No. 99012 - NC Drinking Water Cert. No. 37735 - FL Certification No. E87519
449 Springbrook Road A P.O. Box 240543 A Charlotte, NC 28224-0543
Phone: 704 / 529-6364 A Toll Free Number: 1-800 / 529-6364 A Fax: 704 / 525-0409

Lab -Report
3/6/03
ftis III
LABORATORIES, INC.
Full Service Analytical & Environmental Solutions
Page 6 of 8
Ticona Regional Dist. Center
Customer Project ID: SW Outfall
Attn: Johnny Ledford
Customer Sample ID: KOUTFALL 6
PO Box 87
Prism Sample ID: AC73932
Shelby, NC 28150
Login Group: 6320K8
Sample Collection Date/Time: 2/25/03 09:00
Lab Submittal Date/Time: 2/25/03 15:45
The following analytical results have been obtained for the indicated sample which was submitted to this laboratory
TEST
TEST REPORTING METHOD DATE/TIME
PARAMETER
RESULT UNITS LIMIT REFERENCE STARTED ANALYST
PHENOL DISTILLATION
Completed EPA 420.1 3/3/03 20:55 AJR
PHENOL
Less than mg/L 0.05 EPA 420.1 3/4/03 21:10 AJR
Sample Comments:
Samples appropriately preserved when received by laboratory.
Angela D. Overcash, V.P. Laboratory Services
NC Certification No. 402 - SC Certification No. 99012 - NC Drinking Water Cert. No. 37735 - FL Certification No. E87519
449 Springbrook Road A P.O. Box 240543 A Charlotte, NC 28224-0543
Phone: 704 / 529-6364 A Toll Free Number: 1-800 / 529-6364 A Fax: 704 / 525-0409

Lab Report
PRISM
LABORATORIES, INC.
Full Service Analytical & Environmental Solutions
3/6/03 Page 7 of 8
Ticona Regional Dist. Center Customer Project ID: SW Outfall
Attn: Johnny Ledford Customer Sample ID: N.OUTFALL 7
PO Box 87 Prism Sample ID: AC73933
Shelby, NC 28150 Login Group: 6320K8
Sample Collection Date/Time: 2/25/03 09:00
Lab Submittal Date/Time: 2/25/03 15:45
The following analytical results have been obtained for the indicated sample which was submitted to this laboratory
TEST TEST REPORTING METHOD DATE/TIME
PARAMETER RESULT UNITS LIMIT REFERENCE STARTED ANALYST
TOTAL NITROGEN 3.6 mg/L 0.1 3/6/03 08:49 TAR
METALS DIGESTION Completed EPA 200.7 3/4/03 13:10 MBS
LEAD, TOTAL Less than mg/L 0.005 EPA 200.7 3/5/03 14:31 MSC
NITRITE AND NITRATE 2.8 mg/I 1.0 EPA 300.0 2/28/03 05:24 TAR
TOTAL KJELDAHL NITROGEN 0.8 mg/L 0.5 EPA 351.2 3/4/03 18:24 BCF
TKN DIGESTION BY EPA 351.2 Completed EPA 351.2 3/3103 18:44 BCF
Sample Comments:
Samples appropriately preserved when received by laboratory.
Angela D. Overcash, V.P. Laboratory Services
NC Certification No. 402 - SC Certification No. 99012 - NC Drinking Water Cert. No. 37735 - FL Certification No. E87519
449 Springbrook Road A P.O. Box 240543 A Charlotte, NC 28224-0543
Phone: 704 / 529-6364 A Toll Free Number: 1-800 / 529-6364 ♦ Fax: 704 / 525-0409

Lab. Report s
PRISM
LABORATORIES, INC,
Full Service Analytical & Environmental Solutions
3/6/03 Page 8 of 8
Ticona Regional Dist. Center
Customer Project ID: SW Outfall
Attn: Johnny Ledford
Customer Sample ID: N.OUTFALL 8
PO Box 87
Prism Sample ID: AC73934
Shelby, NC 28150
Login Group: 6320K8
Sample Collection Date/Time: 2/25/03 09:00
Lab Submittal Date/Time: 2/25/03 15:45
The following analytical results have been obtained for the indicated sample which was submitted to this laboratory
TEST
TEST REPORTING METHOD DATE/TIME
PARAMETER
RESULT UNITS LIMIT REFERENCE STARTED ANALYST
PREP. METHOD 625
Completed EPA 625 2/28/03 12:00 SM
BIS-2-ETHYL HEXYL PHTHALATE
Less than ug/L 10 SW846-8270 3/1/03 00:02 WAD
Sample Comments:
Angela D. Overcash, V.P. Laboratory Services
NC Certification No. 402 - SC Certification No. 99012 - NC Drinking Water Cert. No. 37735 - FL Certification No. E87519
449 Springbrook Road A P.O. Box 240543 A Charlotte, NC 28224-0543
Phone: 704 / 529-6364 A Toll Free Number: 1-800 / 529-6364 A Fax: 704 / 525-0409

``��'�� WASTEWATER CHAIN OF CUSTODY
�J�ISM
� /� PAGE _I OF �lJ QUOTE q TO ENSURE PROPER BILLING:
i 1 M /
LABORATORIES, INC. Project Name: /' '' '�,:� �� L• f'r�rr,•�
Short Hold Analysis: (Yes) (No) UST Project: (Yes) (No)
Full Service Analytical & Environmental Solutions *Please ATTACH any project specific reporting
449 Springbrook Road • P.O. Box 240543 • Charlotte, NC 28224-0543 provisions and/or QC Requirements
Phone:[phone] • Fax:[phone]
Client Company Name: r (_ fitInvoice To:
Report To/Contact Name: �F ; 'i•1 ',,I' I' r Address:
Samples INTACT upon arrival?
Received ON WET ICE? Temp _
PROPER PRESERVATIVES indicated?
Received WITHIN HOLDING TIMES?
CUSTODY SEALS INTACT?
VOLATILES rec'd W/OUT HEADSPACE?
PROPER CONTAINERS used?
YES NO N/A
Li- -
Fiepomng Address: / . 1, . .�, r..-,c :•5 � ., j /,
�� ,. �: . •: r > Purchase Order No./Billing Reference
TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL
r r :�
Requested Due Date 1 Day U 2 Days rJ 3 Days U 4 Days U 5 Days
Phone: J %' 'i {!'r'� - !��/t �! Fax (Yes) (No):
Certification:
NELAC USAGE FL
NC L/
U 6-9 Days IJ Standard 10 days
Site Location Name: T/ r w %�
SC NA
�S�mples received after 15:00 will be processed next business day.
Site Location Physical Address: <.r Turnaround time is based on business days, excluding weekends and holidays.
Water Chlorinated:
-OTHER
YES _ NO
(SEE REVERSE SIDE FOR RUSH TURNAROUND FEES)
Sample Iced Upon Collection: YES v f NO
/
SAMPLE
TYPE
CONTAINER TYPE
AND SIZE (ML)
PRESERVATIVES USED
ANALYSES TO BE PERFORMED ON THE SAMPLES H '
y _,
SUB
PRISM
CLIENT SAMPLE
(:'
LAB
LAB
I.D.
CERT.
ID NO.
ID NO.
i
c
7.-pGrab
Plastic
Glass
Other
None
Iced
HCI
NaOH
HNO3
H2SO4
pH
BOD
TSS
Cd
Cr
Cu
Pb
Ni
Ag
Zn
O&G
ON
N
,�,
,L'
as
I
\1
?/
i
ti. ./1
Q`
(."K
i
n
1L�./. f ' ZZAffiriation
Sampler's Signature.��1 ' �•'�� Sampled By (Print Name) /'`� 'Y"11 /' F� � .�
Upon relinquishing' this Chain of Custody!i 3 your authorization for Prism to proceed with the analysers as requested above. Any changes must be
submitted in writiri fo the Prt�m Project Mana er. There will be char es for an changes after analyses have been initialized.
R• elr1tI qu. i�s' Receivedi eiDatd MilitarylHours
eBy: (Signalu,c)._;
I.A ,P•r 'r,l:
Additional Comments:
.. ,� /.. �f'� •i �i,°
Relj
quished By: (Signature) (.•` Received By: (Signature) Date
%i 1� I{.� ` r_, I { ,. Site Arrival Time:
y !
Relinquished B : Si n�ture
q y ( g ; . Received For Prism Labotatories By: Date'
/ /"
�) ,;J Site Departure Time:
!)
,_fir'_..__..._ F�
Field Tech Fee:
Method of Shipment: NOTE: ALL SAMPLE COOLERS SHOULD BE TAPED SHUT WITH CUSTODY SEALS FOR TRANSPORTATION TO THE LABORATORY. Log -in Group No.
c` (-' �) C. _
SAMPLES ARE NOT ACCEPTED AND VERIFIED AGAINST CDC UNTIL RECEIVED AT THE LABORATORY.
tf
Mileage:
❑ Fed Ex ❑UPS ❑ Hand -delivered L9 Prism Field Service ❑Other
Composite Type: FLOW TIME HAND (circle one)
Start Date & Time for Composite Sampler: /
Stop Date & Time for Composite Sample: /
Date & Time Composite Sample Collected: /
Total Hours Composite Collected Over:Hours.
End Flow:
Start Flow:
Total:
Hrs
Hrs
Hrs
Gal / Cu Feet
(circle one)
Date & Time Grabs) Taken: , /r! t� / ; ^' ' () Hrs
Field pH Meter Calibrated: Yes No
Field pH Result: Analyst's Initials:
Field Temp. Result: Analyst's Initials:
Sampler Interrupted: Yes_ No If Yes, Why?
F1f\IA1 RFPORT

