NC0000094_Regional Office Physical File Scan Up To 11/30/2020

Wiggs, Linda
From: Wiggs, Linda
Sent: Monday, July 18, 2016 10:11 AM
To: Davidson, Landon
Cc: Laverty, Brett
Subject: RE: Fletcher Warehousing Lagoon Closure
Attachment A Closures of Permitted Wastewater Ponds and Lagoons:
Item A:
1.Although not indicated how the samples were obtained, I spoke with Mark Swan the sampler. He said he
attempted to go onto the concrete structures to grab the samples, but many of them are not safe. A diagram
indicating where each sample was obtained is needed; for water and sludge.
2.It appears they gathered most of the appropriate parameters in accordance with the permit conditions and 2.a.
Landon, if we want them to sample for other parameters the guidance doc say that needs to come from you.
Sounds like you wanted TCLP.
4.The farmland is not permitted where they want to apply the wastewater, so it sounds like that is not an option.
MSD will need to be contacted.
Item C:
The sludge sampling locations and depth of sludge is not indicated. Again I spoke with Mark Swan he said he
dropped a bucket to the bottom to get sludge samples and that it was not thick, more soupy like algae. (Just
telling you what he said) It looks like they did TCLP metals on the sludge samples. Again, these samples are
lacking, it does not look like a full TCLP was analyzed. Under 17. it states Regional Office will determine what
type of sampling when groundwater is intercepted. Landon, it sounds like you will need to dictate what they
need to do here as well.
Item G:
You will need to decide where they fit, seems like 29 but you said you (and Brett) wanted a monitoring well
installed (and soil samples?)
Landon, I am not trying to skirt my response to Denese and Charlie, but I really do not know what to say to
them with regard to this GW area. And I fear this could blow up to being beyond my position duties/expertise.
Finally the use of fill they offer needs to be a response from Deb Aja.
I have been in email correspondence with Denese and Charlie for a month now explaining why we have been
delayed in responding to them,,,, several pertinent people have been on vacation (Brett, Landon and Julie). They
have understood, but are anticipating response ASAP.
Let me know how you want to proceed.
Environmental Senior Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources

828 296 4500 office
828 299 7043 fax
Email: linda.wiclgs(c�ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
�:: -'_ �'— nothing Compares—-.,_
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Davidson, Landon
Sent: Wednesday, June 01, 2016 10:03 AM
To: Wiggs, Linda <[e-mail]>; Laverty, Brett <[e-mail]>
Subject: FW: Fletcher Warehousing Lagoon Closure
See attached. I recommend a joint review process between you two but you are welcome to come up with your own
delineation of work for this review. Thanks.
G. Landon Davidson, P.G.
Regional Supervisor —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson(a ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
am
?: - 7�> Nothing Compares.,,....
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Denese Ballew [mailto:[e-mail]]
Sent: Wednesday, June 01, 2016 9:29 AM
To: Davidson, Landon <[e-mail]>
Cc: Charlie Owen<[e-mail]>
Subject: Fletcher Warehousing Lagoon Closure
Landon,
I hope that you had a good Holiday weekend.

Please find attached the report in reference to closing out the lagoons at Fletcher Warehousing. I have also
attached the analytical report and a letter both of which are referenced in the report.
Please do not hesitate to call (828-734-1374) or email with any questions. I look forward to hearing back from
you.
Thanks,
Denese Ballew
Project Manager

.ocher W,a.re.housn,g Lagoon Closure 2016
Mr. Landon Davidson
Aquifer Protection Section, Western Regional Supervisor
North Carolina Department of Environmental Quality
Division of Water Resources
Subject: Fletcher Warehousing Lagoon Closure
Dear Mr. Davidson,
On March 7, 2016 Mr. Charlie Owen, of Fletcher Warehou
the former wastewater treatment plant onsite and analyze
i�
Warehousing is located at 4600 Hendersonville Road
willfully surrendered in May 2015. The plant has only had
running thru it since the 1990s when the former Cranstorf
treatment facility. Mr. Owen has owned the site since they
Associates to operate the plant until it was closed out by P
permission from the Surface Water Protection Section Mr
that time there has been rain and small quantities.,of', ewE
cemented the discharge pipe closed and since%......
River. The warehousing facilities have been ca ected to
In March, 2015 Charlie and I met with Unda Wiggs, Bever!
ON -
Resources. In later correspondence With tt y client Ms�1Ni;
be closed utilizing the Lagoon CIq ru Guidelines.
Please see
5/31/16
sing had PaceA#ialgytical collect samples from
*both wat C go oludge samples. Fletcher
her, NC.,The permit for this WWTP was
>torm,wate'r anti asmall amount of sewage
Printwo Mks Plant�clr gtcl the wastewater
eaR, 1990s and has�tdfitracted Wjth Goldie
AdGill Associates. In ea"r#y 241 8 vr'Ith
Owen°drained the aeratiWbas ns and since
runningthruthe plant. In late 2014 McGill
t has not disc-1 ged to the French Broad 'I
Cane Creek W %r and Sewer Authority-
-In 'q . Tim Fox from the Division of Water
s stat�t#ht.. t the former aeration basins,may
enderson County GIS system.
These aeration basins have an
overflow weir at the west end
closest to the round clarifiers. The
sludge sample was taken from the
bottom of the aeration basins at this
discharge point. Water was also
collected from these basins by Pace
Laboratories and analyzed. Please
see the analytical discussion below.

Water Analysis
North Aeration Basin Water
Method "�"'
Result mg/L
2540D Total Suspended Solids
2.9
5210E BOD,5 Day
3.3
Colilert-18 Fecal Coliform
2.0 MPN/100ml
TKN+NO3+NO2 Total Nitrogen
0.80
350.1 Ammonia
ND
351.2 Total Kjeldahl Nitrogen
0.80
353.2 NO2/NO3 (preserved)
ND
365.1 Total Phosphorus
0.059
South Aeration Basin Water
Method
Result mg/L ,
2540D Total Suspended Solids
ND
5210E BOD,S Day
3.3 .
Colilert-18 Fecal Coliform
ND`
TKN+NO3+NO2 Total Nitrogen
0.79 i , ys
350.1 Ammonia
ND `<'4
351.2 Total Kjeldahl Nitrogen
` 0;74
353.2 NO2/NO3 (preserved)
s
;F0.047
N.
365.1 Total Phosphorus'!
0.11
Note: None Defected
Sludge Analysis
North Aeration Basin
The field Data for the North Basin: Sample
collected on 3/7/2016 @ 11:40am, pH=9.0,
Field Temperature was 49.28°F, the Dissolved
Oxygen=9.72mg/L and there was no chlorine
detected.
The field Data for the South Basin: Sample
collected on 3/7/2016 @ 12:00pm pH=9.2,
Field Temperature was 50.54°F, the Dissolved
Oxygen was 9.88mg/L and there was no
chlorine detected.
s �
J%Results
��IHSBiPSR'G
Contarriie
ra `rng/>�#;
s mg/kg
Lev le
7440-38-2
yX60ic (inorganic)
ND
5.8
7440-39-3
Ban'ur
ND
5.8 E+02
7440-43-9
Cadmium
ND
3.0
Chromium 1113V
16065-83-1
Insoluble Salts
ND
3.60E+05
7439-92-1
Lead & Compounds
0.056
2.70E+02
Mercury
Compounds
ND
1.0
7884-49-2
Selenium
ND
2.1
7440-22-4
Silver
ND
3.4
The samples for both the North &
South Aeration Basins have been
compared to the Inactive
Hazardous Sites Branch's
Preliminary Soil Remediation
Goals.

South Aeration Basin
CAS #
"
WContaminate
R "A ultsu ""
m k g/ gLe�relsmg/kg
IHSR'FPSRGR�i�„
7440-38-2
Arsenic (inorganic)
ND
5.8
7440-39-3
Barium
ND
5.8 E+02
7440-43-9
Cadmium
ND
3.0
16065-83-1
Chromium III
Insoluble Salts
ND
3.60E+05
7439-92-1
Lead & Compounds
ND
2.70E+02
Mercury
Compounds
ND
,
T 1 0k
7884-49-2
Selenium
ND
rl 21 °
7440-22-4
Silver
ND
;. 3.4 ,
Mr. Owen would like to close t
• Pump the water from 1
capacity).
• Utilize the clean crush(
the basins
• Allow the neighboring
not beenosed<at-the e
Mr. OWei` t%owns several acres
r kxF
farmer and spray them with th
potential for runoff into nearby str
It is necessary to complete this pro
order to have concrete available.
Please feel free to call (8
have.
Sincerely,
inner:
is at
ant) to fill
ate that has
i by a local
:he
r the summer months when construction is at its peak in
or email ([e-mail]) with any questions you may
benese Ballew
Project Manager
Ballew Environmental Training & Consulting

aceAnalytical
Wmpoc,-Ws;com
March 17, 2016
Mr. Charlie Owen
Fletcher Warehousing Co.
PO Box 188
Fletcher, NC 28732
RE: Project: Fletcher Warehousing 3/7
Pace Project No.: 92289047
Dear Mr. Owen:
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Enclosed are the analytical results for sample(s) received by the laboratory on March 07, 2016. The
results relate only to the samples included in this report. Results reported herein conform to the
most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Chris Derouen
[e-mail]
Project Manager
Enclosures
rgea
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 22

aceAnalyfical -
mvw.patelabs.irorri
Project: Fletcher Warehousing 3/7
Pace Project No.: 92289047
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Charlotte Certification IDS
9800 KinceyAve. Ste 100, Huntersville, NC 28078
North Carolina Drinking Water Certification #: 37706
North Carolina Field Services Certification #: 5342
North Carolina Wastewater Certification #: 12
Asheville Certification IDS
CERTIFICATIONS
South Carolina Certification #: 99006001
Florida/NELAP Certification #: E87627
Kentucky UST Certification #: 84
Virginia/VELAP Certification #: 460221
2225 Riverside Drive, Asheville, NC 28804 North Carolina Wastewater Certification #: 40
Florida/NELAP Certification #: E87648 South Carolina Certification #: 99030001
Massachusetts Certification #: M-NC030 Virginia/VELAP Certification #: 460222
North Carolina Drinking Water Certification #: 37712
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 2 of 22

iaceAnalxical
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SAMPLE ANALYTE COUNT
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Project:
Pace Project No.:
Fletcher Warehousing 317
92289047
Analytes
Lab ID
Sample ID
Method
Analysts
Reported
Laboratory
92289047001
NORTH CLARIFIER
SM 2540D
MSH
1
PASI-A
SM 5210B
MLS
1
PASI-A
Colilert-18
TEP
1
PASI-A
TKN+NO3+NO2 Calculation
EWS
1
PASI-A
EPA 350.1
AES2
1
PASI-A
EPA 351.2
SER
1
PASI-A
EPA353.2
DMN
1
PASI-A
EPA 365.1
BRJ
1
PASI-A
92289047002
SOUTH CLARIFIER
SM 2540D
MSH
1
PASI-A
SM 5210B
MLS
1
PASI-A
Colilert-18
TEP
1
PASI-A
TKN+NO3+NO2 Calculation
EWS
1
PASI-A
EPA 350.1
AES2
1
PASI-A
EPA 351.2
SER
1
PASI-A
EPA353.2
DMN
1
PASI-A
EPA 365.1
BRJ
1
PASI-A
92289047003
NORTH BIG
SM 2540D
MSH
1
PASI-A
SM 5210B
MLS
1
PASI-A
Colilert-18
TEP
1
PASI-A
TKN+NO3+NO2 Calculation
EWS
1
PASI-A
EPA 350.1
AES2
1
PASI-A
EPA 351.2
SER
1
PASI-A
EPA353.2
DMN
1
PASI-A
EPA 365.1
BRJ
1
PASI-A
92289047004
SOUTH BIG
SM 2540D
MSH
1
PASI-A
SM 5210B
MLS
1
PASI-A
Colilert-18
TEP
1
PASI-A
TKN+NO3+NO2 Calculation
EWS
1
PASI-A
EPA 350.1
AES2
1
PASI-A
EPA 351.2
SER
1
PASI-A
EPA353.2
DMN
1
PASI-A
EPA 365.1
BRJ
1
PASI-A
92289047005
NORTH BIG
EPA 6010
CDF
7
PASI-A
EPA 7470
HVK
1
PASI-A
92289047006
SOUTH BIG
EPA 6010
CDF
7
PASI-A
EPA 7470
HVK
1
PASI-A
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 3 of 22

IeAnalyficai
wwwpace0bs.som
ANALYTICAL RESULTS
Project: Fletcher Warehousing 3/7
Pace Proiec Flo® 92289047
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Sample( N�CLARIFIER
Lab ID: 92289047001 Collected: 03/07/16 11:10
Results Units Report Limit DF
Received: 03/07/16 16:45 Matrix: Water
Prepared Analyzed CAS No. Qua[
Field Data
Analytical Method:
Collected By
Mark
1
03/08/16 17:04
Swann
Collected Date
3/7116
1
03/08/16 17:04
Collected Time
11:10
1
03/08/16 17:04
Field pH
8.1 Std. Units
0.10
1
03/08/16 17:04
Field Temperature
8.6 deg C
0.50
1
03/08/16 17:04
Oxygen, Dissolved
10.98 mg/L _
1
03/08/16 17:04
7782-44-7
Chlorine, Total Residual
ND mg/L
0.050
1
03/08/16 17:04
7782-50-5
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
ND mg/L
10.0
1
03/08/16 17:05
5210B BOD, 5 day
Analytical Method: SM 5210B
BOD, 5 day
3.9 mg/L
2.0
1
03/08/16 17:05 03/13/16 15:30
J(B2)
Colilert-18 Fecal Coliform AVL
Analytical Method: Colilert-18
Fecal Coliforms
ND MPN/100mL
1.0
1
03/07/16 17:05
Total Nitrogen Calculation
Analytical Method: TKN+NO3+NO2
Calculation
Total Nitrogen
0.74 mg/L
0.12
1
03/16/16 13:52
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
ND mg/L
0.10.
1
03/09/16 14:58
7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
0.74 mg/L
0.50
1
03/15/16 03:41
7727-37-9
353.2 Nitrogen, N021NO3 pres.
Analytical Method: EPA 353.2
Nitrogen, NO2 plus NO3
ND mg/L
0.020
1
03/15/16 14:19
365.1 Phosphorus, Total
Analytical Method: EPA 365.1
Phosphorus
ND mg/L
0.050
1
03/11/16 22:10
7723-14-0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 03/17/2016 05:19 PM without the written consent of Pace Analytical Services, Inc.. Page 4 of 22

aceAnalytiol
www.pacelabsxom
0
Project: Fletcher Warehousing 317
Pace Pr5�ject�lov�--92289047--,"
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Sample: SOUTH CLARIFIER
Parame ers
Lab ID: 92289047002 Collected: 03/07/16 11:25
Results Units Report Limit DF
Received: 03/07/16 16:45 Matrix: Water
Prepared Analyzed CAS No. Qual
Field Data
Analytical Method:
Collected By
Mark
1
03/08/16 17:07
Swann
Collected Date
317116
1
03/08/16 17:07
Collected Time
11:25
1
03/08/16 17:07
Field pH
8.0 Std. Units
0.10
1
03/08/16 17:07
Field Temperature
9.7 deg C
0.50
1
03/08/16 17:07
Oxygen, Dissolved
9.71 mg/L
1
03/08/16 17:07
7782-44-7
Chlorine, Total Residual
ND mg/L
0.050
1
03/08/16 17:07
7782-50-5
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
ND mg/L
3.1
1
03/08/16 17:05
5210E BOD, 5 day
Analytical Method: SM 5210B
BOD, 5 day
3.3 mg/L
2.0
1
03/08/16 17:05 03/13/16 15:30
J(B2)
Colilert-18 Fecal Coliform AVL
Analytical Method: Colilert-18
Fecal Coliforms
ND MPN/100ml-
1.0
1
03/07/16 17:05
Total Nitrogen Calculation
Analytical Method: TKN+NO3+NO2
Calculation
Total Nitrogen
0.74 mg/L
0.12
1
03/16/16 13:52
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
ND mg/L
0.10
1
03/09/16 14:59
7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
0.74 mg/L
0.50
1
03/15/16 03:42
7727-37-9
353.2 Nitrogen, NO2/NO3 pres.
Analytical Method: EPA353.2
Nitrogen, NO2 plus NO3
ND mg/L
0.020
1
03/15/16 14:20
365.1 Phosphorus, Total
Analytical Method: EPA 365.1
Phosphorus
ND mg/L
0.050
1
03/11/16 22:12
7723-14-0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 03/17/2016 05:19 PM without the written consent of Pace Analytical Services, Inc.. Page 5 of 22

aceAnalytical
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ANALYTICAL RESULTS
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Project: Fletcher Warehousing 3/7
Pace Projec�o.. 922 9047
Sam 're: NORTH BIG
7arameter
Lab ID: 92289047003 Collected:
Results Units
03/07/16
Report Limit
11:40
DF
Received: 03/07116 16:45 Matrix:
Prepared Analyzed
Water
CAS No. Qua[
Field Data
Analytical Method:
Collected By
Mark
1
03/08/16 17:08
Swann
Collected Date
317/16
1
03/08/16 17:08
Collected Time
11:40
1
03/08/16 17:08
Field pH
9.0 Std. Units
0.10
1
03/08/16 17:08
Field Temperature
9.6 deg C
0.50
1
03/08/16 17:08
Oxygen, Dissolved
9.72 mg/L
1
03/08/16 17:08
7782-44-7
Chlorine, Total Residual
ND mg/L
0.050
1
03/08/16 17:08
7782-50-5
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
2.9 mg/L
2.5
1
03/08/16 17:05
5210B BOD, 5 day
Analytical Method: SM 5210B
BOD, 5 day
3.3 mg/L
2.0
1
03/08/16 17:05 03/13/16 15:30
J(B2)
Colilert-18 Fecal Coliform AVL
Analytical Method: Colilert-18
Fecal Coliforms
2.0 MPN/100mL
1.0
1
03/07/16 17:05
Total Nitrogen Calculation
Analytical Method: TKN+NO3+NO2
Calculation
Total Nitrogen
0.80 mg/L
0.12
1
03/16/16 13:52
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
ND mg/L
0.10
1
03/09/16 15:01
7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
0.80 mg/L
0.50
1
03/15/16 03:43
7727-37-9
353.2 Nitrogen, NO2/NO3 pres.
Analytical Method: EPA353.2
Nitrogen, NO2 plus NO3
ND mg/L
0.020
1
03/15/16 14:21
365.1 Phosphorus, Total
Analytical Method: EPA 365.1
Phosphorus
0.059 mg/L
0.050
1
03/11/16 22:12
7723-14-0
Date: 03/17/2016 05:19 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 22

a0,eA9 cal..
mm:pacelebscom
ANALYTICAL RESULTS
Project: Fletcher Warehousing 3/7
Pace Projec No.. 92289047
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Samp e: SOUTH BIG
P ameter
Lab ID: 92289047004 Collected: 03/07/16 12:00
Results Units Report Limit DF
Received: 03/07/16 16:45 Matrix: Water
Prepared Analyzed CAS No. Qua]
Field Data
Analytical Method:
Collected By
Mark
1
03/08/16 17:10
Swann
Collected Date
317116
1
03/08/16 17:10
Collected Time
12:00
1
03/08/16 17:10
Field pH
9.2 Std. Units
0.10
1
03/08/16 17:10
Field Temperature
10.3 deg C
0.50
1
03/08/16 17:10
Oxygen, Dissolved
9.88 mg/L
1
03/08/16 17:10
7782-44-7
Chlorine, Total Residual
ND mg/L
0.050
1
03/08/16 17:10
7782-50-5
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
ND mg/L
5.0
1
03/08/16 17:05
5210E BOD, 5 day
Analytical Method: SM 5210B
BOD, 5 day
3.3 mg/L
2.0
1
03/08/16 17:05 03/13/16 15:30
J(B2)
Colilert-18 Fecal Coliform AVL
Analytical Method: Colilert-18
Fecal Coliforms
ND MPN/100mL
1.0
1
03/07/16 17:05
Total Nitrogen Calculation
Analytical Method: TKN+NO3+NO2
Calculation
Total Nitrogen
0.79 mg/L
0.12
1
03/16/16 13:52
350.1 Ammonia
Analytical Method: EPA350.1
Nitrogen, Ammonia
ND mg/L
0.10
1
03/09/16 15:02
7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
0.74 mg/L
0.50
1
03/15/16 03:43
7727-37-9
353.2 Nitrogen, N021NO3 pres.
Analytical Method: EPA353.2
Nitrogen, NO2 plus NO3
0.047 mg/L
0.020
1
03/15/16 14:25
365.1 Phosphorus, Total
Analytical Method: EPA 365.1
Phosphorus
0.11 mg/L
0.050
1
03/11/16 22:13
7723-14-0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 03/17/2016 05:19 PM without the written consent of Pace Analytical Services, Inc.. Page 7 of 22

aceAnalyfical
www.aacelabs.com
ANALYTICAL RESULTS
Project: Fletcher Warehousing 3/7
Pace Project-No^92289047
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Sample�NORTTHH BIG Lab ID: 92289047005 Collected: 03/07/16 11:45 Received: 03/07/16 16:45 Matrix: Water
Parame ers Results Units Report Limit DF Prepared Analyzed CAS No. Qual
6010 MET ICP, TCLP
Analytical Method: EPA6010 Preparation Method: EPA3010A
Leachate Method/Date: EPA 1311; 03/13/16 11:35 Initial pH: 6.3; Final pH: 4.8
Arsenic
ND mg/L 0.050 1 03/14/16 05:15
`03/16/16 16:26
7440-38-2
Barium
ND mg/L 0.25 1 03/14/16 05:15
03/16/16 16:26
7440-39-3
Cadmium
ND mg/L 0.0050 1 . 03/14/16 05:15
03/16/16 16:26
7440-43-9
Chromium
ND mg/L 0.025 1 03/14/16 05:15
03/16/16 16:26
7440-47-3
Lead
0.056 mg/L 0.025 1 03/14/16 05:15
03/16/16 16:26
7439-92-1
Selenium
ND mg/L 0.10 1 03/14/16 05:15
03/16/16 16:26
7782-49-2
Silver
ND mg/L 0.025 1 03/14/16 05:15
03/16/16 16:26
7440-22-4
7470 Mercury, TCLP
Analytical Method: EPA7470 Preparation Method: EPA7470
Leachate Method/Date: EPA 1311; 03/13/16 11:35 Initial pH: 6.3; Final pH: 4.8
Mercury
ND mg/L 0.00020 1 03/14/1610:30
03/14/1617:47
7439-97-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 03/17/2016 05:19 PM without the written consent of Pace Analytical Services, Inc.. Page 8 of 22

awAnalyt cal
wwvw.pacelaiSs:corn
ANALYTICAL RESULTS
Project: Fletcher Warehousing 3/7
Pace Pr lectd/ No.: 92289047
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Sampl SOUTH BIG Lab ID: 92289047006 Collected: 03/07/16 12:00 Received: 03/07/16 16:45 Matrix: Water
Farr1eters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
6010 MET ICP, TCLP
Analytical Method: EPA 6010 Preparation Method: EPA 3010A
Leachate Method/Date: EPA 1311; 03/13/16 11:35 Initial pH: 6.3; Final pH: 4.6
Arsenic
ND mg/L 0.050 1 03/14/16 05:15
03/16/16 16:29
7440-38-2
Barium
ND mg/L 0.25 1 03/14/16 05:15
03/16/16 16:29
7440-39-3
Cadmium
ND mg/L 0.0050 1 03/14/16 05:15
03/16/16 16:29
7440-43-9
Chromium
ND mg/L 0.025 1 03/14/16 05:15
03/16/16 16:29
7440-47-3
Lead
ND mg/L 0.025 1 03/14/16 05:15
03/16/16 16:29
7439-92-1
Selenium
ND mg/L 0.10 1 03/14/16 05:15
03/16/16 16:29
7782-49-2
Silver
ND mg/L 0.025 1 03/14/16 05:15
03/16/16 16:29
7440-22-4
7470 Mercury, TCLP
Analytical Method: EPA7470 Preparation Method: EPA7470
Leachate Method/Date: EPA 1311; 03/13/16 11:35 Initial pH: 6.3; Final pH: 4.6
Mercury ND mg/L 0.00020 1 03/14/1610:30 03/14/1617:49 7439-97-6
Date: 03/17/2016 05:19 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 9 of 22

acu. nalXjOl.
—.pacelabs.spm
QUALIFIERS
Project: Fletcher Warehousing 3/7
Pace Project No.: 92289047
DEFINITIONS
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
MDL -Adjusted Method Detection Limit.
PQL - Practical Quantitation Limit.
RL- Reporting Limit.
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
S - Surrogate
1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
Acid preservation may not be appropriate for 2 Chloroethylvinyl ether, Styrene, and Vinyl chloride.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis of Acrolein and Acrylonitrile by EPA
Method 8260.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI - The NELAC Institute.
LABORATORIES
PASI-A Pace Analytical Services -Asheville
PASI-C Pace Analytical Services - Charlotte
WORKORDER QUALIFIERS
WO: 92289047
[11 Chlorine analyzed with strips, ND = <0.5 on strip
ANALYTE QUALIFIERS
J(B2) Estimated Value. Oxygen usage is less than 2.0 for all dilutions set. The reported value is an estimated less than value
and is calculated for the dilution using the most amount of sample.
J(M1) Estimated Value. Matrix spike recovery exceeded QC limits. Batch accepted based on laboratory control sample (LCS)
recovery.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 03/17/2016 05:19 PM without the written consent of Pace Analytical Services, Inc.. Page 19 of 22

ace aa/yf16
wwwpacelebscom,
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project: Fletcher Warehousing 3/7
Pace Project No.: 92289047
Lab ID
92289047001
92289047002
92289047003
92289047004
92289047005
92289047006
92289047005
92289047006
92289047001
92289047002
92289047003
92289047004
92289047001
92289047002
92289047003
92289047004
92289047001
92289047002
92289047003
92289047004
92289047001
92289047002
92289047003
92289047004
92289047001
92289047002
92289047003
92289047004
92289047001
92289047002
92289047003
92289047004
92289047001
92289047002
92289047003
92289047004
92289047001
92289047002
92289047003
92289047004
Sample ID
NORTH CLARIFIER
SOUTH CLARIFIER
NORTH BIG
SOUTH BIG
NORTH BIG
SOUTH BIG
NORTH BIG
SOUTH BIG
NORTH CLARIFIER
SOUTH CLARIFIER
NORTH BIG
SOUTH BIG
NORTH CLARIFIER
SOUTH CLARIFIER
NORTH BIG
SOUTH BIG
NORTH CLARIFIER
SOUTH CLARIFIER
NORTH BIG
SOUTH BIG
NORTH CLARIFIER
SOUTH CLARIFIER
NORTH BIG
SOUTH BIG
NORTH CLARIFIER
SOUTH CLARIFIER
NORTH BIG
SOUTH BIG
NORTH CLARIFIER
SOUTH CLARIFIER
NORTH BIG
SOUTH BIG
NORTH CLARIFIER
SOUTH CLARIFIER
NORTH BIG
SOUTH BIG
NORTH CLARIFIER
SOUTH CLARIFIER
NORTH BIG
SOUTH BIG
Date: 03/17/2016 05:19 PM
QC Batch Method
EPA 3010A
EPA 301i0A
EPA 7470
EPA 7470
SM 2540D
SM 2540D
SM 2540D
SM 2540D
SM 5210B
SM 5210B
SM 5210B
SM 5210B
Colilert-18
Colilert-18
Colilert-18
Colilert-18
TKN+NO3+NO2
Calculation
TKN+NO3+NO2
Calculation
TKN+NO3+NO2
Calculation
TKN+NO3+NO2
Calculation
EPA 350.1
EPA 350.1
EPA 350.1
EPA 350.1
EPA 351.2
EPA 351.2
EPA 351.2
EPA 351.2
EPA 353.2
EPA 353.2
EPA 353.2
EPA 353.2
EPA 365.1
EPA 365.1
EPA 365.1
EPA 365.1
,i
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QC Batch Analytical Method
FLD/
FLD/
FLD/
FLD/
MPRP/20943
EPA 6010
MPRP/20943
EPA 6010
MERP/9063
EPA 7470
MERP/9063
EPA 7470
WET/43458
WET/43458
WET/43458
WET/43458
WET/43454
SM 5210E
WET/43454
SM 5210B
WET/43454
SM 5210B
WET/43454
SM 5210B
WET/43441
WET/43441
WET/43441
WET/43441
WET/43613
WET/43613
WET/43613
WET/43613
WETA/26717
WETA/26717
WETA/26717
WETA/26717
WETA/26760
WETA/26760
WETA/26760
WETA/26760
WETA/26782
WETA/26782
WETA/26782
WETA/26782
WETA/26719
WETA/26719
WETA/26719
WETA/26719
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Analytical
Batch
ICP/18858
;ICP%18858
11
M ERC/8707
M ERC/8707
WET/43460
WET/43460
WET/43460
WET/43460
Page 20 of 22

J CHAIN=O'F-CU,S�'®.DY/ ,.nalytical .equest D.ocur ent
N
aceAna/ ical� The Chain -of -Custody is a•LEGAL•DOCUMENT Alf'refevant fields must be completed accurately w
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g h ubble Wrap - � QBubble Bp of ❑No_•he ❑Other
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Did samples,originate In a quaYantine.ione within,t 6 United States -GA, NY, orSC'(chgckmaps)7 - . , Dldsamples originate from a foreign source (Interne
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COMMENTS:`
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compliance with EPA.recommendation?
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Exceptions: VOA, I'i%rm, C, Oil and GreaseR
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Project,NlanagersSCURF Review Date`
Project Manager SRF Review: - W aw Date" -
Note: Vi/henever there is a discrepancy affecting NorthCarolina compliance samples, a copy ofthis formwill 6e sentto the'N-_ h Carollna, fiEHNR Certificatlon Office (i,e
Out of hold, incorrect preservative; out of ternp; incorrect containets) Page 22 of 22
" , I

Wiggs, Linda
From: Van Hoff, Jon <[e-mail]>
Sent: Friday, March 13, 2015 3:28 PM
To: [e-mail]
Cc: Wiggs, Linda; [e-mail]; Greg Wiggins
([e-mail]); [e-mail]
Subject: Fletcher Warehouse
Denese,
When last we talked there were some questions that you were going to find answers to regarding the types of companies
that your facility would accept, where the connection to the sewer system would be located, and a few other
questions. The Metropolitan Sewerage District was in agreement to evaluate this information but as of yet has not given
any form of approval to discharge to MSD.
As for the "Profile Sheet" you sent, MSD did view the document but has not commented on that document.
Since our conversation and correspondences, MSD has learned that the infrastructure or operational efficiency of your
facility is currently non -compliant with regard to the current NPDES. This raises a concern for MSD.
A meeting needs to be scheduled at your facility. Other than myself, this meeting needs to include Linda Wiggs with
ARO and a representative from the Cane Creek Water and Sewer District. Please advise me within 30 days of the
arranged meeting.
Jon H. van Hoff
Industrial Pretreatment Coordinator
Metropolitan Sewerage District of Buncombe County
2028 Riverside Drive
Asheville, North Carolina 28804
Office: [phone]
Cell: [phone]

Wiggs, Linda
From: Bass, Sarah
Sent: Thursday, March 12, 2015 9:30 AM
To: Wiggs, Linda
Subject: RE: WWTP connection criteria
That waste characterization form leads me to believe that this facility should be covered under 40 CFR 437 (Centralized
Waste Treatment, or CWT). We do have 10 permitted across the state (3 of which are in Charlotte) and they do accept
waste in a similar fashion. There is a long list of categorical limits based on the types of waste- oily, metals, organics or a
combination.
Sarah Morrison Bass
N.C. Dept. of Environment and Natural Resources
Division of Water Resources
Pretreatment, Emergency Response and Collection Systems Unit (PERCS)
1617 Mail Service Center, Raleigh, NC 27699-1617
(91.9) 807-6310; fax [phone]
http://por tal.ncdenr. orglweblwglsvi pl /p -et
E-mail correspondence to and from this address may be subject to the
North Carolina .Public Records Law and may be disclosed to third parties.
Before printing this email, please consider your budget and the environment.
`w If you must print, please print only what you need and save ink with the free Eco-Font.
From: Wiggs, Linda
Sent: Wednesday, March 11, 2015 10:29 AM
To: Bass, Sarah
Subject: RE: WWTP connection criteria
Thanks Sarah.
This type operation (much like the one they were thinking about at Old Fort (Hydrotime)) really makes me nervous.
Regardless whether is ends up in our permitting world if they can actually get that WWTP back in shape and apply with
us or if it goes to MSD, it is sketchy. Having trucks full of who knows what and based upon someone's signature that all is
kosher in this tanker, then using a handheld device to determine what is in the tanker. Makes me nervous.
[e-mail]
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]

Link to Division of Water Resources Home Page
http://porta1.ncdenr.org/web/­wq
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: Bass, Sarah
Sent: Friday, March 06, 2015 3:56 PM
To: Wiggs, Linda
Subject: RE: WWTP connection criteria
Linda,
I've attached the first few pages of the permit for Wallace Farms- permitted by Charlotte Water. The leachate off of the
composting site goes to an aerated holding pond and then to Cabarrus County's Rocky River WWTP for treatment. I've
also attached the IDSF from Charlotte's 2014 PAR showing leachate concentrations. Nothing is really of concern.
Wallace Farms' description of discharge is the processing of various types of organic feedstocks, including animal
manures, wood materials, yard materials, cotton materials, tobacco materials, food processing residuals, and food
waste. All of the raw materials received at the facility for composting are non -hazardous.
It is confusing, because the description (below in bold- specifically waste waters) seems to indicate this would be a
centralized waste treatment facility (see the definition from 40 CFR 437 in regular print below). 40 CFR 437 divides
waste categories into metals, oils, organics, or multiple wastestreams. https:Hwww.law.cornell.edu/cfr/text/40/part-
437
This pre-treatment facility will accept profiled waste waters from various customers via drums and
tanker trucks. Those drums/trucks will be screened upon entering the facility using handheld
monitoring instruments to assure us that the waste water in the drums/truck is in fact the same that
we agreed to take thru the waste profiling system.Please see the attached waste profile sheet (MSD
has already reviewed this). I am familiar with MSD's fee structure but if you have one I will need to
have a copy of that as well because this will affect our fee structure. Please also advise of any other
requirements and/or information that the County will need us to provide to move forward.
Centralized waste treatment wastewater means any wastewater generated as a result of CWT activities. CWT
wastewater sources may include, but are not limited to: liquid waste receipts, solubilization water, used oil
emulsion -breaking wastewater, tanker truck/drum/roll-off box washes, equipment washes, air pollution control
scrubber blow -down, laboratory -derived wastewater, on -site landfill wastewaters, and contaminated storm
water.
Sarah Morrison Bass
N.C. Dept. of Environment and Natural Resources
Division of Water Resources
Pretreatment, Emergency Response and Collection Systems Unit (PERCS)
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax (91g) 807-6489
http: //portal. ncdenr. oLglweb/wq/sN-pip y/prel
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Before printing this email, please consider your budget and the environment.
�. If you must print, please print only what you need and save ink with the free Eco-Font.
From: Wiggs, Linda
Sent: Friday, March 06, 2015 9:39 AM
To: Bass, Sarah
Subject: FW: WWTP connection criteria
HI Sarah, When you get a chance take a peek at the email train below and then the attachment. My two questions are
does Charlotte/Mecklenburg really have something like this and do those parameter concentrations have you scratching
your head? When you read the emails there will be many things that have you scratching your head so don't fret.
Whenever you have time, I know PARS are coming in.
[e-mail]
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Resources Home Page
http://Porta1.ncdenr.org/web/wq
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore'may be disclosed to third parties.
From: Denese Ballew [mailto:[e-mail]]
Sent: Tuesday, March 03, 2015 10:58 AM
To: Wiggs, Linda; nberrysa)hendersoncountync.org
Cc: gwiggins(a)hendersoncountync.org; [e-mail]; [e-mail]; Charlie Owen; Rob
Rusnak; Frost, Larry
Subject: Re: WWTP connection criteria
Linda,
This is the first time that I have heard this. I have copied Charlie Owen on this e-mail.
I had a conversation many months ago about a couple of solid waste issues with Larry Frost (he used to work in
DWQ before DWM & I copied him on this email) and spoke of our intentions and he said that this is a permit
issue between you and MSD ( I am sure he will remember this even though it has been a while).
I have spoken with Jon Van Hoff (copied)with MSD's Industrial Waste Treatment Section on several occasions
and it is my understanding that he spoke with the ORC for MSD and they agreed to review the waste profiles
from customers ( would need 2 weeks to review) and decide if we could accept the profiled waste water, we
would work with them through a permitting process that would take a few months during which we would

operate the plant under close supervision, test the waste water prior to discharge, supply them with the
analytical and once we got approval discharge to the MSD system.
This type of operation is in place in Charlotte, NC and Greenville, SC and not scrutinized as closely as proposed
here.
I understand your questions and concerns and am interested to know more about the compliance and any other
significant issues associated with this plant...
Any other operations at the facility are to be under roof and the intention is to treat the storm water in the
WWTP with protection of the environment in mind.
I have attached a waste profile sheet that I created to start evaluating potential customers and it is my
understanding that this has been reviewed by Jon & Roger (both from MSD). We also proposed to screen trucks
entering the facility with fairly sophisticated and expensive hand held monitoring devices to verify the waste on
the truck is in fact the waste we agreed to accept.
In reference to a future inspection I will be happy to be present but, I believe that should be coordinated with
Charlie at a time he is available since he is the owner.
Please feel free to contact me at any time via email or phone @ 828-734-1374.
Thanks for the heads up,
Denese Ballew
From: "Wiggs, Linda" <linda.wiggsQncdenr.gov>
To: "deneseballew(a)yahoo.com" <deneseballew(a).yahoo.com>; "nberryp_hendersoncountync.orq"
<nberry(D_hendersoncountync.orq>
Cc: "gwiggins hendersoncountync.org"<gwiggins(a-)_hendersoncountync.org>;"maiones(D_hendersoncountync.org"
<mai nes(aD_hendersoncountync.org>; "JonVHP_msdbc.org" <JonVHCCDmsdbc.orq>
Sent: Tuesday, March 3, 2015 9:59 AM
Subject: RE: WWTP connection criteria
Hi Denese,
The email below is the first I have heard of any of this. You need to ask Charlie for a copy of my last inspection
report. That WWTP cannot receive any flows (other than a few toilets in the warehouse) until it is compliant. I
held off for another year on working with this facility in order to get the associated sewerline project
completed. Originally I said I would give Charlie until the end of 2013 before I re -inspected, it is now 2015 and
I am concerned to hear of any ventures involving this non -compliant WWTP.
Your email below to Marcus has me confused. My conversation with MSD did not indicate they had been
involved in conversations for several month regarding this venture, who at DENR did you verify what with, the
composting operation will send its stormwater to the WWTP, profiled wastewaters from various customers via
drums/tankers (this raises many questions)?
It was my understanding that the WWTP permit was to be rescinded and the WWTP closed out once the new
sewerline was installed.
If you or Charlie would please contact me regarding this venture, as well as setting up another inspection of the
facility.
Thank you,

Linda.Wiggs anncdenr.gov
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Resources Home Page
hfti)://i)ortal.ncdenr.org/web/Wg
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and therefore may be disclosed to third parties.
From: deneseballew0Dyahoo.com fmailto:deneseballew(ab-yahoo.com]
Sent: Friday, February 27, 2015 4:41 PM
To: nberry(�Dhendersoncountync.org
Cc: gwiggins(c)-hendersoncountync.org; maiones anhendersoncountync.ora; [e-mail]; Wiggs, Linda
Subject: Re: WWTP connection criteria
Importance: High
This is great, thanks.
We have in place prior to the proposed connection a state certified mag meter that is typical for waste water treatment
plants will that suffice as a meter?
Thanks,
Denese
Sent from my Verizon 4G LTE Smartphone
------ Original message ------
From: Natalie Berry
Date: Fri, Feb 27, 2015 4:19 PM
To: Denese Ballew;
Cc: Greg Wiggins;Marcus Jones;[e-mail];Wiggs, Linda;
Subject:WWTP connection criteria
Denisa,
Attached our response to your request. If you have any questions please do not hesitate to ask.
Thanks and have a wonderful weekend.
Natalie
From: Denese Ballew [mailto:deneseballew(c�yahoo.com]
Sent: Thursday, February 26, 2015 3:37 PM
To: Marcus Jones
Cc: Natalie Berry;_ Greg Wiggins; Charlie Owen; Rob Rusnak
Subject: Re: MSD Line Connection
Marcus,
Thanks for getting back with me so promptly.

have beer' talking with MSD about our operation for several months now & it did need special
consideration but we are past that point now.
We are not'connecting a composting operation (the composting operation will discharge its storm
water to the WWTP to be treated), as I mentioned earlier we are needing to tie the waste water
treatment plant (WWTP) line into the MSD line.
This makes the WWTP operation a Pre-treatment plant that discharges to MSD so we do not need a
DENR permit for this operation ( I have verified this with DENR).
If we start a' composting operation it will be after this project is online & will then be permitted thru
DENR. If the County has any permit requirements for this operation please advise so we can plan for
those.
This pre-treatment facility will accept profiled waste waters from various customers via drums and
tanker trucks. Those drums/trucks will be screened upon entering the facility using handheld
monitoring instruments to assure us that the waste water in the drums/truck is in fact the same that
we agreed to take thru the waste profiling system.Please see the attached waste profile sheet (MSD
has already reviewed this). I am familiar with MSD's fee structure but if you have one I will need to
have a copy of that as well because this will affect our fee structure. Please also advise of any other
requirements and/or information that the County will need us to provide to move forward.
There will ultimately be a few operations taking place at this facility over time which is why we are
phasing those operations in 1 at a time. I would be happy to discuss these operations further with you
and any colleagues you find appropriate ( originally planned to do this with all of the solid waste
directors at 1 time a little later) but will need you & those colleagues to sign a non -disclosure
agreement.
I am glad that we could clear up that little misunderstanding and please do not hesitate to call (828-
734-1374) or email with any further questions.
Thanks Again,
Denese
From: Marcus. Jones<majonesa),hendersoncountync.orq>
To: Denese Ballew <deneseballewna.yahoo.com>
Cc: Natalie Berry <[e-mail]>; Greg Wiggins<gwigginsCa)hendersoncountvnc.orq>
Sent: Thursday, February 26, 2015 2:55 PM
Subject: RE: MSD Line Connection
<=,,,, d iv="">
J'

CITY OF CHARLOTTE
CHARLOTTE-MECKLENBURG UTILITY DEPARTMENT
CHARLO"m, NORTH CAROLTiVA
PERMIT
To Discharge Wastewater Under The
Industrial PidtreatmentProgram
Permit Number 6001
In compliance with the provisions of Chapter 23 of the Charlotte City Code, North Carolina General Statute 143-215.1, 40
CFR 403, and other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission and the City of Charlotte, the following industry,
Wallace Farm, 1IIC.
Hereafter referred to by name or as the Permittee, is hereby authorized to:
1. Continue operation of the existing pretreatment facility (No Pretreatment), consisting of an aerated holding and
and a pump system, located at 14410 Eastfield Road, Huntersville, NC 28078• and
2. After receiving authorization to construct from the City of Charlotte, construct and operate pretreatment units as
needed to meet final effluent limitations, monitoring requirements, and all other conditions set forth in Parts I, II
and III hereof; and
3. Discharge wastewater from the facility into the Cabarrus County, Rocky River Wastewater Treatment Plant
NPDES Number NCO036269 in accordance with effluent limitations, monitoring requirements and other conditions
set forth in Parts I, II and III hereof.
This permit shall become effective August 22, 2012
This permit and the authorization to discharge shall. expire on July 31, 2017
ill intert
Environmental Compliance Manager
System -Protection
Environmental Management Division
Charlotte -Mecklenburg Utility Department
4222 Westmont Drive
Charlotte, North Carolina 28217

PARTT—PAGE2
PERMIT# 6001 '
1. Effluent Limits and Monitoring Requirements - Final
Effective.August 22, 2012 and lasting until July 31, 2017, the Permittee is authorized to discharge from pipe 001 to the Cabarrus County
Rocky River Wastewater Treatment Plant NPDES Number NC0036269. This discharge shall be limited and monitored as specified below.
Parameters and prohibitions not included below shall be regulated and limited in compliance with the sewer use ordinance.
Effluent Limitation mir/1 Monitoring Frequency
911less otherwise noted '
Wilted Daily Sample
Parameter Maximum Type City Permittee
Flow(1) .020 MGD Metered 4**/3 months ** I'
4 /6 months
As T ** ' Comp. 4**/3 months 4**/6 months
Ammonia as N *# Comp. 4**/3 months 4**/6 months
BOD5 Comp. 4*V3 months 4**/6 months
COD ** Comp. 4**/3 months 4**/6'months
Cd, T ** Comp. 4**/3 months 4**/6 months
Cr, T ** Comp. 4**/3 months 4**/6 months I
Cu, T *"* Comp. 4**/3 months 4**/6 months
Cyanide, T ** Grab 4**/3 months 4**I6 months
Pb, T # * Comp. 4**/3 months 4**/6 months
Hg, T *** Comp. 4**/3 months 4**/6 months
Ni, T Comp. 4**13 months 4**16 months
TSS *** Comp. 4**/3 months 4**/6 months
Oil & Grease *** Grab 4**/3 months 4**/6 months
Zn, T ** Comp. 4**/3 months 4**/6 months I
PH S.U. Grab 4**/3 months 4**/6 months
* pH must be greater than or equal to 6.0 and less than or equal to 12.0 at all times.
** Grab or 24-hour flow proportional composite samples collected for four consecutive discharge.days,
** No limits at this time, only monitoring,
(1) 'Wastewater meter.

Pretreatment Annual Report (PAR)..
Industrial Data Summary Form (IDSF)
Units = mg/1
Control Authority
CLTWater
Industry.
Town Name
Charlotte
Name: Wallace Farm, Inc.
WWTP Name====>
Rocky River
IUP# 6001
NPDES #=======>
NCO036269
Pipe# 001
1st 6 months, dates
01/01/2014 to 06/30/2014
2nd 6 months, dates
07/01/2014 to 12131/2014
Ammonia-N**
Arsenic,T**
Biochemical Oxygen Demand**
BOD, Carbonaceous 05 Day, 20C*
Cadmium**
1st 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
Total # smpls=>
10
12
Total # smpls=>
10
12
Total # smpis=>
10
12
Total # smpls=>
1
0
Total # smpis=>
10
12
Max mg/I
4.4
4.3
Max mg/I
0.01
0.02
Max boil
270
35
Max boil
190
0
Max mgA
0.002
0.01
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
% Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily TR -
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
_ 0.00
0.00
/o Daily TRC
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
Chromium-
COD-
Copper, T-
Cyanide-
Flow
1st 6
2nd 6
1st 6
2nd 6-
1st 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
Total # smpls=>
10
12
Total # smpls=>
10
12
Total # smpls=>
10
12
Total # smpls=>
. - 11
12
Total # smpls=>
15
12
Max mg/I
0.0078
0.011
Max mg/I
660
340
Max mgA
0.076
0.018
Max mg/I
0.01
0.01
Max MGD
0.0209
0.0107
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily Violation
13.33
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
/o.Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
Lead-
Mercury**
Nickel,T**
Nitrite plus Nitrate, T (as N)*
Nitrogen, T*
1st 6
2nd 6
Ist 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
Total # smpls=>
10
12
Total # smpls=>
10
12
Total # smpls=>
10
12
Total # smpls=>
4
0
Total # smpls=>
4
0
Max mg/I
0.005
0.02
Max mg/1.
0.0002
0.0002
Max mgA
0.014
0.015
Max mg/I
0.5
0
Max mgA
16.5
0
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Monthly Violation
0.00
0.00
%Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
Y.Monthly TRC
0.00
0.00
%Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
Oil & Grease**
pH
Phosphorus, T*
Selenium, T*
Silver*
1st 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
Total # smpls=>
11 •
12
Total # smpls=>
11
12
Total # smpls=>
4
0
Total # smpls=>
1
0
Total # smpls=>
6
8
,Max mg/I
5
5
Max s.u.
8.03
7.4
Max mgA
1.1
0
Max mgA
0.01
0
Max mg/I
0.005
0.005
/o Daily Vidlation
0.00
0.00
/o Daily Violation
0.00
0.00
% Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0100
1/6Monthly Violation
0.00
0.00
%Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
%Monthly Violation
0.00
0.00
%Monthly Violation
0.00
0.00
%Monthly TRC
0.00
0.00
%Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
% Monthly TRC
0.00
0.00
Page 139 of 140 Printed 2/9/2015 2:27:45 PM

Total Kjedahl Nitrogen*
Total Suspended Solids**
Zinc**
1st 6
2nd 6
1st 6
2nd 6
1st 6
2nd 6
otal # smpls=>
4
0
Total # smpls=>
10
12
Total # smpls=>
10
12
Max mg/I
16
0
Max mgA
100
120
Max mgA
0.023
0.022
/o Daily Violation
0.00
0.00
% Daily Violation
_ 0.00
0.00
/o Daily Violation
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
/o Daily TRC
0.00
0.00
% Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
0.00
/o Monthly Violation
0.00
O.Oo
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
/o Monthly TRC
0.00
0.00
Page 140 of 140 Printed 2/9/2015 2:27:45 PM

Wiggs, Linda.
From: Wiggs, Linda
Sent: Wednesday, March 04, 2015 11:32 AM
To: Charlie Owen
Cc: [e-mail]
Subject: fletcher warehouse
Hi Charlie,
You and I need to get together and discuss this venture and I will need to do another inspection. Then I will be able
better advise you in relation -to my regulatory authority. Generally speaking my authority relates all water related
operations. Which as I have gleaned so far is a major component of this venture you are considering. My Division
(DWR), which I am your primary contact, will deal with anything related to your WWTP. DWR'will also directly and/or
indirectly deal with the sewerline, stormwater, composting, pretreatment, SUO, spill controls, etc.
Let me know when you would like to get together for an inspection.
[e-mail]
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway.
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Resources Home Page
http://Porta1.ncdenr.org/web/wa
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.

Wiggs, Linda
From: Denese Ballew <[e-mail]>
Sent: Wednesday, March 04, 2015 11:38 AM
To: Wiggs, Linda
Subject: Re: WWTP connection criteria
Linda,
Thanks for getting back with med got the impression my character was being called into question.
I apologize for the misunderstanding.
I can be present at the inspection if it can be 2+ weeks out and I am not sure about Charlie's schedule.
I would like to meet you also especially since we probably need to work together on this to make it a success or
determine that it will not work at all (either way).
Please know that it has been several years since I operated a plant of this size so I am sure there have been many
changes.
Thanks Again,
Denese
From: "Wiggs, Linda" <[e-mail]>
To: Denese Ballew <[e-mail]>
Sent: Wednesday, March 4, 2015.11:21 AM
Subject: RE: WWTP connection criteria
HI Denese,
I don't think Larry meant it the way it was received. I certainly did not get any bad character assumptions about
you from Larry's email or any others.
I am going to send Charlie an email here in a little bit and cc you to set up an inspection. Once that takes place
I will have a better understanding on how to advice all involved as it relates to my regulatory authority.
One thing I did want to point out that you mentioned below "This WWTP has an NPDES permit to operate
for the next 5 years" . That is not correct, the permit expires in November 2015. It also is only permitted to
receive flows from the toilets in the warehouse (-25 people I think). Nothing else can go to that WWTP under
this permit.
My authority directly relates to the WWTP. It also directly and indirectly relates to the sewerlines and
pretreatment. I can also further assist Charlie with his stormwater permit.
Like I said I will cc you on my email to Charlie. If you can make my inspection that will be nice, I look forward.
to meeting you.
Linda Wiggs
Linda.Wiggs(cD-ncdenr.gov
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778

Wiggs, Linda
From: Wiggs, Linda
Sent: Wednesday, March 04, 2015 11:22 AM
To: 'Denese Ballew'
Subject: RE: WWTP connection criteria
HI Denese,
I don't think Larry meant it the way it was received. I certainly did not get any bad character assumptions about you
from Larry's email or any others.
I am going to send Charlie an email here in a little bit. and cc you to set up an inspection. Once that takes place I will have
a better understanding on how to advice all involved as it relates to my regulatory authority.
One thing I did want to point out that you mentioned below "This WWTP has an NPDES permit to operate for the
next 5 years". That is not correct, the permit expires in November 2015. It also is only permitted to receive flows from
the toilets in the warehouse (-25 people I think). Nothing else can go to that WWTP under this permit.
My authority directly relates to the WWTP. It also directly and indirectly relates to the sewerlines and pretreatment. I
can also further assist Charlie with his stormwater permit.
Like I said I will cc you on my email to Charlie. If you can make my inspection that will be nice, I look forward to meeting
you.
�1111T_Z;Nli
[e-mail]
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Resources Home Page
httP:Hporta1.ncdenr.org/web/wq
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: Denese Ballew [mailto:[e-mail]]
Sent: Wednesday, March 04, 2015 10:35 AM
To: Frost, Larry
Cc: Wiggs, Linda
Subject: Re: WWTP connection criteria
Larry,
I was not trying to throw you under the bus but let me refresh your memory. It was several months ago & I had
called Andrea Keller (she may remember the conversation) to talk about the correct steps to take for a

composting operation, anaerobic digester and a solidification facility. She wanted to be helpful & transferred
the call to your office so I could talk to both of you ( I appreciate your assistance). I threw in the waste water
question because it was convenient for me. Your comment was not in the context of a regulator & you may
have followed it up as you suggested.
There are a few things you should know here:
* I have began investigating what it would take to utilize this WWTP as a pre-treatment facility that discharges
to MSD
* I have not done anything wrong here
*I thought this operation would be permitted by MSD since they own the infrastructure and treatment facility.
*This WWTP has an NPDES permit to operate for the next 5 years
*There has been a negative tone and implications against my character every since I asked Henderson County
what the necessary steps would be to tap into the line. I don't understand that as I have always had a good
working relationship with Henderson County.
*I am an honest person with good character & will not tolerate any inference opposing that. Anything I have
said I am willing to swear on a bible to in a court of law.
*This negative banter will not stop me from investigating the requirements associated with this operation.
*No one has asked me very many questions about our intentions they have mostly jumped to wrong conclusions
and implied that I am less than honest with good intentions.
*I have stated that I would be willing to meet with anyone to answer any questions they may have but mostly all
that has happened are some conversations that have not included me with negative implications.
*I do believe that you (Larry) know me well enough to know that I always have protection of the environment
as a goal of any operation I am associated with.
*If necessary I also know many folks in the DENR organization as a whole that know me well enough to know
that ( I have worked with DENR representatives for over 20 years) & quite frankly many of them out rank you.
Since my character has been called into question here please know that I wont back down.
*I do not believe that this should escalate but believe me when I say I will take this as far as you would like or
may be farther if necessary. I do not wish to have an adversarial professional relationship with either one of you
so I suggest this situation be resolved among us as adults before it continues to escalate into something nasty.
I appreciate your follow up and am open to further discussion on a professional level without character
assassination and negative implications ( Larry, I do not believe those are your intentions & Linda doesn't even
know me).
Since I have this opportunity to talk with both of you please advise me of who I should speak with about
engineered upgrades to this WWTP? Nothing has happened yet but we may need to do something like this in
the future.
Larry, I have a great deal of respect for you & have always been able to work well with you and I don't want
that to change. Quite frankly I don't believe either one of us knows the background info on what is going on
here. I suspect it may have something to do with Henderson County wanting to take this plant via Imminent
Domain which did not work but that is just my assumption not a fact that I know to be true.

i
i
Thanks, i
Denese
From: "Frost, Larry" <la_rry.frost(d)_ncdenr.gov>
To: Denese Ballew <deneseballewa-vahoo.com>
Cc: "Wiggs, Linda" <linda.wiggs(cr�ncdenr.gov>
Sent: Wednesday, March 4, 2015 8:27 AM
Subject: RE: WWTP connection criteria
Denise
I do not'recall the conversation you are referring to. Any comments I made regarding the facility other than
those regarding solid waste management permitting were strictly 3rd party observations and interest on ,my part
from my previous employment, and were not meant to be regulatory or statutory in nature.
I am so far removed from my days with DWQ/DWR that I am sure I would have told you to call them
(DWQ/DWR),
Larry
Larry Frost, Engineering Project Manager
Permitting Branch, Solid Waste Section
Division of Waste Management, NCDENR
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Phone: [phone]
larry.frost(o)-ncden r.gov
http://portal.ncdenr.org/web/Wm/sw
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: Denese Ballew [mailto:deneseballew(c).yahoo.com]
Sent: Tuesday, March 03, 2015 10:58 AM
To: Wiggs, Linda; nberry(c�.hendersoncountync.org
Cc: gwiggins(o)-hendersoncountync.org; majones(a)-hendersoncountync.org; JonVH(a�msdbc.orq; Charlie Owen; Rob
Rusnak; Frost, Larry
Subject: Re: WWTP connection criteria
Linda,
This is the first time that I have heard this. I have copied Charlie Owen on this e-mail.
I had a conversation many months ago about a couple of solid waste issues with Larry Frost (he used
to work in DWQ before DWM & I copied him on this email) and spoke of our intentions and he said
that this is a permit issue between you and MSD ( I am sure he will remember this even though it has
been a while).
have spoken with Jon Van Hoff (copied)with MSD's Industrial Waste Treatment Section on several
occasions and it is my understanding that he spoke with the ORC for MSD and they agreed to review
the waste profiles from customers ( would need 2 weeks to review) and decide if we could accept the
profiled waste water, we would work with them through a permitting process that would take a few
months during which we would operate the plant under close supervision, test the waste water prior
to discharge, supply them with the analytical and once we got approval discharge to the MSD system.

