WQ0010197_Regional Office Historical File Pre 2018 (2)

71
Governor
MICHAEL S. REGAN
Secretary
WS. JAY ZIMMERMAN
Water Resources
Director .
Environmental Quality
September 5, 2017
Mr. Jimmy Summers, VP-EHS (via email)
American & Efird, LLC
Post Office Box 507
Mt. Holly, North Carolina 28120
Subject: Non -Discharge Permit Inspection
Recycle.System. - Permit #WQ0010197
American & Efrid Facility
Finishing Plant #15
Gaston County
Dear Mr. Summers,
Enclosed you will find the report. for the compliance inspection conducted on August 31st, 2017, at the,
referenced facility. I would like. to thank John Smith, Amber Friday and John -Boyer for their time during
the site visit.
The recycle system and records appeared to be well maintained. The issue with the High Water Alarm
that was noted in last year's site visit has been repaired and the alarm is functioning correctly.
The permit expiration date is April 30, 2018. Per permit requirements; a renewal application is due 180
days prior to expiration. Adding the cooling water to the recycle.system would require
addition/modification to this. permit, should you decide to rescind the NPDES.permit. The renewal form
is located on the NCDEQ website at: http://deg.nc.gov/about/divisions/water. resources/water-
resources-permits/wastewater-branch/non-discharge-permitting-unit/application. This change would
need to be covered in the permit renewal prior to rescission of NPDES permit NCG500180.
State of North Carolina I Environmental Quality 1 Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

Permit W00010197 Owner -Facility: American & Efird LLC
Inspection Date: 08/31/2017 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Are flow rates less than of permitted flow?
❑ ❑ ❑
Are application rates adhered to?
❑ ❑ 0 ❑
Is GW monitoring being conducted, if required (GW-59s submitted)?
❑ ❑ N ❑
Are all samples analyzed for all required parameters?
❑ ❑ 0 ❑
Are there any 2L GW quality violations?
❑ ❑ M ❑
Is GW-59A certification form completed for facility?
❑ ❑ 0 ❑
Is effluent sampled for same parameters as GW?
❑ ❑ 0 ❑
Do effluent concentrations exceed GW standards?
El 0 ❑
Are annual soil reports available?
❑ ❑ 0 ❑
# Are PAN, records required?
❑ ❑ M ❑
# Did last soil report indicate a need for lime?
❑ ❑ 0 ❑
If so, has it been applied?
❑ ❑ 0 ❑
Are operational logs present?
E ❑ -❑ ❑
Are lab sheets available for review?
El El❑
Do lab sheets support data reported on NDMR?
❑ ❑ 0 ❑
Do lab sheets support data reported on GW-59s?
❑ ❑ 0 ❑
❑ ❑ ❑
Are Operational and Maintenance records present?
Were Operational and Maintenance records complete? E ❑ ❑ ❑
Has permittee been free of public complaints in last 12 months? ❑ El El
Is a copy of the SOC readily available? ❑ ❑ N ❑
No treatment units bypassed since last inspection? ❑ E ❑ ❑
Comment: This is a closed loop recycle system Records are kept of the pressures which indicate when
differetial pressure changes and the tank back washes This pressure difference is also a
method of verification of the condition of the filter media Many of the questions in this section do
not apply to this permit.
Page: 4

