NC0077623_Regional Office Physical File Scan Up To 1/4/2021

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FACILITY
D
COUNTY A.. CLASS
MAILING ADDRESS
RESPONSIBLE FACILITY OPERATOR
OFFICIAL
Cam) �� �, � REPRESENTATIVE
.
TELEPHONE NO.
WHERE LOCATED
CERT. NUMBER
CLASS
NPDES PERMIT NUMBER NC J OTHER PERMIT NO.
STATE FEDERAL DATE ISSUED
DATE ISSUED
EXPIRATION DATE
STREAM: NAME
CLASS
7Q10
SUB -BASIN

.'rofile
r:
Site Contact:
Kevin S. Misenheimer
OSC
r misenheimer.kevin(aD-epa.gov
www.epaosc.org/oldfort
On 24 March 2004, North Carolina DENR requested assistance at the Old _Fort Industrial Complex
(formerly Old, Fort Finishing) facility in Old Fort, McDowell County, North Carolina (NRC#716874). NC
DENR reported a discharge of NO. 6 oil.into the storm drains and ditches at the facility, which leads to tI
Catawba' River. Initial NC DENR reports indicated that 1,000 gallons of oil had been discharged.
For additional information, visit the Pollution Report (POLREPs) section.,
Images Documents Contacts Links
None for this site. None for this site. None for this site.
List AIL.:
I sites I rp ofile l bulletins I images I documents I POLREPs I contacts I links I
http°//www.epaosc.org/site_profile.asp?site id=778
3/31/2004

Page 1 of 3
United States Environmental Protection Agency
Region 4
POLLUTION REPORT
Date: Wednesday, March 31, 2004
From: Kevin S. Misenheimer, OSC
Subject: Final POLREP
Old Fort Industrial Complex Oil Spill
One Water Street, Old Fort, NC
POLREP No.:
1 Site #:
778
Reporting Period:
D.O. #:
Start Date:
3/24/2004 Response Authority:
OPA
Mob Date:
3/24/2004 Response Type:
Emergency
Completion Date:
NPL Status:
Non NPL
CERCLIS ID #:
Incident Category:
Removal Action
RCRIS ID #:
Contract #
Federal Project #
Reimbursable Account #
Site Description
On 24 March 2004, North Carolina DENR requested assistance at the Old Fort Industrial Complex
(formerly Old Fort Finishing) facility in Old Fort, McDowell County, North Carolina
(NRC#716874). NC DENR reported a discharge of NO. 6 oil into the storm drains and ditches at
the facility, which leads to the Catawba River. Initial NCDENR reports indicated that 1,000
gallons of oil had .been discharged.
Current Activities
OSC Misenheimer was dispatched to the incident scene at 1030 hours on 24 March 2004. OSC
Misenheimer arrived at the scene at approximately 1430 hours. Upon arrival OSC Misenheimer
met with NC DENR representatives and local emergency management staff to ascertain the
circumstances surrounding the discharge of oil. It was determined that the discharge of oil was the
result of a previous incident involving a ruptured valve on an above ground storage (AST) tank on
the facility, which was discovered by local officials in September 2003. The OSC then met with
the suspected responsible party (RP), Mr. Sam Simchon, who owns the industrial
complex. According to the RP, a contractor on site using heavy equipment damaged the valve on
an AST containing an unspecified amount of # 6 oil. The oil was subsequently released from the
tank and flowed into the on site storm water management system, an extensive network of under
ground piping, junction boxes and multiple discharge points. The exact time frame in which this
event occurred was not clearly determined, however, local officials investigated the discharge of
oil in September 2003.
The OSC conducted a site reconnaissance and found that oil had been discharged from the storm
water outfall, into a ditch leading to the Catawba River. From the storm water discharge point, the
ditch entered a 30 inch culvert under Interstate 40 and continued on the other side of the highway
for several hundred feet until its confluence with the Catawba River. The OSC discovered oil in
the drainage ditch and observed evidence (oiled vegetation on river banks) that oil had been
discharged to the river. In addition, the OSC discovered that oil had discharged from another
storm water outfall on the site. This location is where an effort was made by the RP to recover oil
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Page 2 of 3
during the initial spill in September 2003. An earthen, lined containment pit had been constructed
to contain oil flowing from the storm water outfall while allowing water to flow out through pipes
during rainfall events. At the time of the site reconnaissance, it was estimated that the pit
contained several thousand gallons of # 6 oil.
2. Removal Activities To Date
On 24 March 2004, the Responsible Party mobilized Garco, Inc. to the site to begin oil
containment and recovery operations. The OSC met with Garco, Inc. and the RP to discuss a plan
to address the oil discharged and to identify additional sources of oil within the storm water
management system. Garco, Inc. pumped approximately 2,600 gallons of oil from two of the
storm water junction boxes near the ditch leading off site. In addition, crews worked on the south
side of I-40, to remove pockets of oil and oiled vegetation.
On 25 March 2004, Garco, Inc. continued clean up activities. The recovered oil was off loaded
into the onsite containment pit. However, after several thousand gallons of oil was placed in the
pit, oil began to discharge from the outlet pipe. The OSC informed the RP that the containment pit
was not acceptable to hold the recovered oil. The RP then mobilized a frac tank to the site to hold
the recovered oil. Oil recovery efforts continued at the culvert underneath I-40. While flushing
with water on the north side of the culvert, a vacuum truck was used to recover oil from the south
side of the culvert. Approximately 800 gallons of oil was recovered from the culvert. The RP, Mr.
Simchon was not on site orr 25 March 2004.
On 26 March 2004, Garco, Inc. continued to remove oil from the culvert underneath I-
40. Approximately 200 gallons of oil was recovered. Crews continued to clean the drainage ditch
near the Catawba River and began placing straw in the ditch to absorb residual product. Several
underflow dams were constructed on both the north and south side of I-40 to catch any oil released
during subsequent rain fall events. The OSC met with NCDENR, and Garco, Inc. to outline
subsequent actions that would be taken to mitigate the future release of oil over the next few
months. NCDENR agreed to provide oversight of future RP activities. The RP, Mr. Sam
Simchon, was not on site on 26 March 2004, however the OSC spoke to Mr. Simchon several
times to discuss expectations of the ongoing cleanup. OSC Misenheimer demobilized at 1200
hours.
Planned Removal Actions
RP will continue response effort as outlined in the Administrative Order. NCDENR will provide
oversight. Activities include maintenance of boom and sorbent pads in areas where oil may
continue to be released. Also, oil will be contained in underflow dams and removed. Further"
investigation of the storm water system will be carried out to identify other sources of discharge of
oil. The RP will also remove oil and contaminated soil from the pit on site. This material will be
disposed of off site.
Key Issues
A Clean Water Act 311(c) Administrative Order, was issued to Mr. Simchon. The Order outlined
additional activities required to mitigate the continued threat of discharge of oil into the Catawba
River.
Estimated Costs *
Total To
Budgeted Date Remaining % Remaining
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Page 3 of 3
Costs
(Intramural Costs
USEPA - Direct (Region, HQ) $0.0011 $1,000.00 ($1,000.00)11 0.00%
Total Site Costs 11 $0.0011 $1,000.0011 ($1,000.00)11 0.00%1
* The above accounting of expenditures is an estimate based on figures known to the OSC at the
time this report was written. The OSC does not necessarily receive specific figures on final
payments made to any contractor(s). Other financial data which the OSC must rely upon may not
be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an
exact monetary figure which the government may include in any claim for, cost recovery.
www.gpaose.org/oldfort
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age Read
Page 1 of 2
Folders » Inbox » [Fwd: FINAL POLREP- Old Fort Industrial Complex Oil Spill (NO FPN
NUMBER)]
Reply Rep1yAJ.l Forward Edit Print View View°Headers Save
From: Larry Frost <[e-mail]> « Add to Address Book » « Block sender
To: JANET CANTWELL <JANET. CANTWELL@ncmail. net>
Cc:
Subject: [Fwd: FINAL POLREP- Old Fort Industrial Complex Oil Spill (NO FPN NUMBER)]
Sent: Wed, 31 Mar 2004 15:50:09 -0500
FYI
-------- Original Message --------
Subject: FINAL POLREP- Old Fort Industrial Complex Oil Spill (NO FPN
NUMBER)
Date: Wed, 31.'Mar 2004 10:32:29 -0500
From: [e-mail]
To: [e-mail], [e-mail],
[e-mail],[e-mail], [e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail], [e-mail],
steve.lew`is@ncmail. net,ja mes. bateson@ ncma i I. net,
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],DHigman@bal Iston.uscg.mi1,
[e-mail],[e-mail],
[e-mail],[e-mail],
Starr. [e-mail],[e-mail],
Key. [e-mail],[e-mail],[e-mail],
[e-mail],[e-mail],
Taylor. [e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail]1,
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],
[e-mail],[e-mail],.
[e-mail],[e-mail]
CC: [e-mail], LARRY. FROST@ N CMAIL. NET,
CANTW ELLJAN ET@ NCMAIL. NET
----- Forwarded by Bob Bittinger/R4/USEPA/US on 03/31/2004 10:26 AM
Kevin
Misenheimer/R4/US To: Bob
Bittinger/R4/USEPA/US@EPA, Kevin
EPA/US@EPA
M isen heimer/R4/US EPA/US@ EPA
cc:
03/31/2004 09:28 Subject: POLREP #1 Old
Fort Industrial Complex Oil Spill -
https:Hcros.ncmail.net/maiUMessageRead?sid=DC34DB 8D93 C56E82F30BEDOC454B71... 3/31/2004

sage Read
Page 2 of 2
AM Final
POLREP
Attached is a Pollution Report (POLREP) regarding:
USEPA Region 4
Old Fort Industrial Complex Oil Spill
One Water Street,, Old Fort NC,
To view this POLREP, please open the attachment.
Lotus Notes Users, please Launch the attachment.
For additional information regarding this site,
please visit the website by clicking on this link:
http: //www.epaosc.org/oldfort
(See attached file: oldfort_polrep_l.htm)
oldfort polrep i.htm (13.2 KB)
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ition Report Profile
Page 1 of 2
Old Fort Industrial Complex Oil Spill
Old Fort, NC - EPA Region IV
POLREP #1 - Final POLREP
All POLREPs for this site
On -Scene Coordinator - Kevin S. Misenheimer
Emergency - Removal Action
Start Date: 3/24/2004
3/31 /2
Report Number 1
Site Description
On 24 March 2004, North Carolina DENR requested assistance
Old Fort Industrial Complex (formerly Old Fort Finishing) facility it
Fort, McDowell County, North Carolina (NRC#716874). NC DEN
reported a discharge of NO. 6 oil into the storm drains and ditche
the facility, which leads to the Catawba River. Initial NCDENR re
indicated that 1,000 gallons of oil had been discharged.
��n Current Activities
EN
OSC Misenheimer was dispatched to the incident scene at 1030
E -— on 24 March 2004. OSC Misenheimer arrived at the scene at
approximately 1430 hours. Upon arrival OSC Misenheimer met with NC DENR representatives and locc,
emergency management staff to ascertain the circumstances surrounding the discharge of oil. It was
determined that the discharge of oil was the result of a previous incident involving a ruptured valve on at
above ground storage (AST) tank on the facility, which was discovered by local officials in September
2003. The OSC then met with the suspected responsible party (RP), Mr. Sam Simchon, who owns the
industrial complex. According to the RP, a contractor on site using heavy equipment damaged the valve
an AST containing an unspecified amount of # 6 oil. The oil was subsequently released from the tank at
flowed into the on site storm water management system, an extensive network of under ground piping,
junction boxes and multiple discharge points. The exact time frame in which this event occurred was no
clearly determined, however, local officials investigated the discharge of oil in September 2003.
The OSC conducted a site reconnaissance and found that oil had been discharged from the storm wa
outfall, into a ditch leading to the Catawba River. From the storm water discharge point, the ditch entere
30 inch culvert under Interstate 40 and continued on the other side of the highway for several hundred fE
until its confluence with the Catawba River. The OSC discovered oil in the drainage ditch and observed
evidence (oiled vegetation on river banks) that oil had been discharged to the river. In addition, the OSC
discovered that oil had discharged from another storm water outfall on the site. This location is where at
effort was made by the RP to recover oil during the initial spill in September 2003. An earthen, lined
containment pit had been constructed to contain oil flowing from the storm water outfall while allowing w;
to flow out through pipes during rainfall events. At the time of the site reconnaissance, it was estimated
the pit contained several thousand gallons of # 6 oil.
2. Removal Activities To Date
On 24 March 2004, the Responsible Party mobilized Garco, Inc. to the site to begin oil containment at
recovery operations. The OSC met with Garco, Inc. and the RP to discuss a plan to address the oil
discharged and to identify additional sources of oil within the storm water management system. Garco,
pumped approximately 2,600 gallons of oil from two of the storm water junction boxes near the ditch lea(
off site. In addition, crews worked on the south side of 1-40, to remove pockets of oil and oiled vegetatio
On 25 March 2004, Garco, Inc. continued clean up activities. The recovered oil was off loaded into th
onsite containment pit. However, after several thousand gallons of oil was placed in the pit, oil began to
discharge from the outlet pipe. The OSC informed the RP that the containment pit was not acceptable b
the recovered oil. The RP then mobilized a frac tank to the site to hold the recovered oil. Oil recovery e
http://www.epaosc.org/polrep_profile.asp?site_id=778&counter=1105 3/31/2004

ation Report Profile
Page 2 of 2
continued at the culvert underneath 1-40. While flushing with water on the north side of the culvert, a
vacuum truck was used to recover oil from the south side of the culvert. Approximately 800 gallons of of
was recovered from the culvert. The RP, Mr. Simchon was not on site on 25 March 2004.
On 26 March 2004, Garco, Inc. continued to remove oil from the culvert underneath 1-40. Approximat
200 gallons of oil was recovered. Crews continued to clean the drainage ditch near the Catawba River
began placing straw in the ditch to absorb residual product. Several underflow dams were constructed c
both the north and south side of 1-40 to catch any oil released during subsequent rain fall events. The O
met with NCDENR, and Garco, Inc. to outline subsequent actions that would be taken to mitigate the futi
release of oil over the next few months. NCDENR agreed to provide oversight of future RP activities. TI
RP, Mr. Sam Simchon, was not on site on 26 March 2004, however the OSC spoke to Mr. Simchon sev(
times to discuss expectations of the ongoing cleanup. OSC Misenheimer demobilized at 1200 hours.
Planned Removal Actions
RP will continue response effort as outlined in the Administrative Order. NCDENR will provide
oversight. Activities include maintenance of boom and sorbent pads in areas where oil may continue to
released. Also, oil will be contained in underflow dams and removed. Further investigation of the storm
water system will .be carried out to identify other sources of discharge of oil. The RP will also remove oil
contaminated soil from the pit on site. This material will be disposed of off site.
Key Issues -
A Clean Water Act 311(c) Administrative Order, was issued to Mr. Simchon. The Order outlined additior
activities required to mitigate the continued threat of discharge of oil into the Catawba River.
All POLREPs for this site
I sites I rp ofile I bulletins I images I documents I POLREPs I contacts I links I
http://www.epaosc.org/polrep_profile.asp?site_id=778&counter=1105 3/31/2004

:nt in McDowell County (OLD FORT) on 03/24/2004 09:58:23 AM Page 1 of 3
Taken by: J McCauley
JDate Reported: 03124/200
ITime Reported: 09:50 AM
Date Occurred: 03/24/2004 IlTime Occurred: 09:25 AM
Reported by: Larry Frost
Agency: DENR - Asheville Office Phone: [phone]
County: McDowell
City: OLD FORT IiEM Area: W 14
Weather Event: rHazMat
Mat Event: Diesel Fuel
Wx Event Name: Class: Petroleum
Mat Mode: Fixed Facility
FNF Event:
Non-FNF Event:
SAR Event:
FNF Type:
FNF Class:
Fire Event: Com
OTHER EVENT:
Event Description: Caller reported a fuel spill (#6 fuel oil) of appox 1000 gallons, majority of product entered the
Catawba River. Local Fire Dept is on scene trying to contain spill.
NATIONAL RESPONSE CENTER - FLASH FAX
***GOVERNMENT USE ONLY***GOVERNMENT USE ONLY***
DO NOT RELEASE this information to the public without
permission from the NATIONAL RESPONSE CENTER 1-800-424-8802
Incident Report # 716874
INCIDENT DESCRIPTION
*Report taken by: MST2 RATHBUN at 09:48 on 24-MAR-04
Incident Type: FIXED
Incident Cause: UNKNOWN
Affected Area: CATAWBA RIVER
The incident was discovered on 23-MAR-04 at 16:00 local time.
Affected Medium: WATER CATAWBA RIVER
REPORTING PARTY
Name: LARRY FROST
Organization: NC DIVISION OF WATER QUALITY
Address: 59 WOODSIN PLACE
ASHVILLE, NC 28801
PRIMARY Phone: [phone] PRIMARY Phone: [phone]
Type of Organization: LOCAL GOVERNMENT
SUSPECTED RESPONSIBLE PARTY
Name: SAM FIMCHON
Organization: OWNERS OF OLD FORD FINISHING
GREENWOOD, SC
PRIMARY Phone: [phone]
Type of Organization: UNKNOWN
INCIDENT LOCATION
County: MCDOWELL
hitp:11149.168.212. i7Biv1 live/EivlReport.NSFfb66533d12a86c40b852566e1007f741 d/eb9... 3/25/2004

