NC0084638_Regional Office Historical File Pre 2018

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Water Resources IhrZ
October 23, 2018 LINDA CULPEPPER
Environmental Quality . Interim Director
Mr. Michael Shatynski
Solvay, USA, Inc.
504 Carnegie Ctr.
Princeton,New Jersey 08540
Subject: Compliance Evaluation Inspection
Rhodia Groundwater Remediation System
NPDES Permit No.NC0084638
Gaston County
Dear Mr. Shatynski:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on September 25,2018,by Edward Watson. The MRO would like to thank Mr. Teg
Williams and Mr. Scott Smida for their assistance during the site visit. The system is compliant with the
permit. However,the items listed below bare particular attention:
• Please keep the DWR informed as the proposed rebound study scheduled and planned shut-down
of the facility.
• Please submit a copy of the annual report to the DWR, so it can be used as support documentation
should a permit rescission be requested as a result of the rebound study.
• Please place a well tag on MW-34A.
A copy of the report is attached. The report should be self-explanatory. However, should you have any
questions regarding this report, please do not hesitate to contact Edward Watson at(704)235-2198 or by
email at [e-mail].
Sincerely,
—DocuSigned by:
A4•I14v H p; .c1
"—F161 FB69A2D84A3...
Andrew H. Pitner, P.G., Assistant Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
Attachment: Inspection Report
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue,Suite 301 I Mooresville,North Carolina 28115
704-663-1699

FILE
ROY COOPER
Governor
MICHAEL S.REGAN
T Secretary
Water Resources S.JAY ZIMMERMAN
Environmental Quality Director
May 8,2017
Mr. Michael Shatynski
Solvay, USA, Inc.
8 Cedar Brook Drive
Cranberry,New Jersey 08512
Subject: Compliance Evaluation Inspection
Rhodia Groundwater Remediation System
NPDES Permit No.NC0084638
Gaston County
Dear Mr. Shatynski:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on May 5,2017,by Edward Watson and Ori Tuvia. The MRO would like to thank Mr.
Teg Williams and Mr. Scott Smida for their assistance during the site visit.
A copy of the report is attached. The report should be self-explanatory. However, should you have any
questions regarding this report,please do not hesitate to contact me.
I may be reached by phone at(704)235-2198 or email [e-mail].
Sincerely,
Edward Watson, Hydrogeologist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
Attachment: Inspection Report
CC: NPDES (Derek Denard)
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue,Suite 301 I Mooresville,North Carolina 28115
704-663-1699

P
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 1ti 1 2 u 3 I NC0084638 111 121 17/05/05 117 18 I r•I 19 I c I 2011
21111111 111111111111111111111111I IIIIIIIIIII l66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ------ -Reserved
6711.0 I 70 711 u I 72 I i 731 I 174 71
l
1 1 1 1 1 1 180
LJ Section B: Facility Data Li
1
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) 10:10AM 17/05/05 16/05/01
Rhodia remediation site
207 Telegraph Dr Exit Time/Date Permit Expiration Date
Gastonia NC 280561306 11:30AM 17/05/05 20/08/31
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Scott Alan Smida/ORC/704-543-3286/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Michael Shatynski,8 Cedar Brook Dr Cranbury NJ 08512//732-516-1104/6098602203
No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
• Permit • Flow Measurement • Operations&Maintenar II Records/Reports
El Self-Monitoring Progran II Facility Site Review Compliance Schedules Effluent/Receiving Wat€
▪ Laboratory
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Edward Watson MRO GW///
Ori A Tuvia MRO WQ//704-663-1699/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.jtepta/100WAti--- /1 �
A0% a/A rt r) / rep /7
Page# 1

PIV
NPDES yr/mo/day Inspection Type (Cont.)
31 NC0084638 111 121 t 7/05/05 117 8
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
The recovery well next to the treatment system was reviewed during the inspection. The well was in
good order. The MW-23A broken hinged was reported to be repaired. However, the wells were not
reviewed during the site visit.
It is expected that the system will be shut down to observe rebound of the treated area. The GW
monitoring wells would be sampled to observe rebound and therefore indicate if remediation has been
completed to an acceptable level. If it has been determined that system be turned off is warranted, the
permittee will request permit rescission.
The rebound study will be for the period of one year. The MRO has requested that we be kept inform,
of any decisions made that would affect the permitted treatment system, so that we are made aware if
the permit will e rescinded, or if the system will be turned back on for futher remediation. The MRO is
also aware the system start-up may affect Chronic Toxicity testing negatively during system start up
due to chemical build-up that could occur during the rebound study period.
Page# 2

Permit: NC0084638 Owner-Facility: Rhodia remediation site
Inspection Date: 05/05/2017 Inspection Type: Compliance Evaluation
•
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new 0 0 ❑
application?
Is the facility as described in the permit? • 0 0 0
#Are there any special conditions for the permit? 0 IN 0 0
Is access to the plant site restricted to the general public? • ❑ ❑ 0
Is the inspector granted access to all areas for inspection? 0 0 0
Comment: The permit was present and available to be reviewed during the site visit. Teq Williams of
CH2MHill commented that they were considering shutting down the system to monitor site
rebound as part of a possible permit rescission.
It was requested by MRO, DWR that we be kept in communication with the DWM regarding
correspondence for system closure, so we are made aware that the permit was able to be
rescinded.
Compliance Schedules Yes No NA NE
Is there a compliance schedule for this facility? 0 I 0 0
Is the facility compliant with the permit and conditions for the review period? • 0 0 0
Comment: All systems were operating within the scope of the permit.
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? U 0 0 0
Is flow meter calibrated annually? • 0 0 ❑
Is the flow meter operational? • 0 ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? IN0 ❑ ❑
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • ❑ 0 0
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable • 0 ❑ 0
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Operations and maintenance records werre observed during the site visit. The records are
in good order.
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? ❑ I ❑ ❑
Page# 3

Permit: NC0084638 Owner-Facility: Rhodia remediation site
Inspection Date: 05/05/2017 Inspection Type: Compliance Evaluation
Laboratory Yes No NA NE
#Is the facility using a contract lab? • ❑ ❑ 0
#Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees • ❑ ❑ 0
Celsius)?
Incubator(Fecal Coliform)set to 44.5 degrees Celsius+/-0.2 degrees? 0 0 • 0
Incubator(BOD) set to 20.0 degrees Celsius+/- 1.0 degrees? ❑ ❑ II 0
Comment: ETS is performing Chronic Toxicity testing. Prisms Labs are performed analytical testing for
the chlorinated solvents. The ORC performspH calibrations on site prior to sampling filed
parameters.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? I 0 ❑ El
Are the receiving water free of foam other than trace amounts and other debris? • ❑ ❑ 0
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ❑
Comment: Effluent discharge was observed. No foams solids or odors were present.
Page# 4

r-.
Watson, Edward M
From: Shatynski, Mike <[e-mail]>
Sent: Thursday, May 18, 2017 4:42 PM
To: Watson, Edward M
Subject: Re: Permit NC0084638 Compliance Inspection
Edward
Thanks for a copy of the Inspection Report.
My mailing address is as follows:
Michael Shatynski
Remediation Project Manager
504 Carnegie Center
Princeton,NJ 08540
Best Regards
Mike
On Thu, May 18, 2017 at 2:15 PM, Watson, Edward M <edward.watsonancdenr.gov>wrote:
Mr. Shatynski,
I have attached the Compliance Inspection Report for the recent site visit. We initially attempted to mail this
report to you. However, the letter was returned as undeliverable. Can you submit an updated mailing
address? It is important that our files is kept up to date regarding permittee contact information.
Best Regards,
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
704 235 6040 Fax
i

I I"'ti
[e-mail]
610 E. Center Ave.
Suite 301
Mooresville,NC 28115
- - Nothing Compares--.f
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Mike Shatvnski
SOLVAY
www.solvay.com
Please note: We have moved our corporate offices. Effective January 25th 2015, our new address is 504 Carnegie Center,
Princeton, NJ 08540
This message and any attachments is intended for the named addressee(s)only and may contain information that is privileged and/or confidential.If you receive
this message in en-or,please delete it and immediately notify the sender.Any copying,dissemination or disclosure,either whole or partial,by a person who is not
the named addressee is prohibited.We use virus scanning software but disclaim any liability for viruses or other devices which remain in this message or any
attachments.
.:..............................
2

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Water Resources S. JAY ZIMMERMAN
Environmental Quality Director
May 8, 2017
Mr. Michael Shatynski
Solvay, USA, Inc.
8 Cedar Brook Drive
Cranberry,New Jersey 08512
Subject: Compliance Evaluation Inspection
Rhodia Groundwater Remediation System
NPDES Permit No.NC0084638
Gaston County
Dear Mr. Shatynski:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on May 5,2017,by Edward Watson and Ori Tuvia. The MRO would like to thank Mr.
Teg Williams and Mr. Scott Smida for their assistance during the site visit.
A copy of the report is attached. The report should be self-explanatory. However, should you have any
questions regarding this report,please do not hesitate to contact me.
I may be reached by phone at(704)235-2198 or email [e-mail].
Sincerely,
:,„f„/4.
Edward Watson, Hydrogeologist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
Attachment: Inspection Report
CC: NPDES (Derek Denard)
MRO Files
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office(610 East Center Avenue.Suite 301 I Mooresville,North Carolina 28115
704-663-I699

FILE
ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
Water Resources S. JAY ZIMMERMAN
Environmental Quality Director
May 17, 2017
William and Sloan Mayberry
2923 Rockwood Drive
Matthews,North Carolina 28106
Subject: Sampling Results
Permit No.: WI0300202
Mayberry Residence,UIC
Mecklenburg County
Mr. and Mrs.Mayberry:
The Mooresville Regional Office(MRO), Water Quality Regional Operations Section is presenting the
results of the sampling of your geothermal well heat pump system. The samples collected on March 4,
2017, are in conjunction with renewal of the subject permit. The samples were collected from both the
influent and effluent sample ports. The samples were analyzed by the Division of Water Resources
(DWR)laboratory for metals,nitrates,and other inorganic and organic constituents.
The results indicate, at the time of the sampling,exceedances of the 2L Groundwater standards was for
Iron,Aluminum, Copper, Chromium,Manganese, and Zinc at the effluent sampling port.
The MRO would like to perform a re-sampling event during the summer months while the system has
been operational for a while to determine if the system is stripping metals from the heat exchanger, or if
these results could be explained as artifact of system start-up.
Please contact Edward Watson, Hydrogeologist at the Mooresville Regional office should you have
questions regarding the results. I may be reached by phone at 704-235-2198 or email
([e-mail]).
Sincerely,
Edward Watson, Hydrogeologist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
Attachments: Lab Results Final Report
CC: Mecklenburg County Health Department(via email)
Shristi Shrestha,UIC Program Raleigh(via email)
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue,Suite 301 I Mooresville,North Carolina 28115
704-663-1699

AC37388 • North Carolina Division of Water Resources Water Sciences Section Laboratory Results
Loc.Descr.: SLOANE AND BILL MAYBERRY 2923 ROCKWOOD DR. Sample ID: AC37388
County: MECKLENBURG Collector: E WATSON VisitlD PO Number#
_ • Region: MRO Report To MRO Location ID:, W10300202-EFF Date Received: 04/06/2017
River Basin CTB Collect Date: 04/04/2017 Priority COMPLIANCE Time Received: 08_36
Emergency Collect Time: 12_00 Sample Matrix: GROUNDWATER Labworks LoginiD MSWIFT
COC Yes/No Sample Depth Loc.Type: Effluent Delivery Method NC Courier
Final Report Date: 6/17/17
Report Print Date: 06/17/2017
Final Report
If this report is labeled preliminary report,the results have not been validated. Do not use for Regulatory purposes.
Result/ Units Method Analysis
CAS# Analyte Name PQL Qualifier Reference Date Validated by
LAB
Sample temperature at receipt by lab 0.7 °C 4/5/17 MSWIFT
MIC
Coliform, MF Fecal in liquid 1 1 B2Q1 CFU/100m1 SM 9222 D-1997 4/5/17 ESTAFFORDI
Coliform, MF Total in liquid 1 2 Q1 CFU/lo0ml SM 9222 B-1997 4/5/17 ESTAFFORDI
NUT
Nitrate as N in liquid 0.02 0.34 mg/L as N EPA 353.2 REV 2 4/13/17 CGREEN
Nitrite as N in liquid 0.01 0.01 U mg/L as N EPA 353.2 REV 2 4/5/17 CGREEN
NO2+NO3 as N in liquid 0.02 0.34 mg/L as N EPA 353.2 REV 2 4/6/17 CGREEN
WET
Bromide 0.4 0.4 U mg/L EPA300.0rev2.1 4/5/17 CGREEN
Chloride 1.0 9.5 mg/L EPA300.0rev2.1 4/5/17 CGREEN
Fluoride 0.4 0.4 U mg/L EPA 300.0 rev2.1 4/5/17 CGREEN
Sulfate 2.0 140 mg/L EPA300.0rev2.1 4/5/17 CGREEN
Total Dissolved Solids in liquid 12 394 mg/L SM 2540 C-1997 4/5/17 CGREEN
MET
7440-22-4 Ag by ICPMS 1.0 1.0 U . ug/L EPA200.8 Rev5.4 4/17/17 ESTAFFORDI
7429-90-5 Al by ICP 50 6500 ug/L EPA 200.7 Rev4.4 4/13/17 ESTAFFORD1
7440-38-2 As by ICPMS 2.0 2.0 U ug/L • EPA 200.8 Rev5.4 4/17/17 ESTAFFORDI
7440-38-3 Ba by ICP 10 27 ug/L EPA 200.7 Rev4.4 4/12/17 ESTAFFORD1
7440-70-2 Ca by ICP 0.10 97 mg/L EPA200.7 Rev4.4 4/12/17 ESTAFFORD1
7440-43-9 Cd by ICPMS 0.50 0.50 U ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
7440-47-3 Cr by ICPMS 5.0 30 ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORDI
7440-50-8 Cu by ICPMS 2.0 110 ug/L EPA200.8 Rev5.4 4/17/17 ESTAFFORDI
7439-89-6 Fe by ICP 50 8900 ug/L EPA 200.7 Rev4.4 4/13/17 ESTAFFORDI
Hardness by Calculation 1.0 330 mg/L SM 2340B-1997 4/13/17 ESTAFFORD1
7440-09-7 K by ICP 0.10 4.1 mg/L EPA 200.7 Rev4.4 4/12/17 ESTAFFORD1
7439-95-4 Mg by ICP 0.10 22 mg/L EPA 200.7 Rev4.4 4/12/17 ESTAFFORD1
7439-96-5 Mn by ICP 10 120 ug/L EPA 200.7 Rev4.4 4/13/17 ESTAFFORD1
7440-23-5 Na by ICP 0.10 15 mg/L EPA200.7 Rev4.4 4/12/17 ESTAFFORD1
7440-02-0 Ni by ICPMS 2.0 19 ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
7439-92-1 Pb by ICPMS 2.0 2.4 ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
7782-49-2 Se by ICPMS 1.0 1.0 U ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
7440-66-6 Zn by ICPMS 10 150 ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
WSS Chemistry Laboratory>>1623 Mail Service Center,Raleigh,NC 27699-1623 [phone]
"Not Detected"or"U"does not indicate the sample is analyte free but that the analyte is not detected at or above the PQL.
Page 1 of 1