This type of operation is in place in Charlotte, NC and Greenville, SC and not scrutinized as closely
as proposed here.
I understand your questions and concerns and am interested to know more about the compliance and
any other significant issues associated with this plant...
Any other operations at the facility are to be under roof and the intention is to treat the storm water in
the WWTP with protection of the environment in mind.
I have attached a waste profile sheet that I created to start evaluating potential customers and it is my
understanding that this has been reviewed by Jon & Roger (both from MSD). We also proposed to
screen trucks entering the facility with fairly sophisticated and expensive hand held monitoring
devices to verify the waste on the truck is in fact the waste we agreed to accept.
In reference to a future inspection I will be happy to be present but, I believe that should be
coordinated with Charlie at a time he is available since he is the owner.
Please feel free to contact me at any time via email or phone @ 828-734-1374
Thanks for the heads up,
Denese Ballew
From: "Wiggs, Linda" <linda.wiggs(Qncdenr.gov>
To: "deneseballewa-vahoo.com" <deneseballew(a-_)yahoo.com>; "nberrya-hendersoncountync.org"
<nberryC6-hendersoncountync.org>
Cc: "gwigqins(c)-hendersoncountync.org" <gwigqinsahend ersoncountync.org>;"maionesCa�hendersoncountync.org"
<mai nesna.hendersoncountync.org>; "JonVHCa)-msdbc.org' <JonVHamsdbc.org>
Sent: Tuesday, March 3, 2015 9:59 AM
Subject: RE: WWTP connection criteria
Hi Denese,
The email below is the first I have heard of any of this. You need to ask Charlie for a copy of my last inspection
report. That WWTP cannot receive any flows (other than a few toilets in the warehouse) until it is compliant. I
held off for another year on working with this facility in order to get the associated sewerline project
completed. Originally I said I would give Charlie until the end of 2013 before I re -inspected, it is now 2015 and
I am concerned to hear of any ventures involving this non -compliant WWTP.
Your email below to Marcus has me confused. My conversation with MSD did not indicate they had been
involved in conversations for several month regarding this venture, who at DENR did you verify what with, the
composting operation will send its stormwater to the WWTP, profiled wastewaters from various customers via
drums/tanke.s (this raises many questions)?
It was my understanding that the WWTP permit was to be rescinded and the WWTP closed out once the new
sewerline was installed.
If you or Charlie would please contact me regarding this venture, as well as setting up another inspection of the
facility.
Thank you,
Linda Wiggs
Linda.Wi. --ncdenr.gov

Wiggs, Linda
From: Wiggs, Linda
Sent: Tuesday, March 03, 2015 9:59 AM
To: '[e-mail]'; [e-mail]
Cc: [e-mail]; [e-mail];
[e-mail]
Subject: RE: WWTP connection criteria
Hi Denese,
The email below is the first I have heard of any of this. You need to ask Charlie for a copy of my last inspection report.
That WWTP cannot receive any flows (other than a few toilets in the warehouse) until it is compliant. I held off for
another year on working with this facility in order to get the associated sewerline project completed. Originally I said I
would give Charlie until the end of 2013 before I re -inspected, it is now 2015 and I am concerned to hear of any ventures
involving this non -compliant WWTP.
Your email below to Marcus has me confused. My conversation with MSD did not indicate they had been involved in
conversations for several month regarding this venture, who at DENR did you verify what with, the composting
operation will send its stormwater to the WWTP, profiled wastewaters from various customers via drums/tankers (this
raises many questions)?
It was my understanding that the WWTP permit was to be rescinded and the WWTP closed out once the new sewerline
was installed.
If you or Charlie would please contact me regarding this venture, as well as setting up another inspection of the facility.
Thank you,
[e-mail]
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Resources Home Page
http://porta1.ncdenr.org/web/wq
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: [e-mail] [mailto:[e-mail]]
Sent: Friday, February 27, 2015 4:41 PM
To: [e-mail]
Cc: [e-mail]; [e-mail]; [e-mail]; Wiggs, Linda
Subject: Re: WWTP connection criteria
Importance: High

This is great, thanks. -
We have in place prior to the proposed connection a state certified mag meter that is typical for waste water treatment plants will that
suffice as a meter?
Thanks,
Denese
Sent from my Verizon 4G LTE Smartphone
------ Original message ------
From: Natalie Berry
Date: Fri, Feb 27, 2015 4:19 PM
To: Denese Ballew;
Cc: Greg Wiggins;Marcus Jones;[e-mail];Wiggs, Linda;
Subject:WWTP connection criteria
Denisa,
Attached our 'response to your request. If you have any questions please do not hesitate to ask.
Thanks and have a wonderful weekend.
Natalie
From: Denese Ballew [mailto:[e-mail]]
Sent: Thursday, February 26, 2015 3:37 PM
To: Marcus Jones
Cc: Natalie Berry; Greg Wiggins; Charlie Owen; Rob Rusnak
Subject: Re: i,MSD Line Connection
Marcus,
Thanks for getting back with me so promptly.
,.
I have been talking with MSD about our operation for several months now & it did need special consideration
but we are past that point now.
We are not connecting a composting operation (the composting operation will discharge its storm water to the
WWTP to be'treated), as I mentioned earlier we are needing to tie the waste water treatment plant (WWTP) line
into the MSD, line.
This makes the WWTP operation a Pre-treatment plant that discharges to MSD so we do not need a DENR
permit for this operation ( I have verified this with DENR).
If we start a composting operation it will be after this project is online & will then be permitted thru DENR. If
the County has any permit requirements for this operation please advise so we can plan for those.
This pre-treatment facility will accept profiled waste waters from various customers via drums and tanker
trucks. Those drums/trucks will be screened upon entering the facility using handheld monitoring instruments to
assure us that the waste water in the drums/truck is in fact the same that we agreed to take thru the waste
profiling system.Please see the attached waste profile sheet (MSD has already reviewed this). I am familiar with
MSD's fee structure but if you have one I will need to have a copy of that as well because this will affect our fee

structure. Please also advise of any other requirements and/or information that the County will need_ us to
provide to move forward.
There will ultimately be a few operations taking place at this facility over time which is why we are phasing
those operations in 1 at a time. I would be happy to discuss these operations further with you and any colleagues
you find appropriate ( originally planned to do this with all of the solid waste directors :at 1 time a little later) but
will needyou & those colleagues to sign a non -disclosure agreement.
i
I am glad that we could clear up that little misunderstanding and please do not hesitate to call (828-734-1374) or
email with any further questions.
Thanks Again,
Denese
From: Marcus Jones <majones .hendersoncountync.org>
To: Denese Ballew <deneseballew(a�Yahoo.com>
Cc: Natalie Berry <nberry(a),hendersoncountync.orq>; Greg Wiggins<gwigginsCa7hendersoncountync.org>
Sent: Thursday, February 26, 2015 2:55 PM
Subject: RE: MSD Line Connection
<_"" div="">
0
3

Wiggs, Linda
From: Wiggs, Linda
Sent: Tuesday, March 03, 2015.10:49 AM
To: [e-mail]; [e-mail];
[e-mail]
Cc: [e-mail]
Subject: RE: WWTP connection criteria
Hello to all,
I have no idea what Ms. Bellew is talking about, so whoever (Natalie?) got me in the loop here thank you. As you will
see in you inbox I have sent Denese a separate email also.
I briefly spoke with Jon at MSD and he has not been in conversation with her or Charlie for several months now.
Furthermore, DENR has not verified anything to my knowledge. As I said, this is the first I have heard of anything going
on out there.
I did an inspection at the that facility at the beginning of 2013, there were many issues but I was lenient since I expected
him to rescind that permit once the sewerline project was completed. The WWTP facility is considered non -compliant
and is in need of significant repairs. In my inspection report I gave Charlie until the end of 2013 to close that system out
or get it compliant. I did let that slide until 2015 because of the delays in the sewerline project. Which by the way I have
not received the final engineer certification. Do any of you know when I will receive that? I will have to do another
inspection out there. Depending on what they really want to do out there, I will probably need to do this inspection in
concert with Jon and Greg since it seems they are toying with the idea of tying onto your infrastructure. Natalie, I did a
cursory inspection of their flow meter in 2013. 1 would want to do a more thorough review of it at the next inspection to
be sure it is accurate.
[e-mail]
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Resources Home Page
http://portal.ncdenr.org/web/wq
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: [e-mail] [mailto:[e-mail]]
Sent: Friday, February 27, 2015 4:41 PM
To: [e-mail]
Cc: [e-mail]; [e-mail]; [e-mail]; Wiggs, Linda
Subject: Re: WWTP connection criteria
Importance: High

This is great, thanks.
We have in place prior to the proposed connection a state certified mag meter that is typical for waste water treatment plants will that
suffice as a meter?
Thanks,
Denese
Sent from my Verizon 4G LTE Smartphone
------ Original message ------
From: Natalie Berry
Date: Fri, Feb 27, 2015 4:19 PM
To: Denese'Bal'lew;
Cc: Greg Wiggins;Marcus Jones;[e-mail];Wiggs, Linda;
Subject:WWTP connection criteria
Denisa,
Attached our response to your request. If you have any questions please do not hesitate to ask.
Thanks and have a wond.erftil weekend.
Natalie '
From: Denese Ballew [mailto:[e-mail]]
Sent: Thursday, February 26, 2015 3:37 PM
To: Marcus Jones
Cc: Natalie Berry; Greg Wiggins; Charlie Owen; Rob Rusnak
Subject: Re: :,MSD Line Connection
Marcus,
Thanks for getting back with me so promptly.
I have been talking with MSD about our operation for several months now & it did need special consideration
but we are past that point now.
We are not connecting a composting operation (the composting operation will discharge its storm water to the
WWTP to e.treated), as I mentioned earlier we are needing to tie the waste water treatment plant (WWTP) line
into the MSD�line.
This makes the WWTP operation a Pre-treatment plant that discharges to MSD so we do not need a DENR
permit for this operation ( I have verified this with DENR).
If we start a composting operation it will be after this project is online & will then.be permitted thru DENR. If
the County has any permit requirements for this operation please advise so we can plan for those.
This pre-treatment facility will accept profiled waste waters from various customers via drums and tanker
trucks. Those,drums/trucks will be screened upon entering the facility using handheld monitoring instruments to
assure us that -the waste water in the drums/truck is in fact the same that we agreed to take thru the waste
profiling system.Please see the attached waste profile sheet (MSD has already reviewed this). I am familiar with
MSD's fee structure but if you have one I will need to have a copy of that as well because this will affect our fee

i
structure. Please also advise of any other requirements and/or information that the County will need us to
provide to move forward.
There will ultimately be a few operations taking place at this facility over time which is why we are phasing
those operations in 1 at a time. I would be happy to discuss these operations further with you and any colleagues
you find appropriate ( originally planned to do this with all of the solid waste directors at 1 time a little later) but
will need you & those colleagues to sign a non -disclosure agreement.
I am glad that we could clear up that little misunderstanding and please do not hesitate to call (828-734-1374) or
email with any further questions.
Thanks Again,
Denese
From: Marcus Jones <maiones(a hendersoncountync.orq>
To: Denese Ballew <deneseballew(a.yahoo.com>
Cc: Natalie Berry <nberry(cDhendersoncount n�c.org>; Greg Wiggins<gwiggins(cDhendersoncountync.org>
Sent: Thursday, February 26, 2015 2:55 PM
Subject: RE: MSD Line Connection
<_"" div--"">

Wiggs, Linda
From: Denese Ballew <[e-mail]>
Sent: Tuesday, March 03, 2015 10:58 AM
To: Wiggs, Linda; [e-mail]
Cc: [e-mail]; [e-mail];
[e-mail]; Charlie Owen; Rob Rusnak; Frost, Larry
Subject: Re: WWTP connection criteria
Attachments: HULC Waste Profile.pdf
Linda,
This is the first time that I have heard this. I have copied Charlie Owen on this e-mail.
I had a conversation many months ago about a couple of solid waste issues with Larry Frost (he used to work in
DWQ before DWM & I copied him on this email) and spoke of our intentions and he said that this is a permit
issue between you and MSD ( I am sure he will remember this even though it has been, a while).
I have spoken with, Jon Van Hoff (copied)with MSD's Industrial Waste Treatment Section on several occasions
and it is my understanding that he spoke with the ORC for MSD and they agreed to review the waste profiles
from customers ( would need 2 weeks to review) and decide if we could accept the profiled waste water, we
would work with them through a permitting process that would take a few months during which we would
operate the plant under close supervision, test the waste water prior to discharge, supply them with the
analytical and once we got approval discharge to the MSD system.
This type of operation is in place in Charlotte, NC and Greenville, SC and not scrutinized as closely as proposed
here.
I understand your questions and concerns and am interested to know more about the compliance and any other
significant issues associated with this plant...
Any other operations at the facility are to be under roof and the intention is to treat the storm water in the
WWTP with protection of the environment in mind.
I have attached a waste profile sheet that I created to start evaluating potential customers and it is my
understanding that this has been reviewed by Jon & Roger (both from MSD). We also proposed to scree In trucks
entering the facility with fairly sophisticated and expensive hand held monitoring devices to verify the waste on
the truck is in fact the waste we agreed to accept.
I
In -reference to a future inspection I will be happy to be present but, I believe that should be coordinated with
Charlie at a time he is available since he is the owner. j
Please feel free to contact me at any time via email or phone @ 828-734-1374.
Thanks for the heads up,
Denese Ballew
From: "Wiggs, Linda" <[e-mail]>
To: "[e-mail]" <[e-mail]>; "[e-mail]"
<[e-mail]>

Cc: "[e-mail]" <[e-mail]>; "[e-mail]"
<[e-mail]>; "[e-mail]" <[e-mail]>
Sent: Tuesday, March 3, 2015 9:59 AM
Subject: RE: WWTP connection criteria
Hi Denese,
The email below is the first I have heard of any of this. You need to ask Charlie for a copy of my last inspection
report. That WWTP cannot receive any flows (other than a few toilets in the warehouse) until it is compliant. I
held off for another year on working with this facility in order to get the associated sewerline project
completed. Originally I said I would give Charlie until the end of 2013 before I re -inspected, it is now 2015 and
I am concerned to hear of any ventures involving this non -compliant WWTP.
Your email below to Marcus has me confused. My conversation with MSD did not indicate they had been
involved in conversations for several month regarding this venture, who at DENR did you verify what with, the
composting operation will send its stormwater to the WWTP, profiled wastewaters from various customers via
drums/tankers (this raises many questions)?
It was my understanding that the WWTP permit was to be rescinded and the WWTP closed out once the new
sewerline was installed.
If you or Charlie would please contact me regarding this venture, as well as setting up another inspection of the
facility.
Thank you,
Linda.Wiggs(a-)ncdenr.gov
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Resources Home Page
http://portal.ncdenr.org/web/Wq
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and therefore may be disclosed to third parties.
From: [e-mail] [mailto:[e-mail]]
Sent: Friday, February 27, 2015 4:41 PM
To: [e-mail]
Cc: [e-mail]; [e-mail]; [e-mail]; Wiggs, Linda
Subject: Re: WWTP connection criteria
Importance: High
This is great, thanks.
We have in place prior to the proposed connection a state certified mag meter that is typical for waste water treatment
plants will that suffice as a meter?
Thanks,
Denese
Sent from my Verizon 4G LTE Smartphone

i
------ Original message ------
From: Natalie Berry
Date: Fri, Feb 27, 2015 4:19 PM
To: Denese Ballew;
Cc: Greg Wiggins;Marcus Jones; [e-mail];Wiggs, Linda;
Subject:WWTP connection criteria
Denisa,
Attached our response to your request. If you have any questions please do not hesitate to ask.
Thanks and have a wonderful weekend.
Natalie
From: Denese Ballew fmailto:deneseballew(a)�yahoo.com]
Sent: Thursday, February 26, 2015 3:37 PM
To: Marcus Jones
Cc: Natalie Berry; Greg Wiggins; Charlie Owen; Rob Rusnak
Subject: Re: MSD Line Connection
Marcus„
Thanks for getting back with me so promptly.
I have been talking with MSD about our operation for several months now & it did need special
consideration but we are past that point now.
We are not connecting a composting operation (the composting operation willdischarge its storm
water to the WWTP to be treated), as I mentioned earlier we are needing to tie .the waste water
treatment plant (WWTP) line into the MSD line.
This makes the WWTP operation a Pre-treatment plant that discharges to MSD so we do not need a
DENR permit for this operation ( I have verified this with DENR).
If we start a composting operation it will be after this project is online & will then be permitted thru
DENR. If the County has any permit requirements for this operation please advise so we can plan for
those.
This pre-treatment facility will accept profiled waste waters from various customers via drums and
tanker trucks. Those drums/trucks will be screened upon entering the facility using handheld
monitoring instruments to assure us that the waste water in the drums/truck is in fact the same that
we agreed to take thru the waste profiling system.Please see the attached waste profile sheet (MSD
has already reviewed this). I am familiar with MSD's fee structure but if you have one I will need to
have a copy of that as well because this will affect our fee structure. Please also advise of any; other
requirements and/or information that the County will need us to provide to move forward.
There will ultimately be a few operations taking place at this facility over time which is why we are
phasing those operations in 1 at a time. I would be happy to discuss these operations further with you

and any colleagues you find appropriate ( originally planned to do this with all of the solid waste
directors 6t''1 time a little later) but will need you & those colleagues to sign a non -disclosure
agreement.
I am glad that we could clear up that little misunderstanding and please do not hesitate to call (828-
734-1374) or email with any further questions.
Thanks Again,
Denese i
From: Marcus Jones<maiones(c)-hendersoncountync.org>
To: Denese Ballew <deneseballew(c�Yahoo.com>
Cc: Natalie Berry <nberryCa.hendersoncountync.org>; Greg Wiggins<[e-mail]>
Sent: Thursday, February 26, 2015 2:55 PM
Subject: RE: MSD Line Connection
< d iv=,,,,,
4

Waste Pc -file HULcEnterprises
,A Highest if Lqw� Gerbon
Hl1LG Enterprises 4600 Hendersonville Road Fletcher, NC Recyclir solution
1. Generator Information
A. Generator Name
B. Generator Address
C. Generator Contact.
D. Generator EPA ID #
E. Generator Phone #
2. Waste Name (Use full name. Please no acronyms)
A. Name of Waste Stream
B. Describe The Process Generating The Waste _
C. Volume D. Frequency
III. Waste Stream Physical Characteristics
A. Flash Point ° F
D. Color/Appearance
G. Physical State
F. Billing Name
G. Billing Address
H. Billing Contact
I. Billing Phone #
J. HULC Enterprises Sale Contact
E. Waste Container (Truck, Drum...)
B. pH C. Density (#/gallon or S.G.)
E. Solids (%) F. Odor
H. Phases/Layers Single _ or Multiple _ I. BTU Value_
IV. Chemical Composition -Constituents - Do Not Use Generic Terms -(eg. Organics, salts, solids, oils) Attach MSDS (Products)
(% or PPM) M or PPM)
(% or PPM) (% or PPM)
(%or PPM) M or PPM)
(%or PPM) M or PPM)
(% or PPM) (% or PPM)
No Acronyms Please Use Full Chemical Name Total % (must =1009q
V.Waste Content -Please Indicate If The Waste Contain Any Of The Following: (Attach Analytical Where Applicable)
Sulphide ppm Yes _No_ Radioactive Yes _ No _ Pesticide/Herbicide Yes —No —
Cyanide ppm Yes _ No _ PCB's > 50 ppm Yes _ No _ Explosive Material Yes —No _
Benzene ppm Yes _ No _ PCB TSCA Waste Yes _ No _ Dioxins Yes _ No _
OSHA Concerns Yes No

VI. Regulatory Determination
A. Is This Waste Being Considered For Waste Water Treatment? Yes _ No
> 1%TOC and > 1%TSS? Yes_ No _ ( if so please complete pages 2 & 3)
B. Is This Waste a US EPA Hazardous Waste (40 CFR Part 261) Yes _ No
C. Is This a DOT Regulated Material? Yes _ No
VII. Desired Treatment Technology
Generator Waste Disposal Preference: _ Subtitle C/D Landfill _ Waste to Energy _ Kiln Fuels _ Recycling
Waste Water Treatment _ Oil Recovery _ Recycling/Universal Waste
Vill. Generators Certification
Signature Printed or Typed Name and Title Date
THE SAMPLE SUBMITTED IS REPRESENTATIVE AS DEFINED IN 40 CFR 261 APPENDIX I. 1 HEREBY CERTIFY THATTHE ABOVE AND
ATTACHED DESCRIPTION IS COMPLETE AND ACCURATE TO THE BEST OF MY KNOWLEDGE AND ABILITY TO DETERMINE THAT
NO DELIBERATE OR WILLFUL OMISSIONS OF COMPOSITION OR PROPERTIES EXIST AND THAT ALL KNOWN OR SUSPECTED
HAZARDS HAVE BEEN DISCLOSED. I AUTHORIZE HULC ENTERPRISES TO OBTAIN A SAMPLE FROM ANY WASTE SHIPMENT FOR
PURPOSES OF RECERTIFICATION.
IX. HULC Enterprises LLC
Signature Printed or Typed Name and Title Date

To be considered for biological treatmentthe following acceptance parameters must be met
on inbound waste. Any waste deemed to exceed any of the parameters listed below will
require physical chemical treatment.
Metals
Concentration
Antimony
0.206 mg/I
Arsenic
0.104 mg/I
Cadmium
0.0962 mg/I
Chromium
0.487 mg/I
Cobalt
0.124 mg/I
Copper
0.301 mg/I
Lead
0.172 mg/I
Mercury
0.000739 mg/I
Nickel
1.45 mg/I
Silver
0.0351 mg/I
Tin
0.120 mg/I
Titanium
0.0618 mg/I
Vanadium
0.0662 mg/I,
Zinc
0.641 mg/I
CATEGORICAL ORGANICS
Parameter
Concentration
Bis(2- ethylhexyl Phthalate
0.158 mg/I
Carbazole
0.233 mg/I
o-Cresol
0.561 mg/I
p-Cresol
0.205 mg/I
n-Decane
3.31 mg/I
Fluoranthene
0.393 mg/I
n-Octadecane
0.925 mg/I
2,4,6-Trichlorophenol
0.106 mg/I
OTHER LOCAL SEWER USE LIMITATIONS
Parameter
Concentration
Total Phenol
5.0 mg/I
Polar Material
200.0 mg/1
Non -Polar Material
100.0 mg/I
Cyanide
0.4 mg/I
I certify that this waste stream as described in the Generators -Waste Profile (GWP) DOES NOT
these constituents above the limitations listed above, unless otherwise specified.
Signature Date

Total Toxic Organics
ORGANIC PESTICIDES PCBs
ORGANICS - VOLATILES &
SEMI-VOLATILES
ORGANICS - VOLATILES &
SEMI-VOLATILES Cont'd
4,4- DDE
Acenaphthene
cis-1,3-Dichloropropylene
4,4- DDD
Acetonitrile
Diethylphthalate
4,4- DDT
Acrolein
4,6-dinitro-o-cresol
Aldrin
Acrylonitrile
2,4-Dinitrophenol
Arochlor - 1016
Anthracene
2,4-Dinitrotoluene
Arochlor - 1221
Benzene
2,6-Dinitrotoluene
Arochlor - 1232
Benzindene
Di-n-Octylphthalate
Arochlor - 1242
Benzoic Acid
1,2-diphenyl hydrazine
Arochlor - 1248
Benzo (a) Anthracene
Ethylbenzene
Arochlor- 1254
Benzo (b) Fluoranthene
bis-2-(Ethylhexyl) Phthalate
Arochlor -1260
Benzo (k) Fluoranthene
Fluorene
Alpha - BHC
Benzo (g,h,i) Perylene
Hexachlorobenzene
Beta - BHC
Benzo (a) Pyrene
Hexachloroburadiene
Chlordane
Bromodichloromethane
Hexachlorocyclopentadiene
Delta - BHC
Bromomethane
Indeno (1,2,3 cd)Pyrene
Dieldrin
4-Bromophenyl-Phenylether
Isophorone
Endosulfan I Alpha
Butylbenzylphtha late
Naphthalene
Endosulfan II Beta
Carbon Tetrachloride
Nitrobenzene
Endosulfan Sulfate
Chlorobenzene
2-Nitrophenol
Endrin
p-Chloro-m-cresol
4-Nitrophenol
Endrin Aldehyde
Chlorodibromomethane
2-Nitrosodimethylamine
Gamma - BHC
Chloroethane
N-Nitroso-Di-N-Propylamine
Heptachlor
bis-(2-chloroethoxy)methane
Pentachlorophenol
Heptachlor Epoxide
bis-(2-chloroethoxy)Ether
Phenanthrene
2,3,7,8 TCDD
2- Chloroethyl Vinyl Ether
Chloroform
Phenol
Pentachlorodibenzo p-dioxins
bis-(Chloroisopropyl) Ether
Chloromethane
Pyrene
Toxaphene
2-Chloronaphthalene
1,1,2,2, Tetrachloethane
2-Chlorophenol
Tetrachloroethylene
4-Chlorophenyl-Phenylether
Chrysene
Toluene
Dibenzo (a,h) Anthracene
Tribromomethane
Di-n-Butylphthalate
1,2,4, Trichlorobenzene

1,2- Dichlorobenzene
1,1,1, Trichloroethane
1,3- Diclorobenzene
1,1,2, Trichloroethane
1;4- Dichlorobenzene
Trichloroethylene
3,3-Dichlorbenzidine
Vinyl Chloride
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
trans-1,2-Dichloroethylene
Dichloromethane
2,4-Dichlorophenol
1,2-Dichloropropane
i
Does yourfacility manufacture, store, recycle or blend chemical compounds? If yes please answerthe
following:
1) Does your process involve phase transfer catalyst such as alkyl ammonia compounds? _ Yes _ No
2) Does your facility manufacture, store, or blend fungicides, algacides or biocides? _ Yes _ No
Generator Certification: I certify that the above toxic organics are NOT present in the waste described
by the attached Generators Waste Profile unless otherwise specified.
Signature Date

Wiggs, Linda
From:
[e-mail]
Sent:
Friday, February 27, 2015 4:41 PM
To:
[e-mail]
Cc:
[e-mail]; [e-mail];
[e-mail]; Wiggs, Linda
Subject:
Re: WWTP connection criteria i
I
Importance:
High
This is great, thanks.
i
(will
We have in place prior to the
proposed connection a state certified mag meter that is typical for waste water treatment plants that
suffice as a meter?
Thanks,
Denese
Sent from my Verizon 4G LTE Smartphone
------ Original message ------
From: Natalie Berry i
Date: Fri, Feb 27, 2015 4:19 PM
To: Denese Ballew;
Cc: Greg Wiggins;Marcus Jones;[e-mail];Wiggs, Linda;
Subject: WWTP connection criteria
Denisa,
Attached our response to your request. If you have any questions please do not hesitate to ask.
Thanks and have. a wonderful weekend.
Natalie
From: Denese Ballew [mailto:[e-mail]]
Sent: Thursday, February 26, 2015 3:37 PM
To: Marcus Jones
Cc: Natalie Berry; Greg Wiggins; Charlie Owen; Rob Rusnak
Subject: Re: MSD Line Connection
Marcus,.
Thanks for getting back with me so promptly.
I have been talking with MSD about our operation for several months now & it did need special
but we are past that point now.
We are not connecting a composting operation (the_ composting operation will discharge its storm wate�,to the
WWTP to be treated), as I mentioned earlier we are needing to tie the waste water treatment plant (WWTP) line
into the MSD line.
This makes the WWTP operation a Pre-treatment plant that discharges to MSD so we do not need a DENR
permit for this operation ( I have verified this with DENR).
1

If we start a"composting operation it will be after this project is online & will then be permitted thru DENR. If
the County has any permit requirements for this operation please advise so we can plan for those.
This pre-treatment facility will accept profiled waste waters from various customers via drums and tanker
trucks. Those drums/trucks will be screened upon entering the facility using handheld monitoring instruments to
assure us that the waste water in the drums/truck is in fact the same that we agreed to take thru the waste
profiling system.Please see the attached waste profile sheet (MSD has already reviewed this). I am familiar with
MSD's fee structure but if you have one I will need to have a copy of that as well because this will affect our fee
structure. Please also advise of any other requirements and/or information that the County will need us to
provide to move forward.
There will ultimately be a few operations taking place at this facility over time which is why we are phasing
those operations in 1 at a time. I would be happy to discuss these operations further with you and any colleagues
you find appropriate ( originally planned to do this with all of the solid waste directors at 1 time a little later) but
will need you & those colleagues to sign a non -disclosure agreement.
1 am glad that we could clear up that little misunderstanding and please do not hesitate to call (828-734-1374) or
email with any further questions.
Thanks Again,
Denese
From: Marcus Jones <majones hendersoncountync.org>
To: Denese Ballew <deneseballew(a_yahoo.com>
Cc: Natalie Berry <nberry(-hendersoncountync.ora>; Greg Wiggins<gwiggins(a)-hendersoncountync.org>
Sent: Thursday, February 26, 2015 2:55 PM
Subject RE: MSD Line Connection
<_div=""> ,

Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Resources Home Page
hftp://i)ortal.ncdenr.org/web/wq
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and therefore may be disclosed to third parties.
From: deneseballew(aDyahoo.com fmailto:deneseballew(ayahoo.com]
Sent: Friday, February 27, 2015 4:41 PM
To: [e-mail]
Cc: gwiggins(a-)hendersoncountync.org; m_ aiones(c)-hendersoncountync.org; JonVH(c)_msdbc.org; Wiggs, Linda
Subject: Re: WWTP connection criteria
Importance: High
This is great, thanks.
We have in place prior to the proposed connection a state certified mag meter that is typical for waste water treatment
plants will that suffice as a meter?
Thanks,
Denese
Sent from my Verizon 4G LTE Smartphone
------ Original message ------
From: Natalie Berry
Date: Fri, Feb 27, 2015 4:19 PM
To: Denese Ballew;
Cc: Greg Wiggins;Marcus Jones; [e-mail];Wiggs, Linda;
Subject:WWTP connection criteria
Denisa,
Attached our response to your request. If you have any questions please do not hesitate to ask.
Thanks and have a wonderful weekend.
Natalie
From: Denese Ballew fmailto:deneseballew(o-)_yahoo.com]
Sent: Thursday, February 26, 2015 3:37 PM
To: Marcus Jones
Cc: Natalie Berry; Greg Wiggins; Charlie Owen; Rob Rusnak
Subject: Re: MSD Line Connection
Marcus,
Thanks for getting back with me so promptly.
I have been talking with MSD about our operation for several months now & it did need special
consideration but we are past that point now.

We are not connecting a composting operation (the composting operation will discharge its storm
water to the WWTP to be treated), as I mentioned earlier we are needing to tie the waste water
treatment plant (WWTP) line into the MSD line.
This makes the WWTP operation a Pre-treatment plant that discharges to MSD so we do not need a
DENR permit for this operation ( I have verified this with DENR).
If we start a composting operation it will be after this project is online & will then be permitted thru
DENR. If the County has any permit requirements for this operation please advise so we can plan for
those.
This pre-treatment facility will accept profiled waste waters from various customers via drums and
tanker trucks. Those drums/trucks will be screened upon entering the facility using handheld
monitoring instruments to assure us that the waste water in the drums/truck is in fact the same that
we agreed to take thru the waste profiling system.Please see the attached waste profile sheet (MSD
has already reviewed this). I am familiar with MSD's fee structure but if you have one I will need to
have a copy of that as well because this will affect our fee structure. Please also advise of any other
requirements and/or information that the County will need us to provide to move forward.
There will ultimately be a few operations taking place at this facility over time which is why we are
phasing those operations in 1 at a time. I would be happy to discuss these operations further with you
and any colleagues you find appropriate ( originally planned to do this with all of the solid waste
directors at 1 time a little later) but will need you & those colleagues to sign a non -disclosure
agreement
I am glad that we could clear up that little misunderstanding and please do not hesitate to call (828-
734-1374) or email with any further questions.
Thanks Again,
Denese
From: Marcus Jones<majones(d-)hendersoncountync.org>
To: Denese Ballew <deneseballewna.yahoo.com>
Cc: Natalie Berry <nberry(a_)hendersoncountync.org>; Greg Wiggins<gwiggins(c�hendersoncountync.org>
Sent: Thursday, February 26, 2015 2:55 PM
Subject: RE: MSD Line Connection
<=fill div=flll>

Wiggs, Linda
From: Natalie Berry <[e-mail]>
Sent: Friday, February 27, 2015 4:19 PM
To: Denese Ballew
Cc: Greg Wiggins; Marcus Jones; [e-mail]; Wiggs, Linda
Subject: WWTP connection criteria
Attachments: Criteria for WWTP.pdf
Importance: High
Denisa,
Attached our response to your request. If you have any questions please do not hesitate to ask.
Thanks and have a wonderful weekend.
Natalie
From: Denese Ballew [mailto:[e-mail]]
Sent: Thursday, February 26, 2015 3:37 PM
To: Marcus Jones
Cc: Natalie Berry; Greg Wiggins; Charlie Owen; Rob Rusnak
Subject: Re: MSD Line,Connection
Marcus,
Thanks for getting back with me so promptly.
I have been talking with MSD about our operation for several months now & it did need special consideration
but we are past that point now.
We are not connecting a composting operation (the composting operation will discharge its storm water to the
WWTP to be treated), as I mentioned earlier we are needing to tie the waste water treatment plant (WWTP) line
into the MSD line.
This makes the WWTP operation a Pre-treatment plant that discharges to MSD so we do not need a DENR
permit for this operation ( I have verified this with DENR).
If we start a composting operation it will be after this project is online & will then be permitted thru DENR. If
the County has any permit requirements for this operation please advise so we can plan for those.
This pre-treatment facility will accept profiled waste waters from various customers via drums and tanker
trucks. Those drums/trucks will be screened upon entering the facility using handheld monitoring instruments to
assure us that the waste water in the drums/truck is in fact the same that we agreed to take thru the waste
profiling system.Please see the attached waste profile sheet (MSD has already reviewed this). I am familiar with
MSD's fee structure but if you have one I will need to have a copy of that as well because this will affect our fee
structure. Please also advise of any other requirements and/or information that the County will need us to
provide to move forward.

There will ultimately be a few operations taking place at this facility over time which is why we are phasing
those operations in 1 at a time. I would be happy to discuss these operations further with you and any colleagues
you find appropriate ( originally planned to do this with all of the solid waste directors at 1 time a little later) but
will need you & those colleagues to sign a non -disclosure agreement.
I am glad that we could clear up that little misunderstanding and please do not hesitate to call (828-734-1374) or
email with any further questions.
Thanks Again,
Denese
From: Marcus Jones <maiones .hendersoncountync.org>
To: Denese Ballew <deneseballew(c�yahoo.com>
Cc: Natalie Berry <nberry(o�,hendersoncountync.orq>; Greg Wiggins<gwigginsahendersoncountync.org>
Sent: Thursday, February 26, 2015 2:55 PM
Subject: RE: MSD Line Connection
Denese,
We still have not received any details of your request but assume it is to connect a composting operation to
public sewer. We have already -developed a list of considerations and have contacted MSD and DENR for
their review and feedback. This type of connection is not typical and does not fit ours or MSD's fee structure or
DENR's permit rules. Special consideration will likely be needed in order to provide service. Unfortunately,
this will take some time.
Please provide details of your request for sewer service. The only correspondence we have received from you
is the email below:
Good Afternoon,
On Monday 1 sent an e-mail to Natalie ( but I cant find evidence that it was sent) so in an effort to
reach the correct person l decided to send this email to each of you.
Some business partners and 1 are bringing the WWTP at Fletcher Warehousing back online as a pre-
treatment facility that will discharge to MSD's line. When I called MSD about tapping into the line they
said to talk to Natalie first then we could proceed with them (that is the purpose of this email).
My question to you all is what do you need from us? If necessary we can meet you at the site & show
you where we want to tap into the line. Please advise on how to proceed.
Thanks,
Denese
All e-mail correspondence to and from this address is subject to the North Carolina Public Records
Law, which may result in monitoring and disclosure to third parties,

From: Denese Ballew[mailto:deneseballew()-yahoo.com]
Sent: Thursday, February 26, 2015 1:31 PM
To: Natalie Berry; Marcus Jones; Greg Wiggins -
Cc: Charlie Owen; Rob Rusnak
Subject: MSD Line Connection
Good Afternoon,
I wanted to touch base about this again because it is imperative for us to be able to move forward on
this operation.
I understand about out of Town work and inclement weather but for us the reality is each week we
have to put off is another week added to the time -frame it takes us to get into business and generate
income.
If a conference call with the project partners will help great lets do it.
Ultimately we need to know what you need from us so that we can tie into the line and begin
accepting waste water.
Stay safe & warm.
Thanks,
Denese Ballew
Spam
Not spam
Forget previous vote
Spam
Not spam
Forget previous vote

TO: Denisa Ballew
FROM: Natalie J. Berry, PE, Assistant County Engineer
DATE: February 27, 2015
SUBJECT: WWTP at Fletcher Warehouse as pre-treatment facility
Ms. Ballew,
Thank you for your request for sewer service from the Cane Creek Water and Sewer District. We are excited
about having your business in Henderson County. The conditions around your service request are not typical
and will require some additional information to process. Unfortunately, it does not fit within our published '
design standards or fee structure. We need to make sure we are providing service at a minimal cost to youl
but also recovers expenses associated with your service. Also of course, we must make sure the resulting
service is complaint with our collection permit with DENR.
It is our understanding that MSD of Buncombe is waiting for a response to pre-treatment questions regarding
your proposed wastewater. In addition, to a satisfactory response to MSD we will need to review an
Engineered plan for your connection that addresses at least the following:
• Detail plan of the actual connection from the WWTP to our system to include a meter (if no water
meter) and any necessary additions for pre-treatment and testing.
• A detailed schedule and description of any future plans for the business that impact the sewer
service.
• What is the estimated flow? What is the impact of the peak flow on our downstream lift station?
• What is the equivalent water meter for the estimated flow (MSD and our fees are calculated based ion
water meter size).
Thanks again for your interest and please do not hesitate to contact us should you or your Engineer have any
questions.
Cane Creek Water and Sewer District
100 N. King Street, Suite 210
Hendersonville, NC 28792
[phone]

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Permit NC0000094
A. (I.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning November 1, 2001 and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
E
REMENI'S
GHARAC7I:RJTIS'
rNIL
1� t
N�cnthly
pa�ly
MeaApr, met
5ar�pie Type
sample lacOtianl
Avers e
_.9_ _.
u
Mx,m.,.m
Ere uenc
q Y
�.:
b'
Flow
0.01 MGD
Continuous
Recording
Effluent
BOD, 5 day (20°C)
26.0 mg/I
39.0 mgll
Weekly
Grab
Effluent
Total Suspended Solids
30.0 mg/I
45.0 rng/l
Weekly
Grab
Effluent
NH3 as N
Weekly
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
Effluent
Upstream & Downstream
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Weekly
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine
28 /.jg/I
2/Week
Grab
Effluent
Total Nitrogen (NO2+NO3+TKN)
Quarterly
Grab
Effluent
Total Phosphorus
Quarterly
Grab
Effluent
Temperature (°C)
Weekly
Grab
Effluent
Upstream & Downstream
pH3
Weekly
Grab
Effluent
Footnotes:
1. Upstream = upstream at the Butler Bridge; Downstream = downstream at the Fanning Bridge.
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

I
...v
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild; P. E. John E. Skvarla, III
Governor Director Secretary
March 22, 2013
Charles Dexter Owen III, President
Fletcher Warehousing Company
P.O. Box 188
Fletcher, North Carolina 28732
APR 1 1 2013
DWQ/Surface Water Protection Section
Asheville Reggional Office
Subject: Issuance of NPDES Permit NC0000094
Fletcher Warehousing Company
Henderson County
Dear Mr. Owen:
Division personnel have reviewed and approved your application for renewal of the subject
permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit 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 (or as subsequently amended).
The following changes have been incorporated into this permit renewal:
0 The receiving stream classification was changed from.WS-IV to B in 2002 and the
Supplement to Cover page was updated to reflect this change..
A footnote for Total Residual Chlorine monitoring was added to Section A.(L) as
follows: TRC limit and monitoring requirement only apply if chlorine is used for
disinfection. The Permittee shall report all effluent TRC values reported by a NC -
certified laboratory [including field -certified]. Effluent values below 50 µg/L will be
treated as zero for compliance purposes.
The Division recognizes that Phis facility was designed to treat 4 MGD of industrial textile wastewater
and it is recommended that the small volume of 100% domestic wastewater from < 25 employees
would be better treated if discharged to the local POTW. It is our understanding that the permittee is
pursuing a connection to the City sewer line and will request rescission of the NPDES Permit once this
is completed.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 9IM07-6492
Internet www.ncwaterauality.org
NorthCarolina
Naturally
An Equal Opportunity 1 Affirmafive Action Employer

4
Page 2 0£ 2
If any parts, measueement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-
6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division
may require, modification or revocation and reissuance of the permit. This permit does not affect
the. legal requirements to obtain other permits which may be required by the Division of Water
Quality or permits required by the Division of Land Resources, the Coastal Area Management
Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Julie Grzyb by email
[e-mail]) or phone at [phone].
Sincerely,
6�* Vt '4
Charles Wakild P.E.
Enclosure: NPDES Permit NC0000094
cc: NPDES Unit
Central Files
Ashville Regional -Office /-LiadaWiggs, Surface Water Protection Section,"
e-copy:
W. Perry Fisher, II, Fisher Stark P.A. Attorneys, 35 N. Market St., Asheville, NC 28801
Henry Dyar, Project Manager, Goldie & Associates, 210 N. Second St., Seneca, SC 29678

Permit. NC000009
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
i
i
In compliance with the provision of_North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended, 1
Fletcher Warehousing Company
is hereby authorized to discharge wastewater from a facility located on
4600 Hendersonville Highway (Route 25)
Fletcher
Henderson County
to receiving waters designated as the French Broad River in the French Broad Riv
Basin in accordance with effluent limitations, monitoring requirements and other
conditions set forth in Parts I, II, and III hereof.
This permit shall become effective May 1, 2013.
This permit and authorization to discharge shall expire at midnight on November 30, 201;
Signed this day March 22, 2013.
X/vo
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0000094
i
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoke& As of this permit 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.
Fletcher Warehousing Company is hereby authorized to:
1. Continue to operate an existing (4.0 MGD) extended aeration wastewater
treatment facility at a monthly average flow not exceeding 0.01 MGD which
includes the following components:
Influent lift station with manual trash screen
➢'';'Dual 3.75 MGD aeration basins with mechanical aerators
➢; ',Dual final clarifiers with sludge return (no sludge is returned)
➢';Effluent disinfection equipment
➢ ', Flow meter
This facility is located at the former Cranston Print Works plant in Fletcher on
Route 25 in Henderson County, and
2. Discharge from said treatment works at the location specified on the attached map
into the French Broad River. classified B waters in the French Broad River Basin.
Page 2 of 4

A. (I.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Permit NC0000094
I
i
During the period beginning on the effective date of the permit until expiration, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
EFFLUENT'
F
LIMIT S.
:MONITORING REQUIREMENTS:
_� _
.
CHARACTERISIA TICS?
r__ Monthly
Daily
,Measurement
sample Type
', _u Sam IesLocationh
Average_
, :Maximums
-- Frequency
,_,____v4"
! ......
Flow^
0.01 MGD
Continuous
Recording
Effluent
BOD, 5 day 20°C
26.0 mg/L
39.0 mg/L
Weekly
Grab
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Weekly
Grab
Effluent
NH3 as N
Weekly
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
Effluent
Upstream & Downstream
Fecal Coliform (geometric mean)
200/100 mL
4001100 mL
Weekly
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine3
28 pg/L
2/Week
Grab
Effluent
Total Nitrogen NO2+NO3+TKN
Quarterly
Grab
Effluent
Total Phosphorus
Quarterly
Grab
Effluent
Temperature (°C)
Weekly
Grab
Effluent
Upstream & Downstream
pH4
Weekly
Grab
Effluent
Footnotes:
1. Upstream = upstream at the Butler Bridge; Downstream = downstream at the Fanning Bridge.
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
3. TRC limit and monitoring requirement only apply if chlorine is used for disinfection. The Permittee
shall report all effluent TRC values reported by a NC -certified laboratory [including field -certified]
Effluent values below 50 jig/ L will be treated as zero for compliance purposes.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace "amounts.
Page 4 of 4

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Latitude: 35°24'43"
N C 0 0 0 0 0 9 4
Longitude: 82°32'18"
Quad# F8NE
Stream Class:
Fletcher Warehousing
02
8-Digitxuc: 06010105
1Company
Receiving Stream: French Broad River
Facility I>�
Location
North Not to Scale
Page 3 of 4

' 1
NPDES Permit Standard Con itions
Page 1 of 18
j PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month j
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the sample period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 1251 j et.
seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric mean of such discharges. I
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which is
not a designed or established or operating mode for the facility.
Calendar Day
The.period from midnight of one day until -midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL
such a manner as to result in a total sample representative of the wastewater discharge during the sample period.'
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time int
between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Comp
samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a, 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series,of grab samples collected at equal time intervals over a 24 hour , eriod
of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or ,
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point,1 Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system, or
Version 1110912011

NPDES Permit Standard Conditions
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(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
➢ Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
➢ Influent samples shall not be collected more than once per hour.
➢ Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. For pollutants expressed in other units of measurement, the
"daily discharge" is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also
"Composite Sample," above.)
Daily Maximum
The highest "daily discharge" during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. Sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations
prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s), that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWQ or "the Division"
The Division of Water Quality, Department of Environment and Natural Resources.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = 1.
Grab Sample
Individual samples of at least 100 mL collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Version 1110912011

NPDES Permit Standard Conditions
Page 3 of 18
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the. same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
Monthly Average (concentration limit) ,
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Average (concentration limit)
The arithmetic mean of all samples taken over a calendar quarter:
Severe property damage i
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a�
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the-CWA.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Section B. General Conditions
1. Dpty to Comply
.The Permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a permit renewal application [40 CFR 122.41 ].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the;
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section;
405(d) of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any such sections in a permit issued under section 402, or any
requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is
subject to 'a civil penalty not to exceed $37,500 per day for each violation. [33 USC 1319(d) and 40 CF
122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or 405 of
the Act, or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or
402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
Version 1110912011

NPDES Permit Standard Conditions
Page 4 of 18
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a negligent
violation, a person shall be subject to criminal penalties of not more than $50,000 per day of violation, or by
imprisonment of not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In the
case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act, and
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not more than
15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a
person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or
both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating
the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to
$2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections
in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are not to
exceed $16,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$37,500. Penalties for Class II violations are not to exceed $16,000 per day for each day during which the
violation continues, with the maximum amount of any Class 11 penalty not to exceed $177,500. [33 USC
1319(g)(2) and 40 CFR 122.41(a)(3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on 'Bypassing" (Part II.C.4), "Upsets" (Part H.C.5) and 'Power Failures"
(Part II.C.7), nothing in this permit shall be construed to relieve the Permittee from any responsibilities, liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or .
facilities or the undertaking of any work in any navigable waters.
Version 1110912011

NPDES Permit Standard Conditions
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7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of
this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby [NCGS .15013-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the Permit
Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41(h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to
discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required
by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director. (The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing permit.) [40 CFR 122.21(d)] Any Permittee that has not
requested renewal at least 180 days prior to expiration, or any Permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will subject the Permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified [40
CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible I.
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in cha
of a principal business function, or any other person who performs similar policy or decision making'
functions for the corporation, or (b) the manager of one or more manufacturing, production, or oper�tir
facilities, provided, the manager is authorized to make management decisions which govern the operat;
of the regulated facility including having the explicit or implicit duty of making major capital invest
recommendations, and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations; the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for pen
application requirements; and where authority to sign documents has been assigned or delegated toT.�
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer, or
ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above'or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the overall operatic
of the regulated facility or activity, such as the position of plant manager, operator of a well or well eld;
superintendent, a position of equivalent responsibility, or an individual or position.having overall
responsibility for environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
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c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate because
a different individual or position has responsibility for the overall operation of the facility, a new authorization
satisfying the requirements of paragraph (b) of this section must be submitted to the Director prior to or
together with any reports, information, or applications to be signed by an authorized representative [40 CFR
122.221
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"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 orpersons 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. "
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes
or anticipated noncompliance does not stay any permit condition [40 CFR 122.41(f)].
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit,
revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 02H .0100; and North Carolina General Statute 143.215.1 et. al.
14. Annual Administering; and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H .0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Owners of classified water pollution control systems must designate operators, certified by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), of the appropriate type and grade for the
system, and, for each classification must [T15A NCAC 08G .0201]:
a. designate one Operator In Responsible Charge (ORC) who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s) in Responsible Charge (Back-up ORCs) who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system, with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year, and
c. submit a signed completed "Water Pollution Control System Operator Designation Form" to the Commission
(or to the local health department for owners of subsurface systems) countersigned by the designated certified
operators, designating the Operator in Responsible Charge (ORC) and the Back-up Operator in Responsible
Charge (Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
➢ receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge (ORC) and Back-up Operator in Responsible Charge (Back-up ORC)
of the proper type and grade; or
➢ a vacancy in the position of Operator in Responsible Charge (ORC) or Back-up Operator in
Responsible Charge (Back-up ORC).
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(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least weekly
➢ Comply with all other conditions of 15A NCAC 08G .0204.
The ORC of each Class H, III and IV facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least five days per week, excluding holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 08G .0204.
2. Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with- the conditions of the permit [40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] of a
member of the Permittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.i1(c)]:
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41(m)(3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior nc
if possible at least ten days before the date of the bypass; including an evaluation of the anticipated qu
and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in P
ail
II.E.6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforces
action against a Permittee for a bypass as provided in any current or future system -wide collection
permit associated with the treatment facility.
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(3).-'The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
,(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.41(n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of
this condition are met. No determination made during administrative review of claims that noncompliance was
caused by upset, and before an action for noncompliance, is final administrative action subject to judicial
review.
b. Conditions necessary for a demonstration of upset: Any Permittee who wishes to establish the affirmative
defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(1)' An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II.E.6.(b) of this permit.
(4):The Permittee complied with any remedial measures required under Part II.13.2. of this permit.
C. Burden of proof [40 CFR 122.41(n)(4)]: The Permittee seeking to establish the occurrence of an upset has
the; burden of proof in any enforcement proceeding.
.11
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be;utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted
by the Commission. The Permittee shall comply with all applicable state and Federal regulations governing the
disposal of sewage sludge, including 40 CFR 503, Standards for the Use and Disposal of Sewage Sludge; 40 CFR
Part 258, Criteria For Municipal Solid Waste Landfills; and 15A NCAC Subchapter 2T, Waste Not Discharged To
Surface Waters. The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 02H .0124) to
prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means
of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitorinst and Records
1. Representative Sampling
Sample's` collected and measurements taken, as required herein, shall be representative of the permitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream, body of
water, or substance. Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing'Authority [40 CFR 122.410)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly; Discharge Monitoring Report (DMR) Form (MR 1, 1. 1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the last calendar day of the month following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
faciliy, on the last day of the month following the commencement of discharge. Duplicate signed copies of these,
and all other reports required herein, shall be submitted to the following address:
a;
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NC DENR / Division of Water Quality / Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I of
this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division. Permittees should contact the Division's
Laboratory Certification Section (919 733-3908 or http://portal.nedenr.org/web/wq/lab/cert) for information
regarding laboratory certifications.
Facilities whose personnel are conducting testing of field -certified parameters only must hold the appropriate ;field
parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to NCGS
143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section
304(g), 33 USC 1314, of the CWA (as amended), and 40 CFR 136; or in the case of sludge use or disposal,
approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been
specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reportedidown
to the minimum detection or lower reporting level of the procedure. If no approved methods are determined
capable of achieving minimum detection and reporting levels below permit discharge requirements, then the most
sensitive (method with the lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring
device or method required to be maintained under this permit shall, upon conviction, be punished by a fine o not
more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more than 4 years,
or both [40 CFR 122.411.
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge use
and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR
503), the Permittee shall retain records of all monitoring information, including:
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41]. j
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7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Pemuttee shall record the
following information [40 CFR 122.411:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. 'The date(s) analyses were performed;
d. The individuals) who performed the analyses;
e. The' analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting as
a representative of the Director), upon the presentation of credentials and other documents as may be required by
law, to;
a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;
c. 'Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the CWA, any substances or parameters at any location [40 CFR 122.41(i)].
Section E . Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the permit.
2. Planned' Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the'permitted facility [40 CFR 122.41(1)]. Notice is required only when:
a. The' alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122:29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42(a)(1); or
c. The; alteration or addition results in a significant change in the Permittee's sludge use or disposal practices, and
such alteration, addition or change may justify the application of permit conditions that are different from or
absent in the existing permit, including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41(1)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61. The Director may condition approval in accordance with NCGS 143-215.1, in
particular NCGS 143-215. 1 (b)(4)b.2., and may require modification or revocation and reissuance of the permit, or
a minor, modification, to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA [40 CFR 122.41(1)(3), 122.61] or state statute.
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5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.D.2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge, the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40
CFR 122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part H.E.5 and 6. of this permit at the
time monitoring reports are submitted. The reports shall contain the information listed in Part II.E.6. of this permit
[40 CFR 122.41(1)(7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or
information [40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in -the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances. j
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility. j
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division. As required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215. 1 (b)(2) or in Section 309 of the Federal Act.
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11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement, representation, or certification in
any record or other document submitted or required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than
$25,000 per violation, or by imprisonment for not more than two years per violation, or by both [40 CFR 122.41].
12. Annual Performance Reports
Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an, annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.1C). The
report shall summarize the performance of the collection or treatment system, as well as the extent to which the
facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality. The
report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon which
annual period is used for evaluation.
The report shall be sent to:
NC DENR / Division of Water Quality / Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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PART III
OTHER REQUIREMENTS
Section A. Construction
a. The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plants treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless (1) the Division has issued an
Authorization to Construct (AtC) permit or (2) the Permittee is exempted from such AtC permit requirements
under Item b. of this Section.
b. In accordance with NCGS 143-215.1(a5) [SL 2011-3941, no permit shall be required to enter into a contract for the
construction, installation, or alteration of any treatment work or disposal. system or to construct, install, or alter any
treatment works or disposal system within the State when the system's or work's principle function is to conduct,
treat, equalize, neutralize, stabilize, recycle, or dispose of industrial waste or sewage from an industrial facility and
the discharge of the industrial waste or sewage is authorized under a permit issued for the discharge of the
industrial waste or sewage into the waters of the State. Notwithstanding the above, the permit issued for the
discharge may be modified if required by federal regulation.
c. Issuance of an AtC will not occur until Final Plans and Specifications for the proposed construction have been
submitted by the Permittee and approved by the Division.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The. Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of
any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms per liter
(500 µg/L) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or infrequent
basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels"; i
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit. The Division may require specific measures during deactivation of the system to prevent adverse
impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the
permitted facility.
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PART IV
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Definitions
In addition to the definitions in Part II of this permit, the following definitions apply to municipal facilities:
Indirect Discharge or Industrial User
Any non -domestic source that discharges wastewater containing pollutants into a POTW regulated under section
307(b), (c) or (d) of the CWA. [40 CFR 403.3 (i) and 0) and 15A NCAC 02H .0903(b)(11)]
Interference
Inhibition or disruption of the POTW treatment processes; operations; or its sludge process, use, or disposal which
causes or contributes to a violation of any requirement of the Permittee's (or any satellite POTW's if different from the
Permittee) NPDES, collection system, or non -discharge permit or prevents sewage sludge use or disposal in
compliance with specified applicable State and Federal statutes, regulations, or permits. [15A NCAC 02H
.0903(b)(14)]
Pass Through
A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or with
discharges from other sources, causes a violation, including an increase in the magnitude or duration of a violation, of
the Permittee's (or any satellite POTW's, if different from the Permittee) NPDES, collection system, or non -discharge
permit. [15A NCAC 02H .0903(b)(23)]
Publicly Owned Treatment Works (POTW)
A treatment works as defined by Section 212 of the CWA, which is owned by a State or local government organization.
This definition includes any devices and systems used in the storage, treatment, recycling and reclamation of municipal
sewage or industrial wastes of a liquid nature. It also includes the collection system, as defined in 15A NCAC 2T
.0402, only if it conveys wastewater to a POTW treatment plant. The term also means the local government
organization, or municipality, as defined in section 502(4) of the CWA, which has jurisdiction over indirect discharges
to and the discharges from such a treatment works. In this context, the organization may be the owner of the POTW
treatment plant or the owner of the collection system into which an indirect discharger discharges. This second type of
POTW may be referred to as a "satellite POTW organization." [15A NCAC 02H .0903(b)(26)]
"Significant Industrial User" or "SIU"
An Industrial User that discharges wastewater into a publicly owned treatment works and that [15A NCAC 02H
.0903(b)(33)]:
1. Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary,
noncontact cooling and boiler blowdown wastewaters); or
2. Contributes process wastewater which makes up five percent or more of the NPDES or non -discharge permitted
flow limit or organic capacity of the POTW treatment plant. In this context, organic capacity refers to BOD, TSS
and ammonia; or
3. Is subject to categorical standards under 40 CFR Part 403.6 and 40 CFR Parts 405-471; or
4. Is designated as such by the Permittee on the basis that the Industrial User has a reasonable potential for adversely
affecting the POTW's operation or for violating any pretreatment standard or requirement, or the POTW's effluent
limitations and conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options;
5. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraphs 1 or 2 of this definition above has no reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement, the POTW's effluent limitations and
conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options, and thus is not a
Significant Industrial User (SIU); or
6. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraph 3 of this definition above meets the requirements of 40 CFR Part 403.3(v)(2) and thus is a
non -significant categorical Industrial User.
Section B. Publicly Owned Treatment Works (POTWs)
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NPDES Permit Standard Conditions
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I
All POTWs must provide adequate notice to the Director of the following [40 CFR 122.42(b)]:
1. Any new introduction of pollutants into the POTW from an indirect discharger, regardless of the means of
transport, which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants;
and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of effluent
introduced into the POTW, and (2) any anticipated impact that may result from the change of the quantity or
quality of effluent to be discharged from the POTW.
Section C. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from Industrial Users
discharging to the POTW may be present in the Permittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants, this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water quality
standards.
2. Prohibited Discharges
a. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibition against the
introduction of pollutants or discharges into the waste treatment system or waste collection system which,
cause or contribute to Pass Through or Interference as defined in 15A NCAC 02H .0900 and 40 CFR 403. [40
CFR 403.5(a)(1)]
b. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introduction of the following wastes in the waste treatment or waste collection system [40 CFR 403.5(b)]:
(1) Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade
using the test methods specified in 40 CFR 261.21;
(2) Pollutants which cause corrosive structural damage to the POTW, but in no case discharges with pH lower
than 5.0, unless the works is specifically designed to accommodate such discharges;
(3) Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
(4) Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow Irate
and/or pollutant concentration which will cause Interference with the POTW;
(5) Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C (104°F)
unless the Division, upon request of the POTW, approves alternate temperature limits;
(6) Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin in amounts that will cause
Interference or Pass Through;
(7) Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that
may cause acute worker health and safety problems; or
(8) Any trucked or hauled pollutants, except at discharge points designated by the POTW.
c. The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any information shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the Permittee becomes
aware of the circumstances. The written submission shall contain a description of the discharge; the
investigation into possible sources; the period of the discharge, including exact dates and times; if the
discharge has not ceased, the anticipated time it is expected to continue; and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the noncompliance,
Version 1110912011

NPDES Permit Standard Conditions
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3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance by
the Permittee with all applicable effluent limitations. Such actions by the Permittee may be necessary regarding
some or all of the industries discharging to the municipal system.
4. The Permittee shall require any Industrial User (IU) discharging to the POTW to meet Federal Pretreatment
Standards developed under Section 307(b) of the Act as amended (which includes categorical standards and
specific local limits, best management practices and narrative requirements). Prior to accepting wastewater from
any Significant Industrial User (SIU), the Permittee shall either develop and submit to the Division a new
Pretreatment Program or, as necessary, a modification of an existing Pretreatment Program, for approval as
required under section D below as well as 15A NCAC 02H .0907(a) and (b). [40 CFR 122.440)(2)]
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved POTW
Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program
as required under Section 402 (b)(8) of the CWA and implementing regulations or by the requirements of the
approved State pretreatment program, as appropriate.
Section D. Pretreatment Programs
Under authority of sections 307 (b) and (c) and 402(b)(8) of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3(14) and implementing regulations 15A NCAC 02H .0900, and in accordance
with the approved pretreatment program, all provisions and regulations contained and referenced in the pretreatment
program submittal are an enforceable part of this permit. [40 CFR 122.440)(2)]
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the CWA, 40
CFR 403, 15A NCAC 02H .0900, and the legal authorities, policies, procedures, and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof. Such operation shall include but is
not limited to the implementation of the following conditions and requirements. Terms not defined in Part H or Part IV
of this permit are as defined in 15A NCAC 02H .0903 and 40 CFR 403.3.
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 02H .0903(b)(32), .0905 and .0906(b)(1); 40 CFR 403.8(f)(1) and 403.9(b)(1) and (2)]
2. Industrial Waste Survey (IWS)
The Permittee shall implement an IWS consisting of the survey of users of the POTW collection system or
treatment plant, as required by 40 CFR 403.8(f)(2)(i-iii) and 15A NCAC 02H .0905 [also 40 CFR 122.440)(1)],
including identification of all Industrial Users that may have an impact on the POTW and the character and amount
of pollutants contributed to the POTW by these Industrial Users and identification of those Industrial Users
meeting the definition of SIU. Where the Permittee accepts wastewater from one or more satellite POTWs, the
IWS for the Permittee shall address all satellite POTW services areas, unless the pretreatment program in those
satellite service areas is administered by a separate Permittee with an approved Pretreatment Program. The
Permittee shall submit a summary of its IWS activities to the Division at least once every five years, and as
required by the Division. The IWS submission shall include a summary of any investigations conducted under
paragraph C.2.c. of this Part. [15A NCAC 02H .0903(b)(13), .0905 and .0906(b)(2); 40 CFR 403.8(f)(2) and 403.9]
3. Monitoring Plan
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data to
be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific pretreatment
local limits. Effluent data from the Plan shall be reported on the DMRs (as required by Parts II.D and II.E.5.). [15A
NCAC 02H .0903(b)(16), .0906(b)(3) and .0905]
4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a HWA at least once every five years, and as required by the
Division. Within 180 days of the effective date of this permit (or any subsequent permit modification) the
Permittee shall submit to the Division a written technical evaluation of the need to revise local limits (i.e., an
updated HWA or documentation of why one is not needed) [40 CFR 122.44]. The Permttee shall develop, in
accordance with 40 CFR 403.5(c) and 15A NCAC 02H .0909, specific Local Limits to implement the prohibitions
listed in 40 CFR 403.5(a) and (b) and 15A NCAC 02H .0909. Pursuant to 40 CFR 403.5, local limits are
Version 1110912011

NPDES Permit Standard Conditions
Page 17 of 18
enforceable Pretreatment Standards as defined by 40 CFR 403.3(1). [15A NCAC 02H .0903(b)(10), .0905, and
.0906(b)(4)]
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Pernttee shall issue to all Significant. Industrial Users, permits for
operation of pretreatment equipment_ and discharge to the Permittee's collection system or treatment works. These
permits shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control technologies to
assure that their wastewater discharge will meet all applicable pretreatment standards and requirements. The
Permittee shall maintain a current Allocation Table (AT) which summarizes the results of the HWA and the limits
from all IUPs. Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA. [15A NCAC 02H .0906(b)(6), .0909, .0916, and .0917; 40 CFR 403.5; 403.8(f)(1)(iii)
NCGS 143-215.67(a)]
6. . Authorization to Construct (AtQ
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable Industrial
Users for the construction or modification of any pretreatment facility. Prior to the issuance of an AtC, the
proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all
Industrial User Pretreatment Permit QUP) limitations. [15A NCAC 02H .0906(b)(7) and .0905; NCGS 143-
215. 1 (a)(8)]
7. POTW Inspection & Monitoring of their IUs
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by Industrial Users,
compliance with applicable pretreatment standards. [ 15A NCAC 02H .0908(e); 40 CFR 403.8(f)(2)(v)] The
Permittee must:
a. Inspect all Significant Industrial Users (S1Us) at least once per calendar year;
b. Sample all Significant Industrial Users (SIUs) at least once per calendar year for all SIU permit -limited
parameters including flow except as allowed under 15A NCAC .0908(e); and
c. At least once per year, document an evaluation of any non -significant categorical Industrial User for
compliance with the requirements in 40 CFR 403.3(v)(2), and either continue or revoke the designation as non-
significant.
8. IU Self Monitoring and Reporting
The Permittee shall require all Industrial Users to comply with the applicable monitoring and reporting
requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit, or in 15A
NCAC 02H .0908. [15A NCAC 02H .0906(b)(5) and .0905; 40 CFR 403.8(t)(1)(v) and (2)(iii); 40 CFR
122.440)(2) and 40 CFR 403.12]
9. Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the CWA (40 CFR 405 et. seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5 and 15A NCAC 02H .0909, specific local limitations, and other pretreatment
requirements. All remedies; enforcement actions and other, shall be consistent with the Enforcement Response
Plan (ERP) approved by the Division. [15A NCAC 02H .0903(b)(7), .0906(b)(8) and .0905; 40 CFR 403.8(f)(5)]
10. Pretreatment Annual Reports (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 02H .0908. In lieu of submitting annual
reports, Modified Pretreatment Programs developed under 15A NCAC 02H .0904 (b) may be required to submit a
partial annual report or to meet with Division personnel periodically to discuss enforcement of pretreatment
requirements and other pretreatment implementation issues.
For all other active -pretreatment programs, the Permittee shallsubmit two copies of a Pretreatment Annual Report
(PAR) describing its pretreatment activities over the previous calendar year to the Division at the following
address:
Version 1110912011

NPDES Permit Standard Conditions
Page 18 of 18
NC DENR / Division of Water Quality / Surface Water Protection Section
Pretreatment, Emergency Response, and Collection Systems (PERCS) Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
These reports shall be submitted by March 1 of each year and shall contain the following:
a. Narrative
A narrative summary detailing actions taken, or proposed, by the Permittee to correct significant non-
compliance and to ensure compliance with pretreatment requirements;
b. Pretreatment Program Summary (PPS)
A pretreatment program summary (PPS) on forms or in a format provided by the Division;
c. Significant Non -Compliance Report (SNCR)
A list of Industrial Users (IUs) in significant noncompliance (SNC) with pretreatment requirements, and the
nature of the violations on forms or in a format provided by the Division;
d. Industrial Data Summary Forms (IDSF)
Monitoring data from samples collected by both the POTW and the Significant Industrial Users (SIUs). These
analytical results must be reported on Industrial Data Summary Forms (IDSF) or on other forms or in a format
provided by the Division;
e. Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of
IUs in SNC, a summary of data or other information related to significant noncompliance determinations for
IUs that are not considered SIUs, and any other information, upon request, which in the opinion of the Director
is needed to determine compliance with the pretreatment implementation requirements of this permit;
11. Public'Notice
The Permittee shall publish annually a list of Industrial Users (IUs) that were in significant noncompliance (SNC)
as defined in the Permittee's Division -approved Sewer Use Ordinance with applicable pretreatment requirements
and standards during the previous twelve month period. This list shall be published within four months of the
applicable twelve-month period. [15A NCAC 02H .0903(b)(34), .0908(b)(5) and .0905 and 40 CFR
403.8(f)(2)(viii)]
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along with
support information including general records, water quality records, and records of industrial impact on the
POTW and shall retain all other Pretreatment Program records as required by 15A NCAC 02H .0908(f). [15A
NCAC' 02H .0908(f); 40 CFR 403.12(o)].
13. Pretreatment Program Resources
The Permittee shall maintain adequate funding and qualified personnel to accomplish the objectives of its approved
pretreatment program. and retain a written description of those current levels of inspection. [I 5A NCAC 02H
.0906(b)(9) and (10) and .0905; 40 CFR 403.8(f)(3), 403.9(b)(3)]
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits modifications, POTW
monitoring of their Significant Industrial Users (SlUs), and Monitoring Plan modifications, shall be considered a
permit modification and shall be governed by 40 CFR 403.18, 15 NCAC 02H .0114 and 15A NCAC 02H .0907.
Version 1110912011

INK UIL1111101111111k
North Carolina Department of Environmental Quality
Pat McCrory
Governor
Mr. W. Perry Fisher II
Fisher — Stark - Cash
35 N Market St
Asheville, NC 28801
J
Dear Mr. Fisher:
October 26, 2015
Donald R. van der Vaart
REC�EfVED
Division of Water Resources
NOV - 2 2015
Water Quality Regional Ooerations
Asheville Radon ai Office
Subject: apn`tIRpaxtVNP-*$icrexa t
t--.�
D"Per� ESmit NC0000094;:7ED «
Fletcher Warehousing Company
Henderson County
The Division has reviewed your request to suspend submission of monthly Discharge Monitoring
Reports (DMRs). We'apologize for the length of time in handling your request, but the unique
circumstances at the facility required extensive discussion. We appreciate your patience. This
letter also serves to notify you of the options for the facility and its existing permit.
After considering the recommendations of the staff in the Asheville Regional Office, I have agreed
20
Be advised that if any wastewater discharge occurs, the discharge must be monitored as per the
terms of the NPDES permit and other applicable rules or statutes. Please keep the Asheville
Regional Office apprised of any pertinent developments that arise regarding this facility,
especially if the discharge is re -activated.
While requirements for operator visitation, monitoring and reporting are being waived, you are
still required to pay the Annual Administering and Compliance Monitoring Fee that is associated
with this and all NPDES permits.
Currently:
➢ The facility's outfall line has been sealed; the permitted wastewater discharge has ceased.
➢ Domestic waste from the facility bathrooms is disposed of via sanitary sewer.
A decision must be made promptly regarding renewal of NC0000094:
➢ NC0000094 will expire on 11/30/2015.
➢ To date, the Division has received no request to renew the permit. If no renewal request
is received by 11/30/2015, the permit will automatically become Inactive on 12/1/2015 [per
40 CFR 122.41 (b)]. Any wastewater discharge after 11/30/2015 would be illegal, if
permit renewal were not requested.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 512 North Salisbury Street, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Internet: www.ncwater.org
An Equal Opportunity/Affirmative Action Employer— 501/6 Recycled/10% Post Consumer Paper

NC0000094
DMR Submittal Waiver
October 2015
If permit renewal is requested, the Division may renew it to give the permittee the option of
discharge in the future. We have done this several times for industrial, private, and municipal
permittees.
Alternatively, if NC0000094 becomes Inactive, the facility could request a new NPDES permit at
a later date. A new NPDES permit application must include an Engineering Alternatives
Analysis (EAA) [guidance attached]. Due to existing conditions at the site, the EAA must
include characterization of any solids remaining in the lagoons, as well as analyses of
the lagoon water.
If you have any questions about the permit renewal process, contact Charles H. Weaver at 919
807-6391 or via e-mail [[e-mail]]. If you have any other questions regarding
the existing permit requirements, or other technical matters regarding the permit, contact Julie
Grzyb at 919 807-6389 or via e-mail [Julie. grzyb@ncdenr. gov].
Sincerely,
Jay Zimme r�r'l4tor
ivision of Water Resources -Zs
cc: Central Files
Aslie�v lle_Regaona ®'ff ce ksis
NPDES Files
Charles D. Owen / Fletcher Warehousing Company [e-copy]
2

FISHER
STARK
X A S H
ATTORNEYS
April 22, 2015
REC�lVED
Division of Water Aesourcey
MAY - 4 2016
Water Ouality Regional Operations
Asheville Regionai office
Linda Wigs
Environmental Senior Specialist
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources, Water Quality, Regional Operations
2090 US Highway 70
Swannanoa, North Carolina 28778
Re: Discharge Permit No. 0000094
Fletcher Warehousing
Dear Ms. Wigs:
This firm represents the above referenced license Permitee. As such we have
been directed to communicate with you concerning a suspension of the permit.
It is my understanding that your office recently confirmed that the former
waste water. treatment facility operating pursuant to the above permit is no longer
receiving or discharging waste water. The discharge pipe has been sealed and the
facility is no longer receiving any waste water discharge from any point -source
location. For that reason, the permit is no longer actively needed and we would
respectively request that the permit be suspended until further discharge activities
occur, if ever in the future.
Pursuant to that suspension it is my understanding that the Permitee will no
longer be remitting any monthly or annual permit fees and the facility will no longer
be subject to ongoing monitoring. If my understanding is in error, please let me
know as soon as possible. If you have any questions or if I can be of assistance to
you in this or any other matter please do not hesitate to call upon me.
Very truly urs,
v
W. Perry is _.
WPF/rec
35 North Market Street . Asheville, NC 28801 • 828.505.4300 • www.fisherstark.com

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C.20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98ir
I
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 U 2 h I 3 I NC0000094 I11 12 15/04/09 17 18 LCJ 19 L Gj 201
211111 I I I I I I II 11 1 I I I I I I I I I I I I I I I I I.I 1 I II I I I I ji f6
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA-------------Reserved----------- ,
67 70 I 71 I lI 72 ti 73 I � I I�74 751 I I I I I II I80
LJ LJ 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) i
10:OOAM 15/04/09
13/05/01
etehe ing � a
4600 Hendersonville Rd
Exit Time/Date
Permit Expiration Date
Fletcher NC 28732
01:00PM 15/04/09
15/11/30
Name(s) of Onsite Representative(s)fritles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Charles D Owen, PO Box 188 Fletcher NC 2873201BOH828-651-9815/8286519817
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
I
(See attachment summary) .
Name(s) and Signature(s) of Inspectors) Agency/Office/Phone and Fax Numbers Date
Linda S Wiggs ARO WQ#828-296-4500 Ext.4653/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

N
NPDES yr/mo/day Inspection Type 1
31 NC0000094 I11 121 15/04/09 117 18 i r.
� �J
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
�Y
1
R, 57 � 0--"- -
Og
V,/
CJA-J�
-re—ld�k� k 56-0,
Page# 2

Permit: NC0000094 Owner - Facility: Fletcher Warehousing Company
Inspection Date: 04/09/2015 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Permit
Yes No NA NE
I
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
❑
❑
application?
Is the facility as described in the permit?
❑
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
❑
❑
Is access to the plant site restricted to the general public?
❑
❑
❑
❑
Is the inspector granted access to all areas for inspection?
❑
❑
❑
❑
Comment:
Record Keeping
Yes No NA NE
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?
❑
❑
❑
I
❑
Dates, times and location of sampling
❑
Name of individual performing the sampling
i
❑
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?
❑
❑
❑
❑
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?
❑
❑
❑
❑
I
Is a copy of the current NPDES permit available on site?
❑
❑
❑
❑
Page# ; 3

Permit: NC0000094 Owner - Facility: Fletcher Warehousing Company
Inspection Date: 04/09/2015 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ ❑
Comment:
Pump Station - Influent
Yes No NA NE
Is the pump wet well free of bypass lines or structures?
❑
❑
❑
❑
Is the wet;well free of excessive grease?
❑
❑
❑
❑
Are all pumps present?
❑
❑
❑
❑
Are all pumps operable?
❑
❑
❑
❑
Are float controls operable?
❑
❑
❑
❑
Is SCADA telemetry available and operational?
❑
❑
❑
❑
Is audible and visual alarm available and operational?
❑
❑
-❑
❑
Comment:
Aeration Basins
Yes No NA NE
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?
❑
El
El
❑
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?
❑
❑
❑
❑
Is the site free of excessive floating sludge?
❑
❑
❑
❑
Page# 4

Permit: NC0000094
Inspection Date: 04/09/2015
Owner - Facility: Fletcher Warehousing Company
Inspection Type: Compliance Evaluation
Secondary Clarifier
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:
Disinfection -Tablet
Are tablet chlorinators operational?
Are the tablets the proper size and type?
Number of tubes in use?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Comment:
Flow Measurement - Effluent
# 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:
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:
Effluent Pipe
Yes No NA NE
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
Yes No NA NE
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
Yes No NA NE
Yes No NA NE
❑ ❑ ❑ ❑
❑ ❑ ❑ El
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
Yes No NA NE
Page# 5

Permit: NC0000094 Owner - Facility:
Fletcher Warehousing Company
Inspection Date: 04/09/2015 Inspection Type:
Compliance Evaluation
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?
❑
❑
❑
❑
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and ❑ ❑ ❑ ❑
sampling location)?
Comment:
Laboratory
Yes No NA NE
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:
Standby Power
Yes No NA NE
Is automatically activated standby power available?
❑
❑
❑
❑
Is the generator tested by interrupting primary power source?
❑
❑
❑
❑
Is the generator tested under load?
❑
❑
❑
❑
Was generator tested & operational during the inspection?
❑
❑
❑
❑
Do the generator(s) have adequate capacity to operate the entire wastewater site?
❑
❑
❑
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
❑
❑
❑
❑
Is the generator fuel level monitored?
❑
❑
❑
❑
Comment:
Page# 6

Wiggs, Linda
From: Denese Ballew <[e-mail]>
Sent: Tuesday, April 07, 2015 11:26 AM
To: Wiggs, Linda
Cc: Charlie Owen; Rob Rusnak
Subject: Re: info
Attachments: HULC Operations,Overview.docx
Linda,
Thanks for following up with me.
I just completed a draft Operations Overview before checking my e-mail (please see attached).
I hope this allows you adequate time to look it over and please do not hesitate to call (828-734-1374) or email
with any questions.
Thanks,
Denese
From: ' Wiggs, Linda" <linda.wiggs(aD_ncdenr.Qov>
To: "deneseballew(aD-yahoo.com" <deneseballewOa yahoo.com>
Sent: Tuesday, April 7, 2015 11:00 AM
Subject: info
HI Denese,
You said you would send me info prior to our inspection next Tuesday,
me that info?
Linda Wiggs
Linda.Wiggs(a)_ncdenr.gov
Environmental Senior Specialist
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources - Water Quality Regional Operations
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Resources Home Page
http://portal.ncdenr.org/webA6m
when do you think you will get
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and therefore may be disclosed to third parties.

HULC Enterprises incorporates the Highest Use Low Carbon alternate waste recycling methods to offer
cost competitive waste management solutions to the public and industry located in Western North
Carolina (WNC), East Tennessee, Northeast Georgia, and Upstate South Carolina. The creation of this
Bio-products Park will assist local industry to reach their zero waste to landfill goals. The following pages
will discuss the various technologies and methodologies to be used.
Waste Water Treatment Plant
The Bio-products Park is located in Fletcher, NC and has an underutilized waste water treatment plant
(WWTP)-that will be used a --Pre-treatment facility that will discharge to a Municipal WWTP. The plant
onsite is an extended aeration, biological treatment facility with t� 7.5� -Ilion gallon/day (MGD) capacity.
There are 2, 3.75 million gallon extended aeration basins and 2, 3 , 0b gallon clarifiers, as well as a d
chlorine contact chamber and a solids handling facility.
The HULC Enterprises Partners are currently having Evoqua Water
Technologies conduct a study on potential clarifier retrofits to improve
operations capabilities. The alternatives have not been presented to the
partners yet. The system will continue to be a Biological Treatment
Facility but the clarifiers may be retrofitted to perform all of the steps of
the waste treatment process thus eliminating the need for the large
aerobic digestion basins. One treatment process that is being considered
is pictured to the right. Some other alternatives to be proposed include
Small Batch Reactors (SBR), package plant... Each of these will be
evaluated considering performance and capital investment in order to make an appropriate decision.
This operation will be complemented by a state of the art indoor
solidification facility. This facility will contain a solidification pit that is
lined with 30 millimeter plastic, the pit will be made of 12" 5000 psi
concrete using 5/8" rebar and will contain a %" steel tank for mixing
and solidifying waste water. Please see photo of a similar facility to
the right.
Anaerobic Digestion Facility
This facility accept food W wastes 41 rj eJ04
from local farmers, WWTP sludge, Drinling
Water Plant solids, glycerin from Biodiesel
manufacturing, wastes with a BOD > 20-
25,000mg/I, wart waste from local brewers,
left over plants from farmers after harvest
and a wide variety of organic wastes for a tipping fee of $35.00/ton. The new facility will look similar to
the picture above. The biogas produced from this operation will be recovered to offset the facilities
energy use and may produce Renewable Compressed Natural Gas (RNG) for use as vehicle fuel.

y
1.
Composting
The compost facility will accept manure,
food wastes and yard wastes for a fee of
$35.00/ton. This will be an Aerated Static
Pile operation (as pictured above) that
utilizes'a blower to aerate the compost pile. This expedites the curing process allowing curing to take
place in just 30-60 days. The leachate and storm water from this operation will be treated in a lined,
engineered wetland prior to dis fs This water along with all other water/wastewater will be tested
periodically using sophisticated multi -parameter direct reading instruments and by a certified laboratory
as necessary.
The'feedstocks coming into the facility will be close!y scrutinized through a waste profiling process prior
to the facility agreeing to accept them. This will allow the facility to ensure the safety of personnel and
protection of the environment.
This is a model of proposed operations to take place and each of these operations will be permitted
through the appropriate Agencies prior to commencing operations. The order of operations to be
phased ,in and the individual operations may change.

VV ULG1 r Ul1UL1Uil %-Ul1L1 Ul OYSLC111 "PUP itLUl JLFVMg'UUL1U11 DUllll
WPCSOCC
Permittee Owner/Off eer Name:
Mailing Address: " hd,�-
M
NCAC 15A 8G .0201
City- � �` State:/�� Zipjb
Email address: 01*1441' O
Signature:
® d' Phone #: 19165 7h
6,Va/6G(g6)',49 , Z
Date:
.............................. .. .......................................................................................................................
F Facility Name: e-fr—Ae-/` Permit #: O✓C DDC�O d 9% 4
J
SUBMIT A SEPARATE FORM FOR EACH TY TSXXRECEIVED
Facility Type/Grade:
Biological WWTP .r Surface Irrigation OCT 1 8 2013
Physical/Chemical Land Application
Collection System
............................................................................................. QWQ/Surface Water PrQte�gti ,�gction
Asheville Regional Office
Operator in Responsible Charge (ORC)
Print Full Name:%1
Certificate Type / rade / umber: tOW 2- Work Phone #: (X'5 3�3'7 Ll
6Signature: Date:� & 3
"I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. I understand and will abide by the rules
and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC.08G .0204 and failing to.do so can result in Disciplinary
Actions by the Water Pollution Control System Operators Certification Commission."
Operators.
Back -Up Operator in Responsible Charge (BU ORC)
Print Full Name: �-1 a �t''✓ f Or
Certificate Type / Grade / Number: !A' 3r -53© a Work Phone #: (!Q` yl 172— V 9 5/
Signature: V
Aua--CS_ Date:
"I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the
rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15ANCAC 08G .0205 and failing to do so can result in
Disciplinary- Actions by the Water Pollution, Control System Operators Cer6fication Cori issior_: '
.....................................................................................................................................................
Mail, fax or email the WPCSOCC, 1618 Mail Service Center, Raleigh, NC 27699-1618 Fax: [phone]
original to: E'nail.;certadm�iit7a ncdeiirtico`v'
Mail orfax a copy to the Asheville
appropriate Regional Office: 2090 US Hwy 70
Swannanoa 28778
Fax: [phone]
Phone: [phone]
Washington
943 Washington Sq Mall
Washington.27889 .
Fax: [phone]
Phone: [phone]
Fayetteville
Mooresville
Raleigh
225 Green St
610 E Center Ave
3800 Barrett Dr
Suite 714
Suite 301
Raleigh 27609
Fayetteville 28301-5043
Mooresville 28115
Fax: [phone]
Fax:[phone]
Fax:[phone]
Phone:[phone]
Phone:[phone]
Phone:[phone]
Wilmington
Winston-Salem
127 Cardinal Dr
585 Waughtown St
Wilmington 28405-2845
Winston-Salem 27107
Fax:[phone].
Fax:[phone]
Phone: [phone]
Phone:[phone]
Revised 02-2013

Facility Name: ���cf7 t?/' ���✓�/�i 91.E sr�7 �or�?? )Permit #: A/C ©CDOO 9�
.............:......................................................................................................................................
Back -Up Operator in Responsible Charge (BU ORC)
Print Full Name:.
Certificate Type / Grade / Number: Work Phone #:
Signature: Aa_'►� Date: —%2
"I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the
rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
........................................................................
BackUp Op-erator in Responsible Charge (BU ORC)
t
f i
Print Full Name:
2
Certificate Type / Grade /Number: 3 Work Phone #:
� .�." .+fit -;f.}. +✓t°.'r? �
Signaturre. x' '' N Date:
"I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the
rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Back -Up Operator in Responsible Charge (BU ORC)
Print Full Name:
Certificate Type / Grade / Number:
Work Phone #: ( 1
Signature: Date:
"I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the
rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
...................................................................................................................................................
Back -Up Operator in Responsible Charge (BU ORC)
Print Full Name:
Certificate Type / Grade / Number:
Signature:
Work Phone #: ( Z
Date:
"I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the
rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
............................................................................................................................................................................
Revised 02-2013

Annual Wastewater Treatment System Performance Report
for
Fletcher Warehousing Company WWTP
for the Operating Period
January thru December, 2012
MAR 2 6 202
C i,l-i ?tP,L F= LES
RECEIVED
APR 1 5 2013
Preface
DWQ/Surface Water Protection Section
Asheville Regional Office
On July 20 1999, the North Carolina General Assembly ratified House Bill 1160, the Clean
Water Act of 1999, which place significant new reporting requirements on those entities that
own or operate wastewater treatment and collection systems. Specific items included:
1. A Spill Response Plan
2. Sewer Collection System Operation & Maintenance Plan
3. Annual Performance Report
These new requirements became effective October 1, 1999.
This report is designed to meet the minimum requirements for the Annual Performance Report
established by the North Carolina Department of Environment and Natural Resources (DEHNR)
as set forth in their guidance document dated October 19, 1999.
This law was established to provide a mechanism for public oversight (and hopefully, to instill
public confidence) in owners and operators of wastewater treatment systems and in their efforts
to protect the waters of the state.

I. General Information
Facility/System Name:
Responsible Entity
Fletcher Warehousing Company WWTP
Henderson County
Fletcher Warehousing Company
Person(s) in Charge/Contact: Charles D Owen III, President
Robert Orr — Operator -in Responsible Charge (ORC)
Henry Dyar, Project Manager - Goldie & Associates
Applicable Permits: NPDES # NC0000094
Description of Treatment Process, Collection System, and Facilities Served:
Treatment Process — The treatment facility is a conventional "Activated Sludge" process
capable of treating 4.0 million gallons per day (MGD). The current NPDES Permit allows
for 0.010 MGD flow.
Collection System — The main collection system is a standard gravity design with 8-inch
diameter pipe and standard pre -cast manholes. The system has a Spill Response Plan and an
Operation and Maintenance Plan for the sewer collection system.
Facilities Served — The facility serves the warehousing operation with approximately 10
employees and serves to treat activated sludge removed from small wastewater treatment
package plants.
NOTE: This facility was originally constructed to serve Cranston Print Works, a textile print
and dye manufacturing entity. Cranston Print Works ceased operations and sold the facilities.
Fletcher Warehousing Company converted the manufacturing facility into a warehousing
facility. Fletcher Warehousing Company is keeping the WWTP facility in a state of
operational readiness to serve additional area wastewater needs should the need arise. The
facility is currently functioning much like an oxidation basin because of the very low flow and
is more than capable..of treating the very low volume.
II. WWTP Performance
All operating parameters were in compliance with NPDES permit limits for 2012, except for a
fecal violation in September, 2012. The operator adjusted the chlorine dosage, to prevent further
violations.
We take pride in our efforts to protect the local environment and the quality of waters in
our streams.

M. Collection System Performance
The collection system experienced no significant problems for the reporting period.
IV. Notification
A notice advising of the availability of this report will be sent to each user. A copy of this
report is available to interested persons in the offices of:
Fletcher Warehousing Company
PO Box 457
Swannanoa, NC 28778
or by contacting:
Henry Dyar
c/o Goldie & Associates
210 West North Second Street
Seneca, SC 29678
As required, three copies of this report are being provided to NCDEHNR.
V. Certification
I certify that under penalty of law that this report is complete and accurate to the best of
my knowledge.
/✓ CLA- "-/ 9-/3
Henry Dyar, G Idie & Associates Date
This report prepared by:
Henry Dyar
Goldie & Associates
210 West North Second Street
Seneca, SC 29678
Phone: [phone]
Fax: [phone]

Annual Wastewater Treatment System Performance Report
for
Fletcher Warehousing Company WWTP
for the Operating Period
January thru December, 2012
Preface
On July 20 1999, the North Carolina General Assembly ratified House Bill 1160, the Clean
Water Act of 1999, which place significant new reporting requirements on those entities that
own or operate wastewater treatment and collection systems. Specific items included:
1. A Spill Response Plan
2. Sewer Collection System Operation & Maintenance Plan
3. Annual Performance Report
These new requirements became effective October 1, 1999.
This report is designed to meet the minimum requirements for the Annual Performance Report i
established by the North Carolina Department of Environment and Natural Resources (DEHNR)
as set forth in their guidance document dated October 19, 1999.
This law was established to provide a mechanism for public oversight (and hopefully, to instill
public confidence) in owners and operators of wastewater treatment systems and in their efforts
to protect the waters of the state.
F'EB 2 6 2013
DWQ/Surface Water Protection Section
Asheville Regional Office

I. General Information
Facility/System Name:
Responsible Entity:
Fletcher Warehousing Company WWTP
Henderson County
Fletcher Warehousing Company
Person(s) in Charge/Contact: Charles D Owen IIl, President
Robert Orr — Operator -in Responsible Charge (ORC)
Henry Dyar, Project Manager - Goldie & Associates
Applicable Permits: NPDES # NC0000094
Description of Treatment Process, Collection System; and Facilities Served:
Treatment Process — The treatment facility is a conventional "Activated Sludge" process
capable of treating 4.0 million gallons per day (MGD). The current NPDES Permit allows
for 0.010 MGD flow.
Collection System — The main collection system is a standard gravity design with 8-inch
diameter pipe and standard pre -cast manholes. The system has a Spill Response Plan and an
Operation and Maintenance Plan for the sewer collection system.
Facilities Served — The facility serves the warehousing operation with approximately 10
employees and serves to treat activated sludge removed from small wastewater treatment
package plants.
NOTE: This facility was originally constructed to serve Cranston Print Works, a textile print
and dye manufacturing entity. Cranston Print Works ceased operations and sold the facilities.
Fletcher Warehousing Company converted the manufacturing facility into a warehousing
facility. Fletcher Warehousing Company is keeping the WWTP facility in a state of
operational readiness to serve additional area wastewater needs should the need arise. The
facility is currently functioning much like an oxidation basin because of the very low flow and
is more than capable .of treating the very low volume. I
II. WWTP Performance
All operating parameters were in compliance with NPDES permit limits for 2012, except for a
fecal violation in September, 2012. The operator adjusted the chlorine dosage, to prevent further
violations.
We take pride in our efforts to protect the local environment and the quality of waters in
our streams.

III. Collection System Performance
The collection system experienced no significant problems for the reporting period.
IV. Notification
A notice advising of the availability of this report will be sent to each user. A copy of this
report is available to interested persons in the offices of.
Fletcher Warehousing Company
PO Box 457
Swannanoa, NC 28778
or by contacting:
Henry Dyar
c/o Goldie & Associates
210 West North Second Street
Seneca, SC 29678
As required, three copies of this report are being provided to NCDEHNR.
V. Certification
I certify that under penalty of law that this report is complete and accurate to the best of
my knowledge.
l`►'
Henry Dyar, G ldie & Associates
This report prepared by:
Date
i
Henry Dyar.
Goldie & Associates
210 West North Second Street
Seneca, SC 29678
Phone: [phone]
Fax: [phone]

Frazier, Wanda
From: Cranford, Chuck
Sent: Tuesday, July 02, 2013 10:21 AM
To: Wiggs, Linda; Frazier, Wanda
Subject: FW: Henderson County - Fletcher Warehouse Sewer variance request
FYI...
Thanks,
Chuck
Chuck Cranford
Supervisor, Surface Water Protection Section
Division of Water Quality
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
[e-mail]
Email correspondence to and from this address is subject to
the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or
other regulation.
From: Leggett, Michael
Sent: Tuesday, July 02, 2013 9:40 AM
To: Cranford, Chuck; Robertson, Seth
Subject: RE: Henderson County - Fletcher Warehouse Sewer variance request
Chuck,
You can issue the permit in the ARO, just include the conditional language in the permit as a special condition. Feel free
to send Seth or I a draft copy of the permit with the language or have the reviewer call me with questions. I've helped
Linda with some conditional language related to past permits, and will be happy to assist again.
Michael W. Leggett, P.E.
PERCS Unit
919-807-6312
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Cranford, Chuck
Sent: Tuesday, July 02, 2013 9:38 AM
To: Robertson, Seth; Leggett, Michael
Subject: RE: Henderson County - Fletcher Warehouse Sewer variance request

Seth - Thanks for the help.
Michael — Will you be issuing the permit?
Thanks,
Chuck
Chuck Cranford
Supervisor, Surface Water Protection Section
Division of Water Quality
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
[e-mail]
Email correspondence to and from this address is subject to
the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or
other regulation.
From: Robertson, Seth
Sent: Monday, July 01, 2013 4:18 PM
To: Vann Waters
Cc: Leggett, Michael; Cranford, Chuck; harry. buckner(�bmcgillengineers.com
Subject: RE: Henderson County - Fletcher Warehouse Sewer variance request
Vann,
I have reviewed the information we received on June 28th and I support approval of the alternative design assuming the
information submitted matches what is included with the fast -track permit application and the construction methods
and minimum setback is included as part of the issued permit. Let me know if I can provide any additional assistance.
Thanks,
Seth
From: Vann Waters [mailto:Vann.WatersCabMcgillengineers.Com]
Sent: Monday, June 24, 2013 8:49 AM
To: Robertson, Seth
Cc: Leggett, Michael; Cranford, Chuck
Subject: RE: Henderson County - Fletcher Warehouse Sewer variance request
Seth — In our phone conversation, you offered to read the draft of the letter we were writing for the variance but
unfortunately, the project engineer was leaving on vacation this week, so in the interest of expediting things, he signed
the revised plans and letter and it was mailed to you Friday. If you have any changes you need, just contact me and we
will take care of it when he returns next week.
Thanks for your help.
Vann Waters

Senior Engineering Technician
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] ( Fax: [phone]
Email: [e-mail] I Website: www.mcgillassociates.com
From: Robertson, Seth[ma iIto: [e-mail]]
Sent: Tuesday, June 18, 2013 11:57 AM
To: Vann Waters
Cc: Leggett, Michael; Cranford, Chuck
Subject: FW: Henderson County - Fletcher Warehouse Sewer variance request
Vann,
In order for us to approve, we need documentation demonstrating that the proposed alternative design will provide
protection of the waters of the state (including groundwater) that is equal or better than the 02T rule requirements (this
is in accordance with 15A NCAC 02T.0105(n)). Please provide a letter signed and sealed by the design engineers that
clearly details how you will meet this requirement and includes an explanation of the maximum feasible separation that
can be achieved, details of any pertinent existing site conditions such as failing septic tanks or topography, and
specifications for proposed special construction. In order to assist, I have attached an email that includes design details
that we previously approved in a similar circumstance including manhole lining and testing requirements. Please do not
hesitate to contact me with any questions.
Thanks,
Seth
sit is our understanding, based upon information provided by the North Carolina Board of Examiners for Engineers and
Surveyors, that work of this nature requires an engineer's seal. If you have any questions regarding this requirement,
please contact the Board directly.
Seth Robertson, P.E.
Design Management Unit Supervisor
Division of Water Quality
Infrastructure Finance Section
919-707-9175
http://ifs.nc.gov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Leggett, Michael
Sent: Wednesday, May 29, 2013 2:45 PM
To: Robertson, Seth
Subject: FW: Henderson County - Fletcher Warehouse Sewer variance request
No

Variance request we discussed yesterday.
Michael W. Leggett, P.E.
PERCS Unit
919-807-6312
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Vann Waters [mailto:[e-mail]]
Sent: Wednesday, May 29, 2013 11:21 AM
To: Leggett, Michael
Cc: Cranford, Chuck; Harry Buckner
Subject: Henderson County - Fletcher Warehouse Sewer variance request
Michael — here is a pdf of the plan sheet with the well conflict. I have added 25, 50 and 100 foot radius circles for clarity,
changed all the manholes within the 100' radius to water tight lids, changed all the sewer line within the 100' to DIP and
for an extra measure, added a note stating all that for the contractor.
As you can see, the well itself is only a little over 40 feet from the stream bank, requiring two stream crossings to go
around it to the west side. On the east side, we would be on two additional property owners and the terrain raises
significantly, making depth an issue.
If during the review there are any questions, please contact me at any time.
Vann Waters
Senior Engineering Technician
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] I Website: www.mcgillassociates.com

GOLDIE
&ASSOCIATES
Engineering • Environmental • Utility Operations • Laboratory .
October 14, 2013
Mr.-G. Landon Davidson, P.G. ,
,Regonal",,Supervisor
Water; Qualify Section
.2090 U:SHighway 70
:Swann anoa; NC 287.78
Re:: NOV-2013-LV-0593
Perrmt No. NC0000094
Fletcher' Warehousing Company WWTP
Henderson County
Dear Mr. Davidson:
Regarding NOV-2013-LV-0593, for exceeding the monthly average flow for the month
of June 2013, usually the wastewater treatment plant does not discharge due to the low
flow coming from the warehouse. During the month of June, the heavy rainfall that
accumulated on the surface area of the two large aeration basins, clarifier and contact
chamber caused the high discharge flows. .
The noncompliance box was not checked because we thought that the plant was in
compliance. We took the total flow for the month and divided it by the number of days
in the month for the daily average. I have been informed that the State only uses the data
from the days that the plant actually discharges to get the daily average.
We will continue to monitor the Wastewater Treatment Plant and will investigate ways to
prevent the rain water from discharging from the plant.
Sincerely,
Henry Dyar
Operations Manager
Goldie & Associates
CC: Janet Cantwell, NCDENR
Charles D Owen, III, Fletcher Warehousing
210 W. North Second Street
Seneca, SC 29678`
wNyw.goldieassociates.com
Phone: [phone]
Fax: [phone]

i
,Asheville, North Carolina - Average Rainfall u,rrent, l 6a1
s
9&-4ua-t- ® O 4-4
Data
10121 / 1.3 10:41 AM
'r
To investors who want to retire comfortably.
If you have a $566,000'portfolio, dawriiaad tho guide by Forbes columnist and money man urger Ken Fisher's film.
!Ps called `The 45.Minute Retirement' .lan." Even if you have something else in place right now; it stilt rr)akes souse
to;reg0est your guider. t;tse#t d ;1� Cic}�rtlt3 fit§ Ya> sr t sit? t r F,ra,•,. ° ':: s r +, r i
WEATHEROB » AVERAGE RAINPALL,'FOR iiS CMCS.,F DeTAIL
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Asheville., North Carolir1a Average Rainfall
MONTHLY RAINFALL SEASEiNf4i. IiA ltWAI..i,
Mt7Fti7'HLY RAINFALL SEASONALAA!PS A 1,;. RAtt FALL FMCORDS
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Asitevikic:, IVcr;ri Carolina
http: / i average-rainfall.weatherdb.com%1%i1.171Aslieville-North-Carolina
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Page 1 of 2

Cantwell, Janet
From: Charlie Owen <[e-mail]>
Sent: Wednesday, October 23, 2013 11:13 AM
To: Cantwell, Janet
Subject: Re: E mail
Attachments: 2013Rain.pdf
Janet
Letter coming
Thanks see graph attached lots of rain
Charlie Owen
Fletcher Warehousing Company
4600 Hendersonville Road
Post Office Box 188
Fletcher, NC 28732
Office Phone [phone]
Cell Phone [phone]
176x`(828),651-9816
GONFJDENTIALITY NOTICE: This e-mail is intended only for the addressee named above. It contains information that is privileged, confidential or otherwise
protected from use,and disclosure. If you are not the intended recipient, you are hereby notified that any review, disclosure, copying, or dissemination of this
transmission, or taking of any action in reliance on its contents, or other use is strictly prohibited. If you have received this transmission in error, please reply to the
sender listed above immediately and permanently delete this message from your inbox. Thank you for your cooperation.
On Oct 23, 2013, at 11:10 AM, Cantwell, Janet wrote:
Hi Charlie ---Yes, it's correct.
Thanks ---Janet
Janet Cantwell - [e-mail] North Carolina Dept. of Environment and Natural Resources / Asheville
Regional Office / Division of Water Resources — Water Quality Regional Operations
2090 US Highway 70
Swannanoa, NC 28778-8211
Tel: [phone]
Fax: [phone]
Internet: http://portal.ncdenr.org/web/wq/ws
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

From: Charlie Owen [ma i Ito: cha rl ieowen (ffletcherwa fletcherwarehousing.com]
Sent: Wednesday, October 23, 2013 11:06 AM
To: Cantwell, Janet
Subject: E mail
Janet,
Is this correct e mail address?
Thanks
Charlie Owen
Fletcher Warehousing Company
4600 Hendersonville Road
Post Office Box 188
Fletcher, NC 28732
Office Phone [phone]
Cell Phone [phone]
Fax [phone]
CONFIDENTIALITY NOTICE: This e-mail is intended only for the addressee named above. It contains information that is privileged, confidential or otherwise
protected from use and disclosure. If you are not the intended recipient, you are hereby notified that any review, disclosure, copying, or dissemination of this
transmission, or taking of any action in reliance on its contents, or other use is strictly prohibited. If you have received this transmission in error, please reply to the
sender listed above immediately and permanently delete this message from your inbox. Thank you for. your cooperation.
Al
'r
2

Mr. G. La ndon 'Davidson, P.G.
Regional ' Supervisor
Water C[Uality. Section
2090 US Highway 70
Swannanoj, NC 28778
ftftw ft(I-glay"a MVW
. --
bear Mr. Davidson:
Regarding NOV-2013-LV-0.593, for exceeding the monthly average flow for the month of June 2028,
usually the wastewater treatment plant does not dischargelclue to the low flow corning1rom the
warehouse. During summer months,,heavy rainfal[thatt,accumulated on the surface area of the two
large aeration ba sins,,cla rifler and contact chamber caused th6 high discharge flovis. Please see
attached chart.
The noncompliance box was not checked because we thought that, thiiplantwasin compliance,. We.
took the total flow for the month and divided it by the number of days in the month for the. daily
average which - has beenourstandard operating plan since 2000 per attached letter from the State.
,
We will continue to Monitor the Wastewater Treatment Plant and will,investigat6 ways to. prevent -the
rain water from discharging from the plant. . There was no flow; inSepterriber..
Sincerely;
Charles D. Owen, III
Presidlient
Cc: JanetCaritWell, NCININIR
R AK * P
- )0 ;�,E' �R IER, A:C Z37-32 1 848
�ac e.')X 11�3* a, �pi,,)- R04D FUMP,

1p121/ 1i3.10:41 AV
"AsheWI16, North Carolina -Average Rainfall - Current, rical'Data
Sign in '
j I
To -investors who want to retire.cornfortably,
If you have a M,000 portfolio, download the guide by Forbes columnist and money.n-anager Ken Fisher's him.
Ws called "The 15.M411ite Retirement Plan." Even if you have sainething else in place right nay, it still makes sense
to *uest yourguidei Stick HM10 00 l03d Your.Galldei FIsN[:It INVE3T.Yw 'rs° :
EMBED
WEATi1ERD8 M AVERAGE RAINFALL FOR US CITIES,- DETAIL
See all Average Rainfall
Save
Asheville, North Carolina Average Rainfall
SEASONAL; RAINFALL. RAINFALL RECORDS
MONTHLY RAINFALL
MONTHLY RAINFALL SEASONAL RAINFALL RAINFALL RECORDS 1
AVERAGE BY MONTH' THIS YEACs`' Y4AR TO DATE
6
5.6
a
ID
3
2
2
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0.7 ..
January February March April; May June July August September October November December
Month
• Mtt3NTN
-AVERAGE"RAINFALL 2013 RAINFALL
January
3:87 yin 820 in
3.20 in
February 3.92 in
March
a'dTirt 3.90 in
5.80 in
April 3.66'in
May 3:79 in
6,30 in
4Z4 in- 6.50 in
:>iirie _ .
:July
4, i in 12'.00 in
6';40 in
August
4,13 it
Septern.ber 4,57 T:f:
. .. 1,40l ire
October 101 ;n
Noveriber 4.03 in
December -3.54. in
AVERAGE ANNUAL PRECIPITATION 48.02 inches
.Asheville, North Carolina
46.79 inChes
No•th ,Carolina "
41.11 inches
All Average Rainfall
Page 1. or 2
http:i laverage-rainfall.weatherdb:com/ 1 /177/Aoeville=North-Carolina

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
SeptetrIber 8, 2000
Mr. WilliamH. Pott 11
VicePresident
Fletcher Warehousing,
P.O. Box 457
Swannanoa, North Carolina 27778
Dear Mr. Pott:
rF K
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT ANo NATURAL FlEsc)URCES
Subject: Draft NPDES Permit
Permit KC0000094
Fletcher Warehousing
Henderson County
Enclosed with this letter is a copy of the draft NPDES permit for the above referenced facility.
I ertcourage you to review the draftcarefully to ensure thorough understanding of the information,
conditions, and requirements contained therein.
The following changes have been incorporated into your permit'.
Z�
The flow limit has been decreased to 0.01 MGD. This
is change was made in recognition of
the switch in onsite activity to warehousing. A review of the daily monitoring reports
(DMRs) for the site reveals a. reduced and sporadic floe -through the treatment system.
Additionally, a member of your accounting staff quoted water 'usage- for the warehousing
facility at around 8000gpd. In order to accommodate potential- warehouse growth and
periodic storrawater flows, days of zero flow may be averaged in to this monthly flow.
Carbonaceous biochemical oxygen demand (COD),-,. sulfides, total chromium-, phenols and
toxicity monitoring requirements have been removed from the permit. The removal of these
parameters also reflects thechange in onsite activity from fabric finishing to warehousing.
More thana year has passed since the transfer of ownership; these pollutants: should thus
no longer be present in the discharge.
• Fecal coliform and total residual chlorine (TRq limits have been added to the permit. These
effluent limits have been added in anticipation of the reclassification of the French, Broad
River to class B waters. Such a reclassification requires fecal coliform, and TRC limits by
the State of North Carolina's Administrative Code Section T15A.02B.0200. A compliance
schedule has been ificluded in the effluent limitations pages allowing a period of one year to
meet these new requirements;.
• Sam le type for all monitored samples (except for flow) has been changed from composite to
. p
grab. After reviewing the, DMRs, it has been noted that discharge from this facility tends to
be sporadic, in nature; grab samples would thus be more representative, of the discharge.
• The, status of the perinittee will be changed from major to minor due to the change in flow
and the nature of the discharge.
1617 Mail Service Center, Raleigh, North Cardina 27699-1617 919733--500, extension 551 (faxj019733-0719
VISIT US ON THE WERNET @ htto:/i'h2c,enr..state,ne,us/NPDES Natalie,[e-mail]

Sub nit any comments .or questions concerning this -dta. t permit no later than thirty, (30) days
follaivirig receipt 4f -his letter. Comments should be so t,.to:,
Ms. Natalie. Sierra
NCDENR"— DWQ -NPDES Unit
:1:621 Mail Service Centef
Raleigh, North Carolina 2-109-16:17
If you Dave,agy questions or coinmerits cc ncerhir g this draft. permit, please contactme at,
41"§: 733-5 83:extension 551 or bye-mailat Natalie:$ierrac�rncmail.net.
Sierra.
Unit
cc,• Asheville Regional Office jWater Quality Section
NPDES File.
DE.H

