NC0084344_Complete File - Historical_20171231

Michael F. Easley, Governor
William G, Ross Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
January` 6, 2003
Mr. Julio Meraz, Director of Engineering
R. P. Scherer North America
2725 Scherer Drive
St. Petersburg, FL 33716-1016
Subject: Rescission of NPDES Permit
Permit Number NC0084344
R. P. Scherer — Chelsea Labo
Union County
Dear Mr. Meraz:
NC DEPTT, OF EMIR+w
NATURAL REST
Skr+L�-"""'ONAL
atones Facility
Reference is made to your request for rescission of the subject NPDES permit. Staff of the
Mooresville Regional Office have confirmed that this permit is no longer required. Therefore,
in accordance with your request, NPDES permit NC0084344 is rescinded, effective
immediately.
If in the future you wish to discharge wastewater to the States 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 you have questions about this matter, please contact. Bob Sledge at [phone],
extension 547 or the Water Quality staff in our Mooresville Regional Office at [phone].
cc: Mooresville Regional Office
NPDES Unit
Point Source Compliance — Bob Sledge - w/attachments
Central Files - w/attachments
Fran McPherson, DWQ Budget Office
Customer Service
1 800 623-7748
Division of'Water Quality 1617 Mail Serv"rco Center Raleigh, NC 27699-1617
[phone] Fax: [phone]

JAMES B. HUNT JR,
GOVERNOR
BILL HOLMAN
-SEC RE T ART
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
December 4, 2000
Mr, r ictor L, SanAuustin
R.P. Scherer
725 Scherer Drive
St Peteislur_ Florida 33716
Subject: NPDES Permit No. NC0084344
Chelsea Laboratories Site
Union County, NC
Dear SanAgustin:
Our records indicate that NPDES Permit No. NC0084344 was issued on November
20, 2000 for the discharge of wastewater to the surface waters of the State from your
facility. The purpose of this letter is to advise you of the importance of the Permit and the
liabilities in the event of failure to comply with the terms and conditions of the Permit. If
you have not already done so, it is suggested that you thoroughly read the Permit. Of
particular importance are Pages 4 and 5-
Pages 4 and 5 set forth the effluent limitations and monitoring requirements for your
discharge. Your discharge must not exceed any of the limitations set forth. The section
headed ''Monitoring Requirements" describes the measurement frequencies, sample types
and sampling locations, Upon commencement of your discharge (or operation), you must
initiate the required monitoring. The monitoring results must be entered on reporting forms
furnished or approved by this Agency. If you have not received these forms, they should
be aiTiving. shortly. If you fail to receive the forms, please contact this Office as quickly as
possible. I have enclosed a sample of the "Effluent" reporting form (DEM Form MR-1),
plus instructions for completing the form. It is imperative that all applicable parts be
completed, and the original and one copy be submitted as required.
Please be advised that an annual administering and compliance monitoring fee may
be required for your facility. You will soon be receiving a statement from our Raleigh,
Office. It is imperative that the fee be paid in a timely manner so as to prevent enforcement
action or possible revocation of your permit.
The remaining parts of the Permit set forth definitions, general conditions and special
conditions applicable to the operation of wastewater treatment facilities and/or discharge(s).
The conditions include special reporting requirements in the event of noncompliance,
bypasses,. treatment unit/process failures, etc. Also addressed are requirements for a
certified wastewater treatment plant operator if you are operating wastewate
0 I 0
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 28115
PHONE 704-6E3-1699 FAX [phone]°'
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER 50% RECYCLED/1O% POST -CONSUMER PA!#

Mr, Victor SanAgustin
December 4, 2000
l'a=e No.
facilities. Any changes in operation of wastewater treatment facilities, quantity and type of
wastewater being treated or discharged, expansions and/or upgrading of wastewater
treatment facilities must be permitted or approved by this Agency
Failure: to comply with the terms and conditions of an NPDES Permit subjects the
tee to enforcement action pursuant to Section 143-215.6 of the North Carolina
ral Statutes. A civil penalty of up to $25,000 per violation (and/or criminal penalties)
may be assessed for such violations. If you find at any time that you are unable to comply
with the terms and conditions of the Permit, you should contact this Office immediately. A.
Special Order by Consent (SOC) may be necessary while pursuing, action to obtain
compliance..
As a final note, an NPDES Permit is normally issued fora five-year period. Permits
are Wert automatically renewed. Renewal requests must be submitted. to this Agency no later
than 180 days prior to expiration. Please make note of the expiration date of your Permit.
This date is set forth on Page 1 of the Permit. Also note that NPDES Permits are not
automatically transferable. If you, as the Permittee, cease to need this Permit, then you
should request that the Division of Water Quality rescind the Permit or request that DWQ
reissue the Permit to another party, if necessary.
As mentioned previously, the purpose of this letter is to advise you of the importance
r NPDES Permit, Please read the Permit. and contact. this Office. at 704/663-1699 in
ville if you have any questions or need clarification. We look forward to providing.
assistance.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
A.cfnir,sNPD.r,TRDRG:dee

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
Mr. Victor L. SanAgustin
R.P. Scherer
2725 Scherer Drive
St. Petersburg', Florida 3371.6
Dear Mr. SanAgustin:
gr,,„ *lkolVbel ENT, TIERUci
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Oft
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
November 20, 2000
Subject:Issuance of NPDES Permit NC0084344
Chelsea Laboratories Site
Union County
Division personnel have reviewed and approved your application for renewal of the subject. permit.
Accordingly, we are forwarding the attached NPDES discharge perrnit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between
North Carolina and the U.S. Environmental Protection Agency dated May 9, '1994 or as subsequently
amended).
After a review of the draft permit, the .following changes have been made:
• As per the requestof the Aquatic Toxicology Unit, the sampling months for your toxicity test
(Part A. (2.)) will now he February, May, August and November. This allows you to -adhere to
the sampling schedule of the previous NPDES permit.
• After speaking with staff from the Division of Water Quality (Division) Chemistry lab, it has
been determined that EPA Method 6210D will be an acceptable substitute for EPA Method 624.
The monitoring requirement has been accordingly changed on the effluent limits page.
Additionally, EPA Method 625 has been eliminated as a monitoring requirement as per October
1999 correspondence with the Groundwater Section of the Mooresville Regional Office.
• Monitoring frequency for lead has been. reduced to quarterly due to a finding, of .no reasonable
potential. The draft permit listed this .frequency as monthly, but since your facility has not
detected lead within the last permitting cycle, the frequency will he reduced. As per
correspondence from George Maalouf of. Rogers and Callcott Engineers, Inc. dated March 6, 1996,
it was agreed that while lead was limited in the 1996 permit, the permittee would agree to a.
monitoring requirement in the case of a finding of no reasonable potential. Addition -ally, the
facility's recent problems with toxicity indicate that quarterly metals sampling are in order.
• The limits for arsenic have been removed as per your request. You will still he required to
monitor on a monthly basis for arsenic due to the recent (11/99) detect of arsenic in the system..
Once the facility collects 8 to 12 data points indicating non -detection of arsenic, you may submit a
request to have the monitoring frequency reduced to quarterly.
• The pH limit placed in the draft permit has been changed to a monitoring requirement.
Correspondence from the last permit cycle indicates that such a change would be acceptable to the
Your request to change the toxicity test is in conflict with Division policy on whole effluent toxicity.
The nature of your discharge is continuous and as such requires a chronic toxicity test. Sampling of mercury,
PCE,, and TCE will remain at twice monthly as per the draft permit. This monitoring frequency is Division.
policy for limited parameters in Class I and II facilities. I have included a Division policy memo explaining
assignment of monitoring frequencies.
1617 Mai Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer VISIT us ON THE INTERNET @ http:/th2o,enr,state.ne us/NPDES

In addition, the limit for trichloroethene will remain at 81µg/L. Data from June and July 1999
suggest that effluent from your facilityhas serious potential to contaminate the receiving stream with
trichloroethene. I have included with this permit a copy of the EPA National Recommended Water Quality
Criteria per you request in the hope that this will clarify any remaining issues.
Your general permit comrrlerta
is standard on ever;)" permit issued in
subject permit,
regarding the definition of upsets is part of our permit boilerplate and
he state of North Carolina. As such, it cannot be changed for the
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (5( )
days following receipt of this letter. This request must be in the form of a written petition, conformin to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings
(6714 Mail Service Center, Raleigh, North Carolina 27699-671.4). Unless such demand is made, this decision
shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit, This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local
governmental permit that may be required.
If you have any questions concerning this permit,. please contact Natalie Sierra at telephone number
[phone], extension 551.
ntral Files
NPDES Unit
Point Source Contplian+
Aquatic Toxicology Uri
George Maalouf, P.E.
Enforcement Un
Rogers and. Callcott Engin
P.C. Box 5655
Greenville, SC 29606
Sincerely,
Original Signed By
David A. Goodrich
Kerr T. Stevens
ers, Inc.

Permit NC0084344
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina. Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
R. P. Scherer Corporation
is hereby authorized to discharge wastewater from a facility located at the
R. P. Scherer/Chelsea Laboratories Facili
2021 East Roosevelt Boulevard
off US Highway 74
City of Monroe
Union County
y
to receiving waters designated as an unnamed tributary to Rays Fork an the Yadkin -
Pee Dee River Basin
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective January 1, 2001.
This permit and authorization to discharge shall expire at midnight on January 31, 2004.
Signed this day November 20, 2000.
Oniginai Signed By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NCO0 4 44
SUPPLEMENT TO ' I' COVER
R. P. Scherer Corporation i hereby authorized to:
1. Continue to operate an existing groundwater rernediation system consisting of`
four recovery wells, a 50 gpmair stripper, a 1,400 gallon gravity settling
chamber, a pump station with duplex pumps, and an infiltration gallery for
disposal of the treated effluent. This facility will have the option to either divert
the flow to the infiltration gallery or to discharge from outfall 001 to the
unnamed tributary to Rays Fork.
The facility is located at the R. P. Scherer 'Chelsea Laboratories Facility at 2021
East Roosevelt Boulevard off US Highway '74 in the City of Monroe, Union
County.
2. Discharge from said treatment works at the location specified on the attached
map into the unnamed tributary to Rays Fork which is classified C- waters in the
Yadkin - Pee Dee River Basin.

Discharge Point
) '
Scherer - Chelsea Labs
Latitude:
Lone itu.de:
Quad #:
Stream Class:
Receiving Stream:
Permitted Flow:
34°58 5°-
80°29' 29"
H 17NW
UT co Rays Fork
Not specified
Sub -Basin:
03-07,14
R.P. Scherer.
NCOOS4344
Chelsea Latioratories Site

Permit NC0084344
A. (1.) EFFLUENT LIMITATIONS AND MONIT©RING REQUIREMENTS — FINAL
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Perrnittee as
specified below:
EFFLUENT
CHARACTERISTICS
ITS
©NITORING REQUIREMENTS
Flow
Arsenic
Chlorofor
d
ercury
Tetrachloroethene
Toluene
Trichloroethene
eekly Daily Measurement Sample Type Sample Location
Avera Maximum Frequency
Continuous
h
y
Recording
Grab
Effluent
Effluent
hl Grab E
0,C1121agt
8.85 µg1L 2/Month Grab Effluen
Monthly Grab Effluent
81lig!L 2/Month Grab Effluent
EPA Method 6210D
Chronic Toxic'iity2
pH
Quarterly
Grab
Quarterly Grab
onth
Effluent
Effluent
Grab Effluent
Footnotes:
I . This facility has been approved as a non -discharge facility' with the option of an emergency discharge shs uid
the infiltration gallery fail to handle the load of the treated groundwater. If an actual discharge does not
occur during a month, then report such on the monthly monitoring reports. Sampling. only needs to be
completed at the time of a discharge.
Chronic Toxicity (Ceriodaphriia) Quarterly, 'Pass/Fail„ 90%; See A.(2.).
There shall be no discharge of floating solids orisible foam in other than trace amounts.
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubici at an effluent concentration of 90CDin.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined
in the "North Carolina Ceriodaphrtia. Chronic Effluent Bioassay Procedure," Revised February 1998,
or subsequent versions or "North Carolina. Phase 11 Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months
of February, May, August and November. Effluent sampling for this testing shall be performed at
the NPDES permitted final effluent discharge below all treatment processes,
88
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum,
in each of the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the Iowest.
concentration that does have a detectable impairment of reproduction or survival. The definition of

Permit NC0084344
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase Il Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value, Additionally,
DWQ Form AT-3 (original) is to be sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no
later than, 30 days after the end of the reporting period for which the report is made,.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and
all concentration/response data, and be certified by laboratory super -visor and ORC or approved
designate signature. Total residual chlorine of the effluent toxicity sample must be measured and.
reported if chlorine is employed for disinfection of the waste stream,
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required, the permittee will complete the information located at the top of the
aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number,
county, and the month/year of the report with the notation of "No Flow" in the comment area
of the form. The report shall be submitted to the Environmental Sciences Branch at the
address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required.,
monitoring will be requi.redduring the following month.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate environmental
controls, shall constitute an invalid test and will require immediate follow-up testing to be completed
no later than the last day of the month following the month of the initial monitoring.

at all
at a ptt afficiancy.
rtotinde the
bability
Effluent Linoo ve date
provide the operation and n ce
tea
ale of
actions
the la
and e

Pan II
Pagel of 14
PART II
ANDARD CONDITIONS FOR NPDES PERT IIT
CTIQN A. DEFINITIONS
Permit Issuing Authority
The Director of the Division of Water Quality.
DEM or "the Division"`,
Means the Division of Water Quality, Department of Environ
n
ealth and Natural Resources.
Used herein means the North Carolina Environmental Management Commission.
4. Act or "the Act"
The 'Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC
1251, et. seq..
Mass/Day Measurements
a. The "monthly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during a calendar month on which daily discharges are sampled and
measured, divided by the number of daily discharges sampled and/or measured during such
month. It is therefore, an arithmetic mean found by adding the weights of the pollutant found
each day of the month and then dividing this sum by the number of days the tests were
reported. The limitation is identified as "Monthly Average" in Part I of the permit.
b. The "weekly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar week (Sunday Saturday) on which daily discharges are
sampled and measured, divided by the number of daily discharges sampled and/or measured
during such week. It is, therefore, an arithmetic mean found by adding the weights of
pollutants found each day of the week and then dividing this sum by the number of days the
tests were reported. This limitation is identified as "Weekly Average" in Part 1 of the permit.
c. The "`maximum daily discharge" is the total mass (weight) of a pollutant discharged during a
calendar day. If only one sample is taken during any calendar day the weight of pollutant
calculated from it is the "'maximum daily discharge." This limitation is identified as ""Daily
Maximum,`" in Part 1 of the permit.
d. The "average annual discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar year on which daily discharges are sampled and
measured, divided by the number of daily discharges sampled and/or measured during such
year. It is, therefore, an arithmetic mean found by adding the weights of pollutants found each
day of the year and then dividing this sum by the number of days the tests were reported. This
limitation is defined as "Annual Average" in Part I of the permit.

Part II
Page 2 of 14
6. Concentration Measurement
a . The "'average monthly concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar month on
which daily discharges are sampled and measured, divided, by the number of daily discharges
sampled and/or measured during such month (arithmetic mean of the daily concentration
values). The daily concentration value is equal to the concentration of a composite sample or in
the case of grab samples is the arithmetic mean (weighted by flow value) of all the samples
collected during that calendar day. The average monthly count for fecal coliform bacteria is
the geometric mean of the counts for samples collected during a calendar month. This
limitation is identified as "Monthly Average" under "Other Limits" in Part 1 of the permit.
b. The "average weekly concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar week
(Sunday/Saturday) on which daily discharges are sampled and measured divided by the
number of daily discharges sampled and/or measured during such week (arithmetic mean of the
daily concentration values). The daily concentration value is equal to the concentration of a
composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. The average weekly count for
fecal coliform bacteria is the geometric mean of the counts for samples collected during a
calendar week. This limitation is identified as "Weekly Average" under "Other Limits" in
Part 1 of the permit.
c. The "maximum daily concentration"' is the concentration of a pollutant discharge during a
calendar day. If only one sample is taken during any calendar day the concentration of
pollutant calculated from it is the "Maximum Daily Concentration". It is identified as "Daily
Maximum" under "Other Limits" in Part I of the perrnit.
d. The "average annual concentration," other than for fecal colifortn bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar year on
which daily discharges are sampled and measured divided by the number of daily discharges
sampled and /or measured during such year (arithmetic mean of the daily concentration
values). The daily concentration value is equal to the concentration of a composite sample or in
the case of grab samples is the arithmetic mean (weighted by flow value) of all the samples
collected during that calendar day . The average yearly count for fecal coliform bacteria is the
geometric mean of the counts for samples collected during a calendar year. This limitation is
identified as "'Annual Average" under "Other Limits" in Part I of the permit.
e. The "daily average concentration" (for dissolved oxygen) is the minimum allowable amount of
dissolved oxygen required to be available in the effluent prior to discharge averaged over a
calendar day. If only one dissolved oxygen sample is taken over a calendar day, the sample is
considered to be the "daily average concentration" for the discharge. It is identified as "daily
average" in the text of Part I.
The "quarterly average concentration" is the average of all samples taken over a calendar
quarter. It is identified as "Quarterly Average Limitation" in the text of Part 1 of the permit.
A calendar quarter is defined as one of the following distinct periods: January through March,
April through June, July through September, and October through December.
g.

Part II
Page 3 of 14
7. Other Measurements
a. Flow, (MGD): The flow limit expressed in this permit is the 24 hours average flow, averaged
monthly. It is determined as the arithmetic mean of the total daily flows recorded during the
calendar month.
b. An "instantaneous flow measurement" is a measure of flow taken at the time of sampling, when
both the sample and flow will be representative of the total discharge.
c. A "continuous flow measurement" is a measure of discharge flow from the facility which occurs
continually without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for
infrequent maintenance activities on the flow device.
8. Types of Samples
a. Composite Sample: A composite sample shall consist of;
(1) a series of grab samples collected at equal time intervals over a 24 hour period of discharge
and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(2) a series of grab samples of equal volume collected over a 24 hour period with the time
intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow
recorder and totalizer, and the present gallon interval between sample collection fixed at
no greater than 1/24 of the expected total daily flow at the treatment system, or
(3) a single, continuous sample collected over a 24 hour period proportional to the rate of flow.
In accordance with (1) above, the time interval between influent grab samples shall be no
greater than once per hour, and the time interval between effluent grab samples shall be no
greater than once per hour except at wastewater treatment systems having a detention time of
greater than 24 hours. In such cases, effluent grab samples may be collected at time intervals
evenly spaced over the 24 hour period which are equal in number of hours to the detention time
of the system in number of days. However, in no case may the time interval between effluent
grab samples be greater than six (6) hours nor the number of samples less than four (4) during a
24 hour sampling period.
b. Grab Sample: Grab sampies are individual samples collected over a period of time not
exceeding 15 minutes; the grab sample can be taken manually. Grab samples must be
representative of the discharge or the receiving waters.
9. Calculation of Means
a Arithmetic Mean: The arithmetic mean of any set of values is the summation of the individual
values divided by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of the product of the
individual values where N is equal to the number of individual values. The geometric mean is
equivalent to the antilog of the arithmetic mean of the logarithms of the individual values.
For purposes of calculating the geometric mean, values of zero (0) shall be considered to be one
(1).
c. Weighted by Flow Value: Weighted by flow value means the summation of each concentration
times its respective flow divided by the summation of the respective flows.

Part II
Page 4 of 14
10. Calendar Day
A calendar day is defined as the period from midnight of one day until midnight or the next day.
However, for purposes of this perrnit, any consecutive 24-hour period that reasonably represents
the calendar day may be used for sampling.
11. Hazardous SLubstpce
A hazardous substance means any substance designated under 40 CFR Part 116 pursuant to Section
311 of the Clean Water Act.
12. Toxic Pollutant
A toxic pollutant is any pollutant listed as toxic under Section 307(a)(I) of the Clean Water Act.
SECT1QN cENERAL CQNDMONS
1. Duty to Comply
The perrnittee must comply with all conditions of this permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a perrnit renewal application.
a. The permittee shall comply with effluent standards or prohibitions established under section
307(a) of the Clean Water Act for toxic pollutants and with standards for sewage sludge use or
disposal established under sect -ion 405(d) of the Clean Water Act within the time provided in
the regulations that establish these standards or prohibitions or standards for sewage sludge
use or disposal, even if the permit has not yet been modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition is subject to a
civil penalty not to exceed $25,000 per day for each violation. Any person who negligently
violates any perrnit condition is subject to criminal penalties of $2,500 to $25,000 per day of
violation, or in for not more than 1 year, or both. Any person who knowingly
violates permit conditions is subject to criminal penalties of $5,000 to $50,000 per day of
violation, or imprisonment for not more than 3 years, or both. Also, any person who violates a
permit condition may be assessed an administrative penalty not to exceed $10,000 per violation
with the maximum amount not to exceed $125,000. [Ref: Section 309 of the Federal Act 33
U.S.C. 1319 and 40 CFR 122.41 (a)]
c. Under state law, a civil penalty of not more than ten thousand dollars ($10,000) per violation
may be assessed against any person who violates or fails to act in accordance with the terms,
conditions, or requirements of a permit, [Ref: North Carolina General Statutes § 143-215.6A]
d. Any person may be assessed an administrative penalty by the Administrator for violating
section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or limitation
implementing any of such sections in a permit issued under section 402 of the Act.
Administrative penalties for Class 1 violations are not to exceed $10,000 per violation, with
the maximum amount of any Class 1 penalty assessed not to exceed $25,000. Penalties for Class
II violations are not to exceed $10,000 per day for each day during which the violation
continues, with the maximum amount of any Class 11 penalty not to exceed $125,000,

Part l:
Page
0
4
2. l utv to 1 litiaate
The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or
disposal in violation of this permit which has a reasonable likelihood of adversely affecting
human health or the environment.
Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, C-4) and "Power Failures" (Part 11,
C-7), nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of
the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages,
such as fish kills, even though the responsibility for effective compliance may be temporarily
suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may
be subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321.
Furthermore, the permittee is responsible for consequential damages, such as fish kills, even
though the responsibility for effective compliance may be temporarily suspended.
5. Property. Rights
The issuance of this permit does not convey any property rights in either real or personal property,
or any exclusive privileges, .nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State or local laws or regulations.
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
7. Severability
The provisions of this permit are severable, and if any provision of this permit, or the application
of any provision of this permit to any circumstances, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit, shall not be affected thereby.
8. Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to determine whether cause exists for
modifying, revoking andreissuing, or terminating this permit or to determine compliance with this
permit. The permittee shall also furnish to the Permit Issuing Authority upon request, copies of
records required to be kept by this permit.
9. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit.

Pan 11
Page 6 of 14
10.expiration of Permit
The permittee is riot authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date, the permittee shall submit such
information, forms, and fees as are required by the agency authorized to issue permits no later than
180 days prior to the expiration date. Any permittee that has not requested renewal at least 180
days prior to expiration, or any permittee that does not have a permit after the expiration and has
not requested renewal at least 180 days prior to expiration, will subject the permittee to enforcement
procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed
and certified.
a. All permit applications shall be signed as folio
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a
responsible corporate officer means: (a) a president, secretary, treasurer or vice president
of the corporation in charge of a principal business function, or any other person who
performs similar policy or decision making functions for the corporation, or (b) the manager
of one or more manufacturing production or operating facilities employing more than 250
persons or having gross annual sales or expenditures exceeding 25 million (in second quarter
1980 dollars), if authority to sign documents has been assigned or delegated to the manager
in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official.
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described above or by a duly authorized representative of
that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for environmental
matters for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit issuing Authority,
c. Certification. Any person signing a document under paragraphs a, or b. of this section shall
make the following certification:
1 certify, under penalty of law, that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering
the information, the information submitted is, to the best of my knowledge arid belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations."

Part I1
Page 7 of 14
12. Permmt Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request
by the permittee for a permit modification, revocation and reissuance, or termination, or a
notification of planned changes or anticipated noncompliance does not stay any permit condition.
13. Permit Modification. Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and
modifying the permit, revoking andreissuing the permit, or terminating the permit as allowed by
the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122 and
123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North
Carolina General Statute 143-215.1 et. al.
14. Previous Permits
All previous National Pollutant Discharge Elimination System Permits issued to this facility,
whether for operation or discharge, are hereby revoked by issuance of this permit. 'The exclusive
authority to operate this facility arises under this permit. The authority to operate the facility
under previously issued permits bearing this number is no longer effective. 1 The conditions,
requirements, terms, and provisions of this permit authorizing discharge under the National
Pollutant Discharge Elimination System govern discharges from this facility.
SECTION C. OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Certified Operator
Pursuant to Chapter 90A-44 of North. Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
treatment plant operator in responsible charge (ORC) of the wastewater treatment facilities. Such
operator must hold a certification of the grade equivalent to or greater than the classification
assigned to the wastewater treatment facilities by the Certification Commission. The permittee
must also ernploy a certified back-up operator of the appropriate type and any grade to comply
with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility must visit each Class I
facility at least weekly and each Class 1I, I11, and IV facility at least daily, excluding weekends
and holidays, and must properly manage and document daily operation and maintenance of the
facility and rnust comply with all other conditions of Title 15A, Chapter 8A .0202. Once the
facility is classified, the permittee shall submit a letter to the Certification Commission which
designates the operator in responsible charge within thirty days after the wastewater treatment
facilities are 50% complete.
2. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the permittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also
includes adequate laboratory controls and appropriate quality assurance procedures. This provision
requires the operation of back-up or auxiliary facilities or similar systems which are installed by a
permittee only when the operation is necessary to achieve compliance with the conditions of the
permit.

Part II
Page 8 of 14
3. Need to Halt or Reduce not afense
It shall not be a defense for a perrnittee in an enforcement action that it would have been necessary
to halt or reduce the permitted activity in order to maintain compliance with the condition of this
permit.
4. Bypassing QfTreatmerL.Faci1ities
a. Definitions
(1) "Bypass" means the.known diversion of waste streams from any portion of a treatment
facility including the collection system, which is not a designed or established or operating
mode for the facility.
(2) "Severe property damage" means substantial physical damage to property, damage to the
treatment facilities which causes them to become inoperable, or substantial and permanent
loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage does not mean economic loss caused by delays in
production.
b. Bypass not exceeding limitations.
The permittee may allow any bypass to occur which does not cause effluent limitations to lac
exceeded, but only if it also is for essential maintenance to assure efficient operation. These
bypasses are not subject to the provisions of Paragraphs c. and d. of this section.
c. Notice
(1) Anticipated bypass. if the permittee knows in advance of the need for a bypass, it shall
submit prior notice, if possible at least ten days before the date of the bypass; including an
evaluation of the anticipated quality and affect of the bypass.
(2) Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as
required in Part II, E. 6. of this permit. (24 hour notice).
d. Prohibition of Bypass
) Bypass is prohibited and the Permit Issuing Authority may take enforcement action against
a permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property
damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment
facilities, retention of untreated wastes or maintenance during normal periods of
equipment downtime. This condition is not satisfied if adequate backup equipment should
have been installed in the exercise of reasonable engineering judgment to prevent a bypass
which occurred during normal periods of equipment downtime or preventive maintenance;
and
(C) The permittee submitted notices as required under Paragraph c. of this section.
(2) The Permit Issuing Authority may approve an anticipated bypass, after considering its
adverse affects, if the Permit Issuing Authority determines that it will meet the three
conditions listed above in Paragraph d. (1) of this section.

Part II
Page 9 of 14
5. Upsets
a. Definition.
"Upset " means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors beyond the
reasonable control of the permittee. An upset does not include noncompliance to the extent
caused by operational error, improperly designed treatment facilities, inadequate treatment
facilities, lack of preventive maintenance, or careless or improper operation.
b. Effect of an upset.
An upset constitutes an affirmative defense to an action brought for noncompliance with such
technology based permit effluent limitations if the requirements of paragraph c. of this
condition are met. No determination made during administrative review of claims that
noncompliance was caused by upset, and before an action for noncompliance, is final
administrative action subject to judicial review.
c. Conditions necessary for a demonstration of upset,
A permittee who wishes to establish the affirmative defense of upset shall demonstrate,
through properly signed, contemporaneous operating logs, or other relevant evidence that
(1) An upset occurred and that the perrnittee can identify the cause(s) of the upset;
(2) The perrnittee facility was at the time being properly operated; and
(3) The perrnittee submitted notice of the upset as required in Part II, E. 6. (b) (8) of this permit.
(4) The permittee complied with any remedial measures required under Part 11, B. 2. of this
permit.
d. Burden of proof.
In any enforcement proceeding the permittee seeking to establish the occurrence of an upset has
the burden of proof.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of
wastewaters shall be utilized/disposed of in accordance with NCGS143-215.1 and in a manner such
as to prevent any pollutant from such materials from entering waters of the State or navigable
waters of the United States. The perrnittee shall comply with all existing federal regulations
governing the disposal of sewage sludge. Upon promulgation of 40 CFR Part 503, any permit issued
by the Permit Issuing Authority for the utilization/disposal of sludge may be reopened and
rnodified, or revoked and reissued, to incorporate applicable requirernents at 40 CFR Part 503. The
perrnittee shall comply with applicable 40 CFR Part 503 Standards for the Use and Disposal of
Sewage Sludge (when promulgated) within the time provided in the regulation, even if the permit
is not modified to incorporate the requirement. The permittee shall notify the Permit Issuing
Authority of any significant change in its sludge use or disposal practices.
7- r4wer Failures
The permittee is responsible for maintaining adequate safeguards as required by DEM Regulation,
Title 15A, North Carolina Administrative Code, Subchapter 2H, .0124 Reliability, to prevent the
discharge of untreated or inadequately treated wastes during electrical power failures either by
means of alternate power sources, standby generators or retention of inadequately treated effluent.

PartTI
Page 10 of 14
SECTION D._ MONITORING AND RECORDS
Samples collected and measurements taken, as required herein, shall be characteristic of the
volume and nature of the permitted discharge. Samples collected at a frequency less than daily
shall be taken on a day and time that is characteristic of the discharge over the entire period
which the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastestream, body of water, or substance, Monitoring points shall not be changed without
notification to and the approval of the Permit ➢ssuing Authority.
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and
reported on a monthly Discharge Monitoring Report (DMR) Form (DEM No. MR 1, 1.1, 2, 3) or
alternative forms approved by the Director, DEM, postmarked no Iater than the 30th. day
following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the perrnit pr in the case
of a new facility, on the last day of the month following the commencement of discharge.
Duplicate signed copies of these, and all other reports required herein, shall be submitted to the
following address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices
shall be selected and used to ensure the accuracy and reliability of measurements of the volume of
monitored discharges. The devices shall be installed, calibrated and maintained to ensure that the
accuracy of the measurements are consistent with the accepted capability of that type of device.
Devices selected shall be capable of measuring flows with a maximum deviation of less than + 10%
from the true discharge rates throughout the range of expected discharge volumes. Once -through
condenser cooling water flow which is monitored by pump logs, or pump hour meters as specified in
Part I of this permit and based on the manufacturer's pump curves shall not be subiect to this
requirement.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations
published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136; or in the case of sludge use or disposal, approved under 40
CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been specified
in this permit.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels that are below the permit discharge requirements and all
data generated must be reported down to the minimum detection or lower reporting level of the
procedure. if no approved methods are determined capable of achieving minimum detection and

Part II
Page 1 I of 14
reporting levels below permit discharge requirements, then the most sensitive (method with the
lowest possible detection and reporting level) approved method must be used.
Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders
inaccurate, any monitoring device or method required to be maintained under this permit shall,
upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for
not more than two years per violation, or by both. If a conviction of a person is for a violation
committed after a first conviction of such person under this paragraph, punishment is a fine of not
more than $20,000 per day of violation, or by imprisonment of not more than 4 years, or both.
6. Records Retention
Except for records of monitoring information required by this permit related to the permittee's
sewage sludge use and disposal activities, which shall be retained for a period of at least five
years (or longer as required by 40 CFR 503), the permittee shall retain records of all monitoring
information, including all calibration and maintenance records and all original strip chart
recordings for continuous monitoring instrumentation, copies of all reports required by this permit,
for a period of at least 3 years from the date of the sample, measurement, report or application.
This period may be extended by request of the Director at any time.
7. Recording_Results
For each measurement or sample taken pursuant to the requirements of this permit, the permittee
shall record the following information:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), upon thc presentation of credentials and other
documents as may be required by law, to;
a. Enter upon the perrnittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions
of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as
otherwise authorized by the Clean Water Act, any substances or parameters at any location.

Part 11
Page 12 of 14
$ECT1ON 1 . REPORTING REQI `1REMENT'S
Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit.
The discharge of any pollutant identified in this permit more frequently than or at a level in excess
of that authorized shall constitute a violation of the permit.
2. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned physical
alterations or additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for determining
whether a facility is a new source in 40 CFR Part 122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of
pollutants discharged. This notification applies to pollutants which are subject neither to
effluent limitations in the permit, nor to notification requirements under 40 CFR Part 122.42 (a)
(1).
c. The alteration or addition results in a significant change in the permittee's sludge use or
disposal practices, and such alternation, addition or change may justify the application of
permit conditions that are different from or absent in the existing perrnit, including notification
of additional use or disposal sites not reported during the permit application process or not
reported pursuant to an approved land application plan.
Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes in the permitted
facility or activity which may result in noncompliancewith permit requirements.
4. Transfers
This permit is not transferable to any person except after notice to the Director. The Director may
require modification or revocation and reissuance of the permittee and incorporate such other
requirements as may be necessary under the Clean Water Act.
Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit.
a . Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part 11. D. 2
of this permit) or forms provided by the Director for reporting results of monitoring of sludge use
or disposal practices.
b. If the permittee monitors any pollutant more frequently than required by the permit, using test
procedures specified in Part 11, D. 4. of this permit or in the case of sludge use or disposal,
approved under 40 CFR 503, or as specified in this permit, the results of this monitoring shall be
included in the calculation and reporting of the data submitted in the DMR.
c. Calculations for all limitations which require averaging of measurements shall utilize an
arithmetic mean unless otherwise specified by the Director in the permit.

Part II
Page I 3 of 14
6. Twenty-four Hour Reporting
a. The perrnittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the perrnittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence
of the noncompliance.
b. The following shall be included as information which must be reported within 24 hours under
this paragraph:
(11) Any unanticipated bypass which exceeds any effluent limitation in the permit.
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the
Director in the permit to be reported within 24 hours.
c. The Director may waive the written report on a case -by -case basis for reports under paragraph
b. above of this condition if the oral report has been received within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Part IL E. 5 and 6. of
this permit at the time monitoring reports are submitted. The reports shall contain the information
listed in Part II. E. 6. of this permit.
. Other Information
Where the perrnittee becomes aware that it failed to submit any relevant facts in a permit
application, or submitted incorrect information in a permit application or in any report to the
Director, it shall promptly submit such facts or information.
9. Noncompliance Notification
The perrnittee shall report by telephone to either the central office or the appropriate regional
office of the Division as soon as possible, but in no case more than 24 hours or on the next working
day following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of
significant amounts of wastes which are abnormal in quantity or characteristic, such as the
dumping of the contents of a sludge digester; the known passage of a slug of hazardous substance
through the facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators,
compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to such
station or facility.

Part 11
Page 14 of 14
Persons reporting such occurrences by telephone shall also file a written report in letter form within
5 days following first knowledge of the occurrence..
10. Availability of Reports
Except for data determined to be confidential under NCGS I43-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for
public inspection at the offices of the Division of Water Quality. As required by the Act, effluent
data shall not be considered confidential. Knowingly making any false statement on any such
report may result in the imposition of criminal penalties as provided for in NCGS 14'3-215.1(b)(2) or
in Section 309 of the Federal Act.
11. Penalties fo. Falsifcation of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other .document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per violation,
or by imprisonment for not more than two years per violation, or by both.

PART Ill
OTHER REQUIREMENTS
A. Construction
No construction of wastewater treatment facilities or additions to add to the plant's treatment
capacity or to change the type of process utilized at the treatment plant shall be begun until Final
Plans and Specifications have been submitted to the Division of Water Quality and written approval
and Authorization to Construct has been issued.
B. Groundwater Monitutzi
The permittee shall, upon written notice from the Director of the Division of Water Quality, conduct
groundwater monitoring as may be required to determine the compliance of this NPDES permitted
facility with the current groundwater standards.
C. Changes in Discharged of Toxic Substances
The permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe:
a.That any activity has occurred or will occur which would result in the discharge, on a routine or
frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge will
exceed the highest of the following "notification levels";
(1) One hundred microgran-is per liter (100 ug/1);
(2)Two hundred micrograms per liter (200 ug/1) for acrolein and acrylonitrile; five hundred
micrograms per liter (500 ug/l) for 2.4-dinitrophenol and for 2-methyl-t1.6-dini trophenol; and
one milligrarn per liter (1 m /I) for antimony;
(3) Five (5) times the maximum concentration value reported for that pollutant in the permit
application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine
or infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will
exceed the highest of the following "notification levels";
(1) Five hundred micrograms per liter (500 ug/I);
(2) One milligram per liter (1 mg/1) for antimony;
(3) Ten (10) times the maximum concentration value reported for that pollutant in the permit
application.
D. Requirement to Continually Evaluate Alternatives to Wastewater Discharges
The permittee shall continually evaluate all wastewater disposal alternatives and pursue the most
environmentally sound alternative of the reasonably cost effective alternatives. lf the facility is in
substantial non-compliance with the terms and conditions of the NPDES permit or governing rules,
regulations or laws, the permittee shall submit a report in such form and detail as required by the
Division evaluating these alternatives and a plan of action within sixty (60) days of notification by the
Division.

ee t pay the nal a ' stering d compliance mom o g fee
'may) days e being billed by the Di` i ►n. Failure to pay the fee in
eiy manner in accordance 1 .010 4 may cause this
Division to initiate actiort to revoke the pe
500copies of Maas public docu ent +sere pr ed at a cost o 50 or . 7 per copy,

State of North Carolina
Depa:rttent of Environment and Natural Resources
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
CERTIFIED MAIL
RETURN, RECEIPT REOUEST'ED
Mr. Gregory A. Schurig
R.P. Scherer
2725 Scherer Drive
St. Petersburg, Florida 33716
SUBJECT:
Dear Mr, Schurig:
September 2f
NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0084344
RP Scherer Treatment Facility
Union County
This is to inform you that a review of your toxicity self -monitoring report form for the month of
July 2f100 indicates a violation of the toxicity lirnitation. specified in your NPDES Permit,
You should take whatever remedial actions are necessary to eliminate the conditions causing the
effluent toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation
(TRE) which is a site -specific study designed to identify the causative agents of effluent toxicity, isolate
the sources of toxicity, evaluate the effectiveness of toxicity control options, and then confirm reductions
in effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
Toxicity Monitoring and Reporting Requirements. Please note updated mailing addresses for submitting
your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you
to review this information and if it would be helpful to discuss this situation or possible solutions to
resolve effluent toxicity noncompliance, please contact Mr. John Lesley with this office at (704) 663-
1699.
Sincerely,
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
cc: Aquatic Toxicology Unit
Central Files

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

MRO Staff Report — (NPDES Pe
NC0084344 Renewal) Page 1 of 5
SOC PRIORITY PROJECT: No
To: Permits and Engineering Unit
Water Quality Section
Attention: Charles H. Weaver, Jr.
Date: August 6, 1999
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Union
NPDES Permit No.: NC0084344
MRO No.: 99-116
PART I - GENERAL INFORMATION
Facility and Address: R.P. Scherer (formerly Chelsea Laboratories)
c/o Michael Cashman
Mailing Address Phvsical Address
2725 Scherer Dr. 2021 E. Roosevelt Blvd.
St. Petersberg, FL 33716 Monroe, Union County
Date of On -site investigation: August 3, 1999
Report Prepared By: Charley Schwartz, Environmental Engineer
4, Person Contacted and Telephone Number:
Main Contact.: David Scott (Phone## [phone])
ORC Name: Jerry L. Sullivan (Phone# [phone])
Directions to Site: From the jct. of East Roosevelt Blvd. (US Hwy 74 east) and Secrest
Ave. (SR 1941) in the City of Monroe, travel north on Secrest Ave. approximately 0.13
mile to Hasty Street. Turn right onto Hasty Street and travel east approximately 0.1 mile.
The proposed site for a groundwater remediation facility is located approximately 120
feet south of Hasty Street.
6. Discharge Point(s), List for all discharge Points: -
Latitude: 34 58' 50"
Longitude: 80° 29' 29"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: H 17 NW USGS Quad. Name: Wingate, NC
7. Site size and expansion area consistent with application: Yes.
8. Topography (relationship to flood plain included): The treatment system is not located
within the 100 year flood plain.

MR0 Staff Report — (NPDES Permit NC00843.44 Renewal)
Page of 5
9. Location of Nearest Dwelling: There are no domestic dwellings within 1,000 feet of the
groundwater remediation system; however, the treatment system is within 100 feet of the
R,P. Scherer building and within 500 feet of a Tyson Foods plant.
10. Receiving Stream or Affected Surface Waters: UT to Rays Fork
Classification: C
b. River Basin and Subbasin No.: Yadkin 03-07-14
c. Describe receiving stream features and pertinent downstream uses: The treated
groundwater is discharged to a stormwater culvert that flows under Hasty Street.
On the other side of Hasty Street, the culvert emerges into a small channel which
isl -2 feet wide and 1-2 inches deep. Although very small, the channel did have
flow at the time of the inspection (in the midst of a significant drought). Some
cattails were observed along the channel indicating that water is present for
extended periods of time. No significant vegetative cover (trees, bushes, etc.) was
observed along the channel indicating that thermal fluctuations in the channel are
likely to be extreme. No aquatic organisms were observed -in the channel during a
limited investigation. From the Hasty Street culvert, the channel flows
approximately 1000 feet before crossing under a railroad track and entering a
stormwater detention pond. The pond is well vegetated and appears to perform
significant stormwater filtration functions,
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
a. Volume of Wastewater (Actual Flow from DMRs): 3,800 gpd
b. What is the current permitted capacity: Flow limit not specified in permit
c. Current design capacity: 72,000 gpd
d. Date(s) and construction activities allowed by previous ATCs issued in the
previous two years: On February 4, 1998, the DWQ allowed the permittee to
conduct a pilot study test for the removal of diesel contamination identified in
MW-4. One oil water separator was installed between the influent line from MW-
4 and the air stripper. On June 5, 1998, the DWQ extended the deadline for the
permittee to complete the pilot study and submit a permit modification application
for the new treatment unit, Additional information regarding the matter
(including a permit modification request) is not in this Office's file.
e. Description of existing or substantially constructed WWT facilities: The existing
WWT facilities consist of four groundwater recovery wells, one oil water
separator (no permit modification), an air stripping unit with six aeration trays,
one 1,400-gallon gravity settling chamber, one water pump station, and one 150'
by 6' by 2' infiltration gallery.
Description of proposed WWT facilities: No modifications to the WWTP are
proposed at this time; however, the system may need to be modified pending the
results of the toxicity reduction evaluation.

MR© Staff Report — (NPDES Permit NC0084344 Renewal) Page 3 of 5
g.
Possible toxic impacts to surface waters: Many of the chemicals being treated by
the groundwater rernediation system are toxic to aquatic organisms. The treated
groundwater has failed several toxicity tests within the previous twelve months.
In addition, mercury has been reported on two occasions at levels above the
surface water standard. Furthermore, the detection limit of the analytical method
currently used for mercury (0.2 ug/1) is greater than the surface water standard for
mercury (0.012 ug/1).
h. Pretreatment Program (POTWs only): Not needed.
2. Residual handling and utiliation/disposal scheme:
a. If residuals are being land applied specify DWQ Permit No. N/A.
b. Residuals stabilization: N/A
c. Landfill: N/A
d. Other: N/A
3, Treatment Plant Classification: Grade 1 Physical/Chemical (new rating sheet attached)
4. SIC Code(s): 2899 Wastewater Code(s): 66
5. MTU Code(s): 55040
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? No
2. Special monitoring or limitations (including toxicity) requests: None at this time.
3. Important SOC/JOC or Compliance Schedule dates: N/A
4, Alternative Analysis Evaluation
a. Spray Irrigation: current property owner does not want treated effluent sprayed onto
property, concerned with spreading contamination
b. Connect to regional sewer system: City of Monroe denied discharge to sewer.
c. Subsurface: An infiltration gallery is located at the facility and receives
approximately 2 to 2.5 gpm of the effluent flow.
d. Other disposal options: N/A

MR0 Staff Report — (NPDES Permit NC0084344 Renewal)
PART IV - EVALUATION AND RECOMMENDATIONS
Page 4 of 5
The permittee is requesting that the existing NPDES permit be renewed. The permittee
also discharges to an infiltration gallery which operates under Permit No. WQ0010607. At the
time of the site visit, the treatment system was shut down due to a report from the analytical
laboratory that one of the effluent limits may have been exceeded. Prior to renewal of the
NPDES permit there are two issues that should be addressed, These issues are identified below:
1) Continuous Vs. intermittent Discharge - It appears that the existing NPDES permit
was issued to the permittee with the understanding that the outfall would be used as a secondary
or backup discharge to the infiltration gallery. The "Supplement to Permit Cover Sheet" within
the existing permit states the following (Supplement is also attached to the staffreport):
"This permit is being issued with the understanding that R.P. Scherer Corporation's
operation of this groundwater rernediation facility will be operated primarily as a non -
discharge .facility. If the infiltration gallery cannot accept the remediated groundwater
due to natural conditions (i. e. high rainfall events, high groundwater levels, geologic
conditions, etc.) then authorization is given for the dischargeto the above mentioned
creek for a period of time required for the infiltration gallery to be made operable and
returned to service, It should be the understanding ofR.P, Scherer Corporation that the
option to discharge should be used in an overflow situation only.
Upon reviewing the DMRs and groundwater monitoring reports for the facility, it is
apparent that the NPDES outfall has been used continuously as a discharge. During 1998 more
than 50% of the effluent from the treatment system was discharged to the NPDES outfall. The
NPDES outfall has received on average 3,800 gpd over the last 12 months, At the same time, the
infiltration gallery appears to be operating close to its proposed design capacity (below 3 gpm).
However, the flow rate from the recovery wells is still greater than the infiltration rate of the
gallery, Prior to the issuance of the existing peiiuit, the permittee's initial application and
description of the proposed wastewater treatment system had indicated the limited capacity of the
infiltration gallery and the necessity for an additional effluent receptor. Despite this information,
the permit was issued with the operative restriction paragraph presented above,
The MRO's Groundwater Section has reviewed the subject file and evaluated the
operational effectiveness of the existing treatment system. Groundwater staff have indicated that
a reduction in the pumping rate from the recovery wells would likely result in a loss of hydraulic
control (which prevents contamination from spreading) and extend the amount of time necessary
to reduce the groundwater contaminants to acceptable levels, In addition, there are active water
supply wells located in the area which have been contaminated by or are in danger of becoming
contaminated by the contaminant plume. The Groundwater Section has requested that the
NPDES perrnit be renewed to allow for the current pumping rates to be maintained.
2) Effluent Toxicity Fails - Beginning in May 1998, the effluent from the facility failed
at least five toxicity tests. A summary of the toxicity test results from the facility are outlined in
the following table:

MRO Staff Report — (NPDES Permit NC0084344 Renewal)
Month
Result
° 1998
Augus
1998
Fail
Pass
November 1998 Fail
December 1998 Fail
January 1999 Pass
May 1999 Pass
Page 5 of 5
This Office has yet to receive a Toxicity Reduction Evaluation (TRE) from the permittee.
The perrninee‘s consultant has indicated on a couple of occasions that metals in the groundwater
may be the cause of the toxicity fails; however, this has yet to be confirmed. in the December 22,
1995 permit issuance letter from the DWQ (attached), one of the comments addressed the
potential toxic impacts that may occur on account of the levels of arsenic, mercury and lead
detected in the groundwater. Mercury has also been detected in the effluent on two occasions
within the past 12 months, despite the fact that the detection limit for mercury is an order of
magnitude greater than the surface water standard.
If metals are the source of the toxicity fails, the current system ill suited for removing
these heavy elements, The aeration trays primarily remove volatile contaminants, and the gravity
settling unit primarily removes metals that come out of solution due to changes in pressure. The
permittee's consultant stated in an October 21, 1998 letter, "...toxicity is inherent to the area
groundwater and not caused by the permitted groundwater remediation system," So long as the
permittee desires to discharge to surface waters, the treatment system must be capable of treating
the groundwater such that it will not adversely impact surface waters, regardless of whether the
metals are target pollutants for removal. Considering the limited size of the receptor channel and
current flow from the NPDES outfall, even minor exceedances of pei initted limits may adversely
effect aquatic organisms.
This Office recommends renewal of the existing system only after the above issues have
been addressed. It is apparent that the treatment system is necessary to remediate groundwater
contamination, lt is also apparent that the treatment system would not be as effective operating
at a lower pumping rate (i.e. operating without an NPDES permit). However, the permittee must
ensure that the groundwater will not be remediated at the expense of surface water quality.
Therefore, the permittee should identify the source of the continuing toxicity fails, and if
necessary, make appropriate modifications to the treatment system prior to allowing continued
discharge to the receiving stream.
re of Report Preparer
Water Quality Regiona
Date
Date
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3E 17/1999 09:04 919-733-1330
DEHR WATER QUALITY PAGE 03
Cl as c rticrrt 1f*O. cal Water P+a ltxtion. Control Treatment Systems:
Grade I Biological WPCs
- Septic tank/sand filter systems
- Biological lagoon systems
Constructed wetlands and associ
Grade II Biol
- Systems that tt activtzted sludge or ,xed g owth process with a permitted flow
less than or equal to 0.5 million gallons per day (m
s
Grade L1I Biological WPCS
Systems that utilize an aedvat d sludge or process with a permits o
of greater than 0.5 through 2.5 million gallons per day (mgd)
Grade 11 ysle that are required to achieve biological nutrientreductiott *
Grade IV Biological WPCS
- Systems that utilizing an activoted sludge or fixed growth process with a permitted
of greater than 2.5 million gallons per day (mgd)
- Grade 111 systems that are required to achieve biological nutrient reduction *
* Bialag'icai Nur rtr , eduction ..
The reduction of total nitrogen or total phosphorous by.
process as required by the facilities permit,
Classrf c it
(whi
v
Collection Water Pollution Control Systems:
provides lowest grade)
biological
n
sludge or fixed growth
f system:

06/17(1999 09:04
DERR WATER QUALITY PACE 04
Classification of Spray IrriEatinn' 'aier Pollution Control
Systems which utilize spray irrigation for the cease or disposal of wasterwater.
These systems include: septic tans, sand filter. oil/water separators, lagoons,
storage basins, scrag, sedimentation. Systems other than those listed above
shall be subject to additional classification.
?klg'leafier' of Residuals Sysf +s:
tted and dedicated for land application of residuals that are produced by a -
cautrol system or contaminated soils.
Classification of Phvsical/Gb mkcaf''i ater Poll n Control of Systems:
Grade i Physic l/Chernic
physical process to treat
:remediattion systems. **
yam'
pollution control system that utilizes a primarily
its classification includes groundwater
Grade 11 Physical/Chemi .l: Any water pollution control systero that utilizes a primarii
chemical process to treat wastewater. This classiiicatiott includes reverse osmosis,
elecirodialysis, and uhzafiltration systems. **
** Any water pollution cool system dies �y�
activated sludge or fixed growth process, shall not be s
Any subsurface.sys.
systems than may be
subject ra addionnl lass
nif process .to enhance an
to additional classification,.
t*e
Elution Control tem=
and dptasi of wastewater
A NCAC 1 EA.1961. * **
pit i react ru process a water pollution contra!
.0302 through .0307 of .this section shalt be

Permit No. NC0084344
SUPPLEMENT TO PERMrT COVER SHEET
R.P. Scherer Corporation
is hereby authorized to:
1. Enter into a contract for construction of a wastewater treatment facility,
2. Construct and operate a groundwater remediation system consisting of four
recovery wells, a 50 gpm air stripper, a 1,400 gallon gravity settling chamber, a
pump station with duplex pumps, and an infiltration gallery for disposal of the
treated effluent, This facility will have the option to either diven the flow to the
infiltration gallery or to discharge to the unnamed tributary to Rays Fork, The
discharge of remediated groundwater will occur from °titian 001 located at R.P.
Scherer Chelsea Laboratories Facility, 2021 East Roosevelt Boulevard, of US
Highway 74, City of Monroe, Union County (See Part III of this Permit),
3, Make an outlet into an unnamed tributary to Rays Fork, and
4 Discharge at the location specified on the attached map into the unnamed tributary to
Rays Fork which is classified Class C waters in the Yadkin -Pee Dee River Basin.
5. This permit is being issued with the understanding that R.P. Scherer Corporation's
operation of this groundwater remediation facility will be operated primarily as a
non -discharge facility. If the infiltration gallery cannot accept the remediated
groundwater due to natural conditions (i,e. high rainfall events, high groundwater
levels, geological conditions, etc.) then authorization is given for the discharge to
the above mentioned creek for a period of time required for the infiltration gallery to
he made operable and returned to service, It should be the understanding of R.P.
Scherer Corporation that the option to discharge should be used in an overflow
situation only.