..
r• `
Schutte, Maria
From: Schutte, Maria
Sent: Friday, September 02, 2016 11:23 AM
To: '[e-mail]'
Cc: Pitner, Andrew
Subject: FW: WQ0010197 American and Efird Insp Rpt
Jimmy,
My apology, I did not answer all of your questions. Yes, we would still need to add this as a source to the Recycle
permit.
Maria
From: Schutte, Maria
Sent: Friday, September 02, 2016 11:17 AM
To:'[e-mail]' <[e-mail]>
Cc: Pitner, Andrew <[e-mail]>
Subject: RE: WQ0010197 American and Efird Insp Rpt
Jimmy,
ThankYou�for�fih�e`�p`oint�'-sad•'dr-es'�� da�tta h t"�c �i email to ou`�"�'r�file�copy anfd�rn'akert�heacor�r�ectio.ns�to�Frutu.re° '"�-�
0insp_ectr0nfrepor i-
Maria
From: [e-mail][mailto:[e-mail]]
Sent: Wednesday, August 31, 2016 4:11 PM
To: Pitner, Andrew <[e-mail]>
Cc: Schutte, Maria <[e-mail]>; [e-mail]
Subject: RE: WQ0010197 American and Efird Insp Rpt
Maria -
One correction to the 4th bullet point in the cover letter that came with the report, and also the comment on the same
issue under the Recycle & Raw Water Reservoir section of the report: The non -contact cooling water that is sent to the
raw water pond is not associated with the boiler in any way. It is non -contact cooling water that is used to cool dye
machines. The water has no chemicals in it, comes directly from the Raw Water Treatment Plant, and does not come into
contact with any process materials. So in the report, the references to this cooling water should be "non -contact cooling
system water" instead of "boiler non -contact cooling system wastewater" and "non -contact boiler cooling water". Since
this is clean non -contact cooling water and not associated with the boiler in any way, does it need to be added to the -
Recycle Permit if we decide not to renew NPDES Permit #NCG500180?
Also, in "Other Noted Conditions" in the report, the second sentence begins "[t]hese appear to be necessary repairs to the
WWTP.." Please note that the treatment system is a Raw Water Treatment Plant (RWTP) and not a Waste Water
Treatment Plant (WWTP). So the sentence should read "[t]hese appear to be necessary repairs to the RWTP..."
Are you able to make corrections to the report and reissue it?
Thanks!

1
Jimmy
� , I;to•�?ri��i�`
Jimmy Summers I Vice President - Environmental, Health & Safety/Sustainability I Environmental, Health & Safety Department
I American & Efird LLC I P.O. Box 507 1 22 American St., Mount Holly, NC 28120 1 704.951.2578 (tele) 1 704.898.6185 (cell)
[e-mail] I http://www.amefird.com
From: "Pitner, Andrew" <andrew,pitner(@ncdenr.gov>
To: "Jim mv.Summers(o)amefird.com" <Jimmy.Summers(@amefird.com>, "Schutte, Maria" <maria.schutteCa)_ncdenr.gov>,
Date: 08/31/2016 02:01 PM
Subject: RE: WQ0010197 American and Efird Insp Rpt
A copy is attached.
Andrew
From: [e-mail] [mailto:[e-mail]]
Sent: Wednesday, August 31, 2016 1:37 PM
To: Schutte,'-Maria <[e-mail]>
Cc: Pitner, Andrew <[e-mail]> VC.
Subject: Re: WQ0010197 American and Efird Insp Rpt
Hi Maria -
Can you please try to send the inspection report again? I see both of the application form documents, but not the
inspection report.
Thanks,
Jimmy
g Eco.w.' s
Jimmy Summers I Vice President - Environmental, Health & Safety/Sustainability I Environmental, Health & Safety Department
I American & Efird LLC I P.O. Box 507 1 22 American St., Mount Holly, NC 28120 1 704.951.2578 (tele) 1 704.898.6185 (cell) 1
[e-mail] I http://www.amefird.com
From: "Schutte, Maria" <maria.schutte(g)ncdenr.gov>
To: "iimmy.summers(aD_amefird.com" <iimmv.summers(a)_amefird.com>,
Cc: "Pitner, Andrew" <andrew.pitnerCcilncdenr.gov>
Date: 08/30/2016 05:54 PM
Subject: WO0010197 American and Efird Insp Rpt

b
Mr. Summers,
Attached is a copy of the recent inspection report for you records and both of the application forms mentioned. The web -link is also
included in the report, should you have any trouble opening the forms from this email.
Please contact me with any questions.
Sincerely,
Maria Schutte
Environmental Specialist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 663 1699 office
704 235 2184 direct
Maria. schutte(a)-ncdenr.gov
610 East Center Avenue
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
[attachment "image001.png" deleted by Jimmy Summers/Amefird] [attachment "NDPONC 06-16.docx" deleted by Jimmy
Summers/Amefird] [attachment "NDSR 06-16.docx" deleted by Jimmy Summers/Amefird]
The information contained in or attached to this e-mail is confidential and is intended for the use of the individual or entity
named above. You are hereby notified that access, disclosure, copying or distribution by any other person or entity is
strictly prohibited. If you have received this communication in error, please immediately notify the sender or our
Information Systems Help Desk at [phone], Extension 4357, and destroy the original message. Thank
you.[attachment "WQ0010197 American and Efird Insp Rpt-08302016.pdf' deleted by Jimmy Summers/Amefird]
The information contained in or attached to this e-mail is confidential and is intended for the use of the individual or entity
named above. You are hereby notified that access, disclosure, copying or distribution by any other person or entity is
strictly prohibited. If you have received this communication in error, please immediately notify the sender or our
Information Systems Help Desk at [phone], Extension 4357, and destroy the original message. Thank you.