WASTEWATER CHAIN OF CUSTODY
PRISMPAGE ,�_", OF QUOTE H TO ENSURE PROPER BILLING:
LABORATORIES, INC. Project Name: / • ' ` C ` _, •% - !'r 4
Short Hold Analysis: (Yes) (No) UST Project: (Yes) (No)
Full Service Analytical & Environmental Solutions *Please ATTACH any project specific reporting
449 Springbrook Road • P.O. Box 240543 • Charlotte, NC 28224-0543 provisions and/or OC Requirements
Phone:[phone] • Fax:[phone]
Client Company Name: ' ' ' /f/ Invoice To:
Report To/Contact Name: 1 i i t ; f ;`r ,. Address:
Samples INTACT upon arrival? �)
Received ON WET ICE? Temp �(
PROPER PRESERVATIVES indicated?
Received WITHIN HOLDING TIMES?
CUSTODY SEALS INTACT?
VOLATILES rec'd W/OUT HEADSPACE?
PROPER CONTAINERS used?
Reporting Address: 1-, " , % 0 'K. " '
(._;i` it
Purchase Order No./Billing Reference
TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL
i
Phone: Fax (Yes) (No):
!---
Requested Due Dale . 1 Day ❑ 2 Days ❑ 3 Days ❑ 4 Days ❑ 5 Days
Certification:
NELAC USACE
FL NC
Site Location Name: � ` i % �� � "/�
❑ 6-9 Days r_lStandard 10 days
SC OTHER
NA
a pies received after 15:00 will be processed next business day.
Site Location Physical Address: ;�T? i i� i //;' fiC �� t rrr '!;T rnaround time is based on business days, excluding weekends and holidays.
Water Chlorinated: YES _ NO
`- �•flii �1Jr, 1 L �• - %
/ (SEE REVERSE SIDE FOR RUSH TURNAROUND FEES)
Sample Iced Upon Collection: YES
NO —
SAMPLE
TYPE
CONTAINER TYPE
AND SIZE (ML)
PRESERVATIVES USED
ANALYSES TO BE PERFORMED ON THE SAMPLES
SUB
PRISM
CLIENT SAMPLE
LAB
LAB
I.D.ERT
D'
� �!�
�
ID NO..
ID NO.
7.-pGrab
Plastic
Glass
Other
None
Iced
HCI
NaOH
HNO3
HzSO4
pH
BOD
TSS
Cd
Cr
Cu
Pb
Ni
Ag
Zn
O&G
ON-
as N
°
11
y
,
rX
••
••
.(0
Sampler's Signature : ' t { -„ , -; ;-
Sampled By (Print Name) % i? >!, e ' ..� r 5 t'<. % .� 3 / Affiliation
Upon relinquishing, toil, hain of(Ccustody is' our authorization for Prism to proceed with the analyses as requested above. Any changes must be
submitted in writingfor the Prism Project Ma a er. There
will be charges for any changes after analyses have been initialized.
Reli wished By: (Signatyre) r
�..
Received By: (Signature)Dal Military/Hours
Additional Comments:7FieldTech
•
R linquishe By: (Signature)
Received By: (Signature)_ Date
" ,
Time:
Relinquished By: (Signature)'.,`) :. ;';;
Received FFor Prism Laboratories By: Date'
�� j`
me:
ime•
Sitere Ti
/-----�•-••--•-'•""'-"' ] /
ee:
Method of Shipment: NOTE: ALL SAMPLE COOLERS SHOULD BE TAPED SHUT WITH CUSTODY SEALS FOR TRANSPORTATION TO THE LABORATORY. Log -in Group No.
t Al
SAMPLES ARE NOT ACCEPTED AND VERIFIED
AGAINST COC UNTIL RECEIVED AT THE LABORATORY.
Mileage:
��
❑ Fed Ex ❑ UPS ❑ Hand -delivered ❑ Prism Field Service - ❑ Other \ * •� U
`� /� �)
Composite Type: FLOW TIME HAND (circle one)
Start Date & Time for Composite Sampler: /
Stop Date & Time for Composite Sample: /
Date & Time Composite Sample Collected: /
Total Hours Composite Collected Over:Hours.
End Flow:
Start Flow:
Total:
Hrs
Hrs
Hrs
Gal / Cu Feet
(circle one)
Date & Time Grab(s) Taken: Li' I'? / r�! % 2 e) ! Hrs
Field pH Meter Calibrated: Yes No
Field pH Result: Analyst's Initials:
Field Temp. Result: Analyst's Initials:
Sampler Interrupted: Yes_ No If Yes, Why?
FINAL REPORT

COPY COPY COPY COPY COPY
Certified Mail: 7001 1140 0002 8843 4568
Return Receipt to PEM Carter
March 3, 2003
PEMC03:07
NC Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
Attn: Mr. John Lesley
Re: Release of Contact Waters into Stormwater Drainage Ditch — 2124/03 and 2125/03
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Lesley
This report serves as the written requirement for the two incidents listed below.
Incident # 1:
Per our telephone conversation on February 25, 2003 at 9:30 a.m. CNA Holdings, Inc — Ticona reported to
you the release of contact process waters by way of the north stormwater outfall. The first incident
occurred on 2/24/03, discovered at 10:20 a.m. The pump, which is used to move contact process waters,
tripped its circuit breaker which was immediately reset by 10:45 a.m. the same day, stopping any further
release from the north stormwater outfall. We were unable to define the exact starting time of this release,
so a "worse case" time of 3:30 a.m. has been used for the calculation of volume released. This starting
time was the last time the outfall was inspected and found to be in compliance. Based on the triangular
notch weir, height and time of the discharge, approximately 2,682 gallons were released during the
timeframe depicted in this table. An examination of the drainage ditch indicated that the quantity of water
released did flow to Buffalo Creek. There were no observed environmental impacts to Buffalo Creek.
Triangular Notch Weir Water Flow Calculation Tool:
Description: 2/24/03 North Outfall Discharge Due to Pump Breaker Trip
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
1.5
in.
Measured
Date and Time at Begin.of
Discharge:
2/24/03 3:30
a.m.
Measured
Date and Time at End of
Discharge:
2/24/03 10:45
a.m.
Measured
Discharge
Volume:
Discharge Rate:
6.2
gpm
Calc.
Total Discharged:
2,682
gal.
Calc.
Test Parameters:
pH: 6.8
MBAS: 0.2 mg/m3
Odor: none
Foam: none
Color: water white
COD: 50 mg/I
TSS: 22 mg/I
Clarity: clear
Oil sheen: none
IFloating Solids: no

COPY COPY COPY COPY COPY
In addition to the above test parameters: samples of the released water were submitted to outside contract
laboratory (Prism Laboratory) for the following tests: BOD5, phenol, total lead, bis(2-ethylhexyl)phthalate
and total nitrogen. Throughout 2/24/03, the pump operated as designed.
Incident # 2:
On 2/25/03, it was discovered at 9:30 a.m. when I was discussing the first incident with you and later an
official followup phone report on 2/26/03 at 8:28 a.m. with information pertaining to the failure of the pump
again releasing contact water through the north stormwater outfall. In summary: the pump was pulling too
many amps and tripped the circuit breaker providing power to the pump. The probable cause was debris
behind the impeller that caused high current loading in the motor. Both pump and motor were replaced.
Initially the pump was repaired but on restart, motor damage was detected so the entire motor pump
assembly was replaced with the spare motor, stopping any further release from the north stormwater
outfall. We were unable to define the exact starting time of this release, so a "worse case" time of 3:30
a.m. has been used for the calculation of volume released. This starting time was the last time the outfall
was inspected and found to be in compliance. Based on the triangular notch weir, height and time of the
discharge, approximately 4,470 gallons were released during the timeframe depicted in this table. An
examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo Creek.
There were no observed environmental impacts to Buffalo Creek.
Triangular Notch Weir Water Flow Calculation Tool:
Description:
2/25/03 North Outfall Discharge Due to Second Pump Breaker Trip
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
1.5
in.
Measured
Date and Time at Begin.of Discharge:
2/25/03 3:30
a.m.
Measured
Date and Time at End of Discharge:
2/25/03 15:35
p.m.
Measured
Discharge Volume.
Discharge Rate:
6.2
gpm
Calc.
Total Discharged:
4,470
gal.
Calc.
Test Parameters:
pH: 6.8
MBAS: 0.3 mg/m3
Odor: none
Foam: none
Color: water white
COD: 30 mg/I
TSS: 2 mg/I
Clarity: clear
Oil sheen: none
IFloating Solids: no
In addition to the above test parameters: samples of the released water were submitted to outside contract
laboratory (Prism Laboratory) for the following tests: BOD5, phenol, total lead, bis(2-ethylhexyl)phthalate and
total nitrogen.
Preventive action: A spare pump rated as a "sewage ejector" pump capable of handling more debris than a
standard pump with a screen on the inlet to the pump has been purchased. Readiness for immediate motor
replacement will be the action taken to eliminate or minimize releases having the potential to leave through
stormwater outfalls.