L.)
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr, Michael Cashman
R. P. Scherer Corporation
2725 Scherer Drive
Saint Petersburg., Florida 33716-1016
Dear Mr, Cashman:
December 22. 1995
Subject: NPDES Permit No, NC0084341
R. P. Scherer Corporation
Chelsea Laboratories Facility
Union County
In accordance with your application for discharge permit received on July 25, 1994, the Division is
forwarding herewith the subject State NPDES permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between
North Carolina and the U.S. Environmental Protection Agency dated December 6,, 1983. In response to
a letter of September 27, 1995 from Rogers and CalIcon Engineers. Inc. regarding your draft permit, the
following, comments are given:
• The Division has agreed to modify the language contained in the supplement to permit cover
sheet as suggested.
• Based on the review of groundwater monitoring data. limits for these metals must remain in
your permit. However, the Division will agree to re-evaluate these requirements after R.P.
Scherer collects 12 months of data. A review of groundwater monitoring data indicate that
arsenic. mercury and lead were present at levels which constitute a reasonable potential to
violate the instrearn standards for these parameters. Based on the treatment system proposed
which is unlikely to provide. substantial removal of metals and the concentrations documented,
it is possible that toxic impacts. may occur downstream of this discharge if limits for these
metals are not met.
4, A review of the permit file and past data reveals oil and grease not to be a concern. The oil and
grease parameter has been removed from the effluent page.
• Modification of the pH limit from 6.0 - 9.0 SU to 5.5 - 9.0 SU is not possible. Protection of
water quality is the concern with the issuance of this permit. Based on 15A NCAC 2B
.0211(b)(3), the pH standard for a class C receiving stream shall range between 6.0 and 9..0
standard units, As a result, this parameter must remain.
If any parts,: measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicative hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the forrn of a written petition. conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings. Post Office Drawer 27447., Raleigh, North Carolina 27611 -7447. Unless such demand is
made,. this decision shall be final and binding.
P,O,. Box 29535, Raleigh, North Carolina 27626-05.35 Telephone [phone]/FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ ¶0% post -consumer paper

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor \''
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
Mr, Michael Cashman
R.P. Scherer
2725 Scherer Drive
St, Petersburg, Florida 33716
Dear Mr, Cashman:
/.
, ,,',4 - ' 41i, • v .,
;,.
1"
July 12, 1999
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Renewal Application
Permit NC0084344
Chelsea Laboratories site
Union County
The Division received your permit renewal application oncjune 1, 1999. Thank you for
submitting this package.
The perrnit renewal for this facility will be assigned to a member of the .NPDES Unit staff,
That staff member will contact you if further information is needed to complete the permit
renewal. Please note that the NPDES Unit currently has five vacant positions, with an additional
staff member on extended medical leave. This staff shortage is delaying all permit re.newals. Our
four remaining permitwriters are currently reviewing Authorizations to Construct, speculative
limit requests, major permit 'modifications and 201 plan updates ahead of permit renewals. This
is necessary due to a variety of factors. including mandatory deadlines in the statutes which
govern our program.
If this staff shortage delays reissuance of NC0084344, the e2dsting requirements in your
permit will remain in effect until the permit is renewed (or the Division takes other action). We
appreciate your patience and understanding while we operate with a severely depleted staff. if you.
have any additional questions concerning renewal of the subject permit, please contact me at
[phone]. extension 511.
cc: Mooresville Regional Office, Water Quality Section.
NPDES File
David Scott / Rogers & Callcott
1617 Mail Service Center, Ralefgh, North Carolina 27699-1617
Charles H. Weaver, Jr.
NPDES Unit
919 733-5083, extension 511 (fax) 919 733-0719
An Equal Opportunity Affirmative Action Employer Charies_Weaver fif h2o,enr.state,nc.us

ROGERS & .LLC©TT
ENGENEERS, INC.
PO, Box 5655, Greenville, SC 29606
Phone [phone] • FAX [phone]
1999
N. C. Department of Environment and Natura
Division of Water
NPDES Unit
P. O. Box 29535
Raleigh, North Carolina 27626-0535
•
Re: NPDESRenewal Application
R. P, Scherer/Chelsea Laboratories Site
Monroe, Union County, North Carolina
NPDES No, NC0084344
Gentlemen:
Enclosed is the
are the follow
esourcces
r. L. Rogers, RE,
F, 0. Callcott, P.H.
5 W, Avery, Jr.,
Laboratory Dorecorr
iPDES Permit Renewal Application for the above referenced project. Included in this application
Short loan C-GW
USG Map Excerpt of Project Location
Narrative Report Discussing the Remediation Project, Table of Effluent Parameters, Summary
of Analytical Results, and Evaluation of Waste. Water Disposal Options.
In conjunction w itlt this permit application, the facility also operates under a non -discharge permit (Permit No.
WQ0010607). A request was made in February, 1999, (letter is attached) to modify the non -discharge permit as
follows: Air Stripper influent samples (composite from wells MW-2, MW-3, and M W-5) and from MW-4
collected before the inspection tank and one effluent sample will be analyzed once per month for the following
constituents: EPA Method 62I0D plus Acetone. This permit modification is identical to the current permitted
routine, except that the influent is represented by two samples instead of one.
If you have any questions or comments, please feel free to call me at (864)232- 1556.
Sincerely,
J. L. ROGERS AND CALLCOTT ENIINf°ERS,
David Scott
attachments
cc:
Greg Schuri
Peter Holmes
George Maalouf

NPDES PERMIT RENEWAL
R. P. SCHERER/GHELSEA LABORATORIES SITE
MONROE, UNION COUNTY, NORTH CAROLINA
NPDES NO. NC0084344
I. HISTORY OF GROUNDWATER CONTAMINATION RELATED TO THIS PROJECT
Chelsea Laboratories, Inc. of Monroe, North Carolina is a manufacturer of medicine
tablets. This facility was constructed, owned and operated by R. P. Scherer Corporation
in 1976 for the manufacturing of soft gelatin capsules. Chelsea purchased this facility from
R. P. Scherer in January 1986 and has operated it from 1986 through 1998. The plant is
currently idle.
During cleanup of a diesel fuel spill in July 1992, Chelsea discovered tetrachloroethene
(PCE) soil contamination in the vicinity of the diesel spill area. Chelsea excavated the soil
and notified R. P. Scherer of the contamination. With approval from the North Carolina
Department of Environment, and Natural Resources (NCDENR), R. P. Scherer transported
the contaminated soil to an appropriate disposal/treatment facility and voluntarily initiated
a preliminary soil and groundwater investigation in the area of the PCE contamination. The
investigation indicated the presence of limited PCE contamination in the soil and elevated
PCE contamination in the groundwater at the northeast corner of the building. Summaries
of the groundwater analysis and the maximum concentration of contaminants found are
attached, The volatile analysis was performed using EPA Method 8260. Additionally, semi -
volatile analyses using EPA Method 8270 and metals analyses were performed on well
MW-2. No semi -volatile or metals were detected, with the exception of iron and
manganese.
Based on the findings of a preliminary investigation, R. P. Scherer and NCDENR's Inactive
Hazardous Sites Branch determined the need for a Remedial Investigation to delineate the
extent of soil and groundwater contamination, and design and implement appropriate
remedial action. The site was designated number 51 on the Inactive Hazardous Waste
Sites Priority List dated March 11, 1994.
The Interim Remediation System started operation in June 1997. In August 1997,
personnel at Rogers and Callcott observed a strong petroleum odor and sheen on the '
water level meter probe from pumping well MW-4. It was determined that the product
discovered in MW-4 was a diesel fuel that was likely related to a 1992 diesel spill from
Chelsea's underground storage tank. As a result, the system was turned off until interim
measures could be implemented, In November 1997, an application for a pilot test for
diesel fuel recovery was submitted to NCDENR. The application was approved by
NCDENR in March 1998 and the interim pilot test system was constructed and went into
operation in April 1998.
ROGERS AND CALECOTT ENGINEERS

NPDES PERMIT RENEWAL
R. P, SCHERER/CHELSEA 1_,7':30RATORIES SITE
MONROE, UNION COUNTY, NORTH CAROLINA
NPDES Na NC0084344
Page 2
II. TREATMENT FACILITIES - INTERIM GROUNDWATER REMEDIATION SYSTEM
The purpose of the Interim Remediation System is to address on -site groundwater
contamination identified to date. Upon completion of the Remedial Investigation, the
recovery system may be expanded to expedite the rernediation effort,
A schematic diagram of the Interim Remediation System (P & I Diagram) is attached_ The
unit processes include:
Four pumping/recovery wells
Inspection tank (for well MW-4)
Air stripping unit
Gravity settling chamber
Finished water pump station
Infiltration gallery.
A brief narrative of the Interim Remediation System components is found below. Results
from the sampling and analysis program are found in the attached tables.
Pumping Wells
Wells MVV-2, MW-3, MW-4, and MW-5 were converted to groundwater recovery wells The
well pumps are controlled by pump motors phase monitors which sense change in
amperage draw, In addition, float switches at the finished water sump will control pump
operation to prevent overfilling of the sump.
Inspection Tank
Pumped water from well MW-4 is diverted to a 5 foot diameter HDPE "Inspection Tank"
with a capacity of approximately 500 to 600 gallons. This allows time for separation of the
petroleum compounds prior to air stripping. Floating oil residuals are skimmed with
absorbent booms. Copies of correspondence with NCDENR in reference to the pilot
system are attached.
Air Stripping
Contaminated groundwater recovered by the pumping wells and from the inspection tank
is pumped to a low profile, skid -mounted air stripper. The air stripper is sized for 50 gpm.
The air stripper includes a blower, prewired controls, control panel, and gravity discharge.
ROGERS AND CALLCOTT ENGINEERS

Gravity Settling
NPDES PERMIT RENEWAL
P -II SCHERER/CHELSEA LABORATORIES SITE
MONROE, UNION COUNTY, NORTH CAROLINA
NPDES NO NC0084344
Page 3
Naturally occurring iron in the groundwater may be oxidized by the air stripper and
precipitate. A settling tank is provided downstream of the air stripping unit to allow for
settling of the oxidized iron and other sand or sediment that may be in the recovery water.
The tank is a 6' x 8' x 4' deep (1,400 gallons) HOPE lined concrete tank. This provides a
detention time of 28 minutes at 50 gpm or almost 2 hours at 12 gpm. The settled material
is pumped periodically (so far, this was required once since June 1997) by a septic tank
hauler by outside contract.
Finished Water Pumping
Treated water from the air stripper and gravity settler flows to a duplex pumping station.
The pump station is supplied with duplex submersible pumps. The pump station pumps
treated groundwater to the infiltration gallery, and recirculates treated water back to the air
stripper. Since the infiltration gallery only accepts 2 to 3 gpm, the excess treated water is
discharged to a culvert under the road between this site and Tyson.
infiltration Gallery
To enhance the cleanup effort, an infiltration gallery is operated as an integral part of the
overall remediation system. The infiltration gallery reintroduces treated water to the area
of contamination, raising the head in that area. This water should travel the same path
through the fractures as the contaminant. As a result, the additional head and water supply
from the infiltration gallery should enhance the recovery of contaminants by the pumping
wells.
The infiltration gallery consists of two 150-foot long parallel pipes surrounded by stone. The
piping material is perforated corrugated ABS plastic pipe (commonly referred to as French
drain). This pipe is installed in a 6-foot wide trench excavated to the bedrock layer
(approximate elevation 980 feet MSL). The pipe is installed with "full envelope" bedding
using 3/4 inch diameter washed stone. This allows the treated water to percolate from the
pipes and into the surrounding formation. The bedding is approximately 2 feet deep. The
remainder of the trench is backfilled with suitable material.
Flow to the infiltration gallery and the head on the infiltration gallery is controlled with a float
valve located in a sump. The float valve closes when the level of water in the infiltration
gallery reaches a predetermined elevation. A solenoid valve and mercury float switch is
provided as a backup to the float valve. It is important to control the head on the infiltration
gallery so that reinjected water will not seep through the toe of the slope to the north of the
infiltration gallery.
ROGERS AND CALLCOTT ENGINEERS

NPDES PERMIT RENEWAL
R. P SCHERER/CHELSEA LABORATORIES SITE
MONROE, UNION COUNTY, NORTH CAROLINA
NPDES NO, NC0084344
Page 4
Proposed Permit Limits
Based on the results of the sampling and daily inspections, Rogers and Callcott believes
that additional analysis of effluent samples for Method 625 parameters is not warranted
and should be dropped from the permit. This is based on the data and discussion
presented in the February 4, 1999 letter from Scott to Beiniok/Coleson (attached). (Method
625 parameters are currently monitored as part of the Pilot Diesel Fuel Recovery project.)
R. P. Scherer requests the following modification to the permit
Discharge to surface waters (NPDES Permit NC0084344) will be sampled and
analyzed once per month, unless otherwise indicated, for Oil and Grease in
addition to the existing parameters: arsenic, chloroform, lead, mercury, pH (twice
per month), tetrachloroethene, toluene, trichloroethene. This proposal is identical
to the current permitted routine, with the addition of Oil and Grease.
III. EVALUATION OF ENVIRONMENTAL FEASIBILITY OF DISCHARGE
ALTERNATIVES
Several non -surface water discharge options have been pursued and are discussed below.
A. CONNECTION TO SEWERAGE SYSTEM.
Numerous contacts with the City of Monroe were initiated at different points of this project.
An initial request was made to the City on January 11, 1994 to accept purge water from
several wells on the R. P. Scherer/Chelsea Laboratories site. This request was followed
up by delivering several published articles from EPA guidance documents on treatability
of RCRA compounds. This request was denied.
A request for permission to discharge treated groundwater to the City of Monroe was made
May 2, 1994, Again, the City denied the request by letter citing the following reasons:
1, The City of Monroe Treatment Plant was not established for the purpose of
receiving VOC-pretreated wastewater nor designed for this purpose.
2, No additional benefits would be gained by passing the treated water through the
municipal system.
3. The wastewater would result in a low revenue return to the City and might
impose significant risks or costs, The City also does not have the expertise to permit
or monitor this type of discharge.
ROGERS AND CALLCOTL ENGINEERS

NPDES PERMIT RENEWAL
R. P. SCHERER/CHELSEA LABORATORIES SITE
MONROE, UNION COUNTY, NORTH CAROLINA
NPDES NO, NC0084344
Page 5
R. P. Scherer offered to pay the expenses for the City to obtain a consultant to provide
expertise in evaluating the impacts of receiving this water into their system. The City did
not accept this offer. As a result, this alternative is hot feasible.
B. On -Site Disposal.
Three options were proposed to Chelsea Laboratories, Inc. on behalf of R. P. Scherer. R.
P. Scherer does not own land in the Monroe, NC area. The options include using the
treatment discharge as makeup water for the cooling tower, and using the discharge water
as irrigation water. Subsurface disposal of the effluent was also considered. These options
were discussed with Chelsea and with Marion Merrell Dow Inc., the parent company of
Chelsea at that time.
A conference call was initiated on April 22, 1994 with Mr. Al Baker of Marion Merrell Dow
Inc. and Mr. Ben Baker of Dow Corporation to discuss the preliminary design concept. This
was followed with a meeting with Mr. Jim Miller of Chelsea Laboratories and Mr. Al Baker
(via conference call) on May 13, 1994. A request for permission to discharge on -site was
addressed. The request was denied.
Discharge to the cooling tower was denied by Chelsea citing potential repercussions with
new FDA guidelines.
Both spray irrigation and subsurface disposal were denied citing the potential to increase
cleanup liability with regard to potential cleanup if the contaminants were spread to other
portions of the property.
Since the requests to discharge treated groundwater to the sewer or to allow on -site
disposal were denied, no cost analysis could be made. Therefore, a NPDES permit is
required for discharging excess treated groundwater.
Copies of correspondence with the City of Monroe and with Chelsea Laboratories and
Marion Merrell Dow are on file at NCDENR.
ROGERS AND CALLCOTT ENGINEERS

R. P. Scherer/Chelsea Labs
Interim Groundwater Remediatian System
NPDES Permit No. NC0084344
Summary of NPDES Parameters
Flow
Average MGD
Monthly Max MGD
Monthly Mn,iMGD
Monthly Min.
Lead
Mercury
Chlarolorn
Tetrachlor
Toluene
Trichloroethene
nd Grease (added March
Method 6210D+Aceton+
Apr-98
< 0,02
< 0.02
<0.0002
< 0.5.
Jun•97
0.001374
0.006576
0.000005
< 0.02
< 0.02
<0,0002.
< 5.0
< 5.0
<5.0
Apr-98
0.003858 0,004648
0.012240 0.101610
0.001398 0.000000
< 0.02
< 0.02
<0.0002
0.8
< 0.5
May-98
0.006041
0,014667
0,002183
< 0.02
< 0,02
<0.0002
< 0.5
< 0.5
< 0.5
Jun•98
Sep--98
0.004932 0.004009 0.003717 0.004826
0.010888 0.011 127'„ 0.009196 0 011905
0.002337 0.001372 0.001950' 0.001271
<0.02 <0.02 < 0,02 <0.02
< 0.02 < 0.02 < 0,02 < 0.02
<0,00021', <0.0002' <0.0002 <0,0002
< 0.5
< 0.5
< 0,5
< 0.5
< 5,0
77 18 <0.5 < 0.5
< 0.5
0,004026
0.011276
0.001641
< 0.02
< 0.02
0.002
< 0,5
0,004800 0,003 76 0.006072
0,010639 0.015047 0.015669
0.001261 0.001432 0.002450
< 0.02
< 0.5
<002
< 0.02
<0.0002
< 0.5
8.2
< 0.02
< 0.02
<0.0002
<0.5
< 0.5
Feb=99 Mar-99
Apr-99
0.004535; 0.002646 0,001800
0.016709 0.006786 0,00,6320
0.000135 0,000978 0.000076
8.2
8.2
< 0.02
<0.0002
< 0.5
< 0,5
< 0.5
< 0.5
< 5.0
< 0.5
8.2
8.2
< 0.02
< 0.02
<0,0002
< 0.5
< 0.5
< 0.5
< 5.0
<0
8.2
< 0.02
< 0.02
<0.0002
< 0.5
< 0.5
<0.5
< 5.0

R. P. Scherer/Chelsea Labs
Interim Groundwater Remediation System
Summary of Tentatively identified Compounds (less PCE) and detected Method 625 Compounds,
Parameter
cptadeerll
e.ptadecal
itradecan
p
ethy I-
a-n
2.6.I0
lleptene, 4,propyl-
2•propcnoie aCid,20-nlethyl4 ,l-
1V
2,2�ttimelll'y°
cyclohexane, 1-methy1-3-=(1-
llicthvielayl
a
2-but anal, 2,3-di
hutane, 1,3-dictdcll'o-3-nlelllyd-.
influent influent effluent
04/09
04122
not
16 detected
Ito(
ecle
46 detected
not
not
dote
4
32 detected
not
detected 2
not
d
1101
1101
not
detected delecl/:d
not not
detected detected
influent effluent influent effluent
04/22 05/21 05/21 06/15 06/15
not I[01 001 1101
19 detected detected atetected cletecl.a1
net
dciccle
nt l 1101
detected tic'
1101 1101 1104
ect d detested detect
detected
not not
delertcxl
110t
detected detected
not
deter
not not
next
delecte
influent
08/04
det e,4ed
not
detecicd
not
detected
not
not
not ❑01
1101 not not
tectcd delecte d detect
de¢ecied
tot( 1111t
not
not
nfluent effluent
07/14
07/14
1101
1101 not not
cried detccled detect
not not not
d detected ctete tot detect
not
not not
ltcd detected
n01 net Plitt
cted dew led detect
detected , detect
not not not
sled detected di ecled detest
not
not
not
110t not 1[01 t11)t inn
9 19 detected' de?teed detected detested deter
114t not not not lull not not
eeted dctectcd j elcte,ctld tl reel d cletectcd detected eletecl
1101
110(
Itht 1101 11111 1101 not not II0l
tested IF3 1t0ter_tc`d detected dui led 110(19101.1 detected ateteCt
nut [lilt not
20 detected detected detect e:d dltecred delectec
nut
19 detected
not
1101
net 1111(
detected detect
53
1101 1101
9010)1 detect
1101 101
detectt detect
cd detect
not nut not
detected detectccf cletcc4
not 110t
detected dcwccled
I10t
no4 not not
cted detected 18 detected detected
d
1
effluent
08/04
all sarn
ales coftected
concentrations
fluent effluent influent effluent influent effluen
09/10 09/10 10/15 1f '15 11/1'0 11/1C
not not not 1101 1101
clew e�
detected detec
not not not nOd. not
ted detected detected detecletfl detected
d.
d
not not
coed detected
not
(101 1101
coed delecte
led detected
n0l not
coeI I detected
not neat not not
detected detected: detected d1110ctc
not not not
detecictl (let
n0l not
e led de teo(
not
1101 1101 1101
tceled deteett:d cha
d d
not not not
d detected detected
11Q1t not
lelccled detecteddetect
delecte
not
nut.
detected
d
1101 not
tectcd eleteet
not
soled
1101
led
001 1101
llectcd detected
1101
Trill
not
detected
not
ct
001 1101
ected i detect
nut not
ecled detect
not
ectcd e
not not
tied
LI cd
IH1l
detest
influent effluent
12/08 12/08
not not not
detected , detected detected
d
n�Ol net, 1101
1101
il.
not not
detected detected
1101 not 6101
ed detcctcdi d
not
detected
not
not
dcledl tt deice tt Gl detectec
r101
tees
not not not
d delr:t;ted detected
II( 1t ilia( not
d d
not
11r1t
steel
1101
11i1t not
dcic,ctcd detected'
d
1101
DDOI
not
net
nut
1101
not
et
[tot
not
1)01 II0I
cie01 detected
d
• not tot
detected detected
led

NPDES PERMIT APPLICATION - SHORT FORM C-GW
To be filed by persons engaged in groundwater remediation projects
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
P. O. Box 29535, Raleigh, NC 27626-0535
Please print or type
Applicant and facility producing discharge
A. Name R.P. Scherer
B. Mailing address of applicant:
1. Street address 2725 Soberer Drive
2. City- St . Petersburg
3. County
4. State Florida 5. Zip Code 33716
C. Location of facility:
1. Street 2021 East Roosevelt Boulevard
2. City Monroe 3. County Union
4. State NO 5. Zip Code 28111
D. Telephone Number ( 813 ) 572-4000
E. Fax Number ( 813 ) 573-2503
2. Standard Industrial Classification (SIC) code(s):
This application is for a:
New Permits Permit Renewal Permit Modification
If this application is for a permit renewal, record the existing permit number: NCOO 89344
4. Product(s) recovered (circle all that apply): Gasoline Diesel fuel
Other (describe)
(a)
Check here if discharge occurs all year Q , or
(b) Circle the month(s) in which discharge occurs: January February March April
May June July August September October November December
Days per week discharge occurs:
(c)
6. Volume of wastewater discharged to surface waters
Wastewater type
Remediated groundwater
fro
Flow
(GALLONS PER OPERATING DAY)
records max. 0.101.6 mgd
7. Check here if wastewater is discharged directly to the receiving stream(s)
If not, state the specific discharge location: Tributary to Rays Creek
Mark the path taken by the wastewater to the receiving stream(s) on the site map. If a storm sewer is the only
viable means of discharge, trace the route of the storm sewer to its discharge paint(s).
Short Form C-GW
Version 5-98

44 4
NPDES PERMIT APPLICATION - SHORT FORM C-GW
To be filed by persons engaged in groundwater remediation projects
8. Number of separate discharge points:
NOTE: If the facility has separate discharge points (outfalls), include a schematic diagram of
wastewater flow at the facility.
9. Name of receiving water(s): Tributary to Rays Creek
This application must also include the items listed below. This application will be returned he
required items are not included.
• A USGS topographical map (or copy of the relevant portion) which shows all outfalls
• A report of alternatives to surface water discharge as outlined by the Division's "Guidance for Evaluation of Wastewater Disposal
Alternatives' (required by 15A NCAC 2H 0105 (c))
h ; prorectirrdetall (
:1 A list of any chemicals found in detectable amounts at the site, with the maximum observed concentration reported for ach chemical
(the most recent sample must be collected less than one year prior to the date of this application)
• A summary of analytical results containing the maximum values for each chemical detected
• The removal efficiency of each compound detected (if known)
For fuel remediation projects, analyses for volatile organic compounds (VOCs) should be performed. Analyses for any fuel additives likely
to be present at the site should also be performed, At minimum, analyses should be performed for the following compounds:
benzene* toluene* ethylbenzene' xyiene* lead methyl terl-butylether (MTBE) dibromoethane (EDB)
1,2-dichloroethane isopropyl ether napthalene phenol
(*an EPA -approved method capable of detection levels to 1 ppb should be used to detect these mmpound ).
For solvents or unidentified proiects, an EPA Method 624/625 analysis should be performed, The data submitted with this application
should include the ten largest peaks not identified as targeted compounds and not present in the procedural blank. These peaks should be
identified and approximately quantitated (as per the same restrictions found on the NC DENRJDWQ Annual Pollutant Analysis
Monitoring (APAM) Requirement— Reporting Form Ay
if metals or pesticides are suspected to be present, these compounds should be analyzed to the same detection level as presented in the
NC APAM.
certify that I am familiar with the information contained in the application and that to the best of
irykanwledge and belief such information is true, complete, and accurate.
Michael F. Cashman Vice President, Worldwide Manufacturing
PrinuA nerve of Person Siyning Tite
dLf
Signature of Applicant
2 L.=
/Date
This application must &so include the items listed below. This application will be returned if the required items
are not included.
A USGS topographical map (or relevant portion) with all discharge points clearly marked.
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or certification in
any application: record, report plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management
Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method
required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be
guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprisonment not lo exceed six months, or by both:
(18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or imprisonment for not more than 5 years, or both, for a similar
offense.)
Short Form C-GW Version 5-98

4,4 a
aaaaaaa
ARS & LALLCOTT
ENG INE FRS, INC
PO. Box 5655,, 1.1ireem ifle, SC 29606
Phonc FAX 23.3-g05S
August 19, 1999
Mr, Samar Bou-Ghazale Mr.„RouGleason,...
NC Dept. of Environment and Natural Resources
Division of Environmental Management
Water Quality Section
919 North Main Street
Mooresville, NC 28115
W W,K;W,wh"
DTk.','104
By Facsimile: [phone]
By Certified Mail: Z305095269
Ref: Five -Day Written Report of an Upset
NPDES Permit #NC0084344, Non -Discharge Permit #WQ0010607
R. P. Scherer/Chelsea Laboratories
2021 E. Roosevelt Blvd, Monroe, Union County, North Carolina
R & C Project Number 93-121
Gentlemen:
Please consider this letter as the five-day written report of an upset that may have occurred
in the groundwater remediation system at the subject site. A 24-hour verbal report and
written confirmation were submitted to your office on July 30, 1999, when we received the
first indication of a possible upset. Since then, the laboratory analyses were completed
and an analytical report was received on August 18, 1999.
As indicated in our written confirmation to the 24-hour verbal report, two repeat samples
of the effluent were collected for confirmation on July 30, 1999. The samples were
collected at the effluent sampling port and at the end of the pipe. The system was also
shut down temporarily on July 30, 1999 until results of the confirmation samples became
available to prevent any discharge that potentially could had any adverse effects.
Laboratory analysis of the initial effluent sample collected on July 21, 1999 indicated that
the upset had resulted in readings above the NPDES effluent daily maximum for
trichloroethene and tetrachloroethene. The detected levels were 160 and 590 ug/L,
compared with the daily maximum of 92.4 and 8.85 ug/L for each compound, respectively.
Other VOCs were detected but were not above any established daily maximums.
However, analysis of the repeat samples (collected on July 30, 1999) did not confirm the
results of the earlier sample. No VOCs were detected in the two repeat samples except

Five -Day Written Report of a Possible Upset
NPDES Permit #,NC0084,344, Non -Discharge Permit #WQ0010607
R. P, Scherer/Chelsea Laboratories
Au9usf 19, 1999
for tetrachloroethene at concentrations of 0.79 and 0.63 ug/L. These concentrations are
more than ten times below the daily maximum of 8,8 ug/L. Copies of the laboratory
analysis reports are attached. A Daily Monitoring Report (DMR1 is being prepared and will
be submitted to the NCDENR by the end of August as required by the NPDES permit.
In an effort to identify the cause of the upset, Rogers & Galloon has interviewed the
operator and the manufacturer of the system. We have also closely reviewed the system
design, its operation and maintenance, sampling and analysis procedures and historical
data from the site. The evaluation confirmed that the system was properly designed, and
at the time was being properly operated and maintained. Enclosed are copies of the
operation and maintenance records for the last three months and a table and graph
showing the amount of VOCs recovered from the aquifer. Moreover, as the data submitted
in the monthly DMRs show, no significant changes have occurred in the influent
concentrations in July 1999. Therefore, it is apparent that the upset was due to factors
beyond our control that are unrelated to the system design, operation or maintenance.
Because the latest effluent data did not confirm the July 21, 1999 results, R. P. Scherer
plans to re -activate the remediation system as soon as possible. In my discussion with Mr.
Bou-Ghazale on August 18, 1999, R. P. Scherer was authorized to re -activate the system
on August 23, 1999. It is important to re -start the system in August to allow for the routine
influent/effluent and groundwater monitoring required by the permits for August.
We appreciate your attention to this matter. Please contact me if you have any concerns
or need additional information
Sincerely,
J. L. ROGERS & CALLCOTT ENGINEERS, INC.
George Y. Maalouf, P.G.
Enclosures
Copy: DEM, Water Quality Section, Central Files
DEM, Ground Water Section, Permits and Compliance Unit
Ms. Peggy Finley, Groundwater Section, Mooresville Office
Mr. Gregory Schurig, R. P. Scherer
Mr. Jerry Sullivan, Aqua-Trol
Mr. Peter Holmes, Clark Hill
ien Vpscher yupst

ROGERS & LLCOTT
ENGINEERS, INC.
P.O. Box, 5655, Greenville, SC 296C}6
Phone [phone] • FAX [phone]
CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/13/1999
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE �BER
PERMIT #W001 ©6©7
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE DESCRIPTION
J. L. Rogers. P.E.
F. D. Callcott, P.E.
S. W. Avery. Jr.,
Laboratory Director
PAGE 1
56967 INFLUENT (2,3,&5) GRAB ON 07/21/99 AT 1700
56968 INFLUENT 4 GRAB ON 07/21/99 AT 1630
PARAMETER
56967
INF. 2,3,5
56968
INF. 4
VOLATILE ORGANICS, µg/L
ACETONE <500 <500
BENZENE <5.0 <5.0
BROMOBENZENE <5.0 <5.0
BROMOCHLOROMETHANE <5.0 <5.0
BROMODICHLOR©METHANE <5.0 <5.0
BROMOFORM <5.0 <5.0
BROMOMETHANE <5.0 <5.0
n-BUTYLBENZENE <5.0 <5.0
sec-BUTYLBENZENE <5.0 <5.0
tert-BUTYLBENZENE <5.0 <5.0
CARBON TETRACHL©RIDE <5.0 <5.0
CHLOROBENZENE <5.0 <5.0
CHLOROETHANE <5.0 <5.0
CHLOROFORM 28 46
CHLOROMETHANE <5.0 <5.0
2-CHLOROTOLUENE <5.0 <5.0
4-CHLOROTOLUENE <5.0 <5.0
1,2-DIBROMO-3-CHLOR©PROPANE <5.0 <5.0
DIBROMOCHLOR©METHANE <5.0 <5.0
1,2-DIBROMOETHANE <5.0 <5.0
DIBROMOMETHANE <5.0 <5.0
CONTINUED ON PAGE 2

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/13/1.999
N.C. LABORATORY CERTIFICATE NUMBER 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE NUMBER SAMPLE DESCRIPTION
56967
56968
PARAMETER
VOLATILE ORGANICS, µg/L
(CONTINUED)
PAGE 2
INFLUENT (2,3,&5) GRAB ON 07/21/99 AT 1700
INFLUENT 4 GRAB ON 07/21/99 AT 1630
56967 56968
INF. 2,3,5 INF.
1,2-DICHLOROBEN'ZENE <5.0 <5.0
1,3-DICHLOROBENZENE <5.0 <5.0
1,4-DICHLOROBENZENE <5.0 <5.0
DICHLORODIFLUOROMETHANE <5.0 <5.0
1,'1-DICHLOROETHANE <5.0 <5.0
1,2-DICHLOROETHANE <5.0 <5.0
1,1-DICHLOROETHENE <5.0 <5.0
cisai,2-DICHLOROETHENE 200 360
trans-1,2-DICHLOROETHENE <5.0 <5.0
1,2-DICHLOROPROPANE <5.0 <5.0
1,3-DICHLOROPROPANE <5.0 <5.0
2,2-DICHLOROPROPANE <5.0 <5.0
1,1--DICHLOROPROPENE <5.0 <5.0
ETHYLBENZENE <5.0 <5.0
HEXACHLOROBUTADIENE <5.0 <5.0
ISOPR©PYLBENZENE <5.0 <5.0
p-ISOPROPYLTOLUENE <5.0 <5,0
METHYLENE CHLORIDE 7.9 7.4
NAPHTHALENE <5.0 <5.0
n-PROPYLBENZENE <5.0 <5.0
STYRENE <5.0 <5.0
1,1,1,2-TETRACHLOROETHANE <5.0 <5.0
1,1,2,2-TETRACHLOROETHANE <5.0 <5.0
TETRACHLOROETHENE 1100 1700
TOLUENE <5.0 <5.0
1,2,3-TRICHLOR©BENZENE <5.0 <5.0
CONTINUED ON PAGE 3

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALO
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/13/1999
N.C. LABORATORY CERTIFICATE NUMBER — 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE NUMBER SAMPLE DESCRIPTION
PAGE 3
56967 INFLUENT (2,3,8c5) GRAB ON 07/21/99 AT 1700
56968 INFLUENT 4 GRAB ON 07/21/99 AT 1630
PAPAMETR
56967 56968
INF, 2,3,5 INF. 4
VOLATILE ORGANICS, pg/L
(CONTINUED)
1,2,4—TRICHLOROBENZENE <5.0 <5.0
1,1,1—TRICHLOROETHANE <5.0 <5.0
1,1,2—TRICHLOROETHANE <5.0 <5.0
TRICHLOROETHENE 360 790
TRICHLOROFLUOROMETHANE <5.0 <5.0
1,2,3—TRICHLOROPROPANE <5.0 <5.0
1,2,4—TRIMETHYLBENZENE <5.0 <5.0
1,3,5—TRIMETHYLBENZENE <5.0 <5.0
VINYL CHLORIDE <5.0 <5.0
m/p—XYLENE <10 <10
HEXANE <5.0 <5.0
CONTINUED ON PAGE 4

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/13/1999
N.C. LABORATORY CERTIFICATE NUMBER - 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE NUMBER SAMPLE DESCRIPTION
56968 INFLUENT 4 GRAB ON 07 9 AT 1630
PARAMETER 56968
INF. 4
ACID/BASE S, tg./L
PHENOL <10
2-CHLOROPHENOL <10
2-NITROPHENOL <10
2,4-DIMETHYLPHENOL <10
2,4-DICHLOROPHENOL <10
P-CHLORO-M-CRESOL <10
2,4,6-TRICHLOROPHENOL <10
2,4-DINITROPHENOL <10
4-NITROPHENOL <10
4,6-DINITRO-0-CRESOL <10
PENTACHLOROPHENOL <10
BIS(2-CHLOROETHYL)ETHER <10
BIS(2-CHLOROISOPROPYL)ETHER <10
HEXACHLOROETHANE <10
N-NITROSODI-N-PROPYLAMINE <10
NITROBENZENE <10
ISOPHORONE <10
BIS(2-CHLOROETHOXY)METHANE <10
HEXACHLOROCYCLOPENTADIENE <10
2-CHLORONAPHTHALENE <10
DIMETHYLPHTHALATE <10
ACENAPHTHYLENE <10
2,6-DINITROTOLUENE <10
CONTINUED ON PAGE 5
PAGE 4

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/13/.999
N.C. LABORATORY CERTIFICATE NUMBER - 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACIL.I'TY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLEBER SAM'P.LE. DESCRIPTION
56968
PAGE 5
INFLUENT 4 GRAB ON 07/21/99 AT 1630
PARAMETER 56968
INF. 4
ACID/BASE NETYr ALS, mg/L
(CONTINUED)
ACENAPHTHENE <10
2,4-DINITROTOLUENE <10
DIETHYLPHTHALATE <10
FLUORENE <10
4-CHLOROPHENYL PHENYL ETHER <10
DIPHENYLAMINE (N-NITROSO) <10
AZCBENZENE <10
4-B.ROM©PHENYL PHENYL ETHER <10
HEXACHLOROBENZENE <10
PHENANTHRENE <10
ANTHRACENE <10
DI-N-BUTYLPHTHALATE <10
FLUORANTHENE <10
PYRENE <10
BUTYLBENZYLPHTTE <10
BENZO (A) ANTHRACENE <10
3,3'-DICHLOROBENZIDINE <10
CHRYSENE <10
BIS(2-ETHYLHEXYL)PHTHALATE <10
DI-N-OCTYLPHTHALATE <10
BENZO(B)FLUORANTHENE <10
BENZO(K)FLUORANTHENE <10
BENZO(A)PYRENE <10
CONTINUED ON PAGE 6

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22,/1999 DATE REPORTED: 08/13/1999
N.C. LABORATORY CERTIFICATE NUMBER - 27
PERMIT #WQ00I0607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEL IATION FACILITIES
UNION COUNTY, NC
SAMPLE NUMBER SAMPLE DESCRIPTION
56968
PAGE 6
INFLUENT 4 GRAB ON 07/21/99 AT 1630
PARAMETER 56968
INF.
ACID/BASE NEUTRALS, N9/L
(CONTINUED)
INDENO(1,2,3-C,D)PYRENE <10
DIBENZO(A,H)ANTHRACENE <10
BENZO(G,H,I)PERYLENE <10
TENTATIVELY IDENTIFIED COMP UNDS
COMPOUND
TETRACHLOROETHENE
METHOD 621 OD RESULTS
RETENTION ESTIMATED
% FIT TIME, min. CONCENTRATION,
94.6 4.000
O AFL T NTA Tr? IF i SD CO 3S
CONTAINED INT THE$ REPORT
THE COMPOUND NAMES REPORTED FOR CHROMATOGRAPHIC PEAKS THAT ARE NOT TARGET COMPOUNDS ARE ONLY BEST
SPECTRAL FITS DERIVED FROM A COMPARISON TO OUR 62,235 COMPOUND NIST SPECTRAL DATABASE. ESTIMATED
CONCENTRATIONS ARE BASED UPON THE TOTAL ION AREAS COMPARED TO THAT OF THE NEAREST INTERNAL STANDARD
ASSUMING A RESPONSE FACTOR OF ONE.
NOTE THAT THESE DATA ARE PROVIDED ONLY FOR ESTIMATING THE .INDS OF MATERIALS THAT MAY BE ASSOCIATED
WITH A PARTICULAR SAMPLE, AND SHOULD NOT BE CONSTRUED AS EVIDENCE THAT THE NAMED COMPOUNDS ARE
ACTUALLY PRESENT IN THAT SAMPLE.
CONTINUED ON PAGE 7

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/13/1999
N.C. LABORATORY CERTIFICATE NUMBER - 27
PAGE 7
PERMIT #WQ00I0607
R.P. SCHRRER/CHELSEA LABS FACILITY
GROUNDWATER R.MEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE NUMBER SAMPLE DESCRIPTION
56967
56968
INFLUENT (2,3,&5) GRAB ON 07/21/99 AT 1700
INFLUENT 4 GRAB ON 07/21/99 AT 1630
OUALITY CONTROL SUMMARY
56967 56968
INF....2,3,5 INF. 4
SURROGATE % RECOVERY
VOLATILE ORGANICS
4-BROMOFLUOROBENZENE
1,2-DICHLOROETHANE-D4
ACID/BASE NEUTRALS
NITROBENZENE-DS
2-FLUOROBIPHENYL
TERPHENYL-D14
2-FLUOROPHENOL
PHENOL-D5
2,4,6-TRIBROMOPHENOL
NOTE.
104 (105)
95(98)
108 (102)
98 (95)
86
79
72.
46
33
82
ATE RECOVERIES ARE WITRIN CONTRO r I BITS LFN ESS Nr T 'WXT d AN AST; RISK
NOTE: N.SRS IN PARENTHESIS ARE FOR S�TRR£
COVERY REANALYSIS.
CONTINUED ON PAGE 8

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/13/1999
N.C. LABORATORY CERTIFICATE NUMBER 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE UMBER SAMPLE DESCRIPTION
56967 INFLUENT (2,3,&5) GRAB ON 07/2
56968 INFLUENT 4 GRAB ON 07/21/99 AT
ANAL YSE.S, 'HRONQt ©GY
SAMPLE/4 PARAMETER D TEiTF: E ANALYZED METHOD# ANALYST
56967 VOLATILES 07/30 @ 0308 6210D LYNCH
INF. 2,3,& 5 AND 07/30 @ 0131 rr "
56968 VOLATILES 07/30 @ 0202 6210D LYNCH
INF. 4 AND 07/30 @ 0043 '° i°
ABN 08/08 @ 0148 625 rr
AND 07/23
REPORTED BY:
CC: NCDEHNR GRa U? D AT SEC
GREGORY A.
JERRY SULLIVAN (AU.A T".R©
PAGE 8
9 AT 1700
30

ROGERS & LLCOTT
ENGN ERS, INC.
P.©. ox 5655, Greenville, SC 29606
Phone ( 64) 232-1556 • FAX [phone]
CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/09/1999
N.C. LABORATORY CERTIFICATE NUMBER — 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
J. L. Ru g rv, P,E.
F. DCallcorr, RF.
S, W`, Avery, Jr.,
Laboratory Director
PAGE 1
SAMPLE NUMBER SAMPLE DESCRIPTION
56969 EFFLUENT GRAB ON 07/2./99 AT 1600
PA.METER RESULT DATE/TIME METHOD# ANALYST
ARSENIC, mg/L <0.02 07/26 @ 1050 200.7 ASHLEY
LEAD,. mg/L <0.02 08/04 @ 1028 r
MERCURY, mg/L <0.0002 08/03 @ 0850 245.1 LYNN
TOTAL OIL AND GREASE, mg/L <5.0 07/26 @ 0820 413.1 SALLEY
VOLATILE ORGANICS, pag/L
ACETONE <50
BENZENE <0.50
BROMOBENZENE <0.50
BROMOCHLOROMETHANE <0.50
BROMOD I CHLOROMETHANE <0.50
BROMOFORM <0.50
BROMOMETHANE <0.50
n-BUTYLBENZENE <0.50
sec-BUTYLBENZENE <0.50
tert-BUTYLBENZENE <0.50
CARBON TETRACHLORIDE <0.50
CHLOROBENZENE <0.50
07/29 @ 2216 6210D LYNCH
AND 08/03 @ 0001
AND 08/03 @ 0049
n
CONTINUED ON PAGE 2

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/09/1999
N.C. LABORATORY CERTIFICATE NUMBER 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE NUMBER SAMPLE DES RI:PTION
PAGE 2
56969 EFFLUENT' GRAB ON 07/21/99 AT 1600
PARAMETER
VOLATILE ORGANICS, µg/L
(CONTINUED)
RESULT DATE/TIME METHOD# ANALYST
07/29 @ 2216 6210D LYNCH
AND 08/03 @ 0001 " 11
AND 08/03 @ 0049 i° "
CHLOROETHANE <0.50
CHLOROFORM 15
CHLOROMETHANE <CY50
2-CHLOROTOLUENE <0.50
4-CHLOROTOLUENE <0.50
1,2-DIBROMO-3-CHLOROPROPANE <0.50
DIBROMOCHLOROMETHANE <0.50
1,2-DIBROMOETHANE <0.50
DIBROMOMETHANE <0.50
1,2-DICHLOROBENZENE <0.50
1,3-DICHLOROBENZENE <0.50
1,4-DICHLOROBENZENE <0.50
DICHLORODIFLUOR©METHANE <0.50
1,1-DICHLOROETHANE 2.5
1,2-DICHLOROETHANE 0.54
1,1-DICHLOROETHENE 1.4
cis-1,2-DICHLOROETHENE 83
trans-1,2-DICHLOROETHENE <0.50
1,2-DICHLOROPR©PANE <0.50
1,3-DICHLOROPROPANE <0.50
2,2-DICHLOROPROPANE <0.50
1,1-DICHLOROPROPE'NE <0.50
ETHYLBENZENE <0.50
CONTINUED ON PAGE 3

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07
22
PAGE 3
99 DATE REPORTED: 08/09/1999
N.C. LABORATORY CERTIFICATE NUMBER — 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE NUMBER
56969
PARAMETER
VOLATILE ORGANICS, µg/L
(CONTINUED)
HEXACHLOROBUTADIENE
ISOPROPYLBENZENE
p—I SOPROPYLTOLUENE
METHYLENE CHLORIDE
NAPHTHALENE
n— PRO ':YLBENZENE
STYRENE
1,1,1,2—TETRACHLOROETHANE
1,1,2,2—TETRACHLOROETHANE
TETRACHLOROETHENE
TOLUENE
1,2,3—TRICHLOROBENZENE
1,2,4—TRICHLOROBENZENE
1, 1, 1--TRI CHLOROETHANE
1,1,2—TRICHLOROETHANE
TRICHLOROETHENE
TRICHLOROFLUOROMETEANE
1,2,3—TRICHLOROPROPANE
1,2,4—TRIMETHYLBENZENE
1,3,5—TRIMETHYLBENZENE
VINYL CHLORIDE
m/p—XYLENE
p—XYLENE
HEXANE
SAMPLE, DESCRIPTION
EFFLUENT GRAB ON 0 7 / 21 / 9 9 AT 1600
RESULT
<0.50
<0.50
<0.50
1.2
<0.50
<0.50
<0,50
<©.50
<0.50
590
<0.50
<0.50
<0.50
<0.50
<0.50
160
<0.50
<0.50
<0.50
<0.50
<0.50
< 1 . 0
<0.50
<0.50
AND
AND
DATE/TIME METHOD# ANALYST
07/29
08/03
08/03
2216
0001
0049
6210D LYNCH
oa
Lo
CONTINUED ON PAGE 4