PAT MCCRORY
.fir.
j�
N .tom
t
Water Resources
ENVIRONMENTAL QUALITY
Governor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN
Director
Mr. Jimmy Summers, VP-EHS
American & Efird, LLC
Post Office Box 507
Mt. Holly, North Carolina 28120
Dear Mr. Summers:
August 30, 2016
via email I L ru-mm
Subject: Non -Discharge Permit Inspection
Recycle System - Permit #WQ0010197
Facility — Finishing Plant #15
Gaston County
Enclosed you will find the report for the compliance inspection conducted on August 17th, 2016 at the
referenced facility. I would like to thank you and John Smith for your time during the site visit.
Per our conversation(s), I noted below a couple of points to maintain overall site compliance with the
non -discharge system. Some information mentioned in last year's inspection report remains relevant,
so is reiterated with an updated website link.
• The recycle system and records appeared to be well maintained; however, a high water alarm
was found to be inoperable and is to be repaired by fall, after a nearby wasp nest is vacated.
• A Non -Discharge Permit Ownership/Name Change form (NDPONC 06-16) should be
submitted as soon as possible, so we may update our record_ s with you as the permittee and
having signature authority. The form is located on the NCDEQ website at:
http://deq. nc. qov/about/divisions/water-resources/water-resources-permits/wastewater-
branch/non-discharge-permitting-unit/application.
• The permit expiration date is 6/30/2018. Per permit requirements, a renewal application is due.
180 days prior to expiration.
• Recycle of the boiler's non -contact cooling system wastewater to the pond would require
addition/modification to this permit, should you decide to rescind the NPDES permit. The source
addition may be accomplished during permit renewal in 2018; or, by permit modification if you
decide to make this a permanent closed -loop feature. Either way, this process would need to be
covered under this permit prior to rescission of the NPDES permit #NCG500180. The Non
Discharge System Renewal application form (NDSR 06-16) may be also be located at the
web -link above.
The report should -be self-explanatory; however, should you have any questions, feel free to call me at
704-235-2184 or contact me via email at maria.schutteCa)ncdenr.gov.
Sin�y, 1
�'�
Maria Schutte, Environment I Specialist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure(s): Inspection Report August 2016
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office) 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704 663 1699

- State of North Carolina Department of Environmental Quality
Division of Water Resources
Pat McCrory, Governor
Donald R. van der Vaart, Secretary
NON -DISCHARGE COMPLIANCE INSPECTION
Recycle/Reuse/Reclamation .System
GENERAL INFORMATION
Owner: American & Efird, LLC County: Gaston
Permit.#: W00010191(non-discharge WWTP) Project Name: A&E Finishing Plant #15
Issuance Date: 12/05/2011 Expiration Date: 04/30/2018
Permittee Contact: Jimmy Summers, VP EHS & Sustainability Phone: [phone] Cell: 704-898-6185
Email: jiMM.summersgamefird.com
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Date(s): August 17, 2016
Inspection Summary: (additional comments maybe included on attached pages)
Historic System Description: The permitted system is composed of an Alum Floc/Settling Lagoon, which
also receives on -site drain water and filter backwash water from the WWTP sand filters. A floating effluent
box is set below freeboard and routinely skims decant water from the settling pond to a clear well/pump
station back to the head of the plant, which is the recycle & raw water (Catawba River or Groundwater)
storage pond.
Please note:
• On -site records and the Lagoon(s)/Recycle system appeared well maintained, at the time of
inspection; however, a high water alarm was inoperable and is in need of repair as noted. in
the cover letter, along with additional items to maintain compliance.
• The MRO should be informed of any changes to the contact information noted above.
Is a follow-up inspection necessary _yes X no
Inspector Name/Title: Maria Schulte, Environmental Specialist
Telephone No.:. 704-235-2184. Fax No. 704-663-6040
Date of Inspection: 8/17/2016