-nt in McDowell County (OLD FORT) on 03/24/2004 09:58:23 AM Page 2 of 3 -
State: NC
INTERSTATE 40 TO OLD FORD EXIT
RELEASED MATERIAL(S)
CHRIS Code: OSX Official Material Name: OIL, FUEL: NO. 6
Also Known As:
Qty Released: 1000 GALLON(S) Qty in Water: 0 UNKNOWN AMOUNT
DESCRIPTION OF INCIDENT
#6 FUEL OIL IS IN STORM DRAINS AND HAS ENTERED THE CATAWBA RIVER.
ALL.OF THE STORM DRAINS LEAD FROM OLD FORD FINISHING.
INCIDENT DETAILS
Building ID:
Type of Fixed Object: WAREHOUSE
Power Generating Facility: UNKNOWN
Generating Capacity:
Type of Fuel:
NPDES:
NPDES Compliance: UNKNOWN
---WATER INFORMATION ---
Body of Water: CATAWBA RIVER
Tributary of:
Nearest River Mile Marker:
Water Supply Contaminated: NO
DAMAGES
Fire Involved: NO Fire Extinguished: UNKNOWN
INJURIES: Hospitalized: Empl/Crew: Passenger:
FATALITIES: Empl/Crew: Passenger: Occupant:
EVACUATIONS: Who Evacuated: Radius/Area:
Damages:
Hours Direction of
Closure Type Description of Closure Closed Closure
Air: N
Road: N Major N
Artery:
Waterway: N
Track: N
Media Interest: NONE Community Impact due to Material: NO
REMEDIAL ACTIONS
OWNER CONTACTED
Release Secured: UNKNOWN
Release Rate:
Estimated Release Duration:
WEATHER
Weather: OVERCAST, 350F
ADDITIONAL AGENCIES NOTIFIED
Federal:
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nt in McDowell County (OLD FORT) on 03/24/2004 09:58:23 AM Page 3 of 3
State/Local:
State/Local On Scene: EMS, FIRE DEPT
State Agency Number:
NOTIFICATIONS BY NRC
ATSDR NC
24-MAR-04 10:04 (919)7153591
EPA.OERR
(703)9675012
U.S. EPA IV
(404)6504955
FEDERAL EMERGENCY MANAGEMENT AGENC
(800)6347084
GULF STRIKE TEAM
(251)4416601
NC DEPT OF EMERGENCY MGMT
24-MAR-04 10:04 (800)8580368
NOAA 1ST CLASS BB RPTS FOR NC
24-MAR-04 10:04 (206)5266344
STATE OF NORTH CAROLINA DENR
24-MAR-04 10:04 (919)7335083
MSO WILMINGTON
(910)7722200
ADDITIONAL INFORMATION
*** END INCIDENT REPORT 716874 ***
Deaths: Injuries: Eva I Radius:
Responsible Party: RP Phone:
Point Of Contact: I POC Phone:
Event Location: Old Fort Finishing Plant
Latitude (decimal degrees ) (NC inland range is 33.840 - 36.588 degrees. Values outside these parameters may
be used.)
Longitude (decimal degrees) (NC inland range is 75.460 - 84.322 degrees. Values outside these parameters
may be used.)
USFS Block-Sauare-Point Svstem: Block= Square= Point=
IIRRT Request: No IIRRT Mission No.: IIRRT Team Number: II
LEMC: Y SO: PD: LFD: Y CHealth: Sewer: PWRK:
Other Local Agencies:
SHP/SWP: IjEnv. Mgt: Water: Y DRP: CAP: DOT: DMV:
Other State or Federal Agencies:
Notes: 0950 A/C paged
1004 Jimmie Ramsey notified
1006 A/C notified
EM.Hours:
SAR Hours:
Call #:
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UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY
REGION 4
ADMINISTRATIVE ORDER
IN THE MATTER OF Old Fort Industrial -Park Oil Spill
Docket CWA(311c)- j 1 - 2. o c `i - 5000
Proceedings under Section 31-1 (c) of the Clean Water Act (CWA), 33 U.S.C. § 1321-(c), as
amended by the Oil Pollution Act of 1990 (OPA), 33 U.S.C. § 2701 et seq.
I. DEFINITIONS
"Oil" means oil of any kind or in any form, including, but not limited to, petroleum, fuel oil,
sludge, oil refuse, and oil ,mixed with wastes otherthan dredged spoil (Section 311(a)(1) of the CWA,
33U.S.C. §1321(a)(1)).
"Navigable water of the United States" mean's the waters of the United States, including the
territorial seas (Section 502(7) of the CWA, 33 U.S.C. § 1362(7)).
"Facility" means any facility of any kind located in, on, or under, any of the navigable waters of
the United States other than submerged land (Section 311(a)(10) of the CWA, 33U.S.C.§1321(a)(10)).
".Discharge" means.any spilling, leaking, pumping, pouring, emitting, emptying or dumping, but
excludes (A) discharges in compliance with a permit under section 402 of CWA, (B)discharges resulting
from circumstances identified and reviewed and made a part of the public record with respect to a permit
issued or modified under section 40.2 of CWA, and subject to a condition in such permit, and (C)
continuous or anticipated intermittent discharges from a point source, identified in a permit or permit
application under section 402 of CWA which are caused'by events occurring within the scope of relevant
operating or treatment systems (Section 311(a)(2) of the CWA, 33 U.,S.C. § 1321(a)(2)).
"Cofferdam" means the open oil storage pit constructed by Respondent to contain oil discharging
from the storm water system of the Old Fort Industrial Complex:
"NCDENR' means the North Carolina Department of Environment and -Natural Resources,
Division of Water Quality, Asheville Regional Office.
II. FINDINGS OF FACT AND VIOLATIONS ,-
A. This,Order is being issued under §311(c) of the Clean Water Act, 33 U.S.C. § 1321 for a
discharge.or a substantial threat of discharge of oil into waters of the United States.
B. On or about 24 March 2004, a discharge or.a substantial threat of a discharge of an unknown
amount (but at least 3;000 gallons) of oil reached or may reach the Catawba River,, which is' a
navigable water of the United States, This discharge or substantial threat of a discharge from the
Old Fort Industrial. Complex, One Water Street, Old Fort, McDowell County, North Carolina
constitutes a substantial threat to ,the public health or welfare.
i C. Respondent Sam Simchon is the, owner of the facility.

be maintained for a period of six months from the date of issuance of this Order.
Documentation of these inspections should be available upon request.
3. Removal of any oil that is discovered during the routine inspection of the storm water
collection system and discharge systerri.
D. REPORTING REQUIREMENTS
Respondent, shall prepare and submit the following reports:
L ' A letter report which summarizes actions taken and provides documentation that the oil and
contaminated soil has' been removed from the site shall be submitted upon completion of the
tasks outlined in Section B. of this Order.
2. A letter work plan as required in. Section C. of this Order- shall be submitted.
3. Progress reports outlining actions taken to address tasks listed in Section C: of this Order
shall be submitted monthly for a period of 'six months. These shall be submitted upon
approval of the letter work plan by NCpENR. Verbal progress reports, made by -telephone,
may be adequate, if approved in advance by'NCDENR.
All,repoiting should be addressed to:
Ms. Janet Cantwell
Division of Water Quality
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
E. OTHER REQUIREMENTS
NONE
IV. RESERVATION OF RIGHTS AND PENALTIES
A. This Order does not preclude EPA from taking -'any actions'authorized by CWA, the National
Contingency Plan, or any other law. EPA reserves the right to,direct all activities and. to .
comment on and direct changes to deliverables; off -'site shipping and:disposal, and all other
matters.
B. Respondent shall notify EPA of any response 'actions it takes as to this discharge that are in
addition to those described in this Order.
C. Violation of any term of this ORDER may subject Respondents to an administrative civil
penalty of up to $27,506 per day of violation or an amount up to three times the costs

III. WORK TO BE PERFORMED
A: RESPONDENT IS HEREBY ORDERED to complete the'tasks.described below within the
dates specified and in accordance with the National Contingency Plan, 40 CFR Part 300, and any
appropriate area contingency plan, and any applicable §3110) facility response plan.
B. IMMEDIATE STABILIZATION AND MITIGATION ACTIONS
1. Remove oil and oily debris and vegetation from the ditch leading to the Catawba River,
including removal of signif cant oil.which has contaminated the storm water culvert
underneath Interstate 40.
2. Flush the sub -surface storm water system on the site to remove oil. Contain flushed
water and oil and remove the oil from the containment area.
3. Upon'completion of all flushing and oil collection efforts, provide for periodic inspection
of storm sewer outfalls and effluent points to monitor for further discharge of oil into the
onsite'ditches and the Catawba river. Place boom and sorbent materials as needed to
mitigate further discharges which may occur over time due to rainfall events.
4. Within seven (7) days of the issuance of this Order, Respondent shall.remove all oil'
contained in the cofferdam and transfer the material to'a secure container (i.e. frac tank,
tanker truck, etc.). Within thirty- (30) days of the issuance of this Order, Respondent shall
dispose of the collected oil at an appropriate oil recycling,or disposal facility.
5: Within forty five (45) days of the issuance of this: Order, Respondent. shall "remove all soil
from the cofferdam, which is saturated with oil and which may represent -a continuing
threat of discharge of oil into the navigable waters of the U.S. This soil should be
disposed of at an appropriate off site facility:
C. REMOVAL ACTION
Within thirty (30) days from. the date this Order is signed by EPA, -'Respondent shall
develop and submit to the North Carolina Department of Environment and Natural Resources,
Division of Water Quality, Asheville Regional Office (NCDENR) for approval, a Letter Work
Plan and schedule for completing the tasks described below. Respondent shall begin work .
within fifteen (15') days, of NCDENR approval. of the Letter Work Plan. The Work Plan shall
include the following tasks:
1. Identification and mapping of the on site storm water collection and discharge system
which may contain residual oil from the historical spill. This plan should include an
investigation-of'stormwater piping and collection structures underneath the buildings on
site. .
2.' "Regular inspection of the storm water collection and discharge system to ensure that no
oifilischarges are occurring. This includes inspection.of all sumps, pits, and'manholes
to ensure that oil is not collecting in these structures. Inspections should be done twice
a month and after any rainfall of greater than 0.5 inches. The inspection schedule shall

incurred by the Oil Spill Liability Trust Fund as a result of such failure. (Section 311(b)(7)(B)
of the Clean Water Act, 33 U.S.C. § 1321(b)(7)(B) as amended by the Oil Pollution Act of
1990,33 U.S.C. §§ 2701 et
V. EFFECTIVE DATE
The effective date of this ORDER shall be the date of the receipt of this Order by the
Respondents.
IF", � - �dA
Kevin isenheimer
On -Scene Coordinator
Received by
Representing Respondent
cc: Janet Cantwell, NCDENR
Larry Frost, NCDENR
25 •MAP-cil zoO`/
Date
Date

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ADMINISTRATIVE ORDER
IN THE MATTER OF Old Fort Industrial Park Oil Spill
Docket CWA(311 & [ 1 - 2 o O `i — So O O
Proceedings under Section 311 (c) of the Clean Water Act (CWA), 33 U.S.C. § 1321 (c), as
amended by the Oil Pollution Act of 1990 (OPA), 33 U.S.C. § 2701 et seq.
I. DEFINITIONS
"Oil" means oil of any kind or in any form, including, but not limited to, petroleum, fuel oil,
sludge, oil refuse, and oil mixed with wastes other than dredged spoil (Section 311(a)(1) of the. CWA,
33U.S.C. §1321(a)(1)).
"Navigable water of the United States" means the waters of the United States, including the
territorial seas (Section 502(7) of the CWA, 33 U.S.C. § 1362(7)).
"Facility" means any facility of any kind located in, on, or under, any of the navigable waters of
the United States other than submerged land (Section 311(a)(10) of the CWA, 33U.S.C.§1321(a)(10)).
"Discharge" means any spilling, leaking, pumping, pouring, emitting, emptying or dumping, but
excludes (A) discharges in compliance with a permit under section 402 of CWA, (B)discharges resulting
from circumstances identified and reviewed and made a part of the public record with respect to a permit
issued or modified under section 402 of CWA, and subject to a condition in such permit, and (C)
continuous or anticipated intermittent discharges from a point source, identified in a permit or permit
application under section 402 of CWA which are caused by events occurring within the scope of relevant
operating or treatment systems (Section 31 l(a)(2) of the CWA, 33 U.S.C. § 1321(a)(2)).
"Cofferdam" means the open oil storage pit constructed by Respondent to contain oil discharging
from the storm water system of the Old Fort Industrial Complex.
"NCDENR' means the North Carolina Department of Environment and Natural Resources,
Division of Water Quality, Asheville Regional Office.
II. FINDINGS OF FACT AND VIOLATIONS
A. This Order is being issued under §31 l (c) of the Clean Water Act, 33 U.S.C. § 1321 for a
discharge or a substantial threat of discharge of oil into waters of the United States.
B. On or about 24 March 2004, a discharge or a substantial threat of a discharge of an unknown
amount (but at least 3,000 gallons) of oil reached or may reach the Catawba River, which is a
navigable water of the United States. This discharge or substantial threat of a discharge from the
Old Fort Industrial Complex, One Water Street, Old Fort, McDowell County, North Carolina
constitutes a substantial threat to the public health or welfare.
C. Respondent Sam Simchon is the owner of the facility.

be maintained for a period of six months from the date of issuance of this Order.
Documentation of these inspections should be available upon request.
3. Removal of any oil that is discovered during the routine inspection of the storm water
collection system and discharge system.
D. REPORTING REQUIREMENTS
Respondent shall prepare and submit the following reports:
1. A letter report which summarizes actions taken and provides documentation that the oil and
contaminated soil has been removed from the site shall be submitted upon completion of the
tasks outlined in Section B. of this Order.
2. A letter work plan as required in Section C. of this Order shall be submitted.
3. Progress reports outlining actions taken to address tasks listed in Section C. of this Order
shall be submitted monthly for a period of six months. These shall be submitted upon
approval of the letter work plan by NCDENR. Verbal progress reports, made by telephone,
may be adequate, if approved in advance by NCDENR.
All reporting should be addressed to:
Ms. Janet Cantwell
Division of Water Quality
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
59 Woodfm Place
Asheville, NC 28801
E. OTHER REQUIREMENTS
NONE
IV. RESERVATION OF RIGHTS AND PENALTIES
A. This Order does not preclude EPA from taking any actions authorized by CWA, the National
Contingency Plan, or any other law. EPA reserves the right to direct all activities and to
comment on and direct changes to deliverables, off -site shipping and disposal, and all other
matters.
B. Respondent shall notify EPA of any response actions it takes as to this discharge that are in
addition to those described in this Order.
C. Violation of any term of this ORDER may subject Respondents to an administrative civil
penalty of up to $27,500 per day of violation or an amount up to three times the costs

III. WORK TO BE PERFORMED
A. RESPONDENT IS HEREBY ORDERED to complete the tasks described below within the
dates specified and in accordance with the National Contingency Plan, 40 CFR Part 300, and any
appropriate area contingency plan, and any applicable §3110) facility response plan.
B. IMMEDIATE STABILIZATION AND MITIGATION ACTIONS
1. Remove oil and oily debris and vegetation from the ditch leading to the Catawba River,
including removal of significant oil which has contaminated the storm water culvert
underneath Interstate 40.
2. Flush the sub -surface storm water system on the site to remove oil. Contain flushed
water and oil and remove the oil from the containment area.
3. Upon completion of all flushing and oil collection efforts, provide for periodic inspection
of storm sewer outfalls and effluent points to monitor for further discharge of oil into the
onsite ditches and the Catawba river. Place boom and sorbent materials as needed to
mitigate further discharges which may occur over time due to rainfall events.
4. Within seven (7) days of the issuance of this Order, Respondent shall remove all oil
contained in the cofferdam and transfer the material to a secure container (i.e. frac tank,
tanker truck, etc.). Within thirty (30) days of the issuance of this Order, Respondent shall
dispose of the collected oil at an appropriate oil recycling or disposal facility.
5. Within forty five (45) days of the issuance of this Order, Respondent shall remove all soil
from the cofferdam, which is saturated with oil and which may represent a continuing
threat of discharge of oil into the navigable waters of the U.S. This soil should be
disposed of at an appropriate off site facility.
C. REMOVAL ACTION
Within thirty (30) days from the date this Order is signed by EPA, Respondent shall
develop and submit to the North Carolina Department of Environment and Natural Resources,
Division of Water Quality, Asheville Regional Office (NCDENR) for approval, -a Letter Work
Plan and schedule for completing the tasks described below. Respondent shall begin work
within fifteen (15) days of NCDENR approval of the Letter Work Plan. The Work Plan shall
include the following tasks:
1. Identification and mapping of the on site storm water collection and discharge system
which may contain residual -oil from the historical spill. This plan should include an
investigation of stormwater piping and collection structures underneath the buildings on
site.
2. Regular inspection of the storm water collection and discharge system to ensure that no
oil discharges are occurring. This includes inspection of all sumps, pits, and manholes
to ensure that oil is not collecting in these structures. Inspections should be done twice
a month and after any rainfall of greater than 0.5 inches. The inspection schedule shall

incurred by the Oil Spill Liability Trust Fund as a result of such failure. (Section 311(b)(7)(B)
of the Clean Water Act, 33 U.S.C. § 1321(b)(7)(B) as amended by the Oil Pollution Act of
1990, 33 U.S.C. §§ 2701 et seq.)
V. EFFECTIVE DATE
The effective date of this ORDER shall be the date of the receipt of this Order by the
Respondents.
Kevin . isenheimer
On -Scene Coordinator
Received by
Representing Respondent
cc: Janet Cantwell, NCDENR
Larry Frost, NCDENR
25 MAP-C-11 2OOL-1
Date
Date

Incident in McDowell County (OLD FORT) on 03/24/2004 09:58:23 AM
Page 1 of 3
Taken by: J McCauley
JDate Reported: 03/24/2004 IlTime Reported: 09:50 AM
Date Occurred: 03/24/2004 JlTime
Occurred: 09:25 AM
Reported by: Larry Frost
Agency: DENR - Asheville Office
Phone: [phone]
County: McDowell
City: OLD FORT
EM Area: W 14
Weather Event: rHazMat
zMat Event: Diesel Fuel
Wx Event Name: Class: Petroleum
zMat Mode: Fixed Facility
FNF Event:
Non-FNF Event:
SAR Event:
FNF-Type:
FNF Class:
Fire Event:
OTHER EVENT:
aint:
Event Description: Caller reported a fuel spill (#6 fuel oil) of appox 1000 gallons, majority of product entered the
Catawba River. Local Fire Dept is on scene trying to contain spill.
NATIONAL RESPONSE CENTER - FLASH FAX
***GOVERNMENT USE ONLY***GOVERNMENT USE ONLY***
DO NOT RELEASE this information to the public without
permission from the NATIONAL RESPONSE CENTER 1-800-424-8802
Incident Report # 716874
INCIDENT DESCRIPTION
*Report taken by: MST2 RATHBUN at 09:48 on 24-MAR-04
Incident Type: FIXED
Incident Cause: UNKNOWN
Affected Area: CATAWBA RIVER
The incident was discovered on 23-MAR-04 at 16:00 local time.
Affected Medium: WATER CATAWBA RIVER
REPORTING PARTY
Name: LARRY FROST
Organization: NC DIVISION OF WATER QUALITY
Address: 59 WOODSIN PLACE
ASHVILLE, NC 28801
PRIMARY Phone: [phone] PRIMARY Phone: [phone]
Type of Organization: LOCAL GOVERNMENT
SUSPECTED RESPONSIBLE PARTY
Name: SAM FIMCHON
Organization: OWNERS OF OLD FORD FINISHING
GREENWOOD, SC
PRIMARY Phone: [phone]
Type of Organization: UNKNOWN
INCIDENT LOCATION
County: MCDOWELL
http://1149.1168 212.i7/'Oi\/'tiive/'Oiv!ReporrNSr/'n66533df2a86c40b852566e1007f741d/eb9... 3/25/2004