COPY COPY COPY COPY COPY
CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(a.ticona.com
Sincerely,
PEM Carter
Sr. Environmental Engineer

Certified Mail: 7001 1140 0002 8843 4568
Return Receipt to PEM Carter
March 3,, 2003
PEMC03:07
AND NATURAL RESGURME
1900RESVl> ..: i'.rK�6a�
NC Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street
Mooresville, NC 28115���
Attn: Mr. John Lesley
licona
Ticona
Shelby Plant
Highway 198
Shelby, NC 28152
Telephone [phone]
Re: Release of Contact Waters into Stormwater Drainage Ditch — 2/24/03 and 2/25/03
(CNA Holdings, Inc., Shelby Plant; Stormwater Permit No. NCS000064)
Dear Mr. Lesley
This report serves as the written requirement for the two incidents listed below.
Incident # 1:
Per our telephone conversation on February 25, 2003 at 9:30 a.m. CNA Holdings, Inc — Ticona reported to
you the release of contact process waters by way of the north stormwater outfall. The first incident
occurred on 2/24/03, discovered at 10:20 a.m. The pump, which is used to move contact process waters,
tripped its circuit breaker which was immediately reset by 10:45 a.m. the same day, stopping any further
release from the north stormwater outfall. We were unable to define the exact starting time of this release,
so a "worse case" time of 3:30 a.m. has been used for the calculation of volume released. This starting
time was the last time the outfall was inspected and found to be in compliance. Based on the triangular
notch weir, height and time of the discharge, approximately 2,682 gallons were released during the
timeframe depicted in this table. An examination of the drainage ditch indicated that the quantity of water
released did flow to Buffalo Creek. There were no observed environmental impacts to Buffalo Creek.
Triangular Notch Weir Water Flow Calculation Tool:
Description: 2/24/03 North Outfall Discharge Due to Pump Breaker Trip
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
1.5
in.
Measured
Date and Time at Begin.of
Discharge:
2/24/03 3:30
a.m.
Measured
Date and Time at End of
Discharge:
2/24/03 10:45
a.m.
Measured
Discharge
Volume:
Discharge Rate:
6.2
gpm
Calc.
Total Discharged:
2,682
gal.
Calc.
Test Parameters:
pH: 6.8
MBAS: 0.2 mg/m3
Odor: none
Foam: none
Color: water white
COD: 50 mg/I
TSS: 22 mg/I
Clarity: clear
Oil sheen: none
lFloating Solids: no
� Celanese
Ticona
A b—n— of Cdan AG

In addition to the above test parameters: samples of the released water were submitted to outside contract
laboratory (Prism Laboratory) for the following tests: BOD5, phenol, total lead, bis(2-ethylhexyl)phthalate
and total nitrogen. Throughout 2/24/03, the pump operated as designed.
Incident # 2:
On 2/25/03, it was discovered at 9:30 a.m. when I was discussing the first incident with you and later an
official followup phone report on 2/26/03 at 8:28 a.m. with information pertaining to the failure of the pump
again releasing contact water through the north stormwater outfall. In summary: the pump was pulling too
many amps and tripped the circuit breaker providing power to the pump. The probable cause was debris
behind the impeller that caused high current loading in the motor. Both pump and motor were replaced.
Initially the pump was repaired but on restart, motor damage was detected so the entire motor pump
assembly was replaced with the spare motor, stopping any further release from the north stormwater
outfall. We were unable to define the exact starting time of this release, so a "worse case" time of 3:30
a.m. has been used for the calculation of volume released. This starting time was the last time the outfall
was inspected and found to be in compliance. Based on the triangular notch weir, height and time of the
discharge, approximately 4,470 gallons were released during the timeframe depicted in this table. An
examination of the drainage ditch indicated that the quantity of water released did flow to Buffalo Creek.
There were no observed environmental impacts to Buffalo Creek.
Triangular Notch Weir Water Flow Calculation Tool:
Description:
2/25/03 North Outfall Discharge Due to Second Pump Breaker Trip
Variable
Value
Units
Source
Weir Geometry:
Total Weir Length:
70
in.
Measured
Notch Length at Top:
26
in.
Measured
Notch Depth:
13
in.
Measured
Notch Angle:
45
deg.
Calc.
Discharge Details:
Liquid Height Above Notch:
1.5
in.
Measured
Date and Time at Begin.of Discharge:
2/25/03 3:30
a.m.
Measured
Date and Time at End of Discharge:
2/25/03 15:35
p.m.
Measured
Discharge Volume:
Discharge Rate:
6.2
gpm
Calc.
Total Discharged:
4,470
gal.
Calc.
Test Parameters:
pH: 6.8
MBAS: 0.3 mg/m3
Odor: none
Foam: none
Color: water white
COD: 30 mg/I
TSS: 2 mg/I
Clarity: clear
Oil sheen: none
lFloating Solids: no
In addition to the above test parameters: samples of the released water were submitted to outside contract
laboratory (Prism Laboratory) for the following tests: BOD5, phenol, total lead, bis(2-ethylhexyl)phthalate and
total nitrogen.
Preventive action: A spare pump rated as a "sewage ejector" pump capable of handling more debris than a
standard pump with a screen on the inlet to the pump has been purchased. Readiness for immediate motor
replacement will be the action taken to eliminate or minimize releases having the potential to leave through
stormwater outfalls.

CNA Holdings, Inc. — Ticona Plant, is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information submitted with this
notification letter, feel free to call me at 704/480-4900, or via email at pem.carter(o-)-ticona.com
Sincerely,
PEM Carter
Sr. Environmental Engineer

MOORESVILLE REGION
WATER. QUALITY SECTION
Sewage Spill Reporting Record -
NLS 000o (P4
Facility Name or Permit No.: (, , i �,, , s ICI r r))j A /PiL90
Spill Location (including nearest named or numbered road) : %S7s a 1 r„ r, ICs btn rr, P./ . s..V 11-1hl C
Date and Time of spill: 21,aQ b3 3 3 110�
Recurrent Spill Location ? ❑ No ❑ Yes If yes , give approximate dates -of -past spills:
Volume of Spill: 7 D Gallons
Volume Entering Surface Water: _4 A Gallons
Name of Stream Impacted:
Fish Kill : Yes No. of Fish Killed
Other Damages (A N,.�'fC�!-��,
` l;, - t . " --- --- --
Reported By : ?-fig-- �� �( �-fi�_ Telephone No.:
Report Date & Time: /
Report Received By
Rezulatory Action(s) Review Evaluation __-- -_ Enforcement
-- No Action Needed -
Comments
�,,1) �_� 1 0v /); I fk.Z �---