�r
Non -Discharge Permit Inspection Page 2
Permit #WQ0010197 American and Efird, LLC — Gaston County
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational? If no, note below.
Alum Sludge & Filter Backwash Basin
(check any/all that apply)
Y Influent structure (free of obstructions)
NA Baffles/curtains (in need of repair)
* Y Freeboard maintained
N Evidence of overflow
N Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
* Y Excessive solids buildup (from bottom) * The lagoon has a couple of feet of clear water vet.
Sufficient to maintain adequate decant b their system. The MRO did not request a sludge jud e be used.
Y Effluent structure (free of obstructions, easily accessible)
Comment: * Per conversation with Mr. Summers. the Alum solids have not been removed
pond since about 2008. A residuals cleanout event will likely be scheduled in the next 1-2 years. A
freeboard gauge has not been installed, but freeboard is adequately maintained by the floating decant box.
Recycle & Raw Water Reservoir
(check any/all that apply)
Y Influent structure
NA Baffles/curtains (in need of repair)
Y Freeboard maintained
N Evidence of overflow
N Unusual color
N Foam
NE Excessive solids build-up
Y Effluent structure (free of obstructions, easily accessible)
Comment: The non -contact boiler cooling water needs to be added as a source by the next permit renewal.
The high water alarm noted in the cover letter is to be repaired for both audible and visual, after the
residents of a nearby wasp nest have vacated.
Residuals
storage/treatment: NA — see comments under Alum Basin above.
Recordkeeping
Y Is permit available upon request?
Y Are operational logs present? Y Complete?
Y Is the operation and maintenance manual present? Complete?
N Has DWR received any complaints regarding the facility in the last 12 months?
Other noted conditions
Discussed the future placement of graduated water -level gauges to best meet that permit condition;
although, the MRO has not seen any indication that the 2 foot freeboard is an issue with either lagoon.
Out -dated sand filter units are being replaced with newer technology. These appear to be necessary repairs
to the WWTP and not a modification to the permit, but MRO staff should further evaluate at permit renewal.

610 E Center Ave, Mooresville, NC 28115 to american & efird - Google Maps Page 1 of 2
Ogle map,$ 610 E Center Ave, Mooresville, NC 28115 Drive 31.5 miles, 40 min
to american & efird
Map data ©2017 Google United States 2 mi L
610 E Center Ave
Mooresville, NC 28115
Get on 1-77 S in Davidson from E Wilson Ave and NC-1100/13rawley School Rd
Rin-P.7 mi)
t 1. Head west on. E Center Ave toward Cedar St
------0.5 mi
'07 2. Turn left onto S Church St
r 3. Turn right onto E Wilson Ave
t 4. Continue onto NC-1100/Brawley School Rd
A 5. Turn left to merge onto 1-77 S
4mi
5 mi
0 mi
3 mi
Follow 1-77 S and 1-485 Outer to NC-27 W/Mt Holly Rd in 12, Paw Creek. Take exit 14 from 1-485 Outer
-- 2 rnirr(-24.2 mi)
6. Merge onto 1-77 S
mi
7. Use the right 2 lanes to take exit 19A-19B for Interstate 485 Outer S
1.1 mi
htt-os://www.v-oo2le.com/maDs/dir/61 O+E+Center+Ave,+Mooresville,+NC+28115/america... 8/24/2017

610 E Center Ave, Mooresville, NC 28115 to american & efird - Google Maps Page 2 of 2
A 8. Merge onto 1-485 Outer
r 9. Take exit 14 for NC-27/Mt Holly Rd
1 mi
mi
Continue on NC-27 W. Drive to American St in Mount Holly
r * 10. Turn right onto NC-27 W/Mt Holly Rd
1.4 mi
41
11.
Turn left to stay on NC-27 W/Mt Holly Rd
Continue to follow NC-27 W
mi
41
12.
Turn left onto Highland St
-- - ---
0.5 mi
*1
13.
Turn left onto A & E Dr
0^.1 mi
t
14.
Continue onto American St
Destination will be on the left
---- —
- 0.1 mi
American & Efird Inc
24 American St, Mt Holly, NC 28120
These directions are for planning purposes only. You may find that construction
projects, traffic, weather, or other events may cause conditions to differ from the
map results, and you should plan your route accordingly. You must obey all signs or
notices regarding your route.
httDs://www.2oo2le.comlmaT)s/dir/610+E+Center+Ave,+Mooresville,+NC+281151america... 8/24/2017