Incident in McDowell County (OLD FORT) on 03/24/2004 09:58:23 AM Page 2 of 3
State: NC
INTERSTATE 40 TO OLD FORD EXIT
RELEASED MATERIALS)
CHRIS Code: OSX Official Material Name: OIL, FUEL: NO. 6
Also Known As:
Qty Released: 1000 GALLON(S) Qty in Water: 0 UNKNOWN AMOUNT
DESCRIPTION OF INCIDENT
#6 FUEL OIL IS IN STORM DRAINS AND HAS ENTERED THE CATAWBA RIVER.
ALL OF THE STORM DRAINS LEAD FROM OLD FORD FINISHING.
INCIDENT DETAILS
Building ID:
Type of Fixed Object: WAREHOUSE
Power Generating Facility: UNKNOWN
Generating Capacity:
Type of Fuel:
NPDES:
NPDES Compliance: UNKNOWN
---WATER INFORMATION ---
Body of Water: CATAWBA RIVER
Tributary of:
Nearest River Mile Marker:
Water Supply Contaminated: NO
DAMAGES
Fire Involved: NO Fire Extinguished: UNKNOWN
INJURIES: Hospitalized: Empl/Crew: Passenger:
FATALITIES: Empl/Crew: Passenger: Occupant:
EVACUATIONS: Who Evacuated: Radius/Area:
Damages:
Hours Direction of
Closure Type Description of Closure Closed Closure
Air: N
Road: N Major N
Artery:
Waterway: N
Track: N
Media Interest: NONE Community Impact due to Material: NO
REMEDIAL ACTIONS
OWNER CONTACTED
Release Secured: UNKNOWN
Release Rate:
Estimated Release Duration:
WEATHER
Weather: OVERCAST, 350F
ADDITIONAL AGENCIES NOTIFIED
Federal:
http://l49.168.212.17/EM_live/EMReport.NSF/b66533df2a86c4Gb&52-566e l 007f741 d/eb9... 3/25/2004-

Incident in McDowell County (OLD FORT) on 03/24/2004 09:58:23 AM Page 3 of 3
State/Local:
State/Local On Scene: EMS, FIRE DEPT
State Agency Number:
NOTIFICATIONS BY NRC
ATSDR NC
24-MAR-04 10:04 (919)7153591
EPA OERR
(703)9675012
U.S. EPA IV
(404)6504955
FEDERAL EMERGENCY MANAGEMENT AGENC
(800)6347084
GULF STRIKE TEAM
(251)4416601
NC DEPT OF EMERGENCY MGMT
24-MAR-04 10:04 (800)8580368
NOAA 1ST CLASS BB RPTS FOR NC
24-MAR-04 10:04 (206)5266344
STATE OF NORTH CAROLINA DENR
24-MAR-04 10:04 (919)7335083
MSO WILMINGTON
(910)7722200
ADDITIONAL INFORMATION
*** END INCIDENT REPORT 716874 ***
Deaths: I Injuries: Evac:. IRadius:
Responsible Party: JFRP Phone:
Point Of Contact: POC Phone:
Event Location: Old Fort Finishing Plant
Latitude (decimal degrees ) (NC inland range is 33.840 - 36.588 degrees. Values outside these parameters may
be used.)
Longitude (decimal degrees) (NC inland range is 75.460 - 84.322 degrees. Values outside these parameters
may be used.)
USFS Block-Sauare-Point Svstem: Block= Sauare= Point=
IIRRT Request: No IIRRT Mission No.: IIRRT Team Number: II
LEMC: Y SO: PD: LFD: Y CHealth: Sewer: PWRK:
Other Local Agencies:
A/C: A SHP/SWP: jjEnv. Mgt: Water: Y DRP: CAP: DOT: DMV:
Other State or Federal Agencies:
Notes: 0950 A/C paged
1004 Jimmie Ramsey notified
1006 A/C notified
EM Hours:
SAR Hours:
Call #:
http://149.168.212.171EM livelEMReport.NSF/b66533df2a86c4Ob852566e1007f74ldleb9... 3/25/2004

Michael F. Easley
,r
North Carolina Department of Envir---'
/ .�j
GROUNDWATER SE
MAY 6, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED =A
7003 1680 0002 1293 6077
Ms. Renee' Simchon
225 Bypass 72 NW #C
Greenwood, SC 29649-1510
RE: Notice of Violation
15A NCAC 2L Classifications and Water Quality
Standards
Applicable to the Groundwater
Re: Old Fort Industrial Park, LLC
Site Priority Rank: currently unassigned
Incident No.: 86220
McDowell County, NC
Dear Ms. Simchon:
Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental
Management Commission of the Department of Environment and Natural Resources to protect
and preserve the water and air resources of the State. The Division of Water Quality (division)
has the delegated authority to enforce adopted pollution control rules. This letter is a standard
notification and is intended to advise you of the legal requirements under North Carolina law.
This notice documents a violation of the North Carolina groundwater standards as identified by
the presence of free product heating oil in proximity to the groundwaters of the State.
You are responsible for causing, contributing to or allowing the continuing violation of
the groundwater quality standards because you are the owner of Old Fort Industrial Park, LLC
and determined to be in control of the present heating oil contamination that has resulted in
discharges to waters of the State.
NCAC 2L .0106(b) states that any person conducting or controlling an activity which
results in the discharge of a waste, hazardous substance or oil to the groundwater, or in proximity
thereto, shall take immediate action to terminate and control the discharge, mitigate any hazards
resulting from exposure to the pollutants and notify the department of the discharge.
1nehCarolina ©�
atirra!!Y I R NR
Groundwater Section, 2090 U.S. Highway 70, Swannanoa, N.C. 28778 Telephone: [phone] Customer Service
Fax: [phone]

Old Fort Industrial Park, LLC
Page 2 of 2
April 21, 2004
15A NCAC 2L .0106(f) requires that abatement, containment or control of the
contaminants occur prior to or concurrent with assessment activities. You should begin
abatement, containment or control of the contaminants immediately. Also included is the
required removal, treatment or control of secondary pollution sources such as contaminated soil
that would be a potential continuing source of pollution.
To achieve compliance with the above -cited laws or rules, you are to. submit a report
describing the actions taken to correct the above -cited violations. Based upon a site visit
performed on March 31, 2004, abatement measures were observed to be inadequate in
addressing the discharging pollution. In addition, you are to contact this office and arrange
access to the monitoring wells located onsite for the purposes of sampling groundwater. The
Division may also collect soil samples from the property.
Please note that contaminated soil that is temporarily stored onsite must be removed
within 45 days of excavation.
You should be aware that any violation of 15A NCAC 2L may subject you to a civil
penalty assessment under the authority of G.S. 143-215.6A. You should also be aware that the
Division is considering enforcement action including the assessment of civil penalty against you
for your failure to comply with the Notice of Violation issued to you by the Division on May 6,
2002. Your response and/or questions should be directed to G. Landon Davidson of the Asheville
Regional Office at [phone].
Sincerely,
G. Landon Davidson, P.G.
Regional Groundwater Supervisor
-". s ua iit = ectian an t @antweii

Incident Report
Report Number: 200400621
Incident Type: Spill (Oil, Chemical, non -sewage)
On -Site Contact:
Incident Started: 2004-03-23 04:00:00
First/Mid/Last Name:
Ron Richardson
County: McDowell
Company Name:
Old Fort FD
City: Old Fort
Phone:
[phone] Ext.
Responsible Party:
Pager/Mobile Phone:
(828)4424777 Ext.
First Name: -'�
Reported By:
Middle Name:
First/Mid/Last Name:
Bruce A Taylor
Last Name: �c'�'�®�
Company Name:
Owner:
Address:
3931 NC226 S
Address:
City/State/Zip:
Marion NC 28752
City/State/Zip:
Phone:
Phone:
Pager/Mobile Phone:
Date/Time:
Material Category: Estimated Qty: UOM
Chemical Name
Reportable Qty. lbs. Reportable Qty. kgs.
Location of Incident:
Old Fort Finishing Plant - 156 Water Street Old Fort
fiction Taken:
NRC notified incident # 716874
EOC notified
Region 4 notified
Owner notifed and environmental contractor requested
EPA enforcement notified
1500- GARCO (David Walker) on site along with Owner
1530 - EPA - Kevin Wisenhimer on site
Clean up begins
Report Created 03/25/04 05:02 PM
Cause of Incident:
> 100 gallons of 46 Fuel Oil in the abandoned W WTP and
Storm water system - thru a culvert under 140 - moving to the
Catawba River
Evidence that this has been on going since September 2003
;omments:
No sheen in the river - evidence of oil loss over long period of
time.
Other Contact - McDowell EMS
Mavis Lavendar
828.659.2782
EPA On -scene - Kevin Misenhimer
Page 1

Incident Questions:
Did the Material reach the Surface Water? Yes Surface Water Name? Catawba River
Did the Spill result in a Fish Kill? No Estimated Number of fish?
If the Spill was from a storage tank indicate type. Aboveground storage tank (Above Ground or Under Ground)
Containment? Yes
Cleanup Complete? No
Standard Agencies Notified:
Agency Name Phone
EPA Region IV [phone] Ext.
US National Response Center(800)424-8802 Ext.
Emergency Management [phone] Ext.
Groundwater Section [phone] Ext.
Department of Transportation [phone] Ext.
Other Agencies Notified:
Agency Name Phone
DWQ Information:
Report Taken By:
Phone:
Date/Time:
Referred Via:
Did DWQ request an additional written report?
If yes, What additional information is needed?
Report Created 03/25/04 05:02 PM
First Name M.I.
Last Name
Contact Date
Catrina
Jones
2004-03-24 09:30:00 AM
2004-03-04 10:00:00 AM
Jimmy
Ramsey
2004-03-24 09:45:00 AM
Kaye
Decant
2004-03-24 11:00:00 AM
Bruce A
Taylor
2004-03-24 09:00:00 AM
First Name M.I.
Last Name
Contact Date
RO Person Referred to:
Addtional Regional Contacts:
Page 2

FACILITY �.
COUNTY ���'eC� CLASS
MAILING ADDRESS �i�—a,� ��/� �°,�"•,y�
co) f6
RESPONSIBLE
OFFICIAL
TELEPHONE NO.
WHERE LOCATED
ze e
FACILITY
REPRESENTATIVE
3,-
CERT. NUMBER
CLASS
NPDES- PERMIT NUMBER NC OTHER PERMIT NO. -
STATE FEDERAL DATE ISSUED
DATE ISSUED
EXPIRATION DATE
STREAM: NAME
CLASS
7Q10
SUB —BASIN
OPERATOR

State of North C�
Department of E Poni
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. -Ross Jr., Secretary
Gregory J. Thorpe, Ph.D.,Acting Director
March 14, 2002
ML
NC-DENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
A L Hashe
United Merchants & Manufact
200 National Ave
Spartanburg SC 29303
Subject: Rescission of NPDES Permit
Permit No. NCO077623
United Merchants & Manufact_
McDowell County
Dear Mr. Hashe:
Reference is made for the rescission of the subject NPDES Permit. Staff of the
Asheville Regional Office have confirmed that this Permit is no longer required.
Therefore, NPDES Permit No. NCO077623 is rescinded, effective immediately.
If in the future you wish to again discharge wastewater to the State's surface waters,
you must first apply for and receive a new NPDES Permit. Operating a facility without
a valid NPDES Permit will subject the responsible party to a civil penalty -of up to
r $25,000 per day.
If it would be helpful to discuss this matter further, I would suggest that you contact
the Water Quality staff, Asheville Regional Office at [phone].
Sincerely - -
Gregory J. Thorpe, Ph.D.
cc: McDowell County Health Department
Asheville - Water Quality Regional Supervisor - Wattachments
Point Source Branch - Dave Goodrich
Operator Training and -Certification
Point Source Compliance - Robert Farmer - w/attachments
Mr. Roosevelt.Childress, EPA
Central Files - w/attachments
Fran McPherson, DWQ Budget Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative_ Action Employer 50%-recycled/ 100% post -consumer paper

Mar 24 04 10:14a DWQ USER �: (9-19)733-0059 P.1
93/24/04 18:84:SS (202) 267-449S-> 919-733 8059 SHMHC- Page 881
NATIONAL RESPONSE CENTER - FLASH FAX
xxxGOVERNMENT USE ONLYxxxGOVERNMENT USE ONLYxxx
DO NOT RELEASE this information to the public without
permission from the NATIONAL RESPONSE CENTER 1-800-424-8802
Incident Report N 716874
INCIDENT DESCRIPTION <'O
xReport taken by: MST2 RATHBUN at 09:48 on 24-MAR-04 J y
Incident Type: FIXED /� 1
Incident Cause: UNKNOWN v- ,` 5
Affected Area: CATAWBA RIVER 0
The incident was discovered on 23-MAR-04 at 16:00 local time.
Affected Medium: WATER CATAWBA RIVER
REPORTING PARTY
Name: LARRY FROST
Organization: NC DIVISION OF WATER QUALITY
Address: 59 WOODSIN PLACE
ASHVILLE, NC 28801
PRIMARY Phone: [phone] PRIMARY Phone: {828)2311702
Type of Organization: LOCAL GOVERNMENT
SUSPECTED RESPONSIBLE PARTY
Name: SAM FIMCHON
Organization: OWNERS OF OLD FORD FINISHING
GREENWOOD, SC'
PRIMARY Phone: [phone]
Type of Organization: UNKNOWN
INCIDENT LOCATION
County: MCDOWELL
State: NC
INTERSTATE 40 TO OLD FORD EXIT
RELEASED MATERIAL(S)
CHRIS Code: OSX Official Material Name: OIL, FUEL: NO. 6
Also Known As:
Qty Released: 1000 GALLON(S) Qty in Water: 0 UNKNOWN AMOUNT
DESCRIPTION OF INCIDENT
#6 FUEL OIL IS IN STORM DRAINS AND HAS ENTERED THE CATAWBA RIVER.
ALL OF THE STORM DRAINS LEAD FROM OLD FORD FINISHING.
INCIDENT DETAILS
Building ID:
Type of Fixed Object: WAREHOUSE
Power Generating Facility: UNKNOWN
Generating Capacity:
Type of Fuel:
NPDES:
NPDES Compliance: UNKNOWN
---WATER INFORMATION ---
Body of Water: CATAWBA RIVER
Tributary of:
Nearest River Mile Marker:
Water Supply Contaminated: NO

State of North Ca )qv.
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Gregory J. Thorpe, Ph.D.,Acting Director
March 14, 2002
A L Hashe
United Merchants & Manufact
200 National Ave
Spartanburg SC 29303
r�1
NCDERR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Rescission of NPDES Permit
Permit No. NCO077623
United Merchants & Manufact
McDowell County
Dear Mr. Hashe:
Reference is made for the rescission of the subject NPDES Permit. Staff of the
Asheville Regional Office have confirmed that this Permit is no longer required.
Therefore, NPDES Permit No. NCO077623 is rescinded, effective immediately.
If in the future you wish to again discharge wastewater to the State's surface waters,
you must first apply for and receive a new NPDES Permit. Operating a facility without
a valid NPDES Permit will subject the responsible party to a civil penalty of up to
$25,000 per day.
If it would be helpful to discuss this matter further, I would suggest that you contact
the Water Quality staff, Asheville Regional Office at [phone].
Sincerely
Gregory J. Thorpe, Ph.D.
cc: McDowell County Health Department
Point Source Branch - Dave Goodrich
Operator Training and Certification
Point Source Compliance - Robert Farmer - w/attachments
Mr. Roosevelt Childress, EPA
Central Files - w/attachments
Fran McPherson, DWQ Budget Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%.recycled/ 10% post -consumer paper

Wof North Carolina '
Department of Environment
and Natural Resources'
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting
MEMORANDUM
AM
From:
Subject:
NORTH CAROLINA DEPARTMENT OF
/IRONMENT AND NATURAL RESOURCES
February 15, 2002
Landon Davidson
NC DENR / Groundwater Section / Environmental Regional Supery
Asheville Regional Office
Charles H. Weaver, Jr. /
NPDES Unit
Rescission of NPDES Permit NCO077623
United Merchants and Manufacturing/Old Fort Industrial Park .
McDowell County
This facility has an expired permit for the discharge of remediated groundwater. The facility has not discharged in
several years Relevant correspondence concerning this issue is attached.IW4 ijile 5-4-043f,`2t 'a
ipnxinnat>iyI Please indicate below your section's position or viewpoint on this action and return this forn
by March 15, 2002. If you have any questions about this project, please contact me at the telephone number or e-
mail address listed at the bottom of this page.
RESPONSE: (Check one)
�j� Concur with the rescission of this permit. Future groundwater monitoring 'activities should not
u require discharge of wastewater.
Opposes rescission of the above permit, based on reasons stated below, or attached:
❑
1617 Mail Service Center, Raleigh; North Carolina 27699-1617 919 733-5083, extension 511 (fax) 919 733-0719
Visrr us ON THE INTERNET @ http://h2o.6nr.state.nc.us/NPDES Chades.Weaver@ ncmail.net
r�4

