NC0006351_Enforcement_20151117

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sent HARRISBURG NC 28075
�iree ATTN: MR STEVE NOVAK
dwr/wb 9/4/15
City,

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S Form 3800.April 2015(Reverse)PSN 7530-02-000-9047

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Total Pot CHEMICAL SP LTIES� C
$ PO BO 0 V ti
1 Sent To 5910 PHAR \\"Cb
7 Street an HARRISBURG 807
ATTN::MR STEVENOVAK
City,Stat dwr/wb 11/17/15

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or Priority Mail'0 service. -Adult signature restricted delivery service,whicl
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'S Fnn'n 3800,Andl nob F/Ravan:al PSN 75nn-n9Ann-OM9

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CI IEMICAL SPECIALTIES, LLC
•
1'O BOX 1330
• 5910 PHARR MILL .
HARRISBURG NC 28075
ATTN::MR STEVE NOVAK
dtar/wb 11/17/15
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MOORESVILLE NC 28115 1.. fir .
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North Carolina Department of Environmental Qualit_,
Pat McCrory Donald vin der Vaal
Governor Secretary
November 17,2015
CERTIFIED MAIL 7015 0640 0002 9295 6422
RETURN RECEIPT REQLESTED
Mr. Steve Novak-, Vice President of Operations
Chemical Specialties, LLC
P.O. Box 1330
5910 Pharr Mill
Harrisburg, North Carolina 28075
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215. li(a)(6) and, NPDES Pe it No. NiC70006351
Chemical Specialties, LLC WWTP
Cab us County
Case No. LV-2015-0092
Dear Mr. Novak:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$493.85 ($35O00 civil penalty + $143.85 enforcement costs) against Chemical Specialties, LLC,
This assessment is based upon the following, facts: A review has been conducted of the self -
monitoring data reported for May 2014. This review has shown the subject facility to be in violation
of the discharge limitations found in NPDES Permit No. NCO 006351 . The violations are summarized
in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Chemical Specialties, LLC
violated the terms, conditions, or requirements of;NPDES Permit No, NCO006351 and North Carolina
General Statute (G.S.) 143-215.1(a)(6) in the manner and extent shown in Attachment A. A civil
penalty may be assessed in accordance with the maximums established by G.S. 143-215,6A(a)(2).
used. upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environrnental Quality and the Director of the
Division of Water Resources, 1, Michael L. Parker, Regional Supervisor for the Mooresville Region,
hereby make the following civil penalty assessment against Chemical Specialties, LLC:
Mooresville Regional Offine,
Location-, 610 East Center Ave., Suite 301 Moomsvilie, NC 28115
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748
Internet,, hftp://prptal,ncdenr,org/web/wq
An Equal Oppottunity \ Affirmative Action Employer - 30N. Racycled/101% Post Consumer paper

For I of the one (1) violation of G.S, 143-215. 1 (a)(6) and
NPDES Permit No. NCO0063 51, by discharging to into the
waters of the State in violation of the permit daily maximum
effluent limit for total zinc.
$_250.00 For I of the one (1) violation of G.S. 143-215.1(a)(6) and
NPIE S Permit No. NCO0063 51, by discharging waste into the
waters of the State in violation of the permit monthly average
effluent limit for total zinc.
$ 350.00 TOTAL CIVIL PENALTY
$_ 143.85 Enforcement costs
$_ 493.85 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the
Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282.1 (b), which are:
(1) The degree and extent of hann to the natural resources of the State, to the public health, or to
private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1'. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do
not include waiverform). Payment of the penalty )Nrill not foreclose further enforcement action for any
continuing or new violation(s).
Please submit payment to the attention of'.
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit wwritten request for remission including a detailed justification f6r such request:

Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy
of any of the factual statements contained, in the civil penalty assessment document. Because a
remission request forecloses the option of an administrative hearing, such a request must be
accompanied by a waiver of your right to an administrative hearing and a stipulation that no factual or
legal issues are in dispute, Please prepare a detailed statement that establishes why you believe the
civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed
below. In determining whether a remission request will be approved, the following factors shall be
considere&
(1) whether one or more of the civil penalty assessment factors in G.S. 1431 -292.1(b) were
wrongfully applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from
the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please note that all information presented in support of your request for remission must be
submitted in writing. The Director of the Division of Water Resources will review your evidence and
inform you of his decision in the matter of your remission request. The response will provide details
regarding case status, directions for payment, and provision for further appeal of the penalty to the
Environmental Management Commission's Committee on Civil Penalty Remissions (Committee).
Please be advised that the Committee cannot consider information that was not part of the original
remission request considered by the Director. Therefore, it is very important that you prepare a
complete and thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Waiver of Right to
an Administrative Hearing and Stipulation of Facts" form within thirty (30) days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed
"Justification for Remission Request," Both farms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
3. File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a
petition for an administrative hearing. You may obtain the petition form from the Office of
Administrative Hearings, You must file the petition with the Office of Administrative Hearings
within thirty (130) days of receipt of this notice..A petition is considered filed when it is received in

the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m.,
except for official state holidays, The petition may be filed by facsimile (fax) or electronic mail by an
attached file (with restrictions) - provided the signed original, one (1) copy and a filing fee (if a filing
fee is required by NCGS § 15 013-23,2) is received in the. Office of Administrative Hearings within
seven (7) business days following:the taxed or electronic transmission. You should contact the
Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process, The mailing address and telephone and fax numbers for the Office of Administrative
Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax: [phone]
One, (1) copy of the petition must also be served on DEQ as follows:
Mr. Sam M. Hayes, General Counsel
DLL
1601 Mail Service Center
Raleigh, NC 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this notice, as
evidenced by an irate al date/time received stamp (not a postmark), will result in this matter being
referred to the Attorney General's Office for collection of the penalty through a civil action.
Please be advised that additional penalties may be assessed for violations that occur after the
review period of this assessment. If you have any questions about this civil penalty assessment please
contact staff in the Mooresville Regional Office at [phone].
(Date) 'i, -:ovz- ichael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
ATTACHMENTS
cc: Mooresville Regional Office Compliance File w/ attachments
Raleigh Compliance/Enforcement File w/ attachments
Central Files w/ attachments

ATTACHMENT A
CASE NO. LV-2015-0092
Outfall Date Parameter RM2!jed Value Permit Limit
001 5/14/14 Total zinc 1. lbs/day* 0,626 lbs/day (Daily maximura)
001 5/31/14 Total zinc 0.6681 lbs/day* 0.313 Ibs/day (Monthly average)
Denotes civil penalty assessment
The Chemical Specialties, LLC response to NOV-2015-LV-0152 received on May 22,
2015 was reviewed by DWR staff. Mitigating factors were not found that resulted in a
reduced civil penalty amount.

F_
STATE OF NORTH CAROLINA DEPARTMENT E ENVIRONMENTAL
QUALITY
COUNTY OF CAB LTA
IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN
1F CIVIL PENALTY AGAINST ADMINISTRATIVE HEARING AND
CHEMICAL SPECIALTIES, LLC STIPULATION F FACTS
PERMIT NUMBER NCO006351 l
FILE NO, LV-2015-0092
Having been assessed civil penalties totaling $493.85 for violation(s) as set forth in the
assessment document of the Division of Water Resources ees dated November 17, 4I , the undersigned,
desiring to seek remission of the civil penalties, does hereby waive the right to an administrative
hearing its the above -stated matter and does stipulate that the facts are as alleged in the assessment
document. The undersigned further understands that all evidence presented in support of remission of
this civil penalty roust e- submitted to the Director of the Division of Water Resources within 30 days
of receipt of the notice of assessment. No new evidence in support of a remission request will be
allowed after 30 days from the receipt of the: notice of assessment.
This the day of 2015
Y
ADDRESS