'A I I . rmin �� ` E
NCDENR
North Carolina Department of Environment. and natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
August.7, 2015
American & Efird, LLC
Post Office Box 507
Mt. Holly, North Carolina 28120
Attention: John. Eapen
Subject: Non -Discharge Permit Inspection
Recycle System -Permit No.: WQ0010197
Facility — Finishing Plant #15
Gaston County, NC
Dear Mr. -Eapen:
-Enclosed you will find the report for the inspection conducted on July 15t', 2015, for the
referenced Non -Discharge Recycle permit. The report reflects compliance at the time of
inspection. I would like to thank you and your staff for your time during the site visit.
Per our conversation(s), I noted below a couple of points to maintain overall site
compliance -'with the non -discharge. system and the on -site water supply well system.
• Recycle -of the boiler's non -contact cooling system wastewater to the pond would require
addition/modification to this permit, should your pilot test prove to be successful and you
decide to rescind the NPDES permit. The source addition could be accomplishedat the
same time as this permit renewal in 2018; or, by permit modification if you decide to
make this a permanent closed -loop feature soon. Either way, this process would need to
be covered under this permit prior to rescission of the NPDES permit #NCG500180. The
application may be located on the NCDENR website at:
http:Bportal.ncdenr.org/web/Wg/aps/lau/applications
The permit expiration date is 6/30/2018. Per permit requirements, a renewal
application is due 180 days. prior to expiration.
• The application for a large capacity water system is NOT required at this time. A
construction permit would be required, prior to construction,should you wish to add a
well(s) to- the existing irrigation system. In addition, when you utilize the wells, if you
pump ? 100,000 gpd, the water withdrawal should be registered at:
htip://www.ncwater.ora/Permits and Reaistration/Water Withdrawal and Transfer. Rea
istration/report/log i n
- Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Phone: [phone] / Fax: [phone] / Customer Service:1-877-623-6748
Infornat- UAAW nrrionr nnu
An Equal Opportunity \Affirmative Action Employer— Made in part by -recycled paper

I
The report should be self-explanatory; however, I may be reached by phone [phone]) or email
([e-mail]) with questions.
Sincerely,
Maria Schutte, Environmental Specialist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
Enclosure: WWQ0010197 Inspection Report

State of North Carolina
A Department of Environment
and Natural Resources
Division of Water Resources
Pat McCrory, Governor
Donald van der Vaart, Secretary
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
WASTEWATER RECYCLE SYSTEM
GENERAL INFORMATION
City/Town/Owner: American & Efird, LLC County: Gaston
Permit No.: W00010197 (non -discharge WWTP) Facility Name: A&E Finishing Plant #15
Issued: 12/05/2011 Expiration: 04/30/2018
Permittee Contact: John Eapen (YP - EHS) Phone: [phone] Cell: 704-231-2495
Email: john.eapengamefird.com
Reason for Inspection
X ROUTINE. COMPLAINT FOLLOW-UP OTHER
Type of inspection
Reuse System (golf course) X Recycle System
Inspection Date(s): July 15, 2015
Inspection Summary: (additional comments may be included on attached pages)
The permitted system is composed of an Alum Floc/Settling Lagoon, which also receives on -site drain water
and filter backwash water from the WWTP sand filters. A floating effluent box is set below freeboard and
routinely skims decant water from the settling'pond to a clear well/pump station back to the head of the plant,
which is the recycle & raw water (Catawba River or Groundwater) storage pond.
In addition, a pilot test is underway to add the industrial plant's Non -Contact Boiler Cooling Wastewater to the
recycle system, in hopes of making better use of that water. Should this process become a permanent change,
A&E will need to modify this permit, prior to rescission of their NPDES permit # NCG500180.
In 2008, several irrigation wells were installed to alleviate water concerns during droughts. This system. may at
times withdraw >100,000 gals per day which requires registration at:
httn://www.ncwater orQ/Pennits and Registration/Water Withdrawal and Transfer Registration/report/login
On -site records and the Lagoon(s)/Recycle system appeared well maintained & in compliance with permit
requirements, at the time of inspection.
Please note:
• The permit renewal application is due 180 days prior to expiration.
• The MRO should be informed of any changes to the contact information noted above.
Is a follow-up inspection necessary _yes X no
Inspector(s): _Maria Schutte - Environmental Specialist; Edward Watson.- Hydro eologist
Telephone No.: 704-663-1699 Fax No.: 704-663-6040
Date of Inspection: July 15t', 2015