M C Co ^—
JC
�,.` 2 2 F9-w
VENTER ( QIl�T
41CIENTER
01 Real ]Estate Services, Inc.
1...�
STREET • GREENWOOD, SOUTH CAROLINA 29649 • PHONE [phone]
December 21; 1999
Ms. Laura Kay Dechant, Hydrogeologist
Division of Environmental Management
NCDENR
59 Woodfin Place
Asheville, North Carolina 28801
102: Groundwater Corrective Action
1999 Annual Report
Old Fort Industrial Park, L.L.C.
Old Fort, North Carolina
Dear Ms. Dechant:
FAX [phone]
Please find enclosed a copy of the Groundwater Corrective Action 1999 Annual
Report for the Old Fort Industrial Park site. At our request, the monitoring wells at site and
the Process Well were sampled in October, 1999 by Davis & Floyd, Inc. Based on the
sampling results, which show no significant change in the groundwater analyses from recent
sampling events, we request that the monitoring wells be sampled on ah annual basis only.
Also since some of the„inoriitoring wells have never showed any contamination or have been
dry for several years, we request that only monitoring wells MW-1; MW-4, MW-6 and the
Process Well be analyzed for halogenated organics. The remaining wells should have water
levels checked only so that a potentionnetric map can be developed for the annual sampling
event. We request that the sampling event be conducted during the 4`h quarter of the year.
We would submit an annual report summarizing the results by January 31" of the following
year.
We hope that you will consider these changes in the sampling schedule for the Old
Fort Industrial Park site. If you shocdd have any questions; please do not hesitate to call us.
RS:thp
enclosure
Very t y yours
Renee Simchon
Property Manager
REAL ESTAI'E SALES v f R(:)I'FRTY MANAGEMENT • CONSTRUCT ION .
i

' Michael F. Easley
OVA
V w Governor
NCDENR William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
A.L. Hashe
United Merchants & Manufacturing
200 National Avenue
SPARTANBURG, SC 29303
Dear Permittee:
September 27, 2001 t nru,
_ OCT 1 2 2001 ;l
Subject: Notice of Violation
Failure to Submit Permit, Renewal. Application
NPDES Permit NCO077623
United Merchants & Manufacturing
McDowell County
The subject permit expires on April 30, 2000. North Carolina Administrative Code (15A NCAC 2H.0105(e)) requires
that an application for permit renewal be filed at least 180 days prior to expiration of the current permit. To satisfy this
requirement, your renewal package should have been sent to the Division postmarked no later than November 2,1999.
As of this date, the Division has not received a renewal request for the subject permit. This is a violation of Part II,
Section B. 10. of your. permit, -which states "Any permittee that has not requested renewal at least 180 days prior to
expiration... will subject the permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.".
In order to prevent an assessment of civil penalties you must submit a completed permit application (see enclosed forms)
within 10 days of your receipt of this letter. Submit the completed application package to the address listed at the bottom of this
page.
If all wastewater discharge from your facility has ceased and you wish to rescind this permit, contact Rob Lang of the
Division's Compliance Enforcement Unit at [phone], extension 361. You may also contact the Asheville Regional Office
at [phone] to begin the rescission process.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with
the permit renewal application. If you have any questions, please contact Charles H. Weaver, Jr. of my staff. Mr. Weaver's
telephone number, fax number and e-mail address are listed at the bottom of this page.
Sincerely,
Original Signed By
David A. Goodrich
Gregory J. Thorpe, Ph.D.
cc: Central Files
�sheville'Regional Offic�Wate ,Quality Sectionl
NPDES File
1617 Mail'Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 511 (fax) 919 733-0719
VISIT US ON THE INTERNET@ http://h2o.enr.state.nc.us/NPDES e-mail: [e-mail]

r
NPDES Permit NCO077623
United Merchants & Manufacturing
McDowell County
The following items are REQUIRED for all renewal packages:
❑ A cover letter requesting renewal of the permit and documenting any changes at the facility since
issuance of the last permit. Submit one signed original and two copies.
❑ The completed application form (copy attached), signed by the permittee or an Authorized
Representative. Submit one signed original and two copies.
❑ If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
.the renewal package, submit written documentation showing the authority delegated to any such
Authorized Representative (see Part II.B.11.b of the existing NPDES permit).
❑ A narrative description of the sludge management plan for the facility. Describe how sludge (or other
`solids) generated during wastewater treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed
original and two copies.
The following items must be submitted ONLY by Industrial facilities discharging process
wastewater:
❑ Industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Code of
Federal Regulations, Part 122) must submit a Priority Pollutant Analysis (PPA) in accordance with 40
CFR Part 122.21. If `the PPA cannot be completed by the time you complete your application package,
submit the application package without the PPA. Submit the PPA as soon as possible after you receive
the completed analyses.
The above requirement does NOT apply to municipal or nonindustrial facilities.
PLEASE NOTE:
Due to a change in fees effective January 1, 1999, there is no renewal fee required with your
application package.
Send the completed renewal package to:
Mr. Charles H. Weaver, Jr.
NC DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

State -of North Carolina'
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
September 1, 1999
A L HASHE
UNITED MERCHANTS & MANUFACTURING
200 NATIONAL AVE.
SPARTANBURG, SC 29303
Dear Permittee:
Tk?/�
NCDENR
NORTH CAROLINA DEPARTMENT OF
�F
�
Subject: Renewal of NPDES Permit NCO077623
UNITED MERCHANTS &
MANUFACTURING
MCDOWELL County
The subject permit expires on April 30, 2000. North Carolina Administrative Code 15A NCAC
2H.0105(e) requires that an application for permit renewal be filed at least 180 days prior to expiration
of the current permit.
To satisfy this requirement, your renewal package must be sent to the Division postmarked no
later than November 2, 1999. Failure to request renewal of the permit by this date will result in a civil
assessment of at least $250.00. Larger penalties may be assessed depending upon the delinquency of
the request.
If any wastewater discharge will occur after April 30, 2000 (or if continuation of the permit is
desired), the current permit must be renewed. Operation of wastewater treatment works or
continuation of discharge after April 30, 2000 would violate North Carolina General Statute 143-215.1
and could result in assessment of civil penalties of up to $25,000 per day. -
If all wastewater discharge has ceased at your facility and you wish to rescind this permit,
contact Robert Farmer of the Division's Compliance Enforcement Unit at [phone], extension
531. You may also contact the Asheville Regional Office at [phone] to begin the rescission
process.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items
you must submit with the permit renewal application. If you have any questions, please contact me.
My telephone number, fax number and e-mail address are listed at the bottom of this page.
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
iA�`sheville_Regional Office, Water Quality Section ^'
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 511 (fax) 919 733-0719
An Equal Opportunity Affirmative Action Employer [e-mail]

-NPDES Permit NC0077623 -
UNITED MERCHANTS & MANUFACTURING
MCDOWELL County
NPDES File

Incident No.86220
Subject: Incident No.86220 .
From: Jan Andersen <[e-mail]>
Date: Mon; 10 Dec 2007 14:40:40 -0500
To: [e-mail]
BCC: [e-mail]
Attached please find subject files per our phone conversation.
Please call'if you have any questions.
Jan Andersen
Jan Andersen - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Waste Management - Underground Storage Tanks
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Jan Andersen <Jan.Andersen(a,ncmail.net>
NC DENR - Asheville Regional Office
Division of Waste Management - Underground Storage Tanks
MC86220DOC121007.pdContent-Type: application/pdf
Content -Encoding: base64
%IC86220SITEMAPDOC121007-001.pd Content -Type: apphcation/pdf
Content -Encoding: base64
1 of 1 - 12/10/2007 2:42 PM

Re: old fort facility
AM -
Subject: Re: old fort facility
From: Landon Davidson <[e-mail]>'�� C
Date: Fri, 05 Oct 2007 09:27:36 -0400
To: "Messer, Cindy" <[e-mail]>
CC: James Bateson <[e-mail]>, BRUCE PARRIS
<[e-mail]>, [e-mail], Jan Andersen <[e-mail]>
For the petroleum -related issues, Jan Andersen is the UST (underground storage
tank) Section supervisor at 828-296-4500. The UST Section addresses all petroleum
related releases including those releases from above -ground tanks which is the case
for Old Fort.
Landon
Messer, Cindy wrote:
Thank you for the information. If the client needs to speak with someone
regarding the environmental findings, who should I put them in touch with?
Please follow up with a contact name, phone number and email.
Again, I appreciate your efforts in identifying this report.
Cindy
------------------------------------------------------------------------
*From:* Landon Davidson [mailto:Landon. [e-mail]]
*Sent:* Thu 10/4/2007 10:43 AM
*To:* James Bateson
*Cc:* [e-mail]; Messer, Cindy; BRUCE PARRIS
*Subject:* Re: old fort facility
The petroleum related issues surrounding the Old Fort facility should be
documented in a file with the UST Section of the Asheville Office. There
was a significant fuel oil release that was directly impacting the
Catawba River. The current owner of the facility was so recalcitrant in
dealing with the fuel oil release with our agency that the EPA was
called info conduct an emerciencv abatement effort. -•e r�emaini.ncii;s,sues
FuTinq fure'1oiwl recovev d_e14t�wih pop "erly�. We attempted to bring in
other parties such as the contractor that was reportedly to be partly
responsible for the release but again, we received very minimal
cooperation with the owners of the facility. Let me know if you need
more detail on any of these points.
Landon
James Bateson wrote:
> Ben and Cindy,
>
> I scanned the most recent groundwater monitoring report for the Old
> Fort facility. Please find it attached in pdf format. This report
> provides the best available.summary of groundwater cleanup efforts of
> chlorinated solvent available to us here in DWM's central office, but
> does not serve as a complete record of environmental concerns that may
> exist at the site.
> Landon,
> Ben Rogers of NC Pollution Prevention and Cindy Messer of NC > Department of
Commerce are working with a potential developer of the
> United Merchants/Old Fort Finishing Plant. I got a brief synopsis of
> the site history from Kay Dechant on Tuesday afternoon. She mentioned
> that prior to the reorganization, you had been working with the
1 of 3 10/10/2007 10:18 AM

Re: old fort facility
> current owner on issues related to a fuel oil spill. When John Walch
> did a rapid read through the files recently shipped to DWM Oberlin
> Road, he did not find files related to petroleum issues, and I presume
> those files are over with UST on Capitol Boulevard. Any information
> you could give would be appreciated: Cindy Messer 828 654-9852.
> Thanks,
> Jim Bateson
> bboy 430 wrote:
>> Jim,
>> Thought this document might help?!
>> Ben Rogers
>> P2
>> our server is down so this is my personal email. my state email is
[e-mail] <mailto:[e-mail]>
>> "be the change you want to see in the world" MG
>> FLHBBoys
>> ----- -------------------------------------------------------------------
>> *Join Excited - http://www.excite.com* <http://www.excite.com*/>
>> The most personalized portal on the Web!
G. Landon Davidson, P.G.
NCDENR - Division of Water Quality
Aquifer Protection Section
Regional APS Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
web page: http://h2o.enr.state.nc.us/agw.html
G. Landon Davidson, P.G.
NCDENR - Division of Water Quality
Aquifer Protection'Section
Regional APS Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
web page: http://h2o.enr.state.nc.us/agw.html
2 of 3 10/10/2007 10:18 AM

Re: old fort facility ,
Landon Davidson <Landon.Davidson a,nemail.net>
NC DENR - Asheville Regional Office
Division of Water Quality -Aquifer Protection Section
3 of 3 • 10/10/2007 10:18 AM

IBEAM'_- Aident DataEntry
Water Quality; Groundwater L�_;;,�Jents -Incident EntryTj
Page 1 of 2
CIDENT INFORMATION
Incident Number 86220 Site Priority:
Incident Name* 'OLD FORT INDUSTRIAL PARK,FUEI
Incident Address FORMER UNITED MERCHANTS PLANT ..__
Incident City/Town jLD FORT Incident Zip
County* McDowell Region
L__......_.____...--..._.._._.__........_..................
.. .. ..... .. .... ............. ._.._ _ .........__.._ .....- .� .. i.
RO Contact I MEH
CONTAMINATION INFORMATION
Contamination Sources Contamination
#1 {AST System Heating Oil/Kerosene
#2 No Data I No Data
?.............._...._.....-----------.......-- L---..._--._.._........._......
--...__......................_......-------.........._....- ---.,.... _._........._............
....:................_.._..__....__.._.....
#3 No Data.._.. -I I No Data
GROUNDWATER CONTAMINATION No Data
CONTAMINATED WELLS o # Private Drink
o : # Private Non-1
0 # Public Wells
INFORMATION
RP First Name
RP Company
RP Mailing Address
RP City GREENWOOD y
RP Telephone Number
Ownership Type
Operation Type.
RENEE
OLD FORT INDUSTRIAL PARK LLC j
709 CENTER STREET
.- -- -_.......... _ -
RP State North Carolina
864-388 0202
Private
Industrial -
RP siMOH
Lastname
RP Zip
http://ibeam.enr.state.nc.us/dwglGwilIncident Entry jsp?incidentkey=$6220 10/10/2007

IBEAM _ Incident Dat*ntry
Page 2 of 2
STATUS INFORMATION
Report/Discovery Date'' �.04_ _ / 1 s / 2002
----
..
Notice Date 05 / 03 / 2002
............
Next Action CSA
CSA Received
CSA Reviewed
CSA ;Approved
CAP Type
CAP Implemented
Last Modified
OCATIONAL INFORMATION
Latitude; 35.63052 Convert
_................._...................................
Lat/Long QC i GPS Value
OMMENT
Phase Asses
Next Due Date .05
CAP Received
CAP Reviewed
CAP Approved
Remediation Type
Date Closed
Longitude;-82.17505
.......
Quad; M82k5P
EVIDENCE OF LEAKAGE OR SPILLAGE IN AREA AROUND A LARGE FUEL OIL AST. RECOMMEND THAT AST A
REMOVED.
IRMF19FIF Submit Reset
http://ibearn.enr.state.nc.us/dwq/Gwi/Incident_Entry jsp?incidentkey=86220 10/10/2007

r l��
�� lVfaling Address: P.O. Box 216
Waynesville, NC 28786
Street Address: 9 Haywood Office Park
Building A, Suite 102
Environmental, Pc. Waynesville, NC 28785
March 28, 2006 RECEIVED
Mr. Landon Davidson MAR 2 9 2006
North Carolina Department of Environment and Natural Resources Asheville Regional
Asheville Regional Office
2090 U.S. Highway 70 Aquifer Protection
Swannanoa, NC 28778
Re: Quarterly Inspection Report for Old Fort Industrial Park Oil Spill
Old Fort Industrial Park - Old Fort, McDowell County, North Carolina
Dear Mr. Davidson:
This letter report documents inspections conducted during the reporting period of December 2005
through February 2006 at Old Fort Industrial Park, in accordance with the Administrative Order
issued for this.site by the United States Environmental Protection Agency (EPA) on March 25, 2004,
and with the Letter Work Plan submitted by Old Fort -Industrial Park in January 2005. Visual
inspections of the storm water system; including the cofferdam area and the outfall on the north side
of I-40, were performed by Gene Bartlett, an on -site employee of Old Fort Industrial Park, LLC, at
three week intervals during the period. Mr. Bartlett stated that no oil discharge was observed during
any of the inspections, and no additional oil has accumulated in the drainage structures or on the
absorbent booms since maintenance activities were performed at the site by NEO Corporation on
January 10 and 11, 2006 (as documented in the previous inspection report dated February 1, 2006).
The Administrative Order and the Letter Work Plan required inspections and reporting for a period
of six months after the completion of mitigation activities. This report documents the results of
inspections completed in months four through six after completion of the mitigation activities.
Therefore, with submittal of this report, all requirements of the Administrative Order and the Letter
Work Plan have been completed.
Please contact me at the address or telephone numbers on this letterhead, or by e-mail at
[e-mail], if you have any questions or comments.
Sincerely,'
TEC Environmental, P.C.
(06a 01-4-
David Traylor, P.E.
Environmental Engineer
cc: Mr. Sam Simclon / Old Fort Industrial Park, LLC
Mr. Rick Jardine; P.E. / EPARegion 4
Mr. Lee Zimmerman, Esq. / -McNair Law Firm, P.A.
Mr. Charles S. Carter, Esq. / McNair Law Firm, P.A.
Phone: [phone] • Fax. [phone] • Internet: www.tecenviro.com

Mailing Address: P.O. Box 216
Waynesville, NC 28786
1 _ Street Address: 9 Haywood Office Park
Building A, Suite 102
Environmental, Pc. Waynesville, NC 28785
y
DC
February 1, 2006
�=
1 M
ca
m
0
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to
111
Mr. Landon Davidson
o
.� o'
c
C
M
North Carolina Department of Environment and Natural Resources
p
o�
Asheville Regional Office
�
2090 U.S. Highway 70 _
Swannanoa, NC 28778
Re: Quarterly Inspection Report for Old Fort Industrial Park Oil Spill
Old Fort Industrial Park - Old Fort, McDowell County, North Carolina
Dear Mr. Davidson:
This letter report documents inspections and maintenance activities conducted at Old Fort Industrial
Park in accordance with the Administrative Order issued for this site by the United States
Environmental Protection Agency (EPA) on March 25, 2004.. Visual inspections of the storm water
system, including the cofferdam area and the outfall on the north side of I-40, were performed by
Gene Bartlett, an on -site employee of Old Fort Industrial Park, LLC, at three week intervals over the
period of September through November 2005. Mr. Bartlett stated that no additional oil discharge
was observed during any of the inspections. David Traylor of TEC Environmental inspected the
storm water system while onsite on December 2, 2005 to perform the annual groundwater sampling
event. It was observed on December 2 that approximately a 1-inch thickness of oil was present in the
oil/water separator located north of I-40, and that the absorbent booms at the storm water outfalls on
both the north and south sides of I-40 needed to be changed. Old Fort Industrial Park contracted
NEO Corporation to perform the required boom maintenance and product removal activities. NEO
completed the work at the site on January 10 and 11, 2006. Work completed by NEO was as follows:
Used absorbent booms and pads were collected from the outfalls on both the north and south
sides of I-40, placed in drums, and removed from the site for disposal. New absorbent
booms were placed at both outfalls to collect any additional oil that may pass through the
drainage pathway.
• Oil and oily water in the oil/water separator was pumped into two 55-gallon drums and
removed from the site for disposal. Oil clinging to the sides of the oil/water separator was
removed using a degreaser, which was contained and pumped into the drums for disposal.
Inspections are scheduled to continue as required by the Administrative Order, and a second
inspection report will be submitted at the end of the next quarter.
Phone: [phone] • Fax. [phone] • Intemet: www.tecenviro.com

Mr. Landon Davidson
Page 2
February 1, 2006
Please contact me at the addressor telephone numbers on this letterhead, or by e-mail at
[e-mail], if you have any questions or comments.
Sincerely,
TEC Environmental, P.C.
David Traylor, P.E.
Environmental Engineer- - -
cc: Mr. Sam Simchon / Old Fort Industrial Park, LLC
Mr. Rick Jardine, P.E. / EPA Region 4
Mr. Lee Zimmerman, Esq. / McNair Law Firm, P.A.
Mr. Charles S. Carter, Esq. / McNair Law Firm, P.A.

� � � � i i �
J

- ' �` - -� '��� - --f --- �� - - -- � �---� '--J � - - --- � � - - �---� -� � - ' - -- --� �--- - �

Mailing Address.
P.O. Box 216
- T-(
Waynesville, NC 28786
C Street Address.
9 Haywood Office Park
Building A, Suite 102
_ Environmental, Pc
Waynesville, NC 28785
w—
j August 22, 2005Cn
z
rn
C 5)
Mr. Kevin Misenheimer
Federal On -Scene Coordinator
_T ro
USEPA Region 4
c �'
61 Forsyth Street, SW
o
Atlanta, GA 30303
"CD
Re: Report of Cleanup Activities for Old Fort Industrial Park Oil Spill
rl
One Water Street, Old Fort, McDowell County, North Carolina
Dear Mr. Misenheimer:
We are submitting this letter report to document cleanup activities completed at Old Fort Industrial
Park between April and June, 2005, in compliance with the Administrative Order issued for this site
by the United States Environmental Protection Agency (EPA) on March 25, 2004.
Project Background
The North Carolina Department of Environment and Natural Resources (NCDENR) and EPA
Region 4 responded to a discharge of No. 6 fuel oil into the storm drains and ditches at the Old Fort
Industrial Park on March 24, 2004. Old Fort Industrial Park, LLC contracted Garco, Inc. to provide
cleanup services for the spill. Garco recovered oil from the site storm water system, a culvert beneath
Interstate 40 (I-40), and a drainage pathway south of I-40 leading to the Catawba River on March 24
through 26, 2004. An estimated 3,600 gallons of oil were recovered by the cleanup effort.
EPA issued an Administrative Order for this incident on March 25, 2004 requiring additional cleanup
and investigation of this release. Old Fort Industrial Park submitted a Letter Work Plan to EPA
Region 4 in January 2005 that described proposed cleanup activities intended to comply with the
requirements of the Administrative Order. EPA Region 4 approved the Work Plan and the proposed
schedule for the work in March 2005.
Site Cleanup Activities
This section provides a description of the cleanup activities completed at Old Fort Industrial Park in
compliance with Part III, Sections B and C of the Administrative Order. Old Fort Industrial Park
contracted Garco, Inc. to perform the cleanup work. TEC Environmental, P.C. provided oversight
and coordination of the work. The cleanup activities were completed between April 22 and June 8,
2005. The following paragraphs list the requirements of the Administrative Order in bold, followed
by a description of the activities completed to satisfy each requirement.
Phone: [phone] • Fax. [phone] • Internet www.tecenviro.corn

Mr. Kevin Misenheimer
Page 2
August 22, 2005
III. B.1. Remove oil and oily debris and vegetation from the ditch leading to the Catawba River,
including removal of significant oil which has contaminated the storm water culvert
underneath Interstate 40.
Garco personnel collected oily debris and vegetation on the south side of I-40 near the outfall of the
storm water culvert on May 18, 2005. All work was completed by hand since the area is not
accessible to heavy equipment. Oily debris and vegetation that could be reasonably removed using
hand tools was collected and contained in plastic bags for disposal. Absorbent booms and pads were
placed in the drainage pathway to collect any residual oil that might pass through the culvert and
drainage pathway.
Oil that had collected on the north side of the I-40 culvert was also cleaned up on May 18 using
absorbent booms and pads. Garco requested that the pit and underflow dam that was constructed
during the March 2004 cleanup effort on the north side of I-40 be left in place as a stop -gap measure
to intercept any oil that might discharge from the site storm water system before it passes
underneath I-40. Therefore, the pit and underflow dam was left in place instead of being drained
and excavated as proposed in the Letter Work Plan.
Water was flushed through the culvert beneath I-40 as part of the storm water system flushing
(described below) completed on May 17 through 18, and on May 24. No measurable amount of oil
--. was recovered from the culvert during the flushing. Also, no oil was obseived to be recovered by the
absorbent booms after significant rainfall events that occurred during the field effort.
III. B. 2. Flush the subsurface storm water system on the site to remove oil. Contain flushed
water and oil and remove the oil from the containment area.
Garco mobilized a vacuum truck to the site on April 22, 2005. Oil was present on this date in the
oil/water separator located near the outfall of the site storm water system on the north side of I-40
and in the next upstream junction box. The vacuum truck was used to vacuum oil and water from
the drainage structures until the vacuum truck tank was filled. Then water from the bottom of the
vacuum truck tank was decanted back into the storm drainage system at a junction box further
upstream to flush oil in the system piping down to the oil/water separator. This process was
repeated multiple times on April 22, and recovered approximately 140 gallons of oil from the storm
water system. The oil was transported to Garco s facility in Asheboro, NC for disposal.
The lower portion of the storm water system was again flushed on May 17 and 18, 2005. Water
contained in the cofferdam was pumped out using the vacuum truck and then released into the
storm water system at the junction box located midway between the cofferdam and I-40. The water
was allowed to flush though the lower part of the onsite storm water system and through the culvert
beneath I-40. A total of approximately 16,000 gallons of water was flushed through the system by
this method. No measurable amount of oil was recovered by this flushing activity.
The entire lower portion of the storm water system, from the cofferdam to the outfall on the south
side of I-40, was flushed on May 24, 2005. Water that had collected in the cofferdam area from rain
events the previous weekend was pumped from the cofferdam into the storm water pipe at the
_ location where the pipe was severed at the cofferdam. An estimated 80,000 gallons of water were

Mr. Kevin Misenheimer
Page 3
August 22, 2005
pumped through the lower portion of the storm water system on May 24. No measurable amount of
oil was recovered by this flushing activity. Upon completion of the flushing, the storm drainage pipe
was sealed shut with cement to prevent any future flow from entering the lower portion of the storm
drainage system at the cofferdam area. Sealing of this pipe should effectively disconnect the flow
pathway through which oil apparently migrated from the source area of the spill to the Catawba
River.
III. B. 3. Upon completion of all flushing and oil collection efforts, provide for periodic
inspection of storm water outfalls and effluent points to monitor for further discharge
of oil into the onsite ditches and the Catawba River. Place boom and sorbent materials
as needed to mitigate further discharges which may occur over time due to rainfall
events.
Absorbent booms and pads were placed at the outfall of the culvert on the south side of I-40, and at
the outfall of the site storm water system on the north side of I-40 to mitigate any further discharges.
In addition, the pit and underflow dam at the outfall of the site storm water drainage system was
kept in place as a stop -gap measure to intercept any oil that might discharge from the site storm
water system before it passes underneath I-40. Old Fort Industrial Park plans to have their onsite
employee perform the required periodic inspections of the storm water outfalls and effluent points
and report the results to TEC Environmental for documentation and follow-up actions as necessary.
III. B. 4. Remove all oil contained in the cofferdam and transfer the material to a secure
container (i.e. frac tank, tanker truck, etc.). Dispose of the collected oil at an appropriate
oil recycling or disposal facility.
All liquid in the cofferdam was pumped out by vacuum truck on May 17 and 18, 2005. No oil was
present in the cofferdam, only water was present on these dates. The water was used to flush the
storm drainage system as described above.
III. B. 5. Remove all soil from the cofferdam, which is saturated with oil and which may
represent a continuing threat of discharge of oil into the navigable waters of the U.S.
This soil should be disposed of at an appropriate off site disposal facility.
Oil -impacted soil was excavated from the cofferdam area over the period of May 17 through May 27,
2005, and again on June 8, 2005. The soil was excavated using a trackhoe and loaded onto dump
trucks that transported the soil to the Foothills Environmental Landfill in Lenoir, NC for disposal.
Excavation was continued until no further oily sheen or oil -stained soil was present in the cofferdam
area. A total of 576 tons of oil -impacted soil was excavated and disposed of from the site on May 17
through 27. Disposal manifests for the soil will be submitted after they have been provided by the
cleanup contractor. The final excavation measured approximately 83 feet in length, and varied in
width from approximately 23 feet to 35 feet. The depth of the excavation varied from approximately
6 to 8 feet below ground surface. Groundwater was encountered at a depth of approximately 8 feet
- below ground surface. Figure 1 shows the final extent of the cofferdam excavation area.

Mr. Kevin Misenheimer
Page 4
August 22, 2005
As of the date of this report, the excavated cofferdam area has not been backfilled. It is anticipated
that the property owner will choose not to backfill the area and will leave the excavation as a small
storm water retention pond.
III. C.1. Identification and mapping of the on site storm water collection and discharge system
which may contain residual oil from the historical spill, including storm water piping
and collection structures underneath buildings on site.
The suspected pathway by which the oil spill traveled through the storm water system was
confirmed and mapped by smoke testing on April 22, 2005. Figure 2 shows the site storm water
drainage system as mapped on April 22. The smoke testing confirmed that the oil spill entered the
-, storm drainage system through a trench drain along the north side of the industrial park building,
and then traveled through a storm drainage pipe beneath the building and along the pathway shown
on Figure 2. This pathway was effectively broken when the storm drain pipe was severed during
construction of the cofferdam area during the initial spill response, and the pathway has now been
permanently disconnected by the sealing of the drain pipe at the cofferdam area.
Planned Future Activities
Old Fort Industrial Park plans to conduct regular inspections of the storm water collection system as
required by Part III, Section C. 2. and C. 3. of the Administrative Order. The inspections will be
performed by an onsite employee of the industrial park and the results will be reported to TEC
Environmental for documentation and follow-up actions as necessary. Each inspection will include
observation of all sumps, pits, manholes, and discharge points along pathway that the oil spill
traveled. As proposed in the Letter Work Plan and agreed upon by EPA Region 4, inspections will
be done once a month and after any rainfall event of more than 0.5 inches. If any oil is discovered
during the inspections, a cleanup contractor will be contracted to remove the oil and/or replace any
booms and absorbent wads as needed. The inspections will be continued for a period of six months.
Summary and Conclusion
Cleanup activities related to a prior oil spill were completed at Old Fort Industrial Park between
April 22 and June 8, 2008. As documented in this letter report, these activities have addressed the
requirements of Part III, Sections S and C of the Administrative Order, with the exception of the
follow-up inspections which are planned to be performed for a six-month period. Submittal of this
letter report also satisfies the reporting requirement contained in Part III, Section D. 1. of the
Administrative Order.

10
Mr. Kevin Misenheimer
Page 5
August 22, 2005
Sincerely,
_ TEC Environmental, P.C.
a L
David H. Traylor, P.E.
Environmental Engineer
F it _ o au '- el El
cc: Mr. Sam Simchon / Old Fort Industrial Park, LLC
Mr. Landon Davidson / NCDENR Division of Water Quality
Mr. Charles S. Carter, Esq. / McNair Law Firm, P.A.
Mr. Lee Zimmerman, Esq. / McNair Law Firm, P.A.

FIGURES

Mailing Address. P.O. Box 216
Waynesville, NC 28786
C Street Address. 9 Haywood Office Park
Building A, Suite 102
Environmental, Pc. Waynesville, NC 28786
D
rn
T �D91"
u , u
J
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T
'l.
August 23, 2005
G,7
ri
Mr. Landon Davidson
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: Report of Cleanup Activities for Old Fort Industrial Park Oil Spill
Old Fort Industrial Park - Old Fort, McDowell County, North Carolina
Dear Mr. Davidson:
Enclosed is your copy of the letter report submitted to Kevin Misenheimer of EPA Region 4
documenting oil spill cleanup activities completed between April and June 2005 at Old Fort
Industrial Park. Please contact me at the address or telephone numbers on this letterhead, or by e-
mail at [e-mail], if you have any questions or comments.
Sincerely,
TEC Environmental, P.C.
Oa,,,P a A -
David Traylor, P.E.
Environmental Engineer
Enclosure
Phone. [phone] • Fax. [phone] • Internet www'.tecenviro.com

Old Fort
Subject: Old Fort
From: [e-mail]
Date: Tue, 10 May 2005 16:36:10 -0400
To: [e-mail]
CC: [e-mail]
Joan,
Just wanted to give you an update'.
Mr. Simchon agreed to start the required field work no later than April
20 and complete the work within three weeks. Tomorrow (May 11) will be
the end of the three week period.
Although, Mr. Simchon has conducted some of the field work as required,
there are still outstanding items that were required in the January 14,
2005 Letter Work Plan that have not been completed. These include:
- flushing of the storm drainage system and removal of remaining
oil. This includes the portion of the system located between the
cofferdam and I-40. Flushing of and removal of oil from the culvert
underneath I-40.
- The cofferdam will be drained and any oil present will be
recovered. Oil contaminated soil in the cofferdam will be removed and
properly disposed of. The cofferdam will be backfilled with clean soil
and absorbent booms will be placed a the stormwater outfall.
- The pit on the north side of the I-40 culvert will be drained
and oil contaminated material will be excavated and be properly disposed
of. Absorbent booms will be placed at the outfall to mitigate further
discharges.
EPA has not been notified (by the RP or counsel) of the reason why Mr.
Simchon has not completed this work.
Let's discuss our next course of action.
Thanks,
Kevin Misenheimer
Federal On -Scene Coordinator
US EPA Region 4
404.562.8922 Office
404.229.9500 Cell
[e-mail]
1 of 1 5/12/2005 4:59 PM

Old Fort —�
Subject: Old Fort
From: [e-mail]
Date: Wed, 11 May 2005 16:08:27 -0400
To: [e-mail]
CC: [e-mail], [e-mail], [e-mail]
Greg,
EPA has spoken to Mr. Simchon's attorney (Lee Zimmerman) regarding the
completion of work at the Old Fort Industrial Complex Site. Mr.
Zimmerman has assured EPA that arrangements have been made to continue
and complete the work that was agreed to between Mr. Simchon and EPA
(January 14, 2005 work plan). Also, Mr. Zimmerman has assured EPA that
an agent or representative will be available to sign manifests on behalf
of Mr. Simchon for waste materials generated at the site.
It is EPA's understanding that field work will continue next week. The
tasks outlined in the work plan which have yet to be completed include
the following:
1. Flushing of the storm drainage system and removal of remaining
oil. This includes the portion of the system located between the
cofferdam and I-40. Flush water will be introduced to the system south
of the cofferdam and recovered at the outfall on the north side of I-40.
The culvert beneath I-40 will be flushed and oil -and water will be
recovered and disposed of at an appropriate facility.
2. The cofferdam will be drained and any oil present will be
recovered. Oil contaminated soil in the cofferdam will be removed and
properly disposed of. Post -excavation soil samples will be collected
from the cofferdam area to confirm that oil -impacted soil has been
removed. The cofferdam will be backfilled with clean soil and absorbent
booms will be placed a the stormwater outfall. Additional site grading
and earthwork may be required to properly manage storm water effluent at
the outfall coming from underneath the building. (the area of the
cofferdam)
3. The pit on the north side of the I-40 culvert will be drained and
oil contaminated material will be excavated and be properly disposed of.
Confirmation soil samples will be collected after the excavation is
completed. Absorbent booms will be placed at the outfall to mitigate
further discharges.
4. Regular inspections of the stormwater system will be performed
after completion of the mitigation activities for a period of six
months. The inspections will be performed on a monthly basis, or after
any rainfall event of more than 0.5 inches. Any oil discovered during
the inspections will be removed and absorbent booms will be maintained
such that they will continue to mitigate any oil discharges.
Please let me know if you have any questions or if you need
clarification on the activities listed above. Also, please advise me of
your schedule for implementing these activities.
Thanks,
Kevin Misenheimer
Federal On -Scene Coordinator
US EPA Region 4
404.562.8922 Office
404.229.9500 Cell
[e-mail]
1 of 1 5/12/2005 5:00 PM

TestAmerlca
ANALYTICAL TESTING CORPORATION
Nashville Division
COOLER RECEIPT FORM BC# 414180
Client Name : 7b, i I4i! h
Cooler Received/Opened On: 4/28/05 Accessioned By: Mark Beasley
Log -in Pvfonnel Signature
1. Temperature of Cooler when triaged: �` U Degrees Celsius
2. Were custody seals on outside of cooler?............................................................. CYES...N0....NA
a. If yes, how many and where:
3. Were custody seals on containers?......................................................I........................... CAYES ... NA
4: Were the seals intact, signed, and dated correctly? ................................................ ES ...NO...14A
5. Were custody papers inside cooler?................................................................... Q ...NO...NA
6. Were custody papers properly filled out (ink, signed, etc)? ...................................... Q... NO ... NA
7. Did you sign the custody papers In.the appropriate place? ....................................... 19 ... NO ... NA
S. What kind of packing material used? Bubblewrap Peanuts Vermiculite Foam Insert
i lock baggte Paper Other None
9.
Cooling process: ce Ice -pack Ice (direct contact)
Dry ice Other None
10.
Did all containers arrive in good condition ( unbroken)? .............. ............................. YES .NO ... NA
11.
Were all container labels complete (#, date, signed, pres., etc)? ................................. (&NO ... NA
12.
Did all container labels and tags agree with custody papers? ....................................
(a'.NO...NA
13.
Were correct containers used for the analysis requested? ....................................... O..NO... NA
14.
a. Were VOA vials received?.......................................................................... YES... IO ..NA
b. Was there any observable head space present in any VOA vial? .................................
NO ... YES. NAB
15.
Was sufficient amount of sample sent in each container? .........:..............................
9).NO... NA
16.
Were correct preservatives used?..................................................................... &-NO ... NA
If not, record standard ID of preservative used here
17. Was residual chlorine present?.........................:............................................... NO .YES ... NA
18. Indicate the Airblll Tracking Number (last 4 digits for Fedex only) and Name of Courier below:
a�3z
Fed- UPS Velocity DHL Route Off-street Misc.
19. If a Non -Conformance exists, see attached or comments below:
BIS = Broken in shipment
Cooler Receipt Form LF-1 Revised 415105
End of Form

414180
To assist us In using the proper analytical methods,
TestAmerica
is this workbeing conducted for regulatory purposes?
• ANALYTICAL TESTING CORPORATION
Compliance Monitoring
Client Name Ai2,e
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Address: _E 0. l&ar
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Projed Name: old Ci F;l- AIJ f,,,. k _
City/Stataftcode: Asti.)o
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Telephone Number: �3t,
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Report To: c7 Rc4
Sampler Name: (Print Name)
Invoice To:
Sampler Signature:
Quote PO#:
Matrix
Preservation & # of Containeral
Analyze For:
TAT
ash (surcharges may apply)
Dab Needed: Y4 - q9J Ls .
Fax Results: Y 0
SAMPLE ID
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REMARKS
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Spscisi Instructions:
£-mc.,1 Resu1�S ':b �tei 20101 cltt�rev.C, . cc.,sr
LABORATORY COMMENTS:
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Cuistody Seals: Y N N/A
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Data:
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Sample NonConforman
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Process: Other NC/Process: Sea Comment petition Below
Corrected By; !fenny Bundy
Action:,
Closed: © kbundy
Process: TPH Method?
Corrected By: Kenny Bundy
Action: Process Completed
Closed: ® kbundy
Rommenta: Cpmmont added by: $ean►blll on a/2812000 910:04 AM
NC GIR40d with out commento
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Page 1 of 1 412812005 810M5 AM NO M 27470
Semple Nonconformance! CSP_12 Ravlaed 6.160
CaC Revision Form

TestA. merica
ANALYTICAL TESTING CORPORATION
2960 POSTER CREIGRTOA Dxirs • NASHVILLE. TENVESsEE 37204
800-763.0980 • 615-726-3404 Fix
ANALYTICAL REPORT
TESTAMERICA-ASHEVILLE 5781
DINAH TRAMMEL
122 LYMAN STREET
ASHEVILLE, NC 28801
Project:
Project Name: OLD FORT IND. PARK
Sampler: RON SMITH
Lab Number: 05-A59442
Sample ID: SAMPLE #1
Sample Type: Soil
Site ID:
Date Collected: 4/26/05
Time Collected: 10:30
Date Received: 4/28/05
Time Received: 7:45
Report
Dil
Analysis
Analysis
Analyte Result Units Limit
-------------------------- ----------- --------------
Factor
------
Date
--------
Time Analyst Method Batch
---------------------- -----
*GENERAL CHEMISTRY PARAMETERS*
% Dry Weight 86.7 8
1.0
4/28/05
12:24 J. Davis CLIP 1968
*ORGANIC PARAMETERS*
TPH (Diesel Range) 1870 mg/kg 45.9
10.0
4/29/05
2:40 M..Jarrett 8015B 2356
----------------------
Sample Extraction Data
Wt/Vol
Parameter Extracted Extract Vol Date Time Analyst Method
---------------- --------- ----------- -------- ------------------------
EPH/DRO 25.1 gm 1.0 ml 4/28/05 K. Turner 3550
LABORATORY COMMENTS:
ND = Not detected at the report limit.
B = Analyte was detected in the method blank.
J = Estimated Value below Report Limit.
E = Estimated Value above the calibration limit of the instrument.
# = Recovery outside Laboratory historical or method prescribed limits.
All reported results for metals or Organic analyses have been corrected for dry weight.
The TRPH-Diesel surrogate was diluted out due to sample matrix.
The TRPH-Diesel MS/MSD were not reported due to the matrix of the sample spiked.
End of Sample Report.

TestAmerica
ANALYTICAL TESTING CORPORATION
2960 FowEbt CxmcHToh DRIVE • NASHVILLE, THN.VEssEg 37204
800-763-0980 • 615-726-3404 FAx
PROJECT QUALITY CONTROL DATA
Project Number:
Project Name: OLD FORT IND. PARK
Page: 1
Laboratory Receipt Date: 4/28/05
Matrix Spike Recovery
Note: If Blank is referenced as the sample spiked, insufficient volume was received for the defined analytical batch for
MS/MSD analysis on an true sample matrix. Laboratory reagent water was used for QC purposes.
Analyte units Orig. Val. MS Val Spike Conc Recovery Target Range Q.C. Batch Spike Sample
----------------------------------------- ------------------------------- ---------- ------------
Matrix Spike Duplicate
Analyte units orig. Val. Duplicate RPD Limit Q.C. Batch
--------------- ------- -------------------- ------ --- ----- ----------
Laboratory Control Data
Analyte ' units Known Val. Analyzed Val 8 Recovery Target Range Q.C. Batch
--------------- ----------------- ---------------------- ------------ ---------
-UST PARAMETERS—
TPH (Diesel Range) mg/kg 40.0 46.9 117 54 - 126 2356
Duplicates
Analyte units Orig. Val. Duplicate RPD Limit Q.C. Hatch I Sample Dup'd
-------------------------------- -------------------- ----- ---------- ------------
Blank Data
Analyte Blank Value Units Q.C. Batch Date Analyzed Time Analyzed
------------------------------------------------------------------------
Project QC continued . . .

TestAmerica
ANALYTICAL TESTING CORPORATION
2960 FwaER CRkawon DRivs • NASHVILLE, TENYESSEE 37204
800-765-0980 • 615-726-3404 FAx
PROJECT QUALITY CONTROL DATA
Project Number:
Project Name: OLD FORT IND. PARK
Page: 2
Laboratory Receipt Date: 4/28/05
Blank Data
Analyte Blank Value Units Q.C. Batch Analysis Date Analysis Time
--------------- ------------ --------- ---------- ------------- -------------
**UST PARAMETERS**
TPH (Diesel Range) < 0.10 mg/kg 2356 4/28/05 21:34
# = Value outside Laboratory historical or method prescribed QC limits.
End of.Report for Project 414180

� 1+
Test merica
ANALYTICAL TESTING CORPORATION
4/29/05
TESTAMERICA-ASHEVILLE
DINAH TRAMMEL
122 LYMAN STREET
ASHEVILLE, NC 28801
2960 FoyrER GREmiToK Dslls • NASHVILLE, TEnvsssu 37204
800-765-0980 • 615-726-3404 FAx
5781
This report includes the analytical certificates of analysis for all
samples listed below. These samples relate to your project identified
below:
Project Name: OLD FORT IND. PARK
Project Number: .
Laboratory Project Number: 414180.
An executed copy of the chain of custody, the project quality
control data, and the sample receipt form are also included as an
addendum to this report. Any QC recoveries outside laboratory
control limits are flagged individually with an #. Sample specific
comments and quality control statements are included in the Laboratory
notes section of the analytical report for each sample,report. If you
have any questions relating to this analytical report, please contact
your Laboratory Project Manager at 1-800-765-0980. Any opinions, if
expressed, are outside the scope of the Laboratory's accreditation.
Page 1
Sample Identification Lab Number Collection Date
---------------------- ---------- ---------------
SAMPLE #1 05-A59442 4/26/05

TestAmerica
ANALYTICAL TESTING CORPORATION
2060 FosTER Ckmcxron DRIVE • NASHVILLE. TtldV6ssEE 37204
800-765-0980 • 615-726-3404 F.Ax
Page 2
Sample Identification Lab Number Collection Date
---------------------- ---------- ---------------
These results relate only to the items tested.
This report shall not be reproduced except in full and with
permission of the laboratory.
AXOAAI-
Report Approved By: Report Date: 4/29/05
Johnny A. Mitchell, Laboratory Director Gail A. Lage, Senior Project Manager
Michael H. Dunn, M.S., Technical Director Glenn L. Norton, Technical Services
Pamela A. Langford, Senior Project Manager Kelly S. Comstock, Technical Services
Eric S. Smith, QA/QC Director Roxanne L. Connor, Senior Project Manage
Sandra McMillin, Technical Services Mark Hollingsworth, Director of Project
Laboratory Certification Number: 387
This material is intended only for the use of the individual(s) or entity to whom it is addressed,
and may contain information that is privileged and confidential. If you are not the intended recipient,
or the employee or agent responsible for delivering this material to the intended recipient, you are
hereby notified that any dissemination, distribution, or copying of this material is strictly prohibited.
If you have received this material in error, please notify us immediately at 615-726-0177.

Michael F. Easley
aI F
Governoi
�Lievart
Lilliam G. Ross, Jr., Secretary
North var�lr ten =of nvironment and Natural Resources
j
CERTIFIED MAIL 7,000 0600 0025 4981 5865
RETURN RECEIPT REQUESTED
Ms. Renee' Simchon
709 Center Street
Greenwood, SC 29649
Subject: Notice of Violation
G.S. 143-215. et sere __
Oil Pollution and Hazardous
Substance. Control Act of 1978
Old Fort Industrial Park Fuel Oil Spill
Groundwater Incident No. 86220
McDowell County
Dear Ms. Simchon:
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
Asheville Regional Office
GROUNDWATER SECTION
May 6, 2002
North Carolina General Statutes, Chapter 143, authorizes and directs the
Environmental Management Commission of thEi Department of Environment and
Natural Resources to protect and preserve the water and air resources of the state.
The Division of Water Quality (DWQ) has the delegated authority to enforce adopted
pollution control rules and regulations.
Based upon the release of Heating oil spilled in the area of the large above
ground heating oil tank at the subjE'ct site, the DWQ has reason to believe that you are
responsible for activities resulting in noncompliance with North Carolina law. The
specific violations of General Statute 143-215.15 et seg, Oil Pollution and Hazardous
Substances Control Act, are as follows:
1. G.S. 143-215.83(a) Unlawful Discharges:
It shall be unlawful for any person to discharge oil or other hazardous
substances into or upon any waters or land within the state.
To correct the violations, you are required to submit a report to the Asheville
Regional Office assessing the cause, significance, extent of the release and actions
taken to remove the contamination.
Groundwater Section, 59 Woodfin Place Asheville, NC 28801-2414 Telephone: [phone] Customer Service
Fax: [phone] 623-7748

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Ir Idbrrt-Name Page 1 of 2.
Incident Management Data Entry
Incident Information
0510612002
Incident Number
86220
Site Priority 1
45 C
Incident Name
OLD FORT INDUSTRIAL PARK FUEL OIL SPILL
Incident Address
FORMER UNITED MERCHANTS PLANT
Incident City/Town
OLD FORT
Incident Zip
County
McDowell
ROContact
LKD
Responsible Party Information
RP Contact
RENEE SIMCHON
RP Company
OLD FORT INDUSTRIAL PARK LLC
RP Address
709 CENTER STREET
RP City
GREENWOOD
IRP State
I SOUTH CAROLIN
RP Zip
29649
RP Phone
864-388-0202
OwnerShip Type,
Private
Operation Type
I Industrial
Contamination Information
GWContam (YIN)
Sources
Type
Wells
AST System
Heating Oil/Kerosene
Private Well
0
Private NonDrinking
0
Public Well
0
Status Information
Report/Discovery Date
4/19/2002
jPhase
Follow Up
Notice Date
5/3/2002
INext Due Date
5/20/2002
Next Action
CSA
CSA Received
CAP Received
CSA Approved
CAP Approved
Last Modified
5/3/2002
CAP Type
None .
Date Closed
ICAP Implemented
No Data
Locational Information
Latitude (DMS)
353744
Longitude (DMS)
821038
Latitude (Decimal Degrees)
35.6288888888889
Longitude (Decimal Degrees)
82 1772222222222
http://gw.ehnr.state.nc.us/Pirf/I ncdPrnt.ASP?Userl D=ASH6025G&I ncd=86220 5/6/2002

W-.- t-itName Page 2 of 2
lLat/Long OC I EST lOuad 1 M82k5P
Comments
EVIDENCE OF LEAKAGE OR SPILLAGE IN AREA AROUND A LARGE FUEL OIL AST. RECOMMEN
THAT AST AND CONTAMINATED SOIL BE REMOVED.
http://gw.ehnr.state.nc.us/Pi rf/I ncdPrnt.ASP?Userl D=ASH6025G&I ncd=86220 5/6/2002

709 Center Street
Greenwood, SC
29649
May 23, 2002
G. Landon Davidson, L.G.
Regional Groundwater Supervisor
NCDENR
59 Woodfin Place
Asheville, NC 28801-2482
Re: Oil Spill
I am in receipt of your letter dated May 6, 2002. Your office and the town of Old
Fort supervised the oil spill clean up that you refer to when the occurrence
r happened. There were gallons of oil spilled by Biomass Energy, a tenant at the Old
Fort�hidustrial Park all proper authorities were contacted and guidelines followed as
1 -soon�as this accident happened.
r' Under direction and supervision of your office there was a cleanup supervised at the
airne of tfie occurrence. I haves oken with Ka Dechant at the Asheville NCDENR
p Y
office and`.all the files are available on this occurrence. That area has not been
occupied-6r touched since the cleanup was completed and your office and the town
4t I of Old Fort ceased enforcement actions with the company that had the spill. Since
'' the date of the completed work Biomass performed with your office &the town of
r Old Fort's supervision they closed and moved to Tennessee and have no. further
1 f contact with Old Fort Industrial Park.
All information you requested in the last two paragraphs of your letter are in your
Asheville office files with Kay Dechant whom was involved with the process as it
was dealt with when it happen: Our park is 86% vacant at this time and filing for
protection. When this problem was created and dealt with by your office and the
tenant, Biomass, the park was in stable condition and 100% leased to full capacity —
it was in a strong position to handle the tenant whom caused the problem and absorb
the issue. I will be glad to provide any information available and work with your
office in any capacity that I can given our current situation.
Sincer
Renee' Simchon
Property Manager for the LLC
Telephoine,Direet 864=388=0202
Fax 864=223-6685
N" e-ma>�l. seen-aod
_�.... e R@IlleradlS.G0it1
E C E-0V 00
MAY 2 4 2002
GROUNDWATER SECTION
ASHEVILLE REGIONAL OFFICE

OfficeView Pro Message
From: Cantwell, Janet x9-356
To: Dechant, Kay x266
Subject: Re: Simchon address
Received 2002 Apr 25 10:29
Dechant, Kay x266 sent:
> Hi Janet, I'm finally getting around to the NOV for >
Old
> Fort Finishing. I have an adress for Sam Simchon >
at
> 709 Center Street, Greenwood, SC 29649. Is this >
the
address for Renee? Do you have her phone # ?
Thanks, Kay
Hi Kay: Renee' is at the same address as Sam.
Her phone # is: 864-388-0202
Her mobile # is: 864-344-2525
Her fax # is 864-223-6685
Her email: [e-mail]
How's that for information!! ---Janet---
Reply:

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Re: Old Fort Finishing Plant, Old Fort, NC
Subject: Re: Old Fort Finishing Plant, Old Fort, NC
From: Roy Davis <[e-mail]>
Date: Mon, 19 May 2008 09:38:19 -0400
To: Llewellyn McCourry <[e-mail]>
CC: [e-mail], Roy Davis <[e-mail]>
Mr. McCourry: We are not able to make copies for you. However you may come by and
review our completer file and make copies of those documents you wish to have. Roy
Davis
Llewellyn McCourry wrote:
Mr. Bateson / Mr. Davis:
I understand that Old Fort Finishing in Old Fort, NC is a site that the NC DENR
has worked on in the past. I am writing to request information and copies of.the
files on:Old Fort Finishing.
-I am aware'of .an excavation that was done there about 1989 which included drums.
We fee-i! 'the -'water and''•s'o'il could be contaminated and could be
stagger• i ig. number o`f cancer deaths we are seeing.. A lot of the deaths _were::people ` '
who eit-he,r..worked, there.,. worked nearby, or lived in Old Fort. Also, .I need -to
know if -there any plans.for this industry site.
I Would like ,to•se.t up, an appointment to.come by and pick up .these copies..•. 0 .,if -
you can send them to me, -please let me know, and I will forward to you my addr'ess.::
Thank,, you,
L. Omar McCourry..
- -- - -----------------7----7---7---------------'--
.E-mail for .the greater good. ,Join _the i'm.,Initiative from Microsoft.
<httpc//im':live.com%Messenger/IM/Join/Default.aspx?source=EML WL %20Greater Good>
Roy ..Davis,-!-.!, Roy ., Davi s@ncmai l . net.,
.
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division. of Water Quality - Water Quality Section
209V U. S 70 Highway'
Swannarioa-•: NC .2 8 7:78 c.I;
Tel: [phone]
Fax: [phone]
Roy Davis <Roy.Davis(ancmailaiet>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
1 of 1 5/19/2008 9:39 AM

Environmental Matter
Subject: Environmental Matter
From: Llewellyn McCourry <[e-mail]>
Date: Wed, 14 May 2008 15:24:30 -0400
To: < roy.davis@ncmail. net>
Hello Mr. Davis,
Thanks again for taking the time to talk with me this morning. Thought I would send you my contact info in case
you should come across anything else interesting regarding Old Fort Finishing or the Old Fort Area in general.
E-mail: [e-mail]
Cell Ph: 828-527-7767
Sincerely,
L. Omar McCourry
With Windows Live for mobile, your contacts travel with you. Connect on the
1 of 1 k5/15/2008 10:11 AM

Tort Schedule]
Subject: [Fwd: Fw: Old Fort Schedule]
From: Landon Davidson <[e-mail]>
Date: Mon, 16 May 2005-08:21:29 -0400
To: JANET CANTWELL <[e-mail]>
What do you think?
Landon Davidson - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject: Fw: Old Fort Schedule
From: [e-mail]
Date: Sat, 14 May 2005 14:13:36 -0400
To: [e-mail]
Landon,
See below the schedule of work for next week at Old Fort. I will not be
able to come to the site. Let me know if you might be able to send a
DENR representative.
Kevin
----- Forwarded by Kevin Misenheimer/R4/USEPA/US on 05/14/2005 02:12 PM
Greg Russell
<[e-mail]
> To
Kevin
05/13/2005 05:17 Misenheimer/R4/USEPA/US@EPA, Lee
PM Zimmerman
<[e-mail]>, David
Traylor <[e-mail]>
cc
Andy Purgason <[e-mail]>
Subject
Old Fort Schedule
Gentlemen
We will mobilize to Old Fort on Tuesday 5/17.
Our trackhoe may be spotted on Monday.
1 of 2 5/16/2005 8:39 AM