MOORESVILLE REGION
WATER QUALITY SECTION
C cv'mp' r Coo)", /w w �� -
e Spill Reporting Record
Facility Name or Permit No.: CIS) A- #rL-NA1 j7I-rjf n4) F,4uL)7� /4eH NGS 0D00k14'
Spill Location (including nearest named or numbered road) : 2S25- OCAc (b),►r€4 Qf )b,..l
Date and Time of spill: 10 !fin t Z)2 �f7
Recurrent Spill Location ? �lo ❑ Yes If yes, give approximate -dates -of -past -spills:— --
Volume of Spill: 2 Gallons
T
Volume Entering Surface Water: , I . s�Z- Gallons --
Name of Stream Impacted: U T Z-in eC-J L
Z/.23 - 424
Fish Kill : Yes No. of Fish Killed
Other Damages : f) [I D M y► Afog S n n %r'J
Reported By: 'N�m CA L Telephone No.: �2 D 4- .4- 0--
Report Date & Time : Q Ct�
Report Received By:
Regulatory Action's) : Review Evaluation Enforcement
No Action Needed
Comments: � A v Y\ e U AJ b fl el ) V /� Pe F .4 �" -, a Lt� 7�4 V), -% � 1p I Al AA � -

of w ArF9
Q�W
rq r NCDENR
John Groves
CNA Holdings, Inc.
P.O. Box 87
Shelby, NC 28151
Dear Permittee:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
%C DEPT. K EMliiGd�a"�PPR11V
Alan Wl �� gf� LWt. 6
Q r' 'si�jAjkCEP
er�bua9y� GDP
FA
January 3 2003`
Subject: Renewal Notice
NPDES Permit NCO004952
Shelby plant
Cleveland County
The subject permit expires on August 31, 2003. North Carolina Administrative Code (15A NCAC 2H.0105(e)) requires
that an application for permit renewal be filed at least 180 days prior to expiration of the current permit. If you have already
mailed your renewal application, you may disregard this notice.
To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than March 4, 2003.
Failure to request renewal of the permit by this date may result in a civil assessment of at least $500.00. Larger penalties may be
assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after August 31, 2003 (or if continuation of the permit is desired), the current
permit must be renewed. Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1
and could result in assessment of civil penalties of up to $25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact Bob Sledge of the
Division's Compliance Enforcement Unit at [phone], extension 547. You may also contact the Mooresville Regional
Office at [phone] to begin the rescission process.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with
the permit renewal application. If you have any questions, please contact Valery Stephens at [phone], extension 520.
Sincerely,
Q,g
l
Charles H. Weaver, Jr.
NPDES unit
cc: Central Files
VI6rc �vtllelegional Office, Water Quality Section d
NPDES File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 520 (fax) 919 733-0719
VisirusONTHEINTERNET@http://h2o.enr.state.nc.us/NPDES e-mail: [e-mail]

NPDES Permit NC0004952
Shelby plant
Cleveland County
The following items are REQUIRED for all renewal packages:
❑ A cover letter requesting renewal of the permit and documenting any changes at the facility since
issuance of the last permit. Submit one signed original and two copies.
❑ The completed application form (copy attached), signed by the permittee or an Authorized
Representative. Submit one signed original and two copies.
❑ If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
the renewal package, written documentation must be provided showing the authority delegated to any
such Authorized Representative (see Part II.B.11.b of the existing NPDES permit).
❑ A narrative description of the sludge management plan for the facility. Describe how sludge (or other
solids) generated during wastewater treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed
original and two copies.
The followinea items must be submitted by anv Municipal or Industrial facilities discharging
process wastewater:
Industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Code of Federal
Regulations, Part 122) and ALL Municipal facilities with a permitted flow >_ 1.0 MGD must submit a
Priority Pollutant Analysis (PPA) in accordance with 40 CFR Part 122.21.
The above requirement does NOT apply to privately owned facilities treating 100010
domestic wastewater, or facilities which discharge non process wastewater (cooling
water, filter backwash, etc.)
PLEASE NOTE:
Due to a change in fees effective January 1, 1999, there is no renewal fee required with your
application package.
Send the completed renewal package to:
Mrs. Valery Stephens
NC DENR / Water Quality / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

OP W ATF Michael F. Easley, Governor
William G. Ross Jr., Secretary
. QG North Carolina Department of Environment and Natural Resources
Gj rAlan W. Klimek, P.E. Director
1 Division of Water Quality
O `C
June 25, 2002
221
Mr. Pem Carter
CNA Holdings, Inc. - Ticona Facility
P.O. Box 87
Shelby, NC 28152-0087
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr. Carter:
Enclosed is a report for the inspection performed on May 15, 2002 by Mr. Chester
E. Whiting. Where deficiencies are cited in this report, a response is required as well as
for all lettered comments and/or recommendations. Within thirty days of receipt, please
supply this office with a written item for item description of how these deficiencies,
comments and/or recommendations were corrected. If the deficiencies cited in the
enclosed report are not corrected, enforcement actions will be recommended. For
certification maintenance, your laboratory must continue to carry out the requirements set
forth in 15A NCAC for 2H .0800.
Copies of the checklists completed during the inspection may be requested from
this office. Thank you for your cooperation during the inspection. Please contact us at
919-733-3908, if you have questions or need additional information.
Sincerely,
G2�� ANpa-l-l"
James W. Meyer
Laboratory Section
Enclosure
cc: Chester E. Whiting
Mooresville Regional Office
NCDENR
Laboratory Section N. C: Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623
[phone] Fax: [phone] Internet: dwqlab.org Customer Service 1-800-623-7748

ON -SITE INSPECTION REPORT
Laboratory Name:
Laboratory Address:
Laboratory Cert. Number:
Inspection Type:
Inspection Date:
Inspector(s):
Local Contact Person(s):
I. INTRODUCTION:
Ticona, Shelby, WW Laboratory
_ P.O. Box 87,'Shelby, NC 28150
221
Maintenance
May 15, 2002
Chet Whiting
Ms. Pem Carter
The above named laboratory was inspected to verify compliance with 15A NCAC 2H .0800 for the
analysis of environmental samples.
I1. OVERVIEW:
The laboratory was neat and well organized. Laboratory personnel provided the inspector(s) with all
materials, and information requested for examination.
III. DEFICIENCIES, REQUIREMENTS, COMMENTS, AND RECOMMENDATIONS:
GENERAL LABORATORY:
A. COMMENT: We are stronglyrecommending that the method code for each analysis be documented
on the bench work sheet.
B. COMMENT: The laboratory has a bench sheet that has more than one analytical procedure.
RECOMMENDATION: We strongly recommend that each parameter have it's own individual bench
sheet.
MICROBIOLOGY (FECAL COLIFORM MF):
C. COMMENT: No comparison test is conducted before a new lot of consumables are put into use.
REQUIREMENT: It is required that when a new lot of culture medium, pads, or membrane filters is to
be used, a comparison of the current lot in use, (reference lot) against the new lot (test lot), be made.
As a minimum, make single analyses on five positive samples. Ref: Standard Methods, 18th Edition -
Method 9020 B.3d.(page 9-7)
D. COMMENT: The water bath gave indications for stability problems. It may be related to its location
near the window and it is suggested that a new location is suggested. If however the stability has not
been improved it will be necessary to repair, or replace the unit.
BIOCHEMICAL OXYGEN DEMAND:
COMMENT: The laboratory is contracting this analysis out until quality control issues can be resolved.

Ticona Shelby W W Laboratory Audit 2
CHEMICAL OXYGEN DEMAND:
E. COMMENT: The temperature of the COD reactor is not recorded.
REQUIREMENT: Document the temperature of the COD reactor. ref: 15A NCAC 2H .8085 (7), & (7) (A).
SUSPENDED RESIDUE:
COMMENT: The sample duplicate acceptance criteria is 20%. The recommendation was for 10%, or
20% RPD. RPD provides more flexibility over a range of concentrations. The laboratory should easily be
able to meet the recommended criteria.
RPD = (A - B) x 100
+ B)
2
IV. - CONCLUSION:
The laboratory does a good job overall.. All deficiencies from the previous audit were corrected.
Laboratory personnel were professional and courteous throughout the audit process.
Correcting the above cited comments and implementing the recommendations will help this lab to
produce quality data and meet certification requirements. Please respond to all lettered comments.
COMMENT: The annual maintenance audit serves as an excellent marker to remind laboratories to
review SOP documents and Q.A./Q.C. Plans. This is a good time make sure that these documents are
current, and to make additions indicated by the maintenance audit. Please be reminded of the following:
The laboratory should document any methods used for NPDES analysis in Standard Operating
Procedure (SOP) format. Copies of Standard Operating Procedures should be maintained as a part of the
supporting documentation pertinent to each certified analysis. The SOP should contain concise, plain
language instructions that will allow all personnel that may be expected to perform an analysis all
information necessary to properly conduct the test and meet documentation requirements.
The laboratory can develop and maintain SOPs as part of the required Laboratory Analytical Quality
Control Program document.
Each laboratory shall develop and maintain outlining the analytical quality control practices used for the
parameters included in their certification. Supporting records shall be maintained as evidence that these
practices are being effectively carried out. ref.- 15A NCAC 2H .0805 (a)(7) pq. 6.
Report prepared by: Chet Whiting Date: June 17, 2002

STATE OF NORTH CAROLINA
EVALUATION OF ENVIRONMENTAL LABORATORY AUDIT
To improve our service to you and to maintain the quality of the laboratory inspection process, we request that you
complete the following evaluation. Since your comments are important to us, please use the reverse side of this
form to discuss issues not addressed in the items listed below. Please return this form within five (5) days of
this audit. Completing and returning this form is voluntary.
Please return this evaluation to:
James W. Meyer
EHNR/DWQ Chemistry Laboratory
4405 Reedy Creek Road
Raleigh, NC 27607-6445
Certification Officer's Name: Chet Whiting
Inspection Date:
15, 2002
Please evaluate the following using a 10 point scale with 1= poor and 10= excellent
��� ITEMS
Disagree
Neutral
Agree
1 2 3
6
7 S> 10" .
r
:4':s
1.� The certification officer contacted you in advance for your audit
and answered your questions.
2. The certification officer arrived on time and at the agreed place.
3. The certification officer's dress and appearance were professional
and business like.
4. The certification officer's questions and comments were pertinent
to laboratory operations and inspection.
S. The certification officer interacted with your staff in a courteous
and professional manner.
6. The audit results were su— ized in an exit interview following
the survey.
7. Correcting the deficiencies noted in the audit results will improve
your laboratory's operations and data quality.
8. The certification officer's comments have been/will be helpful to
your laboratory staff and laboratory operations.
9. The N.C. Environmental Laboratory Certification Program is
beneficial to your laboratory's analytical performance.
ON A SCALE OF 1 TO 10 (WITH 10 = EXCELLENT) PLEASE RATE NORTH CAROLINA'S ENVIRONMENTAL LABORATORY CERTIFICATION
PROGRAM
ON A SCALE OF 1-TO 10 (WITH 10 = EXCELLENT) PLEASE RATE your certification officer
Laboratory Name Ticona, Shelby
Date:
Signature( Optional)
PLEASE USE THE BACK OF THIS FORM FOR ANY ADDITIONAL COMMENTS THAT YOU MAY HAVE CONCERNING THIS PROGRAM OR THE
CERTIFICATION OFFICER.

OF W ATFR
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
� Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
May 23, 2002
Ms. Pem Carter, Sr. Environmental. Engineer
CNA Holdings, Inc.
Post Office Box 87
Shelby, North Carolina 28151
Subject: Compliance Evaluation Inspection
CNA Holdings, Inc. WWTP
NPDES Permit No. NC0004952
Cleveland County, N.C.
Dear Ms. Carter:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on May 15, 2002, by Mr. Wes Bell of this Office. Please inform the
facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed
report.
The report should be self-explanatory; however, should you have any questions concerning
this report, please do not hesitate to contact Mr. Bell or me at [phone].
Enclosure
cc:
fJCDENR
Customer Service
1 800 623-7748
Sincerely,
2 A,� M— C� J V, 0.�
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Cleveland County Health Department
Division of Water Quality 919 North Main Street Mooresville, NC 28115
Phone [phone]
Fax [phone]

US Environmental Protection Agency, Washington, D.C., 20460
yA
-jr
Fbmi Approved.
OMB No.2040-0057
5
Water Compliance Inspection Report
s
Approval Expires 8-31-98
NC Division of Water Quality / Mooresville Regional Office NCDENR.
-: bC.. r� r � "•+.' _a.,� t -� -�� Y t. ? .J /� wdc i S.r� Y '7 �-+ A Y. �`- uY- Z'.. � ,r �,(- at "tt �: F3 's4"!k i-, tK. ?'S"Sr . k .
'7n �
Transaction Code NPDES No. Yr/Mo/Day Inspection Type Inspector Facility Type
N 5 NC0004952 02/05/15 C S 2.
Remarks:
Inspection Work Days Facility Evaluation Rating BI QA ..........Reserved............
1.5 4 N N
.. 2..Yi''�'�' .f'' 2� b.: •.n.r _ ', i d:. 1 i.: 1 l7 nCB
echo Facility Data
, .,:
Name and Location of Facility Inspected:
Entry Time:
Permit Effective Date:
CNA Holdings, Inc. WWTP
10:24 am
99/5/01
Shelby Plant
NC Highway 198
Exit Time/Date:
Permit Expiration Date:
South of Shelby
1:50 pm
03/08/31
Cleveland County, North Carolina
02/OS/15
Name(s) of On -Site Rep resentative(s)/Title(s)/Pho ne No(s)/Fax No(s):
Mr. Johnny Ledford/ORC/704-480-4692
Mr. Pem Carter/Sr. Environmental Engineer/704-480-4900
Mr. Joe Kendrick/Laboratory Supervisor
Name and Address of Responsible Official:
Title:
Mr. Pem Carter
Sr. Environmental Engineer
CNA Holdings, Inc.
Post Office Box 87
Phone No:
Contacted?
Shelby, North Carolina 28151
704-480-4900
Yes
Section C AreasaEYaluated:Durm Ins echon
P
Checkonly;thoseareas valuated '
-x,
"ItZz
_.-
X Permit X Flow Measurement X Operations & Maintenance X Sewer Overflow
X Records/Reports X Self -Monitoring Program X Sludge Handling/Disposal Pollution Prevention
X Facility Site Review Compliance Schedules Pretreatment Multimedia
X Effluent/Receiving Waters X Laboratory Storm Water Other:
�Summaiw�of�Tin`dmgs�Commeuts� �� _� �� �.,z.£�.�..#•��_ .�`'"�G �
.... �".Y�f-_X........_. -..'�' .-.- .-.._�..• •_,. -::t . _.:..c' =.hav_.�.. ,�� .•-e. F � _ _z ..._.._. _...+f,.-.,....--..._.w..�i.Y..!" ��dv'3.�E�3tY�d-`L �'' -
See Attached Sheet(s) for Summary-
Name(s) and Signature(s) of Inspectors:
Agency/Office/Telephone No:
Date:
Wes Bell �-ZQ-
NCDWQ/MOORESVILLE/[phone]
5/22/02
Date:
Signature of Management QA Reviewer:
Agency/Office/Phone & Fax No:
Date:
EPA Form 3560-3 (Rev. 9-94) Previous editions are obsolete-

ivy CNA Holdings WWTP
Page Two
The facility was last inspected by Linda Love of this office on January 12, 2001.
PERMIT:
The permit authorizes the continued operation of an existing 0.8 MGD activated sludge
wastewater treatment facility consisting of a comminutor, bar screen and grit chamber; three
equalization basins utilizing pH adjustment, two aeration basins with chlorine added on an as -needed
basis, two secondary clarifiers with polymer addition, a waste activated sludge digester, two sludge
ponds, and three polishing ponds. The facility has installed tertiary filters and an UV disinfection
system (via Authorization to Construct dated 4/20/00); therefore, the permit description does not
adequately describe the facility.
The current permit for this facility became effective on 5/l/99 and expires on 8/31/03.
RECORDS AND REPORTS:
Records and reports consisting of monthly monitoring reports, chain of custody forms,
laboratory analyses, calibration log, process control data, Operator -in -Responsible Charge (ORC)
visitation log, operation and maintenance logs, and flow charts are kept in accordance with permit
requirements. The records were organized and well maintained.
FACILITY SITE REVIEW/OPERATIONS & MAINTENANCE:
The process units appeared to be operating properly and the surrounding grounds were well
maintained. The tertiary filters and UV disinfection system are operational; however, only the
tertiary filters are currently in -use. The mixed liquor suspended solids were well mixed and
adequately oxygenated. Urea is added to the aeration basins to enhance microbial treatment.
Screenings are disposed at the county landfill.
A comprehensive process control program consists of pH, DO, ammonia, -phosphorus, COD,
SRT, F/M ratios, microscopic examination, MLSS, MLVSS, SVI calculations,. and sludge. blanket
measurements. Sludge wasting is based on the SRT measurements.
The facility is staffed with one. Grade_ IV ORC. A- certified backup operator has been.
designated and is available when the ORC is unable to visit the facility.
LABORATORY:
The on -site laboratory (Certification # 221) and the. contract services of Prism Laboratories;.
Inc. (Certification # 402 ), Davis & Floyd, Inc. (Certification #'25) of. Greenwood, S.C. and ETT
Environmental of Greenville, S.C. provide analytical support.- The laboratories werenot evaluated.
during this inspection. The pH meter,appeared to be properly calibrated.
EFFLUENT/RECEIVING STREAM:
The effluent discharge was clear with no floatable solids and no foam. The facility discharges." ;
into Buffalo Creek, which is a Class C water in the Broad River Basin. The outfall location.was
well maintained and accessible. The receiving stream did not appear to be negatively impacted.