6
DWR Case Number: LV-2015-0092
Assessed Party.- Chemical Specialties, LLB
County: Cab
Permit Number: NCO006351
Amaunt Assessed: $493.85
Please use this form Nvhen requesting remission of this civil penalty. You must also complete the
"Request For RemissionWaiver of Right to an Administrative Hearinz and Stinulation of Facts
form to request remission of this civil penalty. You should attach any docurnents that you believe
support your request and are necessary for the Director to consider in evaluating your request for
remission. Please be aware that a request for remission is limited to consideration of the five factors
listed below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or
the accuracy of any of the factual statements contained in the civil penalty assessment document.
Pursuant to N.C.G.S. § 14313-282, 1 (e), remission of a civil penalty may be granted only when one or
more of the following five factors applies. Please check each factor that you believe applies to your
case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in MC.G.S. 14313-282.1(b) were
on fully anplied to the detriment of the petitioner (the assess"Ientfiactors are listed
in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental �darn �3,eresulting from the
violation (i.e., explain the steps that you took to correct the violation grad prevent
,future oceurrences),
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation
was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for an pLevious violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions (i.e,, explain how payment of the civil penalty will prevent youftom performing
the activities necessary to achieve compliance).
EXPLANATION: (use additional pages as necessary)

Im
NORTH CAROLINA DIVISION OF WATER RESOURCES
ASSESSMENT FACTORS
Violator: Chemical Specialties, ILLC
Facility: chemical t�eeialties# L C "w a�Tf"
County: Cab
Case Number: LV-2015-0092
Permit Number,: NCO006351
The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation; No environmental harm has been. documented.
The duration and gravity of tht violation- The zinc daily maximum permit limit was exceeded by
66.6%; and the zihr, monthly average permit limit was exceeded by 113,5% during the month of May
2014,
3) The effect on ground or surface water quantity or quality or on air quality; The effect on the
receiving stream is unknown,
4) The cost of rectifying the damage; The cost is unknown.
5) The amount of money saved by noncompliance; The amount of money saved by noncompliance
Unknown,
0) Whether the violation was committed wil!fW!y or mttnfionally�- The Division of Water Resour
has no evidence that the violations were committed wilifully or inteintionally.
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
There have been 5 previous CPAs for the Chemical Specialties, LLC WWTP with no CPAs being
issued in the past 17 years. The last CPA was issued on January 1, 1998; however, the penalty was
waived.
8) The cost tathe State of the enforcement procedures.
The cost to the Division of Water Resources is $143,85,
Date Michael L Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ

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WATER OU',V
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MO()REWLLEREGIONAL OFFICE
CHEWCAL SPECIALTIES, LLC
Po BOX 133
HARRISBURG CSC 28075
Al -TN: MR STEVE NQVAK
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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vert
Governor Secretary
September 4, 2015
CEIMFIED MAW 70 15 0640 W7 5 707 4821
Mr. Steve Novak, Vice President of Operations
Chemical Specialties, LLC
P.O. Box 1330
5910 Pharr Mill
Harrisburg, North Carolina 28075
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for'Violations of N.C. General Statute
143-215. I(a)(6) and NPDES Permit No. NCO006351
Chemical Specialties, LLC WWTP
Cab County
Case No. LV-2015-0092
Dear Mr. Novak:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$493.85 ($350.00 civil penalty + $143.85 enforcement costs) against Chemical Specialties, LLC.
This assessment is based upon the following facts: A review has been conducted of the self -
monitoring data reported for May 2014. This review has shown the subject facility to be in violation
of the discharge limitations found in PDES Permit No. NCO00635 1. The violations are summarized
in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Chemical Specialties, LLC
violated the terms, conditions, or requirements of NPDES Permit No. NCO006351 and North Carolina
General Statute (G.S.) 143-215. 1 (a)(6) in the manner and extent shown in Attachment A. A civil
penalty may be assessed in accordance with the maximums established by G.S. 143-215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the, Director
of the Division of Water Resources, I, Michael L. Parker, Regional Supervisor for the Mooresville
Region, hereby make the follmxing civil penalty assessment against Chemical Specialties, LLC:
MooreswIle Regional Mice
Lacatbrt 610 East Center Ave., Suite 301 Mooresvi%, NC 28115
Phone [phone], Fax, [phone]', Custurner SeNice, 1-87.623-674
Internet http:IIpod8t.ncdenr GRj4ebIwq
ki Equat OPpoMunlY , Affimmabye Ack"m lunpbp30'!'C' ReryrhAM9,r