pLoc. 87 North Carolina Division of Water Resources Water Sciences Section Laboratory Results
Descr.: SLOANE AND BILL MAYBERRY 2923 ROCKWOOD DR. Sample ID: AC37387
County: MECKLENBURG Collector: E WATSON VisitlD PO Number#
Repi..`,,__ . MRO Reboil To MRO Location ID 4Y.^^94202-INF , Date Received: __. 04/05/2017
River Basin CTB Collect Date: 04/04/2017 Priority COMPLIANCE Time Received: 08_35
Emergency Collect Time: 11:16 Sample Matrix: GROUNDWATER Labworks LoginlD MSWIFT
COC Yes/No Sample Depth Loc.Type: Influent Delivery Method NC Courier
Final Report Date: 5/17/17
Report Print Date: 06/17/2017
Final Report
If this report is labeled preliminary report,the results have not been validated. Do not use for Regulatory purposes.
Result/ Method Analysis
CAS# Analyte Name PQL Qualifier Units Reference Date Validated by
LAB
Sample temperature at receipt by lab 0.7 °C 4/5/17 MSWIFT
MIC
Coliform, MF Fecal in liquid 1 1 B2Q1 CFU/100m1 SM 9222 D-1997 4/5/17 ESTAFFORDI
Coliform, MF Total in liquid 1 6 Q1 CFU/100m1 SM 9222 B-1997 4/5/17 ESTAFFORD1
NUT
Nitrate as N in liquid 0.02 0.40 mg/L as N EPA 353.2 REV 2 4/13/17 CGREEN
Nitrite as N in liquid 0.01 0.02 mg/L as N EPA 353.2 REV 2 4/5/17 CGREEN
NO2+NO3 as N in liquid 0.02 0.42 mg/L as N EPA 353.2 REV 2 4/6/17 CGREEN
WET
Bromide 0.4 0.4 U mg/L EPA 300.0 rev2.1 4/5/17 CGREEN
Chloride 1.0 9.4 mg/L EPA 300.0 rev2.1 4/5/17 CGREEN
Fluoride 0.4 0.4 U mg/L EPA 300.0 rev2.1 4/5/17 CGREEN
Sulfate 2.0 140 mg/L EPA 300.0 rev2.1 4/5/17 CGREEN
Total Dissolved Solids in liquid 12 407 . mg/L SM 2540 C-1997 4/5/17 CGREEN
MET
7440-22-4 Ag by ICPMS 1.0 1.0 U ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
7429-90-5 Al by ICP 50 50 U ug/L EPA 200.7 Rev4.4 4/13/17 ESTAFFORD1
7440-38-2 As by ICPMS 2.0 2.0 U ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORDI
7440-38-3 Ba by ICP 10 11 ug/L EPA 200.7 Rev4.4 4/12/17 ESTAFFORD1
7440-70-2 Ca by ICP 0.10 93 mg/L EPA 200.7 Rev4.4 4/12/17 ESTAFFORDI
7440-43-9 Cd by ICPMS 0.50 0.50 U ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
7440-47-3 Cr by ICPMS 5.0 5.0 U ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
7440-50-8 Cu by ICPMS 2.0 14 ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
7439-89-6 Fe by ICP 50 50 U ug/L EPA 200.7 Rev4.4 4/13/17 ESTAFFORD1
Hardness by Calculation 1.0 300 mg/L SM 2340B-1997 4/13/17 ESTAFFORD1
7440-09-7 K by ICP 0.10 3.6 mg/L EPA 200.7 Rev4.4 4/12/17 ESTAFFORDI
7439-95-4 Mg by ICP 0.10 16 mg/L EPA 200.7 Rev4.4 4/12/17 ESTAFFORDI
7439-96-5 Mn by ICP 10 24 ug/L EPA 200.7 Rev4.4 4/13/17 ESTAFFORD1
7440-23-5 Na by ICP 0.10 15 mg/L EPA 200.7 Rev4.4 4/12/17 ESTAFFORD1
7440-02-0 Ni by furnace 2.0 2.0 U ug/L EPA 200.9 Rev2.2 4/19/17 ESTAFFORDI
7439-92-1 Pb by ICPMS 2.0 2.0 U ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
7782-49-2 Se by ICPMS 1.0 1.1 ug/L EPA 200.8 Rev5.4 . 4/20/17 ESTAFFORD1
7440-66-6 Zn by ICPMS 10 39 ug/L EPA 200.8 Rev5.4 4/17/17 ESTAFFORD1
WSS Chemistry Laboratory>>1623 Mail Service Center,Raleigh,NC 27699-1623 [phone]
"Not Detected'or"U"does not indicate the sample is analyte free but that the analyte is not detected at or above the PQL.
Page 1 of 1

/SL4. ':'o, PAT MCCRORY
•• Governor
DONALD R. VAN DER VAART
Secrwrny
Water Resources
ENVIRONMENTAL QUALITY S. JAY ZIMMERMAN April 4,2016 REC[f.:IVED/NCDENRIDIWirector
APR 1 9 2016
Mr.Michael Shatynski
Remediation Project Manager WOROS
Solvay USA Inc. MOORES ILL :REGIONAL OFFICE
8 Cedar Brook Drive
Cranbury,New Jersey 08512
Subject: Issuance of NPDES Permit Renewal
Permit No.NC0084638
Solvay USA Inc.
Gaston County
Facility Class PC-1
Dear Mr. Shatynski:
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 Memorandum of
• Agreement between North Carolina and the U.S.Environmental Protection Agency dated October
• 15,2007 (or as subsequently amended).
•Please note that the receiving stream is listed as an impaired waterbody on the North Carolina draft
2016 303(d) Impaired Waters List for benthos and fish community. Addressing impaired waters
is a high priority with the Division, and instream data will continue to be evaluated. If there is
noncompliance with wed._effluent_limits and stream impairment-can-be-attributed-to-yourfacility,then mitigative measures may be required.
• Through further review,several changes were made to the draft permit sent to you
on October 21,2015:
• Electronic Discharge Monitoring Report(eDMR)requirements have been updated.Four main
revisions include: 1) Electronic reporting of DMR data is required effective December 21,
2016; 2) Electronic reporting requirements of compliance monitoring data and reports have
been added;3)A section has been added that requires permittees to identify the initial recipient
of their electronic submissions; 4) A section has been added on how to request an electronic •
reporting waiver.A footnote was added under Section A. (1.)to state"No later than December
21, 2016, begin submitting discharge monitoring reports electronically using NC DWR's
eDMR application system" and Special Condition A. (3.) was updated to reflect the eDMR
reporting deadline of December 21,2016.
No other significant changes were made to the draft permit. The final permit authorizes
the Solvay USA Inc.to discharge wastewater from its Solvay Gastonia GWR Site to UT
State of Narth Carolina I Environmental Quality I Water Resources
1617 Mail service Center Raleigh,North Carolina 27699-1617
919 707 9000

Page 2 of 4
to Crowders Creek, a class C water in the Catawba River Basin. The permit includes
discharge limitations or monitoring for flow,pH, 1,1 dichloroethylene,and ethylbenzene.
As identified previously, the renewal permit contains the following significant
changes from your current permit:
• Starting December 21, 2016, federal regulations require electronic submittal of all discharge
monitoring reports (DMRs) and specify that, if a state does not establish a system to receive
such submittals, then permittees must submit DMRs electronically to the Environmental
Protection Agency (EPA). The final NPDES Electronic Reporting Rule was adopted and
became effective on December 21,2015.
The requirement to begin reporting discharge monitoring data electronically using the NC
DWR's Electronic Discharge Monitoring Report(eDMR)internet application has been added
to your NPDES permit. [See Special Condition A.(3.)]
For information on eDMR,registering for eDMR and obtaining an eDMR user account,please
visit the following web page: http://deq.nc.gov/about/divisions/water-resources/edmr.
For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the
following web site: http://www2.epa.gov/compliance/proposed-npdes-electronic-reporting-
rule.
• There were no reported effluent pH violations during the last permit cycle. However,the
2014 Annual Groundwater and Surface Water Sampling Results provided by the permittee
indicates potentially low pH conditions in the extraction wells.Monitoring of pH in the
effluent limitations page has been maintained but the frequency has been reduced to monthly.
• Data from the extraction wells(influent)was reviewed from Sept.2011 through Oct.2014.
Influent data for 1,1-dichloroethene showed concentrations close to the allowable
concentration and ethylbenzene showed concentrations greater than the allowable
concentration.As pollutants of concern,monitoring requirements for 1,1-dichloroethene and
_ ethylbenzene were maintained in the permit at the minimum monitoring frequency of
quarterly in order to confirm continued compliance.Note the allowable concentrations are
from US EPA's National Recommended Water Quality Criteria for human health in surface
water.Please be aware that groundwater standards do not apply to a surface water discharge.
Chronic toxicity testing is put in all state permits with complex waste streams to document
the absence of toxicity. Methyl-tert butyl ether(MTBE),xylenes,toluene,ethyl-benzene,
chloroform,benzene,cis-1,2 dichloroethene,trichloroethylene,and 1,1-dichloroethene are all
•
shown to be present in the groundwater at this site.Therefore, chronic toxicity testing will
remain in the permit at the minimum monitoring frequency of quarterly.
Influent data for trichloroethylene and toluene were shown to be present in the groundwater
at concentrations less than half of water quality standards.Given the level of concentrations
of trichloroethylene and toluene in the groundwater and the consistent removal of these
parameters in the treatment system,monitoring for trichloroethylene and toluene was
removed from the permit based on the condition that chronic toxicity testing continue to be
performed.

Page 3 of 4
• Some of the wording has changed in Special Condition A. (2.), Chronic Toxicity Permit
Limit,please review each paragraph carefully.
Please note that the Division cannot grant your request to reduce site inspections.NC
. Administrative Code 15A NCAC 08G.0204 requires an Operator in Responsible Charge(ORC)
must visit the water pollution control system as often as is necessary to insure the proper
operation of the system but in no case less frequently than weekly for physical/chemical grade I
systems, including groundwater remediation systems.
The Division recognizes that the Permittee is.currently conducting semi-annual/annual
monitoring of extraction wells(CP-1,EW-2,EW-3,EW-4,and EW-5). The Permittee shall
submit all extraction wells monitoring results with its next permit renewal application.
This draft permit renewal is based on the application materials and influent/effluent data from the
last permit cycle. If any change of treatment process and/or operation mode (for example,
reduced effluent discharge frequency)has the potential to alter the effluent characteristics,the
permittee is required to notify the Division. The Division may require modification or revocation
and reissuance of the permit according to the requirements of NPDES Permit Standard
Conditions Part II/Section B/Item 13.
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
'Resources or any oth rFederal, State;or Local governmental permits that may be required.
If you have questions concerning this permit, please contact Yang Song by e-mail
([e-mail])or phone at(919) 807-6479.
Sincerely,
. ;ay Z.�f"*'I�;4.1 P.G.
1 irector, Division of Water Resources
Enclosure:NPDES Permit NC0084638
cc: NPDES Unit
Central Files
Mooresville Regional Office/Water Quality Program

Page4of4
e-copy:
South Carolina Department of Health and Environmental Control
Susan Meadows,Aquatic Toxicity Branch
Berme C.Hutson,Consultant,McGuireWoods LLP
Scott Smida,ORC, CH2M HILL North Carolina Inc.
Tegwyn Williams,Project Manager,CH2M HILL North Carolina Inc.