CNA Holdings WWTP►
Page Three
SELF -MONITORING PROGRAM:
Self -monitoring -reports were reviewed for the period -March 2001 through February 2002,
inclusive. No limit violations were reported. All monitoring. frequencies were correct.
The August and September 2001 DMRs did not. have the attached chart recordings: of the -
clarifier pH values to comply with condition 4 on the permit's effluent limitations and monitoring.
-requirements page. Please submit the- additional documentation in order to be compliant with the
conditions of the permit.. The remaining DMRs (relevant to the: permit condition) contained the
appropriate documentation.
All samples appeared to have been properly preserved and meet the required.holding times..
Composite samples are collected flow proportionately.
FLOW MEASUREMENT:
Effluent flow is measured by a continuous recording flow meter with totalizer and circular
chart recording. The flow meter is calibrated on a quarterly basis by the facility's I & E Department
The flow meter was last calibrated on 4/16/02.
SLUDGE DISPOSAL:
Sludge is land applied by SYNAGRO under the authority of Permit #WQ0011038. The
permit became effective on.8/4/00 and.expires 7/31/05.
SEWER OVERFLOW:
Please be advised that pursuant to Part II,. Section E of your NPDES .permit, and North
Carolina Administrative Code (NCAC) 15A 2B .0506 (a)(2),. any failure of a collection system,
pumping station or treatment facility resulting in. a bypass without. treatment of all or any portion of
the wastewater shall be reported to the central office or the appropriate regional office (Mooresville
Regional Office 704-663-1699) as soon as possible but no later than 24 hours from the. time the
permittee became aware of the bypass.. Overflows and. spills occurring outside normal business
hours may also be reported to the: Division's Emergency Response -personnel at 800-662=7956. 800=
858-0368, or 919-733 3300:_A written' report also:be:providedwithia.five:.(5).days;ofthe.tune---
of the -incident. The report: shall contain.a.description:ofthe. bypass;_ - and- its -cause;: the period of the
bypass, including exact dates and times, and -if the bypass has not -been corrected,_the-anticipatedtime°
it is. expected. to continue; andsteps taken (or planned) to reduce-, eliminate;.. and prevent recurrence:
of the.. similar events:. Any- spilL that reaches- surface,waters-(Le.. any spill that. reaches -,any water :
already present in a, conveyance;. stream,- ditch-': etc:..) or any -spill greater than:.1,000 gallons on-the
ground that does not reach surface.waters must be, reported:'
An. adequate: spill. response. for those: spills. reaching: surface_ waters: should, include: am -
evaluation downstream of the point at -which thespill entered. surface:waters-to determine:a:fish
kill occurred. -. The: evaluation should also. include: the collection of upstream dissolved. oxygen: and -
pH measurements for backgroundinformation and dissolved oxygen and. pH:.measurements: at.
multiple points downstream of the -entry point to document -any negative impact_. Failure- to report
the bypass of collection system; pumping station. or treatment: facility subjects violators to penalties-.
of up to $25,000.00 per day per violation.

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
t
No� �l
Aa,
•
2000
PROFESSIONAL ENGINEER'S CERTIFICATIOly MANA'W .
FOR
CONSTRUCTION OF WASTEWATER TREATMENT FACILITIES
rm Division of Water Quality hareby
ATC PROJECT NUMBER: 004956A06M0W1Cd8eJ r=dPt and WXCPftW8 of
CNA Holdings, Inc. (Ticona) Shelby Facility U& Fjm0n= CerBCdlon
NPDES Permit No. NC0004956
6
I, 14R FI-I ¢1Ye T119*4 am a duly registered Professional Engineer
(please print)
in the State of North Carolina and have been authorized to observe (circle one: periodically, weekly, full
time) the construction of the subject project for the Permittee:
Project No.: 004956ACB
Project: CNA Holdings (Ticona) Shelby Facility
Cleveland County
Tertiary Filter and UV Disinfection Project
Location:
The project consists of:
on NC Highway 198
south of Shelby
�r �o
E L1 AUG 2 g 2 ,,)Q r;
• Installation of tertiary pressure filters (Yardney Water Management System Model MM-4860-6A)
• Installation of UV disinfection (Trojan Model Number UV02M15)
I hereby certify that I did regularly observe this project with due care and diligence and that the
© vev
construction was completed in substantial conformance with the Authorization to Construct and aveat ®� ii� o eO.,
approved plans and specifications. ®• �� •°®GGooR
�•••°�ESS10 O
4 ®• �O O O
O
SEAL
4A 1 '/��- Registration No. /`(a I9054 0 Signature. _ l�" ti�3fJ r ��y,�, o
Date �� �� ®��oee.��•°n;Gl NEB° •®���
Upon completion of construction and prior to operation of the modified facility, the Permittee shall provide the
Division with a certification from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit, this Authorization to Construct, and the approved plans and specifications.
The Certification should be submitted to:
NCDENRIDWQ, NPDES Unit, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617

4
_k
CLOSURE PLAN
FOR THE WASTEWATER TREATMENT LAGOON
HOECHST CELANESE CORPORATION
SHELBY, NORTH CAROLINA
\\G2\sys\DATA\WORD\ 10766.0 1 \Closure Plan.doc DAVIS & FLOYD, INC.

CLOSURE PLAN
FOR THE WASTEWATER TREATMENT LAGOON
HOECHST CELANESE CORPORATION
SHELBY, NORTH CAROLINA
AUGUST, 1997
DAVIS & FLOYD, INC. JOB NUMBER 10766.01
PREPARED BY
DAMS & FLOYD, INC.
ENVIRONMENTAL DIVISION
GREENWOOD, SOUTH CAROLINA
\\G2\sys\DATA\WORD\10766.01\Closure Plan.doc nAvic -9- cr nvn CUP

ENGINEERING CERTIFICATE
We, the undersigned Engineers, have prepared the attached Engineering Report and
hereby certify that all data and estimates contained herein are true and correct to the best of our
knowledge and belief.
0
v r
'.. l 1 i' o
Ro and L. Powqjl ` 1 °
State of North r -<`• ° o
License Number` •°° �r, C2�0h0
��9eca�s�aaaae,�
\\G2\sys\DATA\WORD\ 10766.0 1 \Closure Plan.doc DAVIS & FLOYD, INC.

TABLE OF CONTENTS
PAGE
I. Background I.1
II. Closure Plan II.1
III. Amendments to Closure Plan III.1
APPENDICES
Appendix A: Approval Letter from NCDEHNR for Temporary Sludge Storage in the Lagoons
Appendix B: Correspondence Regarding Construction of Emergency Spill Tank
Appendix C: Comparison of RI/FS Soil Analyses to State & Federal Action Levels
nav►c R. V► nvn ►NV

I.1
I. BACKGROUND
The Hoechst Celanese Corporation operates a facility in Shelby, North Carolina. The
facility is produces PET and PBT polymer for use in clothing and specialty resin
products. The SIC codes for the facility are 2821 Plastics Materials and Resins and 2824
Organic Fibers, non -cellulosic. The corresponding North American Industry
Classification System (NAICS) numbers are 325211 Plastic material and resin
manufacturing and 325222 Noncellulosic organic fiber manufacturing.
Constructed during the early 1970's were two lagoons intended for use as emergency
spill containment. Most recently, the ponds were used for storage of excess wastewater
treatment sludge (Once in 1989, once in 1995). A copy of the approval letter for this
practice is contained in Appendix A. In 1993-1994, a'h million gallon tank was erected
at the facility to act as an emergency holding tank. Correspondence regarding the
construction of this tank is contained in Appendix B. With the completion of the
construction of the above ground tank, the need for the earthen ponds was eliminated.
Because these ponds are no longer needed, Hoechst Celanese Corporation wishes to
initiate closure of these facilities.
\\G2\sys\DATA\WORD\ 10766.0 1 \Closure Plan.doc nevrc Je. V1 nvn iNd'

H. CLOSURE PLAN
III DISPOSAL OF REMAINING WASTEWATER
Because these ponds were used intermittently as spill protection, there is not any
remaining wastewater in the ponds that will need to be disposed of The only water left - ,
`_in -these -ponds would-be`possiiile storcriwatefcollection-remaining-after_periods of rain.
Any-srorinwater_remaining in-the-ponds-will-be_removed_naturally;-either_by seeping_into-_
the subsurface,: by -evaporation; or_ by- providing__a maniiiade-drainage .route -through the- - -
r area.: Any__ and __all_._drainage:_r_outes_ shall- be eonstrueted-- with --adequate -silt and
—sedimentation-containment: prior -to -the .commencement of water drainage, -
II.2 TREATMENT OF INVENTORY
The existing depressions may be contoured or back -filled with soil in a manner
consistent with good engineering practices. The top layer of soil will be graded to
prevent run-on collection. During placement of any fill, there will be continuous on -site
construction inspection. The construction inspector will be responsible for ensuring that
the cover is placed in accordance with any and all specifications. The area will be
fertilized and grassed to prevent erosion.
II.3 DECONTAMINATION OF FACILITY
Further decontamination of the facility will not be required. The facility is currently
conducting remediation activities for correcting groundwater contamination in the
former glycol recovery unit bottoms (GRUB) area. Groundwater data compiled in
conjunction with this remediation indicates that only the following compounds might be
DAVIS & FLOVD, INC.