Recycle System Inspection pg. 2
Permit #WQ0010197 American and Efird, LLC — Gaston County 1
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational? If no, note below.
Alum Sludge & Filter Backwash Basin
(check any/all that apply)
Y Influent structure (free of obstructions)
NA Baffles/curtains (in need of repair)
Y Freeboard maintained
N Evidence of overflow
N Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
* Y Excessive solids buildup (from bottom) * The lagoon has a couple of feet of clear water et
Sufficient to maintain adequate decant by their system The MRO did not request a sludge fudge be used
Y Effluent structure (free of obstructions, easily accessible)
Comment: *Per conversation with Mr. Ea
pen the Alum solids have not been removed from the settling pond
since about 2008.' A residuals cleanout event will likely be scheduled in the next 1-2 years A freeboard
gauge has not been installed, but freeboard is adequately maintained by the floating decant box
Recycle & Raw Water Reservoir
(check any/all that apply)
Y Influent structure
NA Baffles/curtains (in need of repair)
Y Freeboard maintained
N Evidence of overflow
N Unusual_ color
N Foam
NE Excessive solids build-up
Y Effluent structure (free of obstructions, easily accessible)
Comment: The addition of the Boiler Non -contact Cooling water to the closed -loop recycle system will
require a permit modification. See more specific comments in the cover letter and the first page of this
report.
Residuals
storage/treatment: NA — see comments under Alum Basin above.
Recordkeeping
Y Is permit available upon request?
Y Are operational logs present? Y Complete?
Y Is the operation and. maintenance manual present? Complete?
N Has DWR received any complaints regarding the facility in the last 12 months?
Other noted conditions

r
OF \N A TF
>�
American & Efird, LLC
Post Office Box 507
Mt. Holly, North Carolina 28120
Attention: John Eapen
Dear Mr. Eapen:
Beverly Eaves Perdue, Governor
Dee Freeman, Secretary
North Carolina Department of Environment and Natural Resources
Charles Wakild, P.E., Director
Division of Water Quality
AQUIFER PROTECTION SECTION
November 8, 2012
to"—w I L
RE: Recycle System Inspection Report
Non -discharge Permit No. WQ0010197
Facility —Finishing Plant #15
Gaston County, N.C.
Thank you for taking the time to meet with me last week. Enclosed you will find the report for the
compliance inspection that I conducted. The recycle system appears to be functioning satisfactorily and
is in compliance with the permit. The report should be self-explanatory.
We discussed the possibility of modifying the permit to allow for additional flow through the system. If
you desire to discuss this matter with a Central Office staff engineer prior to submitting a formal
modification request, you may use the following link: http://portal.ncdenr.org/web/wqlaps/Iau. Click on
"Submittal Meeting" on the left side of the screen to access the online Submittal Meeting Request Form.
The fee for a major modification is $110. Along with other necessary information, be sure to bring along
the record of the weekly freeboard measurements (Condition IV. 3.of your permit).
Should you have any questions, please feel free to call me at 704/235-2183.
Sincerely,
� !!j
Peggy Finley
Environmental Specialist
Enclosure: Inspection Report
MAF/A&E inspection rpt 11-2-12
One
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] T?�6 /�
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org (/ Ytu1,Qb

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly Eaves Perdue, Governor
Dee Freeman, Secretary
Charles Wakild, P.E., Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
Recycle/Reuse/Reclamation System
GENERAL INFORMATION
City/Town/Owner: American & Efird, LLC County: Gaston
Permit # WQ0010197 Project Name: A&E Finishing Plant #15
Issuance Date: 12/7/04 Expiration Date: 4/30/18
Permittee Contact: John Eapen Telephone No. 704/951-2578
ORC Name: NA
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of Inspection
Reuse System (golf course) _X_ Recycle System
Inspection Summary. (additional comments may be included on attached pages)
The recycle system is operating properly. The alum floc basin and settling pond have been
satisfactorily maintained. The system appears to be in compliance.
Is a follow-up inspection necessary _yes X no
Inspector Name/Title Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 11/2/12