Permit NC0084638 •
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOUCES
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,
- Solvay USA Inc.
is hereby authorized to discharge wastewater from a facility located at
321 Telegraph Drive
Gastonia
Gaston County
to receiving waters designated_a&an-unnamed tributary to Crowders Creek in-the-Catawba-River-Basin ---- -- -
in accordance with effluent limitations,monitoring requirements, and other conditions set forth in Parts
I,II,III and hereof.
This permit shall become effective May 1,2016.
This permit and authorization to discharge shall expire at midnight on August 31,2020.
Signed this day April 4,2016.
• a•
AVt(Zjimmerale.
ector,Division of Water Quality
By Authority of the Environmental Management Commission •
Page 1 of 7

Permit NC0084638
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.
Solvay USA Inc.
•
is hereby authorized to:
1. Continue to operate an existing 0.1944 MGD groundwater treatment facility consisting of
extraction wells, a five plate air stripper, a flow recorder, and support equipment for the removal of
VOCs and other pollutants from captured groundwater.
This facility is located at 321 Telegraph Drive in Gastonia at Solvay USA Inc. in Gaston County.
•
2. Discharge from said treatment facility through Outfall 001 at a specified location (see attached
map) into an unnamed tributary to Crowders Creek, a waterbody classified as C waters within the
Catawba River Basin.
•
Page 2 of 7

Permit NC0084638
Part I
A.(1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq.,02B .0500 et seq.]
Beginning on the effective date of the permit and lasting until expiration,the Permittee is authorized to
discharge treated groundwater from OutfalI 001. Such discharges shall be limited and monitored) by
the Permittee as specified below: •
EFFLUENT LIMITS MONITORING REQUIREMENTS
CHARACTERISTICS. Monthly Daily Measurement Sample Sample
Average Mai.thm Fregtuency Type Location
Flow 2
0.1944 MGD Continuous Recorder Effluent
Not greater than 9.0 S.U.nor
pH less than 6.0 S.U. Monthly Grab . Effluent
1,1 Dichloroethylene 3, µg/1 Quarterly Grab Effluent
Ethylbenzene 3, µg/l Quarterly Grab Effluent
Chronic Toxicity 4 Quarterly Grab Effluent
Footnotes:
1. No later than December 21,2016,begin submitting Discharge Monitoring Reports electronically
using NC DWR's eDMR application system. See Special Condition A. (3.).
2. All volume of wastewater leaving the facility shall be monitored. If continuous flow monitoring is
not feasible, then the discharger shall record the approximate time that the discharge began and
ended, along with the instantaneous flow at the time of the effluent sampling.
3. Measurements shall be conducted at a minimum detection limit of 1.0 µg/l.
4. Chronic toxicity (Ceriodaphnia) P/F at 90 %; March, June, September and December; refer to
Special-Condition A-,(-2),-Toxicity-sampling shall occur in conjunction with-sampling-performed-for—
other monitored parameters(pH, 1,1 Dichloroethylene, and Ethylbenzene).
There shall be no discharge of floating solids or foam visible in other than trace amounts.
•
•
Part I,Page 3 of 7

Permit NC0084638
A.(2) CHRONIC TOXICITY PERMIT LIMIT(QRTRLY)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90 %.
The permit holder shall perform at a minimum,quarterly monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised December 2010,or subsequent
versions or"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-December
2010)or subsequent versions.The tests will be performed during the months of March,June,September,
and December.These months signify the first month of each three-month toxicity testing quarter assigned to
the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and
shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below
the permit limit,then multiple-concentration testing shall be performed at a minimum,in each of the two
following months as described in"North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure"(Revised-December 2010)or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form(MR-1)for the months in which tests were performed,using the parameter code TGP3B for
the pass/fail results and THP3B for the Chronic Value. Additionally,DWR Form AT-3 (original)is to be sent
to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh,North Carolina 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete,accurate,include all supporting chemical/physical measurements and all
_ concentration/response data,and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating
the facility name,permit number,pipe number,county,and the month/year of the report with the notation of
"No Flow"in the comment area of the form. The report shall be submitted to the Water Sciences Section at the
address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,monitoring will be
required during the following month.Assessment of toxicity compliance is based on the toxicity testing quarter,
which is the three month time interval that begins on the first day of the month in which toxicity testing is
required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Resources indicate potential impacts to the receiving stream,this permit may be re-opened and modified
to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control
organism survival,minimum control organism reproduction,and appropriate environmental controls,shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day
of the month following the month of the initial monitoring.
Part I,Page 4of7

Permit NC0084638
A.(3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports(DMRs)and program
reports and specify that,if a state does not establish a system to receive such submittals,then permittees must
submit monitoring data and reports electronically to the Environmental Protection Agency(EPA). The final
NPDES Electronic Reporting Rule was adopted and became effective on December 21,2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this permit
(Standard Conditions for NPDES Permits):
• Section B.(11.) Signatory Requirements
• Section D.(2.) Reporting
• Section D.(6.) Records Retention •
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D.(2.)and Section E.(5.)(a)I
Effective December 21,2016,the permittee shall report discharge monitoring data electronically using the
NC DWR's Electronic Discharge Monitoring Report(eDMR)internet application.
Monitoring results obtained during the previous month(s)shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring
data and submit DMRs electronically using the internet. Until such time that the state's eDMR application
is compliant with EPA's Cross-Media Electronic Reporting Regulation(CROMERR),permittees will be
required to submit all discharge monitoring data to the state electronically using eDMR and will be required
to complete the eDMR submission by printing,signing,and submitting one signed original and a copy of
the computer printed eDMR to the following address:
NC DENR/Division of Water Resources/Water Quality Permitting Section
AITTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
If a permittee is unable to use the eDMR_system due to a demonstrated hardship or...due.to-the-facility-being - ---• -
physically located in an area where less than 10 percent of the households.have broadband access,then a
temporary waiver from the NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms(MR 1, 1.1,2,3)or alternative forms approved by
the Director. Duplicate signed copies shall be submitted to the mailing address above. See"How to
Request a Waiver from.Electronic Reporting"section below.
Regardless of the submission method,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.
Starting on December 21,2020,the permittee must electronically report the following compliance
monitoring data and reports,when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports;and
• Clean Water Act(CWA)Section 316(b)Annual Reports.
The permittee may seek an electronic reporting waiver from the Division(see"How to Request a Waiver
from Electronic Reporting"section below).
Part 1,Page 5 of 7 •

Permit NC0084638
2. Electronic Submissions
In accordance with 40 CFR 122.41(lx9),the permittee must identify the initial recipient at the time of each
electronic submission. The permittee should use the EPA's website resources to identify the initial
recipient for the electronic submission.
•
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity(EPA
or the state authorized by EPA to implement the NPDES program)that is the designated entity for receiving
electronic NPDES data[see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type
of electronic submission and for each state. Instructions on how to access and use the appropriate
electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting
Rule is found at: http://www2.epa.gov/compliance/final-national-pollutant-discharge-elimination-system-
npdes-electronic-reporting-rule.
Electronic submissions must start by the dates listed in the"Reporting Requirements"section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic
reporting waiver,a permittee must first submit an electronic reporting waiver request to the Division.
Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written
approval at least sixty(60)days prior to the date the facility would be required under this permit to begin
submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and
• shall thereupon expire. At such time,monitoring data and reports shall be submitted electronically to the
Division unless the permittee re-applies for and is granted a new temporary electronic reporting waiver by
the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an
approved reporting waiver request may submit monitoring data and reports on paper to the Division for the
period that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements (Supplements Section B.(11.)(b)and Supersedes Section B.(11.)(d)l
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B.(11.)(a),or by a duly authorized representative of that person as described in Part 11,Section B.
(11.)(b). A person,and not a position,must be delegated signatory authority for eDMR reporting purposes.
For eDMR submissions,the person signing and submitting the DMR must obtain an eDMR user account
and login credentials to access the eDMR system. For more information on North Carolina's eDMR
system,registering for eDMR and obtaining an eDMR user account,please visit the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification[40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
• ACCEPTED:
Part I,Page 6 of 7

Permit NC0084638
'7 cent fy, under penalty of law, that this document and all attachments were prepared under my direction
or supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief true, accurate, and complete.I am aware that there are significant penalties
for submitting false information, including the possibility offines and imprisonment for knowing
violations."
5. Records Retention [Supplements Section D.(6.)1
•
The permittee shall retain records of all Discharge Monitoring Reports,including eDMR submissions.
These records or copies shall be maintained for a period of at least 3 years from the date of the report. This
period may be extended by request of the Director at any time[40 C}R 122.41].
•
•
•
• Part I,Page 7of7

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Latitude: 35° 12' 0"N Sub-Basin: 03-08-37 f..,•....-• .\
Longitude: 81° 12' 22"W 8-Digit HUC: 03050101 ,,,,,..J.,f„,.iy.,1,,;„ . ,,,,•)
' ''k,','•''' '' .. ''
Permitted Flow: 0.1944 MOD Stream Class: C
Facility Location
North Not to Scale
i
Receivn g Stream:UT to Crowders Creek
Solvay USA Inc. GWR NC0084683
Gaston County
1

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DEQ/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No.NC0084638
Facility Information
Applicant/Facility Name: Solvay USA Inc./Solvay Gastonia Closed Site
Ap leant Address: 8 Cedar Brook Drive; Cranbury,NJ 08512
Facility Addres$'. 321 Telegraph Drive; Gastonia,NC 28056
Permitted FIow: 0.1944 MGD
Type of Waste: Treated GWR wastewater from suspect chlorinated solvents and
gasoline products
. Facility/Permit Status: PC I/Active;Renewal
County: ; Gaston County
Miscellaneous_.
Receiving Stream: UT to Crowders Creek Regional Office: Mooresville
.Stream Classification: C 8-Digit HUC: 03050101
(Crowders Creek)
303(d)Listed? Permit Writer: Yang Song
Yes,biological
Subbasm!Stream Index 03-08-37/ 11-135fut1 Date: 3/20/2016
Drainage Area(mi.
2): -
Summer 7Q10 (efs) 0
Winter 7Q10(cfs): 0
30Q2 (cfs) : 0
Average Flow(Cfs) 0
IWC(%): 100 Lat. 35° 12' 0"N Long. 81° 12'22"W
BACKGROUND
Solvay USA Inc., formerly known as Rhodia Inc. and Rohne-Poulenc Inc., is the former owner
of a chemical manufacturing facility located at 207 Telegraph Drive, approximately 2 miles
south of Gastonia City Limits. In July 1994, the facility was sold to the B.F. Goodrich
Company. In 2001, the facility was sold to Noveon International, Inc. In June 2004, Noveon
became a wholly-owned subsidiary of the Lubrizol Corporation.
Solvay USA Inc. completed a Comprehensive Site Assessment and a Corrective Action Plan
(CAP) that addresses contaminated GW at this former site. To implement the final CAP, Solvay
USA purchased a 0.6 acre property adjacent to the site for construction and operation of a GW
Remediation System,which began operation in October 1996.
The GWR treatment is designed to remove chlorinated solvents and gasoline contaminates from
the captured groundwater at a maximum 135 gallon per minute (gpm) capacity. Initially, the
treatment system consisted of three GW recovery wells (CP-1, EW-2,and EW-3), an air stripper
unit with five trays, two off-gas carbon absorptions, and associated instrumentation. In October
1998 two more GW recovery wells (EW-4 and EW-5) were added. In June 2000 the two 3,000
pounds off-gas carbon adsorption units were permanently removed. Historically the maximum
effluent flow rate has been less than the design.
The permitted discharge for the treated GWR wastewater is to an adjacent unnamed stream on
the western boundary of the property. This stream continues SE for approximately one quarter
'of a mile where it discharges into an Unnamed Tributary(UT)of Crowders Creek. The UT flows
Fact Sheet
NPDES NC0084638
Page 1 of 3