II.2
of any concern to the Closure: Acetone, Benzene, 2-Butanone (MEK), Carbon disulfide,
Chlorobenzene, Ethylene glycol, and 2-Hexanone. However, historical sampling has
shown that Total Organic Carbon levels, and therefore organic concentrations, are
virtually nonexistent down -grade from the emergency ponds. Additionally, the existing
inner tier extraction well system will contain any contaminated groundwater in the area
and prevent it from migrating off site.
Soils contamination is not expected to be a problem. Sampling conducted in 1986 as
part of the above mentioned RI/FS showed that the soils in the emergency ponds did not
pose a threat and were below both State and Federal action levels (Appendix Q.
Therefore, the soils from the facility will be re -graded to allow for stormwater drainage
and maintenance of the area.
The closure activities will minimize, to the extent possible, disturbance of the existing
clay portions of the lagoon structure. During the Closure construction proceedings, the
lagoon area shall be secured in order to protect personnel safety until the Closure is
completed.
All interconnecting piping to and from the lagoons will be closed in place. After
allowing all piping to drain, all ends on the piping will be capped off or otherwise
appropriately plugged, or removed where feasible.
Closure of the lagoon shall be considered complete by Hoechst Celanese Corporation
once inspection and written approval received from the appropriate NCDEHNR Official.
DAVIS & FLOYD, INC.

M. AMENDMENTS TO CLOSURE PLAN
This closure plan has been proposed according to good engineering practices. If, due to
extenuating circumstances, the plans and schedules contained herein are found to be
unattainable, Hoechst Celanese Corporation will submit a revision to the closure plan.
\\G2\sys\DATA\WORD\ 10766.0 1 \Closure Plan.doc DAVIS & FLOYD, INC.

-1 .1 ev - . -. v, ■-v.

J,uL-��•-�' r nt=% = J J r rxurl : Huu SHI-ml-BY SAFETY I L) - PAGE 3
State of North Carolina
Department of Environment, Health, and Natural Resources
Asheville Regional Office
James G, Martin, Governor
William W. Cobcy, Jr„ Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
December: 14, Ig89
Mr.. Ron Caldwell, Environmental Engineer.
Hoechst Celanese Corporation
Post Office Box 87
Shelby, North Carolina 28151-008*7
Dear Mr. Caldwell:
Ann R. Orr
Regional Manager
Subject: Emergency Basin
Wastewater Treatment Facility
Hoechst Celanese Corporation
Cleveland County
This letter is provided art response to the discussion concerning
use of the emergency overflow basin for temporary storages of sludge
from an existing sludge holding basin. The Division of Environmental
Management would not -view use of the emergency overflow basin to be in
violation of the conditions of' Hoechst Celanese's NPDES Permit Number
NC0004952 or the requirement: of environmental regulations so long
sludge storage is conducted in accor"danrp_ with the following
conditions:
Material to l_ie stared in the emer,csc-ncy overflow basin would
consist only of sludge, from Hoechst Celanese's wastewater
treatment facility located near Shelby, North Carolina. and would.
be withdrawn from one of the two -xi rt,:i-)ig sludge holding basins.
Approximately 6600 cubic yards of material. wotil.d be. stored in
the emergency overflow basin.
Material would be stored in the einer-gency b<:is,i n unti.l-
approximately April 1, 1990, or sucli tame as weatliel- conditions
would allow operation of a port:,lhl.c- ofudge press.
Ultimate disposal_ of stored sludge will, be in Cleveland Container.
Corporation's Private landfill wliicls is permitted by the Solid
and Hazardous Waste Branch to 1:•eceive :i.ndusl-r.ial. sli-idges,
lntcrc:hange Building, i9 Wtxxlfin Place, Ashevitic, N.C. 2RR01 • Telephone 704-25kQ0R
An Equal Upportunity Atfirmative A, t4.m F-rnpluyer

/= J UL—GG`—�" • CrO = JY r ccva-t = na��. J1-1LL137 SA17E Y
Ron Caldwell
December 14, 1989
Page Two
Thank you for your inquiry concerning this matter. If there are
questions or a need for additional. information, please contact me at
telephone number 704-251-620.8.
Sincerely,
James R. Reid
Environmental, Chemist

"nVlu a rwIv, ■n-k,.

JUL-28 S7 06 : 34 FROM: HCC SHELBY- SAF-ET-Y- I D :
PAGE 5 -
:i:11,L %oV1 1jt25C
October 15, 1993
Coleen H. Sullins, P.E.
North Carolina Department of
Environmental Management
P.O. Box 29535
Raleigh, N. C. 27626-0535
Dear: Ms. Sullins
Texafe FibersHoechst Celanese Corporation
PO Box 87
Shelby. NC 28151-0087
704 482 2411
This letter is to request permission to construct an Zmergenay Hold
Tank at our Hoechst Celanese -Shelby Waste Treatment Plant (WTP)
NPDES #0004952.
The tank would be constructed above ground and would be used to
collect influent to the WTP that may negatively impact the biomass
in the aeration basin.
The new tank would be used only by exception and is not intended to
be used continuously. When the influent entering "A" Equalization
basin is toxic or heavily loaded then the tank will be- placed in
service. This will be activated by utilizing the output from an on
line respirometer which continuously evaluates the impact of the
WTP influent on the biomass. . The respirometer will provide an
alarm and start a diversion pump. The on line respirometer will be
purchased in the near future.
The WTP influent will be transferred from the existing "A" or "B"
Equalization Basins to the new Emergency Hold Tank by a diversion
pump (See Attached Flow Diagram). The waste water collected in the
new Emergency Hold Tank would then be evaluated and in most
instances would be added back to the WTP influent at a controlled
rate that would not negatively impact the biomass.
The addition of this equipment will help minimize the possibility
of a biomass upset.
It is my understanding from talking with the Mooresville office
that our NPDES Permit would not need to be modified since the new
tank does not change the WTP process and will be used infrequently.
If you have questions please call [phone] Ext. 4360.
Sincerely,
Dewey lliamson
Utilities Maintenance Engineer
Hoechst Celanese -Shelby
Attachments
Hoechst

4UL-26=97 o9:34 FROM: HCC SHELSY SAFETY ID: PAGE 6
State of North Carolina
Cepartment of Environment,
Health and Natural Resources ` • •
Division of Environmental Management
.lames B. Hunt, Jr., Governor
Jonathan S. Howes, Secretary ® E F1
A. Preston Howard, Jr., P.E., Director
November 12, 1993
Dewey Williamson
Hoechst Celanese Corporation
P.O. Box 87
Shelby, NC 28151-0087
Subject Permit No. NC0004952
Authorization to Construct
Emergency Hold Tank
Wastewater Treatment Facility
Cleveland County
Dear Mr. Williamson:
A letter of request for an Authorization to Construct was received October 15, 1993 by the Division
and final plans and specifications for the subject project have been reviewed and found to be satisfactory.
Authorization is hereby granted to modify the existing treatment system by the addition of an emergency
hold tank with dimensions of 47 feet diameter and 40 feet height with centrifugal solids handling pumps
for transfer of influent and all the necessary piping, valves and appurtenances needed for proper operation
with discharge of treated wastewater into Buffalo Creek in the Broad River Basin.
This Authorization to Construct is issued in accordance with Part III, Paragraph A of NPDES
Permit No. NCO004952 issued February 19, 1993, and shall be subject to revocation unless the
wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in
Permit No. NC0004952.
The sludge generated from these treatment facilities must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Environmenml Management.
In the event that the facilities fail to perform satisfactorily, including the creation of nuisance
conditions, the Permittee shall take immediate corrective action, including those as may be required by this
Division, such as the construction of additional or replacement wastewater treatment or disposal facilities.
The Mooresville Regional Office, telephone number 704-663-1699, shall be notified at least forty-
eight (48) hours in advance of operation of the installed facilities so that an in -place inspection can be
made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00
a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays.
Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit, this Authorization to Construct and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535. Raleigh, NC
27626-0535.
P.O. Box 2953S, Raleigh, North Carolina 27626-0536 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