$—I KOO For I of the one (1) violation of G.S. 143-215, 1 (a)(6) and
NP15f'S—Permit No. NCO00635 1, by discharging waste into the
waters of the State in violation of the permit daily at
effluent limit for total zinc.
$250.00 For I of the one (1) violation of G.S. 143-215,1(a)(6) and
NPDES Permit No. NCO006351, by discharging waste into the
waters of the State in violation of the pen -nit monthly average
effluent limit for total zinc.
$350.00 —
49185
TOTAL CIVIL PENALTY
Enforcement costs
TOTAL AMOUNT DUE
Pursuant to GS. 143-215.6A(c), in determining the amount of the penalty I have taken into account the
Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282. I (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violations;
(2) The duration and gravity, of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
is Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural
Resources (do not include waiverfiorM). Payment of the penalty Will not foreclose farther
enforcement action for any continuing or new violation(s).
Please submit payment to the attention of -
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ma
2. Submit a written request for remission including a detailed justification for such request:

Please be aware that a request for remission is limited to consideration of the tive factors listed
below as they may relate to the, reasonableness of the amount of the penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy
of any of the factual statements contained in the civil penalty assessment document. Because a
remission request forecloses the option of an administrative hearing, such request must be
accompanied by a waiver of your right to an administrative hearing and a stipulation that no factual or
legal issues are in dispute. Please prepare a detailed statement that establishes why you believe the
civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed
below. In determining whether a remission request will be approved, the following factors shall be
considered:
(I) -whether one or more of the civil penalty assessment factors in G.S. 14313-282.1(b) were
wrongfiilly applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from
the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please note that all information presented in support of your request for remission must be
submitted in writing. The Director of the Division of Water Resources will review your evidence and
inform you of his decision in the matter of your remission request. The response will provide details
regarding case status, directions for payment, and provision for further appeal of the penalty to the
Environmental Management Commission's Committee on Civil Penalty Remissions (Committee).
Please be advised that the Committee cannot consider information that was not part of the original
remission request considered by the Director. Therefore, it is very important that you prepare, a
complete and thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Waiver of Right to
an Administrative Hearing and Stipulation of Facts" form within thirty (30) days of receipt of this,
notice. The Division of Water Resources also requests that you complete and submit the enclosed
"'Justification for Remission Request," Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
go
3. File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a
petition for an administrative hearing. You may obtain the petition form from the Office of
Administrative Hearings. You must file the petition with the Office of Administrative Hearings
within thirty (30) days of receipt of this notice. A. petition is considered filed when it, is received in

the Office of Administrative Hearings during normal office hours. The Office, of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 am. and 5:00 pm.,
except for official state holidays. The petition may be filed by facsimile (fax) or electronic Tnail by an
attached file (with restrictions) - provided the signed original, one (1) copy and a filing fee (if a filing
fee is required by NCGS § 1 50B-23.2) is received in the Office of Administrative Hearings within
seven (7) business days following the faxed or electronic transmission. You should contact the
Of of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process. The mailing address and telephone and fax numbers for the Office of Administrative
Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax.- [phone]
One (1) copy of the petition must also be served on DENR as follows:
Mr. Sam M. Hayes, General Counsel
DENS
1601 Mail Service Center
Raleigh, NC 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this notice, as
evidenced by an internal date/time received stamp (not a postmark), will result in this matter being
referred to the Attorney General's Office for collection of the penalty throng di a civil action.
Please be advised that additional penalties may be assessed for violations that occur after the
review period of this assessment. If you have any questions about this civil penalty assessment Please
contact staff in the Mooresville Regional Office at [phone].
(V(ate) Mic�h<ael L Parker, Regional upervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
AT"I'ACHMENTS
cc: Mooresville Regional Office Compliance File w/ attachments
Raleigh Compliance/Enforcement File w/ attachments
Central Files w/ attachments