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUP
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/09/1999
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE NUMBER
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE DESCRIPTION
PAGE 4
56969 EFFLUENT GRAB ON 07/21/99 AT 1600
ACID/BASE NEUTRALS, µg/L
RESULT DATE/TIME METHOD# ANALYST
08/07 @ 2349 625 LYNCH
EXTRACTED 07/23/99
PHENOL <10
2-CHLOROPHENOL <10
2-NITROPHENOL <10
2,4-DIMETHYLPHENOL <10
2,4-DICHLOROPHENOL <10
P-CHLORO-M-CRESOL <10
2,4,6-TRICHLOROPHENOL <10
2,4-DINITROPHENOL <10
4-NITROPHENOL <10
4,6-DINITRO-0-CRESOL <10
PENTACHLOROPHENOL <10
BIS(2-CHLOROETHYL)ETHER <10
BIS(2-CHLOROISOPROPYL)ETHER <10
HEXACHLOROETHANE <10
N-NITROSODI-N-PROPYLAMINE <10
NITROBENZENE <10
ISOPHORONE <10
BIS(2-CHLOROETHOXY)METHANE <10
HEXACHLOROCYCLOPENTADIENE <10
2-CHLORONAPHTHALENE <10
DIMETHYLPHTHALATE <10
ACENAPHTHYLENE <10
2,6-DINITROTOLUENE <10
CONTINUED ON PAGE 5

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 07/22/1999
DATE REPORTED: 08/09/1999
N.C. LABORATORY CERTIFICATE NUMBER - 27
S
PLE
PERMIT #WQ00I0607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE DESCRIPTION
PAGE 5
56969 EFFLUENT GRAB ON 07/21/99 AT 1600
PARAMETER
ACID/BASE NEUTRALS, µg/L
(CONTINUED)
ACENAPHTHENE
2,4-DINITROTOLUENE
DIETHYLPHTHALATE
FLUORENE
4-CHLQROPHENYL PHENYL ETHER
DIPHENYLAMINE (N-NITROSO)
AZOBENZENE
4-BROMOPHENYL PHENYL ETHER
HEXACHLOROBENZENE
PHENANTHRENE
ANTHRACENE
DI-N-BUTYLPHTHALATE
FLUORANTHENE
PYRENE
BUTYLBENZYLPHTHALATE
BENZO(A)ANTHRACENE
3,31-DICHLOROBENZIDINE
CHRYSENE
B I S (2 - ETHYLHEXYL) PHTHALATE
DI-N-OCTYLPHTHALATE
BENZQ(B)FLUORANTHENE
BENZO(K)FLUORANTHENE
BENZO (A) PYRENE
RESULT DATE/TIME METHOD# ANALYST
08/07 @ 2349 625 LYNCH
EXTRACTED 07/23/99
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
CONTINUED ON PAGE 6

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RE
EIVED: 07/22/1999
PAGE 6
DATE REPORTED: 08/09/1999
N.C. LABORATORY CERTIFICATE NUMBER o 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE NUMBER
56969
PARAMETER,
ACID/BASE NEUT',i .LS, µg/L
(CONTINUED)
INDENO(1,2,3-C,D)PYRENE
DIBENZO(A,H)ANTHRACENE
BENZO(G,H,I)PERYLENE
SAMPLE DESCRIPTION
EFFLUENT GRAB ON 07/21/99 AT 1600
RESULT DATE/TIME METHOD#ANALYST
08/07 @ 2349 625 LYNCH
EXTRACTED 07/23/99
<10
<10
<10
TENTATIVELY IDENTIFIED COMPOUNDS
COMPOUND
TETRACHLOROETHENE
0 METHOD 6220D RESULTS
% FIT
RETENTION
TIME, min.
93.2 3.99©
DISCLAI R . O ALL TENTATIVELY .LD NTI
CONTAINED IN THIS RE
RT
ESTIMATED
CONCENTRATION, µq/L
THE COMPOUND NAPES REPORTED FOR CHROMATOGRAPHIC PEAKS THAT ARE NOT TARGET COMPOUNDS ARE ONLY BEST
SPECTRAL. FITS DERIVED FROM A COMPARISON TO OUR 62,235 COMPOUND NIST SPECTRAL DATABASE. ESTIMATED
CONCENTRATIONS ARE BASED UPON THE TOTAL ION AREAS COMPARED TO THAT OF THE NEAREST INTERNAL STANDARD
ASSUMING A RESPONSE FACTOR OF ONE.
NOTE THAT THESE DATA ARE PROVIDED ONLY FOR ESTIMATING THE 1GIRDS OF MATERIALS THAT MAY BE ASSOCIATED
WITH A PARTICULAR SAMPLE, AND SHOULD NOT BE CONSTRUED AS EVIDENCE TIAT THE 1fAMED COMPOUNDS ARE
ACTUALLY PRESENT IN THAT SAMPLE.
CONTINUED ON PAGE 7

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
PAGE 7
DATE RECEIVED: 07/22/1999 DATE REPORTED: 08/09/1999
N.C. LABORATORY CERTIFICATE NUMBER - 27
#WQ0010607
R.P. SCHERER+ CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE NUMBER SAMPLE DESCRIPTION
56969 EFFLUENT GRAB ON 07/21/99 AT 1600
QUALITY CONTROL SUMMARY
SURROGATE % RECOVERY
VOLATILE ORGANICS
4-BROMOFLUOROBENZENE 106(103)(101)
1,2-DICHLOR©ETHANE-D4 86(97)
ACID/BASE NEUTRALS
NITROBENZENE-DS 93
2-FLUOROBIPHENYL 84.
TERPHENYL-D14 65
2-FLUOROPHENOL 44
PHENOL-DS 32
2,4,6-TRIBROMOPHENOL 86
NOTE: S J O ATE RECOVERIES
CONTROL LIMITS UNLESS NOTED WITH AN ASTERISK
NOTE: NUMBERS IN PARENTHESIS ARS FOR SURROGATE RECOVERY REANALYSIS.
REPORTED BY:
RY, LABORATORY DIRECTOR
CC: NCDEHNR GR
GREGORY A.
JERRY SULLIVAN (AQUA-TRQL)

Client Name
Address
ROGERS & CA.:LCOTT
ENGINEERS, INC.
PO, Box 5655, Greenville, SC 29606
Phone [phone] • FAX [phone]
Shipping Address° 718 Lowndes Hill Road
Greenville. S.0 29607
e e_� `.
Report To: CQ r
Telephone No.
PO No.
Rogers
Callcott
Lab No.
SAMPLER
Refinished
Relinquished
Sig.)
Relinquished by (Sig.)
FAX No.
Project Na.
Sample ©esca"fption
Date/Time
hd by l Recvd- lnt rct b
Revised June 1994
Received by (Sig
Shipper Name 8�
Recel
hippe
Received by (Si
Shipper Name
CHAIN OF CUSTODY RECORD
chd b ; W Recvd, lntcct b
PAGE
Sample
Refrigerrlted
Container Tvtae
Contolner volume
ab,+`omposite
Sample source (WW, GW, DW, other,
Preserved (Code,
A —None d--No0H
$—HN©, E—HcL
C--H,So, F
Receipt Total CL, mg/L Receipt pH
Subsequent Analysis. _..(Check)
Dote Resubmitted

ROGERS & .LLCOTT
ENGINEERS, INC.
PO, Box 5655, Greenville, SC 29606
Phone [phone] • FAX [phone]
CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 08/02/1999 DATE REPORTED: 08/13/1999
N.C. LABORATORY CERTIFICATE NUMBER 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE EMBER SAMPLE DESCRIPTION
I. L. Rogers:, RE.
F. D. Call:.or,C, RE.
. W. Avery, Jr.,
#btrr [ory Direcoor
PAGE 1
57617 EFFLUENT GRAB ON 07/30/99 AT 1430
57618 EFFLUENT (AT PIPE) GRAB ON 07/30/99
AT 1500
PARAMETER
57617
EFF. GRAB
57618
EFF. AT PIPE
VOLATILE ORGANICS, ixg/L
ACETONE <0.50 <0.50
BENZENE <0.50 <0.50
BROMOBENZENE <0.50 <0,50
BROMOCHLOR©METHANE <0.50 <0.50
BROMODICHLOROMETHANE <0.50 <0.50
BROMOFORM <0.50 <0.50
BROMOMETHANE <0.50 <0.50
n-BUTYLBENZENE <0.50 <0.50
sec-BUTYLBENZENE <0.50 <0.50
text-BUTYLBENZENE <0.50 <0.50
CARBON TETRACHLORIDE <0.50 <0.50
CHLOROBENZENE <0.50 <0.50
CHLOROETHANE <0.50 <0.50
CHLOROFORM <0.50 <0.50
CHLOROMETHANE <0.50 <0.50
2-CHLOROT'OLUENE <0.50 <0.50
4-CHLOROTOLUENE <0.50 <0.50
1,2-DIBROMO-3-CHLOROPROPANE <0.50 <0.50
DIBROMOCHLOROMETHANE <0.50 <0.50
1,2-DIBROM©ETHANE <0.50 <0.50
DIBROMOMETH:ANE <0.50 <0.50
CONTINUED ON PAGE 2

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAA'LOUF
DATE RECEIVED: 08/02/1999 DATE REPORTED: 08/13/1999
N.C. LABORATORY CERTIFICATE NUMBER 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
SAMPLE BER SIMPLE DESCRIPTION
PAGE 2
57617 EFFLUENT GRAB ON 07/30/99 AT 1430
57618 EFFLUENT (AT PIPE) GRAB ON 07/30/99
AT 1500
PARAMETER
57617
EFF. GRAB
57618
EFF. AT PIPE
VOLATILE ORGANICS, iig/L
(CONTINUED)
1,2-DICHLOROBENZENE <0.50 <0.50
1,3-DICHLOROBENZENE <0.50 <0.50
1,4-DICHLOROBENZENE <0.50 <0.50
DICHLORODI'FLUOR©METHANE <0.50 <0.50
1,1-DICHLOROETHANE <0.50 <0.50
1,2-DICHLOROETHENE <0.50 <0.50
1,1-DICHLOROETHENE <0.50 <0.50
cis-1,2-DICHLOROETHENE <0.50 <0.50
trans-1,2-DICHLOROETHENE <0.50 <0.50
1,2-DICHLOROPROPANE <0.50 <0.50
1,3-DICHLOROPROPANE <0.50 <0.50
2,2-DICH.LOROPROPANE <0.50 <0.50
1,1-DICHLOROPROPENE <0.50 <0.50
ETHYLBENZENE <0.50 <0.50
HEXACHLOROBUTADIENE <0.50 <0.50
ISOPROPYLBENZENE <0.50 <0.50
p--ISOPROPYLTOLUENE <0.50 <0.50
METHYLENE CHLORIDE <0.50 <0.50
NAPHTHALENE <0.50 <0.05
n-PROPYLBENZENE <0.50 <0.50
STYRENE <0.50 <0.50
1,1,1,2-TETRACHLOROETHANE <0.50 <0.50
1,1,2,2-TETRACHLOR©ETHANE <0.50 <0.50
TETRACHLOROETHENE 0.79 0.63
TOLUENE <0.50 <0.50
1,2,3-TRICHLOR©BENZENE <0.50 <0.50
CONTINUED ON PAGE 3

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOI.TF
DATE RECEIVED: 08/02/1999 DATE REPORTED: 08/13/1999
N.C. LABORATORY CERTIFICATE NUMBER - 27
PERMIT #WQ0010607
R.P. SCHERER/CHELSEA LABS FACILITY
GROUNDWATER REMEDIATION FACILITIES
UNION COUNTY, NC
PLENUMBER SAMPLE DESCRIPTION
PAGE 3
57617 EFFLUENT GRAB ON 07/30/99 AT 1430
57618 EFFLUENT (AT PIPE) GRAB ON 07/30/99
AT 1500
PARAMETER
VOLATILE ORGANICS, µg/L
(CONTINUED)
57617 57618
EFF. GRAB EFF. AT PIPE
1,2,4-TRICHLOROBENZENE <0.50 <0.50
1,1,1-TRICHLOROETHANE <0.50 <0.50
1, 1, 2-TRICHLOROETHANE <0.50 <0.50
TRICHLOROETHENE <0.50 <0.50
TRICHLOROFLUOROMETHANE <0.50 <0.50
1,2,3-TRICHLOROPROPANE <0.50 <0.50
1,2,4-TRIMETHYLBENZENE <0.50 <0.50
1, 3, 5-TRIMETHYLBENZENE <0.50 <0.50
VINYL CHLORIDE <0.50 <0.50
Cyµ-XYLENE <0.50 <0.50
m/p-XYLENE <1.0 <1.0
HEXANE <0.50 <0.50
CONTINUED ON PAGE 4

CLIENT e: RPS/ HE S ,
7 ' E, NC
C/O GEORIGE OUP
PAGE
DATE RECEIVED: 8/ 1999 DATE REPORTED: /13/1999
. C EARO TORY CERTIFICATE ER
AMPLE
5'76].°7
57.8
PA ETER
SURROGATE
P IT
R. F. ECEERER/CHE
GROI: #nWATER R
t�
ON CO
VOA
4 BROMO
1 2 —DI CHLOROET —D4
. "E: TE ECOVE
0010607
A:FACILITY wO JTm te
e M
PEE ,DES RI PTION
EFFLUENT G ON 7/30/9 AT 1430
EFFLUENT (AT PIPE) G" ON 07/ 0/99
AT 1500
5717 571,8
EFe GRAB EFF, AT PIPE
RECOVERY
8
80
95
94
1THI C ROL LIA ITS NOTED WITH ASTERISK
CONTI ED ON PAGE 5

CLIENT : BPS/CHELSEA
MONROE , NC
C/0 GEORGE
LOUP'
PAGE 5
DATE RECEIVED: 08/02/1999 DATE REPORTED: 08/13/1999
N.C. L
0
TORY CERTIFICATE NUMBER - 27
SAMPLE NUMBFR
57617
57618
SANWLE#
57617 VOLATILES
FFF. 0
*
R.p. PE* IT #wQ0010607
SCRS* Ri'ORELS .:8 FACILITY
GRO'WATER REMEDIATION FACILITIES
ION CO Y, NC
$ PLE DESCRIPTION
EFFLUENT G*.: ON 07/30/99 Al 1430
EFFLUENT (AT PIPE) G ON 07/30/99
AT 1500
ANALYSES CHRONOLOGY
PARAMETER D TEI1ME ANALYZED METHOD# ANALYST
08/02 @ 1908
57618 VOLATILES 08/02 4 2312
FFF. AT PIPE
REPORTED BY:
CC: NOD
GREGORY A . S
JERI? Y SULLIVAN AQUA TROL)
SE ION
RP SCR R
8910D LYNCH
8919D LYNCH
A L RY, LABORATORY DIRECTOR

Client Name
Address
Report To:
ROGERS & CALLCOTI
ENGINEERS, INC.
P.0, Box 5655, Greenville, SC 29606
Phone [phone] • FAX [phone]
Shipping Address; 718 Lowndes Hill Road
Greenville, S.C. 29607
CI) ere '
Telephone No.
PAD No,
Rogers
Callcott
Lob No.
FAX No.
Project No.
Time Sample Description
SAMPLER
Refinished teyr9
Relinquished by (S
Relinquishd by (Sig.)
Seal at'chd byO Rec'
Form Revised June 1994
Recei
Shipper Natrae "eft
Received by (Sig.)
Shipper Name
Re c - ; ed by (Si
0 '+ Shipper N
CHAIN OF CUSTODY RECORD
Date/llme
Date f flme
4
Recvd. Intact b
PAGE
OF
Refri Aerated
Container T
Container volume
Sample type (Qrob/ omp©site
WW, G1N, DW, other)
Receipt Total CL, mg/L Receipt pH
Subsequent. Analysis:_ (Check)
Data Resubmitted

MYLIA-T* ,C.
P VALUE FOR THE FOLIO INC
82 42 Pm

99 THU AQUA--TRQL, INC.
704 882 3542 P.02
CHELSEA WATER REEMEDIATION
MONITORING REPORT FOR MONTH OF
Time In Time Out Total Time
Totalizer#1 Usage
Surface
Discharge
"576')ii
p?.07?
COO 13.
• 9 l7
17/44 915
otalizer #2
Nitration
Gallery
6—9f $tom 4,4jr4J.T c44.0- # 4s€

JJN-03-99 THU I, 03 AM AQUA-TROL,INC.
4 882 3542 P.03
CHELSEA WATER REMEDAATION
MONITORING REPORT FOR WELLS

DATE
AQUA.TROL,
<
Pil VALUES
SEA A T

JUL1-09-99 FRI 11:29
AQUA- iQU-TR0L I NC .
04 882 3542
CHELSEA WATER REMEQJATJ0
t4l1DNETORENG REPORT FOR MONTH OF e,
Date Time In Time Out
Total Tin° e Totalizer#
Surface
Dischar

JUL.- 09-99 FRI 11:29 AM AQUA-TRQL, INC.
704 882 3542 P. 03
C'HELSEA WATER REN EJXATION
MONITORING REPORT FOR WELLS jC.0)v

40 P
AQUA-TROL IN
DATE
A
1
SCR -C
: ?VALUES FOR T
7&4
LANT
JNG
42

PUG-03-99 TUE 12:41 PM AQUA-TROL,INC,
704 882 3542 P.02
CHELSEA WATER REMEDIATION
MONITORING REPORT FOR WELLS

AUG-0
99 TUE 12;54 PM AQUA-TROL,INC.
704 882 3542 P. 01
HELSEA WATER R.EMEDIATION
MONITORING REPORT FOR MONTH OF
Totalizer#].
Surface
Discharge
Totalizer #2
Infiltration
Gallery

m 1a
cr
E 8
2
n▪ .
}
E
ce
0
4
0
Q
O • 0
a_
R.P. SCHERER/CHELSEA LABORATORIES FACILITY
MONROE, NORTH CAROLINA
GROUNDWATER CORRECTIVE ACTION
Pounds of
Month VOCs
Recovered
from
Aquifer
May-97 1.14
Jun-97 5.98
Jul-97 5.81
ug97 —__ 1.72
Apr 98 4,85
5.43 May-98 y 3
Jun-98 8.20
Jul-98 4.09
Aug-9$ 3 51
Sep-98 2.68
Oct-98 3.15
Nov-98 2.57
Dec-98 4,05
Jan-99 2.03
Feb-99 2.57
Mar-99 2.60
Apr-99 0.95
May-99 . 2.83
Jun-99 1.60
Jul-99 2.15
R.P. SCHERER/CHELSEA LABORATORIES FACILITY
MONROE, NORTH CAROLINA
i
I II I III
1
1
May-97 Jul-97 Apr-98 Jun-98 Aug-98 act-98 Dec-98 Feb-99 Apr-99 Jun-99
Jun 97 Aug-97 May-98 Jul-98 Sep-98 Nov-98 Jan-99 Mar-99 May-99 Jul-99
Month/Year
gym-c:\clients\rpscherer\vacremov.wk4 08/19/99

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James D. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
April 20, 1999
GEORGE MAALOUF
Scherer Corporation
2725 SCHERER DRIVE
ST. PETERSBURG, FL 33716
NCDENR
NORTH CAROL.INA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Renewal of NPDES Per-
Chelsea Laboratories
UNION County
Dear Perm
1599
The subject permit expires on November 30, 1999. 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 June 3, 1999. Failure to request renewal of the permit by this date will result in a civil
assessment of at least 5250,00. Larger penalties may be assessed depending upon the delinquency of
the request.
If any wastewater discharge will occur after June 3, 1999 (or if continuation of the permit is
desired), the current permit must be renewed. Operation of wastewater treatment works or
continuation of discharge after June 3, 1999 would violate North Carolina General Statute 143-215.1
and could result in assessment of civil penalties of up to $10,000 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 Mooresville 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 below.
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES File
P.O. Box 29535, Raleigh, North Carolina 27626.0535
An Equal Opportunity Affirmative Action Employer
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
919 733-5083, extension 511 (fax) 919 733-0719
[e-mail]

NC DENR / DWQ / NPDES
Renewal Application Checklist
NPDES Permit NC0084344
Scherer Corporation
"UNION Count-3'
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.
D 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 (see Part II.B.11.b of the existing NPDES peuiiit) prepares the
renewal package, written documentation must be provided showing the authority delegated to the
Authorized Representative.
❑ 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 which discharge
process wastewater:
❑ Submit the last 3 years' production da
reporting to EPA.
❑ Industrial facilities classified as Primary Industries (see Appendix A 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 is not completed within one week of June 3, 1999, submit the
application package without the PPA. Submit the PPA as soon as possible after June 3, 1999.
The above requirements do NOT apply to municipal or non -industrial facilities.
a fo
he facility. Use units consistent with those required for
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 / DWQ / NPDES
P.O. Box 29535
Raleigh, NC 27626-0535

ERS & ALLCOTT
ENGINEERS, IN:
P.O. Box 5655, Greenville, SC 29606
Phone (864) "232-1556 • FAX (864) "233-9058
April 29, 1997
Mr. Rex Gleason
Mooresville Regional Office
North Carolina Department of Environment,
Health and Natural Resources
919 North Main Street
Mooresville, North ,Throlina 28115
Re: R. P, Scherer/Chelsea Laboratories
Interim Groundwater Remediation System
Monroe, Union County, N. C.
NPDES No. NC0084344
Permit No. WQ0010607
Dear Mr. Gleason.
I„.
D. CatIcori,
S. v A VL1 y ,
Lahortiory Director
This letter is to confirm our telephone conversation of today in reference to start-up of the
Interim Groundwater Remediation System at the Chelsea Laboratories facility in Monroe.
Equipment manufacturer's representatives are scheduled to start up the equipment on Thursday,
May 1, 1997. The purpose of this is to test the equipment prior to placing the equipment into full-
time operation. We anticipate placing the equipment into operation on Monday, May 5, 1997.
It is our understanding that DEM may not inspect the system prior to operation,
Monitoring in accordance with the NPDES and the WQ permits will begin on May 5.
If you require further information, or have any questions or comments, feel free to call
at [phone].
Sincerely,
J. L. ROGERS AND CALLCOTT ENGINEERS, INC.
David E. Scott, P.E.
cc: Ms, Karen Connell
Mr. George Maalouf

State of North Carolina.
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
March 20, 1996
CERTlF1ED MAIL
RETURN REQEIPT, REQUESTED
Mr. Michael Cashman
R. P. Scherer Corporation
2725 Scherer Drive
Saint Petersburg, FL 33716-1016
NKr v..
MAO i 1996
Subject: NPDES Permit No. NC0084344
R. P. Scherer Corporation
Chelsea Laboratories Facility
Adjudication Settlement
Union County
Dear Mr. Cashman:
In accordance with your. Petition for Contested. Case Hearing filed, and subsequent notice of
intent to withdrawal in a letter from Rogers & Callcott. Engineers, Inc. dated March 6., 1996, we are
forwarding herewith the modified page of the subject permit. The permit has been modified as
follows:
Effluent] ntations for outfall 001:
The pH listed has been changed to monitoring only. The monitoring shall occur
twice per month and reported but no limit is established.
The attached. effluent page should be placed in the issued permit and the old effluent page
removed and discarded. All other terms and conditions contained in the original permit remain
unchanged and in full effect. This modification is issued pursuant to the requirements of North
Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and
the U. S. Environmental Protection Agency dated December 6, 1983.
It is our understanding based on the March 6, 1996 letter from Rogers & Callcott Engineers, Inc.
that this modification will resolve all items contained in the Petition for Contested Case Hearing. If
this is not the case, the R.P, Scherer Corporation should notify us immediately, but no later than ten
(10) days following receipt of this letter. Unless such demand is made, this decision shall he.final
and binding.
P.Q. Box 29535, Raleigh, North Carolina 276 6-0535 Telephone [phone]'015 FAX [phone]
An Equal Opportunity Afflrma,ive ,Action Employer 50% recycled/ 10% post -consumer paper

If you have any questions concerning this permit, please contact Randy L. Kepler at telephone
number 919-733-5083.
Sincerely„
Preston Howard,
im Patrick, EPA
Attorney Geneti S Office -Environmental
George Y. Maalouf, Rogers & Callcott Engineers
Brian Wagner, Groundwater Section
Permits and Engineering Unit
Central Files
Compliance
. PE

A. (). E. FLUENT 1.,CMITATIONS AND MONFI'O ING REQUIREMENTS FINAL
Perri* No.. NC0084344
period beginning ttn the effective date of the permit and lasting until expiration, the Pennittee is authorized to discharge from
aerial number 001. Such discharges shall be limited and monitored by the f errarittee as specified below:
Ef11,u9_nt C_h ra_ct rfsif $
Flow
Arsenic
Chloroform
Lead
Mercury
pH
Tetrachloroethene
Toluene
Trichloroethene
Chronic Toxicity **
A.is hatatlrnts
f
Monthly Avg." Bally Max'.
50.0 µg/I
25,0 lrglI
0.012 µg/I
8.85 µg/I'
11.0 µg/I
92.4 µg/I
Moni>tO.1O
meet Sample *Se
r .. sierrcy. TrQe
Continuous Recording
Monthly Grab
Monthly Grab
Monthly Grab
Monthly Grab
2/Month Grab
Monthly Grab
Monthly Grab
Monthly Grab
Quarterly Grab
E
E
E
E
E
E
E
E
E
E
This facility is being approved as a non -discharge facility with the option of an emergency discharge should the infiltration gallery fail to handle the Toad of the
treated groundwater. The monitoring requirements listed above only need to be completed upon discharge from this facility. If an actual discharge does not
occur during a month, then report such on the monthly monitoring reports. Sampling only needs to be completed at time of a discharge.
• Sample Locations: E - Effluent
Monitoring shall be conducted during normal work hours.
—Chronic Toxicity (Ceriodaphnia) Quarterly. Pass/Fail, 90%; See Part III, Condition E.
"'The pH shall be monitoring only and results reported on the monthly reporting forms.
There shalt be no discharge of floating solids or visible foam in other than trace amounts,

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 20, 1996
MEMO' :N. T
TO: Dave Goodrich
THROUGH: Matt Matthews
FROM: Kritie Robeson
SUBJECT: R.P. Scherer Corp'
Chelsea Laboratories Facility
NPDES Permit No. NC0084344
Union Counv
By cover letter dated Dec, be 22, 1995 the Division issued the subject facilityan
NPDES Permit No, NC008L344 w 'ith an effective date of February 1, 1.996, and. expiration
date of November 30, 1995. Permit information indicates that thedischarge from this
facility is not continuous. Our office contacted Randy Kepler to verify this information.
Randy informed our office ftiat the facility discharges for approximately two hours twice a
month. This facility is permitted to conduct a chronic toxcity test at 90%; however, based.
on the nature of the dischar.de, our office recommends modifying the permit to change the
toxicity test to a 24 hour acute pass/fail limit at 90%. Through conversation with Randy,
we agreed a limit would he appropriate for this facility due to the constituents of the
discharge.
I appreciate your assistance to undertake the necessary steps to modify the exlstin
permit and incorporate the rtcornlnendations cited above. Please feel free t.a contact me, a
21.36 if =°tau have any questions.
cc: Mooresville Regional Offtc
Larry Ausley
Central Files

Facility Name:
NPDES No:
Type of Waste:
Facility Status:
Permit Status:
Receiving Stream:
Stream Classification:
Subbasin:
County:
Regional Office,:
Requestor:
Date of Request:
Topo Quad:
FACT SHEL 1 FOR WAS 1 ELOAD ALLOCATION
R.P. Scherer / Ch
NC0084344
Industrial - 1009'c
Proposed
-Prepersed- k\e,A3
UT to Ray's Fork
03-07-14
Union 47-L'
Mooresville
Goris
9/19/94
HI7NW
sea Laboi
Wasteload Allocation Summary
(approach taken, correspondence With region, EPA, etc.)
A number of halogens and volatiles were found at the site, Using a removal efficiency of 90% for
these constituents, tetrachloroethene. trichloroethene, and toluene should be limited to water quality
standards or EPA criterion. Chloroform should be monitored. A number of metals were found
above or near the water quality standards and should be limited. These include: arsenic, lead and
mercury. BETX parameters appear at the site, but only toluene was in high enough concentrations
to need a limit. A quarterly,. chronic WET test will be given as a pass/fail analysis at 90%. Ph and
Oil and Grease will be limited per current policy. The testing results submitted by the applicant
have raised concerns that other halogens may be present and were not adequately reported in the
data. Because of this it is recommended that further volatiles and base/neutral - acid. extractable
testing be performed on the effluent. It is recommended that volatiles be tested using EPA methods
601 & 602 be done quarterly and that base/neutral - acid .extractable testing be performed with 10
significant peaks identified quarterly, with the option given to discontinue testing after 12 months.
Information sent by the facility from samples collected in the plume were the basis for these
decisions.
Request #
ries
N.C. DEPT, OF
ENVIRONM EN T, HEA L TH.
& NATURAL RESOU 73
SEP Pst 1994
ENV;PM,Y:r):Ta
eoi Rfi3L'SAICFfl
Special Schedule Requirements and .additional
Recommended by:
Reviewed by
Instream Assessment:
Regional Supervisor:
.Perrnits & Engineering: -z,,,,{
Stream Characteristic: Storm Drain
USGS #
Date:
Drainage Area (mi2): >0,1
Summer 7Q10 (cfs): 0,0
Winter 7Q10 (cfs): 0,0
Average Flow (cfs): 0,0
30Q2 (cfs): 0,0
INVC (%): 100
.nts from Reviewers:
RETURN TO 'TECHNICAL, SERVICES BY:

Type of Toxicity Test:
Recommended Limit:
Monitoring Schedule:
Recommended Limits
TOXI.CS/CONVENTIONAL PARAMETERS
Chronic pass/fail using ceriodaphnia (QCL P/F)
90%
Nov, Feb, May, Aug
Mon. Avg.
Cholroform (14/1):
pH (SU):
Tetrachloroethene(fit!f1):
Toluene (µg/I):
Trichloroeth.ene(µgll):
Arsenic WO):
Mercury (µg/1):
Lead (µgll):
Oil and Grease (mg/1): 30
' i.)0.644 up): 0—( 63
Daily Max.
monitor
6-9
8.85
11
92.4
50.0
0.012
25
60
Frequency
monthly
2/month
monthly
monthly
monthly
monthly
monthly
monthly
2/month
W Q/EL
WQ
WQ
WQ
WQ
WQ
WQ
WQ
x Parameter(s) are water quality limited. For some parameters. the available load capacity of
the imrnediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
OR
No parameters are water quality limited, but this discharge may affect future allocations.
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Special Instructions or Conditions
Permit must contain flow monitoring requirement such that all volumes of wastewater leaving the
facility are monitored. Recommend continuous flow monitoring. Recommend that volatiles be
tested using EPA methods 601 & 602 be done quarterly and that base/neutral - acid extractable
testing be 'performed, with 10 significant peaks identified quarterly, with the option given to
discontinue testing after 1.2 months... This monitoring should coincide with all whole -effluent
toxicity monitoring.
A reopener clause should be placed in the permit to allow for additional limits on these or other
toxicants should the whole -effluent toxicity testing results indicate toxic effects or additional
volatileslextractables testing indicates other constituents are present.
Explain exact pathway of discharge ( i.e. storm sewer to tributary, etc.)
torte Sewver to T
Additional Information attached? (Y or N) if yes, explain with attachments.

Facility Name .
Permit # o -( ripe #C
CI -IRONIC TOXICITY PASS/FAIL PERMIT LIMIT (ORTRLY)
The. effluent discharge shall at no time, exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Cetiodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 198)) OT subsequent versions.
The effluent concentration at which there may be no observable, inhibition of reproduction or significant mortality
is Ji 70, (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
Kmarterl,v monitoring using this procedures to establish compliance with the permit condition. The first test will be
performed a ter thirty days from the effective date of this permit during the months of
NJ • • Effluent sampling for this testing shall be performed at the NPDES
pen-Muccifinal effluent discharge below all treatment processes.
All toxicity testing results required as pa of this permit condition will he entered on the. Effluent Discharge.
Monitoring Form (MR- I) for the month in which it was performed, using the parameter code TCP3B.
Additionally, DEM Forin AT-1 (original, is to be sent to the following address:
Attention: vironmental Sciences Branch
North CarolinaDivision of
Environmental .Management
1401 'Reedy Creek Road
Raleigh, N.C. 27607
Test data shall he complete and accurate and include ail supporting chemical/physical measurements performed in
association with die toxicity tests, as well as all dose/response dam. Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste, st„rearn.
Should tiny single quartet-1Y monitoring intlicate a failure, to ineet specified limits, then monthly monitoring- will
begin immediately until such time that ele test is passed. Upon passing. this montniv test requirement will
revert. to quarterly in the months specffleo. above,
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate, monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival d appropriate environmental controls„shail constitute an invalid test and will require immediate
retestin g(within 30 days of initial Irwin toinlng event). Failure to submit suitable test results will constitute
noncompliance: with monitoring requirements.
70.10
Ci
.1:101i1:1Cd HOW :VICO
C /
Basin & SU b-HJI0 /
R eiving Streain
County (I/AT:et ,rit
Recommended by:
Date
Q CL

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr,, Governor
Jonathan B. Howes, Secretary
A. Preston Howard. Jr., P.E., Director
Mr. 'Michael Cashman
R. P. Scherer Corporation
2725 Scherer Drive
Saint Petersburg, Florida 33716-101.6.
Dear Mr, Cashman:
Decernbe
REcEivED
JAN
c 1996
miiRaeo
...f,A,TAL,
Wt.ACEs
NI Pt
995
Subject: NPDES Permit No, NC0084344
R, P. Scherer Corporation
Chelsea Laboratories Facility
Union County
In accordance with your application for dischargeperinit received on July 25, 1994, the Division is
forwarding herewith the subject State - NPDES permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between
North Carolina and the U.S. Environmental Protection Agency dated December 6, 1983. In response to
a letter of September 27, 1995 from Rogers and Calicott Engineers. Inc, regarding your draft permit, the
following comments are given:
• The Division has agreed to modify the language contained in the supplementto pemit cover
sheet as sugg.ested.
• Based on the review of groundwater monitoring data. limits for these metals must remain in
your permit. However,. the Division will agree to re-evaluate these requirements after R.P.
Scherer collects 12 months of data. A 1%:\,'"ieW of groundwater monitoring data indicate that
arsenic. mercury and lead ‘vere present at levels which constitute a reasonable potential to
violate the instream standards for these parameters. Based on the treatment system proposed.
which is unlikely to provide substantial removal of metals and the concentrations documented,
it is possible that toxic impacts may occur downstream of this discharge if limits for these
metals are not met.
• A review of the pet -raft file and past data reveals oil and grease not to be a concern. The oil and
grease parameter has been removed from the effluent page.
• Modification of the pH limit from 6.0 - 9.0 SU to 5.5 - 9.0 SU is not possible. Protection of
water quality is the concern with the issuance of this permit. Based on 1.5A NCAC 2B
.0211(b)(3), the pH standard for a class C receiving stream shall range between 6.0 and 9.0
standard units. As a result, this parameter mast remain.
If any parts. measurement frequencies or sampling requirements contained in this permit are
unacceptable to you. you have the right to an adjudicative hearing upon written request within thirty (30)
days following receipt of this letter, This request must be in the form of a written petition, conforming to
Chapter 1508 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings. Post Oftice Drawer 27447„ Raleii7.h, North Carolina 27611 -7447.. Unless such demand is
made. this decision shall be final and binding.
Box 29535.. Rafeigh, North Carona .27626-0535 Telepone 919-733-7015/FAX [phone]
An Eqii,?..(7.):-pc,rtuHty AThrmative Action Ei-nploye',,r 50% pos-consumer papr

Please take notice this permit is. not transferable. Part 11, E..4. addresses the requirements to be
fallowed in case of change in ownership or control of this discharge. This permit does not affect the
legal requirements to obtain other permits which may be required by the Division of Environmental.
l'vlanagement of permits required by the Division ©f Land Resources, Coastal Area Management Act or
any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. Randy Kepler at telephone
number 919/7'33-5083 extension 544.
Sincerely,
Original Signed By
David A, Goodrich
A. Preston Howard, Jr.. P.E.
cc: Central Files
Mooresville Regional Office
Roger Pfaff, Environmental Protection Agency
Permits and Engineering Unit
Facility Assessment Unit
Aquatic Survey and Toxicology Unit
Technical Assistance and Certification Group
David Scott_ Rogers and Galleon. Engineers, [ne.

Permit - . NCO' S 4
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO D SCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliat ce rth the Tavision of North Carolina General Statute 143-215.1,
other la ful standards and re ulations promulgated and adopted by the North Carolina Environmental.
Management Commission. at d the Federal Water Pollution. Control Act, as amended,
R.P. Scherer Corporation
option to dischruuge wastewater from a
R.P. Scherer / Chelsea Laboratories Facili
202 East Roosevelt Boulevard
off US Highway 74
City of Monroe
Union County
ac
located at
to receiving waters desi_nted as an unnaned tributar ;° to lays Fork in the Yadkin.
Basin
in accordance with effluent lirmtations, monitoring requirements, and other conditions set forth in
Parts 1. 11, I11, and IV hereof.
This peanut shalbecoirit effective February 1, 1996
This permit and authorization. to discharge shall expire at rnidniglat on November d0, 1999
Signed this day Deeerri r 22, 1995
ed By
David , . Goodrich
Howard, Jr,_ P.E.. Director
Environrnen'tal Management
\'Management t.,.orninission

Permit ` �o. NC0084344
SUPPLEMENT TO PERMIT COVER SHEET
R.P. Scherer Corporation
1. Enter into a contract for construction of a wastewater treatment Sacihty,
2, Construct and operate a groundwater remediation system consisting of four
recovery wells, a 50 gpm, air stripper, a 1,400 gallon gravity settling chamber, a
pump station with duplex pumps, and an,infiltration gallery for disposal of the
treated effluent. This facility will have the option to either divert the flow to the
infiltration gallery or to discharge to the unnamed tributary to Rays Fork. The
discharge of remediated groundwater will occur from outfail 001 located at R.P.
Scherer/ Chelsea Laboratories Facility, 2021 East. Roosevelt Boulevard, of US
Highway 74, City of Monroe, Union Counry (See Part III of this Permit),
3. Bake an outlet into an unnamed tributary to Rays Fork, and
4 Discharge at the location specified on the attached map into the unnamed tributary to
Rags Fork which is classified Class C waters in the Yadkin -Pee Dee River Basin.
This permit is being issued with the understanding that R.P. Scherer Corporation's
�2eration of this groundwater remediation facility will be operated primarily as a.
non -discharge facility. If the infiltration gallery, cannot accept the remediated
goundwater due to natural conditions (i.e, high rainfall events, high groundwater
lei els, geological conditions, etc.) then authorization is given for the discharge to
the above mentioned creek for a period of time required for the infiltration gallery to
be made operable and returned to service. It should be the understanding of R.P.
Scherer Corporation that the option to discharge should be used in an overflow
situation only.

V-7 ,./../".7 ;7_,,) • :),./1()/ ,
r/-1
) 3 .40
) 5 74
4
5. 4
I 7-
0
" .17
< cn

rv_ . EFFIAINNT LIMITATIONS AND MON!1"0I INf:"r I QUII2EMI N"I'S I"IN
During ( g on the t Hccl.ivC datC tul
tal rtrttl I� r I)O1, Sttt;lt discharges shall he
EffluentCharacteristics
Flow
Arsenic
t:.:lol0r0l0rrn
Lead
Mercury
pH
Telrachloroelhene
Toluene
Trichloroethene
Chronic Toxicity ."
©ischar_ e Limitations
Units {Specify)
U.ai.I,Y _MAX,
mitNo. N I)I1 4344
.xpira(it1t, tlti Fat 1t1'littt 4. %ttttktt�rlr
ty 6.lie I'crmittee as
Monitoring Requirements
Measurement
Frequency
Sam_ple
Tyne
L_ocatiown
Continuous Recording E
50.0 a g/i Monthly Grob E
Monthly Grab 1
25.0 tag/l Monthly Grab E.
0.012 µ j(l Monthly Grab E
" 2/Month Grab E:
8.85 tag/l Monthly Grab E
t i.0 p.g/l Monthly Grab r
92,4 tag/I Monthly Grab E
Quarterly Grab L
This facility is being approved as a non -discharge facility with the option of an emergency discharge should the infiltration gallery fail to handle the load of the
treated groundwater. The monitoring requirements listed above only need to be completed upon discharge from this facility. If an actual discharge does not
occur during a month, then report such on the monthly monitoring reports. Sampling only needs to be completed at time of a discharge.
Sample Locations: E Effluent
Monitoring shall be conducted during normal work hours.
"Chronic Toxicity (Ceriodephnia) Quarterly, Pass/Fail, 90©la.; See Part ti'�i, Condition E=.
*Thee pH :,1,°4a11 not be loss than 6,0 standard units nor greater than 9,0 standard units and shill he monitored 2/month at the effluent by grab sampio.
There shall be no discharge of floating: solids or visible foam in other than trace amounts.

Part ll
Page 1 of 1.4
PART II
STANDARD CONDITIONS FOR NPDES PERT I'S
SECTION A,. DEFINITIONS
I. Permit Issuing Authori+
The Director of the Division of Enirc«n
2. ➢EM or Division
Means the Division of Environmental
Natural Resources.
Used he
4. Act or "th Act. "
ent.
anagernent, Department of Environment, Health and
s the North Carolina Envirotrnentai Management Commission.
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33
USC 1251, et. seq.
Mass/Day Measurements
a. The "'monthly average discharge" is defined as the total mass of all daily discharges
sampled and/or measured during a calendar month on which daily discharges are sampled
and measured, divided by the number of daily discharges sampled andor measured during
such month. It is therefore, an arithmetic mean found by adding the weights of the
pollutant found each day of the month and then dividing this sum by the number of days
the tests were reported. The limitation is identified as "Monthly Average" in Part I of the
permit_
b. The "weekly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar week (Sunday - Saturday) on which daily discharges
are sampled and measured, divided by the number of daily discharges sampled and/or
measured during such week. It is, therefore, an arithmetic mean found by adding the
weights of pollutants found each day of the week and then dividing this sure by the
number of days the tests were reported. This limitation is identified as "Weekly Average"
in Part I of the permit.
c. The "maximum daily discharge' i the total mass (weight) of a pollutant discharged during
a calendar day. If only one sample is taken during any calendar day U e weight of pollutant
calculated from it is the "maximum daily discharge." This limitation is identified as "Daily
Maximum," in Part I of the permit
d. The "average annual discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar year on which daily discharges are sampled and
measured, divided by the number of daily discharges sampled and/or measured during such
year. It is, therefore, an arithmetic mean found by adding the weights of pollutants found
each day of the year and then dividing this sum by the number of days the tests were
reporteed. This limitation is defined as "Annual Average" in Part I of the permit.

PART I
5ecti©n$, Schedule cif compliance
1. The perrnirtee shall comply with Final Effluent Limitations specified for discharges in
accordance with the following schedule:
Permittee shall comply with Final Effluent Limitations by the effective date of the perrnit unless
specified below.
2. Permittee shall at all times provide the operation and maintenance necessary to operate the
existing facilities at optimum efficiency.
3. No later than 14 calendar days following a date identified in the above schedule of compliance,
the permittee shall submit either a report of progress or, in the case of specific actions being
required by identified dates, a written notice of compliance or noncompliance. In the latter
case, the notice shall include the cause of noncompliance, any remedial actions taken, and the
probability of meeting the next schedule requirements.

Part II
Page 2 of 14
6. Concentration Measurement
a. The "'average monthly concentration," other than for fecal coliform bacteria, is the sum of
the concentrations of all daily discharges sampled and/or measured during a calendar month
on which daily discharges are sampled and measured, divided by the number of daily
discharges sampled and/or measured during such month (arithmetic mean of the daily
concentration values). The daily concentration value is equal to the concentration of a
composite sarnple or in the case of grab sarnples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. The average monthly count for
fecal coliform bacteria is the geometric mean of the counts for samples collected during a
calendar month. This limitation is identified as "Monthly Average" under "Other Limits" in
Part I of the permit.
b. The "average weekly concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar week
(Sunday/Saturday) on which daily discharges are sampled and measured divided by the
number of d. ily discharges sampled and/or measured during such week (arithmetic mean of
the daily concentration values). The daily concentration value is equal to the concentration
of a composite sample or in the case of grab samples is the arithmetic mean (weighted by
flow value) of all the samples collected during that calendar day. The average weekly count
for fecal coliform bacteria is the geometric mean of the counts for samples collected during
a calendar week. This limitation is identified as "Weekly Average" under "Other Limits" in
Part I of the permit.
c, The "maximum daily concentration" is the concentration of a pollutant discharge during a
calendar day. If only one sample is taken during any calendar day the concentration of
pollutant calculated from it is the "Maximum Daily Concentration". It is identified as
"Daily Maximum" under "Other Limits" in Part I of the permit.
d. The "'average annual concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar year on
which daily discharges are sampled and measured divided by the number of daily
discharges sampled and/or measured during such year (arithmetic mean of the daily
concentration values). The daily concentration value is equal to the concentration of a
composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the sarnples collected during that calendar day . The average yearly count for
fecal coliform bacteria is the geometric mean of the counts for samples collected during a
calendar year. This limitation is identified as "Annual Average" under "Other Limits" in
Part I of the permit.
e. The "daily average concentration" (for dissolved oxygen) is the minimum allowable amount
of dissolved oxygen required to be available in the effluent prior to discharge averaged
over a calendar day. If only one dissolved oxygen sample is taken over a calendar day, the
sample is considered to be the "daily average concentration" for the discharge. It is
identified as "daily average" in the text of Part L
f. The "quarterly average concentration is the average of all sat pies taken over a calendar
quarter. It is identified as "Quarterly Average Limitation" in the text of Part I of the permit.
g. A calendar quarter is defined as one of the following distinct periods: January through
March, April through June, July through September, and October through December..

urements
a. Flow, (MGD): The flow limit expressed in this permit is
averaged monthly. It is determined as the arithmetic mean of
during the calendar month.
Part II
Page 3 of 14
24 hours average flow,
otal daily flows recorded
b. An "instantaneous flow measurement" is a measure of flow taken at the time of sampling,
when both the sample and flow will be representative of the to discharge..
c. A "'continuous flow measurement" is a measure of discharge flow from the facility which
occurs continually without interruption throughout the operating hours of the facility. Flow
shall be monitored continually except for the infrequent times when there may be no flow
or for infrequent maintenance activities on the flow device.
Types ofSarnplea
a. Composite Sample: A composite sample shall consist of:
(1) a series of grab samples collected at equal time intervals over a 24 hour period of
discharge and combined proportional to the rate of flow measured at the time of
individual sample collection, or
(2) a series of grab samples of equal volume collected over a 24 hour period with the time
intervals between samples determined by a preset number of gallons passing the
sampling point. Flow measurement between sample intervals shall be determined by
use of a flow recorder and totalizer, and the present gallon interval between sample
collection fixed at no greater than 1/24 of the expected total daily flow at the treatment.
system, or
(3) a single, continuous sample collected over a 24 hour period proportional to the rate of
flow.
In accordance with (1) above, the time interval between influent grab samples shall be no
greater than once per hour, and the time interval between effluent grab samples shall be no
greater than once per hour except at wastewater treatment systems having a detention time
of greater than 24 hours. In such cases, effluent grab samples may be collected at time
intervals evenly spaced over the 24 hour period which are equal in number of hours to the
detention time of the system in number of days. However, in no case may the time interval
between effluent ,gab samples be greater than six (6) hours nor the number of samples less
than four (4) during a 24 hour sampling period.
b. Grab Sample: Grab samples are individual samples collected over a period of time not
exceeding 15 minutes; the grab sample can be taken manually. Grab samples must be
representative of the discharge or the receiving waters.
9, Calculation of ,,Mean;
a Arithmetic Mean: The arithmetic mean of any set of values is the summation of the
individual values divided by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of the product of
the individual values where N is equal to the number of individual values. The geometric
mean is equivalent to the antilog of the arithmetic mean of the logarithms of the individual
values, For purposes of calculating the geometric mean, values of zero (0) shall be
considered to be one (1).

Part II
Page 4 of 14
c. Weighted by Flow Value: Weighted by flow value means the summation of each
concentration times its respective flow divided by the summation of the respective flows.
10. Calenclar Day
A calendar day is defined as the period from midnight of one day until midnight of the next
day. However, for purposes of this permit, any consecutive 24-hour period that reasonably
represents the calendar day may be used for sampling.
11. Hazardous Substance
A hazardous substance means any substance designated under 40 CFR Part 116 pursuant to
Section 311 of the Clean Water Act.
12. TQX1C Pollutant
A toxic pollutant is any pollutant listed as toxic under Section 3 of e Clean Water Act.
SECTION B. GENERAL CO IONS
1. Pruty to Comply
The permittee must comply with all conditions of this permit. Any pelinit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit renewal
application.
a. The permittee shall comply with effluent standards or prohibitions established under
section 307(a) of the Clean Water Act for toxic pollutants and with standards for sewage
sludge use or disposal established under section 405(d) of the Clean Water Act within the
time provided in the regulations that establish these standards or prohibitions or standards
for sewage sludge use or disposal, even if the permit has not yet been modified to
incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition is subject to
a civil penalty not to exceed $25,000 per day for each violation. Any person who
negligently violates any permit condition is subject to criminal penalties of $2,500 to
$25,000 per day of violation, or imprisonment for not more than I year, or both. Any
person who knowingly violates permit conditions is subject to criminal penalties of $5,000
to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. Also,
any person who violates a permit condition may be assessed an administrative penalty not
to exceed $10,000 per violation with the rnwdmum amount not to exceed $125,000. [Ref:
Section 309 of the Federal Act 33 U.S.C. 1319 and 40 CFR 122.41 (a)j
c. Under state law, a civil penalty of not more than ten thousand dollars ($10,000) per
violation may be assessed against any person who violates or fails to act in accordance with
the terms, conditions, or requirements of a permit. [Ref: North Carolina General Statutes
§ 143-215.6AJ
d. Any person may be assessed an administrative penalty by the Administrator for violating
section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or
limitation implementing any of such sections in a permit issued under section 402 of the
Act. Administrative penalties for Class I violations are not to exceed $10,000 per violation,
with the maximum amount of any Class 1 penalty assessed not to exceed $25,000.

Part II
Page 5 of 14
Penalties for Class Il violations are not to exceed $10,000 perday for each day during
which the violation continues, with the maximum amount of any Class IT penalty not to
exceed $125,000.
2. Duty to Mitigate
The perrnittee shall take all reasonable steps to minimize or prevent any discharge or sludge use
or disposal in violation of this permit which has a reasonable likelihood of adversely affecting
human health or the environment.
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part. II, C-4) and "Power Failures"
(Part II, C-7), nothing in this permit shall be construed to relieve the permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215,3, 143-
215.6 or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is
responsible for consequential damages, such as fish kills, even though the responsibility for
effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Ljabili
Nothing in this pei mit shall be construed to preclude the institution of any legal action or relieve
the perrnittee from any responsibilities, liabilities, or penalties to which the permittee is or may
be subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal. Act, 33 USG 1321.
Furthermore, the permittee is responsible for consequential damages, such as fish kills, even
though the responsibility for effective compliance may be temporarily suspended.
5. Pro➢erty Bights.
The issuance of this permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any
invasion of personal rights, nor any infringement of Federal, State or local laws or regulations.
6. Onshore or Offshore . Construction
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
7, everability
The provisions of this permit are severable, and if any provision of this permit,. or the
application of any provision of this permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this permit, shall not be affected
thereby.
S. Duty to Provide Information
The perrnittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to determine whether cause exists
for modifying, revoking and reissuing, or terminating this permit or to determine compliance
with this permit. The permittee shall also furnish to the Permit Issuing Authority upon
request, copies of records required to be kept by this peuuhit.

Part Il
Page 6 of 14
9. o Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date
of this permit, the permittee must apply for and obtain a new permit.
10. Expiration of Permit
The permittee is not authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date, the permittee shall submit such
information, forms, and fees as are required by the agency authorized to issue permits no later
than 180 days prior to the expiration date. Any permittee that has not requested renewal at least
180 days prior to expiration, or any permittee that does not have a permit after the expiration
and has not requested renewal at least 180 days prior to expiration, will subject the permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Reg uire rtients
All applications, reports, or information submitted to the Permit Issuing Authority shall be
signed and certified.
a. All peruIit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section,
a responsible corporate officer means: (a) a president, secretary, treasurer or vice
president of the corporation in charge of a principal business function, or any other
person who performs similar policy or decision making functions for the corporation,
or (b) the manager of one or more manufacturing production or operating facilities
employing more than 250 persons or having gross annual sales or expenditures
exceeding 25 million (in second quarter 1980 dollars), if authority to sign documents
has been assigned or .delegated to the manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal
executive officer or Ong elected official.
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for
the overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority.

Part II
Page 7 of 14
c. Certification. Any person signing a document under paragraphs a. or b. of this section
shall make the following certification:
"I certify, under penalty of law, that this docurnent and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted_ Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for
knowing violations."
12. Permit Action
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a
request by the perrnittee for a peimit modification, revocation and reissuance, or ten-nination,
or a notification of planned changes or anticipated noncompliance does not stay any permit
condition.
13. Permit 'Modification, Revocation and Reissuance. or Terrnination
The issuance of this pet wit does not prohibit the permit issuing authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed
by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts
122 and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and
North Carolina General Statute 143-215.1 et. al.
14. Previous Permita
All previous National Pollutant Discharge Elimination System Permits issued to this facility,
whether for operation or discharge, are hereby revoked by issuance of this permit. [The
exclusive authority to operate this facility arises under this permit. The authority to operate the
facility under previously issued permits bearing this number is no longer effective. 1 The
conditions, requirements, terms, and provisions of this permit authorizing discharge under the
National Pollutant Discharge Elimination System govern discharges from this facility.
SECTION C, OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Certified Operator
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
treatment plant operator in responsible charge (ORC) of the wastewater treatment facilities.
Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the wastewater treatment facilities by the Certification Commission.
The permittee must also employ a certified back-up operator of the appropriate type and any
grade to comply with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility
must visit each Class I facility at least weekly and each Class II, HI, and IV facility at least
daily, excluding weekends and holidays, and must properly manage and document daily
operation and maintenance of the facility and must comply with all other conditions of Tide
15A, Chapter 8A .0202. Once the facility is classified, the permittee shall submit a letter to the
Certification Commission which designates the operator in responsible charge within thirty
days after the wastewater treatment facilities are 50% complete.

Part II
Page 8 of 14
2. Proper Op
n
nonce
The perrittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the perminee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also
includes adequate laboratory controls and appropriate quality assurance procedures. This
provision requires the operation of back-up or auxiliary facilities or similar systems which are
installed by a permittee only when the operation is necessary to achieve compliance with the
conditions of the permit.
Need So Halt Reduce nil a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
condition of this permit.
4. Bypassing of Treatrnent Facilities
a. Definitions
(1) "Bypass"" means the known diversion of waste streams from any portion of a treatment
facility including the collection system, which is not a designed or established or
operating mode for the facility.
(2) "Severe property damage" means substantial physical damage to property, damage to
the treatment facilities which causes them to become inoperable, or substantial and
permanent loss of natural resources which can reasonably be expected to occur in the
absence of a bypass. Severe property damage does not mean economic loss caused by
delays in production.
b. Bypass not exceeding limitations.
The permittee may allow any bypass to occur which does not cause effluent limitations to
be exceeded, but only if it also is for essential maintenance to assure efficient operation.
These bypasses are not subject to the provisions of Paragraphs c. and d. of this section.
c. Notice
(1) Anticipated bypass. If the permittee knows in advance of the need for a bypass, it
shall submit prior notice, if possible at least ten days before the date of the bypass;
including an evaluation of the anticipated quality and affect of the bypass.
(2) Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as
required in Pan II, E. 6. of this permit. (24 hour notice).
d. Prohibition of Bypass
(1) Bypass is prohibited and the Permit Issuing Authority may take enforcement action.
against a permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property
dam age;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes or maintenance during normal

Part Il
Page 9 of 14
periods of equipment downtime, This condition is not satisfied if adequate backup
equipment should have been installed in the exercise of reasonable engineering
judgment to prevent a bypass which occurred during normal periods of equipment
downtime or preventive maintenance; and
(C) The permittee submitted notices as required under Paragraph c. of this section.
(2) The Permit Issuing Authority may approve an anticipated bypass, after considering its
adverse affects, if the Permit Issuing Authority determines that it will meet the three
conditions listed above in Paragraph d. (1) of this section.
5. Up eta
a. Definition.
"Upset " means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the permittee. An upset does not include noncompliance
to the extent caused by operational error, improperly designed treatment facilities,
inadequate treatment facilities, lack, of preventive maintenance, or careless or improper
operation.
b. Effect of an upset.
An upset constitutes an affirmative defense to an action brought for noncompliance with
such technology based permit effluent limitations if the requirements of paragraph c, of this
condition are met. No determination made during administrative review of claims that
noncompliance was caused by upset, and before an action for noncompliance, is final
administrative action subject to judicial review.
c. Conditions necessary for a demonstration of upset,
A permittee who wishes to establish the affirmative defense of upset shall demonstrate,
through properly signed, contemporaneous operating logs, or other relevant, evidence that:
(1) An upset occurred and that the permittee can identify the cause(s) of the upset;
(2) The permittee facility was at the time being properly operated; and
(3) The permittee submitted notice of the upset as required in Part II, E. 6. (b) (B) of this
permit.
(4) The permittee complied with any remedial measures required under Part II, B. 2. of this
pemlit.
d. Burden of proof.
In any enforcement proceeding the perrnittee seeking to establish the occurrence of an upset
has the burden of proof.
6. .Rmovci.Substarices
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or
control of wastewaters shall be utilized/disposed of in accordance with NCGS 143-215.1 and in
a mariner such as to prevent any pollutant from such materials from entering waters of the State
or navigable waters of the United States. The permittee shall comply with all existing federal

Part II
Page 10 of 14
regulations governing the disposal of sewage sludge. Upon promulgation of 40 CFR Pan 503,
any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40
CFR Part 503. The permittee shall comply with applicable 40 CFR Pan 503 Standards for the
Use and Disposal of Sewage Sludge (when promulgated) within the time provided in the
regulation, even if the permit is not modified to incorporate the requirement. The permittee
shall notify the Permit Issuing Authority of any significant change in its sludge use or disposal
practices.
7. Power Fail
The permittee is responsible for maintaining adequate safeguards as required by DEM
Regulation, Title 15A, North Carolina Administrative Code, Subchapter 2H, .0124 Reliability,
to prevent the discharge of untreated or inadequately treated wastes during electrical power
failures either by means of alternate power sources, standby generators or retention of
inadequately treated effluent.
SECTIQV D. MONI'I`QRING AND RECORDS
I. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the
volume and nature of the permitted discharge. Samples collected at a frequency less than daily
shall be taken on a day and time that is characteristic of the discharge over the entire period
which the sample represents. All samples shall be taken at the monitoring points specified in
this permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority.
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month
and reported on a monthly Discharge Monitoring Report (DMR) Form (DEM No. M.R 1, 1.1, 2,
3) or alternative forms approved by the Director, DEM, postmarked no later than the 30th day
following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the
case of a new facility, on the last day of the month following the commencement of discharge.
Duplicate signed copies of these, and all other reports required herein, shall be submitted to the
following address:
Division of Environmental Management
Water Quality Section
ATTENTION: Central Files
Post Office Box 29535
Raleigh, North Carolina 27626-0535
3. flow Measurrmerlts
Appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of
the volume of monitored discharges. The devices shall be installed, calibrated and maintained
to ensure that the accuracy of the measurements are consistent with the accepted capability of
that type of device. Devices selected shall be capable of measuring flows with a maximum
deviation of less than + 10% from the true discharge rates throughout the range of expected

Part
Page 11 of 14
discharge volumes. Once -through condenser cooling water
logs, or pump hour meters as specified in Part 1 of this peen
pump curves shall not be subject to this requirement,
4. Test Procedures
ow which is monitored by pump
and based on the manufacturer's
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reportirig Acts, and to
regulations published pursuant to Section 304(g), 33 USC 1314, of the Federal. Water
Pollution Control Act, as Amended, and Regulation 40 CFR 136; or in the case of sludge use or
disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels that are below the permit discharge requirements and
all data generated must be reported down to the minimum detection or lower reporting level of
the procedure. If no approved methods are determined capable of achieving minimum
detection and reporting levels below permit discharge requirements, then the rnost sensitive
(method with the lowest possible detection and reporting level) approved method must be used.
Penalties forTarnpering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
permit shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or
by imprisonment for not more than two years per violation, or by both. If a conviction of a
person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not
more than 4 years, or both.
6. Records Retention
Except for records of monitoring information required by this permit related to the permittee's
sewage sludge use and disposal activities, which shall be retained for a period of at least five
years (or longer as required by 40 CFR 503), the permittee shall retain records of all
monitoring information, including all calibration and maintenance records and all original strip
chart recordings for continuous monitoring instrumentation, copies of all reports required by
this permit, for a period of at least 3 years from the date of the sample, measurement, report
or application. This period may be extended by request of the Director at any time.
Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the
permittee shall record the following information:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed,
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.

b.
Part II
Page 12 of 14
8. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), upon the presentation of credentials and
other documents as may be required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or
it;
conducted, or where records must be kept under the conditions of
b. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this permit;
c, Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this pei,irit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or
as otherwise authorized by the Clean Water Act, any substances or parameters at any
location.
Sl T TON E. REPOR I t.`vG REQIJIRES
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this
permit. The discharge of any pollutant identified in this permit more frequently than or at a
level in excess of that authorized shall constitute a violation of the permit_
2. Planned Changes
The permittee shall gave notice to the Director as soon as possible of any planned physical
alterations or additions to the permitted facility. Notice is required only when:
a, The alteration or addition to a permitted facility may meet one of the criteria for dete
whether a facility is a new source in 40 CFR Part 122.29 (b); or
The alteration or addition could significantly change the nature or increase the quantity of
pollutants discharged. This notification applies to pollutants which are subject neither to
effluent limitations in the permit, nor to notification requirements under 40 CFR Part 122.42
(a) (1)•
g
c. The alteration or addition results in a significant change in the permittee's sludge use or
disposal practices, and such alternation, addition or change may justify the application of
permit conditions that are different from or absent in the existing permit, including
notification of additional use or disposal sites not reported during the permit application
process or not reported pursuant to an approved Iand application plan.
Anticipat. l Noncompliance
The permittee shall give advance notice to the Director of any planned changes in the permitted
facility or activity which may result in noncompliance with permit requirements.

Part ll
Page 13 of 14
4. Transfera
This permit is not transferable to any person except after notice to the Director, The Director
may require modification or revocation and reissuance of the permittee and incorporate such
other requirements as may be necessary under the Clean Water Act.
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit.
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part H.
D. 2 of this permit) or forms provided by the Director for reporting results of monitoring of
sludge use or disposal practices.
b. If the permittee monitors any pollutant more frequently than required by the permit, using
test procedures specified in Part II, D. 4. of this permit or in the case of sludge use or
disposal, approved under 40 CFR 503, or as specified in this permit, the results of this
monitoring shall be included in the calculation and reporting of the data submitted in the
DIVER_
c. Calculations for all limitations which require averaging of measurements shall utilize an
arithmetic mean unless otherwise specified by the Director in the permit,
6. Twen,-four Hour Reporti g
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permirtee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permirtee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause; the period of noncompliance, including
exact dates and times, and if the noncompliance has not been corrected, the anticipated time
it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the noncompliance.
b. The following shall be included as information which must be reported within 24 hours
under this paragraph:
(1) Any unanticipated bypass which exceeds any effluent limitation in the permit
(2) Any upset which exceeds any effluent Limitation in the permit,
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the
Director in the permit to be reported within 24 hours,
c. The Director may waive the written report on a case -by -case basis for reports under
paragraph b. above of this condition if the oral report has been received within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Pan II. E. 5 and 6,
of this permit at the time monitoring reports are submitted. The reports shall contain the
information listed in Part II. E. 6, of this pemiit.

Part II
Page 14 of 14
her Information,.
Where the permittee becomes aware that it failed to submit any relevant facts in a permit
application, or submitted incorrect information in a permit application or in any report to the
Director, it shall promptly submit such facts or information.
9. Noncompliance Notification
The permittee shall report by telephone to either the central office or the appropriate regional
office of the Division as soon as possible, but in no case more than 24 hours or on the next
working day following the occurrence or first knowledge of the occurrence of any of the
following:
a. Any occurrence at the water pollution control facility which results in the discharge of
significant amounts of wastes which are abnormal in quantity or characteristic, such as the
dumping of the contents of a sludge digester; the known passage of a slug of hazardous
substance through the facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures of
pumps, aerators, compressors, etc.
c. Any, failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to such
station or facility.
Persons reporting such occurrences by telephone shall also file a written report in letter form
within 5 days following first knowledge of the occurrence.
10. Availability of Reports,
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of
the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be
available for public inspection at the offices of the Division of Environmental Ivlanagement. As
required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided
for in NCGS 143-215.1(b)(2) or in Section 309 of the Federal. Act.
11. Penalties for_Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per
violation, or by imprisonment for not more than two years per violation, or by both.

PART III
OTHER REQUIREMENTS
A. Construction
No construction of wastewater treatment facilities or additions to add to the plant's treatment
capacity or to change the type of process utilized at the treatment plant shall be begun until
Final Plans and Specifications have been submitted to the Division of Environmental
Management and written approval and Authorization to Construct has been issued.
B. Groundwater Monitoring
The perrnittee shall, upon written notice from the Director of the Division of Environmental
Management, conduct groundwater monitoring as may be required to determine the
cornplia_nce of this NPDES permitted facility with the current groundwater standards.
C. Changes in Discharges of Toxic Substances
The permit -tee shall notify the Permit Issuing Authority as soon as it knows or has reason to
believe:
a.That any activity has occurred or will occur which would result in the discharge, on a
routine or frequent basis, of any toxic pollutant which is not limited in the permit, if that
discharge will exceed the highest of the following "notification levels";
(1) One hundred micrograms per liter (100 ug/1);
(2)Two hundred micrograms per liter (200 ug/1) for acrolein and acrylonitrile; five
hundred micrograms per liter (500 ug/1) for 2.4-dinitrophenol and for 2-methy1-4.6-
dinitrophenol; and one milligram per liter (1 mg/1) for antimony;
(3) Five (5) times the maximum concentration value reported for that pollutant in the
permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a
non -routine or infrequent basis, of a toxic pollutant which is not limited in the permit, if
that discharge will exceed the highest of the following "notification levels";
(1) Five hundred micrograms per liter (500 ug/1);
(2) One milligram per liter (1 mg/1) for antimony;
(3) Ten (10) times the maximum concentration value reported for that pollutant in the
permit application.
D. Requirement to Continually_ Evalote Aiternatjves to Wastwater Discharges
The perrnittee shall continually evaluate all wastewater disposal alternatives and pursue the
most environmentally sound alternative of the reasonably cost effective alternatives. If the
facility is in substantial non-compliance with the terms and conditions of the NPDES permit
or governing rules, regulations or laws, the permittee shall submit a report in such form and
detail as required by the Division evaluating these alternatives and a plan of action within
sixty (60) days of notification by the Division.

r
Pan III
Permit No. NC0084344
E. CHRONIC TOXICITY PASS/FAIL PERMIT l ullT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:.
1.) The North. Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina. Chronic
Bioassay Procedure Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 90%© (defined as treatment two in the North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the pet a iit condition. The first test will be performed after thirty days from the effective date
of this permit during the months of February, May, August, and November. Effluent sampling
for this testing shall be performed at the NPDES permitted final effluent discharge below all
treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
—4-401 R.ee-dv Creek Road
Raleigh,. N.C. :27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste strearn.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitorin will begin unmediately until such ti e that a single test is passed, Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should ale:- test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control or°anism survival and appropriate environmental controls, shall. constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.

A. The
tt
ays
acco ce wi
vk the Fermi
rust pay the mm1 tenng and ct m li monitoring fee 3
being billed by the Division. Fair pay the fee timely manner
th 15A NCAC 2H .{ 1 b may cause this Dension to initiate action t

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr_ Governor
Jonathan B. Howes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 2, 1996
Mr. Michael Cashman
R.P. Scherer Corporation
2725 Scherer Drive
Saint Petersburg Florida 33716-1016
Subject: NPDES Permit No. NC0084344
Chelsea Laboratories
Facility
R.P. Scherer Corporation
Union County, NC
Dear Mr. Cashman:
Our records indicate that NPDES Permit No. NC0084344 was
issued on December 22, 1995 for the discharge of wastewater to the
surface waters of the State from your facility. The purpose of
this letter is to advise you of the importance of the Permit and
the liabilities in the event of failure to comply with the terms
and conditions of the Permit. If you have not already done so, it
is suggested that you thoroughly read the Permit. Of particular
importance is Page 4.
Page 4 sets forth the effluent limitations and monitoring
requirements for your discharge. Your discharge must not exceed
any of the limitations set forth. The section headed "Monitoring
Requirements" describes the measurement frequencies, sample types
and sampling locations. Upon commencement of your discharge (or
operation), you must initiate the required monitoring. The
monitoring results must be entered on reporting forms furnished or
approved by this Agency. If you have not received these forms,
they should be arriving shortly. If you fail to receive the forms,
please contact this Office as quickly as possible. I have enclosed
a sample of the "Effluent" reporting form (DEM Form MR-1), plus
instructions for completing the form. It is imperative that all
applicable parts be completed, and the original and one copy be
submitted as required.
Please be advised that an annual administering and compliance
monitoring fee may be required for your facility. You will soon be
receiving a statement from our Raleigh Office. It is imperative
that the fee be paid in a timely manner so as to prevent
enforcement action or possible revocation of your permit.
The remaining Parts of the Permit set forth definitions,
919 North Main Street, Mooresville, North Carolina 28115. Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1C,1;',, caosr-consumer paper

The conditions include special reporting requirements in the event
of noncompliance, bypasses, treatment unit/process failures, etc.
Also addressed are requirements for a certified wastewater
treatment plant operator if you are operating wastewater treatment
facilities. Any changes in operation of wastewater treatment
facilities, quantity and type of wastewater being treated or
discharged, expansions and/or upgrading of wastewater treatment
facilities must be permitted or approved by this Agency.
Failure to comply with the terms and conditions of an NPDES
Permit subjects the Permittee to enforcement action pursuant to
Section 143-215.6 of the North Carolina General Statutes. A civil
penalty of up to $10,000 per violation (and/or criminal penalties)
may be assessed for such violations. If you find at any time that
you are unable to comply with the terms and conditions of the
Permit, you should contact this Office immediately. A Consent
Order may be necessary while pursuing action to obtain compliance.
As a final note, an NPDES Permit is normally issued for a
five-year period. Permits are not automatically renewed. Renewal
requests must be submitted to this Agency no later than 180 days
prior to expiration. Please make note of the expiration date of
your Permit. This date is set forth on Page 1 of the Permit. Also
note that NPDES Permits are not automatically transferable. If
you, as the Permittee, cease to need this Permit, then you should
request that the Permit be rescinded or transferred t another
party, if necessary.
As mentioned previously, the purpose of this letter is to
advise you of the importance of your NPDES Permit. Please read the
Permit and contact his Office at 704/663-1699 in Mooresville if you
have any questions or need clarification. We look forward to
providing any assistance.
Sincerely,
D. Rex Gleason, P. E.
Water Quality Regional Supervisor
Enclosure
DRG:ls

L L
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management.
James B. Hunt, Jr,, Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
DecemberDecernber 22. 1995
Mr. Michael Cashman
R. P. Scherer Corporation
2725 Scherer Drive
Saint Petersburg, Florida 33711.6-1016
Subject: NPDES Permit No, NCOO84344
R. P. Scherer Corporation
Chelsea Laboratories Facility
Union County
Dear Mr. Cashman:
In accordance with your application for discharge permit received on July 25, 1994, the Division is
forwarding herewith the subject State - NPDES permit. This permit. is issued pursuant to the
requirements of North Carolina General Statute 143-215.1. and the Memorandum of Agreement between
North Carolina and the IJ.S. Environmental Protection Agency dated December 6, 1.983. In response to
a letter of September 27, 1995 from Rogers and Callcott Engineers, Inc. regarding your draft permit, the
following comments are given:
• The Division has agreed to modify the language contained in the supplement to permit cover
sheet as suggested.
• Based on the review of groundwater monitoring data, limits, for these .metals must remain in
your permit However, the Division will agree to re-evaluate these requirements after R.P.
Scherer collects 12 months of data. A review of groundwater monitoring data indicate that
arsenic, mercury and lead were present at levels which constitute a reasonable potential to
violate the .instream standards for these parameters. Based on the treatment system proposed
vhich is unlikely to provide substantial removal of metals and the concentrations documented,
it is possible that toxic impacts may occur downstream of his discharge if limits for these
metals are not met,
• A review of the permit file and past data reveals oil and grease not to be a concern. The oil and
grease parameter has been removed frorn the effluent page.
• Modification of the pH limit from. 6.0 - 9.0 SU to 5.5 - 9.0 SLY is not possible. Protection of
water quality is the concern with the issuance of this permit. Based on 15A NCAC 2B
.0211.(b)(3), the pH standard for a class C receiving stream shall range between 6.0 and 9.0
standard units. As a result, this parameter must. remain.
If any parts. measurement frequencies or sampling requirement's contained in this permit are
unacceptable to you. you have the right to an adjudicative hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 1.5013 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings. Post Office Drawer 27447, Raleigh, North Carolina 27611 -7447. Unless such demand is
made, this decision shall be final and binding.
P.0„ Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]/FAX [phone]
An Eglia Opportunity AfflunaAive Acton Employer so% recycedi 10% post -consumer paper

'it in t 1,
'gtrirect
p
ref` chaneeinrownersliip or contr
nt . to •obtain other perrrtit wwh
nt car pernritxrequired h ° the i iw ist rn
Federal :or:Local pXerrmental pernit that.
Part I1, . . addr`e '«es
crf this di cha ee, This permit
ay h: required -by the Division
and Resources, C '-',oustal Area Manage
ay be required,
the
ent.l
ent Act or
u have any questions concerning this permit, please contact Mr. ands Kepler at telephone
ru tal r 919/733-5083 extension 544.
Files
illy Regi al Office
Rog Pfaff,. Etn,1 - nmental Protect n Agency
Peril rits and Engineering Unit
Facility ,ess ent Unit
,Agcr btic Survey and Toxicology Unit
Technical Assistance and Certification imp
on. Rogers and Callc tt Engi Inc
Sincere!w;
Original Sigtna
paid k Gone
A. Preston Howard, Jr., P, ,

Permit No, NC( S4344
STATE F NORTH CAR LI A
DEPART ENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION F ENVIRONMENTAL MANAGEMENT
in ctirrrplian
other lawful
\lama rarr
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
c with the provision ofNorth Can in . General Statute -21 .1,
andards and regulations promulgated and adoptedby the North Carolina Ert ircann
Commission, and the Federal Water Pollution Control .Act, as amended,
ri.d to f.
R P. Scherer Corporation
rlr option to disclaar4 taste ater from a facility, located at
RP, Schercr / lads a Laboratories Facility
2021 Fast Roosevelt Boule‘ard
off US Highway 74
"its of Monroe
Union Count
s design d as unnamed trilatrtar x to Rays Fork
adls
Pee t ccRiver
cordark.'e v itlr effirtent limitations, na nitorm require raacnts, and other et diti:tans sci fort
Parents 1. llti lll, and 1 '" hereof
This permit 'laa.11 become of fectirr lebruary1, 1996
`l"hi pernnt farad aut acariation to
Si
ncd this
dig
1
expire at midnight on Normla 30, 1999
ri Ir# I Signed By
rrrd, Jr,®
am °ntal
AFC
Cottrraa

Permit To. NC0084344
SUPPLEMENT TO PERMIT COVER SHEET
R.P. Scherer Corporation
is hereby authorized to:
Enter into a contract for construction of a wastewater treatrnent facility,
Construct and operate a groundwater remediation system consisting of four
recovery wells, a 50 gpm air stripper, a 1,400 gallon gravity settling chamber, a
pump station with duplex pumps, and an infiltration gallery for disposal. of the
treated effluent. This facility will have the option to either divert the flow to the
infiltration gallery or to discharge to the unnamed tributary to Rays Fork. The
discharge of remediated groundwater will occur from outfall 001 located at R.P.
Scherer / Chelsea. Laboratories Facility, 2021 East Roosevelt Boulevard, of US
Highway 74, City of Monroe, Union County (See Pan III of this Permit),
3. Make an outlet into an unnamed tributary to Rays Fork, and
4 Discharge at the location specified on the attached map into the unnamed tributary to
Rays Fork which is classified. Class C waters in the Yadkin -Pee Dee River Basin,
5. This permit is being issued with the understanding that R.P. Scherer Corporation's
operation of this groundwater remediation facility will he operated primarily as a
non -discharge facility. If the infiltration gallery cannot accept the remediated
groundwater due to natural conditions (i.e. high rainfall events, high groundwater
levels, geological conditions, etc,) then autharir.ation is given for the discharge to
the above mentioned creek for a period of time required for the infiltration gallery to
be made operable and returned to service. It should be the understanding of R.P.
Scherer Corporation that the option to discharge should he used in an overflow
situation only.

STATES
DEF'AI.?.. MENT OF 1.,.FIf=°: INTERIOR'
C OGICAL SURVEY
1-I 7N'W

A. O. EFFLUENT NT LI UI'ATEONS AND +; Niro :G RE QCJIRE 7,NTS FINAL ertnit No. NCI 4344
During the period beginning on the ell :tivc date oft.hc. Permit
it expiration, the Pc -mince is authorized to discliargc from
o1ll a1i(s'serial number (It)f Such disch trgcs shall he Iit sited and mot itowt by the Peree as specified below:
Effluent Characteristics
f loawr
Arsen%c
Chloroform
Lead
Mercury
PH
Tetrachloroethene
Toluene
Trichloro ethene
Chronic Toxicity ..
Discharge Lfmitati©ns
M.Qnf.hIy __Avg. Daily Ma:X,
Measureme,nt
F.regyVAL. cY
Continuous
50.0 p g/ I Monthly
Monthly
25.0 µg/I Monthly
0.012 µg/I Monthly
•2/Month
8.65 µg/I Monthly
11.0 fig/I Monthly
92.4 pg/I Monthly
Quarterly
Monitoring . Requirements
Sample *S_ample
P e Lq c_a t..ii
Recording E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
This facility is being approved as a non -discharge facility with the option of an emergency discharge should the infiltration gaIfery fail to handle the load of the
treated groundwater. The monitoring requirements listed above only need to be completed upon discharge from this facility. If an actual discharge does not
occur during a month, then report such on the monthly monitoring reports, Sampling only needs to be completed at time of a discharge.
" Sample Locations: E - Effluent
Monitoring shall be conducted during normal work hours,
"Chronic Toxicity (Ceriodaphnia) Quarterly, Pass/Fail, 90%; See Part III, Condition E,
***The pH shall not be less than 6,0 standard units nor greater than 9,0 standard units and shall be monitored 2/month at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Section B. Schedule of Compliance
1. The perm, shall comply with Final Effluent L a it tions
ce ° the following schedule:
2. P
existing
e:
red for
sh ' e: ply With Final Effluent ° "tads by e tie date of
shall at times prov theoperation
es at optimumefficiency.
ad tnainten ce necess
*scharge
Less
o operate
No later th 14 calendar ys following a datea ntift in the above schedule
the pemuttee shall submit either a report of pm ss or, in e case of specific
required by identified dates, a written notice of compliance or n ncompliance
case, the notice shallincludethe cause of noncompliance, any rein . `al actions
pmbability of meetiiig the next schedule req eats.
taf comp ` ce,
actions being
In the latter
en, and the

Part II
Page 1 of 14
PART H
STANDARD CON MO S FOR NPDES PE RI I"I"S
SECTION A. DEFINITIONS
1. Remit ;Issuing Authority
The Director of the Division of Environmental
2. BEM or Dlyisipn
n
Means the Division of Environmental Management, Department of Environment, Health and
Natural Resources,
3..
Used herein means the North Carolina Environmental Management Commission.
4. Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33
USC 1251, et, seq.
5. Mass/Day Measurements
a. The "monthly average discharge" is defined as the total mass of all daily discharges
sampled and/or measured during a calendar month on which daily discharges are sampled
and measured, divided by the number of daily discharges sampled and/or treasured during
such month. It is therefore, an arithmetic mean found by adding the weights of the
pollutant found each day of the month and then dividing this sum by the number of days
the tests were reported. The limitation is identified as "Monthly Average" in Part I of the
permit.
b. The "weekly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar week (Sunday - Saturday) on which daily discharges
are sampled and measured, divided by the number of daily discharges sampled and/or
measured during such week. It is, therefore, an arithmetic mean found by adding the
weights of pollutants found each day of the week and then dividing this sum by the
number of days the tests were reported. This limitation is identified as "Weekly Average"
in Part I of the permit.
c. The "maximum daily discharge" is the total mass (weight) of a pollutant discharged during
a calendar day. If only one sample is taken during any calendar day the weight of pollutant
calculated from it is the "maximum daily discharge." This limitation is identified as "Daily
Maximum," in. Part I of the permit.
d. The "average annual discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar year on which daily discharges are sampled and
measured, divided by the number of daily discharges sampled and/or measured during such.
year. It is, therefore, an arithmetic mean found by adding the weights of pollutants found
each day of the year and then dividing this sum by the number of days the tests were
reported. This limitation is defined as "Annual Average" in Part I of the permit.

Part II
Page 2 of 14
6. Concentration Measurer rent
a, The "average monthly concentration," other than for fecal coliform bacteria, is the sum of
the concentrations of all daily discharges sampled and/or measured during a calendar month
on which daily discharges are sampled and measured, divided by the number of daily
discharges sampled and/or measured during such month (arithmetic mean of the daily
concentration values). The daily concentration value is equal to the concentration of a
composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. The average monthly count for
fecal coliform bacteria is the geometric mean of the counts for samples collected during a
calendar month. This limitation is identified as "Monthly Average" under "Other Limits" in
Part I of the permit.
b. The "average weekly concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar week
(Sunday/Saturday) on which daily discharges are sampled and measured divided by the
number of daily discharges sampled and/or measured during such week (arithmetic mean of
the daily concentration values). The daily concentration value is equal to the concentration
of a composite sample or in the case of grab samples is the arithmetic mean (weighted by
flow value) of all the samples collected during that calendar day, The average weekly count
for fecal coliform bacteria is the geometric mean of the counts for samples collected during
a calendar week. This limitation is identified as "Weekly Average" under "Other Limits" in
Part I of the permit.
c. The "maximum daily concentration" is the concentration of a pollutant discharge during a
calendar day. If only one sample is taken during any calendar day the concentration of
pollutant calculated from it is the "Maximum Daily Concentration". It is identified as
"Daily Maximum" under "Other Limits" in Part I of the permit.
d. The "average annual concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar year on
which daily discharges are sampled and measured divided by the number of daily
discharges sampled and/or measured during such year (arithmetic mean of the daily
concentration values). The daily concentration value is equal to the concentration of a
composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day . The average yearly count for
fecal conform bacteria is the geometric mean of the counts for samples collected during a
calendar year. This limitation is identified as "Annual Average" under "Other Limits" in
Part I of the permit.
e. The "daily average concentration" (for dissolved oxygen) is the mirumum allowable amount
of dissolved oxygen required to be available in the effluent prior to discharge averaged
over a calendar day. If only one dissolved oxygen sample is taken over a calendar day, the
sample is considered to be the "daily average concentration" for the discharge. It is
identified as "daily average" in the text of Part I.
f The "quarterly average concentration" is the average of all samples taken over a calendar
quarter. It is identified as "Quarterly Average Limitation" in the text of Part I of the permit.
g. A calendar quarter is defined as one of the following distinct periods: January through
March, April through June, July through September, and October through December.

Part II
Page 3 of 14
7. Other Measureemenls
a. Flow, (MGD): The flow limit expressed in this permit is the 24 hours average flow,
averaged monthly. It is determined as the arithmetic mean of the total daily flows recorded
during the calendar month.
b. An "instantaneous flow measurement" is a measure of flow taken at the time of sampling,
when both the sample and flow will be representative of the total discharge.
c. A "continuous flow measurement" is a measure of discharge flow from the facility which
occurs continually without interruption throughout the operating hours of the facility. Flow
shall be monitored continually except for the infrequent times when there may be no flow
or for infrequent maintenance activities on the flow device.
8. Types of Samples
a. Composite Sample: A composite sample shall consist of:
(1) a series of grab samples collected at equal time intervals over a 24 hour period of
discharge and combined proportional to the rate of flow measured at the time of
individual sample collection, or
(2) a series of grab samples of equal volume collected over a 24 hour period with the time
intervals between samples determined by a preset number of gallons passing the
sarnpling point. Flow measurement between sample intervals shall be determined by
use of a flow recorder and totalizer, and the present gallon interval between sample
collection fixed at no greater than 1/24 of the expected total daily flow at the treatment
system, or
(3) a single, continuous sample collected over a 24 hour period proportional to the rate of
flow.
In accordance with (1) above, the time interval between influent grab samples shall be no
greater than once per hour, and the time interval between effluent grab samples shall be no
greater than once per hour except at wastewater treatment systems having a detention time
of greater than 24 hours. In such cases, effluent grab samples may be collected at time
intervals evenly spaced over the 24 hour period which are equal in number of hours to the
detention time of the system in number of days. However, in no case may the time interval
between effluent grab samples be greater than six (6) hours nor the number of samples less
than four (4) during a 24 hour sampling period.
b. Grab Sample: Grab samples are individual samples collected over a period of time not
exceeding 15 minutes; the grab sample can be taken manually. Grab samples must be
representative of the discharge or the receiving waters.
9. C'alculatio of Means
a Arithmetic Mean: The arithra etic mean of arty set of values is the summation of the
individual values divided by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of the product of
the individual values where N is equal to the number of individual values. The geometric
mean is equivalent to the antilog of the arithmetic mean of the logarithms of the individual
values. For purposes of calculating the geometric mean, values of zero (0) shall be
considered to be one (1).

Part II
Page 4 of 14
c. Weighted by Flow Value: Weighted by flow value means the summation of each.
concentration times its respective flow divided by the summation of the respective flows.
10. Calendar Dav
A calendar day is defined as the period from midnight of one day until midnight of the next
day. However, for purposes of this permit, any consecutive 24-hour period that reasonably
represents the calendar day may be used for sampling.
11. Hazardous Substance
A hazardous substance means any substance designated under 40 CFR Part 116 pursuant to
Section 311 of the Clean Water Act.
12. f'olluta�rtt
A toxic pollutant is any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
LECTION B. GENERALCONpmoNS
1. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit renewal
application.
a. The permittee shall comply with effluent standards or prohibitions established under
section 307(a) of the Clean Water Act for toxic pollutants and with standards for sewage
sludge use or disposal established under section 405(d) of the Clean Water Act within the
time provided in the regulations that establish these standards or prohibitions or standards
for sewage sludge use or disposal, even if the permit has not yet been modified to
incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition is subject to
a civil penalty not to exceed $25,000 per day for each violation. Any person who
negligently violates any permit condition is subject to criminal penalties of $2,500 to
$25,000 per day of violation, or imprisonment for not more than 1 year, or both. Any
person who knowingly violates permit conditions is subject to criminal penalties of $5,000
to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. Also,
any person who violates a permit condition may be assessed an administrative penalty not
to exceed $10,000 per violation with the maximum amount not to exceed $125,000. [Ref:
Section 309 of the Federal Act 33 U.S.C. 1319 and 40 CFR 122.41 (a)]
c, Under state law, a civil penalty of not more than ten thousand dollars ($10,000) per
violation may be assessed against any person who violates or fails to act in accordance with
the terms, conditions, or requirements of a permit. [Ref: North Carolina General Statutes
§ 143-215.6A]
d. Any person may be assessed an administrative penalty by the Administrator for violating
section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or
limitation implementing any of such sections in a permit issued under section 402 of the
Act. Adrninistrative penalties for Class I violations are not to exceed $10,000 per violation,
with the maximum amount of any Class I penalty assessed not to exceed $25,000.

Part Il
Page 5 of 14
Penalties for Class H violations are not to exceed $10,000 per day for each day during
which the violation continues, with the maximum amount of any Class LI penalty not to
exceed $125,000.
2. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use
or disposal in violation of this permit which has a reasonable likelihood of adversely affecting
human health or the environment.
3. Civil and Criminal Liability
Except as provided in permit conditions on "'Bypassing" (Part II, C-4) and "Power Failures"
(Part II, C-7), nothing in this permit shall be construed to relieve the permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-
215.6 or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is
responsible for consequential damages, such as fish kills, even though the responsibility for
effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may
be subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321.
Furthermore, the permittee is responsible for consequential damages, such as fish kills, even
though the responsibility for effective compliance may be temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any
invasion of personal rights, nor any infringement of Federal, State or local laws or regulations.
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
7. Severability
The provisions of this permit are severable, and if any provision of this permit, or the
application of any provision of this permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this permit, shall not be affected
thereby.
8. Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to determine whether cause exists
for modifying, revoking and reissuing, or terminating this permit or to determine compliance
with this permit. The permittee shall also furnish to the Permit Issuing Authority upon
request, copies of records required to be kept by this permit.

Part II
Page 6 of 14
9.
to Re
If the permittee wishes to continue an activity regulated by this permit after the expiration date
of this permit, the permi
10. Exp.. tion of Pern)u
The permittee is not authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date, the permittee shall submit such
information, forms, and fees as are required by the agency authorized to issue permits no later
than 180 days prior to the expiration date. Any permittee that has not requested renewal at least
180 days prior to expiration, or any permittee that does not have a permit after the expiration
and has not requested renewal at least 180 days prior to expiration, will subject the permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
l I. $ignatpry Requirement
ust apply for and obtain a new permit.
All applications, reports, or information submitted to the Permit Issuing Authority shall be
signed and certified.
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section,
a responsible corporate officer means: (a) a president, secretary, treasurer or vice
president of the corporation in charge of a principal business function, or any other
person who performs similar policy or decision making functions for the corporation,
or (b) the manager of one or more manufacturing production or operating facilities
employing more than 250 persons or having gross annual sales or expenditures
exceeding 25 million (in second quarter 1980 dollars), if authority to sign documents
has been assigned or delegated to the manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal
executive officer or ranking elected official.
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for
the overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
The written authorization is submitted to the Permit Issuing Authority.
(

Part II
Page7of 14
Certification. Any person signing a document under paragraphs a. or b. of this section
shall make the following certification:
"I certify, under penalty of law, that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for
knowing violations,"
12. permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a
request by the permittee for a permit modification, revocation and reissuance, or termination,
or a notification of planned changes or anticipated noncompliance does not stay any permit
condition.
13. Permit . Modification. Revocation and Reissuance. or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the perrnit as allowed
by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts
122 and 123; Title 15A of the North Carolina Adrninistrative Code, Subchapter 2H .0100; and
North Carolina General Statute 143-215.1 et. al.
14. Previous Permits,
All previous National. Pollutant Discharge Elimination System Permits issued to this facility,
whether for operation or discharge, are hereby revoked by issuance of this permit. [The
exclusive authority to operate this facility arises under this permit. The authority to operate the
facility under previously issued permits bearing this number is no longer effective. ] The
conditions, requirements, terms, and provisions of this permit authorizing discharge under the
National Pollutant Discharge Elimination System govern discharges from this facility.
5EEC TON C, OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Certified Operatot
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
treatment plant operator in responsible charge (ORC) of the wastewater treatment facilities.
Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the wastewater treatment facilities by the Certification Commission.
The permittee must also employ a certified back-up operator of the appropriate type and any
grade to comply with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility
must visit each Class 1 facility at least weekly and each Class II, III, and IV facility at least
daily, excluding weekends and holidays, and must properly manage and document daily
operation and maintenance of the facility and must comply with all other conditions of Title
15A, Chapter 8A .0202. Once the facility is classified, the permittee shall submit a letter to the
Certification Commission which designates the operator in responsible charge within thirty
days after the wastewater treatment facilities are 50% complete.

Part li
Page 8 of 14
2. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the permittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also
includes adequate laboratory controls and appropriate quality assurance procedures. This
provision requires the operation of back-up or auxiliary facilities or similar systems which are
installed by a permittee only when the operation is necessary to achieve compliance with the
conditions of the permit.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
condition of this permit.
4. Bypassing of Treatment_ Faejliti s
a. Definitions
(1) "Bypass" means the known diversion of waste streams from any portion of a treatment
facility including the collection system, which is not a designed or established or
operating mode for the facility.
(2) "Severe property damage" means substantial physical damage to property, damage to
the treatment facilities which causes them to become inoperable, or substantial and
permanent loss of natural resources which can reasonably be expected to occur in the
absence of a bypass. Severe property damage does not mean economic loss caused by
delays in production.
b. Bypass not exceeding limitations.
The permittee may allow any bypass to occur which does not cause effluent limitations to
be exceeded, but only if it also is for essential maintenance to assure efficient operation.
These bypasses are not subject to the provisions of Paragraphs c. and d. of this section.
c. Notice
(1) Anticipated bypass. If the permittee knows in advance of the need for a bypass, it
shall submit prior notice, if possible at least ten days before the date of the bypass;
including an evaluation of the anticipated quality and affect of the bypass.
(2) Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as
required in Part II, E. 6. of this permit. (24 hour notice).
d. Prohibition of Bypass
(1) Bypass is prohibited and the Permit Issuing Authority may take enforcement action
against a permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property
damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes or maintenance during normal

Part II
Page 9 of 14
periods of equipment downtime. This condition is not satisfied if adequate backup
equipment should have been installed in the exercise of reasonable engineering
judgment to prevent a bypass which occurred during normal periods of equipment
downtime or preventive maintenance; and
(C) The permittee submitted notices as required under Paragraph c. of this section.
(2) The Permit Issuing Authority may approve an anticipated bypass, after considering its
adverse affects, if the Permit Issuing Authority determines that it will meet the three
conditions listed above in Paragraph d. (1) of this section.
5. Upsets
a. Definition,
"Upset " means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the permittee. An upset does not include noncompliance
to the extent caused by operational error, improperly designed treatment facilities,
inadequate treatment facilities, lack of preventive maintenance, or careless or improper
operation.
b. Effect of an upset.
An upset constitutes an affirmative defense to an action brought for noncompliance with
such technology based permit effluent limitations if the requirements of paragraph c. of this
condition are met. No determination made during administrative review of claims that
noncompliance was caused by upset, and before an action for noncompliance, is final
administrative action subject to judicial review,
c. Conditions necessary for a demonstration of upset.
A permittee who wishes to establish the affirmative defense of upset shall demonstrate,
through properly signed, contemporaneous operating logs, or other relevant evidence that:
(1) An upset occurred and that the permittee can identify the cause(s) of the upset;
(2) The permittee facility was at the time being properly operated; and
(3) The permittee submitted notice of the upset as required in Part II, E. 6. (b) (B) of this
permit.
(4) The permute complied with any remedial me ana es requ rcd under Part II, B. 2. of this
permit..
d. Burden of proof.
In any enforcement proceeding the permittee seeking to establish the occurrence of an upset
has the burden of proof.
6. Removed ubstances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or
control of wastewaters shall be utilized/disposed of in accordance with. NCGS 143-215.1 and in
a manner such as to prevent any pollutant from such materials from entering waters of the State
or navigable waters of the United States. The permittee shall comply with all existing federal

Part
Page 1©of 1.4
regulations governing the disposal of sewage sludge. Upon promulgation of 40 CFR Part 503,
any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40
CFR Part 503. The permittee shall comply with applicable 40 CFR Part 503 Standards for the
Use and Disposal of Sewage Sludge (when promulgated) within the time provided in the
regulation, even if the permit is not modified to incorporate the requirement. The perrnittee
shall notify the Permit Issuing Authority of any significant change in its sludge use or disposal
practices.
7. Power Failures
The perrnittee is responsible for maintaining adequate safeguards as required by DEM
Regulation, Title ISA, North Carolina Administrative Code, Subchapter 2H, .0124 Reliability,
to prevent the discharge of untreated or inadequately treated wastes during electrical power
failures either by means of alternate power sources, standby generators or retention of
inadequately treated effluent.
SECTION D. MONITORING AND RECORDS,
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the
volume and nature of the permitted discharge. Samples collected at a frequency less than daily
shall be taken on a day and time that is characteristic of the discharge over the entire period
which the sample represents. All samples shall be taken at the monitoring points specified in
this permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority.
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month
and reported on a monthly Discharge Monitoring Report (DMR) Forrn (DEM No. MR 1,1.1, 2,
3) or alternative forms approved by the Director, DEM, postmarked no later than the 30th day
following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the
case of a new facility, on the last day of the month following the commencement of discharge.
Duplicate signed copies of these, and all other reports required herein, shall be submitted to the
following address:
Division of Environmental Management
Water Quality Section
ATTENTION: Central Files
Post Office Box 29535
Raleigh, North Carolina 27626-0535
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of
the volume of monitored discharges. The devices shall be installed, calibrated and maintained
to ensure that the accuracy of the measurements are consistent with the accepted capability of
that type of device. Devices selected shall be capable of measuring flows with a maximum
deviation of less than + 10% from the true discharge rates throughout the range of expected

Part II
Page 11 of 14
discharge volumes. Once -through condenser cooling water flow which is monitored by pump
logs, or pump hour meters as specified in Part I of this permit and based on the manufacturer's
pump curves shall not be subject to this requirement.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to
regulations published pursuant to Section 304(g), 33 USC 1314, of the Federal Water
Pollution Control Act, as Amended, and Regulation 40 CFR 136; or in the case of sludge use or
disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels that are below the permit discharge requirements and
all data generated must be reported down to the minimum detection or lower reporting level of
the procedure. If no approved methods are determined capable of achieving minimum
detection and reporting levels below permit discharge requirements, then the most sensitive
(method with the lowest possible detection and reporting level) approved method must be used
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
permit shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or
by imprisonment for not more than two years per violation, or by both. If a conviction of a
person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not
more than 4 years, or both.
6. Records Retention
Except for records of monitoring information required by this permit related to the perrnittee's
sewage sludge use and disposal activities, which shall be retained for a period of at least five
years (or longer as required by 40 CFR 503), the permittee shall retain records of all
monitoring information, including all calibration and maintenance records and all original strip
chart recordings for continuous monitoring instrumentation, copies of all reports required by
this permit, for a period of at least 3 years from the date of the sample, measurement, report
or application. This period may be extended by request of the Director at any time.
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the
perminee shahl record the following information:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.

Part II
Page 12 of 14
8. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), upon the presentation of credentials and
other documents as may be required by law, to;
a. Enter upon the permittee's premises where a regulated facility activity is lured or
conducted, or where records must be kept under the conditions of t1"tis perrtrit;
b. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this permit;
c. Inspect at reasonable tines any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and
d. Sarnple or monitor at reasonable times, for the purposes of assuring permit compliance or
as otherwise authorized by the Clean Water Act, any substances or parameters at any
location.
�1 CTlON E. REPORTINQ REQUIREMENTS,
1. ange in, Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this
permit. The discharge of any pollutant identified in this permit more frequently than or at a
level in excess of that authorized shall constitute a violation of the permit.
2. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned physical
alterations or additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for determining
whether a facility is a new source in 40 CFR Part 122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of
pollutants discharged, This notification applies to pollutants which are subject neither to
effluent limitations in the permit, nor to notification requirements under 40 CFR Part 122.42
(a) (1).
c. The alteration or addition results in a significant change in the permittee's sludge use or
disposal practices, and such alternation, addition or change may justify the application of
permit conditions that are different from or absent in the existing permit, including
notification of additional use or disposal sites not reported during the permit application
process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes in the permitted
facility or activity which may result in noncompliance with permit requirements.

Part II
Page 13 of 14
4. Transfera
This permit is not transferable to any person except after notice to the Director. The Director
may require modification or revocation and reissuance of the permittee and incorporate such
other requirements as may be necessary under the Clean Water Act.
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit.
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part IL
D. 2 of this permit) or forms provided by the Director for reporting results of monitoring of
sludge use or disposal practices.
b. If the permittee monitors any pollutant more frequently than required by the permit, using
test procedures specified in Part II, D. 4. of this permit or in the case of sludge use or
disposal, approved under 40 CFR 503, or as specified in this permit, the results of this
monitoring shall be included in the calculation and reporting of the data submitted in the
DMR
c. Calculations for all limitations which require averaging of measurements shall utilize an
arithmetic mean unless otherwise specified by the Director in the permit
6. Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause; the period of noncompliance, including
exact dates and times, and if the noncompliance has not been corrected, the anticipated time
it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the noncompliance.
b. The following shall be included as information which must be reported within 24 hours
under this paragraph:
(1) Any unanticipated bypass which exceeds any effluent limitation in the permit.
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the
Director in the permit to be reported within 24 hours.
c. The Director may waive the written report on a case -by -case basis for reports under
paragraph b. above of this condition if the oral report has been received within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Part 11. E. 5 and 6.
of this permit at the time monitoring reports are submitted. The reports shall contain the
information listed in Part II. E. 6. of this permit.

Part II
Page 14 of 14
8. Other Info rrnatipt
Where the permittee becomes aware that it failed to submit any relevant facts fn a permit
application, or submitted incorrect information in a permit application or in any report to the
Director, it shall promptly submit such facts or information.
9. Noncompliance Notification
The permittee shall report by telephone to either the central office or the appropriate regional
office of the Division as soon as possible, but in no case more than 24 hours or on the next
working day following the occurrence or first knowledge of the occurrence of any of the
following:
a. Any occurrence at the water pollution control facility which results in the discharge of
significant amounts of wastes which are abnormal in quantity or characteristic, such as the
dumping of the contents of a sludge digester; the known passage of a slug of hazardous
substance through the facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures of
pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to such
station or facility.
Persons reporting such occurrences by telephone shall also file a written report in letter form
within 5 days following first knowledge of the occurrence.
la. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of
the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be
available for public inspection at the offices of the Division of Environmental Management- As
required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided
for in NCGS 143-2L5.1(b)(2) or in Section 309 of the Federal Act.
. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per
violation, or by imprisonment for not more than two years per violation, or by both.

4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non -discharge options available. Please provide
regional perspective for each option evaluated,
Spray Irrigation: Insufficient land area available for a
spray irrigation system.
Connection to Regional Sewer System: The City of Monroe does
not accept treated groundwater to its sewer system.
Subsurface.: An infiltration gallery is included in the
proposed groundwater remediation system. The facility only
discharges excess (treated) groundwater when it is necessary.
Other Disposal Options: N/A.
5. Air Quality and/or Groundmater concerns or hazardous materials
utilized at this facility that may impact water quality, air
quality or groundwater? The proposed treatment facility is to
remediate groundwater that has been contaminated with diesel
fuel and tetrachloroethene. Contaminated groundwater will be
properly treated prior to discharging to a storm water culvert
under Hasty Street in the City of Monroe. The storm drain may
enter Rays Fork, Class C waters in the Yadkin -Pee Dee River
basin. No hazardous materials are used at this facility.
Impacts, if any, on the environment will be minimal.
6, Other Special Items: None.
PART IV - EVALUATION AND RECOMMENDATIONS
R. P. Scherer Corporation requests an NPDES Discharge Permit
for the discharge of treated groundwater from a proposed
groundwater remediation facility. Groundwater has been
contaminated with diesel fuel and tetrachloroethene. The property
an which the proposed remediation facility is to be located was
acquired by Chelsea Laboratories, Inc. of Monroe from Scherer
Corporation in January, 1986, Currently, Chelsea Laboratories,
Inc. manufactures medicine tablets.
The proposed groundwater remediation facility will consist of
four (4) pumping/recovery wells, an air stripping unit, a gravity
settling chamber, finished water pump station, a shallow injection
well, an infiltration gallery, and a number of monitoring wells.
Treated groundwater will be discharged into the infiltration
gallery. However, excess (treated) groundwater is to be piped and
discharged to a storm water culvert under Hasty Street in the City
of Monroe. The storm drainage ditch may enter Rays Fork, Class C
NPDES Permit Staff Report
Version 1Q/92
Page 4

waters in the Yadkin Pee -Dee River Basin.
Pending final review and concurrence by the SERGd and the
approval by the North Carolina Department of Transportation and/or
by the City of Monroe for discharging treated groundwater to the
culvert/storm drain, it is recommended that the subject request be
approved and an NPDES Discharge Permit (with a monitoring
requirement for acute toxicity, if necessary) be issued to the
applicant,
Signature f Report Preparer
e7
Water Qualmty Regio Supervisor
Date
NPDES Permit Staff Report
Version 10/92
Page 5

UNITED STATES
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
4600°"' [ '41
a-{ 7 N'

RATING SCALE FOR CLASSIFICATION OF WATER POLLUTION CONTROL SYSTEMS
Name of Facility:
Owner or Contact
Mailing Address:
County:
P.
Person:
rQi7
Present Classification:.
NPDES Per. No. NCOO
Rated by:
Reviewed by:
Telephone:
New Facility
_ Nondisc. Per, No.WQ
Telephone: (7441 a3 -40? Date: B
Health Dept.
Regional Office
Central Office
Existing Facility
Hearth Dept.Per No.
Telephone:
Telephone:
Telephone:
ORC: Grade: Telephone:
on Land Application
IV Total Points: ! ..
Check Classification(s):
Wastewater Classification:
Ciro
Subsurface
One)
S&$SLFdAIE C LASStFICATION
(check all units that apply)
1 septic tanks
2 Pimp tanks
3. siphon or pump -dosing systems
4 sand filters
5, grease traMerceptor
6, on/water separators
7 gravity subsurface treatment and d ID:tea .
O. , pressure subsurface treatment and disposal;
In
be
addition to the 'bore
fated using the point
Spray irrig
Ill
SPRAY IRF03ACLASSIFICATION
(chock as units that apply)
preliminary treatment (definition no. 32 )
2. lagoons
3 septic tanks
4 pump tanks
5. , tamps
6 , sand filters
7, sgresse trapliMeroeplor
S. oillwater separators
e, disinfection
10.chrrrmic*/ arddltian for nutrient/a/gas oordrol
11. spray Irrigation of wastewater
classifications, pretreatment of wastewater In excess of these
rating system and will require an operstor with an appropriate
LAND APPLICATION/RESIDUALS CLASSIFICATION (Applies only to permit holder)
1. Land application Of biooalids, residuals or contaminated soils on a designated elle.
WASTEWATER TREATMENT FACILITY CLASSIFCATICti
The fo&owing systems stun be assigned a Oleos I class '
complex, to require consideration by the Co/maskrro on a cs r y
1, „Oitlwater Separator Systems caorsistwwg only of physical tapered
2, Septic Tarrlu".>and FreerSystems corraiating only of septic tanks, dosing
and direct Sachems;
Lagoon Systems corelsting only at pre5mtnary treatment, lagoons, pumps* disinfection, necessary chernical treatment for
algae or nutrient control, and dared discharge;
4, Mead -loop Recycle Systems;
Groundwater Remediadton Systems consisting only al oihwater separators, pumps, air
and &posttt:
fIt Aquaculture operations with discharge to sudacs miters:
7, Water Plant studio handling and bads -wash water treatment:.
t#, Seafood processing consisting d screening and disposal,
e, Single-family discharging systems, with the exception of Aerobic Treatment Units, will be dassWod 1 permitted after .lu1y 1
1Qg3 or 1 upon InspeQDon by the Dlviabn, It is found that the system is not 'being adequately opersled or maintained. Such
systems wit be notified of the classification or reclassrcaiion by the Commission, In writing,
components shall
dual certification.
My or the technology is unusually
disinfection

A teoid% pond Iotb*Artg taco dbry treatment wet sulkier" detention urns to aloe settling of finely suapendsd wilds;
tion following corrrenterot brcorry trimmers units to ircreaae atheism D.O. or lei any otter purpose:
A. poial'hirQ method by which dissolved oxygen Is added to the *Moore by a nonmecrhankal, gravity mean or flowing down a
oocurrinQ across ate sops or woks movies in a tbky thin toyer and the operation d ter cascade requires ere operator
(15) 'Electrodaysic Proms for rem:wi g Iortar'd vbfrom. dewsnMp
eer
(is) Flaw Prue. A process. operated m�sharically Wally
(17) Foam Separation. The planed frothing or rssnwasr or waslrwsur
ttha krradudbn of air Yn the lcm1 d fine bubbles; alio called 'foam fractionation;
(10) Grit Removal. The process of nrnarring gill and oshar heavy mineral manor from waa$IW V. •ion chamber(19) mesh Tank. A drop two story wasterranr tank canalising ng d an upper salon ereatbn chamber and a lower sludge digs
(20) tretnerwned now lasioeuromore. A d.vloa which Irstkate. and records rase of low;
(21) ion EmcMnge.. A ci ernicaI process k ruts) Iona Iron two Moroni rr>,t cu*si are exchanged;
(Z2) Land : (a) Skidoo Dispose A Mel sludge disposal method by whet with sludge 'nay be applied to land oiler by spraying on to eatersor byeulaetrrfaahr uhpection
4.$. churl plow); (not applicable for types of rktdr deecrlbed in (11) of tie Rule):
(a) Treated H*1*rt. The process of spraying mated ere oowatar orso a lard use or other moored": d spoliation el wewwaser prno a land ws as a
aeon" al final disposal or tetatrnert;
($) Ww croy'in A low speed, contruoboa-washed, ba-washed, rotating drum flier counting under gravity conditions as a poishinp method for removing
augoondsd Nelda from silkier* n 10 osldzeri nitrogen (usually rime);
(24) Nitrification Prooasa. The biochemical ootnoerlbn of tlnoaldized nitrogen (smrnorato and organic:nitrogen) n to nitral• nitrogen;
(25) Maropsrtous Stage, A separate stags orwtor the e d eracteater treatment designed tspecific purpose, convening ammonia ritroge
QS) P►toalphrle Removal, 9blogical. The r moval d dhoephoni s from wastewater by an, oleic/anoxic process desigrod to 'innards knury uptatto of pnosphorue
to
(')
CM twat
series 0f stops or eerie; Tf1a chow
edit/atheism; thus, zero pieta ass assigned even trough this is en anemia( asp to meeting the Snits a the discharge pi absorption red or
) Powdered to Granular r Activated Carbon Food. A biephyskal carbon prestos* this utilize' biological edtvay and organic by using Poor
tar activated carbon; Virgin. or ragenrwad carbon is Is winded Into the system;
Premonition A tank aoorsearuced to provide aeriuPn prior 10 primary trartmenn;
Psrlmyhary CHtl* taut operations lei Ito trsamses process, such as screening, and txrnrrdnulton, tat pt,tpans the lquor for subsequent made operations,:
IAai Pntnasmant.
trsamUnit
, t. kduatrlat Tits cerrltor*l sumo of a west" e1 as srs before dirtharge, to remove or to neutrallzs subssardes W4unioue to sowers
and
=eases or 10 efied a paned reduction in bad on ter treatment process which is operand by the same oovortsng body as the oestwrater
plans being rand:
orient Program, Industrial - met be a. State it EPA required program to ncefv$ Ores on Its Ming &teat:
tardier* the MO settling lank$ through l ech eas:Iwater Is passed Ina tamest storks for the ptapo+s of removing wattteabia are ausponded
0 which is sssocdated with the solids:
initiates, enter' aid In pare pumps:
LNN is Lion or saerutution process uttkxing devices emitting ulravloiet or (prnma rays; ins from
A veatrron prods Inhia hill, which holcontaminated lgtid el pro:surtted through a Membrane Iarrneg many pin
bed Cortraotors. A lied biological growth process In unlit' waalrwalr lbws through tame In elicit a eerie or pintotfy submerged Ocular
n&atlon of Olken following septic tanks, lagoons, or Nome odor tnamsre process h erhich turther biodecorrposlbn la
earns
typo
of
nit sets on In S byMere Subparagraph
h(1)computed) In ;piled and d this Rule Mtn ties *Sled capability to ercyer Olken bve a. resoling low gorrust peso than aok
Neste type of sand titter as delrrd In 5ubparspraph lam) lei
A polishing proms by which affluent imli ars achieved thorough *further reduction of suopordad sold*
Sy leaded rner wan loading rates in the one to thew genre range;
ally loaded floes wait boring rues in the flvs ifprnnwr rang,* At any rats, the batting rats all wooed thee* gouts';
loathes the bins i►ral unit of trutmos plant and which has the purpose of removing skidoos abaoclatrd with the
col to coned atablaZation process where the activated sludge 1 trartf.Rrd lc a i*rk and errand before returT*rQ.iing tank In which lolled sludge I" In. contact with Ow wastewater flower; through the s
hewn) ly residences having harapadty of .0t� gallon or lass which discharge to a n ion k ' shall rhea be appttaebr for
ss by which organic or volatile meter aril sludge Is gasified, lquelieQ rn+nerarzsd or clonwrnrd into mono stable organic miter
strict Includes aerated holing tanks; 4 �,ed try .,�, aid
trig natural or wadi* layers at porous material upon which..digested eewNpe shod
of sludge oontlliorrng In which certain corer:IMAM are messed by succerste waatinpi art bosh water or plants effluent;
ass of using savage gar for ter purptall of healing bulfdngt. diving *Vile* etc; rot rn t riorarratld). A Lank Wand for �ay�.mterh which sludges may be
prior to a dynQ method (u. sirdQo drying ); may bby adding a email amount of air okr4rkeep Us
amount the would be required to achieve atablizatbn of organic manor. A rtoruerat$d tank would simply In used to
would not allow long periods (sexual days d ditsrilon) without resulting odor probiemi:
slgrod to bum sludge and le remorse al mo1ilurs and mmbuatble matrrtats and reduce the sludge to a stork ash;
Thermal): A process to make tasted sludge Iran adorovi and putreecbh, and to rectum the pathogenic organism
ssaapusifters, cheerio dosing or by heel treantie tl;
secfimertudan tarot b whidt the sludge Is permitted 10 battle and Victim through agitation end Vevey:
daikuf Iepron in which biological ottdabn of orgWic mailer Is effected by na1urel trandor al oxygen to the water holt
ponaba. electri *s germ tn9 SQrgefortt; sold", suspended .olds and
drsignrd to remove sold". including rote -biker tnad$bo particular (ns o+bl.
SOD
we it blowing
mail r system*
r prwiarly for to purposed oaken pol$ftl9; A weeding *lgoor+ a "AM es coal ffser
sm.rat kek+'A^ii ++
bevies prwtdre for the harder of heal from s fluid flowing In tubes to wielder fluid outO& the tubes, or vice trrrsa;
process bM
y which at Is added for a pntaradea period d lino to Irltpirthe tfo ds+dantily of saggs
WU; by this
tagNyof wastes, Merited ikrdg. Panseas ttNs: s w hicch sites dsc arge and tnpon expolsere. Inprrdon. I nhaslation
dd 'ct,c*+dtnp diroody y h er �d choke, ell cares dead, masses, behavioral
to ilunc ions or isAr.cty by�b through
,ruMunctioaei �� marts In reproduction) or physical defwtrhaitsra, h such organism' or deal
end not kmaatbrc toad, cadrfun, crromkm mercury. v$nadun, ttrs+ric, etc. eat er*reicrbrobergens
rvyt at'ictioroeahans (OEM; and any other mi1arlile thee Moe or may tersaftrr be determined t0 here
medal such as broken'bre or loch. over ouch wattawatar is nears uteri; A NO rate
A low state tricking finer Is one which is designed to capered+ al one to four mood per
In tuff waitawat1 flows cithen. through iuhx.tStre layers of redo or ilA eta mewl .% Organic
in salt success/vs taw. This method may produce y' *lady 'Mark or RM'y
be
designed to remo a sxcass *rear from slur di, etxrd or urdLg/drd elude prior to dimmest

1e1JII al uonpppi ul sq n (m y wrw at
to reAauw sates franou care ©C7N P ie*++is tp+o+aru
1 1 .ttiu►+ q
II
p rrAretare pottier,/ i•ou p+l: o Mpi0111
pr+
awls
Mil &iron
A (Mt li 'p*elii curls S a'n InNrv4117
._,_._ _ _ _.,. •wrlsseS +11r p�nip0
• must; urelliso +4Ww 4011+x+11Prw
....., rucul*ILO4i SQrvar sra¢,rab !liana nwt� Pia '+o+am 'piAsj6 pal'r_
wig wP^s a i•
SIO11 rst 2Fnte"10 Ai s+M1"l �+EM $0 mad (p)
MOO eti N4p#xl Oulipn+rw *Ir) IMAM. ar4d ....y..... ........... ,p9 ,eat (3)
Q....... ..._...._._......................._.<...—,.............................-.-.... pl pal (4')
5,....,.. » _ .,... _ -Ay GN uoriMtec mid+t �lt+l (1)
5 p,Y3Nihlisr('►)
Z.......,.._. ___._.._ _ (11
)
(1)
(0104
(4)
(4)
(N
(9)
..................._._.........._........ » ^ ._......,.._. _....—.._..._-<._..._._ .�{,,+a�l • Lot*+s uo w **mg (I)
�...,... _..._...__ r..._. ...._ .._ _ .,. .. +Eap�l++9 ,.a� wre+yy (+t!
..,... uWlurrr� (d)
t. <............. ............................_. .......... .................... .mus,rinwn mow psisimi non 4 (i)
�........N................ io
............._.._.,..�.,..._ _ __ _. _.._- __���� (p)
...-......._.._,». __._.. ..«.. rai„oCl 68.41JI p W03 io surrt+S 39ns 'asest 1 Vr"a''tw svi
Or
91NIOd
(ii'chi *p.'► ) =tidis.usrl.udymnraid
To!i >u d i ( pue) teo"cao'e
to:roar
oo.00:
CID° 000
00'001
ne., lawn
to0'Oil
((p)(tt) p (pJ( wuou rs (pXP)
wrp 10 eiuo C101 em srpiliPrt p+u 11 t 'PN ugpuJrp rra)rw+.1e1r 01:5+t0 p0+0P litrtQt tpusgd u© teepmd "t"'
+oi +A!p1F+r1 guipay awn Oug000 peon"uvuow+au peirAttkos+a+) Pm rq 1NY1d d0 MCU 14VIS313
.._.._.._,(C* "aN i+atpMpp ass) waiSexhi Kww1w+viud lutrrt++pyl O 111P49 rurWaa+wd a*uf^CtM
Van
(stuyod eleydoiddth ej3Jio) :sewIpsl uowleei
U!1IJ JOJ pesl1
OL+ aU!MajIO 9441

(l) diffuoed or macre
(m) Rsrar,e Os+oasis......... ...... _._......».... ..._..,......,....,...,_...........,........2
(n) Viand trad•PrAscfir. Fears tow rW....__ r...a►ir, .<....�.... .... ........................,...........»... 5
(o) Ttsatmart prsresasaa for wMam! of n'rtai or cyanide ..................... • 1 5
(P 1 ttrsstmsnt processes for MOWN* Of souk (motorcars ot.hwr than metal or cyaHiCM ._,. .__ ..._._..._.1 5
(7) 111U-CGETIREA MENT 10
(s) ilh►dg+ pi�llrsn Tank ilsatsd larw+oblel... _....... _. .._., _.._..... _ .R�.--_...........�....._..,......5
(b) i�kdipt abeizatkrn (riser cal or tfrnmi) ..........* ._ .......w ... .... ....... 2
(c) M sistad ........,, . ............�...r...... .......,. .......» .2
(s) Moor Cortd*IW»( (ertatnica1 or tfrarmal)...... o.., .. ., 5
Flotation Thickener avert _
(g) Dissolved Alt otation Unit (not applicable to a unit rated as (3)(1)) ......... ..... .. _......... 5
(Pi) Sledge Ciao U1Wzation (including pas stompsl..,... ._........_.. _.._... ........ ... w..................5
(I) sludge rapidity Tank er Aated.... ............................ .__» . ...........H..... ..........,...,,......5
No R motored ................................w.,,..._.....,.. �......... (1) Sludge V% . l
rwraicx (not holuding activated carbon r.nwatbn)..
.... ,,,.., ,.,ti_......».........._ .. ....� .„.._.. .1 0
IV
Vacuum Fluty, Cantriluge, or Faker Presto CO otrw sfmillr dewaq?Mtg dieiosa..__.._....,._.��
($) faESIDUAL3 LrTL ATON/D1SPt�SAL (etcfucarg itrtrwraecl ash)
(a) Poona. Nr+kion 22a�...............................................................2
(Pi) Lund Appttcation (s�trraos and ssbsurlaco) (sae cis
by contracting to a land WQkcebn operator or landfill (operator who holds do land application permit
at Weill permit 2
(C) Dedicate© t.andlat(burral) by the ;amens* ofthewastewater treatment lcCMitr. ..... .. .. ..-....._........,,,S
(() (a nation..... — .. . _ .....,........y.. >.,..................m...5
(5) (laesilo.Motion..- �.........�.,.... �.....�....... ..... ,... _, ..< ... . ,....... .,..........._.......5
(10) CMFM CAL ADOPTION (YSTEkd{S) (ass dslirtltlor trio. a) trot spprlcabs to dterralceJ addabrs woad se Rem (3)Q).
(d)(a)(sll, (()tali (SXb), (7)(b), (7)(e), (=o)• ((1(b) or (alit) 6 Points saes:
List... ..».. .......... ... _ ...._........_..........................5
Tanks or Settling Ponds lot Organic or Toxic Miaiarlab Inducing wastes from mining
slogan or phosphorus compounds k+ srourla Write/thy prosily than la common
art (not appiitibir is stcvmfa> rt!rtiedt er, Inherent In land application ereemr). _..2
otiCabii its iaoyagrr batira ktlrorrrerf M1 lard aPpartton
Fancies having a rating of ter through bur sons, induces. do not require a WOW operator.
hates having an activated snags Picasso oil to asaigr+d a minimum tdatwlMrafiort of r srsa
Facitties honing Madmen' proor ees for the rerrovaf at trace or cyanide wi! is tarreda rrir*rwm clasadkaticst of Cleo It.
FadR;ea haring Daemon processes for the biological retrto.e& of phcer©hona are be assigned a mine rm oiseilieatfon of Class III.
The tolowirg definitions shalt 'poly throughout ills Scrbdtapter.
(1) Activated Carbon Dens. A pryafpVehsmica) traded for rocket% potato organic rnirerW from waaTaweter ftf;ltusr : Ttta o�ty re basis 6teisd In this
mated ea hers a floe acre ra yk'ii from two to eight galore per minute pat altar, Moot and may be ether trplkaw or taavyril(ow tuelda. fin rraall (or
may not to regarrrbed on the wastewater trammed pin, sae,
(2) Aerated Lagoons. A basin In which ai s0dide aye fralrealhod In auaperelon and by stitch biological oxidation w crpark: tram l tiltotugrn sraicraity
accelerded tvy(er of wryer on a flow -through belie: n in a lqutl by spraying, agitation w dtrtuaranXsal Exsernded
A) Aaratbn A u of brewers about Intimate coned between air for high party oaype
Aeratktnt An activesd sludge process ollaim a minimum hydraulic detet1Fort hail of IS haws.
(4) Aiglowitursay managed ea, My `ate on a+idI a romp is produced. managed. and harvested (Crop ecldgfswoks, ea sterr. from, ie.):
¢) swore A process by 1 the ammonium ium Ice a ilrat corwwred to dIssoked arrow* (pH adlittemont) watt the torrents than misaasd to the
atrTttosiinate try physical matt; cor other similar processes which h roman pstrtofeum pratiucb etch to bertons, toluene, arrd tryalit;
is) Carbon liegeroradon. The rlgeretacbf of sxhausae4 canton by the use of a hareem to provide sstrerrrty high 1 r erthroa "Mott r(ofaoiae and oxidize tar
Cabo. c ono Slaw) sr... A dogs Of wastewater inestrerf designed to achieve 'seconda i' situate rl:a:
Centime. A r*thirt r darks In smith centrl'uga► font* it used to tropes* ((roads from Squid(; or to sapsrda iiquids of Natant careg+a,
CPsr�c l AtlttltMrn System a The add rbn of r tamkxl(s) to wastewater ran ap¢tcalton pokes Ice purposes of sodr3 rem.ral. PM ad)u*tt+anti
daftly ward. sec.: the cap.SDr to a pwirrant.V. Crain chemical acd dreary apottcation points to achieve
at as apse
rsrakar a tun points for dlea be nal one
warn: Dmttc
trio capabIllly to add chea)(s) to dual units tar! be rated as one system, casaba),
wit mot In the totems being rated as Warta o�pssswns: to orsa4ars the rtlrasl pile tut
ill) Chemical Sludge Cordtdorirq. The *bonito of a c ormice compound such as Imo. lenic Chbrlde, or a polymer to wet sludge
sppikaaor to a a waled device:
(11) C'tosad Cyess Systems. is* of holding Fonda err ticking tanks for oonta3rrrtens of wasteender containing inorganic. rai-Iwtk mean** arioos from sand, frivol,
Cous.'tetf store or (other siml1w operations. Such 'yaw* shall carry a maximum of two pohts regardless Of perripartg facials" or any oltrr tppurertsnzes
(12) Con tined i(anncvaf of Carbenacsoue DOD and Nitrogenous Rerrovat by harificalen, A s)ngls stage system required to achieve pond affluent knots on ILOD
art ammonia ntrg3an within the sa.mo biological rowan
1f}echiortrtatIon. The pants or complete reduction of residual ctiortne in a t u1d by arty demi or physical promos:
14) Drenarlfkatbn Proc.sa. The ,conversion of rats(,-rttrcfen to ritrnfen ,ad:

ppprr:
P
State
pe ar
State of North Carolina
Pe artment of Environment,
,��'Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P. E,, Director
Mr. Michael Cashman
R.P Scherer Corporation
2725 Scherer Drive
St. Petersburg, FL 3371.6-'11.6
Dear Mr. Cashman:
N.C. DEPT. OF
994 LN .I1,ONNIENI rn Ar rH
& NATURAL RESC ;tr is
Jd1-
lfifiIMS 0 EN`' «tr.'6WI !AA dA,131.E€il
tat S'Ilai li'at'JtlAt GFFI
Subject: NPDES Permit Application
Application No. NC0084344
R.P. Scherer/Chelsea Labs.
Union County
This is to acknowledge the receipt of the following documents on June 28, 1994:
- Application Form and Package.
- Application Processing Fee Of $4C:i0.00.
The following is required inorder to complete review and processing o'f the application
1) Three copies of the permit application and proposal package.
Refer to the subject permit application number when providing the requested information. Also,.
please :note that failure to provide this additional inforrnation within 30 days of the date of this
letter, will subject your application to being returned as incomplete.
This application has been assigned to Sean D. Goris (919-733-5083)
review. You will be advised of any comments, recommendations, qu
necessary for the review of the application.
I am, by copy of this letter,. requesting that our Regional Office Supervisor prepare a staff report
and recommendations regarding this discharge. If you have any questions regarding this
application, please contact the review person listed above.
Ati; 116(
Permit Applicatic:
Steven R. Bowen..
our Permits Unit for
ions or other infor-rnation
)-avid Goodrich, Supervisor
NPDES Group
and (Cal cots En sneers
P.O. ESox 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

SEP PR 1994
-visor:
acility ``a1l tie:
NPDES .No,:
Type of Waste:
Facility Status:
FOR W A S
-)AD ALLOCATION OIYIsEtw
eoi ' !CRESVIALE RIN!-0HL
R.P Scherer / Chelsea Laboralto
NCO()84344
Industrial - 1( 0
Proposed
Perinit Status: c •
Receiving Stream: UT to Rays l ork
Stream Classification: C.
Subba,sin: 03-07-14
County: Anion
Regional Office: Mooresvi1
Requester: Goris
Date of Request: 9/ 19/9)4
Topo Quad: I117NW
Wasteload Allocation Summary
(approach taken, correspondence wvith reaiota, EPA, etc.)
Request #
'[FCt,,* (wF'
ENVI R[ )^ti es i^ N r, HE ALTIEL,
NATIJRAL, RESOURCES,
ROCS,
()CT 17 1994
IjE l lti cif CltrtlRClNErkEbt€t �, * LI tNi
lIt L1 UNA. tff f;
Streani'Chartr.cteristic: St& rlr]
USGS #
Date:
Drainage Area
Summer 7
Winter 7Q10
Average Flout
30Q2 (cfs):
I�t'C ( ):
A number of halogens and volatiles were found at the site. Using a remo gal efficiency of 90 for
these constituents, tetrachloroethene, t.richloroethene, and toluene should be limited to water quality
standards or EPA criterion. Chloroform should be monitored. itored. A number of metals were found
above or near the water quality standards and should be limited. These include: arsenic, lead and
mercury. BE X. parameters appear at the site, but only toluene was iri high enough concentrrtions
to need a limit. A quarterly, chronic WET test Will be given as a pass/fail analysis at 90%. Ph and
Oil and Grease will be limited per current policy. The testing results submitted by the applicant
have raised concerns that other halogens may be present and were not adequately reported in the
data. Because of this it is recommended that further volatiles. and base/neutral - acid extractable:
testing be performed on the. effluent. It is recommended that volatiles be tested using EPA methods
601 & 602 be done quarterly and that base/neutral - acid extractable testing be performed with 10
significant peaks identified quarterly, with the option given to discontinue testing after 12 months.
Information sent by the facility from samples collected in the plume were the basis for these
decisions.
Special Schedule. Requirements and additional coinlnents from Revieers:
Reviewed by
Instrean
Region
Permits & Engineering:
RETURN TO 'TECHNICAL SERVICI S BY:
Date:

Type of Tc xicity Test:
Recommended Limit:
Monitoring Schedule: Nov, Feb, May,
Recontrrande4l. L.itrtitti
Cholrotorm (agll):
p1...1 (SU):
Te track l a meth ene 4I g/l ):
Toluene (pg/I):
T'richloroethene(µg/l):
Arsenic ctrg/l):
Mercury (lag/l):
Lead 41.41):
Oil and Grease
x Parameter
the immediate receivi
effluent limitations for
c pass/lail t
T1 )NAL, PARA
Daily ✓`Ia :,.
monitor
6-9
8,85
1.1.
92.4
5t).4)
0.012
2.5
60
auali
will be consumed.
ditional dischareTers within
lay atfec
portion
TIRS
tC L P/F)
I'requenc'
monthly
2/month
monthly
monthly
t� ronthly
monthly
n�cnt;hiy
monthly
2/month
'WQ/EL
WQ
WQ
WQ
WQ
WQ
WQ
WQ
�e available., load capacity of
lure water quality based
he watershed.
OR.
Nca parameters are water quality li ited. but this tlrsc:har e tra y aftec.t future a
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Special Inst.tctitans or Conditiors
Permit must contain flow monitoring, re- uiren en.t such that arll volumes of wastewater leaving the
facility are. monitored. Recommend continuous flow monitoring. Recommend that volatiles be
tested using EPA methods 601 & 602 be done quarterly and that 'rase/neutral - acid extractable
testing be performed with 10 significant peaks identified quarterly, with the option given to
discontinue testing after 12 months,. This monitoring should coincide with all whole -effluent
toxicity monitoring.
A reopener clause should be placed in the permit to allow for additional hunts on these or other
toxicants should the whole -effluent toxicity testing results indicate toxic effects Or additional
volatiles/extractables testing indicates other constituents are present.
Explain exact pathv ay of discltar° e
,Storm Sewer to Tri ni rry
Additional Information. attached'?
utary. etc.,)
explain with attachments.

iacility Namepflt
r; L.(1 / pipe, #
Lt XR„.„11 vASSIVAIL PERMIT LA.NIFF (QR"FRLN')
The: effluent discharge shall in no time exhibit chronic toxicity using test procedures outlined in:
.1..) *Tile North Carolina Ceriodalbnia chronic: effluent bioassay procedure (North Carolina (Iltronic: Bioassay
Procedur.e - Revised *Se pte in be r I 9 or subsequcnt versions,
e. ft] Lie t C Ce titration at which there may be no observa.ble inIiiNitii 01 repro(' uction or significant mortality
(defined as treatment two in the, North Carolina proced.ure document). The 1.ier10it holder shall perform
quartet iy monitoring using this procedure to establish coinpliance with the prmit. condition. *The first test will be
performed after thirry days from the. effective date o4f this permit (luring The I1I001115 Of
/-4:i'Y • IA 4.'+' fl tient sampling for this testing shall be performed at the NPDES
permuted final effluent discharge below all treatment processes,
Ail toxicity testing results required as partof this permit condition will be entered on the Effluent 11.)ischitrge
Monitoring Form (MR- l) for the month in which it \Nits performed, using the parameter code T6P311,
Additionally. DEM Form i\T- I (original) is to be sent to the following addre.ss:
Attention: Environmental Sciences Branch
North Caraiilina Division of
Environmental !Management
4401 Reedy Creek Road
Raleigh...N.C. r'
Test data shall bo complete and accurate and include all supporting chemical/physical measurements 'performed in
association with he toxicity tests, as well as all dose/response. data. Icital residual chlorine of the effluent toxicity
sample must be 0 isUled and reported if chlorine is employed for disinfection of the waste stream.
Should any single quarterly .monitoring indicate a failure to meet specified lirnits. then monthly monitoring will
begin immediately until such..ti me that, a single test is passed. Upon passing. this monthly test requirement will
revert to quarterly in the months specified above.
Should an test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the. receiving stream, this .permit may be re -opened and
modified to include alternate monitoring requirements ()I 1iinit,
NOTE,: Failure to itchieve test conditions as specified in the cited document, such as minimum contr(iil ort2a.nism
survival and appropriate environmental controls, shall constitute an in test and will require immediate,
:retesting(within 30 days of initial monitoring event), .Failare, to submit suitable test results will constitute,
noncompliance v, ith100111tOrin 9.; require Me rit.S.
7Q10 CfS
Pe 1M itted MGD
I WC
BaSin & Sub baSi 0:A0
Receiving Stream! xi- Tv ,
county Date ,
Recommended
(.71, Vie rS ().',0

DRPTion8l
..NrRONMENT,
NATVRAL RESOURCE§
$CIIHRER/COEFSEA:"FAOORATORIES
GROUNDWATERINTERIM .RENIFINATION: SYSTFM. .
JUL -25 .194
TARLE OF .CONTENTS
Application for NPDES Permit - Short Form C-GW
Project Information
EAfEISUIN [if ENEEREENMEEITAL MANAGEMENT
IPOSESVIELE DEM
Page No,
3
II. History of Groundwater Contamination 4
- Summary of Laboratory Results 5
- List of Maximum Concentrations 6
- Figure of Well Locations 7
III. Proposed Treatment Facilities 8 - 14
IV. Evaluation of Environmental Feasibility of Discharge Alternatives 15
V. Proposed NPDES Discharge 16
- USGS Map (excerpt) 1 7
Appendix A
- Correspondence with Marion Merrell Dow (Chelsea Laboratories)
- May '94 Correspondence with City of Monroe, NC
- Initial Correspondence with City of Monroe, NC
Appendix B
- Laboratory Analysis
Drawing 1 - P & I Diagram
Drawing 2 - Site Plan

Nortn Laroiina Dept. or trivironmeti,.., Health, and Natural Resources
Division of Environmental Management, P.O. Box 29535, Raleigh, NC 27626-0535
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
APPLICATION FOR PERMIT DISCHARGE SHORT FORM C-GW
To be filed by persons engaged in groundwater
remediation projects. Year Men th Day
(DEM USE ONLY)
Do not attempt to complete this form before reading accompanying instructions. 3
(Please print or type) ik,• e2_1?
c2?fr,
ies Facility)
APPLICATION NUMBER
Date Received
1. Name, address, location, and telephone number of facility producing discharge
A. Name R. P. Scherer Corporation (R.p. Scherer/Chelsea La
B. Mailing address
1. Street address 2725 Scherer Drive
2. City Saint Petersburg 3 State Florlda
.4 zip 33716-1016
C. Location: Chelsea Laboratories
1. Street 2021 East Roosevelt Blvd.
2. City Monroe 3.State North Carolina
4. County union
D. Telephone No ( 704)- 289-5531
E. Nature of business Manufacturer of Drug Products
ato
2. Facility contact
A. Name Steve en/George Maalouf J.L. Rogers and Callcott Engineers
B. Title Project Engineer/Project Manager
3. The application is for
SIC
II I
number: NC00
4. Product(s) recovered Tetrachloroethene, Chloroform, CIS-1, 2, -Dichloroethene
f
Methylene Chloride, Trichloroethene; BTEX
[Diesel fuel, leaded or unleaded fuel, solvents, etc.]
This application must also include the following:
A) A report of alternatives to surface water discharge as outlined by N.C. Permit and Engineering Unit's
'Guidance for Evaluation of Wastewater Disposal Alternatives: [Required by 15A NCAC 2H .0105 (c)].
B) An engineering proposal detailing the remediation project. [Required by 15A NCAC 2H .0105 (01
C) A listing of any chemicals found in detectable amounts with the maximum observed concentration
reported. The summary of analytical results containing this maximum value should also be
submitted (i.e. the listing, not the graphical scan). The most recent sample must be no older than
one year previous to the date of this application,
C. Telephone No. (803 ) 232-1556
a new permit, Operrnit renewal, Dpermit modification.
(if known), if application is for renewal or modification, please indicate permit
For fuel remediation projects, volatile organic compounds should be scanned along with any
suspected fuel additives, The following compounds should be included, benzene*, toluene*,
• ethylbenzene*, xylene*, lead , methyl tert-butylether (MTBE), dibromoethane (EDB),
1,2-dichloroethane, isopropyl ether, naphthalene, phenol.
* An EPA approved method capable of detection levels to 1 ppb should be used to detect these
compounds

For solvents or unidentified products, an EPA Method 624/625 analysis should be provided,
with the 10 largest peaks, not identified as one of the targeted compounds and not present in
the procedural blank, identified and approximately quantitated, [As per the same guidance
stipulated on NCDEM's ''Annual Pollutant Analysis Monitoring (APAM) Requirement - Reporting
Form A," Revised June 1990],
If metals or pesticides are suspected to be present, these should be analyzed to the same detection
level as presented in the NC ARAM.
D) The removal efficiency of each compound detected for the proposed project should be provided,
if known.
5. Name of receiving water Tributary of Rays Creek
Attach a USGS topographical map with all discharge points clearly marked.
6. Is potential discharge directly to the receiving water? If not, state sogcif tally the discharge point.
No - Culvert under Hastey Road at head of unnamed tributary to Rays Creek
Mark clearly the pathway to the potential receiving water on the site map. [This includes tracing
the pathway of the storm sewer to its discharge point, if a storm sewer is the only viable means of
discharge.]
7. Amount of treated groundwater to be discharged in gallons per operating day:
72.OflO xi maxi mum
Describe the duration and frequency of the discharge (continuous, intermittent, seasonal)
including the months of discharge, number of days per week of discharge, volume treated
(month)y average flow in gallons per day).
Year Round - Continuous
I certify that I am familiar with the information contained in the application and that to the best
of my knowledge and belief such information is true, complete, and accurate.
LaS
PRINTEDpme of Person Signi9 Title
SIGNATURE of Applicant
0
Date Application Signed
North Carolina General Statute 143-215,6 (b) (2) provides that:
Any person who knowingly makes any false statement representation, or certification in any application,
record, report, plan or other document files or required to be maintained under Article 21 or regulations
of the Environmental Management Commission implementing that Article, or who falsifies, tampers with
or knowingly renders inaccurate any recording or monitoring device or method required to be operated
or maintained under Article 21 or regulations of the Environmental Management Commission implementing
that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprison-
ment not to exceed six months, or by both, (16 U,S.C. Section 1001 provides 3 punishment by a fine of not
more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense)

R. P. SCHERER/CHELSEA LABORATORIES
GROUNDWATER INTERIM REMEDIATION SYSTEM
GENERAL INFORMATION
FACILITY NAME:
R. P. Scherer/Chelsea Laboratories interim 1roundwater Remediatiun System
Union County, North Carolina
Located at
Chelsea Laboratories, Inc.;
2021 East Roosevelt Boulevard (Hihway 74)
Monroe, North Carolina
Prepared by:
J. L. Rogers and Callcutt Engineers,
P. O. Box 5655
Greenville, South Carolina 29606
[phone]
Project Engineer:
Steven R. Bowen, P.E.
N. C. License No. 19611
Project anager
George Y. Maaluf, P.G.
N. C. License No. 129
tic

HISTORY OF GROUNDWATER CONTAMINATION RELATED TO THIS PROJECT
Chelsea Laboratories, Inc. of Monroe, North Carolina is a manufacturer of medicine tablets. This facility
was constructed, owned and operated by R. P. Scherer Corporation in 1976 for the manufacturing of soft
gelatin capsules. Chelsea purchased this facility from. R. P. Scherer in January 1986 and has operated it
since that time.
During cleanup of a diesel fuel spill in July 1992, Chelsea discovered tetrachloroethene (PCE) soil
contamination in the vicinity of the diesel spill area. Chelsea excavated the soil and notified R. P. Scherer
of the contamination. With approval from the North Carolina Department of Environment, Health, and
Natural Resources (NCDEHNR), R. P. Scherer transported the contaminated soil to an appropriate
disposal/treatment facility and initiated a preliminary soil and groundwater investigation in the area of
the PCE contamination. The investigation indicated the presence of limited. PCE contamination in the soil.
and elevated. PCE contamination in the groundwater at the northeast corner of the building. Summaries
of the groundwater analysis and the maximum concentration of contaminants found are attached. The
volatile analysis was performed using EPA Method 8260. Additionally, semi -volatile analyses using EPA
Method 8270 and metals analyses were performed on well MW-2. No semi-volatiles or metals were
detected with the exception of iron and manganese. Refer to Appendix B for copies of the laboratory
analyses.
Based on the findings of a preliminary investigation, R. P. Scherer and NCDEHNR's Inactive Hazardous
Sites Branch determined the need for a Remedial Investigation to delineate the extent of soil and.
groundwater contamination, and design and implement appropriate remedial action. The site was
designated number 51 on the Inactive Hazardous Waste Sites Priority List dated March 11, 1994.
4

SUMMARY OF LABORATORY ANALYSIS RESULTS
R. P. SCHERER/CHELSEA LABORATORIES FACILITY
MONROE, NORTH CAROLINA
Groundwater samples collected on February 16, 1994.
Tuarr
form
-1,2-Dichloroethe
h lene Chloride
chloroethene___
hlowethene
enzene
Elhyibenzene _
Toluene
X enes
al Aromatics (2)_
Acetone
TotalVelatilesi3),_
Concentrations In ing11
<0.002 2.7 <0.002 <0, 0.00 0.002 <0.00
<0.002 0.79 0.26 0,02 .00 <0,002 <0.00
<0,002 0,23 0084 <0.002 <004 <0.00 <0.-002 <0.00
<0.002 88 22 0,73 2,2 0.0047 <0.002 0.0038 •
<0.002 9.5 2.9 0.086 <0.04 <0.00 <0.002 <0.00
0.002 161122 25.244 0.836 2.2 0O04i <0.002 0,00
<O. <0.04 <0.02
<0.0 0.05 0, 2
<0.0021 0.35 0.026
<0.004 0.19<0.04
<0.004 0.50 0.026
<0.01 <0.2 0.13
.01 101,81 25 4
0.0069 <0.04 <0.00 <0.002 <0.00
0.011 4 <0, <0.002
<0.002 O. O. <0.002 <0.00
0.019 <0,08 <O. 0.004' <
0.0369
<0,0
<0.2
0.9019_ 2 2 0.0047
Notes: 1- Sum of the detected Individual chlorinated compound concentrations.
2- Sum of the detected Individual aromatic compound concentrations.
3- Sum of the detected individual volatile organic compounds (VOC's).
Well MW-8 was resampled on March 31, 1994. No VOC's were detected at 0,002 mgll.
Sample
Chloroform
CIS-1,2-Dichloroethene
Mettylene Chloride
Tetrachloroethene
richloroothene
1,1-DCE
1,1 -DCA
Vinyl Chloride
Concentrations In mg/I
Live Haul Shed-- Feed Mill -
<0.004 <0
<0.01
10/01/93 10/07 10/01/93 10/07/93
_ -
.023
.026
0.14
0.29
0.15
0.03
Supply Room Parking Lot #13' ServiceCenter
10/07/93 10/07/93 10/07/93
0.014
0.037
0,01
°tat Haloge_ns 0.1971 0,346 0.47 0.481
Benzene
h lbenzeno j0.064 .0
'Toluene 0.043
X lenesOE33 1 0.39
Total Aromatics J P,844...._ O.
The wells noted as Live Haul Shed, Feed Mill, Supply Room, Parking Lot # 3 and Service Center ate located on adjacent property. These wells are not
included in the Interim temediation plan but may be part of the overall remediation effort,
NOTE: ALL ANALYSIS USING EPA TEST METHOD 8260,
SEE ATTACHED FIGURE FOR WELL LOCATIONS.
0,0021
0.0021

LISTING F MAXIMUM OBSERVEDN A t A T
R. P. H L: A LABO TORIES ILI
MONROE, NORTH CAROLINA
Const
tuent
Chloroform
CIS-1 , - i hI ro then
Methylene Chloride
Tetrachloroethene
Tri hl r ethena
1,1-D **
1, -D A **
VinylVinytChloride
Max Observed
Concentration rri
2
{
0.79
0.29
Benzene
Eth !benzene
Toluene
X'Imes
Acetone:.
9.
0.03
0.037
0.01
0.0069
0.064
9.
0.
0.
Found in tf-Sits es See attached figure for well
°nations.
NOTE: ALL ANALYSIS USING PA TEST METHOD 8260,

M. PROPOSED TREATMENT FACILITIES - INTERIM GROUNDWATER REMEDIATION
SYSTEM
The purpose of the Interim R.emediation System is to address on -site groundwater contamination identified
to date. Upon completion of the Remedial Investigation, the recovery system may he expanded to expedite
the remediation effort.
The proposed Interim Remediation System will consist of converting four monitoring wells into pumping
or recovery wells; installing an air stripping unit to treat contaminated groundwater; constructing an
infiltration gallery to introduce treated groundwater upgradient of the recovery wells and area of
contamination; converting an existing monitoring well to a shallow injection well upgradient of the
infiltration gallery and upgradient of the contaminant plume; and maintaining a background monitoring
well upgradient of the shallow injection well.
The proposed groundwater remediation system i presented schematically in Drawing I. (P c 1 Diagram);
a preliminary site plan showing the location of the proposed facilities is presented in Drawing 2 (Site
PIan). The unit processes include:
Four pumping/recovery wells
Air stripping unit
Gravity settling chamber
Finished water pump station
Shallow injection well
Infiltration gallery.
The figure found on the following page is a schematic of the hydraulic concept of the system. When in
operation, treated water in the infiltration gallery and injection well will raise the water table in that area
while the recovery wells will create a depression in the water table. The resulting hydraulic profile should
further influence groundwater flow toward the recovery wells.
Pumping Wells
Monitoring wells MW-2, MW-3, MW-4, and MW-5 will be converted to groundwater recovery wells.
This will require reaming monitoring wells M�W-3, MW-4, and MW-5 to 6 inches in diameter and
installing pumps, controls, and piping. Well MW-2 is constructed with a 2-inch diameter stainless steel
casing and will be fitted with a smaller pump.
The well pumps will be controlled by well water elevation with level probes, In. addition, float switches
at the finished water sump will control pump operation to prevent overfilling of the sump.
Anticipated well yields observed during well drilling and development are as follows;
MW-2 1 gpm
MW-3 3 gpm
MW-4 3 gpm
MW-5 5 gpm
Total 12 gpm
8

EXISTING
BUILDING
PROPOSED
BACKGROUND
MONITORING WELL
(MW-7)
BEDROCK -7
EXISTING DRIVE
PROPOSED
INJECTION WELL (MW-6
PROPOSED INFILTRATION
TRENCHES
\ EXISTING
WATER TABLE
RECOVERY WELLS
(MW-3,MW-4 & MW--5)
EXISTING MONTORING
WELL (MW-2)
HASTEY
STREET
PROJECTED WATER TABLE
INFLUENCE BY INTERIM
/ REMEDIATION SYSTEM
PRELIMINARY
DAZE
J. L. Rogers & Callcott
Engineers, Inc.
Greeztviile
South, Carolina
_Pet ar•
N—S PROFILE
RF�i i10N
R.P. S
c.
10

Air Stripping
Contaminated groundwater recovered by the pumping wells will be pumped to a low profile, skid -
mounted air stripper. The air stripper will be sized for 50 gpm. This will allow full utilization of the air
stripper and flexibility to accommodate future wells as needed during progression of site remediation, The
air stripper will be housed in a 20 foot by 30 foot metal building. This building can also serve as the
operator's office, record keeping and general storage area for the remediation project. As a convenience,
flow meters for the pumping wells and some pump controls may be installed inside the building.
The air stripper will include a blower, prewired controls, control panel, and gravity discharge. The PCE
concentrations should be reduced to less than 0.002 mg/1. The preliminary design criteria for the air
stripper is presented below:
Constituent
Chloroform
Tetrachloroethene
Trichloroethene
Benzene
CIS-1,2 Dichloroethene
Methylene Chloride
Influent
Concentration
mg/1
2.0
20.0
3.0
0.2
0.3
0.2
Effluent
Concentration
mg/I
0.002
0.002
0.002
0.002
0.002
0.002
The attached table shows the weighted average of the air stripper influent.
Gravity Settling
Naturally occurring iron in the groundwater may be oxidized by the air stripper and precipitate. A settling
tank will be provided downstream of the air stripping unit to allow for settling of the oxidized iron and
other sand or sediment that may be in the recovery water. The tank will have an approximate volume of
1,400 gallons. This will provide a detention time of 28 minutes at 50 gpm or almost 2 hours at 12 gpm.
It is proposed to provide a precast concrete or a poured in place concrete tank with a high density
polyethylene (HDPE) liner,
Finished Water Pumping
Treated water from the air stripper and gravity settler will flow to a pumping station. The pump station
will be supplied with duplex submersible pumps. The pump station will pump treated groundwater to
the shallow injection well and infiltration gallery. During timeswhen the submersible pump yield
exceeds the ability of the shallow injection well and infiltration. gallery to accept the total flow from the
treatment unit, treated water can be recirculated to the air stripper.
This system may produce and treat more water than can be returned via the shallow injection well and
infiltration gallery. Therefore, a surface discharge is sought. An NPDES permit will allow for optimal
operation of the system. Operation of the recovery wells can continue while allowing time for the treated
water in the infiltration gallery to infiltrate thus expediting the remediation process.
The pump station sump will be either a HDPE or HDPE-lined manhole.
10

i
SUMMARY OF LABORATORY ANALYSIS RESULTS AND DESIGN CRITERIA
R. P. SCHERER/CHELSEA LABORATORIES FACILITY
MONROE, NORTH CAROLINA
Groundwater samples collected on February 16, 1994. Concentrations in mg/I
CONSTITUENT
Chloroform_
CIS-1,2-Dichloroethene
Methylene Chloride
Tetrachloroethene
w-
2.7
M
0.7
0.79 0.26
Trichloroethene
Total
Benzene
Eth (benzene
Toluene
X lenes
Total Aromatics {2}
Acetone
Total Volatiles {3)
Projected Well Production
-4
0.0038
0.02
MW-5 j C©I'VIPOSITE ( DESIGN 1 A
0.076
0.04
0.23 0.084 <0,002 <0.04
88 2
9.5'.
01.22
<0.04
0.05
0.5
0.19
0.59
0.2
0
2.9
0.7
2.2
0.086 <0.04
0.43
0.14
0.04
3.93
1.54
2.0
0.3
0.2
20.0
3.0
er Treatmentj
<0.002
<0.0021
<0.00211
<0.002'1
<0.002
25.944
<0.02
<0.02
0.026 <0.002
<0.04 0.019
0898 2.276 .
0.0069
0.011
0.026
0.13
26
0.0369
0,029
0.9057
16.08
0.04 0.0017
0.04
0.05 <0.002
0.01 0.05
0.04 0.04
0.08 0.02
< 0.08
<0.2
2.276
0.0
0.04
16.18
Notes: 1- Sum of the detected individual chlorinated compound concentrations.
2- Sum of the detected individual aromatic compound concentrations.
3- Sum of the detected individual volatile organic compounds (V0C's).
0.05
0.05 '1
<0.002
<0,002
< 0.002
0.05 0.0051
121 50

Infiltration Gallery
To enhance the clean up effort, an infiltration gallery is proposed as and integral part of the overall
remediation system. The infiltration gallery will reintroduce treated water to the area of contamination
raising the head in that area. This water should travel the same path through the fractures as the
contaminant. As a result, the additional head and water supply from the infiltration gallery should enhance
the recovery of contaminants by the pumping wells.
The infiltration gallery will consist of two 150-foot long parallel pipes surrounded by stone. The piping
material will he perforated corrugated ABS plastic pipe (commonly referred to as French drain). This pipe
will be installed in a 6-foot wide trench excavated to the bedrock layer (approximate elevation 980 feet
MSL). The pipe will be installed with "full envelope" bedding using 3/4 inch diameter washed stone. This
will allow the treated water to percolate from the pipes and into the surrounding formation. The bedding
will be approximately 2 feet deep. The remainder of the trench will be backfilled with suitable material.
The infiltration gallery will be located as shown on Drawing 2.
Flow to the infiltration gallery and the head on the infiltration gallery will be controlled with a float valve
located in a sump. The float valve would close when the level of water in the infiltration gallery reaches
a predetermined elevation. A solenoid valve and mercury float switch will be provided as a backup to
the float valve. It is important to control the head on the infiltration gallery so that reinjected water will
not seep through the toe of the slope to the north of the infiltration gallery.
Shallow Injection Well
Monitoring well MW-6 will be converted into a shallow injection well. Treated water will be pumped
to the shallow injection well to raise the head behind the infiltration gallery to create a hydraulic barrier
to prevent migration of contaminated water in the area of the infiltration gallery upgradient toward the
building. A solenoid valve, operated by electrode level probes, will control the flow to the shallow
injection well. The purpose of the injection well is to raise the hydraulic gradient in the well vicinity and
influence the groundwater flow direction toward the recovery wells.
If either the solenoid valve or electrode fails, a well overflow line wili return the excess water to the
pump station sump.
System Piping
All piping with the exception of the well head piping, piping inside the equipment building, piping near
the injection well encasement, and well head piping at the infiltration gallery will be HDPE - PE 3408
piping,.

SYSTEM PERFORMANCE AND EVALUATION
Scheduled sampling of water from the recovery wells, treated water, and water from the background
wells will begin at the time of system start-up. This data will he used to evaluate the performance of the
system and monitor plume movement. The proposed sampling schedule is presented helow
SAMPLING INTERVAL AL DURATION
Effluent Sampling (treated water)
Once a week First 4 weeks
Once a month Next 5 months
Once a quarter thereafter
Influent (from recovery
Once a week
Once a quarter
Background Wells (
Once a quarter
ells
3, 4, and
First 4 weeks
thereafter
and 8

IV. EVALUATION OF ENVIRONMENTAL FEASIBILITY OF DISCHARGE ALTERNATIVES
Several non -surface water discharge options have been pursued and are discussed below.
A. Connection to Sewerage System.
Numerous contacts with the City of Monroe were initiated at different points of this project. An initial
request was made to the City on January 11., 1994 to accept purge water from several wells on the R.
P. Scherer/Chelsea Laboratories site. This request was followed up by delivering several published
articles from EPA guidance documents on treatability of R.CRA compounds. This request was denied (see
letter of January 24, 1994, Frederick to Maalouf, Appendix A).
A request for permission to discharge treated groundwater to the City of Monroe was made May 2, 1994.
Again, the City denied the request by letter (see letter by Mr. Tom Frederick dated May 25, 1994 in
Appendix A) citing the following reasons:
1. The City of Monroe Treatment Plant was not established for the purpose of receiving VOC-
pretreated wastewater nor is designed for this purpose.
2. No additional benefits would be gained by passing the treated water through the municipal
system.
3. The wastewater would result in a low revenue return to the City and may impose significant
risks or costs. The City also does not have the expertise to permit or monitor this type of
discharge.
R. P. Scherer offered to pay the expenses for the City to obtain a consultant to provide expertise in
evaluating the impacts of receiving this water into their system. The City did not accept this offer. As
a result, this alternative is not implem.entable and therefore not feasible.
On -Site Disposal.
Three options were proposed to Chelsea Laboratories, Inc. on behalf of R. P. Sch.erer. R. R. Scherer
does not own land in the Monroe, NC area, The options include using the treatment discharge as makeup
water for the cooling tower, and using the discharge water as irrigation water. Subsurface disposal of the
effluent was also considered, These options were discussed with Chelsea and with Marion Merrell Dow
Inc., the parent company of Chelsea..
A conference call was initiatedon April 22, 1994 with Mr. Al Baker of Marion Merrell Dow Inc. and
Mr. Ben Baker of Dow Corporation to discuss the preliminary design concept. This was followed with
a meeting with Mr. Jim Miller of Chelsea Laboratories and Mr, Al Baker (via conference call) on May
13, 1994. A request for permission to discharge on -site was addressed. The request was denied.
Discharge to the cooling tower was denied by Chelsea citing potential repercussions with new FDA
guidel in.es.
Both spray irrigation and subsurface disposal were denied citing the potential to spread liability with.
regard to potential cleanup if the contaminates were spread to other portions of the property.
14

Since the requests to discharge treated groundwater to the sewer or to allow on -site disposal were denied,
no cost analysis could be made* Therefore, a NPDES permit is required for discharging excess treated
groundwater*
Copies of correspondence with the City of Monroe and with Chelsea Laboratories and Marion Merrell
Dow are provided in Appendix A.

PROPOSED NPDES DISCHARGE
1t is proposed to discharge excess treated recovery water to the culvert under Hastey Road at Longitude
80d29'30", Latitude 34d58'51". An excerpt from the USGS 7.5 minute Monroe and Wingate quadrangles
is provided. Both the proposed discharge point and the discharge pathway are marked. Note that Hastey
Road has been relocated since the last revision of this quadrangle. A current site plan based on a recent
topographic survey is presented showing the current site and proposed facilities for this project. (See
Drawing 2).
The proposed discharge is for a maximum flow rate of 50 gpm (72,000 gpd). It is understood that the
anticipated well yield of this portion of the interim remediation project is 1.0 to 15 gpm... This request for
50 gpm is made to allow full utilization of the air stripping equipment. and allow for increasing well yield
or adding wells as needed.
The proposed design criteria of the air stripping unit is as follows:
Constituent
Chloroform
Tetrachloroethene
Trichloroethene
Benzene
C1S-1,2 Dichloroethene
Methylene Chloride
Influent
Concentration
mg/1
2.0
20.0
3.0
0.2
0.3
0.2
Effluent
Concentration
mg/1
0.002
0.002
0.002
0.002
0.002
0.002
Rogers and Cailcott Engineers has maintained contact with vendors to verify
specification for the air stripping unit will be a performance based spec'
equipment will meet the treatment goals.
16
s level of treatment.
ation to insure that the

REF.: U.S.G.S. 7.5-MINUTE MONROE AND WINGATE
QUADRANGLES, 1971, 1970, PH0T0REVISED 1988.
GRAPHIC SCALE
IN FEET
CONTOUR INTERVAL: 10 FEET
FIGURE 5.
U.S.G.S. TOPOGRAPHIC MAP
ONE -MILE RADIUS
R.P. SCHERER/CHELSEA LABORATORIES
MONROE, NORTH CAROLINA

APPendix
Correspondence ndenee th Manion Merrell Dow (Chelsea L lateries
May ' 4 Correspondence with City of Mtn N
Initial Correspondence with City or Monroe, N

June 1, 1994
Mr. Michael IF, Cashman
Senior Vice President
R. P. Scherer
2725 Scherer Drive
St, Petersburg, FL 33716-1016
Subject: Remediation Water Use Ban
Dear Mr. Cashman:
It has come to my attention that a plan has been proposed to remediate prior perchlorethylene
levels of groundwater contamination at the Chelsea Laboratories, Monroe, North Carolina site. After
reviewing the proposed options for use of the water stream after air stripping, I must inform you that it
is not acceptable to Marion Merrell Dow Inc., owner of Chelsea Laboratories to use the remediated
ground water in the Chelsea site cooling tower or as landscape irrigation as you suggest.
As Marion Merrell Dow Environmental, Health and Safety Director, it is my understanding
that the U.S, Food and Drug Administration would find the use of remediated water in the Chelsea
cooling tower unacceptable. The potential for cross contamination of a drug product with the service
cooling water is always under FDA scrutiny and thus is not an acceptable use for the remediated water
stream.
Using the remediated water stream to irrigate the site landscape is not acceptable because a
processing upset could potentially lead to further soil contamination. In this case, the question of
Chelsea's responsibility could complicate the remediation of prior contamination. The prior
contamination occurred during the period of time R.P. Scherer owned and operated this site, and prior
to the purchase by Chelsea Laboratories, Chelsea Laboratories is indemnified by R.P. Scherer for that
prior soil contamination. Possible future contamination could result in confusion as to which party is
responsible for that clean-up and cause Chelsea and MMD to suffer financial harm.
Therefore, use or remediated ground water in the cooling tower, or for landscape irrigation is
unacceptable. It would be our recommendation that the remediated water stream be discharged to the
local publicly owned treatment works or through a NPDES permitted point. If you require further
input, please do not hesitate to give me a call.
Sincerely,
Al S. Baker, Director
Environmental, Safety and Loss
Prevention
ASI3:ah
asb-059-94
COPY: Jim Miller, Chelsea
George Maalouf, Rogers & Cancan

AUGERS & _
ENGIN££RS
P.�1. Box 5655, Greenville. SC 2(T6Qfi
Phone (803)232-I556 • FAX(803)23w3-905'8
April 18, 1994
Mr, Al S. Baker, Director
Environment, Safety & Loss Prevention
Marion Merrell Dow, Inc.
P. O. Box 8480
Kansas City, Missouri 64114-0480
Subjeect: Preliminary Design of Interim Remediation System
R. P. Scherer/Chelsea Laboratories Facility
2021 E. Roosevelt Boulevard
Monroe, North Carolina
Dear Mr. Baker:
As we discussed last Friday, enclosed are preliminary design drawings for the proposed
interim remediation system at the subject facility. I hope to have your input regarding our ideas
prior to presenting this package to Mr. Jim Miller of Chelsea.
In our discussion last Friday, you expressed some concerns regarding the use of the
facility's cooling tower and grounds irrigation system as receiving points of the treated
groundwater. At startup, the proposed system has a significant safety factor with respect to
treatment. The estimated total initial flow from the four recovery wells is 12 to 15 gpm, and the
design flow rate for the proposed air stripper is 50 gpm, This air stripper has been sized to
reduce the contaminants of concern to less than detection values at the design flow rate, A
second design advantage is that approximately 70% of the air stripper effluent will be returned
to the air stripper influent for further treatment.

Mr : l S. Biker, Ltor
April 18, 1994
'age
If alternate treated water receiving points are not available to operate the system under
optimal conditions, a NPDES permit would be required to discharge the treated water into a
surface water body, This process can be very lengthy, We will approach the local POTW
representative about discharging treated groundwater to the suer, however, an earlier request
as denied.
'We will contact you on Friday, Apri 22, 1994 to discuss any cointments that you may
have and look forward; to receiving your comments.
Sincerely,
J. L ROGERS CAL CO ENGINEER INC,
George " " l uf, I'': :
G /c
enclosures
pc fir Michael el hm Scherer enclosures)
Eyler Tenn nt, Clark, Klein & Beaumont 10 enclos

R. P. SCHERER/CHELSEA LABORATORIES, INC.
MONROE, NORTH CAROLINA
r.1
INTRODUCTION
GROUNDWATER REMEDIAT1ON SYSTEM
APRIL 15, 1994
Chelsea Laboratories, Inc. of Monroe, North Carolina is a manufacturer of medicine tablets. This
facility was constructed, owned and operated by R. P. Scherer Corporation in 1976 for the
manufacturing of soft gelatin capsules. Chelsea purchased this facility from R. P. Scherer in
January, 1986 and has operated it since that time.
During cleanup of a diesel fuel spill in July 1992, Chelsea discovered tetrachloroethene (PCE) soil
contamination in the vicinity of the diesel spill area. Chelsea excavated the soil and notified R.
P. Scherer of the contamination. With approval from, the North Carolina Department of
Environment, Health, and Natural Resources (NCDEHNR), R. P. Scherer transported the
contaminated soil to an appropriate disposal/treatment facility and initiated a preliminary soil and
groundwater investigation in the area of the PCE contamination. The investigation indicated the
presence of limited PCE contamination in the soil and elevated PCE contamination in the
groundwater at the northeast corner of the building. Attachment "A" presents a summary of the
groundwater analysis.
Based on the findings of a preliminary investigation, R. P. Scherer and NCDEHNR's Inactive
Hazardous Sites Branch determined the need for a Remedial Investigation to delineate the extent
of soil and groundwater contamination, and design and implement appropriate remedial action
The site was designated number 51 on the Inactive Hazardous Waste Sites Priority List dated
March 11, 1994.

The purpose of the Interim Remediation System is to address n--site groundwater contamination
identified to date. Upon completion of the Remedial Investigation, treatment of off -site
groundwater may be required.
The proposed Interim Remediation System will consist of converting four monitoring wells into
pumping or recovery wells; installing an air stripping unit to treat contaminated groundwater;
constructing an infiltration gallery to introduce treated groundwater upgradient of the recovery
wells and area of contamination; converting an existing monitoring well to a shallow injection well
upgradient of the infiltration gallery and upgradient of the contaminant plume; and maintaining
a background monitoring well upgradient of the injection well. Refer to Drawing 2 for a
preliminary site plan showing the proposed location of these facilities.
GROUNDWATER .EDIATION SYSTEM
The proposed groundwater rem e cation system is presented schematically in Drawing 1. The unit
processes include:
Four pumping/recovery wells
Air stripping unit
Gravity settling chamber
Finished water pump station including high and low head pumps
Shallow injection well
Infiltration gallery.
Attachment "B" shows the anticipated operation of the system. When in operation, treated water
in the infiltration gallery and injection well will raise the water table in that area while the
recovery wells will create a depression in the water table. The resulting hydraulic profile should
further influence groundwater flow toward the recovery wells.

Monitoring wells MW-2, MW-3, MW-4, and MW-5 will be converted to groundwater recovery
wells. This will require reaming monitoring wells MW-3, MW-4„ and MW-6 to 6 inches in
diameter and installing pumps, controls, and piping, Well MW-2 is constructed with a stainless
steel casing and will be fitted with a smaller pump. The above ground equipment for each well
will be housed in a fiberglass enclosure with approximate dimensions measuring 42 inches by 36
inches by 42 inches tall. The enclosure will be hinged to allow access to the pumping equipment.
The well pumps are controlled by well water elevation with level probes. in addition, float
switches at the finished water sump will control pump operation to prevent overfilling of the
sump.
Contaminated groundwater recovered by the pumping wells will be pumped to a low profile, skid -
mounted air stripper. The air stripper will be housed in a 20 foot by 30 foot metal building. This
building could also serve as the operator's office, record keeping and general storage area for the
remediation project. As a convenience, flow meters for the pumping wells and some pump
controls could be installed inside the building.
The air stripper will be sized for a 50 gpm flow rate and will include a blower, prewired controls,
control panel, and gravity discharge. The PCE concentrations should be reduced to less than
0.002 mg/l. The preliminary design criteria for the air stripper is presented below:

Chloroform
Tetrachloroethene
Trichloroethene
Benzene
CIS-1,2 Dichloroethene
Methylene Chloride
Influent
Concentration
2.0
20.0
3.0
0.2
0.3
0.2
Effluent
Concentration
mat
0.002
0.002
0.002
0.002
0.002
0.002
Naturally occurring iron in the groundwater may be oxidized by the air stripper and precipitate.
A settling tank will be provided downstream of the air stripping unit to allow for settling of the
oxidized iron and other sand or sediment that may be in the recovery water. This will reduce
potential impacts on downstream reuses of the treated groundwater.
Finished Water Piimp➢ng-
Treated water from the air stripper and gravity settler will flow to a pumping station. The pump
station will be supplied with a low head submersible type pump and a high head staged pump. The
low head pump will pump treated groundwater to the shallow injection well and infiltration
gallery. In the event these options can not accommodate the total flow from the treatment unit,
treated water can be recirculated to the air stripper.
This system may produce and treat more water than can be returned via the shallow injection well
and infiltration gallery. Therefore, contingencies for alternate reuse options must be made. The
high head purnp will be available to reuse excess treated water for make-up water for the cooling
tower, or for supplemental water for the irrigation system.
The low head pump will be controlled by mercury float switches with low level off and high level
4

on switch points. The high head pump will operate off a pressure switch located at the pressure
tank with a low level off s
Gallery,
tc
n the sump to prevent the pump from running dry.
The infiltration gallery is two .150-foot long parallel pipes surrounded by stone. The piping
material is perforated corrugated ABS plastic pipe (commonly referred to as French drain). This
pipe will be installed in a &foot wide trench excavated to the bedrock layer (approximate elevation
980 feet MSL). The pipe will be installed with "full envelope" bedding using 3/4 inch diameter
washed stone. This will allow the treated water to percolate from the pipes and into the
surrounding soil. The bedding will be approximately 2 feet deep. The remainder of the trench will
be backfilled with suitable material. The infiltration gallery will be located as shown on Drawing
2.
Flow to the infiltration gallery will be controlled with a float valve located in a sump. The float
valve would close when the level of water in the infiltration gallery reaches a predetermined
elevation.
Sh
n
njection Well.
Monitoring well MW-6 will be converted into a shallow injection well. Treated water wi
pumped to the shallow injection well. A solenoid valve, paced by electrode level probes,
control the flow to the shallow injection well. The purpose of the injection well is to raise the
hydraulic gradient in the well vicinity and influence the groundwater flow direction toward the
recovery wells.
e
If either the solenoid valve or electrode fails, a well overflow line will return the excess water to
the pump station sump,

OTHER ITEMS
Re11Se of Excess Treated Water
As mentioned above, the recovery wells may produce more water than the infiltration gallery and
shallow injection well can accept. This is due in part to the permeability and transmissivity of the
soils on site. As a result, the system may produce excessive water which must be handled. At this
time, obtaining an NPDFS Discharge Permit to release the excessivewater is not desirable. This
process is time consuming, could result in additional monitoring of the discharged water stream,
and may require further treatment prior to release, Additionally, direct discharge to a stream is
discouraged by NCDEHNR.
One option is to use excess water as make-up water for the cooling tower. The high head pump
will be sized adequately to match the line pressure requirements of the cooling tower. A supply
line from the treated water pump station would be tied to the cooling tower supply line in such
a manner as to allow the treated water to be the primary water and the plant water supply to be
the supplemental source.
Another option is to use the excess water in the lawn irrigation system. It is our understanding that
the existing irrigation system is not in use at the present time.
Handling of Excavate4 Ma
During construction of the infiltration gallery, a portion of the soils. excavated may contain
elevated levels of PCE. It is estimated that approximately 150 CY of material may be generated.
NCDEHNR has been informally contacted to determine if the excavated soil containing PCE can
be used as backfill for the infiltration gallery. NCDEHNR would not commit to a definitive
position on this issue. As a result, two options have been given preliminary consideration. The
first option is to haul. the contaminated soil to the Pinewood, South Carolina landfill operated by
6

e second option is to tr =the soil on site. One method is to stockpile. e contd.! inated soil in
roll -off containers. The bottom of the roll -off container wilf be filled with gravel and will have
airdiffuser piping. A blower or vacuum pump would be connected to the diffuser to force air
through the soil thus stripping the PE. This xtay involve additional permitting,
SYSTEM PERFORMANCE ND EVA
Scheduled sampling of water from the r •very ells treated
background wells will begin at the time of system start-up. This data
performance of the system and monitor plume
presented below;
ater, water from he
l be used to evaluate the
mo einent, The proposed sampling schedule is
SAMPI INTO INTER VA I.
Effluent Sampling (treated water)
Once a week
Once a month
Once a quarter
Influent front r over)/ wel
Once week
Once a quarter
Background round Wells
Once a quarter
The cost associated with sampling is not included b
First 4 wt
Next 5 ruonth
thereafter
-, 3, 4, and
First 4 weeks
thereafter

A
tentative schedule f t vzties throu h start p of the s stein is presented bet
o
Prea Design pp ,
Preliminary Design 1
- Develop Constructior
- Approval by NCDEH
- Advertise for bids
Receive Bids
- Award Proj,
Notice to P
- Complete ConstrucConstruction
S -up System
s schedule assumes acceptance by NCDEll of the design con : ]
may affect the schedule include changing to discharge per
additional rmittin, not presently anticipated, etc.
5/94
/22/94
'0/94
1/94
5/94
)5/94
9194
/94
95
/95
onceptual changes that
mans of the design,

ONSTiTI,. ENT I'VIW-
hl!orotorm <O.002'
cis-1,2-Dichloroethene <0 0021_._ _...-0 7
ethylene Chloride <0 002 0.2
Tetrachloroethene_0"
<0-021___
Tri-Noroeti-iene
0, 002
n:ene <0.002C
Ethylbenzene <0.002}
Toluene <0,002
Xylenes <
_. , ..._. O.Qa4!
Total Arornatocs (2) <"0.004-
Acetone <0,01
Volatiles (3) <0.011
0
<0, 2
SUMMARY OF LABORATORY ANALYSIS RESULTS
GROUNDWATER SAMPLES COLLECTED ON FEBRUARY 16, 1994
R. P. SCHERER/CHELSEA LABORATORIES FACILITY
MONROE, NORTH CAROLINA
Concentrations in Parts Per Million (mg/1)
0,7T ©.0038
0.26 ,.. 0•02
0„084 <0.00.
22 23
._. 0.086
2 ae944 ..., _..0.398
0.076 <0.00 <0.00 0 000 0.
<0.
<0.0� 00 <0.00 0Q 7
<0.0 <0.00 <0.00. <0.00
2•2 i 0.0047 < 0 0.90
0.00.0036 _ 0007
`..
2.276
<0,0 _...0069. _ _ .. 0.0
<Q•0 0.011
0.026 <0.00
©0.09
0.026
0,13
26,1
0.0369
0 029
0.9057
of the detected individual chlorinated compound concentrations.
2- Sum of the detected individual aromatic"compound concentrations,
`- Sum orthe detected individual volatile organic compounds (VOC's).
Maximum Contaminant Level in Groundwater based on Tilte 15A of North Carolina Administrative Code Subchapter 2L, Section .0202,
'Maximum Contaminant Level in Drinking Water based on Tilte J 5A of North Carolina Administrative Code Subchapter 18C,. Section .1500.
(>- rite MCI_ of0. i rng/l is for total trihalomethanes as it applies to community water systems using disinfectants and serve.a population of 10,000 or rncr
e
NE - Not Established
<0.0..
<0.0
<0.0
<0.00
0.0047
<0.00.
<0.00,. <0.00
O,tJ01-
0,67.79
<0.40' <0,00 r �_
<0.0 <0.004� 1 '
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AI IA

EXISTING
E3UILDING
PROPOSED
BACKGROUND
MONITORING WELL
(MW-7)
BEDROCK
EXISTING DRIVE
PROPOSED
INJECTION WELL (MW-6
PROPOSED INFILTRATION
TRENCHES
PROPOSED RECOVERY
WELLS (3 REQ'D.)
EXISTING MONT©RING
(MW-2)
EXISTING
WATER TABLE
HASTEY
STREET
--'r PROJECTED WATER T
INFLUENCE BY INTE:ITI
REMEDIATION SYSTE , t
ARY

CITY OF MONROE
P.0„ BOX 69 • MONROE, NOR11-1 CAROLINA 28111-0069
FAX [phone]
May 25, 1994
Mr. Michael Cashman, Senior Vice President
R. P. Scherer Corporation
2725 Scherer Drive
Saint Petersburg, Florida 33716-1016
RE: Groundwater Remediation Effluent nisch rge
2021 East Roosevelt Boulevard
Dear Mr. Cashman:
The City of Monroe has received and reviewed a request on R. P. Scherer's behalf by
Rogers & Callcott Engineers, Inc. to discharge effluent from an air stripper facility,
designed to remove volatile organic chemicals (VOCs) from contaminated
groundwater, into the City of Monroe sanitary sewer system. This request is being
denied for the following reasons:
(1) The City of Monroe Wastewater Treatment Plant was not established for
the purpose of receiving VOC-pretreated wastewater nor is it designed for this
purpose.
(2) According to the data submitted by Rogers & Callcott, the effective
retnoval of VOCs from the groundwater by properly designed treatment facilities
would yield an effluent of quality such that there would be no additional treatment
or benefit gained by passing the effluent through a municipal wastewater treatment
facility.
(3) The wastewater from this groundwater remediation facility would yield a
very low revenue return to the City of Monroe and impose very significant risks, or
potential costs. A discharge of ineffectively treated VOCs through the City's plant
could cause treatment inhibition, effluent permit violations, and sludge
contamination. The City does not have the expertise to properly permit and monitor
this type of discharge, nor do live have structures in place to effectively manage this,
type of risk.

If you have any questions, please call me at (704) 2824601.
ectfull
Tom L. ederick
Director of Water Resources
c: Mr. Steven Bowen, Rogers & Callcott Engineers, Inc.
Mr. Jerry Cox, City Manager
Mr. Kim Hinson, WWTP Superintendent
thAlogitkom0594kmicteSVS

ROGERS &CALL .'Orrr
ElNiG1NEERS,INC.
P.U. 3ca 5655, Greenville, SC'2906
Phone(SU3)232-1556 • FAX(80.3)2'33-9058
May 2, 1994
Mr. To re L. Frederick
Director of Water Resources
City of Monroe
P. Q. Box 69
Monroe, NC 28111-0069
Subject: Request for Permission to Discharge Treated
Groundwater to Municipal. Sewer
R.P. Scherer/Chelsea Laboratories Facility
2021 East Roosevelt Boulevard (Hwy. 74)
Monroe, Union County, North Carolina
R & C Project Number 93-121
tear Mr. Frederick:
1 L.. Rogers, P.C;.
[) Cal➢es�u P.E_
S W`Aver
Laboraia y Direct,,ar
Groundwater analysis at the referenced site have demonstrated some contamination with organic
solvents. Rogers and Callcott Engineers is working for R.P. Scherer to design a remediation system to recover
and treat the contaminated groundwater. The treatment system is being designed to remove volatile organic
compounds (VOC's) to below current detection limits of 0.002 mg/1.
Earlier this year a request was made to your office regarding the discharge of small quantities of
untreated drilling water collected during site assessment activities (Maalouf to Hinson, dated January 11, 1994).
That request was denied on the basis that the worst sample of groundwater was contaminated with hydrocarbons
(Frederick to Maalouf, dated January 24, 1994).
Since the previous request was for permission to discharge untreated drilling water, it is kindly requested
that your office consider accepting groundwater that has been treated to remove the VOC's of concern to less
than drinking water standards.
The proposed interim groundwater remediation system will consist of four (4) recovery wells that
produce a peak combined flow of 15 gpni. Under normal operation, the anticipated average total flow from
these wells is 8 to 12 gpni. This ground water will be treated with an air stripper, which has a design capacity
of 50 gpm, to remove the VOC's. Enclosed is a table which shows the concentration of the various pollutants
found in each recovery well, the estimated well yield, the estimated composite concentration of the various
pollutants in the combined flow from all the wells, the influent design concentration for each pollutant at the
it stripper and the design effluent requirement for the air stripper, It is noted that a recycle loop wig- be
signed into this treatment system, which will allow a portion of the treated groundwater to be recirculated
through the air stripper to further enhance treatment efficiency. Also, mechanical safeguards will be
designed into the tre<ttrnent system to Shut down the well pumps in the even t f an air tritrr r failure.

Mr. Tom L. Frederick
May 2, 1994
Page 2
The current plan is to inject a portion of the treated groundwater into the contaminated aquifer, in order
to expedite this rernediation effort. It is anticipated that 3 to 5 gpm of the treated groundwater can be returned
to the aquifer, so the balance of the treated water must be disposed otherwise. The options available for
disposal of this treated water are very Iitnited; therefore, your decision concerning this request to discharge
excess treated groundwater to the municipal sewer system is very important to the remediation efforts at the
Chelsea facility.
Since we are in the design phase of this project, it would be most helpful if this request could be
considered at your earliest convenience. If there are any questions or if we need to complete appropriate
application forms, please advise.
Thank you for your consideration and we look forward to hearing from you soon.
Sincerely,
J. L. ROGERS AND CALLC©1".t' ENGINEERS, INC.
Steven R. Bowen
SRBB:Is
Enclosure
cc: Mr. Joe Storella, Plant Manager, Chelsea Labcaratories, Inc.
Mr. Michael Cashman, Senior Vice President, R.P. Scherer Corp.
George Maalouf, R & C �,/

SUMMARY OF LABORATORY ANALYSIS RESULTS AND DESIGN CRITERIA
R. P. SCHERER/CHELSEA LABORATORIES FACILITY
MONROE, NORTH CAROLINA
CONSTITUENT
_
Chloroform
CIS-1 ,2-Dichloroethene
Methylene Chloride
Tetrach
oroethene
Trichloroethene
Total (1)
,(,Benzene�_�
Il Ethylbenzene
Toluene
X_rienes
Total Aromatics
A:etone
I1Total Valati
cted Well Production (opm
101.22
<0.04
0.05
0.35
0.19
101.81
Concentrations in mg/I
-4 5 COl"vPOSITE DESIGN A
0.084 <0.002
0.086
25.944 0.8398
<0.02 0.0069
<0.02 0.011
0.026 <0.002
<0.04 l
0.9057
0.076
<0.04
<0.08
Notes; 1- Sum of the detected individual chlorinated compound concentrations,
2- Sum of the detected individual aromatic compound concentrations.
3- Sum of the detected individual volatile organic compounds (VOC's).
Groundwater samples collected on February 16, 1994.
0.43' 2.0
0.001 7
0.01
0.04
0.02
0.05
0.05
0.05
0.05
TrE :t L flt II
< 0.0
0.002
<0.002
<0.002
0.002
0,002
0.002
0.002

r
CITY OF MONROE
P.0. BOX 69 • MONROE_, NORTH CAROLINA 28111.0069
FAX [phone]
January 24, 1994
Mr. George Y. Maalouf, P. G.
Hydrogeologist
Rogers 8t. Callcott Engineers, Inc.
Post Office Box 5655
Greenville, South Carolina 29606
RE: Request for Groundwater Well Discharge to City Sewer
Dear Mr. Maalouf:
The City of Monroe has reviewed your request to discharge up to 165 gallons per day of
groundwater from the Chelsea Laboratory site purged during well drilling for an investigation.
of possible groundwater contamination.
Regrettably, the City of Monroe cannot grant your request. The City does not have the
expertise on staff to consider a request of this type at the present time. Although the State
will advise you that the groundwater can be discharged to a municipal sewer with permission
from the local authority, the State has very specific rules which require that municipal sewer
systems regulate wastewater to prevent discharges which may inhibit biological treatment
operations, pass through the treatment plant and violate effluent standards, or contaminate
sludge. The analysis you have provided contains the presence of EPA priority pollutants.
We are unable to determine the potential effects of this discharge on our system.
I trust that you understand our position on this matter. Please contact me if you have any
questions.
Respectfully,
Toni L. Frederick
Director of Water Resources
c: Mr. Kim Hinson
tht\login \torn©I 94\geomo 124

ROGERS &CA.LLCOTT
ENc1NEERS, INC,
P,0. Bo 5655, Greenville, SC 29606
Phone [phone] • FAX[phone]
January 11, 1994
Mr. Kim A. Hinson
Supervisor, Wastewater Treatment
City of Monroe
P. C. Box 69
Monroe, N.C. 28111-0069
J.L. Roger P E
F. D. Callom, P.E
S. W. Avery, Jr .
Laboratory Director
Via Facsimile [phone]
Subject: Request for Temporary Permit to Discharge
Groundwater into On -Site Wastewater Treatment Plant
R. P. Scherer/Chelsea Laboratories Facility
2021 East Roosevelt Boulevard (Hwy. 74)
Monroe, Union County, North Carolina
R & C Project Number 93-121
Dear Mr. Hinson:
Rogers & Callcott Engineers is conducting a groundwater
contamination assessment at the Chelsea Laboratories facility in.
Monroe. The assessment is being conducted on behalf of the
facility's former owner R. P. Scherer Corporation.
The investigation will consist of installing several
groundwater wells at the facility. A certain volume of water will
be generated during the drilling process. This water is comprised
of city water that is used in the drilling process and groundwater
generated by development and purging of the wells prior to
sampling. Although the exact volume of water generated cannot be
determined at this point, we estimate that a daily average of two
to three 55-gallon drums will be generated over the next few weeks.
A laboratory analysis report of a "worst case" sample is
attached. Volatile organic compounds, mainly tetrachloroehtene,
were detected in this sample. The sample was collected from a
monitoring well located at the source of contamination; therefore,
the quality of the groundwater to be generated during drilling will
at worst be equivalent to the attached data, and at best will be
uncontaminated groundwater from background locations.
Per our discussion yesterday, the Hazardous Waste Section of
NCDEHNR informed me that the generated groundwater from this
investigation can be discharged into an on -site treatment plant
pending approval of the local sewer authority. Therefore, please
consider this letter as a written request for the City of Monroe's
approval to temporarily discharge groundwater generated during
assessment activities at the Chelsea site into the on -site

Mr. Kim A. Hinson
January 11, 1994
Page 2 of 2
wastewater treatment plant. A groundwater treatment system will be
constructed on -site in the near future for long term remediation;
therefore, our discharge request needs only be valid for assessment
activities until such a system is constructed. Records of the
actual volume of water and dates of discharge will be kept for your
review.
We appreciate your prompt review of this application and hope
to receive your written approval prior to starting field
activities, which are scheduled for January 18, 1994. In order to
avoid delays, I will contact you on Thursday, January 13 to answer
any questions you may have. If you have any questions in the
meantime, please contact me at [phone].
Sincerely,
J. L. DGERS & CALLCOTT ENGINEERS, INC.
Geor e Y. Maalouf, P.G.
NC Licensed Geologist 29
GYM/cb
Attachment
pc: Mr. Joe Storella Chelsea Laboratories, Inc.

P.O. Bo
( 03)23 -T5.
RPS/CHELSEA
MONROE, NC
C/O GEORGE Ci
DATE RECEIVED: 09/ 1 ` .99
3
DATE REPORTED: 6 1993
. . osATony DEI `ICATION
SA
39536
8
D)
SPECIFIC 1U'IVI
gshosient (FIELD)
105
7
CRIPTION
f. cs ftcoRE
SENEAveryJE
eory Dxreaor
PAGE
NW 2 GRAB ON 9' 1,f 3T 14: 25
ES T
6.7
6.7
6.7
457
468
418
477
° (FIELD) 17 4
WATER Er feet
E
T
O TiNUE ON PAGE
16.0

CLIENT.:
RPS/cle‘SEA
MOUROg. NC
C/O GEORGE MAALOUP
PAGE
DATE RECEIVED: 09/21/1993
DATE REPORTED: 10/06/1993
S.C. LABORATORY IDENTIFICATION NUMBER - 23105
ER
39536
39537
39538
PER
SAMPLE DESCRIPTION
MW /2 GRAB ON 09/21/93 AT 14:25
RINSATE BLANK GRAB ON 09/21/93 AT
15:10
TRIP BLANK GRAB ON 09/21/93 AT 09:30
Bagal
VOLATILE ORGANICS, Ag/L 39536 39537 39538
BENZENE
<50 <5.0 <5.0
M
BROMODICHLOROMETHANE <50 <5.0 <5.0
BROMOFOR
BROMOMETHANE <50 <5.0 <5.0
<50 <5.0 <5.0
CARBON TETRACHLORIDE <50 <5.0 <5.0
CHLOROBENZENE
CHLOROETHANE <50 <5.0 <5.0
CHLOROFORM <50 <5.0 <5.0
2,400* <5.0 <5.0
OHLOROMETHANE <50 <5.0 <5.0
DIBROMOCHLOROMETHANE <50 <5.0 <5.0
1,1 DICHLOROETHANE <50 <5.0 <5.0
1,2 DICHLOROETHANE <50 <5.0 <5.0
1,1 DICHLOROETHENE <50 <5.0 <5.0
CIS-1,2-DICHLOROETHENE 530 <5.0 <5.0
TRANS-1,2-DICHLOROETHENE <50 <5.0 <5.0
1,2 DICHLOROPROPANE <50 <5.0 <5.0
CIS-1,3-DICHLOROPROPENE <50 <5.0 <5.0
TRANS-1,3-DICHLOR0PROPENE <50 <5.0 <5.0
ETHYL BENZENE 64 <5.0 <5.0
METHYLENE CHLORIDE 290 <5.0 <5.0
1,1,2,2 TETRACHLOROETHANE <50 <5.0 <5.0
TETRACHLOROETHENE . -87,000 <5.0 <5.0
TOLUENE
550 <5.0 <5.0
1,1,1 TRICHLOROETHANE <50 <5.0 <5.0
1,1,2 TRICHLOROETHANE <50 <5.0 <5.0
TRICHLOROETHENE 6,600 <5.0 <5.0
TRICHLOROFLUOROMETHANE <50 <5.0 <5.0
VINYL CHLORIDE
ACETONE <50 <5.0 <5.0
XYLENE <50 <10 <10
<5.0HEXANE 330 <5.0 5.0
<50 <5.0 <5.0
*ESTIMATED VALUE
CONTINUED ON PAGE 3

ENT: /CIS..EA
MONROE, C
C/O L OUP
PAGE
DATE RECEIVED:09/21/1993
DATE REPORTED: 1 /0 /1993
W
536
3957
39538
OGATE
0 TORY NTIPICATIO
ER
2-DICELOROETHAN-4
4 -BROMOPLUOROBENZENE
REPO T I
- 23105
DESCRIPTION.
Ot°
/1/93 AI 14.25
RINSATE 09/21/93 AT
15:10
TRIP
Y CONT
COVERY
3956
09/2609/30
100
101
112
O rPORY MANAG
09/21/93 AT 09:30
101
105
113

Client Na
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United States Risk. Reduction
Environmental Protection Engineering Laboratory
Agency Cincinnati, OH 45268
Research and Development
"EPA Project Summary
Treatability of RCRA Compounds
in a BOD/Nitrification Wastewater
Treatment System with Dual
Media Filtration
Steven I. Safferman and Sanjoy K. Bhattacharya
The discharge of nitrogen and poten-
tially toxic or hazardous organic com-
pounds to the environment from
wastewater treatment plants has come
under scrutiny In recent years. Of
speclffc concern are the many organic
compounds excluded from Resource
Conservation and Recovery Act (RCRA)
regulations If they are discharged Into a
wastewater treatment plant This study
Investigated the treatabllity and fate of 28
organic RCRA compounds in a combined
organic removal and nitrification process
and secondary effluent gravity filtration.
A 3.8 L/min pilot -scale extended aeration
wastewater treatment system with dual
media effluent fitter was used for the
study. With a total concentration of ap-
proximately 1.5 mg/L organics (sum of
the concentration of all 28 RCRA com-
pounds) in the aeration basin, most of the
compounds were removed to below
detectable limits by secondary treatment
under either acclimated or unacclimated
conditions. The effectiveness of the ef-
fluent filter to remove organic com-
pounds could not be assessed as most of
the compounds entering the fitter were
already reduced to below detectable
levels. Ammonia removal was sig-
nificantly impaired at a total concentra-
tion of 19,2 mg/L organics in the aeration
basin. COD reduction was apparently not
inhibited at any of the spike concentra-
tions tested.
This Project Summary was developed
by EPA's Risk Reduction Engineering
Laboratory, Cincinnati, OH, to announce
key findings of the research project that
Is fully docurrtented In a separate report
of the same title fit ee Protect Report or-
dering Information at back).
Introduction
The effects of discharging hazardous
wastes into the environment without ade-
quate treatment have become of increasing
concern to regulatory agencies and the
scientific community. Some of the com-
pounds associated with hazardous waste
can accumulate in the environment and are
mutagenic, teratogenic, or carcinogenic.
They cart also volatilize into the atmosphere,
cause ground water contamination, and in-
hibit wastewater treatment processes.
Under the domestic sewage exclusion
statement, certain RCRA-regulated corn-
pounds are exempt from RCRA regulations
if discharged into wastewater treatment
plants. Such compounds are assumed to
be treated adequately by the facility and to
cause no process interference.
The treatability of these compounds must
be assessed and their effect on the treatment
process understood. The specific objective
of this study was to investigate the treatabllity
and fate of selected organic RCRA com-
pounds in a combination B©D/nitrification
process. The importance of this objective is
realized when the recent changes in regula-
tions to require reduced ammonia discharge
are considered. Many wastewater treatment
plants that previously did not stabilize
nitrogen may now be required to do so
One common means of achieving both
nitrification and carbonaceous BOO
removal is with an extended aeration sys-

tem. In this study, 28 RCRA compounds
with a broad range of properties were spiked
into a pilot -scale extended aeration system
with dual media secondary effluent filters to
achieve the following goals:
• investigate the treatability and fate of the
selected RCRA toxics in the nitrification
process for both acclimated and unac-
ciimated conditions and
• determine the effectiveness of effluent
dual media filtration to remove the com-
posite RCRA toxics.
Procedure
To carry out the objectives of this project,
two 3.78 L./min pilot -scale extended aeration
wastewater treatment plants with dual media
secondary effluent filters were constructed
and operated at the U.S. Environmental
Protection Agency (EPA) Test and Evalua-
tion Facility (T&E) in Cincinnati, Ohio. The
hydraulic retention time of each system was
16.8 hr and the average solids retention time
was 21 days.
The influent was primary effluent from the
Mill Creek Wastewater Treatrnent Plant In
Cincinnati, Ohio; primary effluent from one
of two pilot -scale conventional activated
sludge systems at the T&E facility; or a com.
bination of both. Because the conventional
pilot systems were being spiked with the
RCRA compounds, this design allowed
spiking of the extended aeration systems
continuously or intermittently at various
toxics concentrations..
The 28 RCRA compounds were spiked
into the conventional pilot systems at several
different concentrations ranging from 0.25 to
1.0 mg/L of each organic. These com-
pounds were selected to ensure a good
representation of RCRA compounds with a
wide range of properties. The resulting ran-
ges were Henry's coefficient: 0.0000 to
0.944; and log octanol/water coefficient:
0,07 to 8,69.
The three phased project studied (1)
process interference caused by organic
RCRA compounds, (2) treatability and fate
of organic RCRA compounds, and (3)
removal of organic RCRA compounds by
dual media effluent filtration, A description
of the procedures for each phase follows.
Phase 1, Process Interference
In this phase, the effect of the 28 RCRA
compounds on the ability of a pilot -scale
extended aeration wastewater treatment
plant to adequately treat the wastewater was
investigated. Chemical oxygen demand
(COD), nitrated ammonia, and total Kjeldahl
nitrogen (TKN) were the primary process
control variables used to evaluate the
system's performance.
The performance was compared under
five different spike conditions:
• baseline, system performance before any
spike had been added;
• total spike concentration of 1.8 mg/L,
which was calculated by summing the
amount of each compound found from
each event and taking the average of the
three events;
• total spike concentration of 4.8 mg/L,
which were similarly calculated as above;
• total spike concentration of 19.2 mg/L,
which was calculated based on the spike
pump's setting; and
• discontinuation of spike..
Phase 2, Treatability and Fate
in this phase of the project, the concentra-
tion of the 28 compounds at different stages
of the treatment process were studied. The
Influent spike concentration was about 01
mg/L for each compound, assuming mini-
mal removal by the primary clarifier, From
the literature and from preliminary opera-
tions, this initial concentration was selected
so as not to cause any process interference
to the system.
To Investigate the removal and fate of the
compounds under both acclimated and un-
accl'imated conditions, one of the extended
aeration systems was spiked continuously
with the RCRA compounds to allow the
microorganisms to become acclimated to
the toxics, The other system was spiked
only during sampling events so that the
microorganisms would not become ac-
climated.
Data were obtained from three sampling
events, each consisting of a 48-hr time
period. For the first 24 hr of each event, the
unacclimated system was spiked with the
RCRA compounds. For each event,
samples were taken every 4 hr and com-
posited for analysis of the RCRA com-
pounds.
Phase 3, Removal by Filtration
In this phase, the efficiency of dual media
effluent filtration to remove organic RCRA
compounds was investigated. To assess
the effectiveness, the concentration of each
compound was measured in the secondary
effluent (before entering the fitter) and then
in the fitter effluent. Data were obtained for
two secondary effluents:
• secondary effluent obtained from the ac-
climated extended aeration system, which
was being spiked at a total toxics con-
2
centration into the aeration basin of 1,8
mg/L and
• secondary effluent obtained from the ac-
climated conventional system at the T&E
facility, which was being spiked at a total
toxics concentration into the aeration
basin of 4.8 mg/L.
Samples were collected for RCRA com-
pound analysis 11 times: 3 for the extended
aeration system's secondary effluent and 8
for the conventional secondary effluent.
Results and Discussion
Phase 1, Process Interference
The process control parameters of COD,
ammonia, and nitrate were used to gauge
the process interference caused by the
spiked RCRA compounds during Phase 1 of
this study. Four spike concentrations were
tested. Figure 1 shows the percent removal
of TKN and ammonia and the increase in
nitrate resulting from secondary treatment
for each spike concentration. The trends in
the figure seem to indicate that nttr icatlon
was inhibited even at a low spike concentra-
tion, although ammonia reduction by secon-
dary treatment was not Inhibited until spike
concentrations between 4.8 and 19.2 mg/L
were reached, After spiking ceased,
nitrification returned to tts pre -spiking level
within a few days. COD removal did not
seem to be adversely affected by the spike
even at the highest composite concentration
tested, 19.2 mg/L
To assess the Interference of the RCRA
compounds on an unaccfimated system, a
parallel system was intermittently spiked.
The average total spike concentration (total
concentration of 28 compounds) was 1.3
mg/L for three shock loadings, which ap-
parently caused no inhibition of COD or am-
monia reduction.
Phase 2, Treatability and Fate
The treatability and fate of the 28 organic
RCRA compounds spiked in Phase 1 at a
total concentration of 1,8 mg/L was inves-
tigated in Phase 2 for acclimated and unac-
climated conditions. Composite samples of
aeration basin influent, secondary clarifier
effluent, and recycled activated sludge were
collected three times for analysis of the com-
pounds.
For the three sampling events from the
acclimated system, all of the compounds,
for which valid data were collected, were
removed to below detectable limits (Table
1). The variations in the aeration basin in-
fluent were probably caused by different
removal rates of the compounds in the
primary clarifier, background concentra-

8© —
70
3© -
4
vai of ammonia caused by seconday treatment
TlCf5i caused by secada ,f rre
increase in nitrate caused by secondary treatment, mg/L
2 I i I
0 4 '8 8 1©
Total spike concentration, mg/L
Figure 1. Acclimated conditions, ammonia, T*1, nitrate vs. concentration of spike.
tions of the compounds in M offs secondary
effluent and analytical errors.
For the three sampling events for the un-
acclimated system (spiked intermittently at
an average total concentration of 1.3 mg/L),
only four compounds had removals below
95%::1,1,2-trichloroethane, bis(2-ethylhexyl)
phthalate, toluene, and nitrobenzene (Table
2), The unacclimated conditions apparently
did not result in a significant reduction in
removal efficiency at the RCRA compound's
concentration tested,
Phase 3, Removal by filtration
The secondary effluent from both the ac-
climated and unacclimated nitrification sys-
tems were passed through dual media
effluent filters for the first 62 days of the
project. The secondary effluent from the
conventional system was passed through
one of the filters after day 62. Eleven
analyses were run for the organic RCRA
compounds going into and coming out of
the fitter: three for the nitrification secondary
effluent and the others for the conventional
system.
The filters removed approximately 50% of
the total suspended solids for most operat-
ing conditions. Because the secondary ef-
fluent from the nitrification system had very
low concentrations of RCRA compounds,
the effectiveness of the filters could not be
12
assessed for the first 62 days of the project.
Higher concentrations of some of the com-
pounds were present Ir. the secondary ef-
fluent from the conventional system. The
results indicate acetone, tetrahydrofuran,
tetrachloroethylene, and phenol had sig-
nificant removals by the filters (Table 3).
Values for these compounds, however,
were found only in Event 9. The remaining
compounds, for both Events 4 and 9, had
removals under 20%.
Conclusions
The following conclusions were drawn
from this study:
• COD removal was not inhibited at the
tested composite spike concentrations of
1.8, 4.8 (measured by summing the con-
centrations of all 28 compounds into the
aeration basin), and 19,2 mgJL (estimated
based on pump setting).
• Ammonia removal was significantly in-
hibited at the composite spike concentra-
tion of 19.2 mg/L (the sum of the
concentrations of ail 28 compounds into
the aeration basin).
• Almost 100% of the spiked organic RCRA
compounds were removed when the
spike concentration was at 1,8 mg/L (the
14
16
18
sum of the concentrations of all 28 com-
pounds into the aeration basin) for the
acclimated condition and 1.3 mg/L for the
unacclimated condition,
• Adsorption did not appear to be a principal
mechanism for the removal of the RCRA
compounds,
Recommendations
This study Indicates that an extended
aeration wastewater treatment plant can ef-
fectivety remove low concentrations of or-
ganic RCRA compounds without interfering
with B00, ammonia, and suspended solids
removal. Because of the many different
combinations and concentrations of RCRA
compounds that could be expected in the
influent to a municipal wastewater treatment
piiant, a correlation between this study and a
real life situation is risky. Further studies and
surveys of actual extended aeration was-
tewater treatment plants are required to con-
firm these study findings, to determine if or
when harmful by-products are produced,
and to find the compound's removal
mechanism.
This report was submitted in fulfillment of
Contract No, 68-03-4038 by the University of
Cincinnati under the sponsorship of the U S
Environmental Protection Agency.

Table 1. Summary o! Sampling Events for Acclimated Conditions
Compound
Event 1
Event 2
ABI. % REDSEC AB1. % REDSEC A8!. % REDSEC (ug/L) % REDSEC #
Cyclohexanone 210 100 N NF N NF
Methy ethyl ketone 130 100 150 100
Methyl isobufy! ketone 120 100 148 100
N NF N NF
Tetrahydrofuran 130 100 N NF
63 100
Carbon tetrachloride 79 100 64 100 70 100
Chlorobenzene 190 100 110 100
100 100
Chloroform 100 100 81 100 90 100
1,2-Dichloroethane 110 1 93 100
ee 100
1,2-Dichloropropane 99 100 67 100
74 100
Tetrachloroethyfene 73 100 64 100
ss 100
Trrchloroethylene 69 100 62 100
70 100
1, f,1-Tiichloroethane 100 100 70 100
77 100
1,1,2•Trlchloroethane 91 95 74 100 72 100
Ethylbenzene 75 100 65 100
95 INToluene
130 100 110 100 170 100
o-xyl®ne 150 100 21 100 42 100
Bis(2,ethythexytIphthalate 40 100 40 85
Butyl benzyl phthalate N 45 100NF 13 100 N NF
1,4-plchlorobenzene N NF N NF
42 700
2,4•DImethylphenof 10 100 N NF
2,4-Dinitrophenol 40 100 N NF
N NF N NF
Naphthalene 64 100 77 100
Nitrobenzene 67 100
35 100 N NF 68 100
4-Nitrophenol N NF N NF
Phenol 32 100
100 N NF 180
ABI-: Concentration Into aeration basin, pg/L,
AVG.: Average.
1: Influent concentration less than effluent concentration.
N: None detected.
NF: Compound not found in aeration basin Influent,
% REDSEC: Percent of compound reduced by secondary treatment.
#: Number of samples with valid values, out of 3,
Note: Acetone, Methylene Chloride, and Furfural were analyzed for but not found in feed or the compound found in the blank.
Event 3
4
AVG. ABL AVG.
210
143
120
97
71
133
90
95
60
68'
67
82
79
78
137
71
42
13
42
10
40
69
52
32
150
100
100
100
100 2
100 3
100 3
100 3
100 2
100 3
100 3
100 3
100 3
100 3
100 3
100 3
1€0 3
100 3
100 1
100 1
100 1
100 1
100 3
100 2
100 1
100 2
1
3

Table 2. Summary of Sampling Events for Unacclimated Conditions
Event 1 Event 2
Compound
Event 3
AVG. ABI. AVG.
AB!, % REDSEC AEI. % REDSEC AM % REDSEC 04g/L) % REDSEC #
Cyclohexartone 180 100 N NF N NF 180 100 1
Mealy ethyl ketone 140 100 240 100 330 100 237 100 3
Methyl isobutyl ketone 71 100 N NF 75 100 73 100 2
Tetrahydrofuran 97 100 N 1 N NF 97 100 1
Carbon tetrachloride 36 100 N NF 35 100 36 100 2
Chlorobenzene 65 100 76 100 73 100 71 100 3
Chloroform 72 100 36 100 66 100 58 100 3
1,2-Dichloroothane N NF 12 100 N NF 12 100 1
1,2-Dichloropropane 50 100 31 100 40 100 40 100 3
Tetrachloroethylerre 19 100 38 100 32 100 29 100 3
Trichlomethyiene 27 100 25 100 46 100 33 100 3
1,1,1-Trichforoethane 64 100 N NF 50 100 57 100 2
1,1,2-Trichloroethane 61 100 24 88 42 90 42 93 3
Ethylbenzene 17 100 77 99 45 100 46 100 3
Toluene 57 67 96 99 120 100 91 89 3
o-xylene 48 100 130 98 66 B 100 81 99 3
Bis(2--ethythexyl)phthalate 38 100 22 82 15 100 25 94 3
1,4-Dichlorobenzene 28 100 22 100 24 100 25 100 3
Naphthalene 54 100 50 100 38 100 47 100 3
Nitrobenzene 76 75 32 78 38 81 48 78 3
Phenol 170 100 130 100 220 100 173 100 3
ABI.: Concentration into aeration basin, kigli..
AVG,: Average.
8: Compound found in blank.
I: Influent concentration less than effluent concentration.
N.: None detected.
NF: Compound not found in aeration basin influent.
% REDSEC: Percent of compound reduced by secondary treatment.
#: Number of samples with valid values, out of 3,
Note: Acetone, Furfural, Methylene Chloride, Butyl Benzyl Phthalate, 2,4-Dintrophenol, 24-Dimethylphenol and 4-Nitrophenof
were analyzed for but not found in feed or the compound was found in the blank.
Table 3, Summary of Toxic Filter Sampling Events for Acclimated Conditions
Event 4 Event 9
Compound
FILIN. % RED. FOAL % RED,
Acetone 40 100
TetrahY droluran 230 41
Chloroform 30 21 31 15
1,2-Dichlome then e 88 9 100 15
1,2-Dichtoropropane 40 6 42 1
Methylene chloride 59 10 63 5
Totrachforeethylene 9 24
Trichloroethyiene 4 13 6 8
1,1,1-Trichloroethane 6 3
1,1,2-Trichloroethane 105 5
Phenol
6 100
Influent to filter.
% RED.: Percent reduction of compound by filter

United States
Environmental Protection
Agency
Risk Reduction
Engineering Laboratory
Cincinnati ©H 45268
Research and Development
EPA/600/S2.89/026 Mar. 1990
EPA Project Summary
Removal and Fate of
RCRA and CERCLA Toxic
Organic Pollutants in
Wastewater Treatment
Sanjoy K. Bhattacharya, Rao V. R. Angara, Dolloff F. Bishop, Jr.,
Richard A. Dobbs, and Barry M. Austern
Two separate studies were con-
ducted to Investigate the removal and
fate of 28 selected Resource Conser-
vation and Recovery Act (RCRA)
compounds (0.25 mgiL of each
compound) and 19 selected Compre-
hensive Environmental Response,
Compensation, and Liability Act
(CERCLA) compounds (0.5 mgiL of
each compound) in conventional
activated sludge treatment. In each
study, two pilot -scale (35 gpm) acti-
vated sludge systems (Solids Reten-
tion Time (SRT): 4 days for RCRA
study and 8 days for CERCLA study)
were operated in parallel at The U.S.
Environmental Protection Agency's
Test & Evaluation Facility In
Cincinnati, Ohio. One system was
spiked continuously with either RCRA
or CERCLA toxics to produce an
acclimated biomass; the other was
spiked intermittently with the same
toxics and sampled to determine
performance under unacciimated
conditions. The selected RCRA or
CERCLA compounds did not cause
any adverse effects on Chemical
Oxygen Demand (COD) and
Suspended Solids (SS) removals. The
concentrations of organics (RCRA
study) in the air emissions indicated
that the chlorinated aliphatic solvents
were essentially volatilized into the
plant air emission stream, whereas
the aromatic volatile benzenes were
substantially degraded. Additional
work is planned to attempt to reduce
the analytical variability encountered
In these studies.
This Project Summary was devel-
opedby EPA`s Risk Reduction Engi-
neering Laboratory, Cincinnati, OM, to
announce key findings of the research
project that is fully documented in a
separate report of the same title (see
Project Report ordering information at
back),
Introduction
A survey of publicly owned treatment
works (POTW) showed that concentration
of priority pollutants in the influent
wastewater to many of these plants
exceeded the allowable concentrations
for these chemicals, In a study of the fate
of 22 toxic organics in wastewater
treatment plants, researchers reported
that a typical POTW significantly (up to
90%) reduced the concentrations of most
of these compounds. Certain compounds
were, however, present in the activated
sludge effluent in relatively high (20-30
ug//L) concentration. In an investigation of
the comparative removal of priority
pollutants by six biological and physical -
chemical treatment processes, research-
ers reported that the activated sludge
process provided best results. A further
review of the literature indicated that only
limited data are available for many
priority pollutants.
In the study summarized here, the
removal and fate of selected RCRA and
CERCLA toxic organic pollutants were
evaluated with two pilot -scale activated

sludge systems fed municipal waste-
water, The 28 RCRA (semi -volatile and
volatile) and 19 CERCLA (semi -volatile
only) chemicals (Table 1) were spiked
into the raw wastewater in two separate
test periods.
Experimental Systems and
Testing Approach
The two activated sludge systems
were operated at a flow rate of 35 gpm
and a hydraulic retention time (HAT) of
7.5 hr. An operational SAT of 4 days was
used in the RCRA study period* In the
CERCLA study period, the SAT was 8
days. Each compound was spiked at
0.25 mg& for the RCRA study and at 0,5
mg/L for the CERCLA study. The
operating conditions and design char-
acteristics for the two systems used in
the study are given on the next page.
Both RCRA and CERCLA studies were
performed with an acclimated (con-
tinuous addition of toxicants) and an
unacclimated (intermittent spiking of
toxicants) system. These systems were
operated in parallel.
To sample from the air space above
the primary clarifier, the units were
covered and vented through a duct to the
Table 1.
Operating Conditions and Design Characteristics of the Pilot Systems
Design flow = 2.2 Us
= 191 rn3ld
Primary clarifiers -Diameter = 2.9 m
Weir diameter = 2.8 m
Surface area = 6.8 m2
Surface overflow rate = 28.0 m2im2„d
Aeration basins - 1...W:0 = 5.4 m:3.0 m:3,6 m
Surface area = 16.3 m2
Volume = 59,7 m3
Hydraulic residence time = 7.5 hr.
Secondary clarifiers -Diameter = 3.6 m
Surface area = 10,4 m2
Surface overflow rate = 18.4 m3/m2,d
roof. An air sweep equivalent to a 5
km/hr wind was maintained over the
surface of the primary clarifier by ex-
hausting air at 14,000 L/min. The
aeration basin was fitted with an air tight
cover and the off -gas was also vented to
the roof, Air flow in the aeration basins
averaged 5,600 Umin.
Automated analytical procedures were
used for the conventional pollutants
RCRA and CERCLA Toxic Organic Pollutants
RCRA study period CERCLA study period
acetone
cyclohexanone
furfural
2-butanone
4-methy1-2-pentanone
tetrahydrofuran
Carbon tetrachloride
chlorobenzene
chloroform
1,2-dichloroethane
t,2-(fichloropropane
methylene chloride
tetrachloroethylene
trichloroethylene
1,1,1 -trichloroethane
1,1,2-trichloroethane
ethylbenzene
toluene
total xyeneS
bis(2-ethylhexyl) phthalate
butyl benzyl phthalate
1,4-dichlorobenzene
2„4-dimethylphenol
2,4-clinitrophenol
naphthalene
nitrobenzene
4 -nItropherrol
pheno
7,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
1,2,4-trichlorobenzene
nitrobenzene
7,3-diriitrobenzerte
2,8-dinitrotoluene
p-cresol
4-chloroaniline
hexachloreethane
hexachlorobutadiene
dimethyl phthalate
diethyl phthalate
dibut)l phthalate
butyl benzyl phthalate
bis(2-ethyinexyl) phthalate
naphthalene
lindane
dieldnn
2
(COD, BOD, NH4-N, NO3-N and TKN)
and Gas Chromatography/Mass Spec-
trometry (GC/MS) procedures were used
for the toxic organic compounds. RCRA
samples were analyzed by a contract
laboratory (PEI Associates Inc.,
Cincinnati, OH). Air samples, collected in
stainless steel canisters, were analyzed
by GC/MS. From these data, masses of
each RCRA compound stripped during
the sampling event were calculated.
Sludge and liquid samples were also
analyzed by GC/MS according to
approved USEPA methods. Semi -volatile
RCRA compounds were extracted from
the samples with the use of continuous
liquid -liquid extraction. Prepared portions
of the extracts were injected into the
GC/MS for analysis. The semi -volatile
CERCLA compounds were analyzed
following Method 1625. Analyses were
performed at the EPA's Risk Reduction
Engineering Laboratory (RREL). Details
of the analytical procedures are in the
Project Report.
Three tests (sample collection events)
were performed during the RCRA study
period* For the CERCLA study, 11 tests
were done on the continuously spiked
(acclimated) system and 4 tests on the
intermittently spiked (unacclimated)
system.
Results
The presence of the spiked toxic
organics in the wastewater produced no
major adverse effects on the treatment of
conventional pollutants, Average re-
movals of conventional pollutants in the
pilot systems during the two studies
were between 94% and 97% for SS and
between 81% and 88% for COD. In the
RCRA study period, nitrification in the
activated sludge processes produced

average NH4-N reductions between 76%
and 81% percent in the CERCLA study,
the NH4-N removal was between 88%
and 98%. The CERCLA taxies (0.5 mg/L)
did interfere with nitrification in the
acclimated system,
Substantial variability occurred in the
reported results with some toxic com-
pounds, especially in the RCRA study
period. Table 2 lists average measured
concentrations of the selected RCRA
organics in wastewater and sludges for
the acclimated system. The difference
between the concentration of most toxics
in the spiked wastewater feed and
primary effluent was very small. The
primary sludge showed enhanced con-
centrations of the two phthalates and
naphthalene along with reduced concen-
trations in primary effluent; this indicated
adsorption onto sludge solids, Four
compounds (tetrahydroturan, 1.2 dichlo-
roethane, methylene chloride, and 1,1,2-
trichlordethane) were present in the
secondary effluent stream in high con-
centrations (between 95 and 140 ug/L);,
this indicated these organics were poorly
removed, Five other compounds (cyclo-
hexanone, furfural, 2,4-dimethyl phenol,
2,4-dinitrophenot and 4-nitrophenol) were
not evaluated because of inconsistent
results. The average removals of the
loxic compounds in the RCRA study are
summarized (Table 3), The removal of
RCRA organics with primary treatment
was between 3% and 44%©. The total
removals were between 37% and 99%.
The calculated percent stripped for the
individual volatile compounds varied from
104, to 130%. No air analyses were
performed for the .semivolatiles. Biode-
gradation of a compound was estimated
by subtracting the measured removals by
adsorption and stripping of the compound
from the total removal, The estimated
biodegradation was between -42% and
97%, A negative biodegradation indicated
inconsistent mass balance and the prob-
lems of estimating biodegradation with
this approach, Biodegradation appeared
to be the predominant removal mecha-
nism for the polar solvents and the
aromatic volatiles (e.g,, toluene: 72%,
xylenes: 66%, chlorobenzenes: 66%).
The unacclimated system (e.g., biodeg-
radation of toluene: 56%) showed similar
results, and no significant advantage of
acclimation was observed.
Table 4 lists the average concentra-
tions of the CERCLA organics. Five
compounds showed high concentrations
-in the secondary effluents: 1,2,4-trichlo-
robenzene; 89 ug/L; 2,6-dinitrotoluene;
125 ug/L; p-cresol; 156 ug/L; linden% 198
ug/L.; and dieldrin; 99 ug/L. The average
removals of the toxic compounds in the
CERCLA study are summarized in Table
5. The removals of CERCLA organics in
primary treatment with the acclimated
system was between 4% and 79%. The
total removal varied between 56%0 and
98%. Biodegradation was estimated by
subtracting the removal by adsorption
from the total removal of a particular
compound. The extent of biodegradation
varied between 28% and 100%. The
unacclimated system also exhibited
similar removals. Biodegradation values
were similar for both acclimated and
unacclimated systems (e.g., naphthalene:
79% and dimethyl phthalate: 85%), As in
the RCRA study, no significant advantage
of acclimation was observed for the
CERCLA compounds, In the CERCLA
study period, the amounts of organics
found in the complex primary sludge
samples were substantially lower than the
measured removals across the primary
process, Because of the analytical
variability encountered in these studies,
additional work has been planned..
Conclusions
The following conclusions were drawn
from this study:
1. The polar solvents and aromatic vola-
tiles were biodegraded to a great
extent. For example, toluene ex-
hibited 72% and total xylene showed
66% biodegradation.
2, A significant amount of chlorinated
aliphatic solvents may be volatilized
from an activated sludge system,
The percent stripped varied between
1% and 139%.
3. Pesticides (lindane and dieldrin) were
removed both by adsorption onto
sludge and by biodegradation in the
secondary tank.
The full report was submitted in partial
fulfillment of Contract No. 68-03-4038 by
the University of Cincinnati under the
sponsorship of the U.S, Environmental
Protection Agency.

Table 2. Average Concentrations (ugJL) of`,C A Organics from the Acclimated y.
Co rn and
Ac
Cycle he none
Fur
2-Butanone
4 -Methyl-2-c ontanone
Tetrahydrdfurara
Carbon tetrachloride
Chiorobenzene
Chloroform
rchloroethan
1,2-Dichtoropropans
thylene chloride
achtoroethane:
hloroettryfene
-frdchloroetllene
2-Trichlorootasne
8"tthylbenz In
Totarene
nes
9as-(2«ethylhexy
utylbenzyphthal'
1„4-Dbchterobfnzene
2,4-Dim8thytphenol`
2, 4 -Ctinr tr oh e n of
Naphthalene
Nitrobenzene,
4=Nltroprzenol
Phenol
201
260
216
196'
284
1p2,
eft
Average
1 447
14
238
799
260
255
255
304
228
standard
3Ovtation
Primary Effluent
tAverage of Three Test uns)
econdary Leff ent Primary stodge
tendard Standard
Average Deviation Avers o Deviation Ave
88 88
187 162
9 225
111 247
33 238
83 242
3' 323
8 212
434 146 3
44 194
57 186
233
49 202
47, 192
28 296
28
47 122
89,,
91
26
110
73
787
66
24
52
290 106
3 7 259
39 14 289
140 42 378
54, 20 270
107 62
70 3 163
5 2 254
5 6 273
97 14 191
3 246
2 0 1g
4 73t
6 0
6 0
447
228
65
27
29
Standard Standard'
r"aeon Average levitation
127
62
105 128 6
128 114 146' 111' 171 266
3 1 163 789 2
277 3 1
254 4 46
88 129 775
189 43 68
209
259
165
201
276
179
87
48 73
6 4
97 13t
3 2
1
142 128
5 t

Table 4. Av
Concen:ratla n tta
Compounds
0auhto,obenzene, Probably t,2
Drchlotobenzene, Probably
Dichiorobenzene, Probably 1,4'
7,2, 4 - Trichlarobenzene,
benzene
0anitrobenzene'
2, 6- 0rnrtrrtoitrene
,o•reso1
4• hloroantlarre
Hexandoretharte
robutadaene
yl phthalate
yi phthalate
rate
zyi phthalate
isf2- hylhexyllphthatale
Naphthalerai*
mane
Daeldrrn
CCLA
acs fr
Priori
Acclimated System (Average of Eleven Test Puns)
Standard' Staridaral
Average Deviation Av a Deyiastr'tan
49
375 4
32
207
447 79
264 41
• 406
547
346
576"
497
428
398
431
425
599
79
42
23
319
319
344
459 92
415 85
59 3
31 92
578 125
269
223
239
560
480
272
224
384
343
264;
19
45
30
47
44
40
120
SecondaryEffluent
Prirraary Sludge Sncona arlr Sludge
Standard Standard Standard
Average Devaaoon Average Deviation Average Deviation
25
41
89
32
125
156
30
10
12
17
12
198
22
7
130
11716 5282 233
10485 6194 373
11278' 5264 120
3r3392 17807 2270
377 88; 103
716 56 897
78' 13 730
41586"
484
1040
25709
29667
227
15719
16549
623
20151
164
397
9874
40
60
147
1962
41
1 t35
1727
183
223
134
140
599
/679
257
77
140.
447
509

Table 3. Average Percent Removals of RCRA Organics for the Acclimated System (Average of Three Test runs)
Primary Total" Removed in Sludge + Stripping Biodegradation
Compounds
Standard Standard Standard Standard Standard
Removal Deviation Removal Deviation Removal Deviation Removal Deviation Removal Deviation
Acetone 16.0 26.8 97".t 2,6 2
Cyclonexanone
Furfural
3
92 5
2-Butanone 44.0 31.1 95.0 2.8 7 0 7 1 94 1
4-Methyl-2-pentanone 8.0 60.8 97.5 3.5 1 2 2 7 95 6
Tetrahydrofuran 36,6' 54.7 3 4 6 1 28 52'
Carbon tetrachloride 5,7 75.3 98.3 0.6 7 7 739 77 -42 12
Chtorobenzene 7.0 17.7 99.0 0.8 1 1 38 9 60 9
Chloroform 6,7 19- 1 84.3 5.1 2 1 7'04 12 -21 17
7,2-Drchloroethane .53.0 78.8 3 2 67 11 -17 32
1„2-Drchloropropane 9,0 75.5 77.3 10.2 2 1 97 9 -25 12
Methylene chloride 9,0 27,9 73.0 75.6 724 40
Tetrachloroethane 9.0 21.6 95.3 1.5 1 2 729 22 -35 23
Trrchloroethylene 9,3 21,4 97,3 1.5 7 1 103 11 -6 12
1, t, 1 •Trichloroethane 72.0 17.8 98,0 1.7 1 1 122 15 25 17
T, 1,2-Trirhloroethane 8,3 12.2 52.3 18.9 2 2 56 9 -6 24
Ethylbenzene 4.0 24.1 98.7 0.6 1 7 22 3 76 3
Toluene 18.3 22.7 99.0 0.7 1 1 25 6 72 8
Total xylenes 7,3 20.7 98,7 0,6 1 1 32 10 66 9
8is-(2-elhylhexyl)-phthalate 20,7 6.0 96.7 0.6 11 8 85 8
Butylbenzylphthalate 44.0 9.0 91,0 3.5 77 6 81 9
1,4-Dichlorobenzene 8.3 7,6 94,3 2,1 2 1 93 3
2, 4-©imethylphenol
2,4-Dinitropnenol
Naphthalene 6.7 4,2 96.3 1.5 2 7 94 2
Nitrobenzene 4,3 7.2 95.7 1.5 1 1 93 6
4-Nitrophenol
Phenol 3.0 17,1 98.C7 1.t1 1 0 97 2
"Total Primary + Secondary
Sludge: Primary + Waste Activated sludge

Table 5. Avg1 y�,
CergU'n
nt Removals of CERCLA Organics for the Acclimated System (Average of Eleven Test R'urs)
Dichlorobennule A ibably 1.2
Dichlorobenzont, ably 1,3
Dichtorobenz4np, ably 1,4
1,2,4-Trichiorof4.
we
Nitrobenzene
1, 3-0initrobeniy14
2, 6•Dinitrltoluyry
p-Cresol
4-Chloroanilln+
Hexachloroe8r4v4
Hexachlorob,ye,
Dimethyt phihef
Diethyl phtheJ*y,
Bib+Jtyt phthel
Butyl benryl1'*a1d
Bis(2-ethy/hexylvwbglate
Naphthalene
Undone
Dieldrin
'Toter
"Sludge
Primary
condary
Waste Activated Sludge
r�data point available
Total'
Removed in Sludge.
Standard Standard
Removal Deviation Removal Deviation Removal
15.1
15.0
27.2
6.9
79.0
23.3
11,7
9,9
T1,6
15.0
12.8
9.8
21,4 35.2
34,3 16=2
39.8 13.6
3.5 6.2
3.6 7.6
36.5 10.7
43.6 11,3
9.9 9,6
18.7 8.0
54.0 15.2
93.4
88,9
95.3
85.1
92.8
96.7
68.2
73,9
87.6
97,1
96.2
98.1
97,6
96.1
Standard
Deviation
4.3 20 9
5.1 16 10
5.2 17 9
7.8 37 12 4,8
2.6 1 1 91
3,7
15.3 12 15 S7
21.9 2 1 69
23.1 2 1 78
2.5 0 00
4.5 50 16 47
1.5 1 0 97
1,6 1 1 96
3.T 42 10 54
3.9 49 12 47
97,9 1.3 14 9
55,9 39.2 27 To
81.4- 9. 1 48
SCinyrrna181h1 h�a and Rao V. R. Angara are with the University of Cincinnati,
and Bar 4622 ; the EPA authors Oolioff F. Bishop, Jr., Richard A. Dobbs,
Cincinnati OH Ausiern are with the Risk Reduction Engineering Laboratory,
Sidney A. y 4568
nth
The complet f rs the EPA Project Monitor (see below).
Organic 'porf, entitled "Removal and Fate of RCRA and CERCLA Toxic
Cost: S21.g� --vents in Wastewater Treatment," (Order No.. P8 69-195 200/AS,°
i+rhjact to change) will be available only from:
Natkre Technical Information Service
526t, fi,t Royal Road
Spr1`trflgld^ VA 22161
Telerrnrly. 703-487- 4650
The EPA Prcafr,.-',Menitor can be contacted at:
Risk Ruction Engineering Laboratory
U.S. Err"r,onmental Protection Agency
Cinciorsal, OH 45268
7
73
79
84
28
dation
Standard
Deviation
10
11
10
14
3
38
21
28
17
1
2
10
12
8
38
24

RREL Treatability Database
TREATMENT TECHNOLOGIES CODE AND ABBREVIATION TABLE
AQUEOUS DATA FILE
Ver. 4.0
Treatment Technologies (Those with data)
----------------------
AAS - Activated Alumina Sorption
AFF - Aerobic Fixed Film
AL - Aerobic Lagoons
API - API Oil/Water Separator
AS - Activated Sludge
AirS - Air Stripping
AlkHyd - Alkaline Hydrolysis
AnFF - Anaerobic Fixed Film
AnL - Anaerobic Lagoons
BGAC Biological Granular Activated Carbon
CAC - Che ically Assisted Clarification
ChOx - Chemical Oxidation JParantheses shows oxidation chemical
ie. ChOx(C1) is chlorine, ChOx(Oz) is ozone, and ChOx(Sur) is
surfactant)
ChPt - Chemical Precipitation
ChRed - Chemical Reduction
DAF - Dissolved Air Flotation
ED - Electrodialysis
Fil - Filtration
GAC - Activated Carbon (Granular)
IE - Ion Exchange
KPEG Dechlorination of Toxics using an Alkoxide (Formed by the reaction
of potassium hydroxide with polyethylene glycol (PEG400))
PACT - Powdered Activated Carbon Addition to Activated Sludge
RA - Resin Adsorption
RBC - Rotating Biological Contactor
RO - Reverse Osmosis
SBR - Sequential Batch Reactor
SCOx - Super Critical Oxidation
Sed - Sedimentation
SExt - Solvent Extraction
Soft - Water Softening
SS - Steam Stripping
TF - Trickling Filter
UF - Ultrafiltration
UV - Ultraviolet Radiation
WOx - Wet Air Oxidation
NOTES:
Scale
is the first process unit followed in process train
by the second ie. AS Fil - Activated Sludge followed,
by Filtration.
is the two units together ie. UFWPAC - Ultrafiltration
using Powdered Activated Carbon.
(B) is batch instead of continuous flow.
B - Bench Top
P - Pilot Plant F - Full Scale

Number after letter refers to the plant number in a spec
(ex, F7 - plant 7 is the seventh full scale plant in the
is reference
ndicated report)
Matrix
C - Clean water (ex. distilled)
D - Domestic wastewater
GW - Groundwater
HL - Hazardous leachate
I - Industrial wastewater
ML Municipal leachate
RCRA - RCRA listed wastewater
S - Synthetic wastewater
SF - Superfund wastewater
SP - Spill
T - Tap water
TSDF - Commercial treatment, storage and disposal facility - liquids
W - Surface water
SIC (Standard Industrial Classification)
Codes
For industrial wastewaters a 2 digit SIC code will be given following
the letter designation, i.e. 122 is a Textile Mill Products wastewater.
If the SIC code is unknown a U will be shown, I U.
10 - Metal mining
12 - Coal mining
13 - ail and gas extraction
20 - Food and kindered products
22 - Textile mill products
24 - Lumber and wood products
26 - Paper and allied products except computer equipment
27 - Printing and publishing
28 - Chemicals and allied products
29 Petroleum refining and related
30 - Rubber and misc. plastic products
31 - Leather and leather products
33 - Primary metals industries
34 - Fabricated metal products except machinery & transportation equip.
36 - Electronic and electric equipment
37 - Transportation Equipment
39 - Misc. manufacturing industries
47 - Transportation services
49 - Electric, gas, and sanitary
99 - Ncnclassifiable establishments industries
Effluent Concentration
Effluent concentration will be given as a arithmetic mean to two
significant figures. The number of samples used to calculate the
mean is given after concentration as (n) (ex. 13 (5) - 13 is the
mean of 5 sample values).
% Removal
Percent removal will be calculated on a concentration basis. If data
are available, it will also be calculated on a mass basis for

physical/chemical systems. Those values calculated on a mass basis
will be noted by a (m). An example would be:
% Removal: 99.95
98(m)
where Removal =
Reference Quality Codes
A -
B -
C -
D
99.95 is based on concentration
98 is based on mass
Influent - Effluent
Influent
Papers in a peer reviewed journal.
Government report or database.
Reports and/or papers other than in groups A or B not reviewed.
Group C papers and/or reports which have been given a "good"
quality rating by a selected peer review.
Group C papers and /or reports which have been given a "poor"
quality rating by a selected peer review. These data will only
be used when no other data are available.
Additional Codes Following Reference Codes
V - Volatile emissions data available in Reference
S - Sludge data available in Reference
$ - Costs data available in Reference
Physical/Chemical Properties Data
(c) - Values presented are values that were reported
in the reference as is and are only used where
are not available.
NA - Value for the particular property have not been
in literature to date.
Matrix
SOLIDS DATA FILE
calculated
measured
found
(Includes Thermal Destruction of Liquids)
Combination (two or more of the following)
Debris
Liquid (both aqueous and organic liquids)
Sediment.
Sludge
Soil
Groundwater
Technologies (Those with data)
------------
Treatment systems are non -in situ unless labelled in situ)" after the
name of the technology,
LTD - Low Temperature Desorption Fil - Filtration

SE - Solvent Extraction
TD - Thermal Destruction
Comp - Composting,
Sol - Solidification
Bio - Biological Treatment
CD - Chemical Destruction
BD,asp - Biological Destruction,
aerobic, solid phase.
Concentration
UV - UV Rad.\Light\Solar
Land - Landfarming
Elec Electro-Kinetics
Ozon - °zonation
TD RE - Thermal Destruction
(Rotary Kiln)
VE(in) - Vacuum Extraction
(in -situ)
------- -----
Number in ( " foliowing "After" is number of tests/runs used
to calculate average concentrations and "% Improvement".
Improvement,%
-------------
Change in % based upon "Analytical Method".
DRE = Conc. in - Exhaust gas Conc.
Conc. in
TCA, etc. = Conc. in soil at start - Conc. in soil at end
Conc. in soil at start
EPT, TCLP, etc. = Conc. of Infl. leachate - Conc. of Effl. leachate
Conc. of Infl. leachate
Scale
B - Bench Top, P - Pilot Plant, F - Full Scale
Number after letter refers to the test/run number or plant
number in the specific reference. The test/run is a continuous
flow process unless there is a "(B)" after scale, then it is a batch
process (ex. P1 (B) - is first pilot test under batch conditions).
Reference
Quality codes same as for "Aqueous" data file. One extra. field notes
if cost data are available in reference.
Analytical Method
-----------------
Lists anayltical test used. to generated both the "Before." and. "After"
concentrations except for "(DRE)" which is the destruction/removal
efficiency based upon feed mass per unit time and air emission mass
per unit time.
(DRE) - Destruction and removal efficiency
EPT - Extraction procedure toxicity test
TCA - Total contaminant analysis
TCLP - Toxicity characteristic leaching procedure test

frig Parameters
Key operational parameters during test/run.

RREL Treatability Database
TRICHLOR©ETHYLENE
CAS NO.: 79-01-6
COMPOUND TYPE: HYDROCARBON,HALOGENATED
FORMULA: C2 H CL3
CHEMICAL AND PHYSICAL PROPERTIES
MOLECULAR WEIGHT: 131.39
MELTING POINT (C): -84.8
BOILING POINT (C): 86.7
VAPOR PRESSURE @ T(C), TORR.
SOLUBILITY IN WATER E T(C) ,
LOG OCTANOL/WATER PARTITION
HENRY'S LAW CONSTANT, ATM x
ENVIRONMENTAL DATA
Ver Na. 4.0
77 @ 25
MG/L: 1100 @ 25
COEFFICIENT: 2.53
M3 MOLE -I: 1.17 E-2 @ 25
CHRONIC NONCARCINOGENIC SYSTEMIC TOXICITY
RISK ESTIMATES FOR CARCINOGENS
DRINKING WATER HEALTH ADVISORIES/STANDARDS
WATER QUALITY CRITERIA
AQUATIC TOXICITY DATABASE
FREUNDLICH ISOTHERM DATA
ADSORBENT
FILTRASORB 400
WESTVACO WV-G
WESTVACO WV-W
HYDRODARCO 3000
FILTRASORB 300
FILTRASORB 400
FILTRASORB 400
FILTRASORB 400
MATRIX
Ce
K 1/N UNITS
3390 0.416 ug/L ug/gm
3260 0.407 ug/L ug/gm
1060 0.500 ug/L ug/gm.
713 0.470 ug/L ug/gm
28.0 0.62 mg/L mg/gm
36.3 0.592 mg/L mg/gm
45 0.625 mg/L mg/gm
2.00 0.482 ug/L mg/gm
01/13/94
REF.
333A
2 O'31A
2031A
1006A
463A
1032A
191D
REF.
NA
4B
3468
4B
5B
REF.
73A
73A
73A
73A
3B
1028D
681D
79A

RREL Treatability Database
CAS NO.: 79-01-6
TECHNOLOGY
TRI CHLOROET'HYLENE
Ver. No. 4.0
INFLUENT CONCENTRATION - 0-100 ugfL
EFFLUENT
SIC SCALE CONCENTRATION
CODE ( ug/L )
MATRIX
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AS D
AirS D
AirS D
CAC+AirS D
ChPt. D
GAC D
TF D
TF D
TF D
TF D
AirS GW
AirS GW
AirS GW
AirS GW
AirS GW
AirS GW
AirS GW
AirS GW
AirS GW
AirS GW
AirS GW
AirS GW
Chox(H2O2Oz) GW
GAC GW
GAC GW
RO GW
AS I 28
AS I 28
AirS I U
PACT I 28
F9 <5 (4)
F37 2 (6)
F3 <0.7 (7)
F2 2.1 (3)
F 13 (6)
F5. <2.5 (7)
F5 16 (5)
F5 <0.7 (7)
F20 <1 (6)
F <0.1
F10 <1 (5)
Fi 0.5 (3)
F1 4 (4)
F12 1.3 (10)
F29 1.1 (12)
F22 4.5 (10)
F2 <0.2 (4)
Fi 0.013 (7)
F 0.2 (20)
Fi 0.21 (7)
F <0.02
F10 <1 (5)
F24 <1 (5)
Fil 5 (6)
F37 <1 (6)
F 0.3
P1 3.0
P 0.4 (1)
F 1.4
P <0.3 (1)
P <0.5 (1)
P1 4.3
P <0,5 (1)
P <0.5 (1)
F <0.5 (1)
P 0.7 (1)
P1 4.3 (1)
P2 3.7 (4)
F4 1.3
Fi <1.0
F2 5.5
F1 <5 (1)
F32 <10 (5)
P <1
F8 5 (1)
PERCENT
REMOVAL
>89
97.6
>71
90.6
87
>58
72
>92.3
>96.7
>95.7
>98.5
94.8
89.7
95.4
96.7
76
>77
93.8
90.0
77
>99.73
>98.5
>98.4
93.2
>98.8
99.68
93.2
99.60
98.1
>99.21
>98.7
87
>98.0
>99.44
>98.2
99.03
87
96.2
98.6
>98.8
79
>90.7
>89
>97.2
75
01/13/94
REFERENCE
1B ,S-
1B -S-
234A _--
238A ---
2 018 -S-
375E -S-
1B -5-
234A ---
18 -S-
1587E _--
18 -5-.
238A --
18 -S-
86B -S-
86B -5-
868 -S-
1682B ---
16828 -�
1833D ---
16'828 -- 1421D ---
18 -S-
1B --S-
1B -S-
1B -S-
1042E --$
369A ----
2128
69A --
2228
2078
1327E
215B
2218
223E
208B
1585E
84A --$
1.264E --$
12648 --$
250E --
32B ----
6B
205E
32B ---

28 i ? 10 >20
5 + AS I 28 F28 <10 >4787B
PACT B <10 >89 242E
AirS P2 0.3 99.44 3
R0 B P 68( 30 323
AS SF F6 <10 1} 8 245
AirS SF F7 5 >52 245B
B B 22 56 1.38E
+GAC TSDF 4 <2 >"73 2 B

RREL Treatability Database
CAS NO.: 79-01-6
TECHNOLOGY
AS
AS
AS
AS
AS
AS
AS
AS
Sect
TF
AirS
A1rS
AirS
AirS
AirS
AirS
AirS
AirS
AirS
AirS
AirS
ChOx(H2O2w©z)
GAC
RO
GAC
GAC
AS
AS
CAC
CAC
PACT
AirS
AirS
ChPt
Fir
GAC
UVw03 (B)
UVw03wH202 (B)
UVwH202
UVwH202
UVwH202
UVwH202 (B)
PACT
TRICHLOROETHYLENE
Ver. No. 4.0
INFLUENT CONCENTRATION - >100-1000 ug/L
EFFLUENT
SIC SCALE CONCENTRATION
CODE ( ug/L )
MATRIX
D
D
D
D
D
D
D
D
D
D
GW
GW
GW
GW
GW
GW
GW
GW
GW
GW
GW
GW
GW
GW
HL
HL
I 31
I 28
I 31
I 28
T 31
S
SF
SF
SF
SF
SF
SF
SF
SF
SF
SF
TSDF
P <1.5 (20)
F14 <3 (4)
F6 64 (6)
F4 37 (6)
F38 2 (6)
F28 87 (6)
F12 31 (5)
P1 7 (5)
F36 18 (5)
F39 <1 (5)
P 0.8 (1)
P 3.1 (1)
P 2.1 (1)
F <4
P 0.5 (1)
<5
P 27
P 1.2 (1)
F 0.46 (10)
P 0.2 (1)
P 16 (1)
P1 5.6 (1)
F5 <1.0
F3 110
F <10 (1)
F1 <10 (1)
F2 7 (1.)
F20 <10 (3)
F2 500 (1)
F8 20 (1)
F1 5 (1.)
P <5 (1)
F6 <25 (5)
F6 390 (5)
F6 390 (5)
F4 32 (5)
B1 <0.5 (1)
B2 <0.5 (1)
P1 2.4 (1)
P2 <0.5 (1)
P3 <0.6 (10)
B3 <0.5 (1)
B1 <1
PERCENT
REMOVAL
>98.6
>97.3
87
92.6
99.23
87
74
96.7
93.6
>99.33
99.58
98.6
98.9
>99.38
99.58
>97.1
87
99.69
99.913
99.917
95.5
95.9
>99.36
78
>95.8
>97.8
98.6
>94.1
0
88
95.2
>98.5
>93.6
21.
1
95.3
>99.69
>99.69
99.13
>99.87
>99.89
>99.65
>99. 69
01/13/94
REFERENCE
206B VS-
1B -S-
113 -S-
1B -S-
1B -S-
1B -5-
1B-S-
2418 VS-
86B -S-
1B -S-
2098 --$
211B --$
216B ---
199B --$
219E --$
1.363E ----
26A --S
217E
322B
220B
90D
84A
1264B
250B
237A
245B
31B
6B
31B -
32B
31B
71D
245B
245B
245B
245E
92D --$
92D --$
92D --$
92D --$
92D --$
92D --$
46E ---

RREL Treatability Database
CAS NO.: 79-01-6
TECHNOLOGY
AL
AirS
AirS
AirS
AirS
SS
SS
SS
ChOx(C1)
ChO►x(Oz)
AirS
ChPt
ChPt
Fil
GAC
GAC
Fi1+GAC
(B)
(B)
TECHNOLOGY
PACT
SS
AS
TECHNOLOGY
WOx (B)
WOx (B)
TRICHLOROETHYLENE
Ver. No. 4.0
INFLUENT CONCENTRATION - >1-10 mg/L
EFFLUENT
SIC SCALE CONCENTRATION
CODE ( ug/L )
MATRIX
GW
GW
GW
GW
GW
I 28
I 28
I 28
S
S
SF
SF
SF
SF
SF
SF
TSDF
F2
P2
F
P2
F1
F32
F2
B1
B2
P
F2
F8
F8
F2
F8
F3
<12 (3)
170 (1)
11 (7)
190
7.7 (1)
<10 (10)
<16 (14)
<5. (10)
9,200 (1)
9,500 (1)
<1 (3)
5,400 (1)
3,700 (5)
3,400 (5)
<10 (1)
<10 (5)
<750 (2)
INFLUENT CONCENTRATION - >10-100 mg/L
EFFLUENT
SIC SCALE CONCENTRATION
CODE ( ug/L )
MATRIX
HL
I 28
S
B8
F35
B
<5
<10 (2)
210
PERCENT
REMOVAL
>99.60
84
99.77
91.3
99.30
>99.79
>99.20
>99.911
8.0
5.0
>99.936
0
30
8
>99.46
>99.54
>73
PERCENT
REMOVAL
>99.985
>99.974
99.78
INFLUENT CONCENTRATION - >100-1000 mg/L
EFFLUENT
SIC SCALE CONCENTRATION
CODE ( mg/L )
MATRIX
B2 2 (1)
B2 1.7 (1)
PERCENT
REMOVAL
99.33
99.66
01/13/94
REFERENCE
87B
1585E -�--
322B --$
3.327E --$
211B --$
251B V-$
6B ---
2518 V-$
49E ---
49E - -
1362E $
245E ---
245B ---
245B ---
245B
245B ---
28B VS -
REFERENCE
46E ---
6B _--
202D VS -
REFERENCE
78E
78E

Appendix B
- Laboratory Analysis

WATER 6c SEWER DESIGN
INDUSTRIAL WASTES
GRANTS ex PERMITS
HAZARDOUS WASTES
SUBDIVISIONS
RECREATIONAL FACILITIES
&
x 5655. Greenv I
Phone(803)2 2-I556 • FAX
LABORATORY SERVICES
CLIENT: RPS/CHELSEA
MONROE, NC
c/o GEORGE MAALOUF
DATE RECEIVED: 03/31/94
NPDES MONITORING
WATER ANALYSIS
MONITORING WELL ANALYSIS
TREATABILITY STUDIES
TCLP ANALYSIS
SAMPLING 6&. PICKUP
DATE REPORTED: 04/08/94
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE NUMBER.
49660
PARAMETER
SAMPLE E'S?RIPTION
MW-8 GRAB ON 03/31/94 AT 1410
RESULT
pH, units (FIELD)
SPECIFIC CONDUCTIVITY, u
TEMPERATURE, a C (FIELD)
WATER LEVEL (FEET)
CONTINUED ON PAGE 2
s c
(FIELD)
9.1
206
17.9
10.15
2 Rr NJCL CI BRQT'i

CONSULTING ENQI,NEFRS
WATER & SEWER DESIGN
INDUSTRIAL WASTES
GRANTS & PERMITS
HAZARDOUS WASTES
SUBDIVISIONS
RECREATIONAL FACILITIES
FRS & ALLCOTT
ENGIN EERS. jNc.
P.O.. Box 5655, Greenville. SC 29606
Phone(803)232-I556 • FAX[phone]
LABORATORY SERVICES
CLIENT`:` RIBS/CH1 LSEA
MONROE, NC
c/o GEORGE MAALOUF
LABOIIATO,Y SERVICES
NPDES MONITORING
WATER ANALYSIS
MONITORING WELL ANALYSIS
TREATABILM' STUDIES
TCLPANALYSIS
SAMPLING & PICK-UP
PAGE 2
DATE RECEIVED: 03/31/94 DATE REPORTED: 04/08/94
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE__NUM ER SAMPLE DESCRIPTION
49660 MW-8 GRAB ON 03/31/94 AT 1410
49661 RINSATE BLANK GRAB ON 03/31/94
49662 TRIP BLANK GRAB ON 03/31/94 AT
PARAMETER
VOLATILE ORGANICS, ug/L
BENZENE
BROMODICHLOROMETHANE
BROMOF'ORM
EROMOMETHANE
CARBON TETRACHLORIDE
CHLOROBENZEN'E
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
DI BROMOCHLOROME'THANE
1,1--DICHLOROETHANE
1,2-DICHLOROETHANE
1,1-DICHLOROETHENE
TRANS-1,2-DICHLOROETHENE
CIS-1,2 DICHLOROETHENE
1,2-DICHLOROPROPANE
CIS-1,3-DICHLORO'PROPENE
TRANS-1,3-DIC,HLOROPROPENE
ETHYL BENZENE
METHYLENE CHLORIDE
1,1,2,2-TETRACHLOROETHANE
TETRACHLOROETHENE
TOLUENE
1,1,1-TRICHLOROETHANE
1,1,2-TRICHLOROETHANE
TRICHLOROETHENE
TRICHLOROFLUOROMETHANE
VINYL CHLORIDE
CONTINUED ON PAGE 3
RESULT
46660 466+61
AT 1420
0800
46662
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0

CONSULTING ENGINEERS
WATER & SEWER DESIGN
INDUSTRIAL WASTES
GRANTS & PERMITS
HAZARDOUS WASTES
SUBDIVISIONS
RECREATIONAL FACILITIES
ROGERS &CAL
ENGINEERS.INc•
P.O. Box 5655. Greenville, SC 2�
9tone(803,k232-1556 • FAX[phone]
LABORATORY SERVICES
CLIENT: RPS/CHELSEA.
MONROE, NC
c/o GEORGE MAALOUF
DATE RECEIVED: 03/31/94
N.C. LABORATORY CERTIFICATE NUMBER - 27
$AMPLE. NUMBER SAMPLE DES?RIPTION
NPDES MONITORING
WATER ANALYSIS
MONITORING WET ANALYSIS
TREATABILTTY STUDIES
TCLP ANALYSIS
SAMPLING & PICKUP
PAGE 3
DATE REPORTED: 04/08/94
49660 MW--8 GRAB ON 03/31/94 AT 1410
49661 RINSATE BLANK GRAB ON 03/31/94 AT 1420
49662 TRIP BLANK, GRAB ON 03/31/94 AT 0800
SURROGATE
VOLATILE ORGANICS
1,2-DICHLOR©ETHANE-D4
TOLUENE-D8
4-BROMOFLUOROBENZENE
CONTINUED ON PAGE 4
QUALITY CONTROL SUMMARY,
RECOVERY
49660 49661 4662
108
102
101
101
105
103
103
104
103

CNULTING ENGINEERS
WATER & SEWER DESIGN
INDUSTRIAL WASTES
GRANTS & PERMITS
HAZARDOUS WASTES
SUBDIVISIONS
RECREATIONAL FACILITIES
LABO
CLIENT: RPS/CHELSEA
MONROE, NC
c/o GEORGE MAALOUF
DATE RECEIVED: 03/31/94
5&CALLC©'If
ENGINEERS, INC.
Greenville. SC 29606
FAX [phone]
TORY SERVICES
LABO ORY SERVICES
NPDES MONITORING
WATER ANALYSIS
MONITORING WELL ANALYSIS
TREATABILITY STUDIES
T LP ANALYSIS
SAMPLING & PICK-UP
PAGE 4
DATE REPORTED: 04/08/94
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE'#
49660
MW-8
4'9661.
FIELD
BLANK
49662
TRIP
BLANK
ANALYSES CHRONOLOGY
PARAMETER
pH
CONDUCTIVITY
TEMPERATURE
WATER LEVEL
VOA.
VOA
VOA
REPORTED BY:
DATE/TIME
ANALYZED
03/31 1407
03/31 1407
03/31 1407
03/31 1158
04/06 1408 YENCO
ANALYST
E'LLISON/RAMEY
11
u
04/06 1626 YENCO
04/06 1712 YENCO
LABORATORY MANAGER
METHOD#
9040
9050
170.1
8260
8260
8260