4UL-?S-L97 06=3S FROM: HCC SHELBY SAFETY __ ID- PAGE 7
Permit No. NC0004952
Authorization to Construct
Hoechst Celanese Corporation
November 12, 1993
Page 2
Upon classification of the facility by the Certification Commission, the Permittee shall employ a
certified wastewater treatment plant operator to be in responsible charge (ORC) of the wastewater treatment
facilities. The operator must hold a certificate of the type and grade at least equivalent to or greater than the
classification assigned to the wastewater treatment facilities by the Certification Communion. The
Permittee roust also employ a certified back-up operator of the appropriate type and grade to comply with
the conditions of Title 15A, Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class II, III, and IV facility at least daily, excluding weekends and holidays, and
must properly manage and document daily operation and maintenance of the facility and must comply with
all other conditions of Title 15A, Chapter 8A, .0202.
A copy of the approved plans and specifications shall be maintained on file by the Permittee for the
life of the facility.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Environmental Management in accordance with
North Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from complying
with any and all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Mr. Randy L. Kepler, telephone number
919/733-5083.
Sinc ly,
A. Preston o d, Jr., P.E.
cc: Cleveland County Health Department
Mooresville Regional Office, Water Quality
Training and Certification Unit

JUL-20-'97 09:3S FROM:. HCC _SHELBY SAFETY --._
ID: PAGE B
Hoechst Celanese
October 20, 1994
North Carolina Department of
Environmental Management
Permits and Engineering Unit
POE 29535
Raleigh, NC 27626-0535
Subject: Permit #N00004952
Certification of
construction
Dear Sir:
Textile Fibers
Hoechst Celanese Corporation
PO Box 87
Shelby, NC 28151-0087
704 482 2411
In compliance with your letter dated November 12, 1993 from Preston
Howard Jr. concerning the construction of a waste water treatment
plant emergency hold tank at HCC Shelby Plant, please find attached
a Certificate of compliance that construction has been completed in
accordance with our NPDES permit, authorization to construct and
the approved plans and specifications.
We will be notify the Mooresville Office of our anticipated date to
place the tank in service.
If you have questions please call [phone].
Sincerely,
DeweWiiliamaon
Utilities Maintenance Engineer
Hoechst Celanesse-SHelby

.JUL-23o-97 06=36 FROM: HCC SHELBY SAFETY ID- PAGE 9
Pe_ -alit No. NCO004952
Authorization to Construct
Hoechst Celanese Corporation
November 12, 1993
Page 3
Fn�ine�s ['P:*±fication
I, William E. Ross , as a duly registered Professional Engineer in the State of North
Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the
project, WrP Emergency Hold Tank Shelby, North Carolina for the
Project Nome Location
Perrnittoe hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and
intent of the approved plans and specifications.
Date October 20, 1994

APPENDIX C
COMPARISON OF RI/FS SOIL ANALYSES TO STATE & FEDERAL ACTION LEVELS
nAVIQ P_ Cf nvn laid,

Volatile Compounds (µg/kg)
Chloromethane
Chloroethane
Methylene Chloride
Acetone
Carbon Disulfide
Chloroform
2-Butanone
Vinyl Acetate
2-Hexanone
Tetrachloroethene
Toluene
Chlorobenzene
Ethylbenzene
Total Xylenes
Semi -Volatile Compounds
(µg/kg)
Phenol
2-Methylphenol
4-Methylphenol
Naphthalene
2-Methylnaphthalene
Acenaphthene
Dibenzofuran
Phenanthrene
Di-n-Buthylphthalate
Fluoranthene
Pyrene
Butylbenzylphthalate
B is(2-Ethylhexyl)Phthalate
Chrysene
2-Chlorophenol
Metals (mg/kg)
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
HOECHST CELANESE, SHELBY, NORTH CAROLINA
NORTH EMERGENCY POND SOIL SAMPLE RESULTS
N. EMER N. EMER N. EMER N. EMER
N. EMER
N. EMER
N. EMER
N. EMER
ACTION NW NW NE NE
SW
SW
SE
SE
LEVEL(EPA QUAD QUAD QUAD QUAD
QUAD
QUAD
QUAD
QUAD
REGION III) SS-001 SS-002 SS-003 SS-004
SS-005
SS-006
SS-007
SS-008
440,000
820,000,000
760,000 25 20 18 18
22
200,000,000
20
200,000,000
940,000
1,000,000,000 27 23
26
10
1,000,000,000
NA
110,000
410,000,000
41,000,000
200,000,000
1,000,000,000
1,000,000,000
100,000,000
10,000,000
82,000,000
NA
12,000,000
8,200,000
NA
200,000,000
82,000,000
61,000,000
410,000,000
410,000
780,000
10,000,000
820
3.8
1,000
1,000,000
82,000
NA
610
41,000
10,000
10,000
0
610,000
900 330
400
570
340
870
1,100
178.0 15.3 2259 140 5912 179 7252 374
36.8 169 38.1 253 20.1 467 76.7
1.4 2.5 3.3
20.3 24.9 55.1
82.7 728 81.4 1,076 66.7 1,143 56.5
Note: Original sampling performed as part of the facility's CERCLA Remedial Investigation/Feasibility Study (RI/FS), 1986.
For clarity, only valid analysis results are shown here. Refer to original document for full analysis results.
DAVIS & FLOYD, INC.

Volatile Compounds (µg/kg)
Chloromethane
Chloroethane
Methylene Chloride
Acetone
Carbon Disulfide
Chloroform
2-Butanone
Vinyl Acetate
2-Hexanone
Tetrachloroethene
Toluene
Chlorobenzene
Ethylbenzene
Total Xylenes
Semi -Volatile Compounds
(µl Jkg)
Phenol
2-Methylphenol
4-Methylphenol
Naphthalene
2-Methylnaphthalene
Acenaphthene
Dibenzofuran
Phenanthrene
Di-n-Buthylphthalate
Fluoranthene
Pyrene
Butylbenzylphthalate
B is(2-Ethylhexyl)Phthal ate
Chrysene
2-Chlorophenol
Metals (mg/kg)
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
HOECHST CELANESE, SHELBY, NORTH CAROLINA
SOUTH EMERGENCY POND SOIL SAMPLE RESULTS
S. EMER
S. EMER
S. EMER
S. EMER
S. EMER
S. EMER
S. EMER
S. EMER
ACTION
SE
SE
SW
SW
NE
NE
NW
NW
LEVEL(EPA
QUAD
QUAD
QUAD
QUAD
QUAD
QUAD
QUAD
QUAD
REGION III)
SS-010
SS-011
SS-012
SS-013
SS-014
SS-015
SS-016
SS-017
440,000
820,000,000
760,000
32
27
26
33
16
200,000,000
236
2,060
879
289
738
24
538
142
200,000,000
940,000
1,000,000,000
76
26
42
51
74
22
1,000,000,000
NA
110,000
410,000,000
66
394
1230
22
1,290
1,540
69
41,000,000
200,000,000
8
1,000,000,000
22
23
1,000,000,000
360
350
550
1,600
100,000,000
10,000,000
1,200
1,100
590
1,100
2,900
82,000,000
650
NA
12,000,000
8,200,000
2,500
360
NA
740
200,000,000
1'500
82,000,000
420
61,000,000
410,000,000
410,000
590
780,000
570
10,000,000
1,000
820
3.8
I,000
1,000,000
2,638
360
4424
146
6,496
118
19,977
18,882
82,000
569
84.3
613
33
4,358
59.5
13,557
361
NA
610
2.2
0.41
3.9
2.8
41,000
71.5
28.6
37.1
73.1
10,000
10,000
0
610,000
1,400
235
2,353
71.5
7,315
99.9
2,631
3,798
Note: Original sampling performed as part of the facility's CERCLA Remedial Investigation/Feasibility Study (RI/FS), 1986.
For clarity, only valid analysis results are shown here. Refer to original document for full analysis results.
nAVIQ R_ Cr nVn INIP

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Water Quality
919 North Main Street Mooresville, NC 28.115
August 11, 1997
Mr. Jeff Randolph
Hoechst Celanese -Shelby
P.O. Box 87
Shelby, NC 28151
SUBJECT: Notice of Violation - Effluent Limitations
NPDES No. NC0004952
Hoechst Celanese -Shelby
Cleveland County
Dear Mr. Randolph:
Review of subject self -monitoring report for the month of June, 1997 revealed a violation of
the following parameter:
Reported Limits
Pipe Parameter Value/Unit Value/Type/Unit
001 00530 RES/TSS 191.2 LBS/DA 152.8 FIN LBS/DA
Remedial actions, if not already implemented, should be taken to correct the problem(s). The
Division of Water Quality may pursue enforcement actions for this and any additional violations
of State Law. If you have questions or if you need assistance, please call D. Rex Gleason,
Regional Water Quality Supervisor, at 704/663/1699.
Sincerely,
taw"" d.
B.Christian, Acting
Regional Supervisor
cc: Central Files
GKBDEX96BL