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south for approximately 2 miles and it discharges into Crowders Creek. The section after
Crowders Creek receives this UT is classified C water and is listed in draft 2016 303(d) list as
impaired for benthos and fish community. Crowders Creek flows into South Carolina and is a
tributary to Lake Wylie.
HISTORY
The permit issued in 2011 removed methyl tert-butyl ether (MTBE) and xylene as monitoring
parameters,reduced.1,I-dichloroethylene monitoring frequency to quarterly, and added quarterly
monitoring for trichloroethylene. A. requirement of "measurements for trichloroethylene, 1,1-
dichloroethylene, ethylbenzene, and toluene be conducted at a minimum detection limit of 1.0
µg/L"was added in a footnote.
The permittee is requesting as part of this renewal, deletion of monitoring requirements for
ethylbenzene, toluene, and chronic toxicity; reduction of monitoring frequency to semi-annually
for monitored parameters; reduction of operator site visit frequency.
COMPLIANCE
Discharge Monitoring Reports (DMRs) have been reviewed for the period of January 2011
through June 2015. No violations were reported during this period. A recent staff report done by
the Mooresville Regional Office(MRO)was received on Dec. 9, 2014. The inspection found the
facility to be very reliable.
PERMITTING STRATEGY
Reasonable Potential Analysis(RPA)
The DMR data from January 2011 to March 2015 for trichloroethylene, ethylbenzene, toluene,
and 1,1-dichloroethylene were used to generate a RPA. No dilution is available, since the UT to
Crowders Creek has minimum/no flow.All sample values were below 1.0 µg/L (detection limit).
The effluent data shows the treatment process removing the defined effluent contaminates as
required,meeting any applicable water quality standards(WQS).
Data Review
The DMR data from 2011 through March 2015 was reviewed. The flow averaged 0.0113 MGD
—----with-a-maxirgum flow-of-0;(I84-6-MGD—The-same-data showed the-pig varying from-6:8-sito-
8.0 s.u. and averaging 7.7 s.u. Flow and pH are major permit parameter requirements and will
continue to be monitored and limited in the permit renewal.
Data from the extraction wells (influent) was reviewed from Sept. 2011 through Oct. 2014.
Influent data for 1,1-dichloroethene showed concentrations close to the allowable concentration
and ethylbenzene showed concentrations greater than the allowable concentration. Those two
contaminants were considered as parameters of concern. Monitoring requirements for 1,1-
dichloroethene and ethylbenzene were maintained in the permit at the minimum monitoring
frequency of quarterly in order to confirm continued compliance. Note the allowable
concentrations are from US EPA's National Recommended Water Quality Criteria for human
health in surface water. Please be aware that groundwater standards do not apply to a surface
water discharge.
Chronic toxicity testing is put in all state permits with complex waste streams to document the
absence of toxicity. Methyl-tert butyl ether (MTBE), xylenes, toluene, ethyl-benzene,
chloroform, benzene, cis-1,2 dichloroethene, trichloroethylene, and 1,1-dichloroethene were all
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Influent data for trichloroethylene and toluene were shown to be present in the groundwater at
concentrations less than half of water quality standards. Given the lower concentrations of
trichloroethylene and toluene,the continued chronic toxicity testing, and the consistent removal
of these parameters in the treatment system, monitoring for t ichloroethylene and toluene were
removed from the permit.
For clarity and to validate future data assessments, the narrative establishing a minimum
detection limit of 1.0 ug/L for permit toxicants will be maintained. Extraction wells monitoring
data will be required for future permit renewal to characterize the influent and assist in the permit
development.
•
Whole Effluent Toxicity
The permit requires quarterly chronic toxicity testing using ceriodaphnia dubia, at 90% effluent
concentration. Since January 2011 the facility has passed 17 of 17 toxicity tests.
SUMMARY OF PROPOSED CHANGES
In keeping with Division policies the following will be incorporated into the permit:
• Reduction of pH monitoring to monthly.
• Removal of trichloroethylene and toluene monitoring requirements.
• Addition of electronic DMR requirement.
• Update special condition A.(2) narrative.
. PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: February 9, 2016(estimated)
Permit Scheduled to Issue: March 29,2016 (estimated)
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please
• contact Yang Song at(919)807-6479 or email [e-mail].
NAME: DATE:
CoMN rrs:
No comments were received from Mooresville Regional Office—Water Quality Program.
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NPDES Permit Standard Conditions
Page 1of18
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.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,et.
seq.
Annual Average
The arithmetic mean of all"daily discharges"of a pollutant measured during the calendar year.In the case of fecal
conform,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 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_throug 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
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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).
DWR or"the Division"
The Division of Water Resources,Department of Environment and Natural Resources.
Effluent
- Wastewater-discharged-following-all treatment processes-from a water pollution-confrol-facilityorother-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).
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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
colifonn or other bacterial parameters or indicators,the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Resources.
Quarterly Average(concentration limit)
The arithmetic mean 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 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. Duty 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 CFR
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(bX8)of the Act,is subject to criminal penalties of$2,500 to$25,000 per day of violation,or
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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
Perniittees who own or operate facilities that primarily collect or treat municipal or domestic wastewater and have
an average annual flow greater than 200,000 gallons per day 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 chap 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 Resources/Water Quality Permitting Section
A[TENTION: 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 plant's 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 2011-394],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. Chances 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-p:gtt)-for 2 4=dinitrophenoi and for 2-methyl-4,6-dinitrophenol;and one-milli-gram Alter(-1-m$/L�fur
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);
(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 Dischar?e 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(j)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 defmition 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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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 Permitter shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introductionnvf 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 dosed 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 rate
an od7 r 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,
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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 122.44(j)(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 122.44(j)(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 II or Part IV
of this permit are as defined in 15A NCAC 02H.0903 and 40 CFR 403.3.
I. Sewer Use Ordinance(SUOI
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(t)(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 122.44(j)(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 Pennittee accepts wastewater from one or more satellite POTWs,the
IWS for the Pennittee 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 Iocal limits(i.e.,an
updated HWA or documentation of why one is not needed)[40 CFR 122.44].The Pennittee 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
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• 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 Permittee 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 ail 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(AtC)
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. [15A NCAC 02H.0906(b)(7)and.0905;NCGS 143-
215.1(a)(8)]
7. POTW Inspection&Monitoring of their lUs
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(SIUs)at least once per calendar year;
b. Sample all Significant Industrial Users(SlUs)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
--requirementsoutlined-in the-Division-approved pretreatment program,the industry's pretreatment permit-or-in-1-5A — -
NCAC 02H.0908. [15A NCAC 02H.0906(b)(5)and.0905;40 CFR 403.8(f)(1)(v)and(2)(iii);40 CFR
122.44(j)(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. [I5A 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 shall submit two copies of a Pretreatment Annual Report
(PAR)describing its pretreatment activities over the previous calendar year to the Division at the following
address:
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NC DENR/Division of Water Resources/Water Quality Permitting 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(Ms)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
Ills 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(6)(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 1-5—NCAC 02H:0908(f):[15A —
NCAC 02H.0908(0;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. [15A NCAC 02H
.0906(b)(9)and(10)and.0905;40 CFR 403.8(f)(3),403.9(bx3)]
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 40 CFR 403.18, 15 NCAC 02H.0114 and 15A NCAC 02H.0907.
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FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No.NC0084638
Facility Information
Applicant/Facility Name: Solvay USA Inc. /Solvay Gastonia Closed Site
Applicant Address: 8 Cedar Brook Drive; Cranbury,NJ 08512
Facility Address: 321 Telegraph Drive; Gastonia,NC 28056 _
Permitted Flow: 0.1944 MGD
Type of Waste: Treated GWR wastewater from suspect chlorinated solvents and
gasoline products
Facility/Permit Status: PC I/Active; Renewal
County: Gaston County
Miscellaneous
Receiving Stream: UT to Crowders Creek Regional Office Mooresville
Stream Classification: C 8-Digit HUC 03050101
(Crowders Creek)
303(d)`Listed? Permit Writer: Yang Song
Yes, biological
Subbasin/Stream Index 03-08-37/ 11-135futl Date: 10/9/2015
Drainage Area(mi2): -
Summer 7Q10 (cfs) 0Z )
Winter 7Q10 (cfs): 0
f � fi^tir
30Q2 (cfs): 0
Average Flow(cfs): 0
IWC (%): 100 Lat. 35° 12' 0"N Long. 81° 12' 22"W
BACKGROUND
Solvay USA Inc., formerly known as Rhodia Inc. and Rohne-Poulenc Inc., is the former owner
of a chemical manufacturing facility located at 207 Telegraph Drive, approximately 2 miles
south of Gastonia City Limits. In July 1994, the facility was sold to the B.F. Goodrich
Company. In 2001, the facility was sold to Noveon International, Inc. In June 2004, Noveon
became a wholly-owned subsidiary of the Lubrizol Corporation.
Solvay USA Inc. completed a Comprehensive Site Assessment and a Corrective Action Plan
(CAP) that addresses contaminated GW at this former site. To implement the final CAP, Solvay
USA purchased a 0.6 acre property adjacent to the site for construction and operation of a GW
Remediation System, which began operation in October 1996.
The GWR treatment is designed to remove chlorinated solvents and gasoline contaminates from
the captured groundwater at a maximum 135 gallon per minute (gpm) capacity. Initially, the
treatment system consisted of three GW recovery wells (CP-1, EW-2, and EW-3), an air stripper
unit with five trays, two off-gas carbon absorptions, and associated instrumentation. In October
1998 two more GW recovery wells (EW-4 and EW-5) were added. In June 2000 the two 3,000
pounds off-gas carbon adsorption units were permanently removed. Historically the maximum
effluent flow rate has been less than the design.
The permitted discharge for the treated GWR wastewater is to an adjacent unnamed stream on
the western boundary of the property. This stream continues SE for approximately one quarter
of a mile where it discharges into an Unnamed Tributary(UT) of Crowders Creek. The UT flows
Fact Sheet
NPDES NC0084638
Page 1 of 3

south for approximately 2 miles and it discharges into Crowders Creek. The section after
Crowders Creek receives this UT is classified C water and is listed in 2014 303(d) as impaired
for benthos. Crowders Creek flows into South Carolina and is a tributary to Lake Wylie.
HISTORY
The permit issued in 2011 removed methyl tert-butyl ether (MTBE) and xylene as monitoring
parameters,reduced 1,1-dichloroethylene monitoring frequency to quarterly, and added quarterly
monitoring for trichloroethylene. A requirement of "measurements for trichloroethylene, 1,1-
dichloroethylene, ethylbenzene, and toluene be conducted at a minimum detection limit of 1.0
µg/L"was added in a footnote.
The permittee is requesting as part of this renewal, deletion of monitoring requirements for
ethylbenzene, toluene, and chronic toxicity; reduction of monitoring frequency to semi-annually
for monitored parameters;reduction of operator site visit frequency.
COMPLIANCE
Discharge Monitoring Reports (DMRs) have been reviewed for the period of January 2011
through June 2015. No violations were reported during this period. A recent staff report done by
the Mooresville Regional Office(MRO) was received on Dec. 9,2014. The inspection found the
facility to be very reliable.
PERMITTING STRATEGY
Reasonable Potential Analysis(RPA)
The DMR data from January 2011 to March 2015 for trichloroethylene, ethylbenzene, toluene,
and 1,1-dichloroethylene were used to generate a RPA. No dilution is available, since the UT to
Crowders Creek has minimum/no flow. All sample values were below 1.0 µg/L (detection limit).
The effluent data shows the treatment process removing the defined effluent contaminates as
required,meeting any applicable water quality standards(WQS).
Data Review
The DMR data from 2011 through March 2015 was reviewed. The flow averaged 0.0113 MGD
with a maximum flow of 0.0846 MGD. The same data showed the pH varying from 6.8 s.u. to
8.0 s.u. and averaging 7.7 s.u. Flow and pH are major permit parameter requirements and will
continue to be monitored and limited in the permit renewal.
Data from the extraction wells (influent) was reviewed from Sept. 2011 through Oct. 2014.
Influent data for 1,1-dichloroethene showed concentrations close to the allowable concentration
and ethylbenzene showed concentrations exceeding the allowable concentration. Those two
contaminants were considered as parameters of concern. Monitoring requirements for 1,1-
dichloroethene and ethylbenzene were maintained in the permit at the minimum monitoring
frequency of quarterly in order to confirm compliance. Note the allowable concentrations are
from US EPA's National Recommended Water Quality Criteria for human health in surface
water. Please be aware that groundwater standards do not apply to a surface water discharge.
Chronic toxicity testing is put in all state permits with complex waste streams to document the
absence of toxicity. Methyl-tert butyl ether (MTBE), xylenes, toluene, ethyl-benzene,
chloroform, benzene, cis-1,2 dichloroethene, trichloroethylene, and 1,1-dichloroethene were all
still shown to be present in the groundwater at this site. Therefore, chronic toxicity testing will
remain in the permit at the minimum monitoring frequency of quarterly. --
Fact Sheet
NPDES NC0084638
Page 2 of 3

Influent data for trichloroethylene and toluene were shown to be present in the groundwater at
concentrations less than half of water quality standards. Given the lower concentrations of
trichloroethylene and toluene, the continued chronic toxicity testing, and the consistent removal
of these parameters in the treatment system, monitoring for trichloroethylene and toluene were
removed from the permit.
For clarity and to validate future data assessments, the narrative establishing a minimum
detection limit of 1.0 ug/L for permit toxicants will be maintained. Extraction wells monitoring
data will be required for future permit renewal to characterize the influent and assist in the permit
development.
Whole Effluent Toxicity
The permit requires quarterly chronic toxicity testing using ceriodaphnia dubia, at 90% effluent
concentration. Since January 2011 the facility has passed 17 of 17 toxicity tests.
SUMMARY OF PROPOSED CHANGES
In keeping with Division policies the following will be incorporated into the permit:
• Reduction of pH monitoring to monthly.
• Removal of trichloroethylene and toluene monitoring requirements.
• Addition of electronic DMR requirement.
• Update special condition A.(2) narrative.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: October 21,2015
Permit Scheduled to Issue: December 21,2015
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Yang Song at(919) 807-6479 or email [e-mail].
•
NAME: N1- vI DATE: /C / "'/
Fact Sheet
NPDES NC0084638
Page 3 of 3

Catawba River Basin
2014 AU Number: AU Name: AU Length Area: AU Units: Classification:
IAU Description:
11-(75) CATAWBA RIVER(Lake Norman below elevation 76 31,331.6 FW Acres WS-IV,B;CA
From Lyle Creek to Cowan's Ford Dam
IRCategory: ACS: Parameter Of Interest: Collection Year: 303(d)yr:
5 EC PCB Fish Tissue Advisory(Advisory,FC,NC) 2012 2014
11-(117) CATAWBA RIVER(Lake Wylie below elevation 570) 375.3 FW Acres WS-IV;CA
From Mountain Island Dam to Interstate Highway 85 Bridge at Belmont
IRCategory: ACS: Parameter Of Interest: Collection Year: 303(d)yr:
5 EC PCB Fish Tissue Advisory(Advisory,FC, NC) 2012 2014
11-(122) CATAWBA RIVER(Lake Wylie below elevation 570) 601.1 FW Acres WS-IV,B;CA
From 1-85 bridge to the upstream side of Paw Creek Arm of Lake Wylie,Catawba River
IRCategory: ACS: Parameter Of Interest: Collection Year: 303(d)yr:
5 EC PCB Fish Tissue Advisory(Advisory,FC,NC) 2012 2014
11-(114) CATAWBA RIVER(Mountain Island Lake below elev 1,937.1 FW Acres WS-IV,B;CA
From Water Intake at River Bend Steam Station to Mountain Island Dam (Town of Mount Holly water supply intake)
IRCategory: ACS: Parameter Of Interest: Collection Year: 303(d)yr:
5 EC PCB Fish Tissue Advisory(Advisory,FC,NC) 2012 2014
11-135a Crowders Creek 1.9 FW Miles C
From source to SR 1118
IRCategory: ACS. Parameter Of Interest: Collection Year: 303(d)yr:
5 EC Benthos Fair(Nar,AL,FW) 2002 1998
5 EC Fish Community Poor(Nar,AL,FW) 2004 1998
( 135f ) Crowders Creek 1.4 FW Miles C
iom State Route 321 to State Route 2424
IRCategory; ; ACS: Parameter Of Interest: Collection Year: 303(d)yr:
5 EC Benthos Fair(Nar,AL, FW) 1989 2000
11-135c Crowders Creek 3.3 FW Miles C
From State Route 1122 to State Route 1131
IRCategory: ACS: Parameter Of Interest: Collection Year: -303(d)yr:
5 EC Fish Community Poor(Nar,AL,FW) 2004 1998
11-135e Crowders Creek 1.5 FW Miles C
From State Route 1108 To NC 321
IRCategory: ACS: Parameter Of Interest: Collection Year 303(d)yr:
5 EC Benthos Fair(Nar,AL,FW) 1989 2000 I -
2014 NC 303(d) List-Category 5 Final December 19,2014 Page 22 of 149