State of North Carolina
Department of Environment.
and Natural Resources
Division of Water Quality
w
'James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
eptember 8-�20.0-
Mr. William H. Pott it
Vice President
Fletcher Warehousing
P.O. Box 457
Swannanoa, North Carolina 27778
Dear Mr. Pott:
4 IF
• •
i
NCDE14',"R
NORTH' CAkOLiNA DEPARTMNT' OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: raft NPD:ES Per-mit-
Permit NC0000094
Fletcher Warehousing Co.
Hendekson County
Enclosed with this letter is a copy of the draft NPDES permit for the above referenced facility.
I encourage you to review the draft carefully to ensure thorough understanding of the information,
conditions, and requirements contained therein.
The following changes have been incorporated into your permit:
® the flow limit: ha:s beendecreased. to ,0.01'.MGD� This change was made in recognition of
the switch in onsite activity to warehousing. A review of the daily monitoring reports
(DMRs) for the site reveals a reduced and sporadic flow through the treatment system.
Additionally, a member of your accounting staff quoted=water a -sae or-th�e�.«rarehousiinng
en.odic. storinwa
• Carbonaceous biochemical oxygen demand (COD), sulfides, total chromium, phenols and
toxicity monitoring requirements have been removed from the permit. The removal of these
parameters also reflects the change in onsite activity from fabric finishing to warehousing.
More than a year has passed since the transfer of ownership; these pollutants should thus
no longer be present in the discharge.
• Fecal coliform and total residual chlorine (TRC) limits have been added to the permit. These
effluent limits have been added in anticipation of the reclassification of the French Broad
River to class B waters. Such a reclassification requires fecal coliform and TRC limits by
the State of North Carolina's Administrative Code Section T15A.02B.0200. A compliance
schedule has been included in the effluent limitations pages allowing a period of one year to
meet these new requirements.
• Sample type for all monitored samples (except for flow) has been changed from composite to
grab. After reviewing the DMRs, it has been noted that discharge from this facility tends to
be sporadic in nature; grab samples would thus be more representative of the discharge.
• The status of the permittee will be changed from major to minor due to the change in flow
and the nature of the discharge.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 551 (fax) 919 733-0719
VISIT us ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES [e-mail]

Submit' any comments or questions concerning this draft permit no later than thirty (30) days
following receipt of this letter. Comments should be sent to:
Ms. Natalie Sierra
NCDENR — DWQ -NPDES Unit
1621 Mail. Service Center
Raleigh, North Carolina 27699-1617
If you have any questions or comments concerning this draft permit, please contact me at
919-733-5083 extension 551 or by e-mail at: Natalie. [e-mail].
Qly,;
at ie Sierra
/NPDES Unit
cc: Asheville Regional Office/Water Quality Section
NPDES File
DEH
r

NCDENR ..
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
October 10, 2013
Mr. Charles D. Owen, III
Fletcher Warehousing Company
P.O. Box 188
Fletcher, North Carolina 28732-0188
Subject: NOTICE OF VIOLATION
NOV-2013-LV-0593
Permit No. NC0000094
Fletcher Warehousing Company WWTP
Henderson County
Dear Mr. Owen:
. A review of Fletcher Warehousing Company's WWTP monitoring report for June 2013 showed the
following violation:
Parameter
Date
Limit Value
Reported Value
Limit Type
Flow, in conduit or thru
06/30/2013
0.01 mgd
0.056 mgd
Monthly
treatment plant
Average
Exceeded
It was also noted that the Compliance box on the back of the DMR was marked "Compliant" when in
fact it should have been marked "Non -Compliant" with an explanation for the non-compliance.
Remedial actions should be taken to correct this problem. The Division of Water Resources may
pursue enforcement action for this and any additional violations of State law. If,you should have any
questions, please do not hesitate to contact Janet Cantwell or me at 8281296-4500.
Sincerely,
G. Landon Oavldson, P.G.
Regional Supervisor
Water Quality Section
WQ Central Files
Goldie & Associates/ ORC
G:\WQ\SWP\Henderson\Wastewater\lndustrial\Fletcher Warehouse 00094\NOV-2013-LV-0593.doc
WATER QUALITY SECTION
North Carolina Division of Water Resources — Asheville Regional Office Phone [phone] FAX [phone] Internet: h2o.enr.state.nc.us
2090 U.S. Highway 70, Swannanoa, N.C. 28778 An Equal Opportunity/ Affirmative Action Employer

4 )FIL
_ _ ►o ,
9C®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P.E. John E. Skvarla III
Governor Director Secretary
. I
i
January 28, 2013
Charles D. Owen
Fletcher Warehousing Company
PO Box 188
Fletcher NC 28732
SUBJECT: Compliance Sampling Inspection
Fletcher Warehousing Company
Status: Marginally Compliant
Permit No: NC0000094
Henderson County
Dear Mr. Owen:
On January 14, 2013 a Compliance Sampling Inspection was conducted at the Fletcher
Warehousing Company. You were present during part of the inspection. Also present for
the inspection were Robert Orr and Drew Hopper with Goldie and Associates.
The facility was found to be Marginally Compliant- with. permit NC0000094. Most of the
Wastewater Treatment Plants components are inoperable and have excessive plant
growth; this is an Operation and Maintenance issue. You have stated the facility will tie
onto the Cane Creek Sanitary Sewer District this year. If this system does not tie onto the
public sewer by the end of 2013 the operational and maintenance issues will have to be
resolved.
Please refer to the enclosed inspection report for important comments. If you or your staff
have any questions, please call me at 828-296-4500.
Sincerely, ,v
Linda Wiggs
Environmental Senior Specialist
Asheville Regional Office
Enclosure
cc: Central Files
, RC PO Box 842 Etowah, NC 28729
Goldie and Associates 210 W. North 2"d St Seneca, SC 29678
S:\SWP\Henderson\Wastewater\Industrial\Fletcher Warehouse 00094\CSI.Jan2013.doc
SURFACE WATER PROTECTION — ASHEVILLE REGIONAL OFFICE
Location: 2090 U.S. Highway 70, Swannanoa, NC 28778 One
Phone: [phone]FAX: [phone] NorthCarolina
Internet: www.ncwaterauality.om �a&,ra!!b(

United States Environmental Protection Agency
Washington, D.C. 20460
EPA
Form Approved.
OMB No. 2040-0057
Walter Compfiqn(lp Inspection Rpport
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 11 NC0000094 111 .12I 13/01/14 117 18I S I 19I S I 20I I
Remarks
211111IIII IIII IIIIIIIIIIII I I I I I I I I IIIIIIII11,11,16
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA -------------------- Reserved ----- ---------
67I 169 70121 711 N I 721 NJ 73I I 174 751 I I I I I Li 80
i—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)
Fletcher Warehousing Company
09:00 AM 13/01/14
05/12/01
Exit Time/Date
Permit Expiration Date
4600 Hendersonville Rd
Fletcher NC 28732
11:00 AM 13/01/14
10/11/30
Name(s) of Onsite Rep resentative(s)/Tities(s)/Phone and Fax Numbers)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Charles D Owen,PO Box 188 Fletcher NC 287320188H828-651-9815/8286519817
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Linda S Wiggs /1-1-1 ARO WQ//828-296-4500 Ext.4653/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3 NC0000094 111 12I 13/01/14 117 18ISI
(cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
This wastewater system is an old industrial wastewater treatment plant (WWTP). It is a very large system
that at one time could treat —4MGD of industrial wastewater. The system now receives domestic
wastewater from a couple of bathrooms in the warehouse. The components of the WWTP are basically
inoperable, plants are growing in the clarifiers; the system is functioning only as a gravity pass through flow.
Because of the systems size and lack of flows, it rarely discharges. Effluent limits are being met when it
does discharge, one eleveated fecal was noted in the last 48 months. However, it is possible the elevated
fecal may have been caused by waterfowl. The old basins are full of duck weed and the facility is
frequented by flocks of nesting waterfowl.
The small amount of domestic waste is to be tied onto the Cane Creek Sewer District this year, likely this
summer. Many discussions of tieing this system onto the public sewer have occurred over the years. If this
system does not tie onto the public sewer this year, it will be required of the owner to bring the facility into a
working order. The plant growth and lack of operable parts would have to be remedied if the system is to be
considered compliant, operation and maintenance is currently non -compliant.
Not all parameters of the effluent were evaluated during the inspection, however TSS and Fecal samples
were obtained. The results are Fecal=1/100ml and TSS=11 mg/I.
Because of the lack of flow, compliant monitoring reports, compliant inspection sampling results and the
lack of apparent damage to the environment from this discharge the inspector is willing to hold off until
December 2013 on requiring this facility to get its operation and maintenance (O&M) compliant. However, if
the facility has not tied onto the public sewer system by the end of 2013 a Notice of Violation may be issued
requiring remedial action related to the O & M of the facility.
Page # 2

Permit: NC0000094 Owner -Facility: Fletcher Warehousing Company
Inspection Date: 01/14/2013 Inspection Type: Compliance Sampling
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ 0 [I
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ 0 ❑
Judge, and other that are applicable?
Comment:
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
■
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:
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
❑
fl
❑
Is the wet well free of excessive grease?
■
❑
❑
Are all pumps present?
■
❑
❑
❑
Are all pumps operable?
■
n
n
n
Are float controls operable?
n
n
■
n
Is SCADA telemetry available and operational?
n
n
■
n
Is audible and visual alarm available and operational?
■
n
n
n
Comment:
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual 0
b.Mechanical 171
Are the bars adequately screening debris? El Cl ■ ❑
Is the screen free of excessive debris? ❑ ❑ ■
Is disposal of screening in compliance? ❑ ❑ ■
Ll
Is the unit in good condition? ❑ ❑ ■
Comment:
Aeration Basins Yes No NA NE
Page # 3

Permit: NC0000094 Owner -Facility: Fletcher Warehousing Company
Inspection: Date: 01/14/2013 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?
❑
❑
n ■
Are surface aerators and mixers operational?
n
■
n n
Are the diffusers operational?
n
0110
Is the foam the proper color for the treatment process?
n
n
Cl ■
Does the foam cover less than 25% of the basin's surface?
n
n
n ■
Is the DO level acceptable?
n
n
n ■
Is the DO level acceptable?(1.0 to 3.0 mg/1)
n
❑
n ■
Comment: One floating aerator works. There is no foam present in the basins. The
basin are covered in duck weed. System is basically operating like ponds. See
summary.
Secondary Clarifier
Yes
No
NA NE
Is the clarifier free of black and odorous wastewater?
■
❑
n n
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
❑
❑ n
Are weirs level?
■
n
n n
Is the site free of weir blockage?
n
■
Cl n
Is the site free of evidence of short-circuiting?
❑
■
❑ 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
Is the return rate acceptable (low turbulence)?
n
n
■ n
Is the overflow clear of excessive solids/pin floc?
■
n
n n
Is the sludge blanket level acceptable? (Approximately'/< of the sidewall depth)
Eln
■ n
Comment: This system is not operational. There are plants growing in it. This system
acts as a -flow through. See summary.
Disinfection:Tablet
Yes
No
NA NE
Are tablet chlorinators operational?
Cl
n
■ n
Are the tablets the proper size and type?
■
n
❑ n
Number of tubes in use?
0
Page # 4

Permit: NC0000094 Owner -Facility: Fletcher Warehousing Company
Inspection Date: 01/14/2013 Inspection Type: Compliance Sampling
Disinfection -Tablet
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Comment: This system also has plant growth. Tablets are dropped into the last
trough of this unit for disinfection. see summary.
Flow Measurement - Effluent
# 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: Gallons were indicated.
Yes No NA NE
Yes No NA NE
■nnn
■nnn
■nnn
■nnn
Page 9 5

DIVISION OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FOR For Lab Use ONLY
COUNTYI
M (DM1)
PRIORITY SAMPLE TYPE
/-
RIVER BASIN 'c
REPORT TO FRO
AR O MRO RRO WaRO WiRO WSRO TS
❑AMBIENT ❑ QA
❑ STREAM
(J��
_
L. EFFLUENT
Other BM
Ot
© COMPLIANCE ❑ CHAIN
❑ LAKE
❑ WMI Tr
Shipped by: Bus Courier, Staff, Other
OF CUSTODY
❑ EMERGENCY
❑ ESTUARY
COLLECTOR(S): I—vvt —, 9 J
Lab Number:
Date Received: Time: `Z
Rec'd by; C/11 1�iJFrum: DATA ENTRY ENTRY BY: CK:
DATE REPORTED:
Estimated BOD Range: O-5/5-25/25-65/40-130 or100 plus STATION LOCATION:
Seed: Yes ❑ No ElChlorinated: Yes R/No ❑ REMARKS:
tiL� Date Begin (yy/mm/dd) Time Begin Date End Time End Depth DM DB DBM Value Type Composite Sample Type
�� A H L T S B C O GNXX
BODS 310
DMl/Revised 10/86

United States Environmental Protection Agency
Form Approved.
E^� Washington, D.C. 20460
�+
OMB No. 2040-0057
anne nn 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 I s I 31 NC0000094 111 12 13/01/1 17 181 C I 191S I 201 I
LuJ 11�-!! u U
Remarks
211 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 I I I I I I I I I I I I 11 Jill 1 1 16
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ------------- ------------- Reserved ----------------------
67 I 169 70 71 U 72 I N I 73 LJJ 74 751 I I I I I 180 I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09:00 AM 13/01/14
05/12/01
Fletcher Warehousing Company
Exit Time/ +ate
ermit Expiration Date
4600 Hendersonville Rd
Fletcher NC 28732
11:00 AM 13/01/14
10/11/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)'=
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
r Contacted
Charles D Owen,PO Box 188 Fletcher NC 287320188//828-651-9815/8286519817 -No-
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program N Facility Site Review Effluent/Receiving Waters Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Linda S Wiggs ARP W6//828-296-4500 Ext.4653/
Signature of Management Q A Reviewer ;Agency/Offi6e%0lione and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3I NC0000094 111 12I 13/01/14 117 18ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

Permit: NC0000094 Owner - Facility: Fletcher Warehousing Company
Inspection Date: 01/14/2013 Inspection Type: Compliance Evaluation
Operations $ Maintenance
Yes No NA
NE
U ❑ ❑
0
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑ ❑ ❑
❑
Judge, and other that are applicable?
Comment:
Permit
Yes No NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
d❑ 0
0
Is the facility as described in the permit?
C/o ❑
❑
# Are there any special conditions for the permit?
❑ 0 00
Is access to the plant site restricted to the general public?,
�❑ ❑
❑
Is the inspector granted access to all areas for inspection?
Q(❑ 0
0
Comment:
Pump Station - Influent .;
Yes No NA
NE
Is the pump wet well free of bypass lines or structures?
16 ❑ 0
❑
0
Is the wet well free of excessive grease?
Are all pumps present?
9000
Are all pumps operable?
0" 0 ❑ 0
Are float controls operable?
Cl 0 lWO
Is SCADA telemetry available and operational?
C) ❑ 0"❑
Is audible and visual alarm available and operational?
0 0
0
Comment:
Bar Screens
Yes No NA
NE
Type of bar screen
a.Manual
❑
b.Mechanical
❑
Are the bars adequately screening debris?
00011
Is the screen free of excessive debris?
❑ ❑ 0
❑
Is disposal of screening in compliance?
0 0 0
❑
Is the unit in good condition?,
❑ 0 ❑
0
Comment:
Aeration Basins
Yes No NA
NE
Page # 3

Permit: NC0000094
Inspection Date: 01/14/2013
Aeration Basins
Owner - Facility: Fletcher Warehousing Company
Inspection Type: Compliance Evaluation
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?
A)0 56/�j
Is the DO level acceptable?(1.0 to 3.0 Mg/ 1)
Comment:
Secondary Clarifier
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?
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''/4 of the sidewall depth)
Comment:
Disinfection -Tablet
Are tablet chlorinators operational?
Are the tablets the proper size and type?
Number of tubes in use?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Yes No NA NE
❑❑❑
�nnn
L ❑
❑
❑
Ef
❑6000
❑
❑
{
J ❑
❑
❑
na❑n
n n
m o ho i(VD
nEl"
nn
❑❑0.-
❑
Q ❑
❑
❑
Yes No NA NE
Q❑0❑
I0/nnn
❑❑❑0�
❑ Iff-❑ ❑
Page # 4

I
Permit: NC0000094 Owner - Facility: Fletcher Warehousing Company
Inspection Date: 01/14/2013 Inspection Type: Compliance Evaluation
Disinfection -Tablet Yes No NA NE
GIs there chlorine residual prior to de -chlorination? ❑ n n d
Comment:
Flow Measurement - Effluent
# 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:
Yes t4o NA NE
,❑ ❑ Cl
❑❑❑
WO C1 El
spu
Page # 5

C CI

MONITORING REPORT(MR) VIOLATIONS for: Report Date: 01/14/13 Page: 1 of 1
- % Violation Category: % , h Program Category % .
Permit. nc0000094 MRs Between: 1 2010 ' and 1-2093 Region
,Facility Name: % _ ParamName:,% = County: %, Subbasin: % Violation Action: %- '
Major Minor ,,%
PERMIT: NC0000094 FACILITY: Fletcher Warehousing Company - Fletcher . COUNTY: Henderson REGION: Asheville
Warehousing Company
Limit Violation
MONITORING
OUTFALL /
VIOLATION
UNIT OF
REPORT
PPI LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
09 -2012
001 Effluent
Coliform, Fecal MF, M-FC
09/19/12
Weekly
#/100mi
Broth,44.5C
09 -2012
001 Effluent
Flow, in conduit or thru
09/30/12
Continuous
mgd
treatment plant
CALCULATED
LIMIT VALUE % OVER LIMIT VIOLATION TYPE VIOLATION ACTION
400 600 50 Daily Maximum Exceeded None
0.01 0.05 395.33 Monthly Average Exceeded None
\ Monitoring Violation
MONITORING
OUTFALL /
VIOLATION
UNIT OF CALCULATED
REPORT
PPI
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE LIMIT VALUE % OVER LIMIT
VIOLATION TYPE
VIOLATIOWACTION
01 -2070
001
Effluent
Flow, in conduit or thru. -
01/30/10
Continuous:
mgd
Frequency Violation
Proceed to NOV
treatment plant
01 -2010
001
Effluent
Flow, in conduit or thru
01/31/10-
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant
03 -2010
001
Effluent
Nitrogen, Total (as N) -
03/31/10
Quarterly
mg/I
Frequency Violation
Proceed to NOV
Concentration
' 03 -2010
001
Effluent
Phosphorus, Total (as P) -
03/31/10
Quarterly
mg/I
Frequency Violation
Proceed to NOV
Concentration

Permit NC0000094
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
'PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Fletcher Warehousing Company
is hereby authorized to discharge wastewater fro ac' ity located on
t 2
H er'5 u
to receiving waters designated as the French Broad River in the French Broad River
Basin in accordance with effluent limitations, monitoring requirements and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective XXXX, 2013.
This permit and authorization to discharge shall expire at midnight on November 30, 2015.
Signed this day XXXX, 2013.
for Charles Wakild P.E., Director
Division;p f .Water Quality
By AuthOrity.;gfthe Environmental Management Commission

Permit NC0000094
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit 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.
ij
Fletcher Warehousing Company is hereby authorized to:
,Ef
1. Continue to operate an existing (4.0 1VIGD;), extended aeration wastewater
treatment facility at a monthly average flow,not'exceeding 0.01 MGD which
includes the following components:
➢ Influent lift station with manual trash screen
➢ Dual 3.75 MGD aeration basins with mechanical aerators
➢ Dual final clarifiers with sludge return (no sludge is returned)
➢ Effluent disinfection equipment
Flow meter
This facility is located at the former Cranston Print Works plant in Fletcher on
Route 25 in Henderson County, and
2. Discharge from said treatment works at the location specified on the attached map
into the French Broad River, classified B waters in the French Broad River Basin.

0
FACT SHEET F : EXPEDITED PERMIT REN GALS
sr
Basic Information for Expedited Permit Renewals
Permit Writer/Date
Julie Gr b/ January 10, 2013
Permit Number
NC0000094
Facility Name
Fletcher Warehousing Inc.
Basin Name/Sub-basin number
French Broad / 04-03-02 (06010105 HUC)
Receiving Stream
French Broad River
Stream Classification in Permit
B (previously listed as WS-IV )
Does permit need Daily Max NH3 limits?
No
Does permit need TRC limits/language?
Yes No
Does permit have toxicity testing?
Yes
Does permit have Special Conditions?
Yes No
Does permit have instream monitoring?
Yes No If Yes, attach data summary —
Is the stream impaired (on 303(d) list)? For
whatparameter?
Yes No
Any obvious compliance concerns?
No
Any permit mods since lastpen-nit?
No
Current expiration date
Nov. 30, 2010
New expiration date
Nov. 30, 2015
Comments received on Draft Permit? Draft.�o ,.
Publice Notice Jan. 16, 2013
l,Ygs 1NQ.:If,;Yes, discuss response with
' Supervisor
BACKGROUND: his facility is the former textile plant: Cranston Print Works, which was
converted to a warehousing facility in 190-2000.:T1ie textile plant had a treatment system designed
for a permitted flow of 4.0 MGD which is now used to treat 100% domestic wastewater from < 25
employees. Much of the stormwater runoff,.p er�,virQuly�di.rtectd�tQ�the;treatmetsystem,4baslbeen
rd=ire^rte�,�hc�weyet s . Ovate_r riungff�£ea®m�roof�drainscissstill�be7n co.11le-cted in the aeration basins.
After the plant's conversion the permitted flow was reduced to 0.01 MGD and effluent limits
pertaining to textile facilities were removed from the permit. The facility has two 3.75 MGD
aeration basins (lagoons) where wastewater is stored, Discharges occur only a few times a year.
A review of the stream classification determined the receiving stream is a B classification not
WS-IV as listed inthe previous permit.
EFFLUENT LIMITS: Originally, a Level B water quality model was performed and the water
qulaity based BOD5 limitations were compared to the textile production based limits to determine
which were more stringent. The current concentration limitations in the permit of 26 mg/L for a
monthly average and 39 mg/L for a daily max were based on the more stringent textile production
loading standard of 868 lbs/day (868 lbs/day - (4 MGD * 8.34)= 26 mg/l; 26 * 1.5 = 39 mg/L) and
have been maintained in the permit since 1995. The..TSS :limits are based on secondary treatment
standards for domestic wastewater and the.TRC li �i'itis the, daily maximum required to protect for
acute toxicity. Thb, fecal coliform limits are huma'khe' th'standards and are required for B
classification streams. Fecal coliform :limitations,, ill remain in the permit.
VIOLATIONS & INSPECTIONS: Since 2008 the.facility, has exceeded its fecal coliform limitation
on two occassions due to heavy rainfall. Several NOVs have been issued for monitoring frequency
violations. A routine inspection was performed on 2/19/2010 and the facility was found to be
compliant. However, the inspection recognized that the facility was designed to treat 4 MGD of
industrial textile wastewater and recommended that the small volume of 100% domestic wastewater
from < 25 employees would be better treated by; an on -site treatment system or if discharged to the
local POTW.
INS TR EA M DA TA: gIIp�,no- vunstream sa�np��ag"'�"was not found with any DMRs submitted past
July 2008. Henry Dyar, the ORC at Goldie & Associates, was contacted and in
fecal coliform data collected since 2009 and noted that he would follow-up on including instream
data in the DMR's:as required by the NPDES permit:.. A review of the limited up and downstream
fecal coliform sampling data shows significant variations in fecal coliform levels in the receiving

9
stream. It can not be determined if the plant's discharge, is having An impact on the receiving
stream.
RECOMMENDATIONS: It is recommended that the current limitations and sampling, requirements
be maintained in the permit renewal.
NAME: DATE:
REGIONAL OFFICE COMMENTS:

Wiggs, Linda
From: Grzyb, Julie
Sent: Monday, January 14, 2013 10:40 AM
To: Wiggs, Linda
Subject: RE: Fletcher Warehousing Co. (NC0000094) permit renewal
Linda,
Great news, and thanks for the info on what happened with the stream classification.
I think I will go ahead and Public Notice the renewal given that these tie ins to the sewer line don't always happen as
scheduled and it's a backlogged permit.
However, note that the permit expires in 2015 and I will state in the cover letter that DWQ anticipates that Fletcher will
be connected to the City POTW (which plant??) prioir to pe(mit renewal and will request a rescission. And, that this is
the best alternative given th6 current treatment system iy� 1zed."•for=the small amount of domestic waste it treats.
During the inspection, will you have time to check the" floW'm�ter?',The last inspection noted it needed fixing and I was
wondering if it ever got fixed or replaced. Henry Dyar'of,GoldN2 & Associates said he thought it was replaced but he
didn't say it with much confidence.
I look forward to hearing what you learn during your inspection.
Thanks,
Julie
From: Wiggs, Linda
Sent: Friday, January 11, 2013 3:58 PM
To: Grzyb, Julie
Subject: RE: Fletcher Warehousing Co. (NC0000094) permit renewal
Hi Julie,
This facility is on my priority1ist for an inspection so I am going to go visit them Tuesday 1/15.
1 spoke with the owner and he is all set to tie onto the sewer system, he is just waiting for the city to complete the
mainline. It sounds like that 'Will happen soon, but definitijV',-AuMis :year. So I don't know if that info makes you want to
delay this permit further since you will likely be getting;a `rescisstonx.equest.
Let me know. But I will still be visiting it next week.
The "B" class is correct. It use to be a WS-IV, but in 20b2.wei'e%bi ed that part of the FrB as a WS, so now it is just B.
Have a good weekend, Linda'
Linda Wiggs - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Link to Division of Water Quality Home Page
http://Portal.ncdenr.org/web/­wq

Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: Grzyb, Julie
Sent: Thursday, January 10, 2013 2:22 PM
To: Wiggs, Linda
Subject: Fletcher Warehousing Co. (NC0000094) permit renewal
Linda,
Attached is the draft permit, cover letter, fact sheet and map for Fletcher Warehousing Co. (NC0000094). There are no
changes to the Effluent Limitations and Monitoring Requirements page.
The last inspection noted that the facility descri fio'n riee�cie-d" cjati`n ' I think it is but erha `s you can double check.
p Y p ._ t�, g— p p
Also, Planning's maps show that the stream classification is B -,-.Pot WS-IV. Can you confirm?
I know there has been talk on getting this discharge connected to a WWTP, expanding it for use as a WWTP, or building
an on -site system.
Not sure any of that has gone anywhere but if so, please let me know.
I am hoping to get this out to Public Notice next Wed. so if you can just check on the three concerns listed above I would
appreciate it.
Thanks,
Julie
Julie A. Grzyb, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section
NPDES Complex Permitting, Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6389 (wk); 919/807-6495 (fax)
Julie., rzyWyedenr.mov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be
disclosed to third parties.
:2;

Permit NC0000094
A. (1.) EFFLUENT' LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit until expiration, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
EFFLUENT :
CHARACTERISTICS,
LIMITS ::
r .
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
.'Jre uency
Sample Type
Sample Locationl
Flow
0.01 MGD
Continuous
Recording
Effluent
BOD, 5 day 20°C
26.0 m /L
39,0 m /L ,
Weekly
Grab
Effluent
Total Suspended Solids
30.0 m /L
45.0 m /L
Weekly
Grab
Effluent
NH3 as N
Weekly
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
Effluent
Upstream & Downstream
Fecal Coliform (geometric mean)
200/100 mL
400/100 mL
Weekly
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine
28 /L
2/Week
Grab
Effluent
Total Nitrogen NO2+NO3+TKN
Quarterly
Grab
Effluent
Total Phosphorus
Quarterly
Grab
Effluent
Temperature (°C)
Weekly
Grab
Effluent
Upstream & Downstream
H3
Weekly
Grab
Effluent
Footnotes:
1. Upstream = upstream at the Butler Bridge; Downstream = downstream at the Fanning Bridge.
2. The daily average dissolved oxygen effluent, concentration shall not be less than 5.0 mg/l.
3. The pH shall not be less than 6.0 standard unit's ibr greater than 9.0 standard'units.
There shall be no discharge of floating solids atvisibld foam in other than trace amounts.
.a

FLHER -STARK
P.A:
ATTORNEYS
May 27, 2010
VIA OVERNIGHT COURIER
Mrs. Dina Sprinkle
_
NC DENR/DWQ/Point Source Branch
1617 Mail Service Center
MAY 8 201.0
Raleigh, North Carolina 27699-1617o-
Keith Haynes
L''..1i,NT oStis'U% —
- NCH
North Carolina DENR
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Re: Fletcher Warehousing Permit #NC0000094
Henderson County
Dear Mrs. Sprinkle & Mr. Haynes:
Enclosed is an original (to Mrs. Sprinkle) and a copy to Mr. Haynes of Fletcher
Warehousing Company's application for renewal of permit.
Please reissue this permit for an
additional five (5) year term. Please let me know if you need anything further.
V �Truly s,
W. Perr igher, II `''
perr 1sherstark.com
WPF/sdj -34YI {
encl.
I
.(L-v y -
35 North Market Street • Asheville, NC 28801 •828.505.4300 . www.fislierstark.com

NPDES PERMIT APPL. LTION — SHORT FORM C — MIL--- Industrial
Minor industrial, manufactu - ring and commercial facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number
Please print or type.
1. Contact Information:
Owner Name
— L /-7 PC, -
Facility Name
. L /-r 41a_,-e_/
/(-,
Mailing Address
City
State / Zip Code • V73 2—
Telephone Number 5-
Fax Number C7 'Y_ 17
e-mail Address
59
2. Location of facility producing dis-'---
MAY 2 8 2010
Check here if same as above-.
Street Address or State Roll,
Ile-
2 -
City Ati— J5
State / Zip Code
IY .3..2—
County
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name
-S:5 0 C /Cc_e S J?_
Mailing Address
'A _5'e CO.17 A 14 9-,
City
State / Zip Code
Telephone Number
Fax Number
4. Ownership Status:
Federal El
Page I of 5 ..
State ❑
Private
Public F]
C-MI 10/08

NPDES PERMIT APPL _: ,TION - SHORT FORM C - Mh _. 'Industrial
Minor industrial, manufacturing and commercial facilities.
5. Standard Industrial Classification (SIC) code(s): `Y2,,1-,- 9 9d 6 %Xh'l�
6. Number of employees: Z, 2--5-
7. Describe the treatment system List all installed waste treatment components with capacities,
describe the processes that generate wastewaters. If the space provided is not sufficient attach a,
separate sheet of paper with the system description.
/if .Jft`©7�
S. Is facility covered under federal effluent limitation guidelines? No Yes ❑
If yes, specify the category?
9. Principal product(s) produced: /V�!©it/��T� Tr�,r,-t !e� f U�-�S=•! �y
Principal raw material(s) consumed: //'A-
Briefly describe the manufacturing process(es):
Alh
Page 2 of 5
C-MI 10/08 .

NPDES PERMIT APPL; ,TION .- SHORT FORM C - MIL__ Industrial
Minor industrial, manufacturing and commercial facilities.
10. Amount of principal product produced or raw material consumed
- ---- - - -- -- ---
Product Produced or Raw Material
Vl1 VVGL LILG LLLJL L/LLGC eur5
Product Produced or Raw Material
Consumed
Consumed
AVERAGE
PEAK
per Day
per Month.
per Year
11. Frequency of discharge: Continuous Intermittent ❑
If intermittent:
Days per week discharge _occurs: Duration:
12. Types of wastewater discharged to surface waters only
Discharge
Flow
GALLONS PER DAY
Sanitary - monthly average
0. J5 C
Utility water, etc. - monthly average
Process water - monthly average,
Stormwater - monthly average .
Other - monthly average
Explain:
Monthly Average
.total discharge (all types)
13. Number of separate discharge points: _Outfall Identification number(s)
14. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Page 3 of 5 C MI 10/08

1NPDES PERMIT APPLI1 . CIO1N - SHORT FORM C - Min , Industrial
Minor industrial, manufacturing and commercial facilities.
15. Effluent Data [for new or proposed discharges]
Provide data for the parameters listed. Temperature and pH shall be grab samples, for all other parameters 24-hour :
composite sampling shall be used. If more than one analysis is reported, report daily maximum and monthly average.
If only one analysis is reported, report as daily maximum.
NOTE. Permittees requesting renewal should complete the table ONLY for the parameters
currentlu monitored. S7Lfnf►2af'i2e the n2at 3 vpnrc of offlr�ont Antis
Parameter
Daily
Maximum
Monthly
Average
Units of
Measurement
Biochemical Oxygen Demand (BOD5)
Chemical Oxygen Demand (COD)
Total Organic Carbon
Total Suspended Solids
Ammonia as N
Temperature (Summer)
Temperature (Winter)
pH
Fecal Coliform (If sanitary waste is
present)
Total Residual Chlorine (if chlorine is
used)
16. List all permits, construction approvals and/or applications (check all that apply and provide permit
numbers or check none if not applicable):
Type Permit Number Type
Hazardous Waste (RCRA) NESHAPS (CAA)
UIC (SDWA) Ocean Dumping (MPRSA)
✓' NPDES lo-' Xc: 000 a 1,f Dredge or fill (Section 404 or CWA)
PSD (CAA) . Other
Non -attainment program (CAA)
Permit Number
17. List any chemicals that may be discharged (Please list and explain source and potential
amounts.)
/Yo
Page 4 of 5 C-M110/08

NPDE$ PERMIT APPLE.___.-TION — SHORT FORM C - Mire Industrial
Minor industrial, manufacturing and commercial facilities.
18. Is this facility located on Indian country? (check one)
i
Yes ❑ No �(
19. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is t e, compl te, and accurate.
AO OZA
Printed name of Person Signing Title
re —of App icant ate
North Carolina General Statute 143-21.5.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article,. shall be guilty of a misdemeanor punishable
by a fine not to exceed $25;000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 providesa punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 5 of 5
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director ' Secretary
January '16, 2013
Charles Dexter Owen III, President
Fletcher Warehousin;'g Company
P.O. Box 188 t
Fletcher, North Carolina 28732
Subject: Draft NPDES Permit
Permit NC0000094
Fletcher Warehousing Company
Henderson County
Dear Mr. Owen:
Enclosed with this letter is a copy of the draft permit -;for your facility. Please review the draft
very carefully to ensure thorough understanding of theconditions and requirements it contains.
The draft permit contains one significant change from your current permit:
• A correction was made to the Supplement to Cover page which identifies the stream
classification as B; not WS-IV as listed in the previous permit.
Concurrent with this transmittal, the Division will solicit,public comment on this draft as required by
the EPA by publishing a notice in newspapers havin 'circulation in the general Henderson County area.
Please review this draft carefully to ensure thorough -understanding of the information, conditions, and
requirements contained therein. Should'you,Wish to cbifd f errors or provide comments regarding this
draft please contact the DENR / DWQ / NPDES P,rograrYi aio.later than February 22, 2013.
a
Following the 30-day public comment period, the Division will review all pertinent comments and take
appropriate action prior to issuing a final NPDES permit. If you have questions concerning the draft
permit for your facility, please contact me by e-mail [e-mail]) or call me at (919) 807-
6389.
Respectfully,
Julie A. Grzyb
Environmental Engineer, NPDES Complex Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 91"07-6492
Internet: www.ncwaterguality.org,
An Equal Opportunity 1 Affirmative AVon Employer
NorthCarolina
Naturally

Page 2 of 2
Enclosure: NPDES Permit NC0000094 (Draft: permit)
cc: NPDES Unit (draft permit, fact sheet)
e-copy:
Ashville Regional Office / Linda Wiggs, Surface Water Protection Section
Ashville Regional Office / Jim Adams, DWR / Public Water Supply
TACU, Steve Reid
W. Perry Fisher, I1, Fisher Stark P.A. Attorneys;-35. N. Market St., Asheville, NC 28801
Henry Dyar, Project Manager, Goldie.& Associates, 210 N. Second St., Seneca, SC 29678
•'1 I'� �� e•i�.

Annual Wastewater Treatment System Performance Deport
for
Fletcher Warehousing Company WWTP
for the Operating Period
January thru December, 2010
Preface
On July 20 1999, the North Carolina General Assembly ratified House Bill 1160, the Clean
Water Act of 1999, which place significant new reporting requirements on those entities that
own or operate wastewater treatment and collection systems. Specific items included:
'L. A Spill Response Plan
2. ''Sewer Collection System Operation & Maintenance Plan
3. Annual Performance Report
These new requirements became effective October 1, 1999.
This report is designed to meet the minimum requirements for the Annual Performance Report
established by the North Carolina Department of Environment and Natural Resources (DEHNR)
as set forth in their guidance document dated October 19, 1999.
This law was established to provide a mechanism for public oversight (and hopefully, to instill
public confidence) in owners and operators of wastewater treatment systems and in their efforts
to protect the waters of the state.
�� �::;.
+,'t �17 S�GTION $
�' i;;��• N;ATEFI G �`GIGNA� GLFICE

I. General Information
Facility/System Name: Fletcher Warehousing Company WWTP
Henderson County
Responsible Entity: Fletcher Warehousing Company
Person(s) in Charge/Contact: Charles D Owen III, President
Robert Orr — Operator -in Responsible Charge (ORC)
Henry Dyar, Project Manager - Goldie & Associates
Applicable Permits: NPDES # NC0000094
Description of Treatment Process, Collection System, and Facilities Served:
Treatment Process — The treatment facility is a conventional "Activated Sludge" process
capable of treating 4.0 million gallons per day (MGD). The current NPDES Permit allows
for 0.010 MGD flow.
Collection System — The main collection system is a standard gravity design with 8-inch
diameter pipe and standard pre -cast manholes. The system has a Spill Response Plan and an
Operation and Maintenance Plan for the sewer collection system.
Facilities Served — The facility serves the warehousing operation with approximately 10
employees and serves to treat activated sludge removed from small wastewater treatment
package plants.
NOTE: This facility was originally constructed to serve Cranston Print Works, a textile print
and dye manufacturing entity. Cranston Print Works ceased operations and sold the facilities.
Fletcher Warehousing Company converted the manufacturing facility into a warehousing
facility. Fletcher Warehousing Company is keeping the WWTP facility in a state of
'operational readiness to serve additional area wastewater needs should the need arise. The
facility is currently functioning much like an oxidation basin because of the very low flow and
is more than capable of treating the very low volume.
H. WWTP Performance
All operating parameters were in compliance with NPDES permit limits for 2010, except for
failure to monitor for total nitrogen and total phosphorus for the month of March 2010. A sample
schedule has been put in place to help prevent failure to monitor non compliance.
We take pride in our efforts to protect the local environment and the quality of waters in
our streams.

M. Collection System Performance
The collection system experienced no significant problems for the reporting period.
IV. Notification
A notice advising of the availability of this report will be sent to each user. A copy of this
report is available to interested persons in the offices of -
Fletcher Warehousing Company
PO Box 457
Swannanoa, NC 28778
or by contacting:
Henry Dyar
c/o Goldie & Associates
210 West North Second Street
Seneca, SC 29678
As required, three copies of this report are being provided to NCDEHNR.
V. Certification
I certify that under penalty of law that this report is complete and accurate to the best of
my knowledge.
s/ 3
Henry Dyar, 6oldie & Associates Date
This report prepared by:
Henry Dyar
Goldie & Associates
210 West North Second Street
Seneca, SC 29678
Phone: [phone]
Fax: [phone]

July 20, 2010
Mr. Roger C Edwards
Surface Water Protection Section
2090 U S Highway 70
Swannanoa, NC 28778
RE: Notice of Violation, NOV-2010-MV-0097
Permit No. 0000094, Fletcher Warehousing Company
Dear Mr. Edwards;
GOLDIE..'
ASSOCIATES
engineering, environmental
and laboratory services
The Operator failed to sample for the parameters of Total Nitrogen and Total Phosphorus
for the compliance period beginning January 1, 2010. There is very little discharge from
the Wastewater Treatment Facility and there was only one day in March that flow was
discharged.
We have made it our policy to collect samples at the first discharge event that occurs
during the quarter period. This should. help prevent failure to monitor for these quarterly .
parameters in the future.
Also, the amended DMR. for March 2010 has been mailed to Raleigh.
If you have any questions, or need any additional information, please call 864-882-8194 .
ext 105.
Sincerely;
Henry Dyar
Goldie & Associates
Operations Manager
CC: Charlie Owen
4.
)
f�.
AUG - 3 2010
! WATER QUALITY SECTION
ASHEVILLE REGIOi\AL OFFICE
210 W. North Second Street • Seneca, South Carolina 29678 • Phone '[phone] • Fax [phone]

'A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 25, 2010
Mr. Charles D. Owen, III
Fletcher Warehousing Company
P.O. Box 188
Fletcher, North Carolina 28732-0188
Subject: NOTICE OF VIOLATION
NOV-2010-MV-0097
Permit No. NC0000094
Fletcher Warehousing Company
Henderson County
Dear Mr. Owen:
A review of Fletcher Warehousing Company's monitoring report for March 2010 showed the following
violations:
Parameter
Date
Measuring
Frequency
Violation
Total Nitrogen
03/31/2010
Quarterly
Failure to Monitor
Total Phosphorus
03/31/2010
Quarterly
Failure to Monitor
It was also noted that the Compliance box on the back ofthe DMR was marked "Compliant" when in fact it should
have been marked "Non -Compliant" with an explanation for the non-compliance. If the above parameters were left off
inadvertently, please send an amended DMR to Raleigh at the address found on the front page of your DMR.
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue enforcement
action for this and any additional violations of State law. If you should have any questions, please do not hesitate to
contact Janet Cantwell at 828/296-4500.
Sincerely,
Roger C. Edwards, Regional Supervisor
Surface Water Protection Section
t,
cc� -`�DWQ'Ashevtlle File's '�'
DWQ Central Files
Goldie & Associates/ ORC
S:`:S1� P`.}lender:od:1'asiewarer:hirlusuiaf,Flcicher ll-archouse 00094'?NOV-201O-AIV-0097.doe Wn, Carolina
North Carolina Division of Water Quality 2090 U.S. Highway 70 Swannanoa, N.C. 28778 Phone[phone] Customer Service
Internet: www.ncwaterouality.org FAX [phone]

Annual Wastewater Treatment
for
Fletcher Warehousing
System Performance Report;
n �. _ ..�
F t.
Ak �Zq 2�MQ. ! i
Company WWTP-
5
for the Operating Period
January thru December, 2009
MAR 2 2 2010
Preface
On July 20 1999, the North Carolina General Assembly ratified House Bill 1160, the Clean
Water Act of 1999, which place significant new reporting requirements on those entities that
own or operate wastewater treatment and collection systems. Specific items included:
1. A Spill Response Plan
2. Sewer Collection System Operation & Maintenance Plan
3. Annual Performance Report
These new requirements became effective October 1, 1999.
This report is designed to meet the minimum requirements for the Annual Performance Report
established by the North Carolina Department of Environment and Natural Resources (DEHNR)
as set forth in their guidance document dated October 19, 1999.
This law was established to provide a mechanism for public oversight (and hopefully, to instill
public confidence) in owners and operators of wastewater treatment systems and in their efforts
to protect the waters of the state.

I. General Information
Facility/System Name:
Responsible Entity:
Fletcher Warehousing Company WWTP
Henderson County
Fletcher Warehousing Company
Person(s) in Charge/Contact: Charles D Owen III, President
Robert Orr — Operator -in Responsible Charge (ORC)
Henry Dyar, Project Manager - Goldie & Associates
Applicable Permits: NPDES # NC0000094
Description of Treatment Process, Collection System, and Facilities Served:
Treatment Process — The treatment facility is a conventional "Activated Sludge" process
capable of treating 4.0 million gallons per day (MGD). The current NPDES Permit allows
for 0.010 MGD flow.
Collection System — The main collection system is a standard gravity design with 8-inch
diameter pipe and standard pre -cast manholes. The system has a Spill Response Plan and an
Operation and Maintenance Plan for the sewer collection system.
Facilities Served — The facility serves the warehousing operation with approximately 10
employees and serves to treat activated sludge removed from small wastewater treatment
package plants.
NOTE: This facility was originally constructed to serve Cranston Print Works, a textile print
and dye manufacturing entity. Cranston Print Works ceased operations and sold the facilities.
Fletcher Warehousing Company converted the manufacturing facility into a warehousing
facility. Fletcher Warehousing Company is keeping the WWTP facility in a state of
operational readiness to serve additional area wastewater needs should the need arise. The
facility is currently functioning much like an oxidation basin because of the very low flow and
is more than capable of treating the very low volume.
H. WWTP Performance
All operating parameters were in compliance with NPDES permit limits for 2009..
We take pride in our efforts to protect the local environment and the quality of waters in
our streams.

M. Collection System Performance
The collection system experienced no significant problems for the reporting period.
IV. Notification
A notice advising of the availability of this report will be sent to each user. A copy of this
report is available to interested persons in the offices of -
Fletcher Warehousing Company
PO Box 457
Swannanoa, NC 28778
or by contacting:
Henry Dyar
c/o Goldie & Associates
210 West North Second Street
Seneca, SC 29678
As required, three copies of this report are being provided to NCDEHNR.
V. Certification
I certify that under penalty of law that this report is complete and accurate to the best of
my knowledge.
Henry Dyar, Gotdie & Associates
3-1/9 — / D
Date
This report prepared by:
Henry Dyar
Goldie & Associates
210 West North Second Street
Seneca, SC 29678
Phone: [phone]
Fax: [phone]

, A 7-A
ii�C�DERR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P.E. John E. Skvarla, III
Governor Director Secretary
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Charles D. Owen, III
Fletcher Warehousing Company
P.O. Box 188
Fletcher, Noi�lT`Ctrrolina 28732-018.8
February 19, 2013
7010 1870 0003 0875 2476
SUBJECT: ;; !Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(6)
and NPDES Permit NC0000094
Fletcher Warehousing Company
Fletcher Warehousing Company WWTP
Case No. LV-2013-0030
Henderson County
Dear Mr. Owen:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $237.00
($100.00 civil penalty + $137.00 enforcement costs) against Fletcher Warehousing Company.
This assessment is based upon the following facts: a review has been conducted of the discharge
monitoring report (DMR) submitted by Fletcher Warehousing Company for the month of ,
September 2012. This review has shown the subject facility to be in violation of the discharge
limitations and/or monitoring requirements found in NPDES Permit NC0000094. The violations
which occurred in September 2012 are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Fletcher Warehousing Company
violated the terms, conditions or requirements of NPDES Permit NC0000094 and G.S. 143-
215.1(a)(6) in,the manner and extent shown in Attachment A. In accordance with the maximums
established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed against any person who
violates the terms, conditions or requirements of a permit required by G.S. 143 -215. 1 (a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Departrherit of Environment and Natural Resources and the
Director of the Division of Water Quality, I, Chuck Cranford, Division of Water Quality Regional
Supervisor for the Asheville Region, hereby make the following civil penalty assessment against
Fletcher Warehousing Company:
Nne
orthCarohna
Adu&4
SURFACE WATER PROTECTION —ASHEVILLE REGIONAL OFFICE
Location: 2090 U.S. Highway 70,- Swannanoa, NC 28778
Phone: [phone]\FAX: [phone]
Internet: www.ncwaterguality.org

IS
0 of the 1 violations of G.S. 143-215.1(a)(6) and NPDES Permit No.
$.00 NC0000094, by discharging waste water into the waters of the State
in violation of the Permit Monthly Average limit for FLOW.
1 of the 1 violations of G.S. 143-215.l(a)(6) and NPDES Permit No.
$100.00 NC0000094, by discharging waste water into the waters of the State
in violation of the Permit Daily Maximum limit for FEC COLI.
$100.00 TOTAL CIVIL PENALTY
$137.00 Enforcement Costs
$237.00 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into
account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or
to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6)' Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; 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:
Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural
Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Please submit payment to the
attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit a written request for remission or mitigation including a detailed justification
for such request:
..Please be aware that a request for remission is limited to consideration of the five factors listed
below. as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s)
occurred or the accuracy of any of the factual statements contained in the civil penalty
assessment document. Because a remission request forecloses the option of an administrative
hearing, such a request must be accompanied by a waiver of your right to an administrative
hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please

prepare a detailed statement that establishes why you believe the civil penalty should be
remitted, and submit it to the Division of Water Quality at the address listed below. In
determining whether a remission request will be approved, the following factors shall be
considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282. 1 (b)
was 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 evidence presented in support of your request for remission must be submitted
in writing. The Director of the Division of the Division of Water Quality will review your
evidence and inform you of his decision in the matter of your remission request. The response will
provide details regarding the case status, directions for payment, and provision for further appeal
of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that
was not part of the original remission request considered by the Director. Therefore, it is very
important that you prepare a complete and thorough statement in support of your request for
remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission
of Civil Penalties, 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

E'
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]
and
Mail or hand -deliver a copy of the petition to
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 you have any questions, please contact Janet Cantwell of the Water Quality staff of the
Asheville Regional Office at 828-296-4500.
Sincerely,
Chuck C uiford, Regional Supervisor
Surface Water Protection Section
Asheville Regional Office
ATTACHMENTS
NPDES Point Source w attachments
DWQ Central Files w/ attachments
Goldie & Associates/ ORC w/ attachments
S ',s W P.HendersonliWastew ater,lnclustrial\Fletcher Warehouse 0009=1;LV-2013-0030.doe

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: LV-2013-0030 County: Henderson
Assessed Party: Fletcher Warehousing Company
Permit No.: NC0000094 Amount Assessed: $237.00
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts "
form to request remission of this civil penalty. You should attach any documents that you believe
support your request and are necessary for the Director to consider in evaluating your request for
remission.. Please be aware that a request for remission is limited to consideration of the five factors
listed below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or
the accuracy of any of the factual statements contained in the civil penalty assessment document.
Pursuant to N.C.G.S. § 143B-282. 1 (c), remission of a civil penalty may be granted only when one or
more of the following five factors applies. Please check each factor that you believe applies to your
case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were
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:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF HENDERSON
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINSTRATIVE HEARING AND
STIPULATION OF FACTS
FLETCHER WAREHOUSING COMPANY 1
PERMIT NO. NC00000914 ) FILE NO. LV-2013-0030
Having been assessed civil penalties totaling $237.00 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated February 19, 2013, the undersigned,
desiring to seek remission of the civil penalty, does hereby waive the right to an administrative hearing
in the above -stated matter and does stipulate that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the director of the Division of Water Quality within thirty (30) days of
receipt of the 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
SIGNATURE
20

ATTACHMENT A
Fletcher Warehousing Company
CASE NUMBER: LV-2013-0030
PERMIT: NC0000094 FACILITY: Fletcher Warehousing Company COUNTY: Henderson REGION: Asheville
Limit Violations
MONITORING'
OUTFALL/
VIOLATION
UNIT OF
CALCULATED % OVER
PENALTY
REPORT
PPI LOCATION PARAMETER
DATE FREQUENCY
MEASURE
LIMIT - VALUE LIMIT
VIOLATION TYPE
$100.00
9-2012
001 Effluent FEC COLI
09/19/12 Weekly
#/100ml
400 600 50.00
Daily Maximum Exceeded
$.00
9-2012 '
001 Effluent FLOW
09/30/12 Continuous
mgd
0.01 0.05 395.33
Monthly Average Exceeded

DIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT (FILE)
Violator: Fletcher Warehousing Company / NC0000094
(September 2012 1 R)
County: Henderson
Case Number: LV-2013-0030
ASSESSMENT FACTORS
As required by G.S.143-214.6A(c), in determining the amount of the penalty I considered the factors
set out in G.S. 143B-282.1(b), which are:
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation;
All effluent violations may be detrimental to the receiving stream but may not be
immediately quantified.
2) The duration and gravity of the violation;
One Daily Max Fecal coliform exceeded the permit limit by 50 %.
One Monthly Average Continuous flow exceeded the permit limit by 395.33 %.
3) The effect on ground or surface water quantity or quality or on air quality;
All effluent violations may be detrimental to the receiving stream but may not be
immediately quantified.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
The amount of money saved would include the cost of additional treatment/
adjustments and additional operator time on site.
6) Whether the violation was committed willfully or intentionally;
It does not appear to be either.
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
There have been no civil penalty assessments in the twelve months prior to this
violation.
8) The cost to the State of the enforcement procedures.
$137.00.
Date Chuck Cr ford, Regional Supervisor
Surface Water Protection Section
Asheville Regional Office
02/19/2013

Facility Status: (Please check one of the following)
a,
All monitoring data and sampling frequencies meet permit requirements
(including weekly averages, if applicable) ❑
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially
threatens public health or the environment. Any information shall be provided orally within 24 hours from the time the
permittee became aware of the circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
If the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for
improvements to be made as required by Part ILE.6 of the NPDES permit.
"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 managed the system, or those persons directly responsible
for gathering the information, the information submitted is, to the best of my lmowledge 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."
Fletcher Warehousing Company
Penmittee (Please print or type) ® '
r
Cold'. %ssicie e-s
For questions, contact Signature of P " itteeA*
Henry Dyar Date
He W North 2nd St (Required unless submitted electronically)
Seneca, SC 29678 1-866-882-8194
Permittee Address Phone Number e-mail address Permit Expiration Date
Certified Laboratory (2)
Certified Laboratory (3)
Certified Laboratory (4)
Certified Laboratory (5)
ADDITIONAL CERTIFIL+'D LABORATORIES
.PARAMETER CODES
Certification No.
Certification No.
Certification No.
Certification No.
Parameter Code assistance may be obtained by calling the NPDES Unit at [phone] or by visiting the Surface
Water Protection Section's web site at h2o.enr.state.nc.us/wqs and linking to the unit's information pages.
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be
entered for all of the parameters on the DMR for the entire monitoring period.
** ORC On Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the permittee, then the delegation of the signatory authority must be on
file with the state per 15A NCAC 2B .0506(b)(2)(D).
Page 2 .

i
The fecal coliform sample taken on September 19, 2012 exceeded the daily maximum
permit limit. The Wasterwater facility normally does not discharge but due to a heavy
rain fall on that day runoff water was discharged. We have increased the chlorine dosage
to help prevent future violations.

P-zh & " l/
Permit Enforcement History Details by Owner
02/18/13
1
Owner: Fletcher Warehousing Company
Facility: Fletcher Warehousing Company
Permit: NC0000094
Region: Asheville County: Henderson
Penalty Remission Enf EMC EMC OAH Collection Has
Assessment Penalty Enforcemen Request Enf Conf Remission Hearing Remission Remission Memo Sent Balance Pmt Case
Case Number MR Approved Amount t Costs Damages Received Held Amount Held Amount Amount to AGO Total Paid Due Plan Closed
LR-1999-0004 05/25/99 $1,500 $.00 $1,660.00 No 10/11/99
LV-2003-0605 6-2003 09/15/03 $450 $100.00 $550.00 $.00 No 10/22/03
LV-2007-0145 1-2007 04/16/07 $250 $130.00 $380.00 $.00 No 05/31/07
LV-2013-0030 9-2012 $100 $137.00 $237.00 No
Total Cases: 4 Total Penalty Amount: $2,300 Total Enforcement Cost: $367.00 Sum of Total Paid: $930.00 Total Balance Due: $1,737.00
Sum of Total Case Penalties: $2,667.00 Total Penalties after remission(s): $2,667.00

DIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT (FILE)
Violator: Fletcher Warehousing Company / NC0000094
(September 2012 DiMR)
County: Henderson
Case Number: LV-2013-0030
ASSESSMENT FACTORS
As required by G.S. 143-214.6A(c), in determining the amount of the penalty I considered the factors
set out in G.S. 143B-282.1(b), which are:
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation;
All effluent violations may be detrimental to the receiving stream but may not be
immediately quantified.
2) The duration and gravity of the violation;
One Daily Max Fecal coliform exceeded the permit limit by 50 %.
One Monthly Average Continuous flow exceeded the permit limit by 395.33 %.
3) The effect on ground or surface water quantity or quality or on air quality;
All effluent violations may be detrimental to the receiving stream but may not be
immediately quantified.
4). The cost of rectifying the damage;
The cost is unknown:
5) . The amount of money saved by noncompliance;
The amount of money saved would include the cost of additional treatment/
adjustments and additional operator time on site.
6) Whether the violation was committed willfully or intentionally;
It does not appear to be either.
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
There have been no civil penalty assessments in the twelve months prior to this
violation.
8) The cost to the State of the enforcement procedures.
$137.00.
Date Chuck Cranford, Regional Supervisor
Surface Water Protection Section
Asheville Regional Office
02/19/2013

41.
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P.E. John E. Skvarla, III
Governor Director Secretary
February 19, 2013
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Charles D. Owen, III -
Fletcher Warehousing Company
P.O. Box 188
Fletcher, North Carolina 28732-0188
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(6)
and NPDES Permit NC0000094
Fletcher Warehousing Company
Fletcher Warehousing Company WWTP
Case No. LV-2013-0030
Henderson County
Dear Mr. Owen:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $237.00
($100.00 civil penalty + $137.00 enforcement costs) against Fletcher Warehousing Company.
This assessment is based upon the following facts: a review has been conducted of the discharge
monitoring report (DMR) submitted by Fletcher Warehousing Company for the month of
September 2012. This review has shown the subject facility to be in violation of the discharge
limitations and/or monitoring requirements found in NPDES Permit NC0000094. The violations
which occurred in September 2012 are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Fletcher Warehousing Company
violated the terms, conditions or requirements of NPDES Permit NC0000094 and G.S. 143-
215.1(a)(6) in the manner and extent shown in Attachment A. In accordance with the maximums
established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed against any person who
violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the
Director of the Division of Water Quality, I, Chuck Cranford, Division of Water Quality Regional
Supervisor for the Asheville Region, hereby make the following civil penalty assessment against
Fletcher Warehousing Company:
One
NorthCarolina
Naturallty
SURFACE WATER PROTECTION —ASHEVILLE REGIONAL OFFICE
Location: 2090 U.S. Highway 70, Swannanoa, NC 28778
Phone: [phone]\FAX: [phone]
Internet: www.ncwaterguality.org

0 of the 1 violations of G.S. 143-215.1(a)(6) and NPDES Permit No.
$.00 NC0000094, by discharging waste water into the waters of the State
in violation of the Permit Monthly Average limit for FLOW.
1 of the 1 violations of G.S. 143-215.1(a)(6) and NPDES Permit No.
$100.00 NC0000094, by discharging waste water into the waters of the State
in violation of the. Permit Daily Maximum limit for FEC COLI.
$100.00 TOTAL CIVIL PENALTY
$137.00 Enforcement Costs
$237.00 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into
account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or
to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying -or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; 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:
Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural
Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Please submit payment to the
attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit a written request for remission or mitigation including a detailed justification
for such request:
Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s)
occurred or the accuracy of any of the factual statements contained in the civil penalty
assessment document. Because a remission request forecloses the option of an administrative
hearing, such a request must be accompanied by a waiver of your right to an administrative
hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please

prepare a detailed statement that establishes why you believe the civil penalty should be
remitted, and submit it to the Division of Water Quality at the address listed below. In
determining whether a remission request will be approved, the following factors shall be
considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 14313-282.1(b)
was 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 evidence presented in support of your request for remission must be submitted
in writing. The Director of the Division of the Division of Water Quality will review your
evidence and inform you of his decision in the matter of your remission request. The response will
provide details regarding the case status, directions for payment, and provision for further appeal
of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that
was not part of the original remission request considered by the Director. Therefore, it is very
important that you prepare a complete and thorough statement in support of your request for
remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission
of Civil Penalties, 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]
and
Mail or hand -deliver a copy of the petition to
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 you have any questions, please contact Janet Cantwell of the Water Quality staff of the
Asheville Regional Office at 828-296-4500.
Sincerely,
Chuck Cranford, Regional Supervisor
Surface Water, Protection Section
Asheville Regional Office
ATTACHMENTS
cc: DWQ Regional Supervisor w/ attachments
NPDES Point Source w/ attachments
DWQ Central Files w/ attachments
Goldie & Associates/ ORC w/ attachments
S: t5 W P'u 1.enderson\Wastew ater,lndustrial\Fletcher Warehouse 00094\I_ V-2013-0030. doe

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: LV-2013-0030 County: Henderson
Assessed Party: Fletcher Warehousing Company
Permit No.: NC0000094 Amount Assessed: $237.00
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts "
form to request remission of this civil penalty. You should attach any documents that you believe
support your request and are necessary for the Director to consider in evaluating your request for
remission. Please be aware that a request for remission is limited to consideration of the five factors
listed below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or
the accuracy of any of the factual statements contained in the civil penalty assessment document.
Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only when one or
more of the following five factors applies. Please check each factor that you believe applies to your
case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were
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:

STATE OF NORTH CAROLINA
COUNTY OF HENDERSON
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
FLETCHER WAREHOUSING COMPANY
PERMIT NO. NC0000094
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINSTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. LV-2013-0030
Having been assessed civil penalties totaling $237.00 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated February 19, 2013, the undersigned,
desiring to seek remission of the civil penalty, does hereby waive the right to an administrative hearing
in the above -stated matter and does stipulate that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the director of the Division of Water Quality within thirty (30) days of
receipt of the 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
SIGNATURE
ADDRESS
TELEPHONE
20

ATTACHMENT A
Fletcher Warehousing Company
CASE NUMBER: LV-2013-0030
PERMIT: NC0000094 FACILITY: Fletcher Warehousing Company COUNTY: Henderson REGION: Asheville
Limit Violations
MONITORING OUTFALLI VIOLATION UNIT OF CALCULATED % OVER
PENALTY REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE LIMIT VIOLATION TYPE
$100.00 9-2012 001 Effluent FEC COLI 09/19/12 Weekly #/100ml 400 600 50.00 Daily Maximum Exceeded
$.00 9-2012 001 Effluent FLOW 09/30/12 Continuous mgd 0.01 0.05 395.33 Monthly Average Exceeded

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
(including weekly averages', if applicable) ❑
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially
threatens public health or the environment. Any information shall be provided orally within 24 hours from the time the
permittee became aware of the circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
If the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for
improvements to be made as required by Part 11E.6 of the NPDES permit.
"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 managed 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."
Fletcher Warehousing Company
Permittee (Please print or type) c ---
For questions, contact Signature of PL�itntttee**
Henry Dyar Date
210 W North 2nd St
(Required unless submitted electronically)
"
Seneca, SC 29678 1-866-882-8194
Permittee Address Phone Number-
e-mail address Permit Expiration Date
Certified Laboratory (2)
Certified Laboratory (3)
Certified Laboratory (4)
Certified Laboratory (5)
ADDITIONAL CERTIFIED LABORATORIES
PARAMETER CODES
Certification No.
Certification No.
Certification No.
Certification No.
Parameter Code assistance may be obtained by calling the NPDES Unit at [phone] or by visiting the Surface
Water Protection Section's web site at h2o.enr.state.nc.us/was and linking to the unit's information pages.
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be
entered for all of the parameters on the DMR for the entire monitoring .period. '
** ORC On Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the permittee, then the delegation of the signatory authority must be on
file with the state per 15A NCAC 2B .0506(b)(2)(D).
Page 2

,
The fecal coliform sample taken on September 19, 2012 exceeded the daily maximum
permit limit. The Wasterwater facility normally does not discharge but due to a heavy
rain fall on that day runoff water was discharged. We have increased the chlorine dosage
to help prevent future violations.

Permit Enforcement History Details by Owner
02/18/13
1
Owner: Fletcher Warehousing Company
Facility: Fletcher Warehousing Company
Permit: NC0000094
Region: Asheville
County: Henderson
Penalty
Remission
Enf
EMC EMC OAH Collection
Has
Assessment Penalty
Enforcemen
Request Enf Conf
Remission
Hearing Remission Remission Memo Sent
Balance
Pmt
Case
Case Number MR Approved Amount
t Costs
Damages Received Held
Amount
Held Amount Amount to AGO
Total Paid
Due
Plan
Closed
LR-1999-0004 05/25/99 $1,500
$.00
$1,500.00
No
10/11/99
LV-2003-0605 6-2003 09/15/03 $450
, $10o.00
$550.00
$.00
No
10/22/03
LV-2007-0145 1-2007 04/16/07 $250
$130.00
$380.00
$.00
No
05/31/07
LV-2013-0030 9-2012 $100
$137.00
$237.00
No
Total Cases: 4 Total Penalty Amount:
$2,300
Total Enforcement Cost:
$367.00
Sum of Total Paid: $930.00 Total Balance Due:
$1,737.00
Sum of Total Case Penalties:
$2,667.00
Total Penalties after remission(s):
$2,667.00

0
Limit Vidlations, • Monitoring Violations Reporting Violations r OtherWolations
Permit: hJC17000094 petails.:; T
SOC: a AD':' l= ie#a1s Monitoring Report 09-2012 e#ails .
Facility: F[etcherUarhausing Corrrpany
Details 'Region_, sheville County: Henderson..^s
i
Owner: (FletcherU arehousrng Company
e
' -" Marntain Incident.- � D Mails... ; Inspect. Dt Dey it ..
Facility Reported As: Compliant Non -Compliant O Not Reported Q Is signed Report Type DMR'
,.
'
F6—utfa ii
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tempter
}Date T
W—a al
*Descri tiori °
a SC7C°
FLimit
*GaI4uL:
Unit
°u Over
I ^P Action
001
Effluent
Coliform, Fec...
0911912012
El
Daily Maximum
[1
400
600
#1100m1
50
Proceed to NO
i
...
...
...
001
Effluent
Flow, in cond.,09l30i2012
�
Manthly&erage ..
[j
0.01 ...
0.05 ...
rngd
395.33...
Proceed to NOV
� e 62
,
r
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n
sR.
0
Initrate NOD,,. .Initiate NOV Initiate EnSr+rcernent..: Initiate CEemar�cl,. �a�e E�.Recalr�,late
Help
Finisfa cancel
2 LimrtVialationsfound
Heady SID: VLLP
_ _._.

January 30, 2013
Chuck Cranford, Regional Supervisor
Surface Water Protection Section
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Notice of Violation # NOV-2013-LV-0049
Dear Mr. Cranford,
RECEIVE®
J AN 3 1 2013
DV-iQ/Surfacc Water Protection Section
Asheville Re0ional Office
In our September Monthly report to the Division of Water Quality, we indicated we had
exceeded our daily fecal coliform limit of 400 /100m1 by 200/100ml to 600/100ML on
September 19, 2012 due to an extraordinarily heavy rainfall. 2,000 gallons were
discharged on this date. We had never exceeded this limit. In our operator's response
included with the report as required by the State, they indicated they would adjust future
chlorine wastewater treatment to correct the problem. We did not exceed our allowed fecal
coliform monthly average for September.
Our fecal coliform has been tested on the following days and has been well under permitted
limits.
September 26, 2012 <1 /100m1
October 3, 2012 <1/100ml
November 2012 No Discharge
December 2012 No Discharge
January 2,2013 4/100m1
January 16,2013 <4/100ml
We can provide copies of the tests if requested.
The second violation in your NOV is incorrect. Our permitted monthly average is 300,000
gallons per month (10,000 mgd average). For the month of September 2012 our reported
value was .0049 mgd or 4900 average gallons per day. Report attached. The NOV letter
reports our average as .05 mgd or 50,000 gallons per day of discharged wastewater which
would translate to 1,500,000 gallons in a 30 day month. This is inaccurate. For the month
of September 2012, we discharged approximately 148,600 gallons of wastewater. We were
well below our limits and contest any finding that we were in violation.
If you need any more information, please contact me.
Sincerely,,
Charles D. Owen, III
President
�1
FLETCHER CROSSING INDUSTRIAL PARK I FLETCHER WAREHOUSING COMPANY
PO BOX 188 1 4600 HENDERSONVILLE ROAD FLETCHER, NC 28732 1 TEL: [phone] FAX: [phone]

EFFLUENT
RECEIVED
NPDES PERMIT NO. NC0000094 DISCHARGE NO. 001 MONTH 5 rFI&
YEAR Z&17—
FACILITY NAME Fletcher Warehousin Comnanx CLASS II COUNTY Henderson
CERTIFIED LABORATORY (1) Goldie & Associates CERTIFICATION NO. SC41080C601AN 3 2�13
(list additional laboratories on the backside/page 2 of this form)
OPERATOR IN RESPONSIBLE CHARGE (ORC) Robert Orr GRADE III CERTIFICA rION NO. _ CERTIFICATION NO. 53 0
PERSON(S) COLLECTING SAMPLES Robert On ORC PHONE [phone]DW /Surface Water Protection Section
CHECK BOX 1F ORC HAS CHANGED O NO FLOW / DISCHARGE FR Qshe� e egional Office
Mail ORIGINAL and ONE COPY to: a�
SERVICE
ATTN: CENTRAL FILES
1617 MAIL, S
DIVISION WATER QUALITY (SI TURF OF OPERATOR IN RESPONSIBL C GE) DATE
ERVICE CENTER BY THIS SIGNATURE, I CERTIFY THAT THIS REPO RT is
RALEIGH, NC 27699-1617 ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE
e 50050 00010 00400 50060 00310 00610 00530 31616 1 00300 1 0 600 1 00665
i= 6 FLOW C ENTERPARANI "IM
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DWQ Form MR -I (11104)

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requiremen
(includi
ng g weekly averages, if applicable)
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Non ompliant
The permittee shall report to the Director or the appropriate Regional Office any noncompliant that potentially
threatens public health or the environment. Any information shall be provided orally within 24 hours from the time the
pernuttee became aware of the circumstances. A written submission shall also be provided wi 5 days of the time the
permittee becomes aware of the circumstances.
If the facility is noncompliant, please attach a list of corrective actions being taken and a
improvements to be made as required by Part ILE.6 of the NPDES permit.
" I certify, under penalty of law, that this document and all attachments were prepared under M
in accordance with a system designed to assure that qualified personnel properly gather and ev
submitted. Based on my inquiry of the person or persons who managed the system, or those p(
for gathering the information, the information submitted is, to the best of my knowledge and bi
complete. I am aware that there are significant penalties for submitting false information, inch
fines and imprisonment for knowing violations"
Fletcher Warehousing Comp,
Permittee (Please print or typ
For questions, contact
Henry Dyar
210 W North 2nd St
Seneca, SC 29678
Permittee Address
Signature of Pikmittee*'` *
(Required unless submitted
1-866-882-8194
for
,ection or supervision
ite the information
as directly responsible
; true, accurate, and
g the possibility of
Date
Phone Number e-mail address Permit Expiration Date
ADDITIONAL,
Certified Laboratory (2) ..Certification No.
Certified Laboratory (3) Certification No.
Certified Laboratory (4) Certification No.
Certified Laboratory (5) Certification No.
PARAMETER CODES
Parameter Code assistance may be obtained by calling the NPDES Unit at [phone] or by
Water Protection Section's web site at h2o.enr.state.nc.us/wgs and linking to the unit's informat
Use only units of measurement designated -in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no d
entered for all of the parameters on the DMR for the entire monitoring period.
** ORC On Site?: ORC must visit facility and document visitation of facility as required per 15A NCA
*** Signature of Permittee: If signed by other than the permittee, then the delegation of the signatory au
file with the state per 15A NCAC 2B .0506(b)(2)(D).
visiting the Surface
)n pages.

The fecal coliform sample taken on September 19, 2012 exceeded the da
permit limit. The Wasterwater facility normally does not discharge but d
rain fall on that day runoff water was discharged. We have increased the
to help prevent future violations.
i maximum
to a heavy
ilorine dosage

NC®ENR
North Carolina Department of Environment and Natural Resources
Division. of Water Quality
Pat McCrory Charles Wakild, P.E.
John E. Skvarla, III
Governor Director
Secretary
January 23, 2013
CERTIFIED MAIL 7010 1870 0003 0875 228s
RETURN RECEIPT REQUESTED
Mr. Charles D. Owen, III
Fletcher Warehousing Company
P.O. Box 188
Fletcher, North Carolina 28732-0188
Subject: Notice of Violation and -
Recommendation for Enforcement
Tracking #: NOV-2013-LV-0049
Fletcher Warehousing Company WWTP
NPDES Permit No. NC0000094
Henderson County
Dear Mr. Owen:
A review of the September 2012 self -monitoring report for the subject facility revealed violations of the
following parameters:
Date
Outfall
Parameter
Reported. Value
Permit Limit
. 09/19/2012
001
Fecal colif6rm
600 #/ 100 ml
400 #/ 100 ml
09/30/2012
001
Flow
0.05 mgd
0.01 mgd
A Notice of Violation/ Notice of Recommendation for Enforcement (NOV/ NRE) is being issued for the
noted violation of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No. NC0000094.
Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be
assessed against any person who violates or fails to act in accordance with the terms, conditions, or
requirements of any permit issued pursuant to G.S. 143-215.1. If you wish to provide additional information
regarding the noted violation, request technical assistance, or discuss overall compliance please respond in
writing within ten (10) days after receipt of this Notice. A review of your response will be -considered along
with any information provided. on the September 2012 Discharge Monitoring Report. You will then be notified
of any civil penalties that may be assessed regarding the violations. If no response is received in this Office
within the 10-day period, a civil penalty assessment may be prepared.
SURFACE WATER PROTECTION SECTION—ASHEVILLE REGIONAL OFFICE
Location: 2090 U.S. Highday 70, Swannanoa. North Carolina 28778
Phone: [phone]\ Fax: [phone]
Internet: hftp://Portal.nodenr.orglweb/wcr-4�l—
(� Z An Equal Opportunity \ Affirmative Action Employer — 50% Recycled/10% Post Consumer paper
NorthCarollna
�iztlli'R`iCIJ'

t_.:ft
Mr. Charles D. Owen. III
January 23, 2013
Page Two,
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 this office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Janet Cantwell or
me at 828/296-4500.
Sincerely,
Chuck Cranford, Regional Supervisor
Surface Water Protection Section
Asheville Regional Office
—cc.: DWQ Asheville Files
DWQ Central Files
DWQ Point Source Branch
S .SCVP?Ftendersoir,Wastewater`_.industriaP,I-letcher Warehouse 00091`,.NOV-NRL ?013-LV-0049.doc

North Carolina Department of Environment and Natural Resources
Divi ion of Water Quality
Pat McCrory Charles Wakild, P.E. John E. Skvarla, III
Governor I Director Secretary
January 23, 2013
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Charles D. Owen, III
Fletcher Warehousing Company
P.O. Box 188
Fletcher, North Carolina 28732-0188
Subject: Notice of Violation and
Recommendation for Enforcement
Tracking #: NOV-2013-LV-0049
Fletcher Warehousing Company WWTP
NPDES Permit No..NC0000094
Henderson County
Dear Mr. Owen:
A review of the September 2012 self -monitoring report for the subject facility revealed violations of the
following parameters:
Date
Outfall
Parameter
Reported Value
Permit Limit
09/19/2012
001
Fecal coliform
600 #/ 100 ml
400 #/ 100 ml
09/30/2012
001
Flow
0.05 mgd
0.01 mgd
A Notice of Violation/ Notice of Recommendation for Enforcement (NOV/ NRE) is being issued for the
noted violation of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No. NC0000094.
Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be
assessed against any person who violates or fails to act in accordance with the terms, conditions, or
requirements of any permit issued pursuant to G.S. 143-215.1. If you wish to provide additional information
regarding the noted violation, request technical assistance, or discuss overall compliance please respond in
writing within ten (10) days after receipt of this Notice. A review of your response will be considered along
with any information provided on the September 2012 Discharge Monitoring Report. You will then be notified
of any civil penalties that may be assessed regarding the violations. If no response is received in this Office
within the 10-day period, a civil penalty assessment may be prepared.
SURFACE WATER PROTECTION SECTION —AS[ IEVILLE REGIONAL OFFICE
Location: 2090 U.S. Highway 70, Swatinatioa, North Carolina 28778
Phone: [phone]\ Pax: 828-299-7043
Internet: http:llportal.nodenr.om/web/wg
One
NorthCarolina
An Egwd Opportunity \ Affirmative Action Employer — 50% Recyclecl/10% Post Consumer paper

Mr. Charles D. Owen, III
January 23, 2013
Page Two
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 this office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Janet Cantwell or
me at 828/296-4500.
Sincerely,
Chuck Cranford, Regional Supervisor
Surface Water Protection Section
Asheville Regional Office
cc: DWQ Asheville Files
DWQ Central Files
DWQ Point Source Branch
S: SWP\1-fenderson\WastewateeIndastria1\Fletcher Warehouse 00094,NOV-NRI ?013-1,V-0049.doc

May 27, 2010
FISHER STARK
RA
ATTORNEYS
xa.
R D
MAY 2 a 2010
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFIC
VIA OVERNIGHT COURIER
Mrs. Dina Sprinkle
NC DENR/DWQ/Point Source Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
6117!i h Havness
North Carolina DENR
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Re: Fletcher Warehousing Permit #NC0000094
Henderson County
Dear Mrs. Sprinkle & Mr. Haynes:
Enclosed is an original (to Mrs. Sprinkle) and a copy to Mr. Haynes of Fletcher
Warehousing Company's application for renewal of permit. Please reissue this permit for an
additional five (5) year term. Please let me know if you need anything further.
WPF/sdj
encl.
35 North Market Street - Asheville, NC 28801 m 828.505.4300 • www.fisherstark.com

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
Mail the complete application
N. C. Department of Environment and Natural Res
Division of Water Quality / NPDES Unit ;
1617 Mail Service Center, Raleigh, NC 27699=1
1 ,
NPDES Permit Number
Please print or type.
1. Contact Information:
C E � V
M AY 2 8 2010
WATER QUALITY SECTION
ASHEVILLE REGIONAL C= i-_�E
Owner Name CILE-J-1 %? C) CO'' 7%9G•-''17 y
Facility Name /1t,1 `
Mailing Address Po k C%
City
State / Zip Code C_ 3 2—
Telephone Number ( .2-
Fax Number
ti
e-mail Address 0a)e4 mot,
G'i" t�..5,f/� �' � G..� n�
2. Location of facility producing discharge:
Check here if same as above .❑
Street Address or State Road f j� &)(4
City
State / Zip Code a� ot 3
County I
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or O�gRC)
Name ColGf%� tf di SSl7GlC�lE'-S
Mailing Address 2-I0 G0es.� Alyl-A 1 _('_ce1?d, s �„
City -Sse %7@Ca
State / Zip Code .2_. 9
Telephone Number W-11) F_ F�_ _. F/ 97 -/
Fax Number V 41 ) CS1- +y''.Z D 1? S /
4. Ownership Status:
Federal ❑
State ❑
Private
Public ❑
Page 1 of 5 C-MI 10108

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
5. Standard Industrial Classification (SIC) code(s): ` 2.4" ' -- 9 9d,6 7e--x-11-1,e-1,4&v-q 1
6. Number of employees: 4 25
T. Describe the treatment system List all installed waste treatment components with capacities,
describe the processes that generate wastewaters. If the space provided is not sufficient attach a
separate sheet of paper with the system description.
®a&,f .3� 75 117"
S. Is facility covered under federal effluent limitation guidelines? No N Yes ❑
If yes, specify the category?
9. Principal product(s) produced: e-5/r G 71J�. S � � •ram f'es IrO0015 04 rt
J
Principal raw material(s) consumed:
Briefly describe the manufacturing process(es): A j
Ida,re.hPa-,e- 0/7/y
Page 2 of 5 C-MI 10/08

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
10. Amount of principal product produced or raw material consumed
IT.i.ct, snerifir nm.nunts consumed anal/or units of production over the last three nears)
Product Produced or Raw Material
Consumed
AVERAGE
Product Produced or Raw Material
Consumed
PEAK
per Day
LVA�g
per Month
�i /
/t!✓�
per Year
IVA
11. Frequency of discharge: Continuous 1j
If intermittent:
Days per week discharge occurs:
Intermittent ❑
Duration:
12. Types of wastewater discharged to surface waters only
Discharge
Flow
GALLONS PER DAY
Sanitary - monthly average
Utility water; etc. - monthly average
nn
r"r
Process water - monthly average
Stormwater - monthly average
Other - monthly average
Explain:
Monthly Average
fj 0_5 e 1"7 .Z
total discharge (all types)
f�,/dZ2 e_ a
13. Number of separate discharge points: _�Outfall Identification number(s) 00
14. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Page 3 of 5 C-MI 10/08

BUN_ GkQ) N E
BENDER F
HE 1w
\� . _ 4 l -ter
LLE'
MU P AIRPORT
V*4
0
oh C h,
j V
>
f
er.
r,- Tank
. ftjzs Ch. is
-xri
N
?A
i V I r Vey ✓
1
as Are
Ile
\X�XUEB 19
!C,
.-b U FB
C C_
z ro
Latitude: 35"24'43"
Longitude: 82'32'18"
Quad# nNE
Steam Class: WS-1v
Subbasin 40302:
Receiving Ste= F�erjch Bmad River
77
LAT.*124
kt.o
d((
,
S
In,
j
5 1610) i "e
ROAD U 23
Butle I
a
x-
N
/V
NCO000094
Fletcher Warehousing
Company
FacRity
l�
Location
;a -
North
'SCALE 1:24000

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
15. Effluent Data [for new or proposed discharges]
Provide data for the parameters listed. Temperature and pH shall be grab samples, for all other parameters 24-hour
composite sampling shall be used. If more than one analysis is reported, report daily maximum and monthly average.
If only one analysis is reported, report as daily maximum.
NOTE: Permittees requesting renewal should complete the table ONLY for the parameters
.•�.rrantty mnnitored. summarize the east 3 vears of effluent data.
Parameter
Daily
Maximum
Monthly
Average
Units of
Measurement
Biochemical Oxygen Demand (BOD5)
Chemical Oxygen Demand (COD)
Total Organic Carbon
Total Suspended Solids
Ammonia as N
Temperature (Summer)
Temperature (Winter)
pH
Fecal Coliform (If sanitary waste is
present)
Total Residual Chlorine (if chlorine is
used)
16. List all permits, construction approvals and/or applications (check all that apply and provide permit
numbers or check none if not applicable):
Type Permit Number Type Permit Number
Hazardous Waste (RCRA)
UIC (SDWA)
t/-NPDES d%
PSD (CAA)
NESHAPS (CAA)
Ocean Dumping (MPRSA)
,NCc2D % Dredge or fill (Section 404 or CWA)
Other
Non -attainment program (CAA)
17. List any chemicals that may be discharged (Please list and explain source and potential
amounts.)
W
Page 4 of 5 C-MI 10/08

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
is. Is this facility located on Indian country? (check one)
Yes ❑ No [�
19. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is tlue, complAte, and accurate.
ted name of Person Signing Title
ture of A
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management ComM* ission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 5 of 5 C-MI 10/08

1 A L-
NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor . Director
March 12, 2010
Charles D Owen
Fletcher Warehousing Company
PO Box 188
Fletcher NC 287320188
Natural Resources
Dee Freeman
Secretary
SUBJECT: Compliance Evaluation' Inspection
Fletcher Warehousing Company
Permit No: NC0000094
Henderson County
Dear Mr. Owen:
Enclosed please find a copy of the Compliance Evaluation Inspection Report from
the inspection which I conducted at the site on Februar rL19, 2010. The facility was found
to be in Compliance with permit NC0000094, with the exception of the unknown status of
the effluent flow meter.
Please refer to the enclosed inspection report for additional observations and
comments. Also note that since the permit expires later this year, this would be an
excellent opportunity to make modifications to reflect the status of the components of the
waste water treatment facility. If you have any questions, please do not hesitate to call
me at 296-4500.
Sincerely,
Keith Hayn s
Environmental Sr. Specialist
Enclosure
cc: Central Files
mWA;sha�rlfelles
:\WP Henderson\Wastewater\ ndustria \ letcher are louse 0 4\GE 2-19-10. oc
SURFACE WATER PROTECTION — ASHEVILLE REGIONAL_OFFICE One
Location: 2090 U.S. Highway 70, Swannanoa, NC 28778 NorthCarohna
Phone: [phone]\FAX: [phone]\Customer Service: 1-877-623-6748 Vatural y
Internet: www.ncwaterguality.oro. �/

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance inS ection 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 I Ct 31 NC0000094 111 121 10/02/19 117 18111 191 .cl 20I
LI J tJ U J
Remarks
211 1. 1 1 I I I I I I I I I I I I III 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 I 116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA ------------- —------------ Reserved -------------- --- ---
67 69 70 L II 71 I I 72 73 W 74 761 I I I I I I 180
t--t
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)
Fletcher Warehousing Company '
01:15 PM 10/02/19
05/12/01
Exit Time/Date
Permit Expiration Date
4600 'Hendersonville Rd
Fletcher NC 28732
01:45 PM 10/02/19
10/11/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Robert E. Orr/ORC/866-882-8194/
Name, Address of Responsible Officiallritle/Phone and Fax Number
Contacted
Charles D Owen,PO Box 188 Fletcher NC 287320188//828-651-9815/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance N Facility Site Review
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
Keith Haynes ARO WQ//828-296-4500/ 3 l(.to
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers D to
i
Roger C_ Edwards 1�v ARO WQ//828-296-4500/ %� Zr7l
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3I NC0000094 I11 12I 10/02/19 I17 18 _i
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
This plant was built to treat a high volume of industrial waste, but now the only flow is domestic from the
office and warehouse space. Discharges only occur during rain events. It is still highly recommended that
the facility connect to local sewer or install an on -site treatment system for handling the small volume of
wastewater generated. It is also imperative that the flow meter be properly maintained and operated.
Page # 2

F
Permit: NC0000094 Owner - Facility: Fletcher Warehousing Company
Inspection Date: 02/19/2010 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 011110
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑ ■ ❑ ❑
Judge, and other that are applicable?.
Comment: Plant basically discharges stormwater.
Permit
Yes
No NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
■ ❑
❑
Is the facility as described in the permit?
❑
■ ❑
❑
# Are there any special conditions for the permit?
❑
❑ ■
Cl
Is access to the plant site restricted to the general public?
❑
■ ❑
❑
Is the inspector granted access to all areas for inspection?
■
❑ ❑
❑
Comment: This permit expires on November 30, 2010 which is eight months away.
Please remember that the renewal must be submitted at least six months prior to the
expiration date. This would also be a good time to make modifications to the permit,
such as the facility description. There are no fences around the Wwtp.
Flow Measurement - Effluent
Yes
No NA
NE
# Is flow meter used for reporting?
■
❑ ❑
❑
Is flow meter calibrated annually?
❑
■ ❑
❑
Is the flow meter operational?
❑
■ Cl
❑
(If units are separated) Does the chart recorder match the flow meter?
■
❑ ❑
❑
Comment: It is unknown if the meter was operating properly. It didn't appear that the
meter had been calibrated within the last year.
Page # 3

Mr. Roger C. Edwards
Surface Water Protection Section
2090 U.S. Highway 70
Swannanoa, NC 28778
GOLDIE
ASSOCIATES
engineering, environmental
and laboratory services
Dear Mr. Edwards
RE: Notice of Violation, NOV-2010-MV-0055, ermit No. 0000094, Fletcher
Wareh� Company
The discharge for December 9, 2009 had to be from rain runoff because the aeration
basins and the clarifier had been pump down in preparation for closure of the Wastewater
Treatment Plant. The 200 gallons of discharged flow occurred between the time the
operator left the plant on December 8, 2009 and upon his arrival on December 9, 2009.
The operator noticed the flow on the flow recorder and took a pH & DO reading in the
flume, but there was not any water discharging at this time, therefore there were not any
samples collected since there was not a discharge when the operator was at the site. There
was not any more flow discharged for the rest of the month at the treatment plant.
We ask that you take these circumstances into consideration and rescind the Notice of .
Violation if possible.
Please contact me if .you have any questions or concerns.
Sincerely,
Henry Dyar
Goldie & Associates
Operations Manager
IWATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
210 W. North. Second Street • Seneca, South Carolina 29678 • Phone [phone] • Fax [phone]

Governor
Mr. Charles D. Owen, III
Fletcher Warehousing Company
P.O. Box 188
Fletcher, North Carolina 28732-0188
Dear Mr. Owen:
PWAA
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Director
May 12, 2010
Subject: NOTICE OF VIOLATION
NOV-2010-MV-0056
Permit No. NC0000094
Fletcher Warehousing Company WWTP
Henderson County
Secretary
A review of Fletcher Warehousing Company's monitoring report for January 2010 showed the following
violations:
Parameter
Date
Measuring
Frequency
Violation
Flow, Continuous
01/30/2010
Continuous
Failure to Monitor
Flow, Continuous
01/31/2010
Continuous
Failure to Monitor
It was also noted that the Compliance box on the back of the DMR was marked "Compliant" when in fact it should
have been marked "Non -Compliant" with an explanation for the non-compliance. If the above parameter was left off
inadvertently, please send an amended DMR to Raleigh at the address found on the front page of your DMR.
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue enforcement
action for this and any additional violations of State law. If you should have any questions, please do not hesitate to
contact Janet Cantwell at 828/296-4500.
Sincerely,
Roger C. Edwards, Regional Supervisor
Surface Water Protection Section
c�,;�DWQ �sYieville tF.iles �';`�'
DWQ Central Files
Goldie & Associates/'ORC
S:`•.SWiI I i,� nderg.on`•tk-'astewaIcr%Indastrialkl fetcher Wlirchouse 0009:P No)V-20I O-MV-0056.doc
NorthCarolina
Natmrally
North Carolina Division of Water Quality 2090 U.S. Highway 70 Swannanoa, N.C. 28778 Phone[phone] Customer Service
Internet: www.ncwaterguality.org FAX [phone]

Y��� �i 5 , y, ■•• f -o s
NCDENR�
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
May 12, 2010
Mr. Charles D. Owen, III
Fletcher Warehousing Company
P.O. Box 188
Fletcher, North Carolina 28732-0188
Subject: NOTICE OF VIOLATION
NOV-2010-MV-0055
Permit No. NC0000094
Fletcher Warehousing Company WWTP
Henderson County
Dear Mr. Owen:
A review of Fletcher Warehousing Company's monitoring report for December 2009 showed the following
violations:
Parameter
Date
Measuring Frequency
Violation
BOD, 5-Day (20 Deg. C) -Concentration
12/12/09
Weekly
Failure to Monitor
Ammonia Nitrogen
12/12/09
Weekly
Failure to Monitor
Total Suspended Residue
12/12/09
Weekly
Failure to Monitor
Fecal Coliform
12/12/09
Weekly
Failure to Monitor
Phosphorus, Total (as P) - Concentration
12/31/09
Quarterly
Failure to Monitor
Nitrogen, Total (NO2+NO3+TKN)
12/31/09 TQuarterly
Failure to Monitor
It was also noted that the Compliance box on the back ofthe DMR was marked "Compliant" when in fact it should
have been marked "Non -Compliant" with an explanation for the non-compliance. If the above parameters were left off
inadvertently, please send an amended DMR to Raleigh at the address found on the front page of your DMR.
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue enforcement
action for this and any additional violations of State law. If you should have any questions, please do not hesitate to
contact Janet Cantwell at 828/296-4500.
Sincerely,
Roger C. Edwards, Regional Supervisor
_ Surface Water Protection Section
c z Q A,966V%i11e�File y�
DWQ Central Files
Goldie & Associates/ ORC
ti;'.5��`Pll lendersun`:'',Istc'tt'aier,[ndustri,il'•.!'lefcher Warehouse 00094'•..NOV-2010-MV-005,doc One
No Carolina
Aturu!!y
North Carolina Division of Water Quality 2090 U.S. Highway 70 Swannanoa, N.C. 28778 Phone[phone] Customer Service
Internet: www.ncwatergualitv.ora FAX [phone]

F1SHER ---- STARk
RA:
ATTORNEYS
March 16, 2010
Keith Haynes
Environmental Sr. Specialist
NCDENR
2090 US Highway 70
Swannanoa, NC 28778
RE: Fletcher Warehousing Company
Permit No.: NC0000094
Henderson County
Dear Mr. Haynes:
I would like to discuss with you extending the above referenced permit. Please
give me a call at your earliest convenience.
V
WPF/skh
.........
ID
MAR 1 8 '2010
WATER QUALITY SECTION
ASHEVILLE REGIONAL OF
V,
35 North Market Street - Asheville, NC 28801 - 828.505.4300 - www.fisherstark.com

for
Fletcher Warehousing Company WWTP
for the Operating PeriodRECEIVEL)
January thru December, 2008 MAR - 9 2009
DENR - WATER QUALITY
POINT. SOURCE BRANCH
Preface
On July 20 1999, the North Carolina General Assembly ratified House Bill 1160; the Clean
Water Act of 1999, which place significant new reporting requirements on those entities that
own or operate wastewater treatment arid.collection systems. Specific items included:
1. A Spill Response Plan
2. Sewer Collection System. Operation & Maintenance Plan
3. Annual Performance Report
These new requirements became effective October 1, 1999.
This report is designed to meet the minimum requirements for the Annual Performance Report
established by the North Carolina Department of Environment and Natural Resources (DEHNR)
as set forth in their guidance document dated October 19, 1999.
This law was established to provide a mechanism for public oversight (and hopefully, to instill
public confidence) in owners and operators of wastewater treatment systems and in their efforts
to protect the waters of the state.

I. General Information
Facility/System Name:
Responsible Entity:
Fletcher Warehousing Company WWTP
Henderson County
Fletcher Warehousing Company
Person(s) in Charge/Contact: Stan Littlejohn, Warehouse Manager
Robert Orr — Operator -in Responsible Charge (ORC)
Henry Dyar, Project Manager - Goldie & Associates
Applicable Permits: NPDES # NC0000094
Description of Treatment Process, Collection System, and Facilities Served:
Treatment Process — The treatment facility is a conventional "Activated Sludge" process
capable of treating 4.0 million gallons per day (MGD). The current NPDES Permit allows
for 0.010 MGD flow.
Collection System — The main collection system is a standard gravity design with 8-inch
diameter pipe and standard pre -cast manholes: The system has a Spill Response Plan and an'
Operation and Maintenance Plan for.the sewer collection system.
Facilities Served - The facility serves the warehousing operation with approximately 10
employees and serves to treat activated sludge removed from small wastewater treatment
package plants.
NOTE: This facility was originally constructed to serve Cranston Print Works, a textile print
and dye manufacturing entity. Cranston Print Works ceased operations and sold the facilities.
Fletcher Warehousing Company converted the manufacturing facility into a warehousing
facility. Fletcher Warehousing Company is keeping the WWTP facility in a state of
operational readiness to serve additional area wastewater needs should the need arise. The
facility is currently functioning much like an oxidation basin because of the very low flow and
is more than capable of treating the very low volume.
H. WWTP Performance
All operating parameters were in compliance with NPDES permit limits for 2008, except for the
following occurrence. In May 2008 there was a fecal coliform violation.
We take pride in our efforts to protect the local environment and the quality of waters in
our streams.

i
III. Collection System Performance
The collection system experienced no significant problems for the reporting period.
IV. Notification
A notice advising of the availability of this report will be sent to each user. A copy of this
report is available to interested persons in the offices of:
Fletcher Warehousing Company
PO Box 457
Swannanoa, NC 28778
or by contacting:
Henry Dyar
c/o Goldie & Associates
210 West North Second Street
Seneca, SC 29678
As required, three copies of this report are being provided to NCDEHNR.
V. Certification
I certify that under penalty of law that this report is complete and accurate to the best of
my knowledge.
/�� Henry Dyar, oldie & Associates
-3 o �
Date
This report prepared by:
Henry Dyar
Goldie & Associates
210 West North Second Street
Seneca, SC 29678
Phone: [phone]
Fax: [phone]

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
W PERRY FISHER II
FISHER STARK PA ATTORNEYS
35 NORTH MARKET STREET
ASHEVILLE NC 28801
Dear Mr. Fisher:
Division of Water Quality
Coleen H. DJllins
Director
June 16, 2010
Subject: Receipt of permit renewal application
NPDES Permit NC0000094
Fletcher Warehousing Company
Henderson County
Dee Freeman
Secretary
The NPDES Unit acknowledges receipt of the permit renewal application for the above facility on May 28,
2010; however, on initial review it was noted that the required Sludge Management Plan was not included in the
paperwork submitted. Please submit to this unit a narrative description of your Sludge Management Plan. 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.
For your convenience, we can accept a faxed copy at [phone] or you can mail it attention to me at
the mail service center address listed below. Upon receipt, a member of the NPDES Unit will further review your
application and will contact you if additional information is required.
If you have any additional questions concerning renewal of the subject permit, please contact Julie Grzyb at
[phone].
Sincerely,
Dina Sprinkle
Point Source
cc: CENTRAL FILES
�she�"'lle Regional ©ffice/Surface Water Protection
NPDES Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] \ FAX: 91 M07-6492 \ Customer Service:1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
LA
wA
S
WEC?toN
ATER QUALITY AL OFFICE • r�
[NIECE REG\O
N
:M': 'rthCarolina

Michael F: Easley
Governor
William G. Ross, Jr., Secretary
NCDENR North Carolina Department of Environment and Natural Resources
„ Ian W. Klimek, P.E:;' Di
Division of Water Quality
Stan Littlejohn, Site Manager
Fletcher Warehous- Company ,
P.O. Boxes L,'S
North Carolina 28778
November 9, 2005 D
,
1
. v ua NOV 1 6 2005 ,
WATER QUALITY SEC, ION
ASHEVILLE REGIONAL OF -IC;-
-------- Subject: Issuance:of NPDES,Perinit Na000094------ ____ _._____._,._..
Fletcher -Warehousing Company
Henderson County
Dear Mr. Littlejohn
Division personnel have reviewed and approved your application for renewal of the subject permit. .
Accordingly, we are forwarding the attached NPDES discharge permit. ,This permit is issued pursuant to the. .
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9,1994 (or as subsequently amended).
This final permit includes no major changes from the draft permit sent to you on July 6, 2005.
If anyparts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of .
this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain
other permits which may be required bythe Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be
required. If you have any questions concerning this permit, please contact Sergei Chemikov at telephone number
[phone], extension 594.
cc: Central Files
L,,NI,DES Pemut Pile
" euill t gton ` :®ff e%Surfs e Water7'rotection :lP
DEH
Ben Day, Goldie and Associates
210 W. North Second Street, Seneca, SC 29678
N. C. Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Sincerely,
VW. Klimek, P.E.
Phone: [phone]
fax: [phone]
DENR Customer Service Center:1800 623-7748

Permit NC0000094
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Fletcher Warehousing Company
is hereby authorized to discharge wastewater from a facility located on
:. Route 25
Henderson County
to receiving waters designated as the French Broad River in the French Broad River
Basin
in, accordance with effluent limitations, monitoring requirements and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective December 1, 2005.
This permit and authorization to discharge shall expire at midnight on November 30, 2010.
Signed this day November 9, 2005.
Alanek, P.E. Director
I Divi on of Water Quality
By Authority of the Environmental Management Commission

Permit NCO000094
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for `operation or discharge are hereby
revoked. As of this permit 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.
Fletcher Warehousing Company is hereby authorized to:
1. Continue'to operate an existing (4.0 MGD) extended aeration wastewater
treatment facility at a monthly average flow, not exceeding 0.01 MGD which.
includes the following components: "
➢ Influent lift station with manual trash screen
➢ Dual 3.75 MGD aeration basins with mechanical aerators
➢ Dual final clarifiers with sludge return
➢ Belt press for sludge
➢ _ Sludge dryer
➢ Settling ponds"
➢ Effluent disinfection equipment
This facility is located at the former Cranston Print Works plant in Fletcher on
Route 25 in Henderson County, and
2. Discharge from said treatment works at the location specified on the attached map
into the French Broad River, classified WS-IV waters in the French Broad River
Basin.

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Permit NC0000094
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
-i
""i ' "x`
EFFLUENT,
LIMITS f> k
'
MONITORING
ARE IREMENTrvYr �F;
QU, S
'°uu
,cx^
N�onthly �� Daily Measurement
.r :...q-,*c
Sample Type
E
3' 1
,Sam Ie:Location,r
a'R_r
s Average Maximum Frequency
r
0,P��
,..
Flow
0.01 MGD
Continuous
Recording
Effluent
BOD, 5 day 202C
26.0 m L
39.0 m /L
Weekly
Grab
Effluent
Total Suspended Solids
30.0 m L
45.0 m L
Weekly
Grab
Effluent
NH3 as N
Weekly
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
Effluent
U stream & Downstream
Fecal Coliform (geometric mean)
200/10D mL
400/100 mL
Weekly
Grab
Effluent .
Upstream & Downstream
Total Residual Chlorine
28 p /L
2Meek
Grab
Effluent
Total Nitrogen NO2+NO3+TKN
Quarterly
Grab
Effluent
Total Phosphorus
Quarterly
Grab
Effluent
Temperature (2C)
Weekly
Grab
Effluent
Upstream & Downstream
H3
Weekly
Grab
Effluent .
Footnotes:
1. Upstream = upstream at the Butler Bridge; Downstream = downstream at the Fanning Bridge.
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

NPDES Permit Requirements
Page 1 of 16
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events.
3/Week
Samples are collected three times per week on three separate calendar days.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC 1251, et. seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which
is not a designed or established or operating mode for the facility.
Calendar Dav
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 ml in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate ,method (specific number and size of aliquots necessary, the time
interval between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically.
Composite samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 ,hour
period of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period
with the time intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow recorder and
totalizer, and the preset gallon interval between sample collection fixed at no greater than 1 /24 of the
expected total daily flow at the treatment system, or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at
a constant time interval. This method may only be used in situations where effluent flow rates vary
less than 15 percent. The grab samples shall be taken at intervals of no greater than 20 minutes apart
during any 24-hour period and must be of equal size and of no less than 100 milliliters. Use of this method
requires prior approval by the Director.
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NPDES Permit
Page 2 of 16
In accordance with (4) above, influent grab samples shall not be collected more than once per hour.
Effluent grab samples shall not be collected more than once per hour except at wastewater treatment systems
having a detention time of greater than 24 hours. In such cases, effluent grab samples may be collected at
intervals evenly spaced over the 24-hour period that are equal in number of hours to the detention time of the
system in number of days. However, the interval between effluent grab samples may not exceed six hours nor
the number of samples less than four during a 24-hour sampling period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. The "daily discharge" concentration comprises the mean
concentration for a 24-hour sampling period as either a composite sample concentration or the arithmetic mean of all
grab samples collected during that period. (40 CFR 122.3)
Daily Maximum
The highest "daily discharge" during the calendar month.
Daily Sampling
Parameters -requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. The Division expects that sampling shall be conducted on weekdays except where holidays or other
disruptions of normal operations prevent weekday sampling. If sampling is required for all seven days of the week
for any permit parameter(s), that requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWO or "the Division"
The Division of Water Quality, Department of Environment and Natural Resources.
EMC i.
The North Carolina Environmental Management Commission.
Facility Closure
The cessation of wastewater treatment at a permitted facility, or the cessation of all activities that require coverage
under the NPDES. Completion of facility closure will allow this permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]'D shall be considered =1.
Grab Sample
Individual samples of at least 100 nil collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
Instantaneous flow measurement
A measure of flow taken at the time of sampling, when both the sample and flow will be representative of the total
discharge.
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NPDES Permit Requirements
Page 3 of 16
Monthly Averag(concentration limitl
The arithmetic mean of all "daily discharges" of_a pollutant measured during the calendar month. In the case of fecal
coliform, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Average (concentration limit)
The average of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable,
or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational . error, improperly. designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Average (concentration limitl
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform, the geometric mean of such -discharges.
Section B. General Conditions
1. Duty to Comply
The Permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation
of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or denial of a permit renewal application [40 CFR 122.411.
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under
section 405(d) of the Clean Water Act within the time provided in the regulations that establish these
standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not yet been
modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates section 301, 302, 306, 307, 308, 318 or 405 of the
Act, or any permit condition or limitation implementing any such sections in a permit issued under section
402, or any requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8)
of the Act, is subject to a civil penalty not to exceed $25,000 per day for each violation. [40 CFR 122.41 (a)
(2)]
c. The Clean Water Act provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or
405 of the Act, or any condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, or any requirement imposed in a pretreatment program approved under section
402(a)(3) or 402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a
negligent violation, a person shall be subject to .criminal'penalties of not more than $50,000, per day of
violation, or by imprisonment of not more than 2 years, or both. [40 CFR 122.41 (a) (2)]
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NPDES Permit Requiremen
Page 4 of 1 b
d. ;Any person who knowing violates such sections, or such conditions or limitations is subject to criminal
';penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In
the case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
;penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[40 CFR 122.41 (a) (2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
;condition or limitation implementing any of such sections in a permit issued under section 402 of the Act,
and who knows at that time that he thereby places another person in imminent danger of death or serious
bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not
more than 15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment
violation, a person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than
30 years, or both. An organization, as defined in section 309(c)(3)(15)(1) of the CWA, shall, upon conviction
of violating the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined
up to $2,000,000 for second or subsequent convictions. [40 CFR 122.41 (a) (2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such
sections in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are
riot to exceed $10,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$25,000. Penalties for Class II violations are not to exceed $10,000 per day for each- day during- which_ the
violation continues, with the maximum amount of any Class II penalty not to exceed $125,000. [40 CFR
122.41 (a) (3)]
2. Duty'to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment
[40 CFR 122.41 (d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II. C. 4), "Upsets" (Part II. C. 5) and "Power
Failures" (Part II. C. 7), nothing in this permit shall be construed to relieve the Permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309
of the Federal Act, 33 USC 1319. Furthermore, the Permittee is responsible for consequential damages, such as
fish kills, even though the responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75. et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, -even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion- of personal rights, nor
any infringement of Federal, State or local laws or regulations [40 CFR 122.41 (g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
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NPDES Permit Requirements
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7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of thi
Permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the remainde
of this permit, shall not be affected thereby [NCGS 150B-23].
8; Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the
Permit Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41 (h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41 (b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the Permittee shall submit such information, forms, and
fees as are required by the agency authorized to issue permits no later than 180 days prior to the expiration date.
Any Permittee that has not requested renewal at least 180 days prior to expiration, or any Permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will subject
the Permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified
[40 CFR 122.41 (k)].
a. All permit applications shall be signed as follows:
0) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in
charge of a principal business function, or any other person who performs similar policy or decision
making functions for the corporation, or (b) the manager of one or more manufacturing, production, or
operating facilities, provided, the manager is authorized to make management decisions which govern the
operation of the regulated facility including having the explicit or implicit duty of making major capital
investment recommendations, and initiating and directing other comprehensive measures to assure long
term environmental compliance with environmental laws and regulations; the manager can ensure that
the necessarysystems are established or' actions taken to gather complete and accurate information for
permit application requirements; and where authority to sign documents has been assigned or delegated
to the manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) _For a municipality, State; Federal, or other public agency. by either a principal executive officer or
ranking elected official [40 CFR 122.22].
b.. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
1. The authorization is made in writing by a person described above;
2. The authorization specified either an individual , or a position having responsibility for the overall
operation of the regulated facility or activity, such as the position of plant manager, operator of a well or
well field, superintendent, a position of equivalent responsibility, or an individual or position having
overall responsibility for environmental matters for the company. (A duly authorized representative may
thus be either a named individual or any individual occupying a named position); and
3. The written authorization is submitted to. the Permit Issuing Authority [40 CFR 122.221
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c. .Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate
because a different individual or position has responsibility for the overall operation of the facility, a new
authorization satisfying the requirements of paragraph (b) of this section must be submitted to the Director
prior to or together with any reports, information, or applications to be signed by an authorized
representative [40 CFR 122.22]
d.; Certification. Any person signing a document under paragraphs a. or b. of this section shall make the
following certification [40 CFR 122.22]:
7;,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. 1 am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned
changes or anticipated noncompliance does not stay any permit condition [40 CFR 122.41
13: Permit'Modification_ Revocation and Reissuance or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the
permit,, revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 2H .0100; and North Carolina General Statute 143-215.1 et. al.
14. Annual'Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 2H.0105 (b) (4)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Upon classification of the permitted facility by the Certification Commission, the Permittee shall employ a
certified water pollution control treatment system operator in responsible charge (ORC) of the water pollution
control treatment system. Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the water pollution control treatment system by the Certification Commission. The
Permittee must also employ one or more certified Back-up .ORCs who possess a currentlyy valid certificate of the
type of the system. Back-up ORCs must possess a grade equal to (or no more than one grade less than) the grade
of the system [15A NCAC 8G.0201].
The ORC of each Class I facility must:
➢ Visit the facility at least weekly
➢ Comply with all other conditions of 15A NCAC 8G.0204.
The ORC of each Class II, III and IV facility must:
➢ Visit the facility at least daily, excluding weekends and holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 8G.0204.
Once the' facility is classified, the Permittee shall submit a letter to the Certification Commission designating the
operator in responsible charge:
a. Within 60 calendar days prior to wastewater being introduced into a new system
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b. Within 120 calendar days of:
➢ Receiving notification of a change in the classification of the system requiring the designation of'a
new ORC and back-up ORC
➢ A vacancy in the position of ORC or back-up ORC.
2. ProperOOperation and Maintenance
The Permittee shall at all times provide the operation and maintenance resources necessary to operate the existing
facilities at optimum efficiency. The Permittee shall at all tidies properly operate and maintain all facilities and
systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the Permittee to install
and operate backup or auxiliary facilities only when necessary to achieve compliance with the conditions of the
permit [40 CFR 122.41 (e)].
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41
(c)]
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41 (m) (2)] .
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not `subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41 (m)' (3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior
notice, if possible at least ten days before the date of the bypass; including an evaluation of the
anticipated quality and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II. E. 6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the.use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.41 (n) (2)]: An upset constitutes an affirmative defense to an action
brought for noncompliance with such technology based permit effluent limitations if the requirements of
paragraph b. of this condition are met. No determination made during administrative review of claims that
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noncompliance was caused by upset, and before an action for noncompliance, is final administrative action
subject to judicial review.
b. C,onditions necessary for a demonstration of upset: A Permittee who wishes to establish the
affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or
other relevant evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Pern ittee submitted notice of the upset as required in Part II. E. 6. (b) (B) of this permit.
(4) The Permittee complied with any remedial measures required under Part II. B. 2. of this permit.
d. ' . Burden of proof [40 CFR 122.41 (n) (4)]: The Permittee seeking to establish the occurrence of an
Upset has the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States. The Permittee
shall comply with all existing Federal regulations governing the disposal of sewage sludge. Upon promulgation of
40 CFR Part 503, any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR 503. The
Permittee shall comply with applicable 40 CFR 503 Standards for the Use and Disposal of Sewage Sludge (when
promulgated) within the time provided in the regulation, even if the permit is not modified to incorporate the
requirement. The Permittee shall notify. the Permit Issuing Authority of any.significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 2H.0124 —
Reliability) to prevent the discharge of untreated or inadequately treated wastes during electrical power failures
either by means of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of
the permitted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period the sample represents. All samples shall be taken at the
monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted
by any other wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority [40 CFR 122.41 G)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summed for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR 1, LL 2, 3) or alternative forms approved by the
Director,; postmarked no later than the 28th day following the completed reporting period.
The first;DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of
these, and all other reports required herein, shall be submitted to the following address:
NC DENR / Division of Water Quality / Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I
of this permit and based on the manufacturer's pump curves shall not'be subject to this requirement.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to' the EMC regulations (published pursuant to
NCGS 143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to
Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act (as Amended), and 40 CFR 136; or in
the case of sludge use or disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum
detection and reporting levels that are below the permit discharge requirements and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure. If no approved methods are
deternuned capable of achieving minimum detection and reporting levels below permit discharge requirements,
then the most sensitive (method with the lowest possible detection and reporting level) approved method must
be used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by
a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or
by both. If a conviction of a person is for a violation committed after a first conviction of such person under this
paragraph, punishment is a fine of not more than $20,000 per day of violation, or'by imprisonment of not more
than 4 years, or both [40 CFR 122.411.
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge
use and disposal activities, which shall be,retained for a period of at least five years (or longer as required by 40
CFR 503), the Permittee shall retain records of all monitoring information, including
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record
the following information [40 CFR 122.411:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses
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e.' The analytical techniques or methods used; and
f The results of such analyses.
8. Inspection and Entry
The Pernttee shall allow the Director, or an authorized representative (including an authorized contractor acting
as a representative of the Director), upon the presentation of credentials and other documents as may be required
by law, to;
a. Enter upon the Permittee's premises where a regulated facility or activity is located or conducted, or where
records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this
permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the Clean Water Act, any substances or parameters at any location [40 CFR 122.41 (i)].
Section E ' Reporting Requirements
1. Change in Discharge
All'discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge
of any ;pollutant identified in this permit more frequently than or at a level in excess of that authorized shall
constitute a violation of the permit.
2. Planned Changes
The Pernttee shall give notice to the Director as soon as possible of any planned physical alterations or
additions to the permitted facility [40 CFR 122.41 0)]. Notice is required only when:
a. The alteration or ' addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42 (a) (i).
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices,
and such alternation, addition or change may justify the application of permit conditions that are different
from or absent in the existing permit, including notification of additional use or disposal sites not reported
during the permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to'the Director of any planned changes to the permitted facility or other
activities' that might result in noncompliance with the permit [40 CFR 122.410) (2)].
4. Transfers
This permit is not transferable to any person except after notice to the Director. The Director may require
modification or revocation and reissuance of the permit to document the change of ownership. Any such action
may incorporate other requirements as may be necessary under the Clean Water Act [40 CFR 122.410) (3)].
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.410) (4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II. D. 2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation and reporting of the data submitted on the DMR
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6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written
submission shall contain a description of the noncompliance, and its cause; the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance [40 CFR 122.410) (6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported -under Part II. E. 5 and 6. of this permit at
the time monitoring reports are submitted. The reports shall contain the information listed in Part II. E. 6. of
this permit [40 CFR 122.41 p) (7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or
submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit
such facts or information [40 CFR 122.410) (8)]. '
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the
Division as soon as possible, but in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any' other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to receiving
waters without treatment of all or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division of Water Quality. As required by the -Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may result in the imposition of _criminal penalties as
provided for in NCGS 143-215.1(b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit, including
monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of
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not more than $25,000 per violation, or by imprisonment for not more than two years per violation, or by both
[40 CFR 122.41).
12. Annual Performance Reports
Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.1C).
The report shall summarize the performance of the collection or treatment system, as well as the extent to which
the facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality.
The report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon
which,annual period is used for evaluation.
PART III
OTHER REQUIREMENTS
Section A: Construction
The Permittee shall not commence construction of wastewater treatment facilities, nor add to the planes treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless the Division has issued an
Authorization to Construct (AtC) permit. Issuance of an AtC will not occur until Final Plans and Specifications for
the proposed construction have been submitted by the Permittee and approved by the Division.
Section B.' Groundwater Monitoring
The Permittee shall, upon written notice from the Director of the Division of Water Quality, conduct groundwater
monitoring as may be required to determine the compliance of this NPDES permitted facility with the current
groundwater standards.
Section C Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent
basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
0)'. One hundred micrograms per liter 000 µg/L);
(2) , Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms
per liter (500 µg/L) for 2.4-dinitrophenol and for 2-methyl-4.6-dinitrophenol; and one milligram per liter
0 mg/L) for antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine "or
'infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following "notification levels";
(1) Five hundred micrograms per liter (500 µg/L);
(2y One milligram per liter 0 mg/L) for antimony; —'
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Evaluation of Wastewater Discharge Alternatives
The Permittee shall evaluate all wastewater disposal alternatives and pursue the most environmentally sound
alternative of the reasonably cost effective alternatives. If the facility is in substantial non-compliance with the terms
and conditions of the NPDES permit or governing rules, regulations or laws, the Permittee shall submit a report in
such form and detail as required by the Division evaluating these alternatives and a plan of action within 60 days of
notification by the Division.
Section E., Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system
covered by this permit. The Division may require specific measures during deactivation of the system to prevent
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adverse impacts to waters of the State: This permit cannot be rescinded while any activities requiring this permit
continue at the permitted facility.
PART IV
SPECIAL CONDITIONS FOR MUNCIPAL FACILITIES
Section A. Publicly Owned Treatment Works (POTWsI
All POTWs must provide adequate notice to the Director of the following-
1 - Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to
section 301 or 306 of CWA if it were directly discharging those pollutants; and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger
as influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of
effluent introduced into the POTW, and (2) any anticipated impact of the change on the quantity or quality
of effluent to be discharged from the POTW.
Section B. Municipal Control of Pollutants from Industrial Users.
Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from
industries using the municipal system may be present in the Permittee's discharge. At such time as
sufficient information becomes available to establish limitations for such pollutants, this permit may be
revised to specify effluent limitations for any or all of such other pollutants in accordance with best
practicable technology or water quality standards.
2. Under no - circumstances shall the Permittee allow introduction of the following wastes in the waste
treatment system:
a. Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of _less than 140 degrees Fahrenheit or 60 degrees
Centigrade using the test methods specified in 40 CFR 261.21;
b. Pollutants which will cause corrosive structural damage to the POTW, but in no case Discharges
with pH lower than 5.0, unless the works is specifically designed to accommodate such Discharges;
C. Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW
resulting in Interference;
d. ' Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge, at, 'a flow
rate and/or pollutant concentration which will cause Interference with the POTW;
e, Heat in amounts which will inhibit biological activity in the POTW resulting in Interference; but in
no case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C
(104°F) unless the Division, upon request of the POTW, approves alternate temperature limits;
f, Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will
cause interference or pass through;
g. Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a
quantity that may cause acute worker health and safety problems;
h. Any trucked or hauled pollutants, except at discharge points designated by the POTW.
3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the
Permittee to supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to
ensure compliance by the Permittee with all applicable effluent limitations. Such actions by the Permittee
may be necessary regarding some or all of the industries discharging to the municipal system.
4. The Permittee shall require any industrial discharges sending influent to the permitted system to meet
Federal Pretreatment Standards promulgated in response to Section 307(b) of the Act. Prior to accepting
wastewater from any significant industrial user, the Permittee shall either develop and submit to the
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Division a Pretreatment Program for approval per 15A NCAC 2H .0907(a) or modify an existing
Pretreatment Program per 15A NCAC 2H .0907(b).
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved
POTW Pretreatment Program or to include a compliance schedule for the development of a POTW
Pretreatment Program as required under Section 402(b)(8) of the Clean Water Act and implementing
regulations or by the requirements of the approved State pretreatment program, as appropriate.
Section C.' Pretreatment.Programs
Under'authority of sections 307(b) and (c) and 402(b)(8) of the Clean Water Act and implementing regulations 40
CFR Part 403, North Carolina General Statute 143-215.3 (14) and implementing regulations 15A NCAC 2H
.0900, and in accordance with the approved pretreatment program,. all provisions and regulations contained and
referenced in the Pretreatment Program Submittal are an enforceable part of this permit.
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the Clean
Water Act, the Federal Pretreatment Regulations 40 CFR Part 403, the State Pretreatment Regulations 15A
NCAC:, 2H .0900, and the legal authorities, policies, procedures, and financial provisions contained in its
pretreatment program submission and Division approved modifications there of. Such operation shall include
but is hbt limited to the implementation of the following conditions and requirements:
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program.
2. Industrial Waste Survey (IWS)
The Permittee shall update its Industrial Waste Survey (IWS) to include all users of the sewer collection
system at least once every five years.
3. Monitoring Plan
The Permittee shall implement a Division approved Monitoring Plan for the collection of facility specific
data to be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of
specific pretreatment local limits. Effluent data from the Plan shall be reported on 'the DMRs (as required
by Part II, Section D, and Section E.5.).
4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a Headworks Analysis (HWA) at least once every five
years, and as required by the Division. Within 180 days of the effective date of this permit (or any
subsequent permit modification) the Permittee shall submit to the Division a written technical evaluation
of,the need to revise local limits (ie., an updated HWA or documentation of why one is not needed) [40
CFR 122.42]. The Pernittee shall develop, in accordance with 40 CFR 403.5(c) and 15A NCAC 2H -.0909,
Specific Local Limits to implement the prohibitions listed in 40 CFR 403.5(a) and (b) and 15A NCAC 2H
.0909.
5. Industrial User Pretreatment Permits (11 & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all significant industrial users, permits for
operation of pretreatment equipment and discharge to the Permittee's treatment works. These permits
shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control
technologies to assure that their wastewater discharge will meet all applicable pretreatment standards and
requirements. The Permittee shall maintain a current Allocation Table (AT) which summarizes the results
of the Headworks Analysis (HWA) and the limits from all Industrial User Pretreatment Permits (IUP).
Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA.
Version 6✓20/2003

NPDES Permit Requirements
Page 15 of 16
6. Authorization to Construct (A to C)
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable
industrial users for the construction or modification of any pretreatment facility. Prior to the issuance of
an AtC, the proposed pretreatment facility and treatment process must be evaluated for its capacity to
comply with all Industrial User Pretreatment Permit (IUP) limitations.
7. POTW Inspection & Monitoring of their SIUs
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by industrial
users, compliance with applicable pretreatment standards. The Permittee must:
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year; and
b. Sample all Significant Industrial Users (SIUs) at least twice per calendar year for all permit -
limited pollutants, once during the period from January 1 through June 30 and once during the
period from July 1 through December 31, except for organic compounds which shall be sampled
once per calendar year;
8. SIU Self Monitoring and Reporting
The Permittee shall require all industrial users to comply with the applicable monitoring and reporting
requirements outlined in the Division approved pretreatment program, the industry's pretreatment permit,
or in 15A NCAC 2H .0908.
9. Enforcement Response Plan (ERP,�
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the Clean Water Act (40 CFR 405 et. seq.), prohibitive
discharge standards as set forth in 40 CFR 403.5 and 15A NCAC 2H .0909, and specific local limitations.
All enforcement actions shall be consistent with the Enforcement Response Plan (ERP) approved by the
Division.
10. Pretreatment Annual Reports Y,PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 2H .0908. In lieu of submitting
annual reports, Modified Pretreatment Programs developed under 15A NCAC 2H .0904 (b) may be
required to meet with Division personnel periodically to discuss enforcement of pretreatment requirements
and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual
Report (PAR) describing its pretreatment activities over the previous twelve months to the Division at the
following address:
NC DENR / DWQ / Pretreatment Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
These reports shall be submitted according to a schedule established by the Director and shall contain the
following
a.) Narrative
A brief discussion of reasons for, status of, and actions taken for all Significant Industrial
Users (SIUs) in Significant Non -Compliance (SNC);
b.) Pretreatment Program Summ= XPS)
A pretreatment program summary (PPS) on specific forms approved by the Division;
c.) Significant Non -Compliance Report (SNCR)
The nature of the violations and the actions taken or proposed to correct the violations on
specific forms approved by. the Division;
d.) Industrial Data Summary Forms (IDSF)
Version 612012003

NPDES Permit Requirements
Page 16of16
Monitoring data from samples collected by both the POTW and the Significant Industrial
User (SIU). These analytical results must be reported on Industrial Data Summary Forms
(IDSF) or other specific format approved by the Division;
e.) Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules,
public notice of SIUs in SNC, and any other information, upon request, which in the
opinion of the Director is needed to determine compliance with the pretreatment
implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Significant Industrial Users (SIUs) that were in Significant
Non -Compliance (SNC) as defined in the Permittee's Division approved Sewer Use Ordinance with
applicable pretreatment requirements and standards during the previous twelve month period. This list
shall be published within four months of the applicable twelve-month period.
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along
with support information including general records, water quality records, and records of industrial impact
on the POTW.
13. Funding and Financial Report
The Permittee shall maintain adequate funding and staffing levels to accomplish the objectives of its
approved pretreatment program.
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits
modifications, POTW monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan
modifications, shall be considered a permit modification and shall be governed by 15 NCAC 2'H .0114 and
15A NCAC 2H .0907..
Version 612012003

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Charles Wakild, P. E.
Director
June 22, 2012
MEMORANDUM
TO: Aquifer Protection Section Staff
Interested Parties
FROM: Ted L. Bush, Jr., Deputy Dir±mitted
Division of Water Quality
SUBJECT: Guidelines for the Closure oWastewater Ponds and Lagoons
Dee Freeman
Secretary
Purpose
The purpose of these guidelines is to provide a course of action for the closure of permitted Non -Discharge
wastewater treatment ponds, storage ponds, or lagoons. According to G.S. 143-215.1, construction and operation
of any sewer system, treatment works or disposal system within the state of North Carolina requires a permit. 15A
NCAC 2T .01050) requires that waste treatment systems (or parts thereof, such as lagoons, storage ponds, etc.)
authorized by a permit must be properly closed before that permit (or parts thereof) can become inactive. These
guidelines provide clarification as to what "properly closed" entails.
While each structure must be considered for its unique circumstances, the Aquifer Protection Section (APS) has
outlined general procedures (attached) to be used for closure of wastewater treatment ponds and lagoons permitted
by the Section. These guidelines are not intended to address lagoons used for animal waste and their associated
facilities, or ponds used for the storage of coal combustion by-products. However, it is the intent of APS to require
similar close out procedures for comparable scenarios in coordination with other permitting agencies such as the
Surface Water Protection, or other interested parties. These guidelines supersede Guidelines for the Closure of
Treatment Ponds and Lagoons implemented August 18, 2003.
Closure Approval
The closure of a Non -Discharge permitted wastewater treatment or storage pond or lagoon should begin with
notification by the permittee to the APS. This should include a request to close a specific permitted pond or lagoon,
and an indication whether the permit should be modified or rescinded. APS will make available the attached
closure checklist/ guidelines to the permittee, who should propose a closure plan based on the attached guidelines.
This closure plan should generally include or describe the following (see next page):
1617 Mail Service Center, Raleigh. North Carolina 27699.1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.nmaterquality.ora
An Equal Opportunity 1 Affirmative Action Employer
Nne
orthCarolina
Naturally

i'
Guidelines for the Closure of Permitted Wastewater Treatment Storage Ponds and Lagoons
• Checklist with chosen options and requirements indicated (Attachment A, page A-1)
• Historical use of impoundment (include all waste streams) and current status
• Future plan for site
• Disposal options for wastewater
• Disposal options for sludge
• Sludge disposal location(s)
• Sampling plan for wastewater and/or sludge
Once the permittee submits their closure plan, a preliminary inspecfion will be conducted and an inspection report
with additional closure instructions (if needed) will be presented to the permittee. The permittee will then submit a
final closure report documenting their closure procedure. The final closure report may include the following:
• Sampling results
• Volume of sludge disposed and location
• Companies/Contractors involved
• Final Certifications
The Regional Office will conduct a final inspection and present the results of that inspection to the permittee, along
with their recommendation to the APS Central Office for approval or disapproval of a permit modification or
rescission.
Applicable Regulations
Regulations that may be applicable to the abandonment of Non -Discharge permitted ponds and lagoons are listed
below. These guidelines do not go into the detailed requirements of the regulation listed. However, each bullet
swnmarizes.how the regulation may be applicable to the action requested.
• Title 15A NCAC 2L, Classifications and Water Quality Standards Applicable To The Groundwaters of
North Carolina. This regulation requires that groundwaters must be protected to a level of quality at least
as high as that required under standards established in Section .0202 of that Rule.
• Title. I 5A NCAC 2T, Waste Not Discharged to Surface Waters. This rule establishes requirements that are
protective of surface water and groundwater standards for systems that treat, store, transport, and dispose
of residuals and do not discharge waste to surface waters.
Other pertinent standards and regulations may be found in the Department of Environmental and Natural Resources
(DENR) Division of Land Resources (DLR) regulations pertaining to Sedimentation and Erosion Control and Dam
Safety, the DENR Division of Waste Management (DWM) regulations pertaining to the disposal of wastes and
sludge, and the Department of Transportation (DOT) regulations pertaining to transportation of materials on public
highways.
cc: Surface'Water Protection (Matt Matthews)
Attachments
A. Checklist and Instruction Items
B. Flow Charts
Page 2

ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS
Checklist and Instruction Items
The purpose of the following checklist and instruction items is to aid in the development of a closure plan for
a permitted Non -Discharge wastewater pond or lagoon to be submitted to the appropriate APS Regional
office for approval.
The following checklist allows the applicant to identify the type of lagoon to be closed, and the preferred closure
and disposal options. The selected options include references to, instruction items (e.g. Item A) found on
subsequent pages of this attachment. The instruction items describe what steps are expected to be complete prior to
approval of the closure plan, *including expected sampling and monitoring, and final certifications of complete
closure. Note that the following steps are not all inclusive, as each site is unique and may have varying site
conditions, In addition, flowcharts (Attachment B) have been provided as an alternate to,the instructional Items A-
H. These -charts contain the same information, but give a visual representation of the closure process. For
questions, contact the approving APS Regional Supervisor. Please check all items below that apply and submit a
completed copy with the lagoon closure plan.
E. Type of Pond or Lagoon System
a. Primary and Secondary Biological Wastewater Lagoon Systems (examples: food processing treatment
lagoons, municipal treatment systems without pretreatment programs, neighborhood treatment systems).
b. Primary and Secondary Industrial Wastewater Lagoon Systems(examples: non-food type industrial
treatment systems, municipal treatment systems with pretreatment program).
c.,Tertiary Wastewater Pond Systems ( examples: wastewater biological treatment systems with tertiary
treatment to include infiltration disposal pond systems, effluent polishing pond systems).
II. Closure Options — Structure
a. Conversion to Non -Wastewater Pond — Change of Use (Item B)
b. Complete or partial removal of structure (Items G)
c. Site Reclamation (Item F and H)
I11. Final Liquid and Solid Content Disposal Options
a. Wastewater Disposal to Onsite Permitted Field (Item A)
b. Wastewater Disposal through Pump and Haul (Item A)
C. Sludge Disposal to Permitted Site (Items C and D)
d. Sludge Left in Place (Items C and E)
IV. Sampling and Monitoring Requirements
a. Wastewater Sampling Required (Items A and B)
b. Soil and Sludge Sampling Required (Items C and F)
c. Groundwater Monitoring Required (Item G)
V. Final Certification Required for Closure Activities, as required in Item I.
a. Structural Deconstruction (Professional Engineer or Hydrogeologist)
b. Wastewater Disposal (Facility ORC)
c. Sludge Disposal (ORC / Licensed Sludge Land Application Contractor)
d. Other (Explain: )
A-1
Attachment A ;. June 22, 2012

ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS
Item A. Wastewater Sampling, Analysis, and Disposal
1.. Pond samples require a composite sampling technique. Samples should be composited from several
locations. An ad� equate number of representative and composite samples should be taken and developed
respectively.
2. For permitted disposal sites, sample and analyze wastewater in accordance with permit conditions. In the
absence of permit specified monitoring, sample for the following parameters:
a. Fecal coliform bacteria, chlorine residuals (if used as disinfectant), total nitrogen, BOD5, TSS, pH.
b. Other parameters may be required based on waste streams, as directed by the APS Regional
Supervisor.
3. All wastewater samples must be analyzed by a DWQ-certified laboratory.
4. Once the wastewater is sampled, the pond/lagoon can be dewatered to a permitted disposal site (uniform
application of wastewater) or through a pump and haul permit.
5. Remove or plug all inflow and outflow piping, etc to the pond/lagoon
Item B. Conversion to Non -Wastewater Pond (Tertiary Treatment Ponds Only)
6. Determine pond liquid volume (if water accumulates after complete disposal per Item A, Wastewater
Sampling, Analysis, and Disposal).
7. If some sludge remains, sludge can be left in place, in accordance with Item E#23 below. Otherwise,
remove all residuals and dispose of properly per Item D, Sludge and Soil Disposal.
8. Disinfect and/or treat pond to meet Item 13#11 requirements below.
9. Sample pond (see Item A, Wastewater Sampling, Analysis, and Disposal)
10. ;No pond discharge is allowed to surface water without 1 for approval from an appropriate Surface Water
,(Section Regional Office. Note that pond discharge to class SA waters is not allowable.
11. All discharges must meet water quality standards applicable to receiving stream classification or per limits
provided by DWQ when water quality stream standards for monitored parameters are not defined.
Item C. Soil and Sludge Analysis
12. All soil and sludge samples require a composite sampling technique. An adequate number of
representative and composite samples should be taken and developed respectively. Thickness of sludge or
soil and surface acreage should be considered. Example: one composite sample per acre foot.
13. All soil and sludge samples must be analyzed by a DWQ-certified laboratory.
14. For biological wastewater lagoons systems and tertiary wastewater pond systems, soil or sludge shall be
sampled for: "
a. Pathogen and Vector Attraction Reductions. Testing should be done per 15A NCAC 02T .l 100. If
project concerns only a tertiary pond, and pond sediments/sludge meets CIass A pathogen
reduction requirements (maximum of 1000 fecal coliform bacteria colonies per gram of total
solids), additional characterization for pH, metals, nutrients, and solids as stated in 14.b and 14.c
(below) may not be required, as determined on a case by case basis.
b. Arsenic, cadmium, chromium, copper, lead, mercury, molybdenum, nickel, selenium, zinc, TKN,
ammonia nitrogen, nitrate/nitrite, nitrogen, phosphorus, sodium, calcium, magnesium (mg/kg dry
wt basis), percent total solids and pH.
c. Other parameters may be required based on waste streams, as directed by the APS Regional
Supervisor.
A-2
Attachment A June 22, 2012

ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS
15. For industrial wastewater lagoon systems, this should be the same as biological wastewater lagoon system
sampling plus site -specific parameters and hazardous characterization to include, but not limited to, TCLP,
ignitability, corrosivity and reactivity.
16. If the sludge or soil samples are:
a. Required to be analyzed for hazardous characteristics and results exceed hazardous characteristics
regulatory Iimits, the material needs to be removed and reported to and managed in accordance
with the Hazardous Waste Section in the Division of Waste Management.
b. Not required to be analyzed for hazardous characteristics or results do not exceed the hazardous
characteristics regulatory limits, the soil can be left in place if the following conditions are met:
i. Total concentrations of contaminants in soil .do not exceed protection of groundwater soil
concentrations for North Carolina based on 2L standards, as calculated using theTransport
Model for Calculation of Soil -to -Groundwater Concentrations from the USEPA 1996 Soil
Screening Guidance document. (The EPA Transport model can be found in the "Soil
Remediation Goals Table" at hitp://Wrtal.ncdenr.or web/wm/sf/ihs/ihs ug ide or the "2L,
MCL, and Soil Screening Levels Table" at
http://portal.ncdenr.orglweb/wm/hw/technical/ uidance.)
ii. Total concentrations of contaminants in the soil exceed protection of groundwater soil
concentrations for North Carolina, but results do not exceed naturally -occurring
background concentrations,
iii. A more stringent soil clean-up level is not necessary due to site specific conditions as
determined by the Division.
For sludge left in place, see Item E, Sludge Left in Place. For sludge disposal, see Item D, Sludge
and Soil Disposal.
c. Not required to be analyzed for hazardous characteristics or results do not exceed hazardous
characteristics regulatory limits, but total concentration results exceed corresponding protection of
groundwater soil concentrations for North Carolina as calculated using the Transport Model from
the USEPA 1996 Soil Screening Guidance document described in 16(b)(i), soil and sludge must be
disposed of according to Item D, Sludge and Soil Disposal. For soils that exceed protection of
groundwater levels, Item G, Groundwater Post Closure Monitoring, must also be considered.
17. For ponds or lagoon bottoms that intercept groundwater, Regional Offices will determine what type of
sampling is required for the remaining contents on a case by case basis.
Item D. Sludee and Soil Disposal
18. Measure surface area and depth of sludge and soil (if required) to determine disposal volume
19. Sample sludge and soil (if required) for permitted disposal option including pathogen and vector attraction
reduction verification (see Item C, Soil and Sludge Analysis)
20. If a tertiary pond and sludge/sediments meet Class A pathogen and vector attraction reduction
requirements, sludge/sediments can be land applied uniformly on site without sludge permitting action
(additional sludge or soil characterization may not be required, as determined on a case by case basis).
21. If sludge or soil does not meet Class A pathogen and vector attraction reduction requirements,
sludge/sediments may require a permit modification to land apply.
22. Pathogen and vector attraction reduction testing will not be required if sludge or soil is taken to a permitted
compost or another treatment facility for further stabilization.
A-3
Attachment A June 22, 2012

ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS
Item E. Sludize Left in Place
23. For closure purposes, the Division of Water Quality considers it practical to remove sludge content from
structures. The Division will evaluate the applicability of leaving any remaining volume of sludge content
in the structure on a case by case basis. Sufficient technical justification shall be provided to support such
recommendation.
Item F. Liner Demolition/Disposal
24. If a synthetic liner is present, remove synthetic liner, scarify/rip/disk underlying material in cases where
there is no potential benefit for reuse of the structure based on projected future site use.
a. If there are no historical problems with the lagoon (documented seepage, etc.) and the liner is intact
after dewatering with no visible indications of seepage, soil sampling may still. be required on a
case -by -case basis.
b. If liner and/or lagoon issues are documented, the soil material under the synthetic liner should be
sampled according to Item C, Soil and Sludge Analysis.
25. If clay liner is present, scarify/rip/disk and/or remove and reuse as cap if filling. If the liner is natural clay,
sampling may be required on a case by case basis if the following conditions are not met:
a. Based on existing groundwater monitoring data, no groundwater violations are present,
b. Domestic wastewater systems only,
c. Surficial layer of earthen material (top 6" — 12") removed , and
d. All sludge removed and the remaining material is only soil and not co -mingled soil/sludge.
26. If the clay liner does not -meet the conditions in #25 above, the clay liner should be sampled according to
Item C, Soil and Sludge Analysis.
27. If a pond or lagoon does not have a liner, the underlying soil should be sampled according to Item C, Soil
and Sludge Analysis.
Item G. Groundwater Post Closure Monitoring
28. For facilities with no historic groundwater monitoring, monitoring may be required based on post closure
soil sample results. Contact Regional Office for directions. If groundwater monitoring is not required,
permittee can petition the Division for rescission once the site is reclaimed.
29. For ponds or lagoons with historic groundwater monitoring and no groundwater violations were detected,
no further groundwater monitoring will be required, as recommended by the Regional Office based on
existing data.
30. For ponds or lagoons with historic groundwater monitoring and/or ISA NCAC 2L-standards were
exceeded, the following actions would be required: °
a. Maintain permit with limited actions as recommended by the Regional Office (e.g. annual
groundwater monitoring and reporting).
b. Continue groundwater monitoring as permitted for a minimum of three sampling events.
i. If there are no further groundwater exceedances detected or exceedances show a trend of
lowering toward groundwater standards, the permittee could petition the Division for
permit rescission.
ii. If groundwater exceedances continue at the same level, continued monitoring and or site
evaluation would be required at the Regional Office Supervisor's discretion.
c. in lieu of groundwater monitoring, the Permittee may provide predictive calculations, acceptable to
the Director, to demonstrate groundwater standards can be met at the property boundary.
A-4
Attachment A June 22, 2012

ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS
Item H. ! Berms/Lagoon Walls and Site Reclamation*
31. In cases where retention of municipal structures provides no value based on projected future site use, it is
recommended that minimal demolition be performed to breach or remove sidewalls (dependent on the size)
when the liner is demolished. Minimal demolition may be considered feasible in cases where retention of
the structure or a portion thereof poses minimal risks based on conditions such as low population densities
of surrounding areas, low hazard environment, low probability of encroaching development, etc.
32. For privately owned and higher risk municipal structures, more extensive structure demolition is
recommended to include, but not be limited to, removal of berms/dike walls and general grading of project
site.
33., If structure is completely constructed at or below grade, fill with clean material (partial or complete,
depending on size) and/or grade site to minimize any hazards posed by existing conditions.
34. If structure is finished in the groundwater table, see Item C # 17.
35. Stabilize the site with vegetation. Establishment of trees, grasses, and other viable cover crops should be
considered to assist site stabilization and with removing any remaining nutrients.
*Recognize the added value of planned reclamation efforts. Reclamation activities incorporating created artificial
wetland systems, planted trees, and other pro -active actions viewed as either mitigation efforts or secondary
environmental protection measures may assist with enabling the closure project to qualify for recognition and
benefit from other environmental programs, such as those offered through conservation easements.
Item I. Final Certifications
36. For deconstruction including berm removal, berm breaching, or liner destruction, submit a letter certified
by the overseeing professional engineer that action was taken according to the approved plan, as well as all
local and state regulations.
37. For wastewater disposal, submit a copy of the monitoring report that documents lagoon wastewater disposal
activities, certified by the facility ORC.
38. For ;sludge disposal, submit a copy of the records documenting lagoon sludge disposal, certified by the
licensed sludge land application contractor if land applied. If sludge was disposed of in a landfill, records
from the receiving facility shall be provided.
39. Sampling results from any post -closure sampling conducted at the facility to document proper removal of
sludge in accordance with the approved closure plan shall be submitted.
40. Photos of closure activities documenting conditions prior to initiating closure, closure activities, and post -
closure conditions are recommended, but not required.
41. Other.
A-5
Attachment A ' i; June 22, 2012

ATTACHMENT B
The following flowcharts are a visual alternate to the information provided in Instructional
Items A-H in Attachment A. The checklist provided in Attachment A must still be
completed, whether the Instruction Items or flowcharts are used. Final certification
requirements are only found in Item I in Attachment A.

Attachment B — Closure of Permitted Wastewater Ponds and Lagoons
Flow Chart 1 — Wastewater Sampling and Disposal'
START HERE
Does the site Sample lagoon wastewater in
have permit YES
specific accordance with the permit
monitoring? conditions.
NO
Using an adequate number of
representative composite
samples, test for fecal coliform
bacteria, chlorine residuals (if
used as disinfectant), total
nitrogen, BOD5, TSS, and pH.
Other parameters may be
required by Regional Office
based on waste streams.
Samples should be
composited from several
locations. All samples must
be analyzed by a DWQ-
certified laboratory_
Dewater pond/lagoon to
permitted disposal site or
through a pump and haul permit
issued by DWQ.
Remove or plug all inflow and
outflow piping.
If water accumulates after disposal,
determine pond liquid volume and
disinfect/treat pond (if necessary) to meet
If you have a
water quality standards applicable to
tertiary pond,
YES receiving stream classification or per limits
do you want to
provided by DWQ when water quality
convert to non-
stream standards for monitored
wastewater?
parameters are not defined. Sample as in
previous step. END If sludge remains,
proceed to Flow Chart 2 — Sludge
NO
Analysis and Disposal.
Does sludge YES Proceed to Flow Chart 2 — Sludge Analysis
remain? 'I and Disposal.
NO
Proceed to Flow Chart 3 — Liner
Demolition and Disposal.
'No pond discharge is allowed to surface water without prior approval from an appropriate Surface Water Section Regional Office. All discharges
must meet water quality standards applicable to receiving stream classification or per limits provided by the Division of Water Quality when water
quality standards for monitored parameters are not defined. Pond discharges to class SA waters is NOT allowable.
Attachment B1 June 22, 2012

Attachment B - Closure of Permitted Wastewater Ponds and Lagoons
Flow Chart 2 - Sludge Analysis and Disposal
CONTINUED FROM FLOW CHART 1 —WASTEWATER SAMPLING, ANALYSIS, AND DISPOSAL
What type of wastewater lagoon system is present?
Biological, Industrial' Tertiary,
Using an adequate number of
representative and composite
samples, test for:
1, Pathogen and Vector
Attraction Reduction per
15A NCAC 02T .11002•3
2. Arsenic, cadmium,
chromium, copper, lead,
mercury• molybdenum,
nickel, selenium, zinc,
TKN, ammonia nitrogen,
nitrate/nitrite, nitrogen,
phosphorous, sodium,
calcium, and magnesium in
mg/kg dry weight basis,
percent total solids, and
pH.3
Samples
required to be
tested for
hazardous
characteristics?
NO
Using an adequate number of
representative and composite
samples, test for:
1. Pathogen and Vector
Attraction Reduction per
15A NCAC 02T .11002.3
2. Arsenic, cadmium,
chromium, copper, lead,
mercury, molybdenum,
nickel, selenium, zinc,
TKN, ammonia nitrogen,
nitrate/nitrite, nitrogen,
phosphorous, sodium,
calcium, and magnesium
in mglkg dry weight basis,
percent total solids , and
pH.
3. Site -specific perameters.3
YES Test for TCLP, ignitability,
corrosivity, and reactivity.s
Using an adequate number of
representative composite samples,
[
test for Pathogen and Vector
i
Attraction Reduction per ISA
NCAC 02T .1 100Z3
t
[
t
r
Do samples
t
meet Class A
YES r
pathogen
J -
reduction
requirements?
i
[
[
[
NO
t
!
Test for arsenic, cadmium,
chromium, copper, lead, mercury,
molybdenum, nickel, selenium,
zinc, TKN, ammonia nitrogen,
nitrate/nitrite, nitrogen,
phosphorous, sodium, calcium,
and magnesium in mg/kg dry
weight basis, percent total solids,
and pH.'
Determine volume of sludge then
Do the results
excavate. Manage and report
exceed hazardous
YES material in accordance with
waste
Hazardous Waste Section guidelines.
characteristics?
Proceed to Flow Chan 3 —Liner
Oemolhion and Disposal,
NO
Do the results
exceed groundwater
May require permit modification
protection soil levels
to land apply,+
for NC as calculated YES
Contact DWQ Regional Office
using the Transport
for more information.
Model In the USEPA
Proceed to Flow Chart 3 —
1996 Sail Screening
Liner Demolition and Disposal.
Guidance document?
—1
1
NO 1
Sludge can be left in place or land
applied uniformly on site without
Do samples
DWQ permitting action!
meet Class A YES
If sludge is left in place, proceed to
pathogen
Flow Chart 5 — Groundwater Post
reduction
Closure Monitoring.
requirements?
If sludge Is land applied, proceed to
Flow Chart 3 — Liner Demolition
and Disposal.
NO May require permit modification to
land apply.
Contact DWQ Regional Office for
more Information.
Proceed to Flow Chart 3 — Liner
Demolition and Disposal.
} Forponds oriagoon bottoms that intercept groundwater, DWQ will determine what type of sampling is required for the remaining contents on a case by case basis.
3 Pathogen and vector attraction reduction testing will not be required if sludge is taken to a permitted compost or another treatment facility for further stabilization.
Samples to be analyzed by DWQ•cerfified laboratory.
4 For closure purposes, DWQ considers it practical to remove sludge content from structures. DWQ will evaluate the applicability of leaving any remaining volume of sludge on a case by case basis. Sufficient technical jusbffcation shall be provided to support such
recommendation.
Attachment B2 June 22, 2012

I
i .
Attachment B — Closure of Permitted Wastewater Ponds and Lagoons
Flow
I,
Chart 3 — Liner Demolition and Disposal'
CONTINUED FROM FLOW CHART 1 — WASTEWATER SAMPLING, ANALYSIS, AND DISPOSAL OR
FLOW CHART 2 — SLUDGE ANALYSIS AND DISPOSAL
?
What
type of
liner is
present?
er
i
Clay Lin:1
No Liner
Synthetic Liner
Remove liner,
Scarify/rip/ disk and/or
Soil sampling is
P 9
scariy/rip/ disk
remove and reuse as
required.
underlying material in
cap if filling.
Proceed to Flow
cases where there is no
Chart 4.
potential benefit for
reuse of the structure
based on projected
future site use.
Are all of the
following true?
a. Groundwater
sampling has been
documented and no
groundwater
violations are
NO Soil sampling is required. YES
Historical
present.
Proceed to Flow Chart 4 —
problems or
b. The system is
Soil Analysis and
damaged
domestic waste -
Disposal.
liner?
e water only.
c. The surficial layer of
earthen material
was removed.
NO
d. No residuals
remain.
Soil sampling may be required
on a case -by -case basis.
Proceed to Flow Chart 5 —
Groundwater Post Closure
Monitoring.
YES
I Proceed to Flow Chart 6 —
1 Site Reclamation.
' For closure purposes, the DWQ considers it practical to remove sludge content from structures. DWQ will evaluate the applicability of leaving any
remaining volume; of sludge content in the structure on a case -by -case basis. Sufficient technicaliustillcation shall be provided to support
recommendation.'
Attachment 83 l June 22, 2012

Attachment B — Closure of Permitted Wastewater Ponds and Lagoons
Flow Chart 4 — Soil Analysis and Disposal
CONTINUED FROM FLOW CHART 3 — LINER DEMOLITION AND DISPOSAL
What type of wastewater lagoon system is present?
Biological,
Using an adequate number of
representative and composite
samples, test for:
1, Pathogen and Vector
Attraction Reduction per
15A NCAC 02T .11002.3
2. Arsenic, cadmium,
chromium, copper, lead,
mercury, molybdenum,
nickel, selenium, zinc,
TKN, ammonia nitrogen,
retrate/nitrite, nitrogen,
phosphorous, sodium,
calcium, and magnesium in
mgfkg dry weight basis,
percent total solids, and
pH's
Samples
required to be
tested for
hazardous
characteristics?
NO
Industrial' I I Tertiary'
Using an adequate number of
Using an adequate number of
representative composite samples,
representative and composite
test for Pathogen and Vector
samples, test for:
Attraction Reduction per 15A
1. Pathogen and Vector
NCAC 02T .1100 2.3
Attraction Reduction per
15A NCAC 02T .11002a
2. Arsenic, cadmium,
chromium, copper, lead,
mercury, molybdenum,
Do samples
nickel, selenium, zinc,
meet Class A
TKN, ammonia nitrogen,
pathogen
nitrate/nitrite, nitrogen,
reduction
phosphorous, sodium,
requirements?
calcium, and magnesium
in mglkg dry weight basis,
percent total solids, and
NO
pH.
3. Site -specific parameters.
Test for arsenic, cadmium,
chromium, copper, lead, mercury,
molybdenum, nickel, selenium,
zinc, TKN, ammonia nitrogen,
nitrate/nitrite, nitrogen, '
phosphorous, sodium, calcium,
and magnesium in mglkg dry
weight basis, percent total solids.
and pH?
YES Test for TCLP, ignitability,
cortosivily, and readivity.3
c
Iiiiiiii
YES j
Determine volume of sail then
Do the results
excavate_ Manage and report
exceed hazardous
YES material in accordance with
waste
Hazardous Waste Section guidelines.
characteristics?
Proceed to Flow Chart 5 —
Groundwater Post Closure
Monitoring.
NO
Do the results
exceed groundwater
protection soil levels
Groundwater post closure
for NC as calculated
ES monitoring required.
Yusing
the Transport
Proceed to Flow Chart 5 —
Model in the USEPA
Groundwater Post Closure
1996 Soil Screening
Monitoring,
;uidance document?'
---- -- - ---
-----
---- ---- - -- - -
I
NO
1
I
I
.
1
1
. 1
e samples
meet Class A
YES
Soil can be left in place.
pathogen
Proceed to Flow Chart 5 —
reduction
Groundwater Post Closure
requirements?
Monitoring.
For ponds or lagoon bottoms that intercept groundwater, DWQ will determine what We of sampling Is required for the remaining contents on a case by case basis.
r Pathogen and vector attraction reduction testing will not be required if sludge is taken to a permitted compost or another treatment facility for further stabilization.
Samples to be analyzed by DWO-certirted laboratory.
If soil eoncentrefion results exceed groundwater protecdon levels but do not exceed naturally occurring soil background concentrations, then they are not considered an exceedance.
Attachment 194
NO[ May require permit modification to
land apply.
Contact DWQ Regional Office for
more information.
Proceed to Flow Chart 5—
Groundwater Post Closure
June 22, 2012

Attachment B — Closure of Permitted Wastewater Ponds and Lagoons
Flow Chart 6 — Groundwater Post Closure Monitoring
CONTINUED FROM
FLOW CHART 2 — SLUDGE ANALYSIS AND DISPOSAL,
FLOW CHART 3 — LINER DEMOLITION AND DISPOSAL, OR
FLOW CHART 4 — SOIL ANALYSIS AND DISPOSAL
Has there >NO Is groundwater NO
been historic monitoring Proceed to Flow Chart6 —
groundwater Site Reclamation.
monitoring? required?
YES
YES Contact DWQ Regional Office to
approve well locations before
installation.
Sampling of NO No further groundwater monitoring
wells indicate is required. Proceed to Flow
groundwater Chart 6—Site Reclamation.
violations?
YES
Maintain permit with limited actions.
Continue groundwater monitoring as
permitted for minimum of three
sampling events.
After minimum of
three sampling
events, are,
groundwater
violations detected
or exceedances
not showing a
lowering trend?
YESI
Continue monitoring on a schedule
set by DWQ Regional Office
Supervisor.
In lieu of groundwater monitoring, predictive calculations,
acceptable to the Director, can be submitted to demonstrate
groundwater standards can be met at the property
boundary. Proceed to Flow Chart 6 —Site Reclamation.
Proceed to Flow Chart 6 — Site
Reclamation.
k.
Attachment B5 June 22, 2012

Attachment B — Closure of Permitted Wastewater Ponds and Lagoons
Flow Chart 6 — Site Reclamation'
CONTINUED FROM FLOW CHART 3 — LINER DEMOLITION AND DISPOSAL OR
FLOW CHART 5 — GROUNDWATER POST CLOSURE MONITORING
Berms/Lagoon Wall52
YES Is the structure
privately owned
or high risk
municipal?
NO
Is the structure
completely
constructed at or
below grade?
NO
Is the structure
finished in the
groundwater
table?
YES
Contact DWQ Regional Office to
determine what type of sampling
will be required. Then, proceed
to appropriate Flow Chart.
Recommended more extensive structure demolition
(e.g. removal of berms/dike walls, general grading,
etc.). Stabilize the site with vegetation. END
YES Fill with clean material and/or
grade site. Stabilize the site
with vegetation. END
NO
u
Recognize the added value of planned reclamation efforts. Reclamation activities Incorporating created artificial wetland systems, planted trees, and other pro-
active actions viewed as either mitigation efforts or secondary environmental protection measures may assist with enabling the closure project to qualify for
recognition and benefrt from other environmental programs, such as those offered through conservation easements.
:In cases where retention of municipal structures provides no value based on projected future site use, it is recommended that minimal demolition be performed to
breach or remove s/dewails (dependent on the size) when the liner is demolished. Minimal demolition maybe considered feasible in cases where retention of the
structure or a portion thereof poses minimal risks based on conditions such as low population densities of surrounding areas, low hazard environment low
probability of encroaching development etc.
Attachment B6 Jane 22, 2012

Michael F. Easley, Governor,
WOliam -G..Ross Jr., Secretary
North Carolina Department of Enviroortient and Natural Resources
SURFACE WATER PROTECTION SECTION
January 11, 2008
W.. Perry fisher
I North;Pack Square
Suite 415
Asheville, NC 28801
Subject: Request for Temporary Flow Increase
Fletcher Warehousing
ng
NPDES Permit NC0000094
Henderson County
Dear Mr. Fisher:
Coicen H. Sullins, Director
Division otWalcr Quality
This Office is in''receilp t of you letter dated Decembet.21, 2007 in which a temporary
flow increase is. requested" for the subject facility. The Permittee. is requesting the -,flow increase
in.order too more efficientlycloseoutthe currenVwastewater treatment plant..'
After reviewing this request, this Office has determined that for a period of 180- days
from the date of this letter, the facility bas permission to dischargd 0.250 MGD. During this time
it is requested, that the, effluent be sampled using compositinog, methods with the following -
pollutalits'analyzed: BOD5, Total Suspended Solids, NW and with grab samples collected for
Fecal Colif6rin and Total. Residual- Chlorine. An accurate flow recording should also be
maintained. ' Once the facility no longer has a discharge, the Permittee should request that the
subject NPDES permit be rescinded.
Please be advised that this letter'does not excuse the permittee from complying with all
other. limits, terms, and conditions of thesubjectNPDES_ Permit.
If you have any questions. regarding this matter, please do hesitate to,:contAct-Keith
Haynes of the ARO DWQ staff, or me at 296-4500,
Sincerely,
Roger C. Edwards, Supervisor
Surface Water Protection Section
Cc: NPDES Unit"'
Flbwrequwtresponse rpoll )C, VU.27
North Carolina Division of Water Quality 2090 U:S. Hijbway 70 Swannanoa, NC 28778'Phone [phone], Customer Service
Internet h2o.enrstate,ncxs; FAX [phone]
An Equal OpportunitylAffmattive Aden Employer — 50% Recyclad/1 07. Past consumer Paper

F \NA� Michael F. Easley, Governor
COPY
G. Ross Jr., Secretary
f BFILE V o ery North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
�Division of Water Quality
SURFACE WATER PROTECTION SECTION
January 11, 2008
W. Perry Fisher
1 North Pack Square
Suite 415
Asheville, NC 28801
Subject: Request for Temporary Flow Increase
Fletcher Warehousing
NPDES Permit NC0000094
Henderson County
Dear Mr. Fisher:
This Office is in receipt .of you letter dated December 21, 2007 in which a temporary
flow increase is requested for the subject facility. The Permittee is requesting the flow increase
in order too more efficiently closeout the current wastewater treatment plant.
After reviewing this request, this Office has determined that for a period of 180 days
from the date of this letter, the facility has permission to discharge 0.250 MGD. During this time
it is requested that the effluent be sampled using compositing methods with the following
pollutants analyzed: BOD5, Total Suspended Solids, NH3 and with grab samples collected for
Fecal Coliform and Total Residual Chlorine. An accurate flow recording should also be
maintained. Once the facility no longer has a discharge, the Permittee should request that the
subject NPDES permit be rescinded.
Please be advised that this letter does not excuse the permittee from complying with all
other limits, terms, and conditions of the subject NPDES Permit.
If you have any questions regarding this matter, please do hesitate to contact Keith
Haynes of the ARO DWQ staff, or me at 296-4500.
Sincerely,
Roger C. Edwards, Supervisor
Surface Water Protection Section
Cc: NPDES Unit
Flowrequestresponse
NorthCarolina
Naturat/tl
North Carolina Division of Water Quality 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10%a Post Consumer Paper

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department o, environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Asheville Regional Office
SURFACE WATER PROTECTION p_ ...
April 5, 2007
Mr. Stan Littlejohn
Fletcher Warehousing Company
Post Office Box-4-rq— \ Be
Swa`nnanoa(, North Carolina 28778
SUBJECT: Compliance Evaluation Inspection
Fletcher Warehousing Company
Permit No: NC0000094
Henderson County
Dear Mr. Littlejohn:
Enclosed please find a copy of the Compliance Evaluation Inspection form from
the inspection conducted on April 3, 2007. Mr. Keith Haynes and I of the Asheville
Regional Office conducted the Compliance Evaluation Inspection. The facility was found
to not be in Compliance with permit NC0000094.
Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff have any questions, please call Mr. Keith Haynes at (828)
296-4500.
Sincerely,
Lar ost
vironmental Engineer
Enclosure
cc: NPDES Unit
Central Files
aiall il;
NorthCarolina
Alaturally
2090 U.S. Highway 70, Swannanoa, NC 28778 Telephone: [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 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 -•:I 2 I1 1 31 GOD 1) I11 12I n;;'0!Ei"3 117 18I-I 19I-I 20I
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --------------------------- Reserved ----------------------
67I 169 701 I 711 I 721 ci I 73 f I 174 751 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)
I a..r;'�.^hex. w-:...._...4,...,....n•: C;�crc�tici�-
Exit Time/Date
Permit Expiration Date
Rt 25
Fl.et.:.ne NC 28732
n1:1 . PM 071CA/0*3
0/'.1. 3 ;
Name(s) of Onsite Representative(s)Mtles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
eC: ()!•i E'! , I.''Q Box 44 i i•. u......u.-l.Cd t'; 18•,';i; No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance IS Sludge Handling Disposal
Facility Site Review
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
sDate
La:, .. I`'.Cosil. �(r' WQ'1/823...29 G"4y.. 100 t-.4fS18 3'._lelp
K,,' h gi.av_ cast <iY.t :9;?; ,'8_ J .:96 4500
Signature of Management Q%A Reviewer Agency/Office/Phone and Fax Numbers
%Date
'.g.0 Ci;;/,'ii2ti-?_9ri-4SOi;,' l S
;;;gc... .. ...,_�'vl� _....> y���.�•i
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type 1
3II11 12I :; a I17 18I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
This WWTP was built an high industrial load and now serves the domestic need of the office and warehouse.
The only time the system discharges is during rain events: Stormwater needs to be removed from this
system:
The permittee should consider connecting to the municiple sewer system or the replacement of the existing
system with a properly engineered system for the flow, The flow should not include storrnwater.
Page # 2

Permit: NC0000094 Owner - Facility: Fletcher Warehousing Company
Inspection Date: 04/03/2007 Inspection Type: Compliance Evaluation
perations . Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
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?
Comment: The grass has recently been mowed. There are 2 operational aerators in th
ebasins.
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
n
®
n
Is the facility as described in the permit?
■
n
n
Cl
# 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:
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
n
Are surface aerators and mixers operational?
■
n
n
n
Are the diffusers operational?
n
n
■
n
Is the foam the proper color for the treatment process?
■
n
n
n
Does the foam cover less than 25% of the basin's surface?
■
n
n
n
Is the DO level acceptable?
n
n
n
n
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
n
0
Comment: Aeration basins appear to be in very good condition and not over grown as
was observed during the last inspection.
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? ■ ❑ n ❑
Is flow meter calibrated annually? ❑ n
Is the flow meter operational? ® n n n
(If units are separated) Does the chart recorder match the flow meter? ® n ❑ n
Cornment: The meter appears to be operating properly, however it is dated 1997.
Please ensure the meter is calibrated annually.
Page # 3

MEMORANDUM
TO: GroundwaterRegional Supervisors
Permits & Compliance Unit
Operations Branch
FROM: Arthur Mouberry, P.E.
Chief, Groundwater Section
.SUBJECT: Guidelines for the Closure of Treatment Ponds and Lagoons
August 18, f
. )
Purpose: The purpose of these guidelines is to protect the quality of the groundwater resources
of the state while accomplishing the closure of a treatment pond or lagoon.
Backeround: Man-made treatment ponds and lagoon type structures are used to contain fluids
and semi -solids for a variety of reasons. As these ponds and lagoons become no longer
necessary, the structure needs to be abandoned in an environmentally friendly manner. The
Groundwater Section's major concern with the elimination of these structures is that
groundwater remains protected both during and after abandonment. Each structure must be
considered for its unique circumstances on a case -by -case basis.
Regulations relevant to the abandonment of ponds and lagoons for ground waters of the state
include the Classifications and Water Quality Standards found in Title 15A NCAC 2L. Other
pertinent standards and regulations may be found in the DENR Land Resources regulations
pertaining to Sedimentation and Erosion Control and Dam Safety, the DENR Waste
Management regulations pertaining to the disposal of wastes and sludge, and the NCDOT
regulations pertaining to transportation of materials on public highways. Lagoons for animal
waste are regulated under the federal NRCS Standards.
Recommended Procedure:
The major elements of pond and lagoon structures include the contents, the walls, the floor and
the liner, if one exists. Each element must be characterized for its quantity and material
properties in order to prepare a closure plan. Guidelines for the preparation of this plan are
described in the following steps:
1) Collect and assemble field information by characterizing the structural elements and
liquid contents, including bottom sludge in the impoundment. Sampling will be required
in most situations, and the types of sampling and analyses will depend on factors such as
what the lagoon was used for, its construction materials (earthen, concrete, natural or
synthetic liner), and size. The samples must be representative of the medium sampled,
and the rationale for the depths, locations and number of samples should be justified and
documented in preparation of being legally defensible. The sampling must be performed
Lagoon Closure final.doc Pagel of 3

under the direction of a qualified individual and analyzed by a DWQ Certified
Laboratory.
2) Prepare and submit a Closure Plan to the DWQ regional office at least 30 days prior to
commencing deconstruction activities. This should include as a minimum:
a. the quantity and characteristics (TCLP, nutrients, metals) of the materials for
disposal (contents, walls, floor and mel r), including the calculations used to
determine volumes,
b. an assessment of alternatives (actions, costs and timing) in sufficient detail to
select an optimum approach consistent with minimal groundwater impact,
c. a proposed method for removal/disposal, including the abandonment and salvage
of any physical equipment, and a timetable for the project,
d. site reclamation plan and section view of the treatment, storage and disposal
area(s),
e. vicinity map, and
f. location map to scale showing items such as the location of samplint pouf,
existing monitoring and supply wells (within 500 feet), depth to groundwater,
direction of groundwater flow, roads, structures, and rock outcrops. -
3) If the structure is to be retained for an ornamental pond, storage or any other function
other than for treatment, then the Closure Plan will need to demonstrate that the residuals
of treatment (e.g. physical connections, bottom sludge, coliforms, nutrients and metals)
conform to all appropriate surface water standards.
If the structure is to be abandoned in place (totally or partially), sampling of the
underlying native soil, whether it has a natural or synthetic liner, is re_ quired. If the
sampling determines that the soil is contaminated, , then the Closure Plan will need to
demonstrate, by modeling or numerical calculations, that leaving the contents and or
structure materials in place will not cause a contravention of the groundwater quality
standards in the groundwater beneath the structure. If the modeling does not demonstrate
this, than removal or treatment of the soils must be included as part of the Closure Plan.
If it were an earthen structure, the preferable approach would be to completely eliminate
the walls and incorporate the material in the existing site.
4) Any land disturbing activity associated with the closure activities that affect more than
one (1) acre of land -must have an erosion and sediment control plan approved by the
Land Quality Section of the Division of Land Resources. NC General Statute 113A-
57(4) requires this plan to be submitted at least thirty (30) days prior to beginning the
land -disturbing activity.
Closure Documentation:
Lagoon Closure final.doc Page 2 of 3

Upon completion of the closure, the owner should submit documentation to the DWQ regional
office with the following:
1) A description of all actions taken and dates relative to the abandonment.
2) Copies of all pertinent correspondence with private, local, state and/or federal agencies.
3) Ultimate disposal sites with weigh tickets or processing verifications, as appropriate.
4) Certification by a Professional Engineer (PE) or Professional Geologist (PG) if the pond or
lagoon:
a) is greater than five (5) acres in total area,
b) contains hazardous substances as defined by TCLP tests, or
c) involves a breaching of a dam, which could impose a safety hazard to persons or property
below it.
Lagoon Closure final.doc Page 3 of 3

r
GAD o 3( m° G a

Re: Sludge Waste Hauling
Subject: Re: Sludge Waste Hauling
From: Roy Davis <[e-mail]>
Date: TMue 20 kMay. T114:29:19 -0400
To: Henry Dyar <[e-mail]>, Roger Edwards <[e-mail]>,
"keith.haynes >> Keith Haynes" <[e-mail]>, Roy Davis <[e-mail]>,
Landon Davidson <[e-mail]>
Henry: Given that the owners of the Fletcher Warehousing Wastewater Treatment Plant
plan to take the plant out of service when the present NPDES permit expires
(November, 2010)°, it does not make sense to me to continue to dispose of sludge in a
system only to have to turn around and deal with that sludge in a couple of years.
Likewise, y��� n•eed,�t-o:rf�zn some other means to d spos'e of"all _waste aat-,YV 6ted sludgge
Furthermore con inued`use-fbk ' Ifat -purpose only makes more complicate`ic.7F3 etcher
Warehousing's problems when the time to close out the plant arrives. Roy Davis
Henry byar wrote:
Roy,
Goldie & Associates would like to haul sludge generated at the Pointe West
Wastewater Plant in Seneca, S.C. to the Cranston Wastewater Treatment Plant in
Fletcher, N.C.
C,-r`4nst7o-n h Carolina Department of Health and Environmental Control need a
�lett�er f acceptance from NCDENR before they will permit the sludge removal. If
you could help us with this or refer us to someone else we would appreciate it.
Thanks, Henry Dyar
Roy Davis - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Roy Davis <Roy.Davis(a.,ncmai..1.tiet>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
1 of 1 5/20/2008 2:29 PM

Annual Wastewater Treatment System Performance Report
for
Fletcher Warehousing Company WWTP
for the Operating Period
January thru December, 2007
Preface
On July 20 1999, the North Carolina General Assembly ratified House Bill 1160, the Clean
Water Act of 1999, which place significant new reporting requirements on those entities that
own or operate wastewater treatment and collection systems. Specific items included:
1. A Spill Response Plan
2. Sewer Collection System Operation & Maintenance Plan
3. Annual Performance Report
These new requirements became effective October 1, 1999.
This report is designed to meet the minimum requirements for the Annual Performance Report
established by the North Carolina Department of Environment and Natural Resources (DEHNR)
as set forth in their guidance document dated October 19, 1999.
This law was established to provide a mechanism for public oversight (and hopefully, to instill
public confidence) in owners and operators of wastewater treatment systems and in their efforts
to protect the waters of the state.