Permit #WQ0010197 Page 2
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational? If no, note below.
Alum Floc Basin
(check any/all that apply)
Y Influent structure (free of obstructions)
_N_ _ Evidence of overflow
_N Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
_N_ Excessive solids buildup (from bottom)
Y Effluent structure (free of obstructions, easily accessible)
Comment: Periodic checks on the thickness of the sludge layer at the bottom of the basin have shown
it to be negligible.
Settling Basin
(check any/all that apply)
Y Influent structure
_N_ Evidence of overflow
_N_ Unusual color
_N_ Foam
N Excessive solids build-up
Residuals
storage/treatment: NA
Recordkeeping
Y. Is permit available upon request?
Y Are operational logs present? _Y_ Complete?
Y Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment:

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American & Efird, Inc.
Post Office Box 507
Mt. Holly, North Carolina 28120
Attention: John Eapen
Dear Mr. Eapen:
IVIMIdt71 F. �0.i Y, --.-
William G. Ross Jr., Secretary
North, grolina Department of Environment and Natural Resources
> Coleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION SECTION
October 3, 2008
RE: Recycle System Inspection Report
Non -discharge Permit No. WQ0010197
Facility — Finishing Plant #15, Alum Floc Basin
Gaston County, N.C.
Enclosed you will find the report for the compliance inspection that I conducted on September 30, 2008
at the referenced facility. The report should be self-explanatory but should you have any questions,
please call me at 704/235-2183.
I have researched your question about the continuing need for a permit for the alum basin and offer the
following information:
• In an effort to control pollution of the State's waters, NC General Statute 143-215.1 establishes
the activities for which permits are required. These include the construction or operation of any
disposal system within the State (a)(2). The basin at the plant serves as a disposal system for
the alum floc.
• Under delegated authority, the Division of Water Quality enforces 15A NC Administrative Code
Subchapter 2T .1001. This section of the rules applies to the permitting of closed -loop disposal
systems in which non -domestic wastewater is repeatedly recycled back through the process in
which the waste was generated.
An active permit will be required until the disposal system is properly decommissioned.
Sincerely,
Peggy Finley
Environmental Specialist
Enclosure: Inspection Report
MAF/A&E inspection rpt 9-30-08
on t NhCaro.
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone]Qtul,/
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org LL

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Coleen H. Sullins, Director
— - 4 0 * 2
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
Recycle/Reuse/Reclamation System
GENERAL INFORMATION
City/Town/Owner: American & Efird, Inc. County: Gaston
Permit # WQ0010197 Project Name: Finishing Plant #15 - Alum
Floc Basin
Issuance Date: 12/7/04
Permittee Contact: John Eapen
ORC Name: NA
Reason for Inspection
X ROUTINE COMPLAINT
Expiration Date: 11/30/09
Telephone No. 704/951-2578
FOLLOW-UP OTHER
Type of Inspection
Reuse System (golf course) X Recycle System
Inspection Summary• (additional comments may be included on attached pages)
The recycle system is operating properly. The alum floc basin has been satisfactorily
maintained.
Is a follow-up inspection necessary yes X no
Inspector Name/Title Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 9/30/07

Ell
Permit #WQ0010197
Page 2
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational? If no, note below. .
Alum Basin
(check any/all that apply)
Y Influent structure (free of obstructions)
NA _ Baffles/curtains (in need of repair)
_N_ _ Evidence of overflow
_N Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
N Excessive solids buildup (from bottom)
Y Effluent structure (free of obstructions, easily accessible)
Comment: Periodic checks on the thickness of the sludge layer at the bottom of the basin
have shown it to be negligible.
Residuals
storage/treatment: NA
Recordkeeping
Y Is permit available upon request?
Y Are operational logs present? _Y_ Complete?
Y Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment:

Subject: MAP
From: Peggy Finley <[e-mail]>
Date: Fri, 01 Dec 2006 09:56:48 -0500
To: [e-mail]
Dawn:
We have looked at the map you submitted and are comfortable that Well #9 meets the
separation distance to the lagoon under the well construction rules. When the
Division finalizes the guidance regarding on -site wells under the new non -discharge
rules, we'll evaluate the situation from that perspective. For now we can all just
sit tight.
Peggy
Peggy Finley - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality - Aquifer'Protection Section
Iredell County Government Center
610 E Center St., Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: (7Q4) 663-6040
1 of 1 12/1/2006 9:57 AM