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dd. s6 h> ri , .. r,. a .... ,�.,. E N. r r. n. }•'s��, „at�., ,..„. ..,, , . � '.<�, i.� . a. r+t ':: ,c,i v�,s m h•� e,.„,�h ss .: �« �u ��:; �',...r. ti. 1.�` � �ds �e" ��i�3, � ..a�, m—�a�� ,.ir'�s�,.., `4�p.._:.� 4..�.q�:.3,fi_. �4.< —x°..��. �' a�3i'�,?, 1r ,.�xt�,,,�. ?i� .i�, � -
PERMIT: FACILITY: COUNTY: REGION:
MONITORING OUTFALU VIOLATION UNIT OF CALCULATED %LOCATION PARAMETER FREQUENCY LIMIT VIOLATION TYPE VIOLATION ACTION
REPORT ppl DATE MEASURE VALUE Over

Whole Effluent Toxicity Testing and Self Monitoring Summary
Reidsville Lake WTP NC0046345/001 County: Rockingham Region: WSRO Basin: CPF01 Jan AprJul Oct SOC_JOC•
Ceri7dPF Begin: 8/1/2011 Chr Monit: 90% NonComp: 7010: PF: IWC: Freq: Q
J F M A M J I A S 0 N D
2011 • * • * * * • • * Fail Fail *
2012 Fall * * Fail * * Fail * • Pass * *
2013 Pass * • Fail * * Pass * * Pass • *
2014 Fail * * Fail * Fail • * * * • •
2015 Pass * * Pass • • • * * * • *
Reidsville WWiP NC0024881/001 County: Rockingham Region: WSRO Basin: CPF01 Jan Apr Jul Oct SOC_JOC:
Ceri7dPF Begin: 6/1/2013 chr iim:61% NonComp: Single 7Q10: 7.4 PF: 7.5 IWC: 61 Freq: Q
J F M A M I J A S 0 N D
2010 >100(P) * * >100(P) * * >100 >100(P) * >100 * *
2011 >100 * • >100 * * >100 • * >100 * *
• 2012 86.6 * * 67.6 * * 67.6 * * 86.6 * •
2013 >100 * * 43.1 >100 >100 >100 • * 67.6 *
2014 >100 * * >100 * * >100(P) * * >10(XP) * *
2015 >100(P) • • >100(P) • * • * * * * *
REXAM,Inc NC0087874/001 County: Guilford Region: WSRO Basin: CPF02 Feb May Aug Nov SOC JOC:
Ceri7dPF Begin: 12/1/2004 chr Iim 90% NonComp: 7Q10: 0 PF: 0.001 IWC: 100 Freq: Q
J F M A M I J A S 0 N D
2010 * H • * * * * H • * • *
2011 * H • * H * * H • * H •
2012 • H • * H * • H * * * *
2013 * H * * H • * H * * H *
2014 • H • * H * • H * * H *
2015 * H • * H • * * * * * *
Rhodla,Inc N00084638/001 County: Gaston Region: MRO Basin: CTB37 Mar Jun Sep Dec SOC_JOC:
Ceri7dPF Begin: 7/1/2011 chr lim:90% NonComp: Single 7010: 0.0 PF: 0.194 IWC: 100 Freq: Q
I F M A M J J A S 0 N D
2010 * * Pass * * Pass * * Pass * * Pass
2011 * * Pass * * Pass * * Pass * * Pass
2012 * * Pass * " Pass • * Pass • * Pass
2013 * * Pass * * Pass * * Pass * * Pass
2014 * * Pass * • Pass • * Pass * • Pass
2015 * * Pass * * * * * * * * *
Page 110 of 147 •

Solvay USA Inc. Outfall 001
NC0084638 2014 Freshwater RPA- 95% Probability/95% Confidence Qw= 0.1944 MGD
MAXIMUM DATA POINTS = 58
Qw(MGD)= 0.19 W WTPIWTP Class: PC-1
1Q10S(cfs)= 0.00 IWC ®1QIOS = 100.000000% •
7QI OS(cfs)= 0.00 IWC ®7Q10S= 100.000000%
7Q10W(cfs)= 0.00 IWC®7Q10W= 100.000000%
30Q2(cfs)= 0.00 IWC®30Q2= 100.000000%
Avg.Stream Flow,QA(cfs)= 0.00 IWC®QA= 100.000000%
Receiving Stream: UT to Crowders Creek Stream Class: C
PARAMETER STANDARDS&CRITERIA(2) REASONABLE POTENTIAL RESULTS
TYPE -J C RECOMMENDED ACTION
(1) NC WQS/ Applied %FAV/ a z n #Det Max Pred Allowable Cw
Chronic Standard Acute Cw
Acute: NO WQS
Trichloroethytene C 30 HH µg/L 15 0 0.55000 __ _ ___ _ _ _ _
Chronic: 30.00000 All samples were less than 1ug/I
No value>Allowable Cw
Acute: NO WQS
1,1 Dichloroethylene NC 1500 FW µg/L 21 0 0.50000 ___ _ ___ _ _ _
Chronic: 1500.00000 All samples were less than 1 ug/I
No value>Allowable Cw
Acute: NO WQS
Ethylbenzene NC 97 FW µg/L 17 0 0.50000 _ _ — — _ _ _ _
Chronic: 97.00000 All samples were less than l ug/1 — — — —_
No value>Allowable Cw
Acute: NO WQS
Toluene NC 11 FW µg/L 21 0 0.50000
Chronic: 11.00000 All samples were less than 1 ugll-- _-----_
No value>Allowable Cw
•
nc008483-RPA-2015,rpa
•
Page 1 of 1 10/8/2015

•
CDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E.Skvarla, Ill
Governor Secretary
December 2, 2014
Mr. Michael Shatynski
Solvay USA, Inc.
8 Cedar Brook Drive RECEIVEDIDENR/DWR
Cranberry, New Jersey 08512 DEC 9 2014
Water Quality
Subject: Compliance Evaluation Inspection Permitting Section
Rhodia remediation site
NPDES Permit No. NC0084638
Gaston County
Dear Mr. Shatynski:
Enclosed please find a copy of the Compliance Evaluation Inspection report for the inspection
conducted at the subject facility on November 25, 2014, by Ms. Marcia Allocco of this office. I thank
Messrs. Williams and Hockett of CH2M Hill for their assistance regarding the site visit/inspection.
The inspection report should be self-explanatory; however, should you have any questions
concerning the report, please do not hesitate to contact me at [phone] or
[e-mail].
Sincerely,
Marcia Allocco, MS; Environmental Senior Specialist
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
cc: Wastewater Branch
MSC 1617— Central files basement
Mr. Dan Hockett, CH2M Hill, ORC
MA
Mooresville Regional Office
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115
Phone:[phone] Fax:[phone] Customer Service:1-877-623-6748
Internet http:llportaI.ncdenr.orglweb/wq
An Equal Opportunity\Afrmative Action Employer—30%Recycled/10%Post Consumer paper

United States Environmental Protection Agency Form Approved.
EPA Washington,D.C.20480 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 U 2 IS I 3 1 NC0084638 111 121 14/11/25 (17 18 t,•t 19 11.1 201 I
211 till ' 1111111 11 11111111111 mil , 111II r6
inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA --------Reserved— ---
67 Ito I 70 L_1 h 71 It] 72 I N I 731
I 17479
l
1 I 1 1 1 1 180
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)
10:02AM 14/11/25 11/07/01
Rhodia remediation site
207 Telegraph Dr Exit Time/Date Permit Expiration Date
Gastonia NC 280561306 11:46AM 14/11/25 15/12/31
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
•
///
Daniel Nathan Hodcett/ORC/704-543-3284/
Name,Address of Responsible OfficiaVTitie/Phone and Fax Number
Michael Shatynski,8 Cedar Brook Dr Cranbury NJ 08512//732-518-1104/6098802203 Contacted
No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
In Permit II Flow Measurement NI Operations&Maintenance I Records/Reports
III Self-Monitoring Program IN Facility Site Review Effluent/Receiving Waters II Laboratory
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Marcia Allocco Q//704-863-1699 Ext.2204/ U 4 i '
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/ma/day Inspection Type 1
31 NC0084638 111 121 14/11/25 117 18 1_J
Section D:Summary of Flnding/Comments(Attach additional sheets of narrative and checklists as necessary)
Page# 2

Permit: NC0084638 Owner-Facility: Rhoda remediation site
Inspection Date: 11/25/2014 Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ • ❑
application?
Is the facility as described in the permit? • ❑ ❑ ❑
#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: NC0084638 was reissued by the Division on June 1.2011,with an effective date of July 1,
2011. The permit is set to expire on December 31.2015. The previous compliance
evaluation inspection was conducted on January 26,2010.
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: CH2MHill staff periodically review contaminant levels in the treatment system influent and
surrounding monitoring wells to aid in system performance and operation as well as
modeling of plume dynamics.
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting? • ❑ ❑ ❑
Is flow meter calibrated annually? • ❑ ❑ ❑
Is the flow meter operational? • ❑ ❑ ❑
(If units are separated)Does the chart recorder match the flow meter? • ❑ ❑ ❑
Comment: The effluent flow meter(ISCO 4230 bubbler) has been calibrated annually and was last
calibrated/verified by Clearwater, Inc. on July 15,2014. The associated paperwork noted no
deviation from true values.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? • ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ • ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ 0 • ❑
Comment: There was an intermittent discharge from the treatment system to the drainage swale and
unnamed tributary to Crowders Creek during the inspection. Under normal operating
conditions the majority of the treated effluent is used as process water by the adjacent
property owner(Lubrizol Advanced Materials, Inc.).
Effluent Sampling Yes No NA NE
Page# 3

Permit: NC0084838 Owner-Facility: Rhodia remediation site
Inspection Date: 11/25/2014 Inspection Type: Compliance Evaluation
Effluent Sampling • Yes No NA NE
Is composite sampling flow proportional? 0 0 • 0
Is sample collected below all treatment units? MI 0 0 0
Is proper volume collected? • 0 0 0
Is the tubing clean? ❑ ❑ ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • 0 0 0
Celsius)?
Is the facility sampling performed as required by the permit(frequency,sampling type 0 0 0
representative)?
Comment: The permit requires arab samples for all required parameters.All effluent samples are kept
on ice in a cooler until transfer to the analytical laboratory. Effluent samples are collected
downstream of the effluent flow meter.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? • 0 0 0
Are all other parameters(excluding field parameters)performed by a certified lab? U 0 0 0
#Is the facility using a contract lab? 1111 0 0 0
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees 11 0 0 0
Celsius)?
Incubator(Fecal Coliform)set to 44.5 degrees Celsius+/-0.2 degrees? ❑ ❑ II 0
Incubator(BOD)set to 20.0 degrees Celsius+/-1.0 degrees? 0 0 � ❑
Comment: On-site analyses(pH)are performed under field laboratory certification#5508 (CH2MHill).
The permittee has also contracted Prism Laboratories, Inc. (certification#402)and
Environmental Testing Solutions. Inc.Iwhole effluent toxicity testing)to provide the
remaining permit analytical requirements. The contracted operator had an exemplary
documentation system related to the on-site analyses of pH samples. However,please
ensure that a calibration time is provided when calibrating the pH meter:this time must
precede the sample/analysis time reported for the effluent.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? 0 0 0
Is all required information readily available,complete and current? 111 ❑ 0 ❑
Are all records maintained for 3 years(lab. reg.required 5 years)? al 0 0 0
Are analytical results consistent with data reported on DMRs? 0 0 0
Is the chain-of-custody complete? • 0 0 0
Dates,times and location of sampling 111
Name of individual performing the sampling 111
Results of analysis and calibration
Page# 4

•
Permit: NC0084638 Owner-Facility: Rhodia remediation site
Inspection Date: 11/25/2014 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Dates of analysis 111
Name of person performing analyses
Transported COCs 111
Are DMRs complete:do they include all permit parameters? • ❑ 0 0
Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ • 0
(If the facility is=or>5 MGD permitted flow)Do they operate 24/7 with a certified operator 0 0 • 0
on each shift?
Is the ORC visitation log available and current? • ❑ 0 0
Is the ORC certified at grade equal to or higher than the facility classification? • 0 ❑ 0
Is the backup operator certified at one grade less or greater than the facility classification? ❑ • 0 0
Is a copy of the current NPDES permit available on site? II0 0 0
Facility has copy of previous year's Annual Report on file for review? 0 0 MI 0
Comment: A recent ORC change(October 7,2014)has left the Back-up ORC position vacant. Please
ensure a back-up ORC is designated for the system by February 5,2015, as per 15A NCAC
08G .0201.
The reviewed records were organized and well maintained and all documentation requested
during the inspection was readily retrievable. Monthly discharge monitoring reports(DMRs)
were reviewed for September 2013 through August 2014. No limit violations were reported
and all monitoring frequencies were correct.
Page# 5

.1-NAFA
Ai,
��It
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
July 23,2009 •;:p �
CERTIFIED MAIL:7007 1490 0004 5537 9940
RETURN RECEIPT REQUESTED
Mr.Michael Shatnski ji, r
Rhodia,Inc.
Cn 7500.
Cranbury,NJ 08512
•
Subject: NOTICE OF VIOLATION `�lQ'
Effluent Toxicity Testing �r '"' `'vr
NPDES Permit No.NC0084638
Rhodia Remediation Site
Mecklenburg County
Dear Mr. Shatnski:
This is to inform you that a review of your toxicity self-monitoring report form for the month of May 2009 indicates a violation of the
toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity violation(s). Your efforts
may include conducting a Toxicity Reduction Evaluation(TRE),a site-specific study designed to identify the causative agents of effluent toxicity,
isolate the sources of toxicity,evaluate the effectiveness of toxicity control options,and confirm reductions in effluent toxicity. Please be aware that
North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and Reporting
Requirements. Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT)
Test Forms. We encourage you to review this information; if it would be helpful to discuss this situation or possible solutions to resolve effluent
toxicity noncompliance,please contact Mr.John Giorgino with this office at(919)743-8441.
Sincerely,
,4a9w
Cindy A.Moore
Supervisor,Aquatic Toxicology Unit
cc: bs/Mooresville Regional Office
John Lesley/Mooresville Regional Office
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center,Raleigh,North Carolina 27699-1621 One
Location:4401 Reedy Creek Road,Raleigh,North Carolina 27607 NorthCarolina
Phone:[phone] FAX:[phone] Customer Service:1-877-623-6748
Internet:http:/Ih2o.enr.state.nc.us/esb/ Naturally
An Equal Opportunity 1 Affirmative Action Employer