',�
I. General Information
Facility/System Name: Fletcher Warehousing Company WWTP
Henderson County = -
Responsible Entity: Fletcher Warehousing Company
Person(s) in Charge/Contact: Stan Littlejohn, Warehouse Manager
Robert Orr — Operator -in Responsible Charge (ORC)
Henry Dyar, Project Manager - Goldie & Associates
Applicable Permits: NPDES # NC0000094
Description of Treatment Process, Collection System, and Facilities Served:
Treatment Process — The treatment facility is a conventional "Activated Sludge" process
capable of treating 4.0 million gallons per day (MGD). The current NPDES Permit allows
for 0.010 MGD flow.
Collection System — The main collection system is a standard gravity design with 8-inch
diameter pipe and standard pre -cast manholes. The system has a Spill Response Plan and an
Operation and Maintenance Plan for the sewer collection system.
Facilities Served — The facility serves the warehousing operation with approximately 10
NOTE: This facility was originally constructed to serve Cranston Print Works, a textile print
and dye manufacturing entity. Cranston Print Works ceased operations and sold the facilities.
Fletcher Warehousing Company converted the manufacturing facility into a warehousing
facility. Fletcher Warehousing Company is keeping the WWTP facility in a state of
operational readiness to serve additional area wastewater needs should the need arise. The
facility is currently functioning much like an oxidation basin because of the very low flow and
is more than capable of treating the very low volume.
II. WWTP Performance
All operating parameters were in compliance with NPDES permit limits for 2007, except for the
following occurrence. In January 2007 there was a flow violation.
We take pride in our efforts to protect the local environment and the quality of waters in
our streams.

III. Collection System Performance
The collection system experienced no significant problems for the reporting period.
IV. Notification
A notice advising of the availability of this report will be sent to each user. A copy of this
report is available to interested persons in the offices of.
Fletcher Warehousing Company
PO Box 457
Swannanoa, NC 28778
or by contacting:
Henry Dyar
c/o Goldie & Associates
210 West North Second Street
Seneca, SC 29678
As required, three copies of this report are being provided to NCDEHNR.
V. Certification
I certify that under penalty of law that this report is complete and accurate to the best of
my knowledge.
Henry Dyar, Goldie & Associates Date
This report prepared by:
Henry Dyar
Goldie & Associates
210 West North Second Street
Seneca, SC 29678
Phone: [phone]
Fax: [phone]

12/21/2007 03:34 82850543 PERRY FISHER PA PAGE 02/02
PeYx-y F i slier, P.A. n ,IE C' E L. d [� (11,
1� U
oFc 2 1 zoo
December 21, 2007
Susan Nilson
DE..UNR
161.7 Mall Service Center
Raleigh, NC 27699-1617
RE: Permit Number 00094
Dear .Ms. Wilson:
I represent the above referenced permit holder. The
shutting down their waste water treatment lagoons. rA.§ par
WATER QUALITY SECTION
ASHEVILLE REC'0 ,,AL OFFIC
is in the process of
-may awy of-bac-i ound, this permit until recently allowed for the discharge of
approximately 4 million gallons per day. However, the permit was modified through
action on the part of Ole Department of Environment, .H.ealtli and. Natural Resources over
time to allow the current discharge of only to 10,000 gallons per day. The discharge
limitation of 10,000 gallons per day does not allow for discharge of two (2) waste water
treatment lagoons, each containing approximately 2 million gallons nor does it allow for
storm water events..
We had earlier this year eoudu.eted a. 2 year hydrological study of die site
indicating that an anticipated 2 year rain, event: would result in approximately 800,000
gallons of effluent -- the storm water system is integrated into the waste water processing
for the facility.
IjkWA Nl-VeA-M�� tlaat-tl�e-alao e refer r p i_ bd-niaci f d liy-,;ac rnittrst alive=_�
letter. 1 au Id�req e t�thai the p�txxi�t�5e modi��d�to allaw;.dt�cliarge,of iaedween 200Q00.=
and .4'6f1� �l0ilp'"day. I would request iris discharge modj.tiicatian be te�r�porat�y_
T would anticipaxe that we would need at least 9q days and would hopefully nog; need
more than 180 days. Please note I am trying to ask for- the minimum feasible
modification. We may need to revisit this based on unforeseen time param-eters or other
evesits. Jf so, I appreciate your cooperation in advance, Please note this is dart of the
process of Shul:ting down. the waste water treatment facility and not everything can be
anticipated or planned for in advance.
I look forward to hearing from the Department soon.
jT Truly Yo�lrs,
F ler, II
r rr 0e,- (8.28) 505-4302
[e-mail]
WPF/skh
pc' Keith Haynes, via facsimile
Charles D. Owen, III
1 North Peck Sy ixc Spite 415 ,Asheville, NC 28501
[phone] F4C3imde [phone]
Per'y Fisl'exL,aw.corn

12/21/2007 03:34 828505430' PERRY FISHER PA PAGE 01/02
TELECOPIER TRANS
PERRY FISH, PA
i NORTH PACK SQUARE, BUTTE 415
A.SHEVU11, NORTH CAR01INA 28801
FHONENO. (828) 505A300
FAX NO. [phone]
DEC 2 1 2007
WATER QUALITY sEC7,,ON
3HEVILLE REGIONAL 0,cmFICE
DATE: December 21, 2007 FAX NO: 828/299-7043 NO. OF PAGES: 2
TO: Keith Haynes
FROM- Perry Fisher
SUBJ: Permit No. 00094
DESC:
COMMENTS:
If all pages are not received or there is a problem with this transmission, please call [phone].
The information contained in this facsimile message is ATTORNEY PRIVILEGED and confidential information intended only for the exclusive
use of the individual entity named as recipient. If the reader is not the intended recipient, be hereby notified that any dissemination is strictly
prohibited. If you have received this communication in error, please notify us immediately by telephone and return the original message to us at
the address at the top of this page via the U.S. Postal Service. Thank you.
Q

JUL-27-07 FRI 03:39 PM FAX N0, P. 01
TLLLICOPYER TRANSMITTAL
VAN WINKLE, BUCK, WALL, STARNES AND :UAVIS, P.A.
11 NORTH MARKET STREET
ASHEVILLE, NORTII CAROLINA 28801-2929
PHONE NO, [phone]
I{AX NO. [phone]
DATE: - �Rily 27, 2007y 1-AX NO: 299-7043 NO, OF PAGE1,8: 2
TO:
1, ROM:
SUBP
DESC;
COMMENTS:
Roger Edwards
W. ferry I±isher,1I
Flotcher %rchousiilg Conlpaily; PetillitNo. NCO000094
J U L 2 7 2007
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
an.,te�.._a.a..ev+xr..m.�...i. it m.,. .. ns.a A0,
If all pages are not received or there is a problem with this transmission, please call [phone] and ask for Stacy Hanson.
The information contained in this facsimile message is ATTORNEY PRIVILEGED and confidential information intended onlyfor the exclusive
use of the individual entity named as recipient. If the reader is not the intended recipient, be hereby notified that any dissemination is strictly
prohibited. If you have rocoived this communication in error, please notiry us Immediately by telephone and return tho original message to us at
the address at the top of this page via the U.S. Postal Service. Thank you.
File No.: 8093-4

JUL-27-07 FRI'03:40
PM FAX NO.
11 North M arket Street, Asheville, NC P8801
VAN
W1 N K 1, F f'.()- PDX 7376, Asheville, K 28802-73/6
JAW IiiM TEL 828,2b&2991 vwl, -ntcorn
I www iwfi
July 27, 2007
Jones 1,, Ryi*cl
•
VIA FACSIMILE 828-299-7043 and US MAIL
OUy F. Clerim
Carolyn Lloyd Coward
Mr, Roger Edwards
Dale A, Curriclon
1 North Carolina Department of Environmental
and Natural Resources
Roy W. Davis, Jr.
Division of Water Quality
Tracy L. DiLfonhach
2090 U.S. Highway 70
Cynthia W. Eller
Swannaiioa, NC 28778
W. Parry Fisher 11
Stephen J. Grabollsteill,
Robert H. Haggard,
k0: Fletcher W0rC1101ISi[1g Company
Larry C. Hirris, jr.
Pomiit No. NC0000094
W. .1,11110S Johnson
Dear Mr. EdwaTds'.
Dona ArnialaUe Johnston"
Craig D, Justus
1 am _writing on behalf of Fletcher W=1101-1.qing Company to request
'Permit
John G. Kelso
modification of its refere'ncud above. AlliS purillitee previously bold a,
Barry B. Kcininon
permit �,vjijojl tfflowed it to. discharge over 4,000,000 gallons per day, Tile
Carolina T. Knox
I current. permit was reduced, but that reduction is too great to haildle the
Brian F. D. Lavollo
j practical and day to day riccds or tlie permitce.- Attached is a letter dated A1110
Arniirlvad M. Long,
20, 2007 fi- , 0111 Civil Design Concepts, 11A, It indicates that lie runoff
13ther E. Manheinier
calculations lcul, from the 1111pervious surface, on the property for a I 0-year storm
event would be 821,416 gallons— For these reasons, I would request that the
Larry S. McDevitt
perinit be modified to change the flow limitations to 821 ngd,
W, Ca?lelofl Melcalf
I appreciate your assistance in this matter. Please give 1110 a call upon
Anna S. Mills
your receipt of this letter so iblat we might discuss this matter larther.
Mark A. Phikston
SUZE11111ah M. Ploninions,
Ve Truly Your
Michalle RII)PL)rl
A I
y
Philip J. Smilli
hillfft L. Snead, Jr.
Bradley A, Stark I WllP,/Skh 8 257 2767
O.F. Starnes VIVIG11,fil-in. com
Allan R. Torlelori
Michael M. Thompson
chirr'. M. V11jallovic
David M, Wilkotsori
P. 02
2 7
2007
L
WATER QUALITY SECTION
ASHEVILLE REGIONA'
8fcpIj(,,n 13. WilliOrnson
Jeffrey D. Zentnu
'Of Coumel Van Winkle�Hkpck, Wall, -Starnes and Davis, P.A.

JUL-27-07 FRI 03:40 PM n FAX NO. 0 P. 03
Cat,
Cl'I+IIL DESIGN CONCEMS, PA
Stine 20, 2007
Charles Owen, III
Fletcher Crossing Industrial Park
P.O. Box 188
V]otcher, NC 28732
Re; Fletcher Crossing Project
CDC Project No. 10730
Dmr Mr. Owen,
,Attached Lire the approximate calculations/hydrographs to deteruine the aamount of storm water
runoff beftig transported and treated at the existing treatment facility. It appears that a roo
leader/storm sewers stem eomwas the nmoff from the impervious buildings to the treatment
i'acilit , The attached runoff calculations are fora two-yoar and 10-year storm event using the
total square footage of the connected buildings (approximately 279,000sf). Durhtg a twr
(24 hour) storm event, we calculated that storm water runoff volume would be approximately
75,250 cubic feet or 5Wgallons, For the 10- ear stornx event, the amount ofzunoff would
be approximately 109,815 cubic feet or 821,416 gallo~;.rs. We calculated these volumes using
the SCS method in HydroCad with a five-minute concentration tinic and a CN-98.
Please feel free to contact Mark Cathey or myself at our office if you have any questions or
require any additional information,
SMCAM 1071 OlDocAco20junc07.doc
FJ
E
2 7 2007 ;�...
QUALITY SECTION
_ ASHEVILLE
CJWATER
REONAI_ OFFICE
+�
200 Swannatioa River Road, Ashevillo, NC 28805 Phone [phone] Fax [phone]
PO Box 5432, Asheville, NC 28813

JUL-27-07 FRI 03:40 PM FAX N0, P. 04

SEP-11-2007 TUE 02;54 PM FAX NO, P. 01/04
P
TELECOP1LR TRANSMITTAL
17ATI s:
TO:
Mzom:
SUM;
1)I'Sc.
COMMI"WTS:
VAN WINKLE, RUCK, 'WALIa, STARNES AND DAVIS, P.A.
I I NORTH MARKETSTRE ET
ASHEVILLF, NORTH CAROLINA. 28801�2929
PHONE NO. [phone]
I+AX NO. [phone]
September 11,2007 FAX NO; 299-7043 NO. OF PAG138:
1). Kcitll Haynes
W. Parry Fisher, 11
Flctcher Warchousinb Company, Permit No. 0000094
Thonk you for yorlr call this morning;. Enclosed is a dupli
g5prcciritc your assistance in modifying tho permits.
W I' ['-'/skh
257 2767
yu1 mYfrm, cony
SEP 1 1 2007
c
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
4
If all pages aro not receivad or thorn is a problem with this transmission, please call [phone] and ask for Stacy Hansen.
The Information contained In this facsimile message is ATTORNEY PRIVILEGED and confidential information intended only for the exclusive
tlsc of the individual entity named as recipient. If the reader is not the intended recipient, be hereby notified that any dissemination is strictly
prohibiled. If you have roceived lies gommunication in error, please notify us immediately by telephone and return the original message to us at
the address at the top of this page via the U.S. Postal Service, Thank you.
File No,: 8093-4

SEP-11-2007 TUE 02:54 PM ,� FAX N0, P. 02/04
y
t VAN WINKLE
LAW I -hint
Mai 1,1 ingwell Adonis'
Jones R 13yrQ
Guy F. Cleriei
(44arAyn Lloyd (toward
pale A. Curridcn
Roy W. DaviS, Jr.
Tracy I., Dielonbach
Cyrithla W. Eller
W. ferry Fisher 11
SLephcn J: Grtiocnslrin
Robed 11. 1laiggard
Larry C, 1-Idrl'15, Jr.
W. Jamey Jahnsnn
Diann Aananlago,lnhraSton'
Craig 1), .JusUla
John G, Kelso
Garry B. Kanpsm
Car9lilie T. Knox
III illn F, D, 1 awdla
Arrnislead M, Long
ESlher F. M-,nhririu r
harry S. Mc,Devilt
W. Carloton MelrtdF
Anna S. Mills
Marl( A, RnWwi
Susannah M. Plurnnaons
Michnlle Pipporl
Adrani L. Slimly
r Bali;) J• 5rrailh
Albu t L. Sncod, Jr.
Dradlcy A. S1aik
O,E. St; ric,2
Audal R. rarlclo(j
Michael M. llzk)nip'orl
Claire M, Vuj'Inovir:
David M. Wilkerson
Stoplaen B. William ;on
Jilffrcy 1). Zenlnor
'01 Counsel 1
I
July 27, 2007
VIA FACSIMILE 828-299-7043 and US MAIL
Mr. Roger Edwards
North Carolina Departmclit of Environmental
and Natural Resources
Division of Water Quality
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: Fletcher Warehousing Compzlny
Permit No, NCO000094
Dear Mr. Edwards:
11 North Mai ket Strect, Asheville, NC 28801
P.O. Box 7376, Ashevillo, NC 28802-7376
1 EL 828.258 29911 www.VWI awFrm.coiii
I am writing on behalf of Fletcher Warehousing Company to request
modification of its permit referenced above. This perinitee previously held a
permit which allowed it to discharge over 4,000,000 gallons per day. The
: current permit was reduced, but that reduction is too great to handle the
practical,and day to day needs of the pennitce, Attached is a letter dated June
20, 2007 from Civil Design Concepts; PA. It indicates that the runoff
calcr.tlatioris from the impervious surface on the property for a 10-year storm
event would be 821,416 gallons, For these reasons, I would request That the
Permit be modified to ehattge the flow litnitations to 821ingd.
I appreciate your assistance in this matter. Please give me a call upon
your receipt of this letter so that we might discuss this matter further.
Vserruly You
WPF/slchasp 2767
V
X,():
Van Winkle,BUCk, Wall, Sterrles and NMI, P.A.

r
Charles Owens
Fletcher Warehousing Company
PO Box 457
Swannanoa, NC 28778
Michael F. Easley, Governor
l� W."ent
liam G. Ross Jr., Secretary
North Carolina Department of Enand Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
June 1, 2007
FRFoN - 5 2007
f=AE
OUALITY SECTION ISUBJECT: Payment Acknowledgment LE REGION NAL OFFICE
Civil Penalty Assessment
Fletcher Warehousing Company —
Permit Number: NC0000094
Case Number: LVL 2007-0145
Henderson County
Dear Mr. Owens:
I
This letter is to acknowledge receipt of check number 2594 in the amount of $380.00 received
from you dated May 24, 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. j
If you have any questions, please call Bob Guerra at 919-733-5083 Ext. 539.
j
Sincerely, ;
i :::�AaurnieSingleton
Singleton -
cc: Enforcement File #: LV-2007-0145
Q_Ash eville-Regional�O:ffice_Supery sor
Central Files .
a
One
hCarolina
NNaturally -
1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service 1 800 623-7748

ATIIIII.8
BOIHoa4O - eInOQDBM
S-mo- Loot- n1 'QN'�
00 oat
LoozArm v.un yuawGw(4u3ra uepdw000 a nog 4uiod
76 CJ z ANVdWOO ONIenoN3wm N3NOJ3 d

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
Asheville Regional Office
SURFACE WATER PROTECTION
March 12, 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7006 2150 0005 2459 7278
Mr. Charles Owen
Fletcher Warehousing Company
Post Office Box 46-7- \N��3
Swannanoa, North Carolina 28778
Subject: NOTICE OF VIOLATION
NOV-2007-MV-0042
Permit No. NC0000094
Fletcher Warehousing Company
Henderson County
Dear Mr. Owens:
A review. of Fletcher Warehousing Company's monitoring report for December 2006
showed the following violations:
Parameter
Week
Ending
Measuring
Frequency
Violation
BOD, 5-Day (20 Deg. C)
12/30/06
Weekly
Failure to monitor
Coliform, Fecal
12/30/06
Weekly
Failure to monitor
DO, Oxygen, Dissolved
12/30/06
Weekly
Failure to monitor
Nitrogen, Ammonia Total
12/30/06
Weekly
Failure to monitor
Solids, Total Suspended
12/30/06
Weekly
Failure to monitor
Remedial actions should be to correct this problem. The Division of Water Quality may pursue
enforcement action for this and any additional violations of State law.
Carefully review these violations and deficiencies and respond in writing to this office within 30
working days of receipt of this letter. You should address the causes of non-compliance and all
actions taken to prevent the recurrence of similar situations. If you should. have any questions,
please do not hesitate to contact Mr. Larry Frost at [phone].
Sincerely,
Roger C. Edwards, Regional Supervisor
Surface Water Protection
cc: WQ Central Files
NPDES Unit
NorthCarolina
2090 U.S. Highway 70, Swannanoa, N.C. 28778 828/296-4500 (Telephone) 828/299-7043(Fax) Customer Service 877-623-6748 �atura//1�

7
North Carolina Department o
SURFACE WATER PROTECTION
April 16, 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED . 7006 2150 0005 2459 5472
Mr. Charles Owens
Fletcher Warehousing Company
Post Office Box 457
Swannanoa, North Carolina 28778
Michael F. Easley, Governor
William G. Ross Jr., Secretary
ironment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Asheville Regional Office
LE
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(6)
and NPDES Permit NC0000094
Fletcher Warehousing Company
Fletcher Warehousing Company
Case No. LV-2007-0145
Henderson County
Dear Mr. Owens:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $380.00
($250.00 civil penalty + $130.00 enforcement costs) against Fletcher Warehousing Company.
This assessment is based upon the following facts: a review has been conducted of the discharge
monitoring report (DMR) submitted by Fletcher Warehousing Company for the month of January
2007. This review has shown the subject facility to be in violation of the discharge limitations
and/or monitoring requirements found in NPDES Permit NC0000094. The violations, which
occurred in January 2007, are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Fletcher Warehousing Company
violated the terms, conditions or requirements of NPDES Permit NC0000094 and G.S. 143-
215.1(a)(6) in the manner and extent shown in Attachment A. In accordance with the maximums
established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed against any person who
violates the terms, conditions or requirements of a permit required by G.-S. 143-215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the
Director of the Division of Water Quality, I, Roger C. Edwards, Division of Water Quality
Regional Supervisor for the Asheville Region, hereby make the following civil penalty assessment
against Fletcher Warehousing Company:
NorthCarolina
�aturalty
2090 U.S. Hiy 70, Swannanoa, NC 28778 Phone: [phone] FAX:[phone] Customer Service 1- 800 623-7748

i of the 1 violations of G.S. 143-215.1(a)(6) and NPDES Permit No.
$250.00 NC0000094, by discharging waste water into the waters of the State
in violation of the Permit Monthly Average limit for FLOW.
'$250.00 - TOTAL CIVIL PENALTY
$13000 (` Enforcement Costs
r . $380.00 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into
account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or
to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; 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
MIN
2. Submit a written request for remission or mitigation including a detailed justification
for such request:
Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s)
occurred or the accuracy of any of the factual statements contained in the civil penalty
assessment document. Because a remission request forecloses the option of an administrative
hearing, such a request must be accompanied by a waiver of your right to an administrative
hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please
prepare a detailed statement that establishes why you believe the civil penalty should be
remitted, and submit it to the Division of Water Quality at the address listed below. In
determining whether a remission request will be approved, the following factors shall be
considered:

(1) whether one or more of the civil penalty assessment factors in NCGS 14313-282.1(b)
was 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 evidence presented in support of your request for remission must be submitted
in writing. The Director of the Division of the Division of Water Quality will review your
evidence and inform you of his decision in the matter of your remission request. The response will
provide details regarding the case status, directions for payment, and provision for further appeal
of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that
was not part of the original remission request considered by the Director. Therefore, it is very
important that you prepare a complete and thorough statement in support of your request for
remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission
of Civil Penalties, 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

o
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
acceptsfilings 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]
and
Mail or hand -deliver a copy of the petition to
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 you have any questions, please contact the Water Quality staff of the Asheville Regional Office
at 828-296-4500.
Sincerely,
R 0
ge C. Edwards, Regional Supervisor
Surface Water Protection
Asheville Regional Office
ATTACHMENTS /
" (I
�Ig wl .ttaoh...e , is
Enforcement File w/ attachments
Central Files w/ attachments
NPDES Unit

JUST CATION FOR REMISSION REO'uEST
DWQ Case Number: LV-2007-0145 County: Henderson
Assessed Party: Fletcher Warehousing Company
Permit No. (if applicable): NC0000094 Amount Assessed: $380.00
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts "
form to request remission of this civil penalty. -You should attach any documents that you believe
support your request and are necessary for the Director to consider in evaluating your request for
remission. Please be aware that a request for remission is limited to consideration of the five factors
listed below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or
the accuracy of any of the factual statements contained in the civil penalty assessment document.
Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only when one or
more of the following five factors applies. Please check each factor that you believe applies to your
case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were
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:

STATE OF NORTH CARS__ NA DEPAR'_L1v-LE,NT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF Henderson
Fletcher Warehousing Company
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINSTRATIVE FEARING AND
Fletcher Warehousing Company ) STIPULATION OF FACTS
PERMIT NO. NC0000094 ) FILE NO. LV-2007-0145
Having been assessed civil penalties totaling $380.00 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated April 16, 2007, the undersigned, desiring
to seek remission of the civil penalty, does hereby waive the right to an administrative hearing in the
above -stated matter and does stipulate that the facts are as alleged in the assessment document. The
undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the director of the Division of Water Quality within thirty (30) days of
receipt of the 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
SIGNATURE
Fill

ATTACHMENT A
Fletcher Warehousing Company
CASE NUMBER: LV-2007-0145
PERMIT: NC0000094 FACILITY: Fletcher Warehousing Company COUNTY: Henderson REGION: Asheville
Limit Violations
MONITORING OUTFALL/ VIOLATION UNIT OF CALCULATED % OVER
PENALTY REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE LIMIT VIOLATION TYPE
$250.00 1-2007 001 Effluent FLOW 01/31/07 Continuous mgd 0.01 0.049 385.71 Monthly Average Exceeded

* Y.
DIVISION OF WATER QUALITY CIVIL PENALTY ASSESSMENT (FILE)
Violator: Fletcher Warehousing Company
County: Henderson
Case Number: LV-2007-0145
ASSESSMENT FACTORS
As required by G.S. 143-214.6A(c), in determining the amount of the penalty I considered the factors
set out in G.S. 143B-282.1(b), which are:
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation;
This facility's effluent discharges to the French Broad River, part of the French
Broad River basin. No harm has been reported or detected.
2) The duration and gravity of the violation;
This facility has not experienced other flow problems in the last year..
3) The effect on ground or surface water quantity or quality or on air quality;
All NPDES effluent permit violations are considered to be detrimental to the
receiving stream.
4) The cost of rectifying the damage; .
No cost associated with this violation, as no harm/damage has been reported or
detected.
5) The amount of money saved by noncompliance;
The facility has possibly saved the cost of making the needed plant improvements
to remove stormwater from their process.
6) Whether the violation was committed willfully or intentionally;
There is no evidence that the violations are 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
This facility had a compliance issue in December 2006 for failure to monitor, high
fecal Coliform in August and September 2006.
8) The cost to the State of the enforcement procedures.
In this case approximately $130.00.
dr-710 7
Date Rbg C. Edwards, Region -al Supervisor
Surface Water Protection
Asheville Regional Office

L
March 19, 2007
Mr. Larry Frost
Surface Water Protection
2090 US Hwy 70
Swannanoa, NC 28778
Re: Notice of Violation
NOV-2007-MV-0042
Permit No. NC0000094
Fletcher Warehousing Co
Henderson County
Dear Mr. Frost:
GOLDIE
ASSOCIATES
engineering, environmental
and laboratory services
This correspondence is in regard to the Notice of Violation for the month of December
2006 at the Fletcher Warehousing Wastewater treatment system. The wastewater
treatment facility had zero flow for the month except for the day of December 28, 2006.
When Robert Orr, ORC, of the facility arrived at the plant on December 27, 2006 there
was zero flow. When he returned on December 28, 2006 there was no discharge at that
time, but the plant had discharged flow during the time that he left the plant on December
27 and on his return on December 28, 2006. He did not sample because the plant was not
discharging at the time he was there.
The facility has very little flow except when there is runoff from storm water. If you
need any additional information or have any questions, please feel free to call me at 864-
882-8194 ext 105.
Sincerely,
GOLDIE & ASSOCIATES
I Z
Henry Dyar
Operations Manager
Cc: Mr. Roger Edwards
Mr. Charles Owens
Mr. Stan Littlejohn
I� MAR 2 2.2001
WATER QUALITY SECTION
AS iaVILLE REGIONAL OFFICE
210 W. North Second Street • Seneca, South Carolina_29678 9 Phone [phone] • Fax [phone]

�' , �--a. vw,a . w.+x ...o,..cr.., a:, .....•...-...., r.: s'`«.: n'NYA• vis:u... .$
GOLDIE
February 5, 2007 {„ D E C E E
Mr. Roger C. Edwards ' ASSOCIATES
F E B 9 2007
Surface Water Protection. engineering, environmental
2090 US Hwy 70 and laboratory services
Swannanoa, NC 28779- WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE h
of Violations / d
NOV-2007-LM-0004 0�
Permit No. NC0000094 1 ti
1
Fletcher Warehousing Co.
Henderson County
Dear Mr. Edwards:
This correspondence is in regard to the Notice of Violation for the month of November
2006 at the Fletcher Warehousing Wastewater treatment system. The average daily
maximum for flow exceeded the permit limit on November 16, 2006 due to a heavy rain
event. Theplant usually discharges a very low flow or zero flow reading.
The average flow calculation was determined by dividing the total flow by six which was
the number of days that the plant actually disclhUged. wool < 1=ike to _r-e-vise the
mWor=th. This would bring the average daily max mi um down to 0.0115 MGD, which stills
exceed'the average daily'maximum but by only 1500 gallons.
The plant has a continuous flow recorder and monitors the flow 24 hours per day, the
operator failed to record the daily flow reading of zero on the DMR on Novemberl 8,
2006. We have corrected this omission on the revised DMR
Goldie & Associates has made an Inflow & Infiltration Study of the plant's collection
system and has recommended that the Fletcher Warehousing Company consider tying on
to the local municipality's sewer system.
If you have any questions or concerns please call me at [phone] ext 105.
Sincerely,
lV/"V-Ly
Henry Dyar
Operations Manager
Goldie & Associates
Cc: Mr. Keith Haynes
Mr. Charles Owens
Mr. Stan -Littlejohn
210 W. North Second Street 0 Seneca, South Carolina 29678 9 Phone [phone] • Fax [phone]

Copyright © 1992-1998. ChemSWTM, Inc.,[phone], All eserved, http://www.chemsw.com
EFFLUENT
NPDES PERMIT NO. NC0000094 DISCHARGE NO: 001
FACILITY NAME Fletcher Warehousing Company CLASS
OPERATOR IN RESPONSIBLE CHARGE (ORC) Robert Orr
MONTH 4/0Ile n,_6P}- YEAR .2&16C,
II COUNTY: Henderson
GRADE III PHONE [phone]
CERTIFIED LABORATORIES (1) Goldie and Associates (2) Pace Labs
CHECK BOX IF ORC HAS CHANGED PERSON(S) COLLECTING SAMPLES
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL FILES xaj'a't O
Robert Orr
DIVISION OF WATER QUALITY
(SIGNATURE OF OPERATOR IN RESPONSIBLE CHARGE)
1617 MAIL SERVICE CENTER
BY THIS SIGNITURE, I CERTIFY THAT THE REPORT IS
RALEIGH, NC 27699-1617
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE
— 15-- � 00 6
DATE
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-pyright ©1992-1998, ChemSW—, Inc.,[phone], All rights reserved. http://VAM.chemsW.cOm
Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
Compliant
all monitoring data and sampling frequencies do NOT meet permit requirements F77l
Noncompliant. __.._ ...
the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation,
iaintenance, etc., and a time table for improvements to be made.
certify, under penalty of law, that this document and all attachments were prepared under my direction or
.tpervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate
le information submitted. Based on my inquiry of the person or persons who manage the system, or those
ersons directly responsible for gathering the information, the information is, to the best of my knowledge and belief,
ue, accurate, and complete. I am aware that there are significant penalties for submitting false information,
icluding the possibility of fines and imprisonment for knowing violations."
Permittee (Please print or type) , �j1 a iXe
x questions, contact:. 139
enry Dyar a a G 94> C/-.�✓ v li
oldie & Associates Signature of ermitte. * Dat
10 W. North 2nd St. /Wei 2 — S— a I I
eneca, SC 29678 1-866-882-8194
ermittee Address Phone Number Permit Exp. Date -
PARAMETER CODES Forms by ChemSwvonB84-o845;p/n11158;v5.21;211198
00010 Temperature 00556 Oil & Grease 00951 Total Fluoride 01067 Nickel 50060 Total
00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
00080 Color (Pt -Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine
00082 Color (ADMII) 00625 Total Kjeldhal 01207 Cadmium '01105 Aluminum
Nitrogen
00095 Conductivity
00300 Dissolved Oxygen
03100 BOD5
00340 COD
00400 pH
00530 Total Suspended
Residue
00545 Settleable Matter
00630 Nitrates/Nitrites
00665 Total Phosphorous
00720 Cyanide
00745 Total Sulfide
00927 Total Magnesium
00929 Total Sodium
00940 Total Chloride
01032 Hexavalent Chromium
01034 Chromium
01307 Total Cobalt
01042 Copper
01045 Iron
01051 Lead
01147 Total Selenium- 71880 Formaldehyde
31616 Fecal Coliform 71900 Mercury
32730 Total Phenolies 81551 Xylene
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
arameter Code assistance may be obtained by calling the Waer Quality Compliance Group at [phone], extension 581 or 534
he monthly average for fecal coliform is to be reported as -a GEOMETRIC mean. Use only units, designated in the reporting
Icility's permit for reporting data.
ORC must visit facility and document visitation of facility as required per 15 A NCAC 8A .0202 (b) (5). (B)
If signed by other than the permittee, delegation of signatory authority must e on file with the state per 15A NCAC 2B .0506 (b)
:) (D)

February 5, 2007 E C
Mr. Roger C. Edwi F E B °� 9 2007
Surface Water P ote 1 1
2090 US Hwy 70 I 1
Swannanoa, N0287 8 WATER QUALITY SECTION
i. ASHEVILLE REGIONAL OFFICE
Dear Mr. Edwards:
GOLDIE
ASSOCIATES
engineering, environmental
and laboratory services
Notice of Violations
NOV-2007-LM-0004
Permit No. NC0000094
Fletcher Warehousing Co.
Henderson County
This correspondence is in regard to the Notice of Violation for the month of November
2006 at the Fletcher Warehousing Wastewater treatment system. The average daily
maximum for flow exceeded the permit limit on November 16, 2006 due to a heavy rain
event. The plant usually discharges a very low flow or zero flow reading.
The average flow calculation was determined by dividing the total flow by six which was
the number of days that the plant actually discharged. We would like to revise the
November DMR as to take the total flow and divided it by the number of days in the
month. This would bring the average daily maximum down to 0.0115 MGD, which stills
exceed the average daily'maximum but by only 1500 gallons.
The plant has a continuous flow recorder and monitors the flow 24 hours per day, the
operator failed to record the daily flow reading of zero on the DMR on Novemberl 8,
2006. We have corrected this omission on the revised DMR
Goldie & Associates has made an Inflow & Infiltration Study of the plant's collection
system and has recommended that the Fletcher Warehousing Company consider tying on
to the local municipality's sewer system.
If you have any questions or concerns please call me at [phone] ext 105.
Sincerely,
Henry Dyar
Operations Manager
Goldie & Associates
Cc: Mr. Keith Haynes
Mr. Charles Owens
Mr. -Stan Littlejohn
210 W. North Second Street 0 Seneca, South Carolina 29678 • Phone [phone] • Fax [phone]

Copyright ©1992-1998. ChemSWI. Inc.,[phone], A" reserved. http://www.chemsw.com A
EFFLUENT
NPDES PERM�7T N0.' "` °' y'`NC0000094 "'DISCHARGE NO: 001 MONTH %l%Uem.62r YEAR �
FACILITY NAME Fletcher Warehousing Company CLASS II COUNTY: Henderson
OPERATOR IN RE PO1NSIBLE CHARGE (ORC) � 1 (Robert Orr GRADE II PHONE [phone]
�oldi �n A
CERTIFIED LABO Ifs I I� R V t} �S (2) Pace Labs
II , �_. (1)_..�.,_____ ;s°ociates
CHECK BOX IF ORC HAS CHA�i
Mail ORIGINAL and
ATTN: CENTRAL'FILE
DIVISION OF WATER L
1617 MAIL SERVICE C Et`
RALEIGH, NC 27669-1
TE B - 9 2007
RWATER QUALITY SECTIO
ASHEVILLE REGIONAL OFF
RSON(S) COLLECTING SAMPLES Robert Orr
3NATURE OF OPERATOR IN RESPONSIBLE CHARGE) DATE
THIS SIGNITURE, I CERTIFY THAT THE REPORT IS
�U:RATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE
50050 "' 00010 00400 1 50060 1 00310, 1 00810 -1 00530 1 31616 1 00300 1 00600 00665
.....d..-.,
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' Fecal Coliform: data based on non -ideal colony count
< Below detection limit for method used

oyright O 1992-1998, ChemSWTM, Inc.,[phone], All rights.-_ _d. http://www.chemsw.com
Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
Compliant
kil monitoring data and sampling frequencies do NOT meet permit requirements C_1
Noncompliant
the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation,
aintenance, etc., and a time table for improvements to be made.
certify, under penalty of law, that this document and all attachments were prepared under my direction or
ipervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate
e information submitted. Based on my inquiry of the person or persons who manage the system, or those
arsons directly responsible for gathering the information, the information is, to the best of my knowledge and belief,
.le, accurate, and complete. I am aware that there are significant penalties for submitting false information,
cluding the possibility of fines and imprisonment for knowing violations."
tr questions, contact:
mry Dyar
)Idie & Associates
10 W. North 2nd St.
eneca, SC 29678
Permittee (Please print or type) , : f.
..-fh
y .y ..
a fD A-_ 6'a Lei Q - 4D C.I. s
Signature of Mermitteel Dat6
1-866=882-8194-
ermittee Address Phone Number Permit Exp. Date
PARAMETER CODES Forms by ChsmSW(707)88"845;p/n11158;v5.21:211193
)0010 Temperature 00556 Oil & Grease 00951 Total Fluoride 01067 Nickel 50060 Total
)0076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
)0080 Color (Pt -Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine
)0082 Color (ADMII) 00625 Total Kjeldhal 01207 Cadmium '01105 Aluminum
Nitrogen
)0095 Conductivity
00630 Nitrates/Nitrites
01032 Hexavalent Chromium
01147 Total Selenium
71880 Formaldehyde
)0300 Dissolved Oxygen
01034 Chromium
31616 Fecal Coliform
7190Q Mercury
)3100 BOD5
00665 Total Phosphorous
32730 Total Phenolies
. ;81551 Xylene
)0340 COD
00720 Cyanide
01307 Total Cobalt
34235 Benzene
)0400 pH
00745 Total Sulfide
01042 Copper
34481 Toluene
)0530 Total Suspended
00927 Total Magnesium
38260 MBAS
Residue
00929 Total Sodium
.01045 Iron
39516 PCBs
)0545 Settleable Matter
00940 Total Chloride
01051 Lead
50050 Flow
irameter Code assistance may be obtained by calling the Waer Quality Compliance Group at [phone], extension 581^or'534
ie monthly average for fecal coliform is to be reported as.a GEOMETRIC mean. Use only units,designated in the reporting
cility's permit for reporting data.
DRC must visit facility and document visitation of facility as required per 15 A NCAC 8A .0202 (b) (5)..(B)
If signed by other than the permittee, delegation of signatory authority must a on file with the state per 15K NCAC 2B .0506 (b)
) (D)

%1A,7 tichal F. EasleEc
rnor 3.
0mnj V�Iliam . Ross Jtary J
Q rid
NG North Carolina Departrt"1en of Enviro ent urarces
t 7 Alan W. Klimek, P.E. Director
>_ Division of Water Quality
p �"
Asheville Regional Office
SURFACE WATER PROTECTION
January 19, 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7005 1820 0002 9207 4922
Charles Owens
Fletcher Warehousing Company
PO Box 457
Swannanoa NC 28778
Subject: NOTICE OF VIOLATION
NOV-2007-LM-0004
Permit No. NC0000094
Fletcher Warehousing Company
Henderson County
Dear Mr. Owens:
A review of Fletcher Warehousing Company's monitoring report for November 2006 showed the
following violations:
Parameter
Date
Limit Value`
Reported
Limit Type
Value
Flow, in. conduit or thru
11/30/06
0.01 mgd
0.058 mgd
Monthly
treatment plant
Average
Exceeded
Parameter
Date
Measuring
Violation
Frequency
Flow, in conduit or thru
11/18/06
Continuous
Frequency
treatment plant
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue
enforcement action for this and any additional violations of State law.
To prevent further action, carefully review these violations and deficiencies and respond in writing to
this office within 15 days of receipt of this letter. You should address the causes of non-compliance
and all actions taken to prevent the recurrence of similar situations. If you should have any
questions, please do not hesitate to contact Keith Haynes at 828/296-4500.
Sincerely, _
9z� el. '
Rogd1 C. Edwards, Regional Supervisor
Surface Water Protection
cc: WQ Central Files
N P D E S aP�
2090 U.S. Highway,70, Swannanoa, N.C. 28778 828/296-4500 (Telephone) 828/299-7043(Fax) Customer Service 877-623-6748
Nol
rrtirrrrllr�thCarolina

-% J
R70Ec December 13, 2006 14 2006 I
Mr. Roger C. Edwards
Surface Water Protection
2090 US Hwy 70
Swannanoa, NC 28778
Dear Mr. Edwards:
WAT Q ITY SECTION
SHEVILLE REGIONAL OFFICE
GOLDIE
ASSOCIATES
engineering, environmental
and laboratory services
Notice: Notice of Violations
NOV 2006 LV 0538
NOV 2066 LV 0539
Permit No. NC0000094
Fletcher Warehousing Co.
Henderson County
This correspondence is in regard to the Notice of Violations for the months of August &
September 2006 at the Fletcher Warehousing Wastewater treatment system. On
December 13, 2006, I discussed these system conditions with Mr. Larry Frost of your
office.
On the evening of August 29, 2006 a thunderstorm with heavy rain and lightning
occurred. Lightning disabled the aerators and the rain caused a high flow in a short time
period. Due to the summer heat and the resulting loss of aeration, along with the high
flow rate, the plant became operationally unstable causing low dissolved oxygen levels
and a high fecal coliform count.
We had the aerators repaired and put back into service, but it took -several days to make
adjustments to the plant to return it to proper operation. We have maintained compliance
since September 20, 2006.
We do not believe futher corrective action is needed, since the plant is now operating
correctly.
Sincerely,
le��Qq�a,
Henry Dyar
Operations Manager
Goldie & Associates
Cc:. Mr. Larry Frost -
Mr. Charles Owens
Mr. Stan Littlejohn
210. W. North_ Second Street 9 Seneca, South Carolina 29678 • Phone [phone] Fax [phone]

�F W A FTF/� p 1ich-LsleyEv:orm
William G. Ross Jr., Secretary
G North Carolina Department of Environment and Natural Resources
r Alan W. Klimek, P.E. Director
Division of Water Quality
Asheville Regional Office
SURFACE WATER PROTECTION
November 27, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED '7005 0390 00013553 2265
Mr. Charles Owens
Fletcher Warehousing Company
Post Office Box 457
Swannanoa, North Carolina 2877.8
Dear Mr. Owens:
Subject: NOTICE OF VIOLATION
NOV 2006 LV 0538
Permit No. NC0000094
Fletcher Warehousing Company
Henderson County
A review of Fletcher Warehousing Company's monitoring report for August 2006 showed
the following violations:
Parameter
Date
Limit Value
Reported
Limit Type
Value
DO, Oxygen, Dissolved
08/30/06
5 mg/I
3.6 mg/I
Daily Minimum Not
Reached
Coliform, Fecal MF, M-
08/30/06
400
1,400 #/100ml
Daily Maximum
FC Broth,44.5C
#/100ml
Exceeded
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue
enforcement action for this and any additional violations of State law.
Carefully review these violations and deficiencies and respond in writing to this office within ten (10)
working days of receipt of this letter. You should address the causes of non-compliance and all
actions taken to prevent the recurrence of similar situations. If you should have any questions,
please do not hesitate to contact Mr. Larry Frost at [phone].
Sincerely,
* &ftZV A.
Roger C. Edwards, Regional Supervisor
Surface Water Protection
cc: WQ Central Files
NPDES Unit
2090 U.S. Highway 70, Swannanoa, N.C. 28778 828/296-4500 (Telephone) 828/299-7043(Fax) Customer Service 877-623-6748
NorthCarolina
Naturallt,�

W AT,
� chael F, slelraGovernor
Q Wi "am s;J�,, Secretary
North Carolina Depa;7.f En ron nt and Na ra>z)t-sources
r Alan W. Klimek, P.E. Director
O v Division of Water Quality
Asheville Regional Office
SURFACE WATER PROTECTION
November 27, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7005 0390 00013553 2289
Mr. Charles Owens
Fletcher Warehousing Company
Post Office Box 457
Swannanoa, North Carolina 28778
Subject: NOTICE OF VIOLATION
NOV-2006-LV-0539
Permit No. NC0000094
Fletcher Warehousing Company
Henderson County
Dear Mr. Owens:
A review of Fletcher Warehousing Company's monitoring report for September 2006
showed the following violations:
Parameter
Date
Limit Value
Reported
Limit Type
Value
DO, Oxygen, Dissolved
09/06/06
5 mg/I
3.68 mg/I
Daily Minimum Not
Reached
DO, Oxygen, Dissolved
09/13/06
5 mg/I
3.96 mg/I
Daily Minimum Not
Reached
Coliform, Fecal MF, M-
09/20/06
400
1,040 #/100ml
Daily Maximum
FC Broth,44.5C
#/100ml
Exceeded
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue
enforcement action for this and any additional violations of State law.
Carefully review these violations and deficiencies and respond in writing to this office within ten (10)
working day of receipt of this letter. You should address the causes of non-compliance and all
actions taken to prevent the recurrence of similar situations. If you should have any questions,
please do not hesitate to contact Mr. Larry Frost at [phone].
Sincerely,
Roger C. Edwards, Regional Supervisor
Surface Water Protection
cc: WQ Central Files
NPDES Unit
NorthCarolina
2090 U.S. Highway 70, Swannanoa, N.C. 28778 828/296-4500 (Telephone) 828/299-7043(Fax) Customer Service 877-623-6748 Naturally
,

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
Date: December 15, 2005
Henry Dyan
210 W. North 2nd St.
Seneca, SC 29678
Subject: Notice of Incomplete Discharge Monitoring Report NC0000094
Dear Permittee:
The purpose of this letter is to call your attention to problems with the recent submittal of the Discharge
Monitoring Report (DMR) from your facility. As. you may know, the data recorded on your DMR is keyed
into the Division's database. Our data entry staff has informed me of problems with your recent DMR
submittal. Until these problems have been corrected, your DMR will be considered incomplete. Please
seethe attached form. along with a copy of the problem DMR for details regarding the DMR's deficiency.
Incomplete or illegible DMRs affect our staff's ability to provide a timely and effective evaluation of DMR
submittals. Please be aware that until the Division receives a corrected DMR, you may be considered
noncompliant with your NPDES permit and 15A NCAC 02B .0506, and you may be subject to further
enforcement action. Please take the necessary steps to correct the problems and, submit two copies of the
amended DMR within fifteen (15) days of the date of this letter to the following address:
Attention: Michele Phillips
Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Future DMR submittals with the same or similar problems will be unacceptable. If you have any questions
about the proper completion of DMRs, please contact Michele Phillips at 919-733-5083 Ext. 534. Thank
you for your assistance in this matter.
Sincerely,
Michele
cc: CAsheu RET-R'�egionali®-ffice"
Central Files
PSG C EP 1`
i
DEC 1 6 2005
I
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
None hCarolina
Naturally
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Phone: [phone] Customer Service
Internet: httpJ/h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 Fax: [phone]
An Equal Opportunity/Affirmative Action Employer

I. '
✓I
IV
Notice of Incomplete Discharge Monitoring Report
Permit Number: I co o o o o ci `i'
Facility: T' I t ta-'-e rykt r-thdk-l�a L-1 cah �n
13
County:
DMR Month and Year: `
f t
The Division of Water Quality deems the aforementioned DMR as incomplete due to the
following reason(s): (Please see the highlighted areas on the attached DMR for
:'details.)
0. The written values are illegible.
❑ The Average, Maximum, and/or the Minimum data points have been omitted.
❑
Ll
The Units of Measure have been omitted or are incorrect.
The DMR Parameter Codes have been omitted.
Other:
li 24_ S D_. (�1�.� o�
l -uY QJ1 ��Y1
�

THE
VAN WINKLE
LAW FIRM
Marla Tugwell Adams
Jones P. Byrd
Guy F. Clerici
Carolyn Lloyd Coward
Dale A. Curriden
Roy W. Davis, Jr.
Tracy L. Diefenbach
Cynthia W. Eller
W. Perry Fisher II
Stephen J. Grabenstein
Robert H. Haggard
Larry C. Harris, Jr.
W. James Johnson
Craig D. Justus
John G. Kelso
Barry B. Kempson
Caroline T. Knox
Brian F. D. Lavelle
Esther E. Manheimer
Larry S. McDevitt
W. Kevin McLaughlin, Jr.
W. Carleton Metcalf
Anna S. Mills
Vaughn S. Monroe
Mark A. Pinkston
Emily Belcher Reynolds
Michelle Rippon
Adam L. Shealy
Philip J. Smith
Albert L. Sneed, Jr.
O.E. Starnes
Allan R. Tarleton
Michael M. Thompson
Claire M. Vujanovic
Stephen B. Williamson
December 7, 2005
Mr. Larry Frost
North Carolina Department of Environmental
and Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
11 North Market Street, Asheville, NC 28801
P.O. Box 7376, Asheville, NC 28802-7376
TEL [phone] www.vwlawfirm.com
900z Z
��
QUALITY S: ;C)N
— --WATER
Re: Surface Water Protection Letter dated October 17, 2005
Fletcher Warehousing Company
Permit No.: NC0000094
Henderson County
Dear Mr. Frost:
I am following up on our recent conversation. As we discussed, I am counsel
to Fletcher Warehousing Company and have been asked to follow-up on the
October 17, 2005 correspondence from Roger C. Edwards, Regional Supervisor to
Fletcher Warehousing Company c/o Stan Littlejohn.
Pursuant to our discussions, this letter will address solely those issues going
forward rather than substantively addressing the "Notice of Violation." Currently,
the Town of Fletcher is attempting to annex the Fletcher Warehousing Company
property. Fletcher Warehousing Company is resisting those efforts because the Town
of Fletcher has indicated that while it desires to include the property within its tax
base, it does not want to provide "core services." Core services would necessarily
include sewer. We are in negotiations with counsel for the Town of Fletcher
regarding the annexation. In essence, we have indicated that if they provide core
services to the property and the facility, we will agree to the annexation. The
negotiations are continuing and during those negotiations, we are maintaining our
objection to the proposed annexation.
I will continue to keep you informed of the situation as it develops. In the
interim, if you have any questions or if I can be of assistance to you in this or any
other matter, please do not hesitate to call upon me. I would appreciate your
providing me with copies of all further correspondence or communication relating to
permits for the facility.
Van Winkle, Buck, Wall, Starnes and Davis, P.A.

I
Mr. Larry Frost
December 7, 2005
Page 2
I appreciate your assistance in this matter and look forward to the continued cooperation
with the North Carolina Department of Environment and Natural Resources, Division of Water
Quality.
WPF/aj
V
e truly yo s,
. Pe sher,
F 8-257-2767
r [e-mail]
Van Winkle, Buck, Wall, Starnes and Davis, P.A.

`WATFR Michael F. Easley
F1'� Governor
r . NC ENR William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
November 9, 2005
Stan Littlejohn, Site Manager
Fletcher Warehousing Company
P.O. Box 457
Swannanoa, North Carolina28778
---------- —T_--------------------_;.—__Subject:Issuance-of-NPDESPermitN03000094--
Fletcher Warehousing Company
Henderson County
Dear Mr. Littlejohn:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the.
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9,1994 (or as subsequently amended). .
This final permit includes no major changes from the draft permit sent to you on July 6, 2005.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of
this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain
other permits which maybe required by the Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be
required. If you have any questions concerning this permit, please contact Sergei Chemikov at telephone number
[phone], extension 594.
J
cc: Central Files
NPDES Permit He
(Asheville RegionatOffice/Surface Wa� er Protecuon<--,'
DEH
Ben Day, Goldie and Associates
210 W. North Second Street, Seneca, SC 29678
N. C. Division of Water Quality/ NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Sincerely,
rw-limek, P.E. '
D E
NOV 10 2005
LVIATER ER QUALITY SECTIOI,,
ASHEVILLE REGIONAI. _OFFICE
O
Phone: [phone] -
fax: [phone]
DENR Customer Service Center 1 800 623-7748

Permit NC0000094
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Fletcher Warehousing Company
is hereby authorized to discharge wastewater from a facility located on
Route 25
Fletcher
Henderson County
to receiving waters designated as the French Broad River in the French Broad River
Basin
in accordance with effluent limitations, monitoring requirements and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective December 1, 2005.
This permit and authorization to discharge shall expire at midnight on November 30, 2010.
Signed this day November 9, 2005.
ur-
Alanimek, P.E. Director
Divi on of Water Quality
By Authority of the Environmental Management Commission

Permit NC0000094
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit 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.
Fletcher Warehousing Company is hereby authorized to:
-1. Continue to operate an existing (4.0 MGD) extended aeration wastewater
treatment facility at a monthly average flow_ not exceeding 0.01 MGD which
includes the following components:
➢ Influent lift station with manual trash screen
➢ Dual 3.75 MGD aeration basins with mechanical aerators
➢ Dual final clarifiers with sludge, return
➢ Belt press for sludge
➢ Sludge dryer
➢ Settling ponds
➢ Effluent disinfection equipment
This facility is located at the former Cranston Print Works plant in Fletcher on
Route 25 in Henderson County, and
2. Discharge from said treatment works at the location specified on the attached map
into the French Broad River, classified WS-N waters in the French Broad River
Basin.

BUNQQl+' _E C _
-, \.^ t .I HENDEON- �� \\ idw -r • •
MU P ''`AIRPORT •� '� {
O, L - -
1
;1v,nas ch-
kn
,ICT. rJ
IT �` UFB 19 �-•ty ; �'�.J 1 °c \ a
in
coo
Y Pigs
UFB SGµ.r� .'
iJ lj� LAT. tt"r I4 d O` y `'`r �'F` �CLOII •'\� f%t 1' 1
ROAD U 23 ' • Strip Wei
�� •. Butler ari ae e p " '-
70
Latitude: 35°24' 43"
Longitude: 82°32' 18.
Quad # HNE
Stream class: wS-ty
Subba, in 40302
Receivirg Stream wench Bmad River
NC0000094
Fletcher Warehousing
Company
Facffi
a
J
Location`
k
North
SCALE 1:24000

Permit NC0000094
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit until expiration, the Permittee is
authorized to discharge from outfa11001. Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENTS:
,�; {Y ` LIMITS a *r
F MONITORING REQUIREMENTS
CHARACTERISTICSt� 3
zapt
V A A
k" Monthly `'
Daily
Measurement
Sample,Type
=Sam IeWcationl
�" t a � x
r
Flow
0.01 MGD
Continuous
Recording
Effluent
BOD, 5 day 20°C
26.0 m /L
39.0 m /L
Weekly
Grab
Effluent
Total Suspended Solids
30.0 m L
45.0 m L
Weekly
Grab
Effluent
NH3 as N
Weekly
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
Effluent
Upstream & Downstream
Fecal Coliform (geometric mean)
200/100 mL
400/100 mL
Weekly
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine
28p /L
2/Week
Grab
Effluent
Total Nitrogen NO2+NO3+TKN
Quarterly
Grab
Effluent
Total Phosphorus
Quarterly
Grab
Effluent
Temperature (2C)
Weekly
Grab
Effluent
Upstream & Uownstream
H3
Weekly
Grab
Effluent _
Footnotes:
1. Upstream = upstream at the Butler Bridge; Downstream = downstream at the Fanning Bridge.
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other, than trace amounts.