WATER MA X SPIKEIMATSPIKE DUPLICATE RECO RY
DATE EXTRACTED:
DATE ANALYZED: t4 /
VOAi
ACID
PEST
ANALYST:
ANALYST:.
CONC. SPIKE SAMPLE CONC. % CONC. Q
ADDED (rg/L) IlF UT.°1` MS RED MSD PCs RPD 1$PD RECO
Oi1T OF OUTSIDE QC Lim'1TS RECOVERY: VOAs , 00 i OF •
O !T 0 OUTSIDE QC LIMITS BIN our OF
OUT OF OUTSIDE QC LIMITS ACID OUT OF
OUT OF OUTSIDE QC LIMITS PEST OUT OF
REVIEWED BY:
GC/GC] iS LAB: INITIA
EXTRACTION LAB: tN TIALS. UA
QUALITY CONTROL: INITIALS
LI
U
LIMITS
LIMITS

HERS &
ENGINE
Client Name
Address
c
P.0, Box 5655, Greenville, SC 29606
Phone (B03) 232-4556 • FAX (B03) 233-9058
Attention ...
Telephone No.
R&C
Lab No.
SAMPLER
Relinquished by (Sig.)
wished by (Si
Sample Station ID
Date/Time
(( /7;
Date/Time
Re eiv Sigt.)
Shipp
iRReece)ved by (S+g.)
Shipper Name & n
ived by (Sig.)
pper Name &
Seal a at°chd by
„ OF
Filtered (Yes/No)
Preserved (Cod
Refrigerated (Yes/No}
Sample typo (Grab/Composite)
to soiree (WW, GW, DW, other)
Preservation Code:
A - None D - NaGH
B-HNG3 E -HCL
C • H2SO4 F
HAZARDS ASSOCIATED WITH SAMPLES
Receipt Total C1 mg/L Receipt pH
Client P.O. Number
Subsequent Analysis: (Check)
Date Resubmitted
CHAIN OF CUSTODY RECORD PAGE
Date/Time
Date/Time

Page
Field Data Information Log for Ground -Water Sampling
Date (yr/mo/day)
Field Personnel
Site Name
Job 1
WeIiID% rd
Upgradient
Weather Conditions
Air Temperature
Total Wel Depth (TWD)
Depth to Ground Water (DGW) -,
Length of Water Column (LWC) - TWD.
t Casing Volume (OCV) . LWC x
5 Casing Volumes -
Method of Well Evacuation
37
gal - Standard Evacuation Volts
Method of Sample Collodion
Total Volume of Water Remov
//©
VOLUME PURGED (gaitona)
TIME (military)
pH ( S.U.)
Eh (mV)
Sp, Cond. (}tmhoa//cm)
Water Temp. ('C)
TURBIDITY (subjective) •
P.O. Box 5655, Greenviitc. aC 2
Ptxx+e(8©3)232-t556 • FAX [phone]
Diarnete
Material
Measuring Point Elevation. 7©P
Height of Riser (above land surface)
C/oS
Land Surface Elevation
Screened Interval , _, [►«
Dedicated Pump or Bailer YES
Steel Guard Pipe Casing
Locking Cap YES NO
Protective PostVAbutme YES
Weil Integrity Satisfactory .k YES
Well Yield LOW t / M9OERATE
HIGH
Remarks
FIELD ANALYSES
7
A.
/•
7
t) Clear (2) Srght (3) Mad 4
DMMENTSbBSERVATIONS:

ROGERS & LiroTT
ENGINEERS4N(7
P a Box 5655, Greenville, SC 29606
Phone [phone] FAX [phone]
CLIENT: EPS/CHELSEA
MONROE, NC
C/O GEORGE • OUP
Rogers, BE
F, 0, Galleon, RE.
S W Avery, ir
[sal:scamps), Dllector
PAGE 1
DATE RECEIVED: 02/16/1994 DATE REPORTED: 03/07/1994
N.C. LAMORATORY CERTIFICATE NUMBER - 27
SAMPLE N HER SAMPLE DESCRIPTION
4'7105
47106
47107
4'7108
DETER
MW 11 GRAB ON 02/15/94 AT 09:00
MW 12 GRAB ON 02/15/94 AT 09:25
MW 13 GRAB ON 02/15/94 AT 15:00
MW /4 GRAB ON 02/15/94 AT 11:40
RESULT
47105 47106 47107 47108
pH, units (FIELD) 5.6 6.6 6„7 6.8
5.7 6.7 6.7 6.8
6.0 6.7 6.7 6.8
6.1 6.6 6.7 6.8
SPECIFIC CONDUCTIVITY,
pmhos /cm (FIELD)
TEMPERATURE, °C (FIELD)
WATER LEVEL, feet
CONTINUED ON PAGE 2
424 369 1,038 1,149
412 386 1,025 1,144
384 370 1,033 1,138
383 400 1,094 1,132
17.5 1.4.8 17.1 17.9
22.31 10.32 8.76 9.90

CLIENT: RPS/CHELSEA.
MONROE, NC
C/O GEORGE MAALOUF
PAGE 2
DATE RECEIVED: 02/16/1994 DATE REPORTED: 03/07 '1994
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE NUMBER S
P
E DESCRIPTION
47105 MW #1 GRAB ON 02/15/94 AT 09:00
47106 MW #2 GRAB ON 02/16/94 AT 09:25
47107 MW #3 GRAB ON 02/15/94 AT 15:00
47108 MW #4 GRAB ON 02/15/94 AT 11:40
PARAMETER
VOLATILE ORGANICS
BENZENE
BROMODICHLOROMETHANE
BROMOFORM
BROMOMETHANE
CARBON TETRACHLORIDE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
DI BROMOCHLOROMETHANE
1,1 DICHLOROETHANE
1,2 DICHLO'ROETHANE
1,1 DICHLOROETHENE
CIS-1,2-DICHLOROETHENE
TRANS-1,2-DICHLOROETHENE
1,2 DICHLOROPROPANE
CIS-1,3-DICHLOROPROPENE
TRANS-1,3-DICHLOROPROPENE
-ETHYL BENZENE
METHYLENE CHLORIDE
1,1,2,2 TETRACHLOROETHANE
TETRACHLOROETHENE
TOLUENE
1,1,1 TRICHLOROETHANE
1,1,2 TRICHLOROETHANE
TRICHLOROETHENE
TRICHLOROFLUOROMETHANE
VINYL CHLORIDE
ACETONE
HEXANE
TOTAL XYLENES
CONTINUED ON PAGE 3
RESULT
47105 47106 47107 47108
<2.0 <40 <20 6.9
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 2,700 700 3.8
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 790 260 20
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 50 <20 11
<2.0 230 84 <2.0
<2.0 <40 <20 <2.0
<2.0 88,000 22,000 730
<2.0 350 26 <2.0
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<2.0 9500 2,900 86
<2.0 <40 <20 <2.0
<2.0 <40 <20 <2.0
<10 <200 130 29
<2.0 <40 <20 <2.0
<4.0 190 <40 19

CLIENT: RPS/CHELSEA.
MONROE, NC
C/O GEORGE MAALOUF
PAGE 3
DATE RECEIVED: 02/16/1994 DATE REPORTED: 03/07/1994
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE NUMBER
SAMPLE DESCRIPTION
47105 MW #1 GRAB ON 02/15/94 AT 09:00
47106 MW #2 GRAB ON 02/16/94 AT 09:25
47107 MW #3 GRAB ON 02/15/94 AT 15:00
47108 MW #4 GRAB ON 02/15/94 AT 11:40
SURROGATE
VOLATILE ORGANICS
1.,2-DICHLOROETHANE-D4
TOLUENE-D8
4-B'ROMOFLUOROBEN'ZENE
NOTE: RUNDERS` °N PA,
NOTE:
5
N,
% RECOVERY
1*
47105 47106 47107
93
102
100
104 (109 )
87*(99)
93(112)
SURROGATE RNCOY.
SURROGATE RECOVERIES ARE WITHIN CONTROL LIMITS
CONTINUED ON PAGE 4
1.07(103)
85*(9'7)
92(113)
47 08
93
96
99
SIS
S NOTED WITH
TERISK

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUP
PAGE 4
DATE RECEIVED: 02/16/1994 DATE REPORTED: 03/07/1994
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE NUMBER SAMPLE DESCRIPTION
47109 MW #5 GRAB ON 02/15/94 AT 16:45
47110 MW #6 GRAB ON 02/15/94 AT 10:00
47111 MW #7 GRAB ON 02/14/94 AT 17:30
47112 MW #8 GRAB ON 02/14/94 AT 16:00
PARAMETER
pH,, units (FIELD)
SPECIFIC CONDUCTIVITY,
Amhos/Cm (FIELD)
TEMPERATURE, °C (FIELD)
WATER LEVEL, feet
CONTINUED ON PAGE 5
RESULT
47109 47110 47111 47112.
5.9 6.0 7.4 9.2
6.0 5.8 6.7 9.2
6.1 5.9 6.5 9.2
6.0 6.0 6.6 9.2
306 170 131 195
319 165 129 195
316 168 129 298
329 180 140 198
16.3 18.3 19.1 18.6
6.25 19.55 14.85 11.12

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
PAGE 5
DATE RECEIVED: 02/16/1994 DATE REPORTED: 03/07/1994
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE NUMBER SAMPLE DESCRIPTION
47109 MW #5 GRAB ON 02/15/94 AT 16:45
47110 MW #6 GRAB ON 02/15/94 AT 10:00
47111 MW #7 GRAB ON 02/14/94 AT 17:30
47112 MW #8 GRAB ON 02/14/94 AT 16:00
PARAMETER
VOLATILE ORGANICS, gg/L
RESULT
47109 47110 47111 47112
BENZENE <40 <2.0 <2.0 <2.0
BROMODICHLOROMETHANE <40 <2.0 <2.0 <2.0
BROMOFORM <40 <2.0 <2.0 <2.0
BROMOMETHANE <40 <2.0 <2.0 <2.0
CARBON TETRACHLORIDE <40 <2.0 <2.0 <2.0
CHLOROBENZENE <40 <2.0 <2.0 <2.0
CHLOROETHANE <40 <2.0 <2.0 <2.0
CHLOROFORM 76 <2.0 <2.0 <2.0
CHLOROMETHANE <40 <2.0 <2.0 <2.0
DIBROMOCHLOROMETHANE <40 <2.0 <2.0 <2.0
1,1 DICHLOROETHANE <40 <2.0 <2.0 <2.0
1,2 DICHLOROETHANE <40 <2.0 <2.0 <2.0
1,1 DICHLOROETHENE <40 <2.0 <2.0 <2.0
CIS-1,2-DICHLOROETHENE <40 <2.0 <2.0 <2.0
TRANS-1,2-DICHLOROETHENE <40 <2.0 <2.0 <2.0
1,2 DICHLOROPROPANE <40 <2.0 <2.0 <2.0
CIS-1,3-DICHLOROPROPENE <40 <2.0 <2.0 <2.0
TRANS-1,3-DICHLOROPROPENE <40 <2.0 <2.0 <2.0
ETHYL BENZENE <40 <2.0 <2.0 <2.0
METHYLENE CHLORIDE <40 <2.0 <2.0 <2.0
1,1,2,2 TETRACHLOROETHANE <40 <2.0 <2.0 <2.0
TETRACHLOROETHENE 2,200 4.7 <2.0 3.8
TOLUENE <40 <2.0 <2.0 <2.0
1,1,1 TRICHLOROETHANE <40 <2.0 <2.0 <2.0
1,1,2 TRICHLOROETHANE <40 <2.0 <2.0 <2.0
TRICHLOROETHENE <40 <2.0 <2.0 <2.0
TRICHLOROFLUOROMETHANE <40 <2.0 <2.0 <2.0
VINYL CHLORIDE <40 <2.0 <2.0 <2.0
ACETONE <200 <10 <10 <10
HEXANE <40 <2.0 <2.0 <2.0
TOTAL XYLENES <80 <4.0 <4.0 <4.0
CONTINUED ON PAGE 6

97
93
95
96 96
100 102
100 100
CLIENT: / HEL E,
MONROE, NC
C/O GEORGE LODE
PAGE
DATE RE EIVE : 02/16/1994 DATE REPORTED: 03,/ / 1994
0 ~ , TORY ERT F AT NUMBER 27
NUMBERPLE
47109
47110
47111
47112
VOLATILE ORG IC
1, 2-INLET ~. E-D4
TLU E-
4 -BROMO FLUORE EN Z ENE
S"LE DESCRIPTION
5 GRAB ON 02/15/94 AT 16:45
GRAB ON / 1. / 4 AT 10:00
E ON 0 2/ 14 / 4 AT 17:30
G E ON 02/14/94 AT 16:00
RECOVERY
4'7109 4711 4°7111 471.12
103
89
SURROGATE RE RECOVERIESVERIES T1
CONTINUED ON PAGE 7

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE JCAALOUP
PAGE 7
DATE RECEIVED: 02/16/1994 DATE REPORTED: 03/07/1994
N.C. LABORATORY CERTIFICATE NUMBER ^- 27
SAMPLE NUMBER SAMPLE 'DESCRIPTION
47113 ORO POND . INFLUENT GRAB ON 02/15/94 AT 13:35
47114 ORO POND - EFFLUENT GRAB ON 02/15/94 AT 13:30
47115 FIELD BLANK GRAB ON 02/14/94 AT 17:00
47116 FIELD BLANK GRAB ON 02/15/94 AT 17:00
PARAMETER
VOLATILE ORGANICS, µg/L
RESULT
47113 47114 47115 47116
BENZENE <2.0 <2.0 <2.0 <2.0
BROMODICHLOROMETHANE <2.0 <2.0 <2.0 <2.0
BROMOFORM <2.0 <2.0 <2.0 <2.0
BROM©METHANE <2.0 <2.0 <2.0 <2.0
CARBON TETRACHLORIDE <2.0 <2.0 <2.0 <2.0
CHLOROBENZENE <2.0 <2.0 <2.0 <2.0
CHLOROETHANE <2.0 <2.0 <2.0 <2.0
CHLOROFORM <2.0 <2.0 <2.0 <2.0
CHLOROMETHANE <2.0 <2.0 <2.0 <2.0
DIBROMOCHLOROMETHANE <2.0 <2.0 <2.0 <2.0
1,1 DICHLOROETHANE <2.0 <2.0 <2.0 <2.0
1,2 DICHLOROETHANE <2.0 <2.0 <2.0 <2.0
1,1 DICHLOROETHENE <2.0 <2.0 <2.0 <2.0
CIS-1,2-DICHLOROETHENE <2.0 <2.0 <2.0 <2.0
TRANS-1,2-DICHLOROETHENE <2.0 <2.0 <2.0 <2.0
1,2 DICHLOR©PROPANE <2.0 <2.0 <2.0 <2.0
CIS-1,3-DICHLOROPROPENE <2.0 <2.0 <2.0 <2.0
TRANS-I,3-DICHLOROPROPENE <2.0 <2.0 <2.0 <2.0
ETHYL BENZENE <2.0 <2.0 <2.0 <2.0
METHYLENE CHLORIDE <2.0 <2.0 <2.0 <2.0
1,1,2,2 TETRACHLOROETHANE <2.0 <2.0 <2.0 <2.0
TETRACHLOROETHENE <2.0 <2.0 <2.0 <2.0
TOLUENE 7.1 <2.0 <2.0 <2.0
1,1,1 TRICHLOROETHANE <2.0 <2.0 <2.0 <2.0
1,1,2 TRICHLOROETHANE <2.0 <2.0 <2.0 <2.0
TRICHLOROETHENE 3.4 2.0 <2.0 <2.0
TRICHLOROFLUOROMETHANE <2.0 <2.0 <2.0 <2.0
VINYL CHLORIDE <2.0 <2.0 <2.0 <2.0
ACETONE 59 32 <10 <10
HEXANE <2.0 <2.0 <2.0 <2.0
TOTAL XYLENES <4.0 <4.0 <4.0 <4.0
CONTINUED ON PAGE 8

02/ AT
02/15/94 AT
AT 17:00
AT 17:00
4711.E
107
91
94
CLIENT; RPsiCHELSEA
MONROE, NC
C 0 GEORGE OOP
DATE RECEIVED: IVE 0 1/ 1994
DATE
REPORTED: °3
N.C. LABORATORY CERTIFICATE NUMBER 27
• P%E NUMBER
47113
47114
47115
47116
0 ATE
VOLATILE ORGANICS
1, - f1L R ETH -04
TOLUENE-D8
4-BRONOFLUOROBENZENE
CONTINUED PAGE
RAMP
E DESCRIPTION
ORO POND
ORO POND
FIELD
FIELD
47113
INFLUENT
EFFLUENT
K GRAB ON
K BON
PAGE
GRAB ON
GRAB ON
02/14/94
02/15/94
TROL T Ua

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUP
DATE RECEIVED: 02/16/1994
PAGE 9
DATE REPORTED: 03/07/1994
N.C. LABORATORY CERTIFICATE NUMBER .. 27
SAMPLE NMBER
47117
47118
47119
PARAMETER
VOLATILE ORGANICS,
BENZENE
BROMODICHLOROMETHANE
BROMOFORM
BROMOMETHANE
CARBON TETRACHLORIDE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHAN E
DIBROMOCHLOROMETHANE
1,1 DICHLOROETHANE
1,2 DICHLOROETHANE
1,1 DICHLOROETHENE
CIS-1,2-DICHLOROETHENE
TRANS-1,2-DICHLOROET'HENE
1,2 DICHLOROPROPANE
CIS-1,3-DICHLOROPROPENE
TRANS-s1,3-DICHLOROPR©PENS
ETHYL BENZENE
METHYLENE CHLORIDE
1, 1, 2, 2 TETRACHLOROETHANE
TETRACHLOROETHENE
TOLUENE
1,1,1 TRICHLOROETHANE
1,1,2 TRICHLOROETHANE
TRICHL©ROETHENE
TRICHLOROFLUOROMETHANE
VINYL CHLORIDE
ACETONE
HEXANE
TOTAL XYLENES
CONTINUED ON PAGE 10
SAMPLE DESCRIPTION
FIELD BLANK GRAB ON 02
EQUIPMENT/BAILER RINSA
AT 08:40
TRIP BLANK GRAB ON 02/
RESULT
47117 47118
/16/94 AT 08:45
TE BLANK GRAB ON 02 / 16
14/94 AT 08:10
47119.
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<2.0 <2.0 <2.0
<10 <10 <10
<2.0 <2.0 <2.0
<4.0 <4.0 <4.0

CLIENT:
RP S HE LEA
NR E, NC
0 GEORGE
U'
PAGE 10
RECEIVED: 0/ 1 , 1994 DATE REPORTED: RTED 7, :1994
N.C. L ,BO TORY CERTIP CATE NUMBER 27
E
47117
47118
47119
BER
SAMPLE DESCRIPTION
FIELD B E GRAB ON 0 1/ 4 AT 08:45
EQUIPMENT/BAILER RINSATE BUNK G B ON / 1. / 4
AT 08:40
TRIP BLANK GRAB ON 02/14/94 AT 0 1
B OGATE RECOVERY
VOLATILE ORGANICS 11 4711 471
132 DI HL H E HANE-D4 1
TLEN D
4-BROMOFLUOROBENZENE 94
REPORTED B
103
92
94
100
100
9
SURROGATE VER'S WITH. 1CONTROL%I,1 TS UN 'S NOTED W.ZTH
TORY MANAGER
1

CLIENT:
ERS 6.1UALLCO L 1
ENGIN EERS, INC.
P.O. Box 5655, Greenville, SC 29606
Phone(6O3)232-1556 • FAX[phone]O58
RPS/CHELSEA
MONROE, NC
C/O GEORGE MAAL©UF
1-LRogers.P.E.
F. D. Cancon, P.E.
Avvery
PAGE 1
DATE RECEIVED: 02/16/1994 DATE REPORTED: 03/07/1994
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE PARAMETER
47105 VOLATILES
MW #1
ANALYSES CHRONOLOGY
DATE
SAMPLED DATE/TIME METHOD # ANALYST
02/15/94 02/25 @ 00:11 8260 LYNCH
47106 VOLATILES 02/16/94 02/25 @ 20:17 8260 LYNCH
MW #2 TETRACHLOROETHENE If 02/28 @ 14.57
TRICHLOROET.HENE
47107
MW #3
VOLATILES
TETRACHLOROETHENE
TRICHLOROETHENE
47108 VOLATILES
MW #4
47109 VOLATILES
MW #5
47110 VOLATILES
MW #6
47111 VOLATILES
MW #7
47112 VOLATILES
MW #8
47113 VOLATILES
ORO INF.
47114 VOLLATILES
ORO EFF.
47115 VOLATILES
F.BLK.
CONTINUED ON PAGE 2
02/15/94 02/25 @ 19:05 8260
02/15/94 02/25 @ 11:11 8260
02/14/94 02/24 @ 22:24 8260
02/14/94 02/24 @ 20:37 8260
02/15/94 02/25 @ 17:51 8260
02/15/94 02/25 @ 16:00 8260
02/14/94 02/24 @ 23:36 8260
02/15/94 02/25 @ 15:23 8260
1Q 02/28 @ 14:17 "
LYNCH
11
1
02/15/94 02/25 @ 00:47 8260 LYNCH
LYNCH
LYNCH
LYNCH
LYNCH
LYNCH
LYNCH
LYNCH

CLIENT:
RPS/CHELSEA
MONROE, NC
C/O GEORGE LOUD
PAGE 2
DATE RECEIVED: 02/16/1994 DATE REPORTED: 03/07/1994
N.C. LABORATORY CERTIFICATE NUMBER - 27
S. *LE 1 PARAMETER
47116 VOLATILES
F.BLE.
47117 VOLATILES
F. ELK .
47118 VOLATILES
RINSATE
ANALYSES CHEVNO
5
DATE
PLED DATE/TIME METHOD / ANALYST
02/15/94 02/25 @ 14:46 8260
LYNCH
02/16/94 02/25 @ 14:07 8260 LYNCH
02/16/94 02/25 @ 18:28 8260 LYNCH
47119 VOLATILES 02/14/94 02/24 @ 23:00 8260 LYNCH
T.BLE.

S &CALLCOTT
GIN EERS, INC.
P 0 Box 5655, Greenvinc, SC 29606
Phone [phone] • FAX [phone]
Client Name
Address _
Attention
Telephone No,
R & C
Lab No,
SAMPLER
Relinquished ig„
FAX No.
Seal 2 at'chd b
Sample Station ID
Date/Time
Date/Time
Shippe
Seal
at"chd by
CHAIN OF CUSTODY RECORD PAGE OF
Date/Time
Date/Time
Date/Time
ecvd, Intact
Comments:
Filtered (Yes/No)
Refrigerated (Yes/No)
Semple time (Grab/Composite)
Sample source (WW, GW, DW, other)
Preservation Code:
A - None D NaOH
B HNO3 E HC1-
C - HSO4 F
HAZARDS ASSOCIATED WITH SAMPLES
Receipt Total C12 mg/L Receipt pH
Client EC, Number
Subsequent Analysis: Check)
' Date Resubmitted
' r Q

ERS &L►LLC©TT
ENGINE RS, INC.
Box 5655, Greeovilie, SC 2%06
Phone [phone] • FAX [phone]
Client Name 1 ` / a etCe
Address M(71 'CO _- NCB.
Attention
Te4ephone No,
&C
Lab No,
SAMPL' R
gRelinq ':Caed by (Si
Redi fished by (Si
ed by (Sig.)
at`chd by
Sample Station ID
Date/Time
Date/Time
Date/Time
Recvd. intact by
Seal 8 at'chd by
CHAIN OF CUSTODY RECORD PAGE ©F
Date/Time
Date/Time
DaterTime
Comments;
Filtered (Yes/No)
Refrigerated (Yes/No)
Semple type (Grab/Comp
Semple source (WIN, OW, DW, other)
Preservation Code:
A - None ©- NaOH
B-HN©3 E•HCL
C - H2SO4 F
HAZARDS ASSOCIATED WITH SAMPLES
Receipt Total Cl2 mg/L Receipt pH
Client P.O. Number
Subsequent Analysis: (Check)
Date Resubmitted

ROGERS &CALLCOTT
ENGINEERS. INC
P,O, Box 5655, Greenville, SC 29606
Phone [phone] • FAX [phone]
CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 10/08/1993
DATE REPORTED: 10/21/1993
N.C. LABORATORY CERTIFICATE NUMBER - 27
1, I,., Rogrrs,, P..E.:.
1 C,), Calicou„
s Avery,
Laboriiiory Dtre(:or
PAGE 1
SAMPLE NUMBER SAMPLE DESCRIPTION
40589 MW-2 GRAB ON 10/07/93 AT 13:00
40590 MW-1 GRAB ON 10/07/93 AT 13:50
40591 TYSON - SERVICE CENTER GRAB ON 10/07/93 AT
15:30
40592 TYSON - LIVE HAUL SHED GRAB ON 10/07/93 AT
15:50
40593 TYSON - FEED MILL GRAB ON 10/07/93 AT 16:10
PARAMETER RESULT
40589 40590 40591
pH, units (FIELD) 1) 6.4 6.0
2) 6.4 6.0
3) 6.4 6.0
4) 6.4 6.0
SPECIFIC CONDUCTIVITY,
Amhos/cm (FIELD) 1) 475 374
2) 464 373
3) 464 373
4) 464 374
TEMPERATURE, °C (FIELD) 16.9 18.4
5.9
196
17.2
WATER LEVEL, feet 16.31 28.93 29.75
*UNABLE TO MEASURE DUE TO SUBMERSIBLE PUMP IN THE WELL
CONTINUED ON PAGE 2
40592
6.4
542
18.5
40593
6.5
737
,11., rtrAW
18.7

CL
NT: 2PB/ HEL EA
MONROE, NC
C/O GEORGE k'^ LOUP
DATE RECEIVED:
08 1993
DATE REPORTED: 10/21.1993
N. C . LABORATORY CER IFIA 'E
AMPLE NUMBER
40594
40595
40596
40597
TER
PH, Hsi PIE D)
2)
4
SPECIFIC CONDUCTIVITY,
mhos/am (FIELD)
E 27
SAMPLE DESCRIPTION
TYSON - SUPPLY E0
TYSON - PARKING LOT
16:45
ALTER LOVE GRAB ON 10d
SURFACE WATER IGRAB
RESULT
40594 40595
6.6
6.6
653
2) 652
T PE TURF, °IO ELI))
WATER LEVEL, feet
4)
6.7
6.8
'727
732
20.7 27 ,9
35
*ESTIMATED VAL DUE SUBMERSI
CONTINi ED► ON PAGE
E
THE WELL
PAGE 2
B ON I/ '7 / 3 AT 16:30
GRAB ON 10/07/93 AT
07/93 AT 19.10
ON 10/ 6/ 3 AT 09:30
40596 40597
6.
5
1,277
17
4
17.90
6.0
'732
17.7

CLIENT: RPS/CHEL,SEA
MONROE, NC
C/O GEORGE MAALOUF
PAGE 3
DATE RECEIVED: 10/08/1993 DATE REPORTED: 10/21/1993
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE NT BER SAMPLE 'DESCRIPTION
40589 MW-2 GRAB ON 10/07/93 AT 13:00
40590 MW-1 GRAB ON 10/07/93 AT 13:50
40591 TYSON - SERVICE CENTER GRAB ON 10/07/93 AT
15:30
40592 TYSON - LIVE HAUL SHED GRAB ON 10/07/93 AT
15:50
40593 TYSON - FEED MILL GRAB ON 10/07/93 AT 16:10
PARAMETER RESULT
VOLATILE ORGAIICS,, , g/'L 40589 40590 40591 40592 40593
BENZENE
BROMO D I CHLOROMETHANE
BROMOFORM
BROMOMETHANE
CARBON TETRACHLORIDE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
DI BROMOCHLOROMETHANE
1,1 DICHLOROETHANE
1,2 DICHLOROETHANE
1,1 DICHLOROETHENE
C'IS-1,2-DICHLOROETHENE
TRANS-1,2-DICHLOROETHENE
1,2 DICHLOROPROPANE
CIS-1,3-DICHLOROPROPENE
TRANS-I,3-DICHLOROPROPENE
ETHYL BENZENE
METHYLENE CHLORIDE
1,1,2,2 TETRACHLOROETHANE
TETRACHLOROETHENE
TOLUENE
1,1,1 TRICHLOROETHANE
1,1,2 TRICHLOROETHANE
TRICHLOROETHENE
TRICHLOROFLUOROMETHANE
VINYL CHLORIDE
ACETONE
HEXANE
XYLENE
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
3,200 <2.0 2.1 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 23 30
<2,000 <2.0 <2.0 5.1 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
84,000 <2.0 <2.0 160 290
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
7,500 <2.0 <2.0 9.2 150
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
<10,000 12* <10 37* <40
<2,000 <2.0 <2.0 <4.0 <8.0
<2,000 <2.0 <2.0 <4.0 <8.0
*ACETONE PRESENT IN LAB BLAN1 AT 12 Fig/L
CONTINUED ON PAGE 4

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
PAGE 4
DATE RECEIVED: 10/08/1993 DATE REPORTED: 10/21/1993
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE NUMBER SAMPLE DESCRIPTION
40594 TYSON - SUPPLY ROOM GRAB ON 10/07/93 AT 16:30
40595 TYSON - PARKING LOT #3 GRAB ON 10/07/93 AT
16:45
40596 WALTER LOVE GRAB ON 10/07/93 AT 19:10
40597 SURFACE WATER - 1 GRAB ON 10/08/93 AT 09:30
PARAMETER
VOLATILE ORGANICS, µg/L
RESULT
40594 40595 40596 40 97
BENZENE 390 <8.0 <2.0 <2.0
BROMODICHLOROMETHANE <10 <8.0 <2.0 <2.0
BROMOFORM <10 <8.0 <2.0 <2.0
BROMOMET'HANE <10 <8.0 <2.0 <2.0
CARBON TETRACHLORIDE <10 <8.0 <2.0 <2.0
CHLOROBENZENE <10 <8.0 <2.0 <2.0
CHLOROETHANE <10 <8.0 <2.0 <2.0
CHLOROFORM <10 <8.0 <2.0 <2.0
CHLOROMETHANE <10 <8.0 <2.0 <2.0
DIBROMOCHLOROMETHANE <10 <8.0 <2.0 <2.0
1,1 DICHLOROETHANE 11 37 <2.0 <2.0
1,2 DICHLOROETHANE <10 <8.0 <2.0 <2.0
1,1 DICHLOROETHENE <10 <8.0 <2.0 <2.0
CIS-1,2-DICHLOROETHENE 130 20 <2.0 <2.0
TRANS-1,2-DICHLOROETHENE <10 <8.0 <2.0 <2.0
1,2 DICHLOROPROPANE <10 <8.0 <2.0 <2.0
CIS-1,3-DICHLOROPROPENE <10 <8.0 <2.0 <2.0
TRANS--1,3-DICHLOROPROPENE <10 <8.0 <2.0 <2.0
ETHYL BENZENE 38 <8.0 <2.0 <2.0
METHYLENE CHLORIDE <10 <8.0 <2.0 <2.0
1,1,2,2 TETRACHLOROETHANE <10 <8.0 <2.0 <2.0
TETRACHLOROETHENE 160 14 <2.0 2.3
TOLUENE 43 <8.0 <2.0 4.5
1,1,1 TRICHLOROETHANE <10 <8.0 <2.0 <2.0
1,1,2 TRICHLOROETHANE <10 <8.0 <2.0 <2.0
TRICHLOROETHENE 170 370 <2.0 5.2
TRICHLOR©FLUOR©METHANE <10 <8.0 <2.0 <2.0
VINYL CHLORIDE 10 <8.0 <2.0 <2.0
ACETONE <50 <40 <10 15*
HEXANE <10 <8.0 <2.0 <2.0
XYLENE 390 <8.0 <2.0 <2.0
*ACET 11E P1 ESENT IN LAB BLAND AT 12 Ng/L
CONTINUED ON PAGE 5

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
PAGE 5
DATE RECEIVED: 10/08/1993
DATE REPORTED: 10/21/1993
N.C. LABORATORY CERTIFICATE NUMBER - 27
SAMPLE NUMBER
40598
40599
40600
PARAMETER
VOLATILE ORGANICS
SAMPLE DESCRIPTION
FIELD BLANK ADJACENT TO LIVE HAUL SHED GRAB ON
10/07/93 AT 15:55
BAILER RINSATE (FIELD BLANK) GRAB ON 10/07/93
AT 14:00
TRIP BLANK GRAB ON 10/07/93 AT 08:10
RESULT
40598 40599 40600
BENZENE <2.0 <2.0 <2.0
BROMODICHLOROMETHANE <2.0 <2.0 <2.0
BROMOFORM <2.0 <2.0 <2.0
BROMOMETHANE <2.0 <2.0 <2.0
CARBON TETRACHL©RIDE <2.0 <2.0 <2.0
CHLOROBENZENE <2.0 <2.0 <2.0
CHLOROETHANE <2.0 <2.0 <2.0
CHLOROFORM <2.0 <2.0 <2.0
CHLOROME'1'HANE <2.0 <2.0 <2.0
DIBROMOCHLOROMETHANE <2.0 <2.0 <2.0
1,1 D'ICHLOROETHANE <2.0 <2.0 <2.0
1,2 DICHLOROETHANE <2.0 <2.0 <2.0
1,1 DICHLOROETHEN'E <2.0 <2.0 <2.0
CIS-1,2-DICHLOROETHENE <2.0 <2.0 <2.0
TRANS-1,2-DICHLOROETHENE <2.0 <2.0 <2.0
1,2 DICHLOROPROPANE <2.0 <2.0 <2.0
CIS-1,3-DICHLOROPROPENE <2.0 <2.0 <2.0
TRANS-1,3-DICHLOROPROPENE <2.0 <2.0 <2.0
ETHYL BENZENE <2.0 <2.0 <2.0
METHYLENE CHLORIDE 7.7 2.9 <2.0
1,1,2,2 TETRACHLOROETHANE <2.0 <2.0 <2.0
TETRACHLOROETHENE <2.0 <2.0 <2.0
TOLUENE <2.0 <2.0 <2.0
1,1,1 TRICHLOROET'HANE <2.0 <2.0 <2.0
1,1,2 TRICHLOROETHANE <2.0 <2.0 <2.0
TRICHLOROETHENE <2.0 <2.0 <2.0
TRICHLOROFLUOROMETHANE <2.0 <2.0 <2.0
VINYL CHLORIDE <2.0 <2.0 <2,0
ACETONE <10 <10 <10
HEXANE <2.0 <2.0 <2.0
XYLENE <2.0 <2.0 <2.0
CONTINUED ON PAGE 6

CLIENT: RPS/CHELSEA
MON RO E , NC
C / O GEORGE MAALOUF
DATE RECEIVED: 10/08/1993
DATE REPORTED: 10/21/1993
N.C. LABORATORY CERTIFICATE NUMBER - 27
PAGE 6
SAMPLE NUMBER SAMPLE DESCRIPTION
40589 MW-2 GRAB ON 10/07/93 AT 13:00
40599 BAILER RINSATE (FIELD BLANK) GRAB ON 10/07/93
AT 14:00
PARAMETER
TOTAL ANTIMONY
DISSOLVED ANTIMONY
TOTAL ARSENIC
DISSOLVED ARSENIC
TOTAL BERYLLIUM
DISSOLVED BERYLLIUM
TOTAL CADMIUM
DISSOLVED CADMIUM
TOTAL CHROMIUM
DISSOLVED CHROMIUM
TOTAL COPPER
DISSOLVED COPPER
TOTAL IRON
DISSOLVED IRON
TOTAL LEAD
DISSOLVED LEAD
TOTAL MAGNESIUM
DISSOLVED MAGNESIUM
TOTAL MERCURY
DISSOLVED MERCURY
TOTAL NICKEL
DISSOLVED NICKEL
TOTAL SELENIUM
DISSOLVED SELENIUM
TOTAL SILVER
DISSOLVED SILVER
TOTAL THALLIUM
DISSOLVED THALLIUM
TOTAL ZINC
DISSOLVED ZINC
RESULT
40589 40599
<0.20 <0.20
<0.20 <0.20
0.012 <0.005
0.010 <0.005
<0.01 <0.01.
<0.01 <0.01
<0.005 <0.005
<0.005 <0.005
<0.02 <0.02
<0.02 <0.02
0.04 <0.01
0.04 <0.01
8.6 <0.10
2.0 0.10
0.068 <0.005
0.031 <0.005
13 <0.02
12 <0.02
<0.0002 <0.0002
0.0002 0.0002
<0.02 <0.02
<0.02 <0.02
<0.05 <0.05
<0.05 <0.05
<0.01 <0.01
<0.01 <0.01
<0.10 <0.10
<0.10 <0.10
<0.05 <0.05
<0.05 <0.05
RESULTS IN MILLIGRAMS PER LITER (mg/L) UNLESS OTHERWISE NOTED.
CONTINUED ON PAGE 7

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAALOUF
DATE RECEIVED: 10/08/1993
DATE REPORTED: 10/21/1993
N.C. LABORATORY CERTIFICATE
SAMPLE NUMBER
NUMBER - 27
SAMPLE DESCRIPTION
PAGE 7
40589 MW-2 GRAB ON 10/07/93 AT 1
40599 BAILER RINSATE (FIELD BLAN
AT 14:00
PARAMETER
ACID EXTRACTABLEB, µg/L
PHENOL
2-CHLOROPHENOL
2-NITROPHENOL
2,4-DIMETHYLPHENOL
2,4-DICHLOROPHENOL
P-CHLORO-M-CRESOL
2,4,6-TRICHLOROPHENOL
2,4-DINITROPHENOL
4-NITROP'HENOL
4,6-DINITRO-O-CRESOL
PENTACHLOROPHENOL
BASE NEUTRAL EXTRACTABLES,
BIS(2-CHLOROETHYL)ETHER
1,3-DICHLOROBENZENE
1,,4-DICHLOROBENZENE
1,2-DICHLOROBENZENE
BIS(2-CHLOROISOPROPYL)ETHER
HEXACHLOROETHANE
N-NIT''ROSODI-N-PROPYLAMINE.
NITROBENZENE
ISOPHORONE
BIS(2-CHLOROETHOXY)METHANE
1,2,4-TRICHHLOROBENZENE
NAPHTHALENE
HEXACHLOROBUTADIENE
HE.XACHLOROCYCLOPENTADI ENE
2-CHLORONAPHTHALENE
DIMETHYLPHTHALATE
ACENAPHTHYLENE
2,6-DINITROTOLUENE
ACENAPHTHENE
2,4-DINETROTOLUENE
CONTINUED ON PAGE 8
RESULT
40589 40599
<20 <20
<20 <20
<20 <20
<20 <20
<20 <20
<20 <20
<20 <20
<20 <20
<20 <20
<20 <20
<20 <20
AgfL
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
00
GRAB ON 10/07/93

CLIENT:
EPS/HELSEA
MONROE, NC
C/O GEORGE
UF
DATE RECEIVED: 10/08/1993
DATE REPORTED: 10/21/1993
N.C. LAB° TORY CERTIFICATE NUMBER
SAMPLE N BER
40589
40599
PARAMETER
PAGE 8
SAMPLE DESCRIPTION
MW -2 GRAB ON 10/0/3 AT 1 : 00
BAILER RINSATE (FIELD BLANK)GRAB ON 10
AT 14:00
RESULT
RASE NEUTRAL EXTRACTARLES 40589 40599
,g/L (CONTINUED)
DIETHYLPHTHALATE
FLUORENE
4-OHLOROPHENYL PHENYL ETHER.
DIPHENYLAMINE (N-NITROSO)
AZOBENZENE
-BRO OPHENYL PHENYL ETHER
HEXACHLOROBENZENE
PWENANTNEENE'
ANTHRADENE
I -N -HDTYLPHTHALATE
FLUOEANTHENE
PYRENE
BUTYLBENZYLPHTHALATE`
<10
<10
10
10
<10
<10
<10
10
10
<10
BENO (A) TB EN <10
3,3'-D OHL POBEN ID NE <10
CHRYSENE <10
BIS (-ETHYLEEYL) PHTHALATE <10
DI N-O TYLP T TE <10
BENZO(B)FLUO THENE <10
BETO () ELUD" • THENE <10
BETO (A) PYRENE' <0
INiENO(1,,3-,D)PYENE <10
DIENO (A, H) ANTH GENE 10
BEND (, H, I) PER"LENE <1.0
CONTINUED ON PAGE
<`10
10
<10
<10
<10
10
0
<10
<10
10
0
<10
10
0
<10
10
10
<10
<10
<10
<10
<10
<1

CLIENT RP / HEL E,
'ZONE, NC
C/O E R E _ m,L OUR
DATE RECEIVED: 10/08/1993
DATE REPORTED: ED: 10/ 1/ 1993
N.C. LABORATORY CERTIFICATE 7U B R 27
SAMPLE N BED
40589
40590
4t9....
40592
40593
VOLATILE ORGANICS
1:IBLCCET E-D4
TOLUENE-DS
4-BROMOFLUROBENZENE
PAGE 9
.PLE DESCRIPTION
2 GRAB ON 10/07/93 AT 13 : 00
1 GRAB ON 10/07/93 AT 13:50
TYSON SERVICE CENTER GRAB ON 10/07/93 AT
15:30
TYSON LIVE HAUL SHED GRAB ON 10/07/93 AT
1 : 0
TYSON FEED MILL RAB ON 10/07/93 AT 16:10
rU a
RECOVERY
40589 4590 40591 4059 40593
107
97
87
ACID/BASE
NITROBENZENE 73
'LUOROB I PHEN"L 73
TERPBEL-14 85
FLUON 40
PHENOL D 7
2,4,8-TRIBROMOPHENOL 78
CONTINUED ON PACE 10
104 97 101 108
99 94 101. 10
92 92 106 93

CLIENT: RPS/CHELSEA
MONROE, NC
0 GEORGE r <a LOU
PAGE 10
DATE RECEIVED: 10/08/1993
DATE REPORTED: 10/ 1/ 1 93
N. C. LABORATORY CERTIFICATE NUMBER 27
SAMPLE NUMBER. PLE DESCRIPTION
40594 TYSON SUPPLY ROOM GRAB ON 10/07/93 AT 30
40595 TYSON PARKING LOT #3 GRAB ON 10/07/93 AT
16:45
40596 WALTER LOVE GRAB ON 10/07/93 AT 19 10
40597 SURFACE WATER — 1 GRAB ON 10/08/93 AT 09: 0
9SALTNTRO.LSMM
•'OCATE RECOVERY
VOLATILE ORG C..:
40594 40595 40596 40597
1,2 —D I CHLOROETHANE—D4 104 105 104 105
TOLUENE—D8 101 100 104 10
4—BROMOFLUROBEN Z ENE 96 91 109 94
CONTINUED ON PAGE 11

RPS/CHELSEA
.N.E, NC
C/O GEORGE ®*L B`
DATE RECEIVED . 1 /08
99
PAGE
DATE REPORTED 18 / 21/1993
N. C . LABORATORY CERTIFICATE 3U. B t
S,; PLE, N EER SAt1PLE DESCRIPTION
40598
40599
40600
S * • °GATE
VOLATILE ORGANICS
FIELD B E ADJACENT TO LINTE HAUL , SHED GRAB ON
10/6"7/ 3 AT 1 : 8
BAILER RINSATE (FIELD BLANK) GRAB ON 1 /0 / 3
AT 14:00
TRIP B' 4 K GRAB ON 10/ 0/ 3 AT 08: 10
' TROL�..i
EERY
40598 40599 40600
1,-DI CHLOE.OETHANE -D4 91
TOLDEN 93
4 BROMO Z. ENE 88
ACID/BASE NESTwS
NITROBENZENE
-°LUROB I PNENY L
TE N.ENYL-i 14>
2 -FLUOROPHENOL
D5
2,4,6-TR N PF EN L
95 92
93 93
90 89
79
93
90
27
81
AVORATORY i NAGER

Client Name
Address
Attention ..�
Telephone No.
R&C
Lab No.
SAMPLER
Reim d by
tS &
ENGINE
P,O, Box 5655, Greenville, SC 29606
Phone (B03) 232-1556 • FAX (803} 233-9058
FAX No.
at'chd by
Form Revised August 1989
Sample Station ID
Date/Time
Date/Time
DatefTime
d by ( ig.
Shipper am
Seal # at'chd by
CHAIN OF CUSTODY RECORD PAGE
Date/Time
7 o�
Date/Time
Date/Time
Recvd, Intact by
Comments:
V DCC.
OF
Filtered (Yes/No)
Preserved (Code)
Re/rtgreeted (Yes/No)
Sample type (Grab/Composite)
Preservation Code:
A - None ©- NuOH
a-HNo3 E-HCL
C • H2SO4 F -
HAZARDS ASSOCIATED 1 ')TH SAMPLES
Receipt Total Cl2 mg/L Receipt pH
Chent P.O. Number
Subsequent Analysis: (Check)
Date Resubmitted

ER
CLIE
.0,
anOW3
t
2
RPS/CHELSEA
MONROE,NC
C/0 GEORGE
SC 29
OUP'
DATE RECEIVED: 09/21/1993
DATE REPORTED: 10/06/1993
S.C.
S.L.
ORATORY IDE
1
6
233
/CATION
t-
RESULT
, units I'IE 6.7
6.7
6.7
6.7
SPECIFIC CONDUCTIVITY,
(FIELD) 4
57
468
4'7
477
TEMPERATURE, °C (FIELD) 17w4
WATER LEVEL feet 16.50
CONTINUED ON PAGE
27
Rogers. P .
( fcou, P.
'. A9505.ir
ry 1392aor
PAGE 1
DESCRIPTION
14:25

CLIENT: RPS/CHELSEA
MONROE, NC
C/O GEORGE MAAL00F
DATE RECEIVED: 09/21/1993
DATE REPORTED: 10/06/1993
S.C. LABORATORY IDENTIFICATION NUMBER - 23105
SAMPLE NH_ER
3953E
39537
39538
PARAMETER
VOLATILE ORGANICS, ,pg/L
BENZENE
BROMODICHLOROMETHANE
BROMOFORM
BROMOMETHHANE
CARBON TETRACHLORIDE
CHLOR©BENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
DIBROMOCHLOROMETHANE
1,1 DICHLOROETHANE
1,2 DIC'HLOR©ETHANE
1,1 DICHLOROETHENE
CIS-1,2-DICHLOROETHENE
TRANS-I,2-DICHLOROETHENE
1,2 DICHLOROPROPANE
CIS-1,3-DICHLOROPRO'PENE
TRANS-1,3-DICHLOROPROPENE
ETHYL BENZENE
METHYLENE CHLORIDE
1, 1, 2 , 2 TETRACHLOROETHANE
TETRACHLOROETHENE
TOLUENE
1,1,1 TRICHLOROETHANE
1,1,2 TRICHLOROETHANE
TRICHLOROETHENE
T'RICHLOROFLUOROMETHANE
VINYL CHLORIDE
ACETONE
XYLENE
HEXANE
*ESTIMATED VALtTE
CONTINUED ON PAGE 3
PAGE 2
SAMPLE DESCRIPTION
MW #2 GRAB ON 09/21/93 AT 14:25
RINSATE BLANK GRAB ON 09/21/93 AT
15:10
TRIP BLANK GRAB ON 09/21/93 AT 09:30
RESULT
3953 39537 39538
<50
<50
<50
<50
<50
<50
<50
2,400*
<50
<50
<50
<50
<50
530
<50
<50
<50
<50
64
290
<50
87,000
550
<50
<50
6,600
<50
<50
<50
330
<50
<5.0
<5.0
<5.0
<5.0
<5.©
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<10
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5. 0
<5.0
<5.0
<5.0
<5.0
<5.©
<5.0
<5.©
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<10
<5.0
<5.0

CLRRS/CNELREA
MONROE,
C/O GEORGE L U "
DATE F E EIVED: C/9/21/1993
DATEREPORTED: 10/0B/1993
PAGE 3
19 C. .,.ORATORY IDENT/PICAT 0N ER
S/kMPLE
39536
39537
39538
105
DESCRIPTION
2 09/21/93 AT 1 25
RINBATE E'GRAB ON 0 / 21 AT
1. :1 '3
TRIP BG ON 21 ' 3 AT 09:20
TY CO Rpr,�s
OGATE RECOVERY
39536 39536 353' 3953
09/2609/30
1 , 2 --,DICHLOROET D4 100 1.02 101
TOLUENE -D8 1431 108 103
105
-BROHOFLUORO B EN Z ENE 112 101
13 1
13
REPORTED Y

Client Name
Address
Attention
Telephone No,
R&C
Lab No,
Aa' tPLEi
elirvqushed by
S &
N
P r. ass,ren;tte
Phone (Bt31} 232-tSSb • FAX
FAX No.
Date Time Sample Station ID
at'cbd by
Date/Time
Shrp'sr' am tt
teceived by (Sig.)
Shipper Name & tt
Received by (Sig.)
ipper Name & a
CHAIN OF CUSTODY RECORD PAGE
Date/Time
Date/Time
d intact by
OF
Filtered (Yet/No)
Preserved (Code) I
rratraratwd (Yes/N©)
Semple type (C"arefCarnpasItaw�
le ecaurce (WWr GW, ow. a tt�arrs
Preservation Code:
A•None D•N.DH
8 HNO3 E - HCL
C- H.SO4 F
HAZARDS ASSOCIATED WITH SAMPLES
Total Cie
Client P.O. Number
Subsequent Analysis:
Date Resubmitted
mg/L Receipt pH