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information. Please take time to review this information.The items below do not address or include all the toxicity testing and reporting
requirements contained in your NPDES permit. If you should have any questions about your toxicity testing requirement,please contact Mr.
John Giorgino with the Aquatic Toxicology Unit at(919)743-8401 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the appropriate
parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period
(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure of any
single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at least two multiple
concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as can be completed will be
accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly test, you
may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement
initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit,except for NPDES Permits which contain episodic toxicity monitoring
requirements(eg, if the testing months specified in your NPDES permit are March,June,September,and December, then toxicity testing must
be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,then you must provide
written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months of the calendar
year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental Sciences
Section at(919)743-8401 and provide written documentation indicating why the test was invalidated and the date when follow-up testing will
occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the information block
located at the top of the AT form indicating the facility name,permit number,pipe number,county and the month/year of the subject report.
You should also write"No Flow"on the AT form,sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities which have not
received a facility classification. In these cases,a duly authorized facility representative must sign the AT form. The AT form must also be
signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting your toxiaty test
results certified mail,return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center,Raleigh,North Carolina 27699-1621 One
Location:4401 Reedy Creek Road,Raleigh,North Carolina 27607 na
NPhone:919-743-84001 FAX:[phone] Customer Service:1-877-623-6748 1t NorthCaroli
li
Internet:http://h2o.enr.state.nc.us/esb/ Naturally
An Equal Opportunity 1 Affirmative Action Employer ff// ;/

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 29,2009
CERTIFIED MAIL:7007 1490 0004 5537 9735 t
RETURN RECEIPT REQUESTED +# �„ 4 +'
Mr. Michael Shatnski
Rhodia,
JuN 11
[nc. � C
�UvJ
Cn 7500.
Cranbury,NJ 08512
Subject: NOTICE OF VIOLATION
Effluent Toxicity Testing mute.
NPDES Permit No.NC0084638
Rhodia Remediation Site
Mecklenburg County
Dear Mr. Shatnski:
This is to inform you that a review of your toxicity self-monitoring report form for the month of March 2009 indicates a violation of the
toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity violation(s). Your efforts
may include conducting a Toxicity Reduction Evaluation(TRE),a site-specific study designed to identify the causative agents of effluent toxicity,
isolate the sources of toxicity,evaluate the effectiveness of toxicity control options,and confirm reductions in effluent toxicity. Please be aware that
North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and Reporting
Requirements. Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT)
Test Forms. We encourage you to review this information; if it would be helpful to discuss this situation or possible solutions to resolve effluent
toxicity noncompliance,please contact Mr.John Giorgino with this office at(919)743-8441.
S. cerely, 'nn s,,n
Cindy A.Moore
Supervisor,Aquatic Toxicology Unit
cc: 1111111Mtaelooresville Regional Office
John Lesley/Mooresville Regional Office
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center,Raleigh,North Carolina 27699-1621 One
Location:4401 Reedy Creek Road,Raleigh,North Carolina 27607 NoTtllCaroli.na
Phone:[phone] FAX:[phone]\Customer Service:1-877-623-6748 rt
Internet http:/Ih2o.enr.state.nc.us/esb/ Naturally
hook An Equal Opportunity 1 Affirmative Action Employer

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information. Please take time to review this information.The items below do not address or include all the toxicity testing and reporting
requirements contained in your NPDES permit. If you should have any questions about your toxicity testing requirement,please contact Mr.
John Giorgino with the Aquatic Toxicology Unit at(919)743-8401 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the appropriate
parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period
(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure of any
single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at least two multiple
concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as can be completed will be
accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly test, you
may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement
initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit,except for NPDES Permits which contain episodic toxicity monitoring
requirements(eg,if the testing months specified in your NPDES permit are March,June,September,and December,then toxicity testing must
be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January I-June 30,then you must provide
written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months of the calendar
year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental Sciences
Section at(919)743-8401 and provide written documentation indicating why the test was invalidated and the date when follow-up testing will
occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the information block
located at the top of the AT form indicating the facility name,permit number,pipe number,county and the month/year of the subject report.
You should also write"No Flow"on the AT form,sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities which have not
received a facility classification. In these cases,a duly authorized facility representative must sign the AT form. The AT form must also be
signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting your toxicity test
results certified mail,return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center,Raleigh,North Carolina 27699-1621 One
Location:4401 Reedy Creek Road,Raleigh,North Carolina 27607 North Carolina
Phone:[phone] FAX:[phone]\Customer Service:1-877-623-6748 1 ./
Internet:http://h2o.enr.state.nc.us/esb/ Naturally
An Equal Opportunity 1 Affirmative Action Employer

OF W A 7--
-6)
0 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
December 21, 2005
>xl..APT.0 Et�w t,.G
CERTIFIED MAIL �B 1<;�Tf tr• nF�'�3:;P,CFF
RETURN RECEIPT REQUESTED t": 't OFFICE
Mr. Edward J. Petrie
Rhodia, Inc. 200=
CN 7500 DEC 2
Cranbury,New Jersey 08512
SUBJECT: NOTICE OF VIOLATION A4 svgr, rt
Whole Effluent Toxicity Testing W�1 I`.+ ,",,,;I1:t~
NPDES Permit No. NC0084638
Rhodia, Inc. Treatment Facility
Gaston County
Dear Mr. Petrie:
This is to inform you that a review of your toxicity self-monitoring report form for the month of October 2005
indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity
violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (TRE), a site-specific study designed
to identify the causative agents of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity
control options, and confirm reductions in effluent toxicity. Please be aware that North Carolina General Statutes provide
for assessment of civil penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note appropriate mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this information; if it
would be helpful to discuss this situation or possible solutions to resolve effluent toxicity noncompliance, please contact
me or Mr. Kevin Bowden with this office at(919) 733-2136.
Sincerely,
m
Matt Matthews
Aquatic Toxicology Unit Supervisor
cc: elter'E}imiee&.Mooresville Regional Office
John Lesley-Mooresville Regional Office
Central Files
Une
No hCarolina
Jaturally
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh,NC 27699-1621 Phone[phone] Customer Service
Internet www.esb.enr.state.nc.us 4401 Reedy Creek Rd. Raleigh,NC 27607 FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and
reporting information. Please take time to review this information.The items below do not address or include all the toxicity testing
and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity testing
requirement,please contact Mr.Kevin Bowden with the Aquatic Toxicology Unit at(919)733-2136 or another Unit representative at the
same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report
forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the appropriate
parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting
period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure
of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at least two
multiple concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as can be
completed will be accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any
single quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per
the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the
Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit,except for NPDES Permits which contain episodic toxicity monitoring
requirements(eg,if the testing months specified in your NPDES permit are March,June,September,and December,then toxicity testing
must be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,then you must
provide written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months
of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental
Sciences Section at(919)733-2136 and provide written documentation indicating why the test was invalidated and the date when
follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the information
block located at the top of the AT form indicating the facility name,permit number,pipe number,county and the month/year of the
subject report. You should also write"No Flow"on the AT form,sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities which have
not received a facility classification. In these cases,a duly authorized facility representative must sign the AT form. The AT form must
also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting your toxicity
test results certified mail,return receipt requested to the Environmental Sciences Section.

�QF w A 1-E9Q Michael F.Easley,Governor
G William G.Ross Jr.,Secretary
C/j II North Carolina Department of Environment and Natural Resources
O Alan W.Klimek,P.E.,Director
Division of Water Quality
July 5,2005
CERTIFIED MAIL (' itip(iNMF 1I,-1
RETURN RECEIPT REQUESTED 7 .-?`tI0-004 r #//4 ti :11 : .S JUFCE
i)Fr.r -
Mr.Edward J.Petrie
Rhodia,Inc.
Cn 7500
Cranbury,NJ 08512 JUL C E 200')
Subject: Whole Effluent Toxicity Reporting Requirements
Effluent Toxicity Testing
NPDES Permit No.NC0084638
Rhodia,Inc.Treatment Facility .; + r`
Gaston County
Dear Mr.Petrie:
This is to inform you that the Environmental Sciences Section has received your toxicity self-monitoring
report form for April 2005;however,the form was received late and was not signed by the Operator in Responsible
Charge.
The Environmental Sciences Section received the April 2005 toxicity self-monitoring report form on June 27,
2005. The required signed original Aquatic Toxicity(AT)Test Form was not received by this office within the 30 day
reporting period,thus the reason for this correspondence.
Please be reminded that the reporting of toxicity self-monitoring data is a dual requirement. Both the DMR
and AT Test forms must be filed no later than 30 days after the end of the reporting period for which the report is
made. AT test forms must be filed with this office while your monthly DMRs must be filed with the Division's
Central Files. In addition,toxicity test results must be reported on your monthly DMR. Mailing addresses for our
office and Central Files are located on the reverse side of this correspondence.
In the future,you are requested to submit the toxicity self-monitoring report form to this office within the 30-
day reporting period. Please submit a signed April 2005 toxicity self-monitoring report form to this office no later
than July 15,2005.
The reverse side of this letter contains a summary of important toxicity monitoring and reporting
requirements. Please read this one page summary and if you have any questions,please contact Mr.Kevin Bowden
with the Aquatic Toxicology Unit at(919)733-2136.
Sincerely,
114
Matt Matthews,Supervisor
Aquatic Toxicology Unit
cc: oiriiiiiiarrawitmeemariiitigiessidiffice
John Lesley—Mooresville Regional Office
Aquatic Toxicology Unit Files
Central Files
Noe Carolina
Mural!;
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh,NC 27699-1621 Phone[phone] Customer Service
Internet http:llwww.esb.enr.state.nc.us 4401 Reedy Creek Rd. Raleigh,NC 27607 FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and
reporting information. Please take time to review this information. The items below do not address or include all the toxicity
testing and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity-
testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at [phone] or another Unit
representative at the same number.
➢ The permittee is responsible for ensuring,that,toxipity,testing is oondu9ted according to the permit requirement and that toxicity report
forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT'form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting
period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon
failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at
least two multiple concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as
can be completed will be accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure
of any single quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity
testing per the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will
influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring
requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and December, then toxicity
testing must be conducted during these months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing this monthly test requirement,the permittee will revert to the
quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,then you
must provide written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six
months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental
Sciences Section at [phone] and provide written documentation indicating why the test was invalidated and the date when
follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and the
month/year of the subject report. You should also write "No Flow" on the AT form, sign the form and submit following normal
procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC) except for facilities which
have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT
form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting your
toxicity test results certified mail,return receipt requested to the Environmental Sciences Section.

OF W ATFRQ Michael F.Easley,Governor
0 �i William G.Ross Jr.,Secretary
. • North Carolina Department of Environment and Natural Resources
.<" Alan W.Klimek,P.E.Director
Division of Water Quality
November 15,2005
CERTIFIED MAIL Per—a Y1'"6'1O5--46154-6 t 72 N,tics' I,':utv�ItW><
RETURN RECEIPT REQUESTED AN'14A
$OOR . .cIEgOURCE$
mAL OFFict
Mr. Edward J.Petrie
Rhodia,Inc.
CN 7500 r WV E 200'' •
Cranbury,New Jersey 08512
x
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity Testing T ,_,, _�
NPDES Permit No.NC0084638 6 `"
Rhodia,Inc. Treatment Facility
Gaston County
Dear Mr.Petrie:
This is to inform you that a review of your toxicity self-monitoring report form for the month of September 2005
indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity
violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (TRE), a site-specific study designed
to identify the causative agents of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity
control options, and confirm reductions in effluent toxicity. Please be aware that North Carolina General Statutes provide
for assessment of civil penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note appropriate mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this information; if it
would be helpful to discuss this situation or possible solutions to resolve effluent toxicity noncompliance, please contact
me or Mr.Kevin Bowden with this office at(919)733-2136.
Sincerely,
Matt Matthews
Aquatic Toxicology Unit Supervisor
cc: ''j"jllpllnamjresvvi`lle Regional Officii
+!
John Lesley-Mooresville Regional Office
Central Files
NiaNae Carolina
turally
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh,NC 27699-1621 Phone[phone] Customer Service
Internet www.esb.enr.state.nc.us 4401 Reedy Creek Rd. Raleigh,NC 27607 FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycledl10%Post Consumer Paper

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and
reporting information. Please take time to review this information.The items below do not address or include all the toxicity testing
and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity testing
requirement,please contact Mr.Kevin Bowden with the Aquatic Toxicology Unit at(919)733-2136 or another Unit representative at the
same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to.the permit requirement and that toxicity report
forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the appropriate
parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting
period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure
of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at least two
multiple concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as can be
completed will be accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any
single quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per
the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the
Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit,except for NPDES Permits which contain episodic toxicity monitoring
requirements(eg,if the testing months specified in your NPDES permit are March,June,September,and December,then toxicity testing
must be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,then you must
provide written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months
of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental
Sciences Section at(919)733-2136 and provide written documentation indicating why the test was invalidated and the date when
follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the information
block located at the top of the AT form indicating the facility name,permit number,pipe number,county and the month/year of the
subject report. You should also write"No Flow"on the AT form,sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities which have
not received a facility classification. In these cases,a duly authorized facility representative must sign the AT form. The AT form must
also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting your toxicity
test results certified mail,return receipt requested to the Environmental Sciences Section.