THE
VAN WINKLE
LAW F I RM
Marla Tugwell Adams*
Jones P. Byrd
Guy F. Clerici
Carolyn Lloyd Coward
Dale A. Curriden
Roy W. Davis, Jr.
Tracy L. Diefenbach
Cynthia W. Eller
W. Perry Fisher II
Stephen J. Grabenstein
Robert H. Haggard
Larry C. Harris, Jr.
W. James Johnson
Diana Armatage Johnston*
Craig D. Justus
John G. Kelso
Barry B. Kempson
Caroline T. Knox
Brian F. D. Lavelle
Armistead M. Long
Esther E. Manheimer
Larry S. McDevitt
W. Carleton Metcalf
Anna S. Mills
Mark A. Pinkston
Suzannah M. Plemmons
Michelle Rippon
Adam L. Shealy
Philip J. Smith
Albert L. Sneed, Jr.
Bradley A. Stark
O.E. Starnes
Allan R. Tarleton
Michael M. Thompson
Claire M. Vujanovic
David M. Wilkerson
Stephen B. Williamson
Jeffrey D. Zentner
July 27, 2007
11 Nort#<°.M2ii3$$C1Y!7�,2$80i
P.O. Box 7376, Asheville; NC 28-80.2-,-7�376---.. - :. • 1.1..
TEL 828-258-'-)rl9lvabb.dadlaeb#irm.eena— ---,
VIA FACSIMILE 828-299-7043 and US MAIL
Mr. Roger Edwards
North Carolina Department of Environmental
and Natural Resources
Division of Water Quality
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: Fletcher Warehousing Company
Permit No. NC0000094
Dear Mr. Edwards:
I am writing on behalf of Fletcher Warehousing Company to request
modification of its permit referenced above. This permitee previously held a
permit which allowed it to discharge over 4,000,000 gallons per day. The
current permit was reduced, but that reduction is too great to handle the
practical and day to day needs of the permitee. Attached is a letter dated June
20, 2007 from Civil Design Concepts, PA. It indicates that the runoff
calculations from the impervious surface on the property for a 10-year storm
event would be 821,416 gallons. For these reasons, I would request that the
permit be modified to change the flow limitations to 821 ngd.
I appreciate your assistance in this matter. Please give me a call upon
your receipt of this letter so that we might discuss this matter further.
WPF/skh
*Of Counsel
Van Winkle, Buck, Wall, Starnes and Davis, P.A.

CIVIL DESIGN CONCEPTS, PA
June 20, 2007
Charles Owen, III
Fletcher Crossing Industrial Park
P.O. Box 188
Fletcher, NC 28732
Re: Fletcher Crossing Project
CDC Project No.10730
Dear Mr. Owen,
Attached are the approximate calculations/hydrographs to determine the amount of storm water
runoff being transported and treated at the existing treatment facility. It appears that a roof
leader/storm sewer system connects the runoff from the impervious buildings to the treatment
facility. The attached runoff calculations ,are for a two-year and 10-year storm event using the
total square footage of the connected buildings (approximately 279,000sf). During a two-year
(24 hour) storm event, we calculated that storm water runoff volume would be approximately
75,250 cubic feet or 562,870 gallons. For the 10-year storm event, the amount of runoff would
be approximately 109,815 cubic feet or 821,416 gallons. We calculated these volumes using
the SCS method in HydroCad with a five-minute concentration time and a CN=98.
Please feel free to contact Mark Cathey or myself at our office if you have any questions or '
require any additional information.
SAACADU 0730Wocs\co2OjuneO7.doc
200 Swannanoa River Road, Asheville, NC 28805 Phone [phone] Fax [phone]
PO Box 5432, Asheville, NC 28813

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PERVIOUS AND IMPERVIOUS AREAS lt:y000,*— 7.110,9WANNANIIA RIVER ROADASHEVILLE, NO 28805
FLETCHER CROSSING c PHONE FAX (628(828)) 252-536252-5388
5
CIVIL DESIGN CONCEPTS PA
FLETCHER CROSSING — HENDERSON COUNTY, NC 4w.�� "ttp:liwww.civildesigneoncepts.com

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arehousing (NC0000094)
Subject: Re:, Fletcher Warehousing (NC0000094)
Date: Mon, 27 Jun 2005 10:42:45 r0400
From: Sergei Chernikov <[e-mail]>
Organization: NC DENR DWQ
To: Roy Davis <[e-mail]>
Roy,
I am a little bit familiar with their situation because I have done a permit modification about a year ago
(reduces sampling frequency). I spoke to consultant and told him that they have to remove stormwater from
WWTP and this will alleviate their flow problems. He told me that they will do it and that option was
investigated for 2 years, and they have decided to proceed. They have also requested increase in permitted
flow, but I have not allowed it and explicitly stated in the letter that they have to reconfigure their
stormwater system. However, they have not done 'it yet. At this point we have no other option but to issue
the permit as is and continue to issue fines- for all permit violations, including unpermitted discharge to
Cane Creek. It should force them to find and alternative to existing wastewater treatment situation.
Serge
Roy Davis wrote:
Yes. the wwtp needs to be taken out of operation. The wwtp was origionally
constructed with a hydraulic capacity probably greater than 4 mgd to serve
Cranston Print Works. Cranston closed down and the property was acquired by
Charles Owen who in turn leases the property out for use as a warehouse. The
wwtp'now receives only a few hundred gallons per day of domestic wastewater
plus some waste activated sludge from area package plants. Steel structures
and mechanical components are badly deteriorated. The plant is operting as
an aerobic lagoon. The current NPDES pertmit allows the discharge"of 10,000
gpd of treated ww. During conditions of high ground water arid/or rainfall
flow violations occur. I should add that warehouse roof drains go to the
wwwtp. This situation has continued for several years. It is now time to
move on. Stan Littlejohn with Fletcher Warehousing has been looking at
alternative wwt schemes f'or.the past several'months. Pumping to public sewer
is an option. The permit"allows discharge of treated ww to the French Broad
River. The effluent outfall was undermined by last September's flooding and
is now leaking treated ww to Cane Creek which is not allowed by the permit.
This is not an environmental problem but rather an administrative one. The
company needs to find an appropriate wwts. We need to push the Company into
finding an alternative to the present situation. Roy Davis
Sergei Chernikov wrote:
Roy,
I have started working on the renewal of the Fletcher permit. Please let
me know.if you have any issues that have to be addressed.
1 of 2 6/27/2005 10:42 AM

arehousing (NC0000094)
Thank you!
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
Roy Davis - Roy.DavisCncmail.net
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
2 of 2 6/27/2005 10:42 AM

z /o
(� L / 1

NPDES RENEWAL PACKAGE
FLETCHER WAREHOUSING COMPANY
PERMIT No. NC0000094
Prepared for:
Plecther Warehousing Company
PO Box 457
Swannanoa, NC 28778
Prepared by:
Goldie & Associates, Inc.
210 West North Second Street
Seneca, SC 29678
April 2005
7RAR�2 0 2005
Wh,TER QUALITY SECTION
:�HFVILLE REGIONAL OFFIC

PEIt1VIIT F'OIt1VI
(Short Form Q

NPDES PERMIT APPLICATION - SHORT FORM C-Manufacturing
For manufacturing or commercial facilities with a discharge <1 MGD
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
http://h2o.enr.state.nc.us/NPDES/
NPDES Permit Number INCO000094
1. Contact Information:
Facility Name
Owner Name
Street Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
County
Operator Name
Street Address
City
State / Zip Code
Telephone Number
Please print or type
Fletcher Warehousing Company
Fletcher Warehousing Company
PO Box 457
Swannanoa
NC 28778
( 828) 298-6802
( 828) 299-0901
stan.littlej ohn(csprings. c om
Henderson
Goldie and Associates (Contracted WWTP Operations)
210 W. North Second Street
Seneca
SC, 29678
( 864) 882-8194
2. Location of facility producing discharge:
Check here if same as above ❑
Facility Name (If different from above)
Street Address or State Road 4600 Hendersonville Highway (Highway 25)
City Fletcher
State / Zip Code NC, 28732
County Henderson
3. Ownership Status: .
Federal ❑ State ❑ Private ❑ Public ❑
4. Standard Industrial Classification (SIC) code(s): 4226-9906 Textile Warehousin
5. Number of employees:. < 25
6. Principal product(s) produced:_ Warehousing Only
Principal raw material(s) consumed: N/A
7. Principal process(es): Warehousing Only
Page 1 of 3 Version —08103

NPDES PERMIT APPLICATION a SNORT FORM C-Man .facturing
For manufacturing or commercial facilities with a discharge <1 MGD
S. Amount of principal product produced or raw material consumed
IT.i.Ct _gnpriffi- mmn7/nf z rnnc,imorl
Product Produced or Raw Material
Product Produced or Raw Material
Consumed
Consumed
AVERAGE
PEAK
per Day
N/A
N/A
per Month
N/A
N/A
per Year
N/A
N/A
9. Check here if discharge occurs all year d , or circle the month(s) in which discharge
occurs:
January February March April
July August September October
May June
November December
Days per week discharge occurs: Seven
A10TE. If the facility has separate discharge points (outfalls) or multiple industrial processes,
include a schematic diagram of wastewater flow at the facility.
10. Types of wastewater discharged to surface waters only
Discharge per operating month
Flow
(GALLONS PER OPERATING MONTH
Sanitary - monthly average
Avg: 0.005 MGD, Avg Monthly Max: 0.09 MGD
Includes some stormwater from roof drains, etc.
Utility water, etc. - monthly average
N/A
Process water - monthly average
N/A
Monthly Average
Avg: 0.005 MGD, Avg Monthly Max: 0.09 MGD
total discharge (all types)
Includes some stormwater from roof drains, etc.
11. List all permits, construction approvals and/or applications (check all that apply and provide permit
numbers or check none if not applicable):
Tvpe
0 None
UIC.
® NPDES
PSD
= NESHAPS
Permit Number
NC0000094
Type
Non -Attainment
Ocean Dumping
Dredge/Fill Permits
RCRA
0
Other
Permit Number
Page 2 of 3 Version -08103

NPDES PERMLL- .aPP)LICATION - SHORT FORM u-Manufacturing
For manufacturing or commercial facilities with a discharge <1 MGD
12. Number of separate discharge points:
13. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
French Broad River
14. Do you add any chemicals that may be discharged? (Please list and explain source and
potential amounts.)
15. Is this facility located on Native American lands? check one)
YES F-I NO
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Stan Littlejohn Site Manager
Printed name of Person Signing Title
Signature
Date
Id5-
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $10,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $10,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 3 of 3 Version -08103

LOCATION MAP

2,
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UFB 19
Q31
N00000094 - Fletcher Warehousing Co.
35"24"43'" S Ub-B iisi n: 04-03-02
1-;'11"'VirLide: 82"32' 18"'
F8N'EIS',-.vI;md
S i rea rn Class- WS-IV
R---cLtvjm-, French Brfmd Ri\,,!r
0
U
yy 20
F B
2
2 0 5 0
rx
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(3a 0
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ROA-0
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i
0
Facility x
Location
Fletcher Wnr�housm2 Co

SLUDGE N LANAGEIVIENT

SLUDGE SUPPLEMENT
Flecther Warehousing Company
NPDES Permit No. NC0000094
Flecther Warehousing Company's wastewater facilities do not dispose of sludge or other
solids, and thus has no Sludge Management Plan in place. The facility was originally
designed.for handling 1.0 MGD of domestic and industrial wastewater; thus, the amount
of biosolids entering the plant at the now permitted flow of 0.1 MGD is easily treated and
degraded by the plant without need for removal. The facility does accept small amounts
of biosolids from other domestic treatment facilities, but these amounts remain
insignificant relative to the treatment capacity of the plant.

FILE
State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
I fflW.VW'J
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
WATER QUALITY SECTION
Mr. Stan Littlejohn
Warehouse Manager
Fletcher Warehousing Company
Post Office Box 457
Swannanoa, North Carolina 28778
Dear Mr. Littlejohn:
June 2, 2004
Subject: Compliance Evaluation Inspection
Status: In Compliance
NPDES Permit Number NC0000094
Fletcher Warehousing Company
Wastewater Treatment System
Henderson County
Attached is the report resulting from my May 28, 2004 inspection of the wastewater treatment
system serving Fletcher Warehousing Company. For your information I am also sending you a
copy of my December 20, 2002 inspection report cover letter which4summanzes my feelings
regarding the old Cranston Print Works wastewater treatment plant. Mike Holder with Goldie and
Associates is doing a good job of taking care of the wastewater treatment system.
Should you have need to discuss this or related matters please do not hesitate to call me at 1-
828-296-4659.
, I
'ncerely,
Roy M. Da 's
Environmental Engineer
Xc: Goldie and Associates
2090 U.S. Highway 70, Swannanoa, North Carolina 28778 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection e O
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 NC0000094 111 121 04/05/28 117 18 U 19 U 20 U
Remarks
211111111111111111111111111111111111111111111111166
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 CIA -----------Reserved---- —
67 I 169 70 U 71 U 72 U 73 W 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)
Fletcher Warehousing Company
10:00 AM 04/05/28
01/01/01
Exit Time/Date
Permit Expiration Date
Rt 25
Fletcher NC 28732
11:00 AM 04/05/28
05/10/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
William M. Holder/ORC/828-884-5589/
Name, Address of Responsible Officialfritle/Phone and Fax Number
William H Pott, II,PO Box 457 Swannanoa NC 28778//828-298-6802/ Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Flow Measurement 0 Operations & Maintenance
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
Roy M Davis ARO WQ//828-296-4500/828-299-7043
Signature anagement Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

NPDES yr/mo/day Inspection Type
31 NC0000094 I11 12 l 04/05/28 117 18 U
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Mike Holder with Goldie & Associates is doing a good job of taking care of the former Cranston Print Works
wastewater treatment system.
1

Permit: NC0000094 Owner - Facility: Fletcher Warehousing Company - Fletcher Warehousing Company
Inspection Date: 05/28/04 Inspection Type: Compliance Evaluation
Does the plant have general safety structures in place such as rails around or covers over tanks, pits, or wells? ❑ ❑ ❑
Is the plant generally clean with acceptable housekeeping? ❑ ❑ ❑
Comment:

5.b�P0-� �-1 ) 9 l bs
1

i
1*1
\ A On, 0 a —A
r
150
- . 1 �C , _ : ,, -AJ 11 _ _ . - /1 _ _ /-

e--,>

07/14/2004
Mr. Forrest R. Westall
North Carolina Department of Environment and Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Subject: Notice of violation NOV-2004-LV-0249
Permit No. NC0000094
Fletcher Warehousing Company
Henderson County
Dear Mr. Westall:
We are in receipt of the above notice of violation.
I have met with Mr. Roy Davis to discuss the options available in addressing the issues
raised by your correspondence. It is our belief that storm water runs from our buildings
on the property and into the wastewater system and increases effluent levels. We are
currently in the process of attempting to map the existing sewer and storm drain system.
Once we have completed the map we will be in a position to better address all the issues
and concerns.
Please feel free to call if there are any questions or concerns.
Sincerely,
Stan Littlejohn.
Vice President
Fletcher Warehousing Company
6515 Hendersonville Highway
Fletcher, NC 28732
LJ
IJUL 1 4 2004
10
WATER QUALITY SECTION

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Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
March 22, 2004
Mr. William H. Pott II
Fletcher Warehousing Company
P.U. Box 457
Swannanoa, North Carolina 28778
Subject: NPDES Permit Modification
Fletcher Warehousing Company
NPDES Permit NC000094
Henderson County
Dear Mr. Pott II:
Division personnel have reviewed your request for revision of sampling requirements and increase
in flow adjustment. We have reduced your sampling frequency for several parameters in accordance
with state regulations (Administrative code section 15A NCAC 2B .0500). New sampling
frequencies are presented in Attachment A(1.).
However, Lwe.a°�' re -unable to gran your request for inc��re'ase in permitted ofl v. Analyses of Discharge
Monitoring Reports for your facility indicated that since the conversion to Fletcher Warehousing
Company during 2001 and 2002 flow has been recorded only in March of 2001. Since-the,begintunR z�
Stermwater-can"be-discharged-in-accordance-with'S"tormwater G_eneraLP_ermit Please contact Ken
Pickle at 919-733-5083 (ext. 584) to obtain information on General Storinwater Permits.
If any parts, measurement frequencies or sampling requirements contained in this permit
modification are unacceptable to you, you have the right to an ad)udicatory hearing upon written
request within thirty (30) days following receipt of this letter. This request must be in the form of a
written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with
the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-
6714). Unless such demand is made, this decision shall be final and binding.
If you have any questions concerning this permit, please contact Sergei Chernikov at telephone
number [phone], extension 594.
Sincerely,
lan Klimek, P.E.
Director, Division of Water Quality
cc: Central Files n
1�151ic"y, e>Regional OfficeWate` uality'Section D v
NPDES Unit
Goldie and Associates
210 West North Second St. APR 19 2004
Seneca, SC 29678
WATERA ISECTION
North Carolina Division of Water Quality n / ASHEVILLE REGION 1715�&115
1617 Mail Service Center C�f� /�\FAX [phone]
Raleigh, North Carolina 27699-1617 ( ff �/��a—l�on the Internet at http://h2o.enr.state.nc.us/

Permit NC0000094
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning November 1, 2001 and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENT `;`
CHARAC'TERIStICS
.
LIMITS
MONITORINGREQUIREMENTS.
Monthly
Average .
Daily
Maximum .
Measuremeht
Frequency
Sample Type
Sample Locationl
Flow
0.01 MGD
Continuous
Recording
Effluent
BOD, 5 day (202C)
26.0 mg/I
39.0 mg/I
Weekly
Grab
Effluent
Total Suspended Solids
30.0 mg/I
45.0 mg/I
Weekly
Grab
Effluent
NH3 as N
Weekly
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
Effluent
Upstream & Downstream
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Weekly
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine
28pg/l
2/Week
Grab
Effluent
Total Nitrogen (NO2+NO3+TKN)
Quarterly
Grab
Effluent
Total Phosphorus
Quarterly
Grab
Effluent
Temperature (2C)
Weekly
Grab
Effluent
Upstream & Downstream
pH3
Weekly
Grab
Effluent
Footnotes:
1. Upstream = upstream at the Butler Bridge, Downstream = downstream at the Fanning Bridge.
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
F

Permit NC000009ti
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning November 1, 2001 and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored bthe
Permittee as specified below: y
Footnotes:
1. Upstre m =upstream at the Butler Bridge; Downstream =downstream at the Fanning Bridge.
2. ag. :,.,, d si no, •e ess
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

WATER POLLUTION CONTROL SYSTEM OPERATORS
CERTIFICATION COMMISSION
CLASSIFICATION
RATING SHEET FOR WATER POLLUTION CONTROL SYSTEMS
FACILITY iNFORMATI6N•
NAME OF FACILITY: Go.,
PC) Box 4,5 7
MAILING ADDRESS: _ S w A N N A N i C• 9
COUNTY:
CONTA T-PER I k� P07 �' C SON.1 TELEPHONE:
PERMIT NO: ,Ay C 00 0 0 09 LiCheck One: NC P"'- WQ HEALTH DP
ORC: J C7 1 h�' A I R 1 L TELEPHONE: ( S—V4 8 C� L�� l 0
RATING INFORMATION: (Before completing this section, please refer to pages 2-4)
PERMITTED FLOW: O MGD BNR? ' YES NO
CHECK CLASSIFICATION: WASTEWATER: 1 2 -Z 3 4
COLLECTION: 1 2 3 4
SPRAY IRRIGATION SUBSURFACE LAND APPLICATION
PHYSICAL/CHEMMICAL GRADE I _ _ GRADE II
RATED BY: Povv REGION: AS DATE: C-)J d G
1
REGIONAL OFFICE TELEPHONE NUMBER: & &T:

United States Envii, mtal Protection Agency
Form Approved
Washington, D.C. 20460
OMB
No. 2040-0003
EPA NPDES. Compliance Inspection. Report
Approval Expires 7-31-85
Section A: National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 2 u 3 NC0000094 t1 12 011127 17 18 L-1
�---�
19 IS 1 20
Remarks
IIIIIIIIIIIIIIIIILIIIII}IIIIIIIIIIIII11111111111
Reserved FacilityEvaluation- Rating • BI,
g QA
66
Reserved
67 L1-1J I I ( 169 70 15 u I 71 I onI 72 IuI 73 � 74
75 80
Section B: Facility Date
14ame and Location of Facility Inspected
Entry Time
Permit Effective Date
Fletcher Warehousing Co.
9:30 AM
)an 1, 2001
Exit Time/Date
Permit Expiration Date
10:30 PM
Oct 31,2005
',Jame(s) of On -Site Representative(s)/Title(s)
Phone No(s)
Fom Kilpatrick
1-828-884-5589
Vame, Address of Responsible Official
Title
3ill Pott
Vice President -Finance
Phone No.
Contacted
1-828-298-6802
Yes
Section C: Areas Evaluated During Inspection CODES ca S - Satisfactory M - Marginal U - Unsatisfactory
N - Not evaluated/Not applicable
S
Permit
Records/Reports
Facility Site Review
S
Flow Measurement
Laboratory
Effluent/Receiving Waters
N
Pretreatment
Compliance Schedules
Self -Monitoring Program
S
Operations & Maintenance
Sludge Disposal
Other:
S
N
S
S
S
S
S
a
Section D: Summary of Findings/Comments (Attach additional
sheets if necessary)
Dwen Manufacturing has no plan for future use of the wastewater trteatment plant serving Fletcher Warehousing beyound what is now taking place.
Vame{s Signature(s) of Inspector(s)
Agency/Office/Telephone
Date
toy M Da s
DWQ/ARO 828-251-6208
j i A� % 0j
ii n e of er
Agency/Office
Date
j o-•L1:-�0AACzq—Wa'4-�Q/ARO
828-251-6208
h� i Q
Regulatory Office Use Only
fiction Taken
Date
Compliance Status
Noncompliance
Compliance

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
WATER QUALITY SECTION
December 3, 2001
Mr. William H. Pott II
Vice President
Fletcher,Warehousing Company
Post Office Box 457
Swannanoa, North Carolina 28778
Dear Mr. Pott:
�f
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Compliance Evaluation Inspection
6Status: In Compliance
`gPDES Permit Number NC0000094
Fletcher Warehousing Company
astewater Treatment Plant
enderson County
Attached is a copy of the report resulting from my November 27,
2001 inspection of the wastewater treatment plant serving Fletcher
Warehousing Company. For the record I will state that you and ,Tom
Kilpatrick accompanied me during the inspection.
The plant continues to discharge
receiving rain. In addition to direct
still lead to the treatment plant. Mr.
system receives the occasional load of
the volume of water contained in the
waste activated sludge is insignificant.
based on whether or not we are
rainfall, roof and yard drains
Kilpatrick informs me that the
waste activated sludge. Given
various basins, the volume of
Thank you for taking the time to meet with me on the 27th. Please
do not hesitate to call me at 818-251-6208 should you need to discuss
matters relating to wastewater treatment.
S' cerely,
1
Roy M . D is ck�-
Environmental Engineer
Enclosure
xc: Tom Kilpatrick
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
N ichael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director.
Division of Water Quality
WATER QUALITY SECTIOI.
February 14, 2001
Mr. William H. Pott II
Vice President
Fletcher Warehousing Company
Post Office Box 457
Swannanoa, North Carolina 28778
Dear Mr. Pott:
m--"CDE14
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Compliance Evaluation Inspection
Status: In Compliance
NPDES Permit Number NC0000094
Fletcher Warehousing Company
Wastewater Treatment Plant
\Henderson County
On February 13, 2001, in the company of Mr. Tom Kilpatrick, I
inspected the wastewater treatment plant serving Fletcher Warehousing
Company. Attached is the report resulting from that inspection.
On the day of the inspection the plant was not discharging.
Mr.. Kilpatrick informs me that the system receives the occasional load
of waste activated sludge. I notice that your recently issued NPDES
Permit for this system calls for effluent fecal coliform limits to go
into effect on'November 1, 2001. You should make preparations to be
able to provide effluent disinfection by that date.
Roof and yard drains still lead to the wastewater treatment
plant. The presence of their stormwater will make the treatment
process more difficult to control should the plant ever be called upon
to treat a significant amount of wastewater. What would be involved
in the removal of those drains from the treatment plant?
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

William H. Pott
February 14, 2001
Page Two
Please do not hesitate to call me at 818-251-6208 should you need
to discuss matters relating to wastewater treatment.
Sincerely,
Roy M.)Davis
Environmental Engineer
Enclosure
xc: Tom Kilpatrick
00094CEI.01
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

AdL
United States En nmental Protection Agency
Form Approved
Washington, D.C. 20460
OMB
No. 2040-0003
EPA NP®ES Compliance Inspection. Report
Approval Expires 7-31-85
Section A: National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 u 2 LJ 3 1 N C0000094 11 12 010213 17 18 u
19 IS l 20 I` I
Remarks
Illlllllllillllllllllllllllllllllllllllllllllll'
Z' Reserved Facility Evaluation Rating BI QA
Reserved 66
67 I l I 169 70 5 71 1onI 72 IuI 73, 174
�L
75 80
Section B: Facility Date
Name and Location of Facility Inspected
Entry Time
Permit Effective Date
Fletcher Warehousing Co.
2:00 PM
Jan 1, 2001
Exit Time/Date
Permit Expiration Date
2:30 PM
Oct 31,2005
Name(s) of On -Site Rep resentative(s)/Title(s)
Phone No(s)
Tom Kilpatrick
1-828-884-5589
Name, Address of Responsible Official
Title
Bill Pott
Vice President -Finance
Phone No.
Contacted
1-828-298-6802
No
Section C: Areas Evaluated During Inspection CODES S - Satisfactory M - Marginal U - Unsatisfactory
. N - Not evaluated/Not applicable
S
Permit
Records/Reports
Facility Site Review
S
Flow Measurement
Laboratory
Effluent/Receiving Waters
N
Pretreatment
Compliance Schedules
Self -Monitoring Program
S
Operations & Maintenance
Sludge Disposal
Other: Row 36
S
N
S
S
S
S
S
Section D: Summary of Findings/Comments (Attach additional sheets if necessary)
On the day of inspection the wastewater treatment plant serving Fletcher Warehousing was not discharging.
Name(s) and Signa ure(s) of Inspector(s)
Agency/Office/Telephone
Date
Roy M. DA i' i
\
DWQ/ARO 828-251-6208
Signature of Reviewer /
1,
Agency/Office
DWQ/ARO 828-251-6208
Date
l
Regulatory Office Use Only
Action Taken
Date
Compliance Status
Noncompliance
Compliance

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
Division of Water Quality
P,
IWAL
0 % 00--ft AAAIIMIII i
NCDENii
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
WATER QUALITY SECTION
Mr. William H. Pott II
Vice President
Fletcher Warehousing Company
Post Office Box 457
Swannanoa, North Carolina 28778
Dear Mr. Pott:
December 20, 2002
Subject: Compliance Evaluation Inspection
Status: In Compliance
NPDES Permit Number NC0000094
Fletcher Warehousing Company
Wastewater Treatment System
Henderson County
Attached is the report resulting from my December 20, 2002 inspection of the wastewater
treatment system serving Fletcher Warehousing Company. Fletcher Warehousing continues to
use the system to provide treatment for the bathroom waste generated by about 40 employees
and to receive waste activated sludge disposed of by Goldie & Associates.
This is the way I see things. The existing treatment plant is completely inappropriate for the
volume of waste being treated, it is highly unlikely that it will ever be used again to treat a large
volume of wastewater and with the passing of every year it becomes less an asset and more a
pile of scrap. It is time to move on and provide appropriate waste water treatment. Given that
some plant sanitary sewers also carry storm water, I would suggest that selected bathrooms
around the plant be sewered and the decision made as to how that sewage will be treated. You
could make application for an Authorization to Construct Permit for a small package plant or
connect to the nearest public sewer. Given the proximity of public sewer that is my preference.
On the drive back to the office this morning it occurred to me that the Henderson County Health
Department might permit several septic tank -drain field systems at various locations around the
grounds to serve selected rest rooms. You could explore this option. At the conclusion of any
such project all sewers to the existing treatment plant should be severed.
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

William Pott
Page Two
December 20,; 2002
I should ad,d that any time the existing wastewater treatment system is discharging Fletcher
Warehousing must meet all permit and regulatory requirements. Including but not limited to
monitoring, compliance with permit effluent limits, operator visitation and providing continuous
flow recording:
We would want to see a proposed closure plan if you choose to abandon the treatment plant.
If you choose to go this route give me a call so I can sit down with the person preparing the plan.
Of great interest would be the removal and disposal of the aeration basin contents.
I would be interested in hearing what you are able to learn from Don Green on the subject of
getting storm water out of the treatment plant. Should you have need to discuss any of these
matters please do not hesitate to call me at 1-828-251-6208.
Sincerely,
Roy M. Da is `ram
Environmental Engineer
Xc: Tom Kilpatrick
00094CE1.02
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 501/6 recycled/10% post -consumer paper

z
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 J 2 1 5 1 31 NC0000094 111 121 02/12/20 117 18 Lj
19 I �20 LJ
Remarks
21IIIIIIIIIIIIIIIIIIIII1IIIIIIIIIIIIIIIIIIIIIIIIl61
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ----- ------- -------------- Reserved-----------
67 I 169 70 71 11 72 1,,1 73 � 74 751
LJ liLJ 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)
10:00 AM 02/12/20
01/01/01
Fletcher Warehousing Company
Exit Time/Date
Permit Expiration Date
Rt 25
Fletcher NC 28732
11:00 AM 02/12/20
05/10/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Thomas W. Kilpatrick/ORC/828-891-8165/
William Pott//828-298-6802/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
William H Pott II,PO Box 457 Swannanoa NC 28778//828-298-6802/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Miscellaneous Questions Permit Flow Measurement Operations & Maintenance
Records/Reports Self -Monitoring Program Sludge Handling Disposal Facility Site Review
Effluent/Receiving Waters Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The wastewater treatment plant serving Fletcher Warehousing far exceeds the needed hydraulic capacity.
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Roy M Davis ARO WQ//828-251-6208/828-251-6452
R__t�_Yy\�2-
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

to •,•
astewater Treatment System Performance Report
for
LU
� UJ C. L ``
G = E!
D W =z Fletcher CompanySEP 2 6 2000a
wCCL
(formerly Cranston Prim ors, Inc. WATER QUALITY SECTION
ASNEVILL- REGIQ�- AL OFFICE
for the Operating Period
January thru December, 1999
Preface
On July 20, 1999, the North Carolina General Assembly ratified House Bill 1160, the Clean Water
Act of 1999, which placed significant new reporting requirements on those entities that own or
operate wastewater treatment and collection systems. Specific items included:
1. A Spill Response Plan
2. Sewer Collection System Operation & Maintenance Plan
I Annual Performance Report
These new requirements became effective October 1, 1999.
This report is designed to meet the minimum requirements for the Annual Performance Report
established by the North Carolina Department of Environment and Natural Resources (DEPIlVR)
as set forth in their guidance document dated October 19, 1999.
This law was established to provide a mechanism for public oversight (and hopefully, to instill
public confidence) in owners and operators of wastewater treatment systems and in their efforts to
protect the waters of the state.

I. General Information
Facility/System Name:
Responsible Entity
Person(s) in Charge/Contact-
Applicable Permits:
Cranston Print Works WWTP
Ejcher Wareho�sin mf 7n
Tom Kilpatrick - Operator -in -Responsible Charge (ORC)
Bill Pott - Vice President
INIREMS M-4a s ,90
Description of Treatment Process, Collection System and Facilities Served:
Treatment Process - The treatment facility is a conventional "Activated Sludge" process
capable of treating 4.0 million gallons per day (MGD).
Collection System - The main collection system is a standard gravity design with 8-inch
diameter pipe and standard pre -cast manholes. The system has a Spill Response Plan and
an Operation and Maintenance Plan for the sewer collection system.
Facilities Served - The facility serves the warehousing operation with approximately 10
employees and serves to treat activated sludge removed from small wastewater treatment
package plants.
NOTE: This facility was originally constructed to serve Cranston Print Works, a textile
print and dye manufacturing entity. Cranston Print Works ceased operations and sold the
facilities. Fletcher Warehousing Company converted the manufacturing facility into a
warehousing facility. Fletcher Warehousing Company is keeping the WWTP facility in a
state of operational readiness to serve additional area wastewater needs should the need
arise. The facility is currently functioning much Iike an oxidation basin because of the very
low flow and is more than capable of treating the very low volume. Most water is
evaporated by running one blower. Occasional grab samples confirm the nature of the
confined wastewater. Occasionally, flow is observed over the effluent weir after a rain
event but is of such a low volume that is neither detected or recorded by the flow meter.
II. Performance
This system was a "no flow" facility for 1999. The system is "in compliance" with all
applicable NPDES permit conditions for the operating period.

III. Notification
A copy of this report is available to interested persons in the Offices of
DDK Environmental, Inc.
1 King Road
Pisgah Forest, NC 28768
or by contacting the office at 828-884-5589.
As required, three copies of this report is being provided to NCDEHNR Readers who have
questions or desire detailed information are invited to contact Tom Kilpatrick.
IV. Certification
I certify that under penalty of law that this report is complete and accurate to the best of my
knowledge.
Tom Kilpatrick, (SRC Date
This report prepared by:
DDK Environmental, Inc.
1 King Road
Pisgah Forest, NC 28768
Phone: [phone]
Fax:[phone]
February 24, 2000

NORTH kROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
January 24, 2000
Mr. William H. Pott II
Vice President -Finance
Owen Manufacturing Company
Post Office Box 457
Swannanoa, North Carolina 28778
Subject: Compliance Evaluation Inspection
Status: In Compliance
�/NPDES Permit Number NC0000094
Fletcher Warehousing Company, LTD
Wastewater Treatment Plant
Henderson County
Dear Mr. Pott:
Attached is the report resulting from my January 20,
2000 inspection of the wastewater treatment plant serving
the Fletcher Warehousing Company. I was accompanied in my
inspection by Tom Kilpatrick with DDK Environmental. A
small discharge was occurring at the time of the inspection
as a result of recent rains. Tom tells me that plant units
are operational with the exception of one aerator which is
experiencing a bearing problem. I view the treatment plant
as a valuable resource and encourage you to maintain it in
an operable condition until such time as its ultimate use is
decided upon.
Mark McIntire in our Central Office, is working on
transfer of Cranston Print Works NPDES Permit to Fletcher
Warehousing Company. Should you have need to discuss
matters relating to the wastewater treatment plant serving
Fletcher Warehousing please do not hesitate to call me at
828-251-6208.
Sincerely,
Roy M .
Environmental Engineer
Enclosure
xc: Tom Kilpatrick
00094E1.00
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801-2414
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

United States Envi mtal Protection Agency
Form Approved
Washington,, D.C. 20460
OMB
No. 2040-0003
PA NPDES Compliance Inspection Report
Approval Expires 7-31-85
Section A: National Data System Coding
-
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN I 21 1 3 NC0000094 11 12 000120 17 18 LJ
19 IS I 20 L`J
Remarks
I I I I I I II 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 I I I
I I I I I I I I I
Z' Reserved Facility Evaluation Rating BI QA
Reserved 66
67 [_M 69 70u 71 73 74
onL___
75 80
Section B: FacilityDate
Name and Location of Facility Inspected
Entry Time
Permit Effective Date
Fletcher Warehousing Co.
10:00 AM
Oct.1, 1995
Exit Time/Date
Permit Expiration Date
11:00 AM
Sep,30,2000
Name(s) of On -Site Represenfative(s)/Title(s)
Phone No(s)
Tom Kilpatrick
1-828-884-5589
Name, Address of Responsible Official
Title
Bill Pott
Vice President -Finance
Phone No.
Contacted
1-828-298-6802
No
iection C: Areas Evaluated During Inspection CODES S - Satisfactory M - Marginal U - Unsatisfactory
N - Not evaluated/Not applicable
S
Permit
Records/Reports
Facility Site Review,.'
S
Flow Measurement
Laboratory
Effluent/Receiving Waters
N
Pretreatment
Compliance Schedules
Self -Monitoring Program
$
Operations &Maintenance
Sludge Disposal
Other: Row 36
$
N
$
S
S
S
$
Section D: Summary of Findings/Comments (Attach additional sheets if necessary)
S small volume of septage and waste activated sludge is disposed of in this wastewater treatment plant.
Name(s) an nature(s) of Inspectors)
Agency/Office/Telephone
Date
boy M. Da is
1 1
DWQ/ARO 828-251-6208
Li � 00
iign wer
Agency/Office
Date
DWQ/ARO 828-251-6208
/
r
Regulatory Office Use Only
Action Taken
Date
Compliance Status
❑ Noncompliance
Compliance

f State of North Carolin
` Department of Environment
ti and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
Mr. William H. Pott II
Vice President
Fletcher Warehousing Company
P.O. Box 457
Swannanoa, North Carolina 28778
Dear Mr. Pott:
, Tk?
A
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
November 28, 2000
Ct j y I i.
2000
Sub) ect: Issuance of NPDES Permit NC0000094
Fletcher Warehousing Company
Henderson County
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between
North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently
amended).
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings
(6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision
shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local
governmental permit that may be required.
If you have any questions concerning this permit, please contact Natalie Sierra at telephone number
[phone], extension 551.
cc: Ce& 1 e
As � , gill- ; egon�a Mice Water • ualit ection;
NPDES Unit
Point Source Compliance Enforcement Unit
Technical Assistance & Certification Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
An Equal Opportunity Affirmative Action Employer
Sincerely,
Original Signed By
ckavid,�. Goodrich
err Stevens p p
Telephone [phone] FAX [phone]
VISIT US ON THE INTERNET a@ http://h2o.enr.state.nc.us/NPDES

Permit NC0000094
.f
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 1437215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Fletcher Warehousing Company
is hereby authorized to discharge wastewater from a facility located on
Route 25
Fletcher
Henderson County
to receiving waters designated as the French Broad River in the French Broad River
Basin
in accordance with effluent limitations, monitoring requirements and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective January 1, 2001.
This permit and authorization to discharge shall expire at midnight on October 31, 2005.
Signed this day November 28, 2000.
Original Signed By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0000094
SUPPLEMENT TO PERMIT COVER SHEET
Fletcher Warehousing Company is hereby authorized to:
1. Continue to operate an existing (4.0 MGD) extended aeration wastewater
treatment facility at a monthly average flow not exceeding 0.01 MGD which
includes the following components:
➢ Influent lift station with manual trash screen
➢ Dual 3.75 MGD aeration basins with mechanical aerators
➢ Dual final clarifiers with sludge return
➢ Belt press for sludge
Sludge dryer
➢ Settling ponds
➢ Effluent disinfection equipment
This facility is located at the former Cranston Print Works plant in Fletcher on
Route 25 in Henderson County, and
2. Discharge from said treatment works at the location specified on the attached map
into the French Broad River, classified WS-IV waters in the French Broad River
Basin.

r? �� \\ UFB 19 fI
I ti
i N 1 t Discharge Point
� t �� 1, i � • it f � y } ' � ' ` a)
�; 2050
dr
' r-
i
U
11�`J
`j e`er \`20
-- A.-
1 4 �
'JotfeSy
• U
• ! ��::. 2
Butler Badge
NC0000094 - Fletcher Warehousing Co.
Latitude:
35"24'43" Sub -Basin: 04-03-02
Longitude:
82'32'18"
Quad N:
F8NE/Skyland
Stream Class:
WS-IV
Receiving Stream:
French Broad River
Permitted Flow:
0.01 MGD
\
A:.
y �
Facility X
Location'
w^.y
/ Fletcher Warehousing Co.
94
no N t t her Warehousing
Fletcher Warehousing

Permit NC0000094
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
During the period beginning on the effective date of the permit until October 30, 2001, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored
by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS,.
LIMITS
MONITORING REQUIREMENTS
�z
Monthly
Average
Daily,,",*
Maximum.
Measurement
Frequency
Sample Type
Sample Location
Flow
0.01 MGD
Continuous
Recording
Effluent
BOD, 5 day 20TC
26.0 m /I
39.0 m /l
3/Week
Grab
Effluent
Total Suspended Solids
30.0 m /I
45.0 m /I
3/Week.
Grab
Effluent
NH3 as N
3/Week
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
Effluent
U stream & Downstream
Fecal Coliform (geometric mean)
Weekly
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine
3/Week
Grab
Effluent
Total Nitrogen NO2+NO3+TKN
Quarterly
Grab
Effluent
Total Phosphorus
Quarterly
Grab
Effluent
Temperature (IC)
Weekly
Grab
Effluent
Upstream & Downstream
FP—H3
3/Week
Grab
Effluent
Fnntnnte,'
1. Upstream = upstream at the Butler Bridge; Downstream = downstream at the Fanning Bridge
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC0000094
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning November 1, 2001 and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample Locationl
Flow
0.01 MGD
Continuous
Recording
Effluent
BOD, 5 day 20TC
26.0 m /I
39.0 m /I
3/Week
Grab
Effluent
Total Suspended Solids
30.0 m /I
45.0 m /I
3/Week
Grab
Effluent
NH3 as N
3/Week
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
Effluent
Upstream & Downstream
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Weekly
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine
28 ll
3/Week
Grab
Effluent
Total Nitrogen NO2+NO3+TKN
Monthly
Grab
Effluent
Total Phosphorus
Monthly
Grab
Effluent
Temperature (TC)
Weekly
Grab
Effluent
Upstream & Downstream
pH3
3/Week
Grab
Effluent
Footnotes:
1. Upstream = upstream at the Butler Bridge; Downstream = downstream at the Fanning Bridge.
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

F-
ONITED STATES:ENL!FitONMENTAL-PPOTECTIO.N,AGENCY
""���►
REGION 4 .
345 COURTLANO STREET. N.E. ATLANTA. GFOPG1A 80365 S.UPEANNO SEc fjo
To: File
FROM; Cy phi is GuYley; B`PA �[� ��.•
Xot h Carolin"a. Project• Qf€`3:csr
SUBJ: Cranston Print Works
Fletcher, Henderson County, North Carolina
NCD 003 150 539
This Site 1: spection' Pra ar.1-tization :(SIP) evaluated data
presented in the Site In$ ­Pe ct can -.of June.'1986 by:North C.arol.ina:
gal id-.a�zd Hazardous Waste. -Management Branch_
The processes at: Ghe Cxaz�ston Print'Vorks fac;:lity ird1_-4`de a.
textile printing and.fiLniahing opetation. Twd types of chtoniium-
containiaa.g waste are: generated on site; a wasbeVoLter from t.extile
printing operations,-and.chrome waste from stripping and plating
printing rollers. The source areas identified at the site:
chrome .plating and'stripping wastes were disposed in 3 wells on
s.ite. These wells had gravel bottoms Bet In the water table
aquifer. And 3 iinl-ined surface impoundments hold WWTP sludge
from th' pri nti operation..
A .removal, actzon has„ ec.eu red in regard to the:.3::chromium
waste. ..d disposal wells in .j g;i.:::, H.asecl on the 198:5- sampling data
and- .du�:' to .Tow targeti vain s :the site will not be:: gu-rsued .for
listii A dispositriori.°of No Further Remedial: Action Planned 'has.
been. assigned to the Cranston Print Works fac3;:lity.

North:* Carolina Superfund section
.-Ap'r-11. 10, 1.99.1.
Pace -2-
-: 2) Sludge Laqopr ;xr,
In the early 19-70's, sludge from our waste treat-
ment plant was.pumped into three (3) lagoons as a
means of wasting sludge-, which. is a requirement for
an activated sli-idqe waste treatment plant. This
sludge contained, trace trace- amounts of chrome (trivalent)
that was t.s.stp-d:.::.recentl*..Y..,to )ap 'less tha.n...the
'r acceptable: bia,�k4 ..pund level. N-0:'s-ludg.p..
has beeh..-jpum,�*.!6.4. into these: lagoons since --the
mid '1970 of sludge wasting -
op
re Fe-V-04 aped:
Z
Since then, however, these. lagoons were..permitted
a
by. the state Department -of Euman ResourPes, as a
-private landfill for. fly.ash from our coal-fired
boiler. These lagoo"ns havesince he'eh used for
disposal. Of our- boiler fl'Y: Ash. Orie lagoon is
,
closed.out According to state requirements, and
the other two,will be closed in the'near future.
that:'. t-ime,, we sites
properl-y: *Iqped out;.::.; Th ".tra.ce amounts of chrome.
e. t presen.t.-Is nq..:.carcinogenic
and not. at -threat to -:citizens or workers on site
and. 'Is:.: Voes backg.z. . :1.0ps than 1.6 ti pubd limit).
The amou.n-t:of 4,4826 tong. :of ohromin_- -that we. are listed as Having
is not -correct, We -do not feel that axiy type of cleanup is required
or in. anyway would be benefildlial.
Please review our file and let. us' know if you find -you can honor
our request.
'Very. truly yours,
'CRANSTON PRINT, -WORKS COMPANY
...... James A. Grant
Technical Manager
Fletcher Division
j -dhV

Attention: Mr. Jack Butler
Dear Mr. Butler:
I would like to thank you for getting back to us and advising us
as..how..t ..Q proceed.- Based on our aonvexsatiqn,. I would like to re
; 8 - 09ory.
::quest:, bat wO.,:be.mb0.
.moved into site C.'.t As we.A1.0dussed,
t .-urlile to.sUbstantiate this
I believe here i4.�;.§uf f iciont data in o
reque-6t, howi2ivor,. .:if :we need to furnish .additional i-nformation we
will rd -":be more thaC. n--glad to comply-:
mply,.
A our site situation bte`dks down into two pa.rts as
s. a reVie.w? xx
tollows:
1) Chrome Well:
It. the - late 197.0.' ko waste: from out chtome plating
area Was treat4d to make :a:`lkali)fte (conversion frc5m
hexava-l-Ont to trivalent) and placed in..a well in an..
as. cons-idered-:-the best- disposal'
ingoli�bj-e. state, .-This'w
at time and dc5na with state:*:,dpproval. In. 1.981, this:
think-ing.was c"harig"ad.- The .wall ­was cleaned out under
state supervision. and monitoring wells put in to
-m itqt any t act movement. Since then.- the grotind-
-Waer:Se.ction-::of-::the North Carolina:Dartment.,o,f
k turaI.Resources .and dtmunity Devel�5pment hasmoni-
tored. 'this and continue to -find no movement of any
0hr.ame in. the ground water.4,
[We. would, therefote- consider this site properly.
cleaned up and would reco0imend.continuing to
monitor as a -means to insure this in the futurej.
-Continued-
AN EMPLOYEE -OWNED COMPANY

Ms. Denise Bland
30 June 1986
Page 3
'Mo reinainder ,of. the residents -Within' 3 miles: of the :site are dependent on
groundwater, -which is: drawn primarily from • ijw bedroc .:aquifer,- :-Die- to. the
hydrog�-olog cal conditions at t1: site, the: *-Qater table and bedrock aquifersk6b on' as a single'-nydrologic unit, 'Chromium coritamination. of• the w.ator
table aquifer may the_ i�ef ore impact grouridiater u! sed_by local residents for.
drinking:; water supply. --- If you have any questions, please contact me at [phone].
Sincerely,
:.
Pat Dekii
.....
• . . 1tiaste. Maiagement Specrali.st .
Solid °and: Hazardous 'Waste:Management Branch
:.:.. BnviromentaL Health-Sedt-Wn
PD/tb./0184b,
,s

Ms. Denise Bland
30 June 1986
Page 2
Me three sludge lagoons and three chrome waste ..dli.spiaaal.. wells. are.:
potential sources of chromium contamination to. -groundwater-:"d::SItrface :water`'
at the site:. The sludge .lagoons are each approximatelf 2:.0. °'s lucre o f
deep axa:'Iie as close' as. 50 ft. from. Cane -Creek. The :sludg. zontains- 64 :84
mg/kg . total chromium, however, extractable chromium i:s. less' than . 05. mg/7:.
'rite slitdge..basins ate.uhlihed and the depth to the water:table has bee-Ti.
measured. at 2.1 - 4.7�. feet -below the site. The lagoons are therefore 'in:, or
close to, tie water .table. around the basins has been breached and
overflow to land .surface could .occur. Although facility slope is essefitially
zero, the proximity of surface water suggests that any overland mig:3ration or
groundwater flow will be toward .Cane -.Creek. The. three chrome wast6 disposal
wells were pumped out and sealed 1-11 1981. However, between 1973.:atd.19.81; the
wells contained waste having up to..98 mg/1 total chromium. Extractable
chromium was measured as high as 0.46 mg/.1. The wells were concrete -walled-'
but had only gravel. at the bottom: The wells were 10 - 15 ft. deep:,
therefore, flow from the bottom of the well could .enter the.:water. table
directly -
To date;- no evidence" bf :surface water contamination .is- ava=iTable.
Surface water 'and staiment ...say °lee. were. colleeted .during the . NC C�tCI A Unit -
inspect ion o€'Octdber....,.:1g85. No detectable levels of organic or
.inorganic'contaminants were:.measured in the water. In sediment:,. only: total
chrafnium l*ev&.I-s were measurable ranging from 3.9 - 11 mg/kg. Downstream
samples showed no significant increase. in chromium.
Groundwater contamination from'the chrome disposal' -wells has been
documented. Soil samples from borings in the saturated zone around the wells
showed total 'chromium. levels ranging fram --l::98 -. 53.66 ill" reported on
May 18; 19:$1. Total chromium levels exceeding background were in
groundwater from these. sane borings. fine monitoring well; 'sampled in ' .
November.19810 exceeded groundwater standards for chromium:-.: ..'itroniium was also
detect..d:-b ,-:Octoner .22i' 1985 'in 1 monitoring: well near .the :d 9b.6sal wells...
.:�.'w -p ntly, there..are no surface- water. �intakes...£ar.:drijiking ..watei:'
supply within 3 miles downstream of the:::site.: 'Howevet.,*;Crarist6n Print .Works
does have -a process tooter intake on Carie Creek at the .site.- In -addition.
surface water within 3 downstream miles' is used: for boating and fishing y'
local residents. Many of the local'residents, including Grans_ton Print Works,
have access to city water from either -. Asheville or Hendersonville, NC.

James G. Martin, Governor . Ronald H. Levine, MA.., M.P.E.
Phillip J. Kirk, Jr., Secretary 30 June 1986.State H.eaith:Director
ris.. Denise Bland
E;A NC CERC1•A Pro ject' Officer
Air and:-Hazardaua Material.Division
.3�5.-Ceurtland. stteei, N.k:
Athanta; - GA .0365 :.:. .
Dc,ai :Ms, Blaiici: .
Si &mcT-. Site litspection Report
Cranston'Print Works NC D003150539
us 25
Pletcher, NC
hnelosed please. find the.Site Inspection Report for the subject
site. Infotmat:ion and comlipsions about .t:he site:.are.-.based on. prior• field
investigations,, and sampl t g..,.data. conyersations with -'facility opi rators, and .,
State acid local:.:.gavernmerit:.officials,: grid an on -site inspection conducted 'by.
HC CBRCLA Unit:'person wi..:
C...:A on 1?r nt Works:. is ..a.. textile::01ht•ing. and finis iing �operatioit:..
locatekQ`.n W 25. in. laletther::.NC:.:. The. facility was,..built .and; began operating
arouid 150. Rion to 'this.; the site`was vacalit..kand:
Two types of chromium -containing waste are generated on site; a
wastewater from' -textile printing operations, and chrome waste from stripping
and plating 'printing rollers. Until 197% wastewater from printing operations
was discharged direc4y to the :French Broad'.River. In .1973. - astastewater .
treatmentplant. (WWTP) }as. contstructed on. site. Printing wastewater was
-routed.-through:t WWTP and sludge .was disposed o£ .:in three. on -site. sludge
A
basiri�x' lagoons'. These b.asi�ns were used -for. WW'TP slu�f .6 approximately :. r
1973.:-1975.: 7Also, in.1973,-the plant began chrome stripping and plating .
t e r-own.printing ro3lers:: Waste from chrome stripping operati.ans was
treated to reduce hexavalent chromium.and.'waste sludge teas disposed of in
3 w6iis-on site... These wells were used :.from 1973; until they :were pumped out
io 1981":at the -regUest. of the Division of Bnviroimtenial Management, NG -
7)epartinent of Natural Resources and Cwimunity Development. Since then, the
wells have been filled with. gravel and sealed at the top. Five monitgKiDg
wells were installeii around the old disposal wells to. monitor groundwater,
contamination. Currently, chrome waste is.shipped:of£ 'site for disposal and
WWTP sludge is sent to the Henderson County Landfill.

Property Boundary
Property Pounm Araving Scale
Approx. 550' 1" equals 100'.-
Property Sounds
Approx. 1559'
MRS, Waste Treatment System
CONTROL $fDO. , HOLDING. TANK
CLARiFER$
CONTACT TAN
OLD W, E BASINS SCHROME WASTE
TREATMENT
20' x 20'
I1 Treatment T
and Stora ea
e'
Property Boundary
Approx, 950'
r
W. T_ PaIkAc N011a;7
WAREh
(Fini Ned
4.
1977

Pp w
�VAstE
i
DIVISION OF ENVIRONMENTAL MANAUKUT
ENVIRON lEtiTAL -OPERATIONS swiMON
February 11. 1981
l+ir. Richard A. Y'ieweg, Resident t4anager
Crinston Print Works Company
Fletcher, North Carolina 28732
subject: haste Disposal Neils
Cranston Print Works CaMarW
Henderson Count:Y 4 KOrth Carpi i net
Dear Mr. Viewega.
It was recently brought to our attention that Cranston Print Works
Campany at its Fletcher% Korth Carolinas location has made use of wells
for purposes of underground *taste disposal. This is to infom You that
North Carolina setexral Statute 143w214.2(b) prohibits the disrhaege of
any waste to the 5roundwaters of this State DY Means of wells.
Cranston Print Works Comnp4rtY is to Imediately Cease the use of
wells for waste disposal in this State,the matter of groundwater
monitoring, clean-up or other actions to be taken. by the Campany in
this matter will be discussed during the February 13, 1981 meeting
in the Asheville Regional Office involving representatives of Cranston
Print Works Caipany and the Division of Environmental riana~gewnt. The
Cwoaimy should do nothing toward abandermot or destruction of its
Berea (3) waste disposal wells of this time as they May play a part
in fdture clean-up or mnitoring activities.
sincerely.
) 00 V t ,ZY
Han Link
.Regional hydrologist
M-ar
cc:- W. Marshall Rackley
Mr. Lee LaiMn
Mr. 0111 livers
Mr. R. L. Gaffney
Mr. Ted Kw
Mr. Heath P. Babson
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090 U.S. ; I K; I MAY
SWANNANOA NC28778

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NC
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CH, ARLES OWENS
FLETCHER WAREHOUSING Ci)t1hPANY
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2090 U.S. Highway 70, Swanna h ti,
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UNITED STATES POSTAL SERVICE
Environment
2090 U.S. Highway 70,
CDENR
NCDEN4
DIVISION OF WATER QUALITY
SURFACE WATER PROTECTION
2090 U.S. HIGHWAY 70
SWANHANOA NC 28778
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V �1' 2090 U.S. Highway 70;�_Swannanoa, Nc 28778
NCDENR
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CHARLES OWENS
FLETCHER WAREHOUSING COMPANY 3Zcerifltifled
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SW/ANNANOA NC 28778 ❑ Insured Mall C.O.D.
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NCDENR
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FLETCHER WAREHOUSING COl
POS-TLOFFICE BOX 457
-SWANNANOA NC 28778
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Fletcher Warehousing Co
P.O. Box 188
Fletcher, NC 28732-018
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Charles D. Owen. III ismCe J
Fletcher Warehousing Ccr pit; fiegistered
erMufle ail � ssMail
Post Office Box 188 etumReceipt for Merchandis,
Fletcher, NO 29732-0188 I r Insured Mail O.D.
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