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North Carolina Department of Environment and Natural Resources
6 Alan W. Klimek, P.E. Director
> Division of Water Quality
AQUIFER PROTECTION SECTION
September 19, 2006
American & Efird, Inc.
PO Box 507
Mount Holly, North Carolina 28120
Attention: John Eapen, Plant Manager
RE: Recycle System Inspection Report
Permit No. WQ0010197
Facility: Mt. Holly Plant
Gaston County, N.C.
Dear Mr. Eapen:
Enclosed you will find the report for the compliance inspection that I conducted on September 13, 2006.
The report should be self-explanatory but should you have any questions, please call me at 704/235-
2183.
Sincerely,
A
IL
Peggy Finley
Hydrogeological Technician
Enclosure: Inspection Report
Cc: Dawn C Reeves, P.E., American & Efird, Inc., EHS Dept., POB 507, Mt. Holly, NC 28120
(with enclosure)
MAF/recycle/A&E/inspection rpt 9-06
1VonrthCarolil
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] oft hCaro i
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Internet: www.newaterquality.org

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
d&17?W'J
loal 0 2
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: American & Efird, Inc. County: Gaston
Permit # W00010197 Project Name:.Mt. Holly Plant
Issuance Date:12/7/04 Expiration Date: 11/30/09
Permittee Contact: Dawn Reeves Telephone No.: 704/951-2171
ORC Name: none required
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Surface Irrigation X Recycle
Other
Inspection Summary: (additional comments may be included on attached pages)
The recycle system appears to be operating properly. Recordkeeping is in order.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Hydro Tech II
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 9/13/06

Permit #W00010197 Page 2
Type
Activated Sludge Spray, low rate
Activated Sludge Spray, high rate
Activated Sludge Drip, low rate
Lagoon Spray, low rate
Reuse (Golf Courses)
_X_ Recycle /Reuse
Single Family Spray, low rate
Single Family Drip
Infiltration System
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
List any action items necessary for each unit.
Comments:
Settling Lagoon
(check any/all that apply)
NE Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N_ Vegetation (is there excessive vegetation on the lagoon bank
_NA _Liner (if visible, is it intact)
_NA Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
_NA _Staff gauge ( clearly marked)
_N Evidence of overflow (vegetation discolored or laying down/broken)
—N—Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
_N_ Floating mats (sludge, plants, inorganics)
—N—Excessive solids buildup (from bottom)
NA Aerators/mixers operational (if present)
NE Effluent structure (free of obstructions, easily accessible)
Comments: Lagoon has been checked for solids buildup. Accumulation was found
to be minimal.

rl
I
Spray Irrigation
Permit #WQ 000
Alum Floc Basin
Page 3
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N_ Vegetation (is there excessive vegetation on the lagoon bank
—NA _Liner (if visible, is it intact)
NA Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
—NA _Staff gauge ( clearly marked)
N Evidence of overflow (vegetation discolored or laying down/broken)
N Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
_N_ Floating mats (sludge, plants, inorganics)
—N—Excessive solids buildup (from bottom)
NA Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Comments: Basin has been checked for solids buildup. Accumulation.was found to be
minimal.
Filters
Y sand filter backwash
Recordkeeping
Y Is permit available upon request?
Y Are flow rates less than permitted flow?
NA Are monitoring reports present: NDMR _ NDAR
Y Are operational logs present? _ Complete?
NA Are lab sheets available for review?
NA Do lab sheets support data represented on NDMR or NDAR?
NA Are all samples analyzed for the required parameters?
_N_ Are there any 2L GW quality violations?
NA Are annual soil reports available?
NA Did the last report indicate a need for lime? Was it applied?
NE Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Y = Yes NA= Not Applicable
N= No NE= Not Examined

May 18, 2004
DIVISION OF WATER QUALITY
Mooresville Regional Office
MEMORANDUM
TO: Tom Cadwallader
THROUGH: Andrew Pitner gV ,1 ` xv
FROM: Peggy Finley 01�—dd�—o
RE: American & Efird, Mt. Holly
Gaston County
WQ0010197 GW04045
Settling Lagoon for Alum Floc Basin
The site visit revealed that the settling pond is well maintained with freeboard
greater than two feet. The 14 feet deep pond was evaluated recently to determine
whether any accumulating sludge should be removed. This was found to not be
necessary.
This office recommends renewal of the permit with no additional groundwater
conditions. Should you have any questions, please contact Peggy Finley.