Helms Mulliss&Wicker,PLLC Attorneys at Law
Charlotte Raleigh Wilmington www.hmw.com
HELMS MULLISS WICKER
704.343.2060 ` \ 201 North Tryon Street
Fax [phone] Charlotte,NC 28202
benne.hutson@,hmw.com P.O.Box 31247(28231)
704.343.2000
f 704.343.2300
May 2, 2005
Mr. Matt Matthews
"i
Aquatic Toxicology Unit Supervisor , ,_.�,•�,a�
Davison of Water Quality , ;�E�r .' 4- RCES�E
North Carolina Department of Environment and Natural Resources o � '
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
MAY ° 4 20A5
Re: Rhodia Inc.
February 16, 2005 Notice of Violation
Whole Effluent Toxicity Testing
NPDES Permit No. NC0084638
Gaston County /Vvi
Client-Matter No. 4066081.000602
Dear Matt:
As you may remember, we represent Rhodia with regard to environmental matters associated
with the operation of the groundwater remediation system at its former Gastonia facility. I am writing
to inform the agency of the actions Rhodia has taken in response to this Notice of Violation.
Upon receiving the sampling results for the December 2004 toxicity sampling (which it
received prior to receiving the Notice of Violation), Rhodia switched from quarterly to monthly
toxicity sampling as required by its NPDES permit. Sampling in both January and February showed
compliance with the toxicity requirements of the NPDES permit. We understand these sampling
results were timely submitted directly to Kevin Bowden of the Aquatic Toxicology Unit by Handex,
Rhodia's operator in responsible charge of its remediation system.
As both the January and February samples showed compliance, Rhodia has, pursuant to the
NPDES permit, resumed quarterly sampling for toxicity.
C719622

Mr. Matt Matthews
May 2, 2005
Page 2
If you have any questions regarding any of the matters discussed in this letter, please let me
know.
Sincerely,
HELMS MULLISS & WICKER,PLLC
enne C. Hutson
cc: Rhodia Management Team (via electronic mail)
C719622

�QF W A Michael F.Easley,Governor
�0 C- William G.Ross Jr.,Secretary
f!? • om North Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E.Director
A (7- Division of Water Quality
February 16, 2005 • -
Ic DEPT.07 r-^.,,.r,�..��`
CERTIFIED MAIL AND NAT: T
RETURN RECEIPT REQUESTED MOORE
Mr. Edward J.Petrie
Rhodia, Inc.CN 7500 FEB 1 7 2005
Cranbury,New Jersey 08512
SUBJECT: NOTICE OF VIOLATION R
Whole Effluent Toxicity Testing • `.9' 4
NPDES Permit No.NC0084638
Rhodia, Inc. Treatment Facility
Gaston County
Dear Mr.Petrie:
This is to inform you that a review of your toxicity self-monitoring report form for the month of December 2004
indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity
violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation(TRE), a site-specific study designed
to identify the causative agents of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity
control options, and confirm reductions in effluent toxicity. Please be aware that North Carolina General Statutes provide
for assessment of civil penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note appropriate mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this information; if it
would be helpful to discuss this situation or possible solutions to resolve effluent toxicity noncompliance, please contact
me or Mr.Kevin Bowden with this office at(919)733-2136.
Sincerely,
744
Matt Matthews
Aquatic Toxicology Unit Supervisor
cc: ay' _
John Lesley-Mooresville Regional Office
Central Files
NNaOne Carolina
turally
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh,NC 27699-1621 Phone[phone] Customer Service
Internet www.esb.enr.state.nc.us 4401 Reedy Creek Rd. Raleigh,NC 27607 FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and
reporting information. Please take time to review this information.The items below do not address or include all the toxicity testing
and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity testing
requirement,please contact Mr.Kevin Bowden with the Aquatic Toxicology Unit at(919)733-2136 or another Unit representative at the
same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report
forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the appropriate
parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting
period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure
of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at least two
multiple concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as can be
completed will be accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any
single quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per
the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the
Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit,except for NPDES Permits which contain episodic toxicity monitoring
requirements(eg,if the testing months specified in your NPDES permit are March,June,September,and December,then toxicity testing
must be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,then you must
provide written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months
of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental
Sciences Section at(919)733-2136 and provide written documentation indicating why the test was invalidated and the date when
follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the information
block located at the top of the AT form indicating the facility name,permit number,pipe number,county and the month/year of the
subject report. You should also write"No Flow"on the AT form,sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities which have
not received a facility classification. In these cases,a duly authorized facility representative must sign the AT form. The AT form must
also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting your toxicity
test results certified mail,return receipt requested to the Environmental Sciences Section.

�oF w A 7- ,9p Michael F.Easley,Governor
Q G. William G.Ross Jr.,Secretary
CO 7 North Carolina Department of Environment and Natural Resources
-i
pAlan W.Klimek,P.E.,Director
Division of Water Quality
December 9,2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr.Ed Petrie
Rhodia,Inc. DEC 1 200t
CN7500
Cranbury,NJ 08512
Subject: Whole Effluent Toxicity Reporting Requirements
Effluent Toxicity Testing
NPDES Permit No.NC0084638
Rhodia,Inc.Treatment Facility
Gaston County
Dear Mr. Petrie:
This is to inform you that the Environmental Sciences Section has received your toxicity self-monitoring report forms for
September and October 2004;however,problems were encountered with the report forms.
The Environmental Sciences Branch received an unsigned copy of the September 2004 toxicity self-monitoring report
form by fax on December 1,2004. The required signed original report form was not received.
The Environmental Sciences Branch received an unsigned copy of the October 2004 toxicity self-monitoring report form
by mail on November 30,2004. The required signed original report form was not received. The faxed October report form listed
the wrong NPDES number. The sample collection dates appear to have 2002 as the year of collection.
Kevin Bowden of our office spoke with Amy Parham on December 6,and requested the corrected original toxicity self-
monitoring report forms for September and October be sent to us no later than December 15,2004.
Please remember that the reporting of toxicity self-monitoring data is a dual requirement. Both the DMR and AT Test
forms must be filed no later than 30 days after the end of the reporting period for which the report is made. AT test forms must be
filed with this office while your monthly DMRs must be filed with the Division's Central Files. In addition,toxicity test results
must be reported on your monthly DMR. Mailing addresses for our office and Central Files are located on the reverse side of this
correspondence.
In the future,you are requested to submit the signed original toxicity self-monitoring report form to this office within the
30-day reporting period.
The reverse side of this letter contains a summary of important toxicity monitoring and reporting requirements. Please
read this one page summary and if you have any questions,please contact Mr.Kevin Bowden with the Aquatic Toxicology Unit at
[phone].
Sincerely,
`77
Matt Matthews,Supervisor
Aquatic Toxicology Unit
cc:
John Lesley—Mooresville Regional Office
ETT Environmental,Inc.
Aquatic Toxicology Unit Files No` Carolina
Central Files aturally
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh,NC 27699-1621 Phone[phone] Customer Service
Internet esb.enr.state.nc.us 4401 Reedy Creek Rd. Raleigh,NC 27607 FAX [phone] I-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

•
WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and
reporting information. Please take time to review this information. The items below do not address or include all the toxicity
testing and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity-
testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at [phone] or another Unit
representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report
forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting
period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon
failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at
least two multiple concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as
can be completed will be accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure
of any single quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity
testing per the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will
influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring
requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and December, then toxicity
testing must be conducted during these months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing this monthly test requirement, the permittee will revert to the
quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30, then you
must provide written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six
months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental
Sciences Section at [phone] and provide written documentation indicating why the test was invalidated and the date when
follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and the
month/year of the subject report. You should also write "No Flow" on the AT form, sign the form and submit following normal
procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC) except for facilities which
have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT
form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting your
toxicity test results certified mail,return receipt requested to the Environmental Sciences Section.

�QF w A rFjQQ Michael F.Easley,Governor
0 t!i William G.Ross Jr.,Secretary
It r- North Carolina Department of Environment and Natural Resources
> 7-1
' Alan W.Klimek,P.E.,Director
Division of Water Quality
December 6,2004
•
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr.Edward J.Petrie
Rhodia,Inc.
CN 7500
Cranbury,New Jersey 08512
Subject: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No.NC0084638
Rhodia,Inc.Treatment Facility V.
Gaston County •
Dear Mr.Petrie:
This is to inform you that the Environmental Sciences Section has received your toxicity self-monitoring report form
for the month of September 2004;however,the report form was received late. This is in violation of Title 15A of the North
Carolina Administrative Code,Chapter 2,Subchapter 2B,Section.0506(a)(1)(A)which states that"monthly monitoring reports
shall be filed no later than 30 days after the end of the reporting period for which the report was made."
On 12/1/2004,Mr.Kevin Bowden from this office contacted Ms.Amy Parham with Handex to determine why our
office had not received the September AT report form. Ms.Parham was requested to fax the form along with support
information to document timely receipt by our office. Ms Parham faxed the September 2004 AT test result to our office on
12/1/2004 as requested. Ms.Parham was also asked to submit an original completed AT form for September via US mail.
Your Discharge Monitoring Reports(DMR)for September 2004 was received by the Division's Central Files on
11/4/2004. The September 2004 DMR indicated a toxicity test was performed on 9/16/2004. We remind pemtittees that
reporting of toxicity self-monitoring data is a dual requirement. Toxicity test results must be entered on your DMR and the
Aquatic Toxicity Reporting Form(AT-1)must be submitted to: DWQ/ESS, 1621 Mail Service Center,Raleigh NC 27699-1621
within the required time frame.
We encourage the Company to consider submitting toxicity test results to our office via certified mail.
You will be considered noncompliant with the reporting requirements contained in your NPDES Permit for the month
of September 2004 until you make acceptable demonstration to the Environmental Sciences Section that the report form was
submitted to this office within the required 30 day reporting period. Please be advised that the September 2004 toxicity late
reporting event subjects the Company to the enforcement authority of the Division.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting requirements.
Please read this one page summary and if you have any questions concerning this Notice,please contact Mr.Kevin Bowden with
the Aquatic Toxicology Unit at(919)733-2136.
Sincerely,
Overton
Chief,Environmental Sciences Section
cc:
John Leslie-Mooresville Regional Office
Aquatic Toxicology Unit Files
Central Files N Carolina
/vaturally
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh,NC 27699-1621 Phone[phone] Customer Service
Internet www.esb.enr.state.nc.us 4401 Reedy Creek Rd. Raleigh,NC 27607 FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and
reporting information. Please take time to review this information. The items below do not address or include all the toxicity
testing and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity-
testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at [phone] or another Unit
representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report
forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting
period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon
failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at
least two multiple concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as
can be completed will be accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure
of any single quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity
testing per the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will
influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit,except for NPDES Permits which contain episodic toxicity monitoring
requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and December, then toxicity
testing must be conducted during these months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing this monthly test requirement,the permittee will revert to the
quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30, then you
must provide written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six
months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental
Sciences Section at [phone] and provide written documentation indicating why the test was invalidated and the date when
follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the
information block located at the top of the AT`form indicating the facility name, permit number, pipe number, county and the
month/year of the subject report. You should also write "No Flow" on the AT form, sign the form and submit following normal
procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities which
have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT
form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting your
toxicity test results certified mail,return receipt requested to the Environmental Sciences Section.

\-\OF W A 7F9QG Michael F.Easley
Governor
William G.Ross,Jr.,Secretary
Department of Environment and Natural Resources
Alan W.Klimek,P.E.,Director
Division of Water Quality
June 29,2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
t L UT.Cr ENVIRONMENT
Mr.Edward J.Petrie
,.; k ,.-:: .i F"SOURCES
Rhodia,Inc. "`'AL OFFICE
Cn 7500
Cranbury,New Jersey 08512
SUBJECT: NOTICE OF VIOLATION JUL 0 1 2004
Effluent Toxicity Testing
NPDES Permit No.NC0084638
Rhodia,Inc.
Gaston County
Dear Mr.Petrie:
This is to inform you that the Environmental Sciences Branch has not received your toxicity self-
monitoring report form for the month of April 2004. This is in violation of Title 15A of the North Carolina
Administrative Code,Chapter 2, Subchapter 2B,Section.0506(a)(1)(A)which states that"monthly
monitoring reports shall be filed no later than 30 days after the end of the reporting period for which the
report was made."
Your Discharge Monitoring Report for April 2004 does not indicate that a chronic toxicity test
was conducted. Please remember that reporting of toxicity self-monitoring data is a dual requirement.
Toxicity test results must be entered on your Discharge Monitoring Report and the Aquatic Toxicity
Reporting Form(AT Report Form)must be submitted to: DWQ/ESB, 1621 Mail Service Center,Raleigh
NC 27699-1621 within the required time frame.
You will be considered noncompliant with the reporting requirements contained in your NPDES
Permit for the month of April 2004 until you make acceptable demonstration to the Environmental Sciences
Branch that the report form was submitted to this office within the required 30 day reporting period.
Failure to submit toxicity self-monitoring report forms as required by the NPDES Permit subjects
Rhodia,Inc.to the enforcement authority of the Division.
Our office received your May 2004 toxicity test result within the required 30 reporting period.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting
requirements. Please read this one page summary and if you have any questions concerning this Notice,
please contact Mr.Kevin Bowden with the Aquatic Toxicology Unit at(919)733-2136.
Sincerely,
• verton
Assistant Water Quality Section Chief
for Environmental Sciences
cc: Rex Gleason-Mooresville Regional Office
',,� :. . '•III _ ,,.
Aquatic Toxicology Unit Files
—4711 Central Files
N aENR
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh,NC 27699-1621 [phone]
800 623-7748

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information.The items below do not address or include
all the toxicity testing and reporting requirements contained in your NPDES permit. If you should have any questions
about your toxicity-testing requirement,please contact Mr.Kevin Bowden with the Aquatic Toxicology Unit at(919) 733-
2136 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
permit limit,then at least two multiple concentration toxicity tests(one per month)will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December,then toxicity testing must be conducted during these months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required,then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing.this monthly test requirement,the permittee will
revert to the quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not occur
during the first six months of the calendar year.
➢ If you receive notification from your~contract laboratory that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at (919) 733-2'136 and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the
information block located at the top of the AT form indicating the facility name,permit number,pipe number, county and
the month/year of the subject report. You should also write"No Flow"on the AT form,sign the form and submit following
normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities
which have not received a facility classification. In these cases,a duly authorized facility representative must sign the AT
form. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting
your toxicity test results certified mail,return receipt requested to the Environmental Sciences Branch.