ATTACHMENT A
CASE NO. LV-2015-0092
Outfall Date Parameter RmqtAVale Permit Limit
001 5/14/14 Total in 1,043 lbs/day* 0.626 lbs/day (Daily maximum)
001 5/31/14 Total zinc 0.6681 lbs/day* 0.313 lbs/day (Monthly average)
Denotes civil penalty assessment
The Chemical Specialties, LLC response to NCI V-2015-LV-0152 received on May 22,
2015 was reviewed by DWR staff. Mitigating factors were not found that resulted in a
reduced civil penalty amount.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY F CABARRUS
IN TIME MATTER F ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTY AGAINST ADMINISTRATIVE HEARING AND
CHEMICAL SPECIALTIES, LLC STIPULATION F FACTS
PERMIT NUMBER NCO0063 51'
FILE NO. LV-2015-0092
Having been assessed civil penalties totaling $493.85 for violations as set forth in the
assessment document of the Division of Water Resources dated March 19 2015, the undersigned,
desiring to seep remission of the civil penalties, does hereby waive the right to an administrative
hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment
document. The undersigned further understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director oft e Division ofWater Resources within 30 dais
of receipt of the -notice of assessment. No new evidence in support of a remission request will be
allowed after 30 days from the receipt of the notice of assessment;
This the day of 2015
V
ADDRESS
TELEPHONE

DWR Case Number: LV-2015-0092
Assessed Party: Chemical Specialties, LLC
County: Cabarrus
Permit Number: NCO006351
Amount Assessed: $493.85
Please use this form when requesting remission of this civil penalty, You must also complete the
"Reanest For Remission, Waiver of Rizht to an Administrative Hearing, and,Stipulation oL facts"
form to request remission of this civil penalty. You should attach any documents that you believe
support your request and are necessary for the Director to consider in evaluating your request for
remission. Please be aware that a request for remission is limited to consideration of the five factors
listed below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or
the accuracy of any of the factual statements contained in the civil penalty assessment document.
Pursuant to N.C.G.S. § 14313-282.1(c), remission of a civil penalty may be granted only when one or
more of the following five factors applies. Please check each factor that you believe applies to your
case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1Lb) were
wrongfully applied to the detriment of the pplitiggg (the assessment factors_are listed
in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting -from the
violation (i.e., explain the steps that you took to correct the violation card prevent
future occurrences);
(e) the violation was inadvertent or a result of an accident (i.e., explain why the violation
was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil nenaltics for anv orevious violations;
(e) payment..of the civil ve
actions (i. e., explain how payment of the civil penalty will prevent you ftom performing
the activities necessary to achieve compliance).
EXPLANATION: (use additional pages as necessary)

CFILE
NE ;R
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
September 4, 2015
i I 1 11 111i
Mr. Steve Novak, Vice President of Operations
Chemical Specialties, LLC
P.O. Box 1330
5910 Pharr Mill
Harrisburg, North Carolina 28075
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N C . General Statute
143-215. l(a)(6) and NPDES Permit No. NCO006351
Chemical Specialties, LLB WWTP
Cab County
Case No. LV-2015 -0092
Dear Mr. Novak:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
S493.85 ($350.00 civil penalty + $143.85 enforcement costs) against Chemical. Specialties, LLC.
This assessment is based upon the following facts: A review has been conducted of the self -
monitoring data reported for May 2014. This review has shown the subject facility to be in violation
of the discharge limitations found in NPDES Permit No. NCO00635I. The violations are summarized
in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Chemical Specialties, LLC
violated the terms, conditions, or requirements of NPDES Permit No. NCO006351 and North Carolina
General Statute (G. S.) 143 -215. 1 (a)(6) in the manner and extent shown in Attachment A. A civil
penalty may be assessed in,accord ance with the maximums established by G.S. 143-215,6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the Director
of the Division of Water Resources, 1, Michael L. Parker, Regional Supervisor for the Mooresville
Region, hereby make the following civil penalty assessment against Chemical Specialties, LLC:
Mooresvib Regional Office
Locat1cm: 610 East Center Ave, Sulle 301 Mooresville, NC 28115
Phan 704)663-16991 Fax., [phone], Customer Servjc1-877-623-,6748
Internet http:/,(portal.nrde�ir,org/webAvq
An Equm, Oppertunlily'x Mirmalivo Ador Emptorf - 30% Recycledf10% Post Ounqualer paper