•ort Schedule]
Tue: We will be onsite with a vac truck and crew to start removing
water and oil from the coffer dam area and to evaluate the situation in
the stormwater basins and wier down by I-40
Wed: Continue with water work and start excavation and hauling
activities.
Thur: Same
Fri: Same
One question at large: Can we decant the vacuum truck and run this
water through the system? The system will have absorbent booms and pads
and eventually runs through the wier.
Greg Russell
President - GARCO, Inc.
336-683-0911
Landon Davidson <Landon.Davidson(a,ncmail.net>
NC DENR - Asheville Regional Office
Division of Wai
r (Quality - Groundwater Section
Content -Type: message/rfc822
Fw: Old Fort Schedule
Content -Encoding: 7bit
2 of 2 5/16/2005 8:39 AM

gal Park/Simchon site
Subject: Old Fort Industrial _Park/Simchon- siteV���'
From: J Cantwell <Janet.Cantwell@ mail. t>
Date: Fri, 12 Aug 2005 10:03:41 -0400
To: Landon Davidson <[e-mail]>, Kevin Misenheimer
<misenheimer.kevin@epa. gov>
Hi Guys ---You asked about site visits to Old Fort Industrial:
5/13/05 --- Wanda Frazier/DWQ and I made a site visit and found oil in the vault next to the retention
pond beside I-40. We also saw where oil had dripped from the pipe at the retention pond next to I-40
near the vault (took pictures). Nothing had been -done at the back of the plant. We checked the
Catawba at the bridge, I-40, next exit east, and saw nothing. We also looked at the Catawba River on
the south side of I-40 across from the vault and saw nothing exiting the pipe. Discoloration from
previous oil spills on the rocks on the bank of the river was still slightly evident.
5/17/05 --- I met with Carl of GARCO at the site. They were beginning to vacuum out the oil and
water from the vaults and then would flush with water. David Traylor of TEC Environmental, PC,
who has contracted with the Simchons, was also there on site making notes and taking pictures. I'll
forward them to both of you.
6/13/05 --- I made a "Level 1" inspection of the site from the parking lot. There was no one there and it
didn't appear anything was being done.. There was a trackhoe sitting by the coffer dam: the dam was
full of water from the recent'rains but I didn't see a "sheen" of oil on the water. I did not check the
vault or retention pond down near the culvert going under I-40.
I believe it's probably time to make another check of the site! I'll let you know what I find. —Janet.
Landon Davidson wrote:
Janet -
You've been there more recently than I have, would you please provide Kevin with a summary of
you observations? Thanks.
Landon ,
Subject:
Old Fort
From: Misenheimer.Kevin(&,,epamail.epa.gov
Date: Mon, 08 Aug 2005 15:51:17 -0400
To: landon.davidson(-)ncmail.net
To: landon. davidsonna,ncmail.net
Landon,
1 of 2 8/12/2005 10:09 AM

, ial Park/Simchon site
Have you been out to the Old Fort Site recently? I spoke to Garco
(Contractor to Mr. Simchon) and they said that they have not done any
additional work at the site (boom and pad maintenance) and in fact have
not been paid for the work that they did.earlier this year.
Just wondering if DENR had conducted any site visits or could say if any
other oil had been observed in the storm water system.
Thanks,
Kevin Misenheimer
Federal On -Scene Coordinator
US EPA Region 4
404.562.8922 Office
404.229.9500 Cell
[e-mail]
Janet Cantwell - Janet.Can-�:well@riciiia:i.l..net
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 US Highway 70
Swannanoa, NC 28778-8211
Tel: [phone]
Fax: [phone]
Link to the DIVISION OF WATER QUALITY:
http://h2o.enr.state.nc.us/
Link to the NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES:-
http://www.enr.state.nc.us/
Janet Cantwell <Janet.Cantwell(a,ncmail.net>
NC DENR - Asheville Regional Office
Division of Water Quality -Surface Water Protection
_..................._............._._____..................._.._.... ........ . _.......... _ ....... .... ... __...._..__ ._;
2 of 2 8/12/2005 10:09 AM

Subject: [Fwd: Old Fort]
From: Landon Davidson <[e-mail]>
Date: Tue, 09 Aug 2005 09:47:05 -0400
To: JANET CANTWELL <[e-mail]>
Janet -
You've been there more recently than I have, would you p7
summary of you observations? Thanks.
Landon
Landon Davidson - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject: Old Fort
From: [e-mail]
Date: Mon, 08 Aug 2005 15:51:17 -0400
To: landon.davidson@nc mail.net
Landon,
Have you been out to the Old Fort Site recently? I spoke to Garco
(Contractor to Mr. Simchon) and they said that they have not done any
additional work at the site (boom and pad maintenance) and in fact have
not been paid for the work that they did earlier this year.
Just wondering if DE14R had conducted any site visits or could say if any
other oil had been observed in the storm water system.
Thanks,
Kevin Misenheimer
Federal On -Scene Coordinator
US EPA Region 4
404.562.8922 Office
404.229.9500 Cell
[e-mail]
Landon Davidson <Landon.Davidsonnancmail.net>
NC DENR - Asheville Regional Office
Division of Water Quality - Groundwater Section
Content -Type: message/rfc822
-
Old Fort
Content -Encoding: 7bit
1 of 1 8/9/2005 5:40 PM

dustrial Park pictures from David Traylor
Subject. @ldgFortKIndustrial.Par-k=pictures--frOm David,Tray_lor
From: Janet Cantwell <[e-mail]>
Date: Fri, 12 Aug 2005 10:05:16 -0400
To: Landon Davidson <[e-mail]>, Kevin Misenheimer
<misenheimer. kevin @ epa.gov>
Janet Cantwell - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 US Highway 70
Swannanoa, NC 28778-8211
Tel: [phone]
Fax: [phone]
Link to the DIVISION OF WATER QUALITY:
http://h2o.enr.state.nc.us/
Link to the NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES:"
http://www.enr.state.no.us/
Subject: Emailing:1MG_0697, IMG_0698, IMG_0699, IMG_0696
From: "David Traylor" <[e-mail]>
Date: Tue, 17 May 2005 14:07:47 -0400
To: <Janet.Cantwell @ncmail.net>
Janet,
Attached are pictures from this morning at Old Fort.
Thanks,
David Traylor,.
TEC Environmental, P.C.
Phone: [phone]
Fax: [phone]
[e-mail]
1 of 4
8/12/2005 10:11 AM

Austrial Park pictures from David Traylor

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i--,dustrial Park pictures from David Traylor
Janet Cantwell <[e-mail]>
NC DENR -Asheville Regional Office
Division of Water Quality -Surface Water Protection
Emailing: IMG 0697, IMG_0698, IMG_0699, IMG 0696 Content -Type: message/rfc822
Content -Encoding: 7bit
Content -Type: image/jpeg
IMG_0697.JPG
Content -Encoding: base64
Content -Type: image/jpeg
IMG_0698.JPG
Content -Encoding: base64
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IMG_0696.JPG Content -Type:. image/jpeg
Content -Encoding: base64
4 of 4 8/12/2005 10:11 AM

_)ld Fort work schedule.doc
Subject: Fw: Emailing: Old Fort work schedule.doc
From: "Greg Russell' <[e-mail]>
Date: Wed, 20 Apr 2005 16:42:41 -0400
To: <[e-mail]>
CC: <[e-mail]>
FYI:
Greg Russell
President - GARCO, Inc.
336-683-0911
----- Original Message -----
From: Greg Russell
To: David Traylor; Misenheimer.Kevin (a)-epamail.epa.gov ; Renee Simchon
Cc: Andy Purgason
Sent: Tuesday, April 19, 2005 3:51 PM
Subject: Emailing: Old Fort work schedule.doc
This is a best guess of what will actually happen due to profilling and approvals on the soil. As you will
see that analytical sample was taken today.
Let me know if you have any questions or comments.
GAR
Your files are
attached and ready to send with this message.
Old Fort work schedule.doc Content -Type: application/msword
Content -Encoding: base64
1 of 1 8/12/2005 10:37 AM

GARCO, Inc.
Environmental, Industrial & Recycling Services
TO: Sam Simchon (Old Fort Industrial Park)
David Traylor (TEC)
Kevin Misenheimer (EPA)
Andy Purgason (GARCO)
FROM: Greg Russell
DATE: 4/19/05
RE: Schedule of activities for Old Fort Industrial
April 19, 2005
GARCO Project Manager on site to take stockpiled soil sample and deliver to Test
America in Asheville.
April 19, 2005
GARCO will be on site with vacuum truck, tools and equipment to remove free oils from
the storm water collection basins.
Week of April 25, 2005
GARCO will have laboratory data back from Test America.
GARCO will prepare profiles for soil disposal.
Profile decision, acceptance and notification usually take about three days to complete.
Week of May 2, 2005
GARCO will mobilize equipment and start the excavation, loading, transportation and
disposal of approximately 500 tons of petroleum contaminated soil located in the area of
the former coffer dam.
Week of May 9, 2005
GARCO will provide limited site restoration activities and contouring of ditch lines for
future storm water flows.
Demobilization.
Post Office Box 1.907 / Asheboro, NC 27204-1907 / 336-683-0911 / Fax [phone]
www.egarco.com

, . Fort Storm Sewer.pdf]
Subject: [Fwd: Fw: Old Fort Storm Sewer.pdf]
From: Landon Davidson <[e-mail]>'
Date: Mon, 02 May 2005 14:45:49 -0400
To: JANET CANTWELL <[e-mail]>
fyi
Landon Davidson - [e-mail]
North Carolina Dept —of Environment and Natural Resources
Asheville Regional Office
Division of Water -Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject: Fw: -Old Fort Storm Sewer.pdf
From: [e-mail]
Date: Mon, 02 May 2005 09:43:30 -0400
To: [e-mail]
see attached site layout
----- Forwarded by Kevin Misenheimer/R4/USEPA/US on 05/02/2005 09:43 AM
"Zimmerman,!Lee"
<LZimmerman@MCNA
IR.NET> To
Kevin Misenheimer/R4/USEPA/IfS@EPA
04/29/2605 12:08 cc
PM "Carter, Charlie"
<[e-mail]>,
[e-mail],
[e-mail]
Subject
Old Fort Storm Sewer..pdf
Kevin - attached is the mapping of the Stormwater Collection System at
Old Fort prepared by David Traylor. I spoke to Greg Russell at Garco
this morning about the schedule of activities at the site. I need to
discuss with my client and then will get with you.
<<Old Fort Storm Sewer.pdf>>
Lee W. Zimmerman
.McNair Law Firm, P.A.,
1 of 2 1 8/12/2005 10:37 AM

,d Fort Storm Sewer.pdf]
Post Office Box 11390
Columbia, SC 29211
803-799-9800 Ext.262
803-753-3219 (fax)
[e-mail]
http://www.mcnair.net
Notice -of Confidentiality
The information contained in and transmitted with this electronic
communication (including attachments) is subject to attorney and/or
client privileges or is otherwise confidential. It is intended SOLELY
for the addressee designated by the sender., If you are not the intended
addressee or receive this communication in error, any dissemination,
distribution, copying, or other use or reliance on any information
contained or transmitted herein by or to anyone other than the addressee
designated by the sender is UNAUTHORIZED AND STRICTLY PROHIBITED. If
you receive it in error, please notify the McNair. Law Firm, P.A., by
return message or by telephone at [phone] or 799-9800. Any
charges for such notification will be reimbursed. Thank you.
(See,attached file: Old Fort Storm Sewer.pdf)
Landon Davidson <[e-mail]>
NC DENR - Asheville Regional Office
Division of Water Quality - Groundwater Section
Fw• Old Fort Storm S.ewer.pdfjl Content -Type: message/rfc8221
11 Content -Encoding: 7bit
Old Fort Storm Sewer.pdf Content -Type: application/pdf
Content -Encoding: base64
2 of 2 8/12/2005 10:37 AM

........... . ..
..... . ......
SCALE:
1 Inch 100 feet
. . ...... . ........ . .........
0 100
i�V-3()K Gallon AST
(source of spill) ,--Grate Inlet
r-Trench Drain t
0
rate Inlet
Grate Ilnl:�: Me
Junction Box��L
Pipe Save,. —
Pipes Not Mapped
Beyond These Poln
Concrete Box—/
Junction I
Concrete Bf
........ .......
............ ... ....
Industrial Park Building
Ditch
—Approx. Area of Cofferdam
. . .........
Pipe
With Underflow Dam
Ditch I
FIGURE 1 :T:� DRAINAGE SYSTEM
OROM
North
Industrial Park -Old Fart,
Carolina

..sort
Subject: Re: Fw: Old Fort
From: Landon Davidson <[e-mail]>
Date: Tue, 07 Jun 2005 10:36:25 -0400
To: [e-mail]
CC: JANET CANTWELL <[e-mail]>
Kevin -
Not really. My continued and outstanding concerns are the as follows:
1) lack of information being submitted directly to the State of NC
2) failure on the part of Simchon to communicate other parties that were involved
with the initial release around the AST
3) assessment around the AST.
These are my concerns and don't really spill over into your area. I'm very pleased
with what the EPA has accomplished at the site. Keep me informed.
Thanks.
Landon
[e-mail] wrot"e:
Landon,
Here is an update regarding Old Fort. Do you have any specific concerns
at this time?
Kevin Misenheimer
Federal On -Scene Coordinator
US EPA Region 4
404.562.8922 Office
404.229.9500 Cell
[e-mail]
----- Forwarded by Kevin Misenheimer/R4/USEPA/US on 06/06/2005 09:01 AM
David Traylor
<dtraylor@tecenv
iro.com> To
Kevin Misenheimer/R4/USEPA/US@EPA
06/06/2005 08:56 cc
AM Lee Zimmerman
<[e-mail]>, Charlie
Carter <[e-mail]>,
Please respond [e-mail]
to Subject
dtraylor@tecenvi RE: Old Fort
ro.com
Kevin,
Garco completed excavating and hauling contaminated soil from the
cofferdam area on 5/27. A total of 576 tons of contaminated soil was
disposed of from the site. I collected 11 confirmation soil samples
from the excavation for EPA 9071 oil & grease and 3 of the samples had
oil & grease concentrations above the NC state limit of 250 mg/kg. I
spoke to Mr. Simchon last week and he agreed that additional soil should
be excavated and the samples recollected. I plan to meet Garco at the
1 of 3
6/7/2005 4:�

Fort
site tomorrow morning to excavate additional soil in these three areas
and recollect confirmation samples.
Garco flushed approximately 80,000 gallons of water through the
stormwater system from the cofferdam area south during the week of 5/23.
They recovered no appreciable amounts of oil during this flushing. The
entrance of the stormwater pipe south of the cofferdam (at the location
indicated as "Pipe Severed" on the stormwater drainage system map), was
grouted shut to prevent additional stormwater from flowing through that
point from the northern part of the facility. We will find out tomorrow
if any additional oil has been flushed through the southern portion of
the storm system by the several inches of rain we have received here in
the last week.
Items left to be completed:
1. Excavate additional soil and recollect confirmation samples from
areas of cofferdam where oil & grease was > 250 mg/kg.
2. Backfilling of the cofferdam area
3. Additional flushing of storm system if necessary
4. Set up the underflow dams and boom maintenance areas that will be
monitored after the field work is complete. (Note: Garco would like to
leave the small pit located on the north side of I-40 in place for now
to'use as part of the underflow dam/boom maintenance setup to catch any
future oil that might pass through the system. This would prevent the
possibility of having to clean this area up again at a later date if
additional oil is discharged).
No work was performed at the site last week. Garco will.be back on site
tomorrow morning. I will have to get an update from Greg Russell on
what their schedule is for completing the remaining tasks.
David Traylor
TEC Environmental, P.C.
Phone: [phone]
Fax: [phone]
[e-mail]
-----Original Message -----
From: [e-mail]
[mailto:[e-mail]]
Sent: Monday, June 06, 2005 8:08 AM
To: [e-mail]
Subject: Old Fort
David,
I was just writing to get an update from you regarding the Old Fort
Industrial Complex clean up. Can you give me a quick review of the
status at this point.
Thanks,
Kevin Misenheimer
Federal On -Scene Coordinator
US EPA Region 4
404.562.8922 Office
404.229.9500 Cell
[e-mail]
2 of 3 ' 6n12005 4:37 PM

ort
1
Landon Davidson - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Landon Davidson <Landon.DavidsonPncmail.net>
NC DENR - Asheville Regional Office
Division of Water Quality -Groundwater Section
3 of 3 6/7/2005 4:37 PM

ild fort Update]
Subject: [Fwd: Fw: Old fort Update]
From: Landon Davidson <[e-mail]>
Date: Mon, 02 May 2005 14:35:16 -0400
To: JANET CANTWELL <[e-mail]>
fyi
Landon Davidson - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject: Fw: Old fort Update
From: [e-mail]
Date: Mon, 02 May 2005 09:42:36 -0400
To: [e-mail]
update
----- Forwarded by Kevin Misenheimer/R4/USEPA/US on 05/02/2005 09:42 AM
Greg Russell
<[e-mail]
To
David Traylor
04/29/2005 03:33 <[e-mail]>,
PM [e-mail]
cc
Kevin
Misenheimer/R4/USEPA/US@EPA, Andy
Purgason <[e-mail]>
Subject
Old fort Update
2nd set of lab data not yet back from the lab. Should have been in
today Not Ready.
We need to get the lab data and then make a final decesion on where the
material will be disposed. As you all are aware, if the analytical is
above 3,000 ppm Petroleum the North Carolina landfills will not accept
this material. The first sample was a grab at > 3,000 ppm. We went
back on Tuesday and resampled with the composite method of sampling and
have submitted the sample for DRO.
1 of 2 5/3/2005 4:53 PM

,..d fort Update]
We will hopefully have this info on Monday. We will then complete
profiles and submit to the landfill for acceptance.
Then we can schedule the field activities to begin. I would estimate
that Wed or Thur of next week would be the earliest we could start work.
Greg Russell
President - GARCO, Inc.
336-683-0911
Landon Davidson <Landon.Davidson(a),ncmail.net>
NC DENR - Asheville Regional Office
Division of Water Quality - Groundwater Section
Fw: Old fort Update Content -Type: message/rfc822
Content -Encoding: 7bit
2 of 2 5/3/2005 4:53 PM

Fw: Old fort Update
Subject: Fw: Old fort Update
From: [e-mail]
Date: Mon, 02 May 2005 09:42:36 -0400
To: [e-mail]
update
----- Forwarded by Kevin Misenheimer/R4/USEPA/US on 05/02/2005 09:42 AM
Greg Russell
<[e-mail]
04/29/2005 03:33
PM
To
David Traylor
<[e-mail]>,
[e-mail]
cc
Kevin
Misenheimer/R4/USEPA/US@EPA, Andy
Purgason <[e-mail]>
Subject
Old fort Update
2nd set of lab data not yet back from the lab. Should have been in
today Not Ready.
We need to get the lab data and then make a final decesion on where the
material will be disposed. As you all are aware, if the analytical is
above 3,000 ppm Petroleum the North Carolina landfills will not accept
this material. The first sample was a grab at > 3,000 ppm. We went
back on Tuesday and resampled with the composite method of sampling and
have submitted the sample for DRO.
We will hopefully have this info on Monday. We will then complete
profiles and submit to the landfill for acceptance.
Then we can schedule the field activities to begin. I would estimate
that Wed or Thur of next week would be the earliest we could start work.
Greg Russell
President - GARCO, Inc.
336-683-0911
1 of 1 5/3/2005 4:53 PM

,::'i � is ;zr:
......................... _........ ..
R/.; „: 1:,
........................ _.......... _.................................... ___._._._...._.............. ...._._....................... .............................. ._.._..._.......
._....... __.._..._.._.--
_............ _.... _
jr
•�
®�
,.....,..
.......... ............. o.........,
0
i= SCALE:
1 In =100 feel
...............
0 100
0-30K Gallon AST
(source of spill)
\
Trench Drain
rate Inlet
�
N
A
O
ti
n
m
Industrial Park Building
anhole
1
rate Inlet
'
b
i
i
Grate Inlel�:
i
! 1
Manhol
r /
i( ........
.,—...-,
�••„•,.,,,'
Junction Box,
..r.--.�,—......o.__....r-..__._.,r
Culvert —�
pen Ditch
"'.I.
Pipe Severe
N
Approx. Area of Cofferdam
A
I
Pipes Not Mapped
01
•C1
...................__..:......._,.. 't ,\
Beyond These POInLs--,
o+ ,,,.....,....._........._,
t
•t
�/
°
m I
1
j
Rwl '
1 t
Concrete Box
verflcw Pipe .....
Junction Box
+ .
r�
e ••---^
Concrete Box
.....
F�".G
ilNVater Separator r.-•.`Y'"ems
With Underflow Dam ....
y...... 0 ....a.........
36.
s.. O/a C
oq�Y
....
; to
..........................
..._
C
Y-..
' Open Ditch
CPSI"�OP�\J�
Ta
FIGURE 1
TORM DRAINAGE SYSTEM
Environmental,._
ort Industrial Park - Old Fort, North Carolina

_.Tort Storm Sewer.pdff
Subject: [Fwd: Fw: Old Fort Storm Sewer.pdfl
From: Landon Davidson <[e-mail]>
Date: Mon, 02 May 2005 14:45:49 -0400
To: JANET CANTWELL <[e-mail]>
fyi
Landon Davidson - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject: Fw: Old Fort Storm Sewer.pdf
From: [e-mail]
Date: Mon, 02 May 2005 09:43:30 -0400
To: [e-mail]
see attached site layout
----- Forwarded by Kevin Misenheimer/R4/USEPA/US on 05/02/2005 09:43 AM
"Zimmerman, Lee"
<LZimmerman@MCNA
IR.NET> To
Kevin Misenheimer/R4/USEPA/US@EPA
04/29/2005 12:08 cc
PM "Carter, Charlie"
<[e-mail]>,
[e-mail],
[e-mail]
Subject
Old Fort Storm Sewer.pdf
Kevin - attached is the mapping of the Stormwater Collection System at
Old Fort prepared by David Traylor. I. spoke to Greg Russell at Garco
this morning about the schedule of activities at the site. I need to
discuss with my client and then will get with you.
<<Old Fort Storm-Sewer.pdf>>
Lee W. Zimmerman
McNair Law Firm, P.A.
Post Office Box 11390
Columbia, SC 29211
1 of 2 5/3/2005 2:23 PM

sort Storm Sewer.pdfl
803-799-9.800 Ext.262
803-753-3219 (fax)
[e-mail]
http://www.mcnair.net
Notice of Confidentiality
The information contained in and transmitted with this electronic
communication (including attachments) is subject to attorney and/or
client privileges or is otherwise confidential. It is intended SOLELY
for the addressee designated by the sender. If you are not the intended
addressee or receive this communication in error, any dissemination,
distribution, copying, or other use or reliance on any information
contained or transmitted herein by or to anyone other than the addressee
designated by the sender is UNAUTHORIZED'AND STRICTLY PROHIBITED. If
you receive it in error, please notify the McNair Law Firm, P.A., by
return message or by telephone at (803)"753-3262 or 799-9800. Any
charges for such notification will be reimbursed. Thank you.
(See attached file: Old Fort Storm Sewer.pdf)
Landon Davidson <Landon.Davidson(a,ncmail.net>
NC DENR - Asheville Regional Office
Division of Water Quality - Groundwater Section
Content -Type: message/rfc822
Fw: Old Fort Storm Sewer.pd
Content -Encoding: 7bit
Old Fort Storm Sewer.pdf Content -Type: application/pdf
Content -Encoding: base64
2 of 2 5/3/2005 2:23 PM

Microsoft TerraServer Imagery
Page 1 of 2
Search TerraServer
Click to get
wosther f'ereealst ''
lktaps for this point
INF4��att�r
iheNtr'szt�tA�p 'E Main St, Old Fort, NC 28762
Old Fort, North Carolina, United States 4/5/1999
OUT jr
IN
Size
Image courtesy of the U.S. Geological Survey
House and Home Demographics:
[3 Schools, Crime and Demographics for 28711
Q Schools, Crime and Demographics for 28752
�" O ` mr
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i _.PF
, / ' -
t

GARCO, Inc.
Environmental, Industrial & Recycling Services
TO: Sam Simchon (Old Fort Industrial Park)
David Traylor (TEC)
Kevin Misenheimer (EPA)
Andy Purgason (GARCO)
FROM: Greg Russell
DATE:4/19/05
RE: Schedule of activities for Old Fort Industrial
April 19, 2005
GARCO Project Manager on site to take stockpiled soil sample and deliver to Test
America in Asheville.
April 19, 2005
GARCO will be on site with vacuum truck, tools and equipment to remove free oils from
the storm water collection basins.
Week of April 25, 2005
GARCO will have laboratory data back from Test America.
GARCO will prepare profiles for soil disposal.
Profile decision, acceptance and notification usually take about three days to complete.
Week of May 2, 2005
GARCO will mobilize equipment and start the excavation, loading, transportation and
disposal of approximately 500 tons of petroleum contaminated soil located in the area of
the former coffer dam.
Week of May 9, 2005
GARCO will provide limited site restoration activities and contouring of ditch lines for
future storm water flows.
Demobilization.
Post Office Box 1907 / Asheboro, NC 27204-1907 / 336-683-0911 / Fax [phone]
www.egarco.com

ort work schedule.doc
Subject: Fw: Emailing: Old Fort work schedule.doc
From: "Greg Russell" <[e-mail]>
Date: Wed, 20 Apr 2005 16:42:41 -0400
To: <[e-mail]>
CC: <[e-mail]>
FYI:
Greg Russell
President - GARCO, Inc.
336-683-0911
----- Original Message -----
From: Greg Russell
To: David Traylor; Misenheimer.Kevin(d-)epamail.epa.gov ; Renee Simchon
Cc: Andy Purgason
Sent: Tuesday, April 19, 2005 3:51 PM
Subject: Emailing: Old Fort work schedule.doc
This is a best guess of what will actually happen due to profilling and approvals on the soil. As you will
see that analytical sample was taken today.
Let me know if you have any questions or comments.
GAR
Your files are
attached and ready to send with this message.
Old Fort work schedule.doc Content -Type: application/msword
Content -Encoding: base64
1 of 1 4/20/2005 4:47 PM

.,rt Industrial Park]
Subject: [Fwd: Fw: Old Fort Industrial Park]
From: Larry Frost <[e-mail]>
Date: Mon, 18 Apr 2005 07:24:11 -0400
To: JANET CANTWELL <[e-mail]>
FYI
-------- Original Message --------
Subject: Fw: Old Fort Industrial Park
Date: Fri, 15 Apr 2005 16:37:16 -0400
From: [e-mail]
To: [e-mail]
CC: [e-mail]
Landon,
Can you send someone from DENR
next wedn_ esdav3 I can't travel
here in Atlanta. I will try to
I'm not sure that will happen.
Thanks,
to Old Fort to oversee Mr. Simchon's work
during this time because I am on -call
find someone else from EPA to go, but
Kevin Misenheimer
Federal On -Scene Coordinator
US EPA Region 4
404.562.8922 Office
404.229.9500 Cell
[e-mail]
----- Forwarded by Kevin Misenheimer/R4/USEPA/US
"Zimmerman, Lee"
<LZimmerman@MCNA
IR.NET>
04/15/2005 03:43
PM
on 04/15/2005 04:34 PM
To
Kevin Misenheimer/R4/USEPA/US@EPA
CC
Joan
Redleaf-Durbin/R4/USEPA/US@EPA,
[e-mail],
[e-mail],
[e-mail]
Subject
Old Fort Industrial Park
Kevin - Mr. Simchon has engaged Garco, Inc. of Asheboro, NC to implement
the wor!;t
an at Old Fort. Mr. Simchon advises Garco will commence work
on prind will complete the work within three weeks. As
req r. Simchon will forward to you a letter detailing his March
2004 investigation of the on -site storm water system and the potential
migration pathways of the oil from the original spill.
Mr. David Traylor of TEC Environmental, P.C. in Waynesville, NC will
also remain actively involved with the implementation of the work plan.
1 of 2 it 41/18/2005 11:49 AM

A Industrial Park]
Please let me know if you have any questions.
Sincerely,
Lee W. Zimmerman
McNair Law Firm, P.A.
Post Office Box 11390
Columbia, SC 29211
803-799-9800 Ext.262
803-753-3219 (fax)
[e-mail]
http://www.mcnair.net
Notice of Confidentiality
The information contained in and transmitted with this electronic
communication (including attachments) is subject to attorney and/or
client privileges or is otherwise confidential. It is intended SOLELY
for the addressee designated by the sender. If you are not the intended
addressee or receive this communication in error, any dissemination,
distribution, copying, or other use or reliance on any information
contained or transmitted herein by or to anyone other than the addressee
designated by the sender is UNAUTHORIZED AND STRICTLY PROHIBITED. If
you receive it in error, please notify the McNair Law Firm, P.A., by
return message or by telephone at [phone] or 799-9800. Any
charges for such notification will be reimbursed. Thank you.
2 of 2 4/18/2005 11:49 AM

MCNAIR L,w FIRM, P.A.
ATMIlNero&000NGSAWATLAW
LAN DUARK CENTER, SUITS 5DU
46D1 91( FORKS RDAD
RALEIGH, NO 27009
PHONE [phone]
FACSIMILE (91 B) 7664076
DATE: September 14, 2004
FROM: Charlie Carter
DINER OFFICES
ANDEi60Tt
CHARLESTON
CHARLOTTE
AR¢E g"M
aREENVILLE
HILTON HEAD ISLAND
MYRTLE BEACH
FACSLMME .
NO. OF PAGES (MCL. COVER): 4
TO: LANDON DAVIDSON ORGANIZATION: 14C DENR
FAX NO: [phone] PHONE NO: [phone]
MESSAGE: ATTACHED IS THE OLD FORT 908 LETTER RESPONSE. PLEASE
CALL IF ANY QUESTIONS. REGARDS,
140TICE OF CONFIDENTIAL TY
The information contained In and transmitted with this form is subject to atbomey and/or client
privileges or is otherwise confidendal. It is intended SOLELY for the addressee designated by the
sender. If you are not the Intended addressor or receive this communication in error, any
dissemination, distribution, copying, or other use or reliance on any informatlon contained or
transmitted heroin by or to anyone other than the addressee designated by the sender Is
UNAUTFIORWED AND STRICTLY PROHIBITED. If you recelve the facslmile In error, please notify
the MCN,vR Law FIRM, P.A., by telephone at (919) 78"61 or 782• OGRO nr by return facsimile. Any
charges for such notification will be reimhumed. Thank you.

By -Pam rAtqw
JUne 22, =14,
E 6 .......... .
U
4WDwMM I lih Moor
USEP 15 2004
TNtsd Statm &Vh0r=wW ation Aaacy,
F-daim 4
'61 pbrayfil steAt,
Atlauft. GemBFm.3os03-a%0 Ac.3--
4 ClaW *atw Acyt Smflealog
on SPM in McDawdl C=V' North C=Uau, OA Or about Muck 23,
465&R)Aticr daW Ajpdl 19,2004, Old Fwtb4vgzjRj pad; LLjC
-mts dw e=lased Rspouse to c,"n WILIV Ac%
6ca0m 309 bhrm4,.
qnva,-
qucsdws, pWft do nm hadwe to act
IL
za
WhGg j70REIST/Se

REMNSE OF OLD FORT DMUSTRL4L PARK, LLCI TO EPA
CLEAN WATER ACT, SECTION 308
MORMA.TI!t3N REQUEST
01A Fore Industrial bark, L.L.C.
225 EVess 721wiW
Greenwood, SQaat Carolina 29649
1, A. report regarding thie type and volume of ofl spflled (in gallons or btmis) and the
name of the wwstet body affected. If the naive of the water body is not avallable, use the
best demiption availsbIp-
RESPONSE: Old fort 1WdsttW Path, TLC (Owner) does not know the amnaut mud type of old
believed iu have been released at Old Fort Industrial Fad (OM) rteaz Old F'oxt, Narft Carolina..
It is believed the rel=e comiated *of about 12,0DD gallotus of No. 5 fuel %I owned by Biomass
GToup, LLC (Biomass) and'Amidd in a 30,000 gallon aboveaotmd- storage tank ("1sr) fin
ogeratxoa of cnuunetcial gmerea)s on property at OFT leased from the Owner: It to believvd
an initial slug of Biomass fuel oil reached a stofmwatsr ditch. upstce= of tie OPIP pmperty lino.
A is not kw ma that fuel oll i+d d into the stozmdrain at OM reached the Catawba River.
Z. Duration of the spill event. Report the time and dame %:ke spill bit, how long the
product remained in the watereourse, as wall ens an the shoreline or hanks a d when the
cteani:p operm6ous were considered complete and all products removed from waters of the
Vatited 5tfes and adjoining shoreline.
RESP()ltiiMOn or about h= 26, 2003, EJ. Sulfivan crf EJ. SuMv= Co, LLC.: broke a pipe
f mn the Eliy nms AST, Ile contra W att=pted to fix Eke broken pipe by caprpmg' ft liiwe,
then the contractor c vcre3 the broken line with gravel, so fluffier rrleaws wrem nut detectable.
The Owner was not acdficd of tize release initially, 0n September 13, 2003, it Wag discovered
the it pain and gavel covet famed. nd fuel ail wag released into onsft soils and storm drains.
Conreciive action was iuitiaterl Scptembcr 13, 2003, sad it is not believed fool oil impacted a
water of tbz United States as did by st&xe and regulations, old Fort const=ted confer
da=, removed Ave pmduct, =cavated contatainaftd soils, and flushed OFT sw= drains for
several days.
Matatebance of the oo£%x dams, storage of the =wvssed soils in a covered area, and storm dram
gushes continuo todoe,

3. 'be cause of the spill[,
RESPONSE: See RPSPONSt to No. 2 above,
4. Name of the immediate receiving ditek creep, straw, river, lake, arroyo, swA1e,
eta, if know.
RTSPONSE: Th= is uo known came of the io=ediaft meiving. ditch, c reek, strrazu,rim,
lake, a ye, Gr swale.
4.A. Also include The xa]mm of all dowstm m rer ring wat�I'3 that the spM erected.
RESPONSE: It is belied ft sgi11 did not a ct a downs"= receiving water.
4.B Addlffohslly, Dist Al dawvstrrm tecaivlag water bodies to the first major river or
lake, rWwdless of whether or not the spilt affected the w.atu lwdh s...
RESPONSE: Catawba River.
5. Site location map.
R3 VONSIK: A t whed
f% Drawing of the site showing locations of the faellfties.
RESP'ON59.. jkttached
7. Sketch of the quill site showing event of the spHL
RESPONSEz Alt whod
8. Phatographt of the spW and the $piili We liatb before and aftr cleanup.
RESPONSE: A ±mhed
MLUMMA 794179w
TOTAL P. M

■ Complete items 1, 2 and 3. Also complete --I 1
kNorth� Carolina Department of
Emriromnent and Natural Resources
1eDEHR A 59 Woodfm Place, Asheville, NC 28801
vision of Water Quality
Y®a
RS,NEF SIMCHON
709 CENTER STREET
CgR.EENWOOD, -SC 29649
I11-I1111III111161161116161111661
- i
2. Ar`xle Number (Copy from service
r, i4666 3
Received by (Please Print Clearly) B. qa I _of( Deliver
Is deliver
If YES, e
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7 Yes
7 No
Merchandis
❑ Yes
PS Form 3811 , July 1999 Domestic Return Receipt 102595-99-M-178!

UNITED STATES POSTAL SERVI(TW PO
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• Sender: Please print yol
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Postag Pai _
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NCDENR—DWO
GROUNDWATER SECTION d
59 WOODFIN PLACE
ASI-IEVILLE NC 28801
ItJdi,IIII Itit IIIIIIIIIII till IIIII IIIII I III III