WATF Michael F.Easley
O 9 Governor
C.)‘ pG William G.Ross,Jr.,Secretary
g. . r Department of Environment and Natural Resources
—I Alan W.Klimek,P.E.,Director
Division of Water Quality
June 29,2004
CERTIFIED MAIL rIG r
RETURN RECEIPT REQUESTED ANf
Mr.Edward J.Petrie
Rhodia,Inc.
Cn 7500
Cranbury,New Jersey 08512 JULC 2C04
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No.NC0084638
Rhodia,Inc.
Gaston County
Dear Mr.Petrie:
This is to inform you that the Environmental Sciences Branch has not received your toxicity self-
monitoring report form for the month of April 2004. This is in violation of Title 15A of the North Carolina
Administrative Code,Chapter 2, Subchapter 2B,Section.0506(a)(1)(A)which states that"monthly
monitoring reports shall be filed no later than 30 days after the end of the reporting period for which the
report was made."
Your Discharge Monitoring Report for April 2004 does not indicate that a chronic toxicity test
was conducted. Please remember that reporting of toxicity self-monitoring data is a dual requirement.
Toxicity test results must be entered on your Discharge Monitoring Report and the Aquatic Toxicity
Reporting Form(AT Report Form)must be submitted to: DWQ/ESB, 1621 Mail Service Center,Raleigh
NC 27699-1621 within the required time frame.
You will be considered noncompliant with the reporting requirements contained in your NPDES
Permit for the month of April 2004 until you make acceptable demonstration to the Environmental Sciences
Branch that the report form was submitted to this office within the required 30 day reporting period.
Failure to submit toxicity self-monitoring report forms as required by the NPDES Permit subjects
Rhodia,Inc.to the enforcement authority of the Division.
Our office received your May 2004 toxicity test result within the required 30 reporting period.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting
requirements. Please read this one page summary and if you have any questions concerning this Notice,
please contact Mr.Kevin Bowden with the Aquatic Toxicology Unit at(919)733-2136.
Sincerely,
verton
Assistant Water Quality Section Chief
for Environmental Sciences
John Lesley-Mooresville Regional Office
Aquatic Toxicology Unit Files
ATACentral Files
IWDENR
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh,NC 27699-1621 [phone]
800 623-7748

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information.The items below do not address or include
all the toxicity testing and reporting requirements contained in your NPDES permit. If you should have any questions
about your toxicity-testing requirement,please contact Mr.Kevin Bowden with the Aquatic Toxicology Unit at(919) 733-
2136 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
permit limit,then at least two multiple concentration toxicity tests(one per month)will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December,then toxicity testing must be conducted during these months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required,then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing.this monthly test requirement,the permittee will
revert to the quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not occur
during the first six months of the calendar year.
➢ If you receive notification from your,.contract laboratory that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the
information block located at the top of the AT form indicating the facility name,permit number,pipe number, county and
the month/year of the subject report. You should also write"No Flow"on the AT form,sign the form and submit following
normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities
which have not received a facility classification. In these cases,a duly authorized facility representative must sign the AT
form. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting
your toxicity test results certified mail,return receipt requested to the Environmental Sciences Branch.

\N'`'!'� Michael F. Governor
0����'pG William G.Ross al Secretary
� North Carolina Department ofEnvironmrnt and Natural Resources
r
Alan W.Klimek.P.E.Director
Isimmtmgewitaisiar
y Division of Wate Quality
coieen H.Sullins.Deputy Director
Division of Water Quality
March 24,2004
Mr. Ed Petrie
Rhodia, Inc.
CN 7500
Cranbury,NJ 08512-7500
Subject: Toxicity Test Results
Rhodia,Inc. Groundwater Remediation System
NPDES Permit No.NC0084638
Gaston County,NC
Dear Mr Petrie:
Enclosed is a copy of the toxicity test results relative to the inspection conducted at the
subject facility on March 9, 2004 by John Lesley of this Office. Effluent Samples were collected
on March 9 and 12, 2004 by Division staff for use in a chronic Ceriodaphnia dubia pass/fail
toxicity test. The test utilizing these samples resulted in a pass. •
The report should be self-explanatory;however, should you have any questions concerning
this report,please do not hesitate to contact Mr. Lesley or me at(704)663-1699.
Sincerely,
•
D. Rex Gleason,P. .
Water Quality Regional Supervisor
Enclosure
cc: Central Files
Aquatic Toxicology Unit
Gaston County Health Department
One
•1o;d -ail L.a
,/�/ y t+ICDFf+rit
N.C.Division of Water Quality, Mooresville Regional Office, 919 North Main Street, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

Rhodia, Inc. GW Remediation System
NPDES Permit No.NC0084638
Page 2
Whole effluent samples were collected on March 9 and 12, 2004 by Division staff for use
in a chronic Ceriodaphnia dubia pass/fail toxicity test. Rhodia, Inc. has an effluent discharge
permitted at 0.1944 MGD entering a UT of Crowders Creek(7Q10 of 0.0 CFS). The test using
these samples resulted in a pass. Toxicity test information follows:
Test Type 3-Brood Ceriodaphnia dubia pass/fail
Test Concentration 90%sample
Test Result Pass
Control Survival 100%
Control Mean Reproduction 23.4 neonates
Test Treatment Survival 100%
Treatment Mean Reproduction 24.5 neonates
First Sample pH 6.98 SU
First Sample Conductivity 232 micromhos/cm
First Sample Total Residual Chlorine <0.0052 iiig/1
Second Sample pH 6.91 SU
Second Sample Conductivity 219 micromhos/cm
Second Sample Total Residual Chlorine <0.0052 mg/1
Test results for these samples indicate that the effluent would not be predicted to have
water quality impacts on the receiving stream.

N(ypEPT.OF •FNVIRORMtiJT
Division of Water Quality ANDTu 'DICES
-Aquatic Toxicology Unit sopRESVI�.I �N� OFFICE
March 19,2004
MAR 2 3 2004
MEMORANDUM �+�{
To: Rex Gleason ������ a .3'� SEC i=k`,'
Water Quality Supervisor,MRO
Through: Matt Matthews 14"
tr
Supervisor,Aquatic Toxicology Unit
From: Sandy Mort 40t/
Quality Assurance Officer,Aquatic Toxicology Unit
Subject: Whole effluent toxicity test results
Rhodia,Inc.
NPDES Permit#NC0084638/001
Gaston County
The aquatic toxicity test using grab samples of effluent discharged from Rhodia's groundwater
remediation facility has been completed. Rhodia has an effluent discharge permitted at 0.1944
million gallons per day(MGD)entering UT Crowders Creek(7Q10 of 0.0 CFS). Whole effluent
samples were collected on March 9 and 12,2003 by John Lesley for use in a chronic Ceriodaphnia
dubia pass/fail toxicity test. The test using these samples resulted in a pass. Toxicity test
information follows.
Test Type 3-Brood Ceriodaphnia dubia pass/fail
Test Concentrations 90%sample
Test Result Pass
Control Survival 100%
Control Mean Reproduction 23.4 neonates
Test Treatment Survival 100%
Treatment Mean Reproduction 24.5 neonates
First Sample pH 6.98 SU
First Sample Conductivity 232 micromhos/cm
First Sample Total Residual Chlorine <0.0052 mg/L
Second Sample pH 6.91 SU
Second Sample Conductivity 219 micromhos/cm
Second Sample Total Residual Chlorine <0.0052 mg/L
Test results for these samples indicate that the effluent would not be predicted to have water quality
impacts on receiving water. Please contact us if further effluent toxicity monitoring is desired. We
may be reached at(919) 733-2136.
Basin: CTB37
cc: Central Files
Environmental Sciences Branch Water Quality Section

W ATF9 Michael F.Easley
p Governor iuK:
r Department of Environment and Natural Resources
0 + Alan W.Klimek,P.E.,Director
Division of Water Quality
May 28,2003.
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Mr.Edward J.Petrie
Rhodia Inc.
Cn 7500 ;r3
i•
Cranbury,New Jersey 08512
Subject: NOTICE OF DEFICIENCY
Effluent Toxicity Testing
NPDES Permit No.NC0084638 �r+rr iVv ��#'�
Rhodia,Inc.Treatment Facility
Gaston County
Dear Mr.Petrie:
This is to inform you that the Environmental Sciences Branch has not received your toxicity self- •
monitoring report form for March 2003. This is in violation of Title 15A of the North Carolina
Administrative Code,Chapter 2,Subchapter 2B,Section.0506(a)(1)(A)which states that"monthly
monitoring reports shall be filed no later than 30 days after the end of the reporting period for which the
• report is made."
Information contained on your March 2003 DMR indicates that a toxicity test was conducted on
March 18;however,the Environmental Sciences Branch did not receive the Aquatic Toxicity Test Form
within the 30 day reporting period.
Please remember that reporting of toxicity self-monitoring data is a dual requirement. Toxicity test
results must be entered on your Discharge Monitoring Report and the Toxicity Reporting Form(AT Report
Form)must be submitted to: DWQ/ESB, 1621 Mail Service Center,Raleigh NC 27699-1621 within the
required time frame.
You are requested to submit the March 2003 toxicity self-monitoring report form to this office
no later than June 30,2003. Failure to submit the report form by June 30,2003 will result in issuance
of a Notice of Violation.
Please be reminded that late and/or non-reporting of toxicity self-monitoring data subjects you to the
enforcement authority of the Division.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting
requirements. Please read this one page summary and if you have any questions concerning this Notice
please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at(919)733-2136.
Sincerely,dait.
D�
• Overton
• ssistant Water Quality Section Chief
For Environmental Sciences
cc: li..� Ile Regional Office
John Lesley-Mooresville fteilelfffilDffice
Aquatic Toxicology Unit Files
Central Files
ANTA
NCDENR
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh,NC 27699-1621 [phone]
1.800 623-7748

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
> The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information.The items below do not address or include
all the toxicity testine and reportine_reauirements contained in your NPDES permit. If you should have any questions
about your toxicity testing requirement,please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at(919) 733-
2136 or another Unit representative at the same number.
> The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
> The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
• > Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the
reportine period(eg,January test result is due by the end of February). •
> Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
permit limit,then at least two multiple concentration toxicity tests(one per month)will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
> Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December,then toxicity testing must be conducted during these months).
> Should the permittee fail to monitor during a month in which toxicity monitoring is required,then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing this monthly test requirement,the permittee will
revert to the quarterly months specified in the permit. Please note that your permit may or may not contain this language.
> If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not occur
during the first six months of the calendar year.
> If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur.
> If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the
information block located at the top of the AT form indicating the facility name, permit number,pipe number, county and
the month/year of the subject report. You should also write"No Flow"on the AT form,sign the form and submit following
normal procedures.
> The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities
which have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT
form. The AT form must also be signed by the performing lab supervisor.
> To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting
your toxicity test results certified mail,return receipt requested to the Environmental Sciences Branch.

O�G�w A T FRQ G Michael F.Easley
Governor
William G.Ross,Jr.,Secretary
> _ Department of Environment and Natural Resources
0 `•c Alan W.Klimek,P.E.,Director
Division of Water Quality
August 23, 2002 EIEP- •
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Edward J. Petrie AUG 7 2002
Rhodia Inc.
CN 7500
Cranbury,New Jersey 08512
Subject: NOTICE OF DEFICIENCY
Effluent Toxicity Testing
NPDES Permit No. NC0084638
Rhodia Inc. WWTP
Gaston County
Dear Mr. Petrie:
This is to inform you that the Environmental Sciences Branch has not received your
toxicity self-monitoring report form for the month of June 2002. This is in violation of Title 15A of
the North Carolina Administrative Code,Chapter 2, Subchapter 2B, Section .0506(a)(1)(A) which
states that"monthly monitoring reports shall be filed no later than 30 days after the end of the
reporting period for which the report is made."
Information contained on your June 2002 DMR indicates that a toxicity test was conducted
during the month of June; however,the Aquatic Toxicity Test Form was not received by the
Environmental Sciences Branch within the 30 day reporting period. To prevent further action,
please submit an original toxicity self-monitoring report form by September 13, 2002 or notify this
office of any problem which may have prevented the report from being received on time. Failure
to submit the June 2002 test form by the date specified above will result in the issuance of a Notice
of Violation. Additional reporting and/or monitoring violations within a twelve(12)month period
may subject you to a civil penalty assessment.
The reverse side of this Notice contains a summary of important toxicity monitoring and
reporting requirements. Please read this one page summary and if you have any questions
concerning this Notice please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at
[phone].
Sincerely,
erton
Assistant Water Quality Section Chief
for Environmental Sciences
cc: ' ;ex Gleason-Mooresville Regional Offic
John Lesley-Mooresville Regional Office
Aquatic Toxicology Unit Files
Central Files
MENR
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh,NC 27699-1621 [phone]
1-800 623-7748

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information.The items below do not address or include
all the toxicity testing and reporting requirements contained in your NPDES permit. If you should have any questions
about your toxicity testing requirement,please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at(919) 733-
2136 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the .
permit limit,then at least two multiple concentration toxicity tests(one per month)will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December,then toxicity testing must be conducted during these months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required,then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing this monthly test requirement,the permittee will
revert to the quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not occur
during the first six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and
the month/year of the subject report. You should also write"No Flow"on the AT form,sign the form and submit following
normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities
which have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT
form. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting
your toxicity test results certified mail,return receipt requested to the Environmental Sciences Branch.