100.00 For I of the one (1) violation of G.S. 143-215.1(a) ) and �r' �J
NPDES Permit No. NCO0063 5 1, by discharging waste into the
waters of the State in violation of the permit daily maximum
effluent limit for total zinc.
250,00 For I of the one (1) violation of G. S. 143-215 . I (a)(6) and
NPDES Permit No. NCO0063 5 1, by discharging waste into the
waters of the State in violation of the permit monthly average
effluent limit for total zinc.
350.00
493.85
TOTAL CIVIL PENALTY
Enforcement costs
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty, I have taken into account the
Findings of Fact, and Conclusions of Law and the factors set forth at G.S. 14313-282. l(b), which are:
(1) The degree and extent of harni to the natural resources of the State, to the public health, or to
private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(Khether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment oft a penalty:
Payment should be made directly to the order of the Department of Environment and Natural
Resources (do not include waiverform). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s).
Please submit payment to the attention of
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Um
2. Submit a written request for remission including a detailed justification for such request:

I
Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy
of any of the factual statements contained in the civil penalty assessment document. Because a
remission request forecloses the option of an administrative hearing, such a request must be
accompanied by a waiver of your right to an administrative hearing and a stipulation that no factual or
legal issues are in dispute. Please prepare a detailed statement that establishes why you believe the
civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed
below. In determining whether a remission request will be approved, the following factors shall be
considered:
(1) whether one or more of the civil penalty assessment factors in G.S. 143B-282. I (b) were
wrongfully applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from
the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
t5) whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please note that all information presented in support of your request for remission must be
submitted in writing. The Director of the Division of Water Resources will review your evidence and
inform you of his decision in the matter of your remission request. The response will provide details
regarding case status, directions for payment, and provision for further appeal of the penalty to the
Environmental Management Commission's Committee on Civil Penalty Remissions (Committee),
Please be advised that the Committee cannot consider information that was not part of the original
remission request considered by the Director. Therefore, it is very important that you prepare a
complete and thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Waiver of Right to
an Administrative Hearing and Stipulation of (acts" form within thirty (30) days of receipt of this.
notice, The Division of Water Resources also requests that you complete and submit the enclosed
"Justification for Remission Request," Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a
petition for an administrative hearing. You may obtain the petition form from the Office of
Administrative Hearings, You must file the petition with the Office of Administrative Hearings
within thirty (30) days of receipt of this notice. A petition is considered filed when it is received in

IL
the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m.,
except for official state holidays. The petition may be filed by facsimile (fax) or electronic mail by an
attached file (with restrictions) - provided the signed original, one (1) copy and a filing fee if a filing
fee is required by NCGS §150B-23.2) is received in the Office of Administrative Hearings within
seven (7) business days following the faxed or electronic transmission. You should contact the
Office of Administrative Hearings with, all questions regarding the filing fee and/or the details of the
filing process. The mailing address and telephone and fax numbers, for the Cuff lee of Administrative
Hearings are as follows -
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC, 27699-6714
TO: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DENR as follows-,
Mr. Sam M. Hayes, General Counsel
DENR
1,601 Mail Service Center
Raleigh, NC 27699-1,601
Please indicate the case number (as found on page one of this letter), on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this notice, as
evidenced by an internal date/time received stamp (not a pas ark,), vvil I result in this matter being
referred to the Attorney General's Office for collection of the penalty through a civil action.
Please be advised that additional penalties may be assessed for violations that occur after the
review period of this assessment. If you have any questions about this civil penalty assessment please
contact staff in the Mooresville Regional Office at [phone]
(piatej./ Michael L. Piarker, Regional upervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
ATTACHMENTS
cc: Mooresville Regional Office Compliance File wattachments
Raleigh Compliance/Enforcement File w/ attachments
Central Files w/ attachments

ATTACHMIENT A
CASE NO. LV-201,5-0092
Outfall Date Parameter Renorted Value Permit Limit
001 5/14/14 Total zinc 1.043,lbs/day* 0.626 lbs/day (Daily maximum)
001 5/31/14 Total zinc 0.6681 lbs/day* 0.313 lbs/day (Monthly average)
Denotes civil penalty assessment
The Chemical Specialties, LLC response to NOV-2015-LV-0152 received on May 22,
2015 was reviewed by DWR staff. Mitigating factors Nvere not found that resulted in a
reduced civil penalty amount.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF CABARRUS
IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTY AGAINST ADMINISTRATIVE HEARING AND
CHEMICAL SPECIALTIES, LLC STIPULATION OF FACTS
PERMIT NUMBER NCO0063 51
FILE NO. LV-2015-0092
Having been assessed civil penalties totaling $493,85 for violation(s) as set forth in the
assessment document of the Division of Water Resources dated March, 19,.,2,0-15 , the e undersigned,
=
desiring to seek remission of the civil penalties, does hereby waive the right to an administrative
hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment
document. The undersigned further understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director of the Division of Water Resources within 30 days
of receipt of the notice of assessment, No new evidence in support of a remission request will be
allowed after 30 days from the receipt of the notice of assessment.
This the day of 2015
BY
ADDRESS
TELEPHONE

JUSTWICATION FOR REMNSt(* gl-QUST
DWR Case Number: LV-2015-0092
Assessed Party: Chemical Specialties, LLC
County: Cabarrus
Permit Number: NCO006351
Amount Assessed: $493.85
Please use this form when requesting remission of this civil penalty. You must also complete the
f, train istrative Hearing and Stipulation of Facts"
form to request remission of this civil penalty. You should attach any documents that you believe
support your request and are necessary for the Director to consider in evaluating your request for
remission. Please be aware that a request for remission is limited to consideration of the five factors
listed below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission, is not the proper procedure for contesting whether the violation(s) occurred or
the accuracy of any of the factual statements contained in the civil penalty assessment document.
Pursuant to N C.G. S. § 143 B-282. I (c), 'remission of a civil penalty maybe granted only when one or
more of the following five factors applies. Please check each factor that you believe applies to your
case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were
Ton full aDDlied to the detriment of the petitioner (the assessment factors are listed
in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental dama e resultin from the
violation (i.e., explain the steps that you took to correct the violation and prevent
.future occurrences),,
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation
was unavoidable or somethingyou could not prevent or, reparefor),-
the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil ,pmalt y will pe vent payment for the remaining.necessary=remedial
actions (i.e., explain how payment Qf the civil penalty will pre -vent youftom performing
the activities necessary to achieve compliance),
EXPLANATION: (use additional pages as necessary)

NORTH CAROLINA DIVISION OF WATER
ASSESSMENT FACTORS
Violator:
Facility:
County:
Case Number: LV-2015-0092
Permit Number: NCO006351
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation; No envirom-nental harm has been documented.
2) The duration and gravity of the violation; The zinc daily maximum permit limit was exceeded by
66.6% and the zinc monthly average permit limit was exceeded by 113.5% during the month of May
2014.
3) The effect on ground or surface water quantity or quality or on air quality; The effect on the
receiving stream is unknown.
4) The cost of rectifying the damage; The cost is unknown.
5 1 ) The amount of one saved by noncompliance; The amount of money saved by noncompliance is
unknown.
6) Whether the violation was committed willfully or intentionally, The Division of Water Resources
has no evidence that the violations were committed willfully or intentionally.
8) The cost to the State of the enforcement procedures.
The cost to the Division of Water Resources is $143,85.
at Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR